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The Post Office Horizon IT Inquiry
Monday, 4 November 2024
(10.00 am)
MR BLAKE: Good morning, sir.
SIR WYN WILLIAMS: Morning.
MR BLAKE: This morning we're going to hear from
Mr Recaldin.
SIR WYN WILLIAMS: Yes.
MR BLAKE: Thank you.
SIMON DOMINIC RECALDIN (affirmed)
Questioned by MR BLAKE
MR BLAKE: Thank you very much. Can you give your full name
please?
A. Simon Dominic Recaldin
Q. Thank you very much. Mr Recaldin, you appeared at the
Inquiry on 29 September last year, and you confirmed the
truth of three witness statements, that's your first
witness statement, second witness statement and third
witness statement. I'd just like to begin today by
briefly taking you through your fourth, fifth, sixth,
seventh and eighth witness statements. The fourth has
a URN of WITN09890400 and is dated 15 May 2024; the
fifth is WITNO9890500, dated 3 September 2024; the sixth
is WITN09890600, dated 4 September 2024; the seventh is
WITN09890700, dated 4 September 2024 as well; and the
eighth is WITN09890800, dated 16 October 2024.
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SEG as the "Senior Executive Group". With apologies, it
should have been the "Strategic Executive Group".
Finally, under the seventh witness statement, I refer to
"DBT" and this should have been defined as the
"Department for Business and Trade”. I hope those are
acceptable.
Q. Thank you very much. Subject to those, are those
statements true to the best of your knowledge and
belief?
A. They are.
Q. Thank you very much. Those witness statements, those
that haven't already been published, will be published
on the Inquiry's website shortly.
You are the Director of the Remediation Unit, which
was previously known as the Historical Matters Business
Unit; is that correct?
A. Thatis correct.
Q._ You've been in that position since 10 January 2022. Can
you assist us with what you were doing prior to taking
up that role?
A. I worked for NatWest, then became Royal Bank of
Scotland, and then back to NatWest again for 33 years
doing a number of roles through junior management,
senior management and leadership within the Royal Bank
of Scotland.
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Do you have copies of all of those witness
statements in front of you?
Ido.
Can you confirm that your signature appears on all of
those statements?
Ian.
Can you also confirm that those statements are true to
the best of your knowledge and belief?
They are. There are a couple of amendments that I would
like to go through, if that’s okay.
Thank you very much. Yes, please do take us through
those amendments?
So in the sixth witness statement if I - if t's of
help to the Inquiry, there's couple of acronyms which
are incorrect. The first one in the Rule 9(56), sixth
witness statement, is I referred to SEG as the "Senior
Executive Group". With apologies, that should have been
the "Strategic Executive Group". In the same statement
I referred to "DBT" and this should have been defined as
“the Department for Business and Trade". Thirdly,
refer to "DRP", and that should have been defined as
the "Dispute Resolution Procedure". Finally in this
witness statement, I refer to "DRT", and that should
have been defined as the "Dispute Resolution Team"
In my seventh witness statement, again, I refer to
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Thank you very much. Towards the end of your time,
I think you've said that you were involved in
‘compensation schemes of some sort; is that correct?
Yeah, in my last years of financial crisis in 2008 I was
involved in two significant remediation programmes. One
was called Project Rosetta, which was the investigating
the alleged misselling of sophisticated financial
products, such as swaps and collars and caps, and we had
to investigate 13,500 trades to understand whether they
were missold and, if they were, then we'd have had to
‘compensate the clients accordingly.
And the second programme was called Project
Sapphire, and that was — actually came from
a Government report, the Tomlinson Report, when the
Royal Bank of Scotland was accused of deliberately
taking businesses to the wall in order to free up their
capital and effectively make companies go bust to free
up the capital and we were charged with investigating
those allegations and compensating accordingly. I was
the Operations Director in both of those programmes.
Thank you very much. I would like to look at the work
of your team and your unit. Can we please bring up onto
screen POLO0460645. You have produced a slide
addressing the various schemes that are currently
running. That will come on the screen at the moment.
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We see there at the top the Remediation Unit and
you've set out those schemes that are directly run by
your unit and those that are run by the Department for
Business and Trade; is that correct?
That is correct.
We see there on the left-hand side the Horizon Shortfall
Scheme. That relates to those who were not on the part
of the Group Litigation but who have been impacted by
matters relating to the Horizon shortfalls?
Correct.
We then have the "Overturned Convictions". I don't
think it’s called a scheme: it's just overturned
convictions redress; is that correct?
Yes.
It provides redress for those whose Horizon related
convictions have been overturned by the courts?
Correct.
You then have the "Suspension Remuneration Review".
That involves repayment to postmasters who were
suspended without pay; is that correct?
That is correct.
Can you assist us with why those post masters wouldn't be
able to claim under the Horizon Shortfall Scheme or how
that is different to the Horizon Shortfall Scheme?
They might be able to claim under the Horizon Shortfall
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detriment or potential detriment. That review of 19
products came down to ten, including an additional
category called "Other", and we confirmed that those ten
products might or do create detriment.
A good example of that would be a very bad training
manual that was issued to a postmaster that, had they
followed that training manual to the letter, they would
have suffered detriment and, therefore, that — it
should be redressed, and that is the scheme on the ~
that is set up to redress those issues around those ten
products.
Do those products relate to Horizon in some way?
No, they don't.
Thank you. Can you give us some other examples,
perhaps, just to assist us?
It might be a foreign exchange process; it might be
an ATM shortfall not related to Horizon
Thank you very much. Then there are two further schemes
under your section "Schemes run by [the Department for
Business and Trade]". The first is the GLO scheme,
that's those who were part of the Group Litigation; is
that correct?
That's correct.
Presumably your department or your unit is involved in
disclosure, perhaps making representations as well, in
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Scheme and, if they do, they get compensated
accordingly. There are others who do not have a claim
under Horizon Shortfall Scheme but were suspended and
therefore they are entitled to reimbursement of that pay
that they should have got when they were suspended.
If you are a subpostmaster who experienced a shortfall
but who was also suspended, do you have to complete two
separate forms for those two different schemes?
No. No, you'll get your compensation through — your
redress through the Horizon Shortfall Scheme.
Thank you. The "Suspension Remuneration Review"
therefore applies to those who didn't experience
a shortfall but were nevertheless suspended; is that
correct?
Yes, that's correct.
We then have the "[Post Office] Process Review". Can
you assist us with what that involves?
During our investigations for all schemes, a number of
allegations, issues, complaints were received around
a number of products and the use of those products
created what we call detriment. So we proactively did
a review of number of products where postmasters were
identifying problems with them, ie detriment, and we
investigated about 19 different products to understand
whether or not the use of those products created
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relation to ~
No, just disclosure. We have completed the disclosure
exercise required for the Department of Business and
Trade for the GLO cohort.
Thank you. Are you able to assist us with when that
disclosure was completed?
Itwas completed four weeks earlier than expected.
I think it was around June this year it was completed.
Then the HCRS, the Horizon Compensation Redress Scheme,
that is redress for those whose convictions have been
automatically overturned by the recent statute; is that
correct?
Correct.
Again, your Department provides information. What kind
of information —
Disclosure.
What kind of disclosure might be required for that
scheme?
Well, what we've done there, we've worked closely with
Government and legal advisers about what disclosures
they would require for these cases because many of these
cases, we understand -- because it's obviously run by
the Department of Business and Trade -- their
‘compensation may be limited to the £600,000 sum and,
therefore, the amount of disclosure to support those
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claims may be less ~ will be significantly less than
for claims of over £600,000.
So is it likely that, in relation to that scheme, it
will be £600,000 as of right, without requiring more
proof than simply that you were convicted?
Well, my understanding is that if the claim is ~ if the
claimant is, and their legal advisers are comfortable
with an offer of £600,000, then limited disclosure, if
any disclosure is required to support that.
Thank you. Your teams work also involves other areas.
It involves the Criminal Appeals Review Process; is that
correct?
Correct.
What is your involvement in that, briefly?
Ihave ultimate oversight of it. The work is part of
the Remediation Unit.
Is that providing, for example, disclosure to the courts
or the Crown Prosecution Service or others?
Via our legal advisers, yes.
Thank you. Also, I think your team is also involved in
related civil liability; is that correct?
Correct.
Is that individuals who bring claims against the Post
Office outside of those schemes but relating to Horizon,
or more broadly?
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a committee that oversees cases where we look at options
available to us to resolve cases which might be going —
as it says in the statement, that might be going to
mediation
Thank you:
“Monthly, previously fortnightly, [Remediation
Committee] meetings.”
At (g) wider Post Office governance committees
including the weekly Strategic Executive Group meetings.
Do you feel that you have sufficient time for all of
those and all of the other work that you carry out in
your unit?
No.
Can you assist us with that, please?
There's alot on. There's a lot to do. This is the
biggest miscarriage of justice ever in UK history, that
creates a lot of work, and I do spend a lot of time,
appropriately, in my view, in governance forums because
use those to make decisions and guide my business
through extremely troubled times.
Do you feel you have sufficient support, sufficient
staff, sufficient deputies?
Yes.
How long do you feel you have had sufficient support
for: throughout your period?
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Nothing outside these schemes, and nothing outside
Horizon —- it won't be dealt with by my team.
Thank you. Paragraph 140 of your sixth statement, you
have outlined various meetings that you're involved in.
Perhaps we can bring that on screen. It's your sixth
statement, WITNO9890600. It's page 42. Thank you. At
page 42, paragraph 140, you've set out various other
meetings and boards that you are a member of.
Yeah.
We have there little in (a):
"Monthly monitoring meetings with [the Department
for Business and Trade] to formally oversee the
[Historic Shortfall Scheme], discuss performance and any
outstanding matters, risks and issues."
We have the Horizon Redress Programme Board, the
HMC, what's the HMC?
Horizon Management Committee.
Horizon Management Committee or Horizon Matters
Committee?
Sorry, Horizon Matters Committee, thank you
If we scroll down to (d), you chair two further
subcommittees of the HMC. If we could carry on, please,
the HSS DRP Decision Committee, can you assist us with
what that is?
That's the Dispute Resolution Process, that's
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Oh, in terms of sufficient support and the team around
me, yes, I feel I've had adequate support for some time.
In her witness statement, and we've heard in oral
evidence, Karen McEwan commented that the sheer volume
of information and number of compensation schemes, and
their complexity, made it difficult for you to explain
to her all the relevant information. Is that something
you agree with or disagree with?
Can you repeat that, please?
The sheer volume of information and the number of
‘compensation schemes and their complexity made it
difficult for you to explain to her all the relevant
information in her original briefing.
I apologise if that has come across that way and
I didn't realise that that — I hadn't explained it
clearly enough to her. I think ~ by their very nature
I think these are complicated. I think they are the
right thing for the postmaster, having said that. My
experience would say they're not ~- from my experience
of other remediation schemes, complexity is what they
bring and, in order to ensure fair and reasonable
outcomes in a timely fashion to postmasters, sometimes
they will be complex.
Before we tum to the specific schemes, I want to ask
you some broad questions about the administration of
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those schemes and some themes that have come up
recently, before we took the break, in respect of their
administration.
Yeah.
First of all, has it been the few of the organisation
throughout your involvement, that the schemes should not
be administered by the Post Office?
No, it has not been. I have a view, and I'm conscious
of the evidence that Mr Read gave as well ~ which I, by
the way, conform to -- is when I was first interviewed
for this role, which would have been in 2021, back end
of 2021, I was interviewed for the role to head up what
was then called the Compensation Schemes and now Redress
Schemes, and I made it very clear to the interview panel
that, traditionally — whatever traditionally means —
that you wouldn't run a remediation scheme this way.
Iwas asked how you would run it and I was clear,
being the interview, that it would be completely
independent of Post Office. It would probably be part
of reporting to Government but there would be a way that
you could separate it and there was a danger of conflict
of interests, and it has to be separate from the Post
Office because you're judge, jury, prosecution, witness,
et cetera.
And the feedback I got directly from the Chief
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the Government will be extremely supportive, and provide
the important funding, and all the governance and all
the structure required in order for any redress schemes
to be a success’,
The Inquiry held compensation hearings dating back to
July 2022, April 2023. In your view, was that the
articulated position of the Post Office?
Apologies, what was the articulated position?
Was the articulated position of the Post Office that it
would have been better for the Department for Business
and Trade to be administering and running those
compensation schemes?
The articulated position of the Post Office was clearly
embedded in the signed documentation under the
operational agreement that this is how these schemes
would be run.
Do you think that a picture was or was not given that
the Post Office would prefer not to be administering
those schemes?
Ihave seen evidence that it's clear that Post Office
made their position clear to the Minister at the time
that they — the Post Office viewed it would be better
and more -- more independent, although it is
independent -- it will be clearer and have more
transparency if Government were to operate the redress
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Executive was that they sort of had been down that route
and had been -- had a clear direction from Government
that there was a degree of accountability here in that
the Post Office had committed these dreadful things —
and, by the way, some dreadful things have been done --
and, therefore, it was sort of feet to the fire time,
and you did it, you fix it.
can go on further, and so, you know, I think it's
very clear, also from the operational agreement between
the Government and Post Office about how we operate the
schemes, I think clauses 5 and 6, is very clear as well
about -- that Post Office will be doing this, and Post
Office signed up to that operational agreement. So from
that point, the die was set and there was probably
litle point in pushing against that because the
agreement had been settled.
What was the view of Mr Read as communicated to you
about the appropriateness of the Post Office carrying
out those schemes themselves or administering the
schemes themselves?
Mr Read made it quite clear that he agreed with my point
and that he had said he had pressed Government on this
but had the response, "It's sort of feet to the fire
time, and you're accountable and therefore we are
looking to you to deliver the solution. But, obviously,
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schemes.
That's the articulated position to the Minister.
Yeah.
You've been present at compensation hearings in this
room. Do you think that that message has been
articulated to the Chair?
To Sir Wyn?
Yes.
In those compensation hearings, I don't think so.
Do you know a reason for that?
I think the reason for that, as I've said, and as say in
my statement, I think it's because the operational
agreement made it clear — which Post Office signed up
to ~- that the Post Office would be at administrating
and carrying out the redress schemes. That was
a commitment that they made. I have been in ~ the
Select Committee in February asked me this question as
well. They asked me -- they made the statement that, in
their view, the redress schemes operated by Post Office
should be controlled by the Government.
I think the notes will show that I agreed with that,
and the Minister at the time was in the room, and
I know, subsequent to that meeting, we had a ministers
meeting literally the next week when myself and
officials from the Department were mandated to go away
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and look at the opportunity and look at the possibility
of transferring the Post Office redress schemes into
Government.
What happened to that?
That was called ~- from a Post Office perspective, that
was called Project Green, and that's all documented, I'm
sure, in your evidence, you have seen some of that
articulation, and that was submitted to Government, it
would probably have been March/April this year and -- of
how we thought that could happen and, at the time, the
Government declined the opportunity to pursue that any
further.
Thank you. Has there been any change to that situation?
I think there has, yes.
To what extent and how?
In terms of there — over recent weeks, there has been
some further engagement on that from the Government.
Do you anticipate there will be a change to the
situation?
Well, you -- I think the Interim Chair was very clear
about his intentions, his wishes, in this space and
I know he has lobbied hard in Government around that, so
I do expect a change, yes.
Could we please bring up onto screen the witness
statement of Mr Staunton, it's WITN11410100. Thank you.
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getting it right in terms of the attitude to
subpostmasters?
No.
I'd like to take you to a couple more passages from his
witness statement, please. If we could turn to page 22.
Do you have any views as to the sentence that I've just
taken you to and your understanding of why Mr Staunton
may have said such a thing?
No. I had one conversation with that -- the past
Chairman
What was said in that conversation?
twas a meeting that I established to brief him up on
the redress schemes that the Post Office ran
Did he raise any concerns?
He raised a lot of interest but no concerns.
If we could please have a look at page 22, paragraph 41,
he says at the bottom of that page:
"My impression was that there seemed to be little
recognition within the Post Office's Remediation Team
that we were looking at an injustice on an industrial
scale and that lawyers (both internal and external) made
issues overly adversarial. That is why I suggested to
Mr Read while I was chairman that the process be taken
out of Post Office's hands ...”
Ill take you to one more passage, 45(a), that's at
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If we could turn, please, to page 7, it's paragraph 14
I'd like to take you to. Mr Staunton's written
evidence, and reflected in his oral evidence, was as
follows, he says a few sentences down:
“As an outsider coming into the organisation (with
no prior experience of managing a company involved in
the prosecution of criminal offences), it seemed obvious
that exoneration was something that required proactive
consideration. But it became clear early on, that this
was not on the agenda. Instead, there were three
complex schemes for redress which only helped those
whose convictions had already been overturned or who had
not been convicted but nonetheless lost money (for
‘example by ploughing their own savings into the losses
wrongly calculated by the Horizon System). These were
administered, it seemed to me, in a bureaucratic and
unsympathetic way (particularly in relation to
overturned convictions), as evidenced by some of the
‘examples given elsewhere in this document."
Was that a view that Mr Staunton communicated to you
at all: that the schemes were administered in
a bureaucratic and unsympathetic way?
No.
Did Mr Staunton have a conversation with you at all
where he was concemed that the Post Office wasn't
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page 24. He says there:
“At my first Board meeting on 6 December 2022, there
was a discussion regarding postmaster repayments for
unreconciled losses. We were told there were some 77
postmasters who were currently repaying unreconciled
balances, despite advice that continuing to accept
repayment where cases had not been investigated was
a breach of an implied term in postmasters' contracts.
There was a concem from the Remediation Team that if we
notified postmasters and requested they pause payments,
we might be ‘inadvertently stimulating claims against
an unfunded position’. The Board rightly felt that we
should do what was right and pause repayments, but the
fact that this was brought up at all indicated to me.
that the culture of the Remediation Team was to try to
minimise claims."
Again, were those concerns that were brought to you
at all by Mr Staunton or anyone acting on his behalf?
Absolutely not, no. It seems to me that the phrase
“inadvertently stimulating claims against an unfunded
position", that is a risk that should be articulated in
a number of different governance documents. So to your
question, no, that wasn't -- Mr Staunton didn't talk to
me about that.
Thank you. Can we please turn to POL00155397. What was
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your relationship like with Mr Staunton?
Excellent.
If we scroll down, please, this is an email that the
Inquiry has already seen and I'm sure you will have
looked at it, it pre-dates your time at the Post Office,
and it's an email from Mark Underwood. The subject
matter is "GLO Post Settlement [Group Executive] Paper’.
We see there at the bottom of that page, so if we scroll
down slightly, the section on "Fees’, it's, as I say,
something we've already looked at. He says there:
"My strong view is that you cannot seek payment from
applicants -- however small and regardless of the
rationale behind it. Optically this would be extremely
challenging and would be in 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 through having a very tight and clearly
communicated set of eligibility criteria and
requirements in terms of the documentation applicants
have to provide in order to be accepted into the
scheme."
You weren't there at the time but did you in any way
have the impression when you joined that the schemes
were set up to be intentionally bureaucratic?
No.
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if the interpretation of that is confusing matters and
elongating processes, I have to say, Herbert Smith
helped design the process, and it's a very difficult
process design to ensure full and fair redress in
a timely way. So I think they were helping Post Office
So I think that's probably a bit unfair and, of course,
all legal advisers have to be instructed, and they are
instructed by the client, in this case the client is
Post Office. So I don't recognise fingers in the pie
I won't bring it up on to screen but, just for the
purpose of the transcript, that document is POLO0293169.
How about Herbert Smith's involvement more broadly,
given that they represented the Post Office in the Group
Litigation towards the later stages; to what extent do
you feel it was appropriate or inappropriate for them to
design, for example, the HSS, Historic Shortfall Scheme?
So it was — their appointment was well before my
appointment so I didn’t ~ I wouldn't have had a say in
that, and they are esteemed professionals in what they
do, they've got a track record of being able to do ~
build remediation schemes. I have no further comment
than that.
Thank you. That document can come down, thank you. I'd
like to move on to the topic of taxpayers’ money, value
for money, and the Department for Business and Trade's
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Do you have a view as to what is said there and whether,
in some way, the eligibility criteria and requirements
were too narrow?
Ive a very strong view.
What is your view?
It's outrageous.
What's outrageous?
To deliberately design, allegedly -- design eligibility
criteria that would be restrictive, I think that’s — in
terms of remediation, you just don't go there, you don't
do that.
Having seen what you've seen over the number of years
you've been involved, do you have a view as to whether
that plan was, in fact, the rationale or something that
was actually put in place?
In terms of what is in place, I don't recognise that.
In terms of what was in place on your arrival or before
your arrival, do you recognise that at all?
No.
The Inquiry has also seen a document from 2020 where
Angela van den Bogerd suggests in 2020 that there were
too many fingers in the pie from Herbert Smith Freehills
and that that in some way delayed the process; do you
have a view on that at all?
I don't know what “fingers in the pie" means. I think,
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funding. That's a topic that cropped up quite a bit
before we took our break. Can we please bring up onto
screen POL00458427, and if we could start, please, on
page 2. This is an email chain discussing development
of the Inquiry's hearing on compensation, Thursday,
27 April. It's dated 30 April. If we look at the
bottom of that page, we can see there some views from
you. You say:
“Indeed in the appropriate spirit of
collaboration -- on the basis of ‘funds being no object’
within reason of course, I have asked that parties get
together online Tuesday to look at ... ways 32 weeks
could be brought down ...”
I think that's 32 weeks of disclosure in the GLO
scheme; is that correct?
That is correct.
*... and the associated risks for Post Office Board
would need to consider within and without appetite.
This includes the potential for recruiting even more
people."
At that bullet point you say:
“As briefly discussed with you both on Thursday, it
appears that less the contract being finalised between
us on GLO disclosure is signed up by Wednesday this
week, due to [the Department for Business'] identity
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change to DBT, this will be kicked down the road for
a considerable amount of time meaning Post Office will
have to work [I think that must be ‘at risk'] for
an unacceptable period of time."
We see the phrase "work at risk" in a number of
places. Does that describe a situation where the Post
Office is having to fund these schemes without knowing,
in fact, whether the Government will step in and be
funding them themselves?
In terms of the formality of the documentation, yes,
correct.
If we scroll, please, to the first page and the bottom
of the first page, we see there an email from Mr Read to
Lona Gratton and he says as follows, about halfway
through that email chain:
“I always refer to David Bickerton’s observation
that no one will be criticised for paying too much
compensation to postmasters ... however everyone will be
slaughtered if we continue to ‘nickel and dime’ on legal
fees, admin costs, compensation itself and a convoluted
and complex process ... see today's article in The
Times.
“I won't allow this to happen as my job is to
protect the brand, ensure timely compensation is paid
(and speedy justice delivered) and that trust in the
25
A\little further down, it says:
“The funding request went into [the Department for
Business] many months ago, has just been through DBT, is
with [Her Majesty's Treasury, His Majesty's Treasury],
is due an additional governance layer and expected to
emerge now July earliest - more likely September
earliest due to the usual nonsense of summer breaks etc.
“if you believe we should start communicating and
settling prior to funding being formalised, better
people than I can advise, but my understanding is that
is a call for {the Post Office] Board (clearly with
government representation) who are obliged to look after
the interests of Post Office to consider associated
risks including potentially wrongful trading as the
Board would have to be comfortable that any liability
would be covered by funding/support -- but you know
this, apologies.”
In terms of wrongful trading, was there a concern
within the Post Office that, because you hadn't secured
Government funding and were having to fund the schemes
yourself, there may be an allegation or even an offence
that's being committed by the Post Office?
Continually. For my entire tenure this has been
an issue about the potential for wrongful trading and,
therefore, as a commercial, separate legal entity, the
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Post Office is not completely eroded through this torrid
period.
“I hope we can work together on helping [the
Department for Business and Trade] break the mould and
understanding that managing public money is not simply
about limiting spend and reducing cost, it is also about
the effective and efficient use of funds. I fear they
are missing this vital ingredient.”
If we scroll up, we see a response from Mr Staunton.
He says there in the first paragraph:
“No corporate would allow this to fester as much,
which is why you are right to quote David Bickerton's
observation that managing public money is only one
ingredient of this exercise.”
Before I turn to a question, I'd just like to show
you one other email chain, and that's between you and
Mr Cameron. That can be found at POL00423920. It's the
second page ~ the bottom of the first page into the
second page, sorry. We see there an email from you to
Mr Cameron, 14 May last year. You say there:
“I get the urgency that we really do need to get on
with this as the clock is ticking, the judgment is
pushing 4 years and victims of detriment are not getting
younger. If it helps we are paying away in Detriment A
with some momentum."
26
Board have to act on behalf of Post Office and,
therefore, they have to be advised of the risks of
potential wrongful trading. Therefore, without formal
letters of comfort in place, as the lawyers would say,
then that is a risk that the Board will have to accept
and, because of the way the construct of the Board is,
there is potential personal liability there and that is.
why they have to be appropriately legally advised about
the risks of wrongful trading and the implications on
the Board and Post Office and then as individuals.
Thank you. If we scroll onto the first page, we see the
response from Mr Cameron. He says:
“In that context, our position on wrongful trading
has changed in the [business as usual] business. We are
delivering NBIT without sufficient funding and without
thinking we are wrongful trading because of HMG policy,
statement of intent, support letters etc. Personally
I cannot distinguish the position from our position on
remediation schemes."
So it seems there was also a concern about wrongful
trading in respect of the NBIT scheme?
Correct.
He says:
"Lam not saying therefore that we can rush off and
do whatever we like, simply that the position is less
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clear cut than we thought.
“But my main point is that the day after getting
funding or deciding we cannot wait, we should be ready
to progress all 14 workstreams as appropriate with the
postmaster community AND be asking for ‘any others’ at
the same time, so it is clear to everyone we are
pursuing justice with all the speed at our disposal. If
that's the plan, great. But I don't get the sense that
itis and honestly I think we will come a cropper.”
He says:
“That is the point I would make at the Board if I am
there or you would be kind to make on my behalf: no
criticism and no need to defend. Just speed for the
future. And if [His Majesty's Government] doesn't like
it, we need to have an argument."
Thank you. That can come down.
I'm going to take this in a number of parts. First
of all, to what extent, if any, has a focus on managing
public money or value for money slowed down or impacted
negatively on compensation: so the value for money or
the managing public money aspect?
Well, I think there's a danger of two issues being
conflated here. If I may answer that in maybe
a slightly different way, and if it doesn't, please come
back to me, is I don't think we should be confused about
29
is there a value for money debate challenging whether
that is an appropriate process; are there more efficient
ways of doing it; can you find cheaper lawyers ~- dare
I say that in this forum — et cetera; then that is
a consistent challenge.
Now, if that's a value for money debate, then.
I understand that. But it's not about the redress; it's
more around the processes established to release that
redress. I hope I'm making some sense.
Yes, I mean, we saw in that email from Nick Read, he
said, "We'll be slaughtered if we continue to ‘nickel
and dime’ on legal fees, admin costs,” and then he said
“compensation itself"?
Yes.
Is it your view that, when it comes to compensation
itself, there is or is not consideration of managing
public money, value for money, value for the taxpayer?
It's my strong view that there is not a value for money
debate around the amount of redress that is paid out.
In respect of the test that is applied when calculating
an amount to be given to an individual, is there any
consideration of that?
In terms of the independent panels, there is no
reference to that for a consideration at all, in their
determinations.
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the amount available for redress and the impact of value
for money on that, which, in an operational sense
I don't see any restrictions or value for money debate
around the amount of redress available for payment.
I want to make that clear. I know this is something
that Sir Wyn asked a question of a previous witness
about.
So in terms of the £1.4 billion provision available
for redress in the Post Office redress schemes, that is
sacrosanct and I don't recognise any value for money
debate around that and, certainly, the terms of
references for the independent panel in HSS and the
independent panel on the OC, there is no restriction in
there about amounts, or there's no debate about value
for money, there is nothing about this is taxpayers
funds at all; this is what is a fair and fulsome
response to this, in terms of the amount of redress. So
I don't recognise a value for money debate in redress.
Where I do recognise a value for money debate and
officials reminding me and my team on a regular basis
around we need to manage public money appropriately, and
there are plenty of Green Papers that say more about it
than I can, then that a consistent conversation with
Government with me and others, but that's more around
the process designed to release those redress funds: so
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I said we'll take it in stages. So that was the
managing public money aspect. To what extent, if any,
has the Department for Business and Trade’s delay in
authorising, or their bureaucracy, slowed down or
impacted negatively on compensation?
I don't know whether I can put a value on that. You
know, the Government have a process to follow in order
to release funds to make processes available, and the
process is the process, in that the DBT, Department for
Business and Trade, do not have oodles of cash, and nor
should they, waiting for Post Office to apply to fund
redress schemes.
They have a process they need to go through. They
need to see a business case to justify that spend. They
then need to analyse that, they need to understand that
and then they need to go to Treasury. They have their
‘own process, it's absolutely tried and tested.
My challenge around this has always been it's very
difficult to articulate a process that nobody has ever
done before. This is the biggest miscarriage of justice
ever and my frustration has been around the whole
process, and the Government know this, you've seen all
my emails, is that we're trying to squeeze a non-BAU
process in -- business as usual process into a business
as usual process and this breaks the mould.
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As I keep on saying, this is the biggest miscarriage
of justice ever and to be redistribution agreement by
a ~and there are good reasons for it, that I'm not
arguing against those ~ there are good reasons for it
to make sure it's fit and proper and set up
appropriately to understand that. But that can be
restrictive, and that process takes months. And, during
that process, quite understandably and reasonably, you
get lots of questions back around "Don't understand how
you get to that number. How do you justify that?
Please explain this’, and that's absolutely fine, you
have to look at your business case for that. But that
whole process -- the process takes its time, it takes
its time in terms of the process it needs to go through.
In that exchange with Mr Cameron, for example, where
you're discussing concems about wrongful trading,
concems about the delay in funding and those kinds of
matters, and that's 2023, the summer 2023, to what
extent have delays been built into the system because of
that process?
We never - you never build any delay into a system. To
be clear, what Mr Cameron is talking about is redress
schemes outside the terms of reference for the -- my
understanding is these are schemes non-Horizon related,
and they -- but they follow the same process in terms of
33
Apologies. I do, but I can't recall it.
Are you able to say anything in respect of the amount of
funds that has been recently announced as part of the
budget?
The — do you refer to the 1.8 billion?
Yes.
can only assume ~ and it is an assumption, please, it
is an assumption, I know nothing about it at all. All
I -- I know what my provision is. I know my provision
for the compensation scheme, the redress schemes that
I look are in Post Office, the four, I know the
provision for that is 1.4 billion
Is that going forward or is that taking into account
sums that have already been spent?
So I can help the Inquiry if it helps —
Yes.
~- there as well. So that is ~ that includes ~ so far
as of last week, across alll the schemes that I operate,
we have paid out in redress 302 million. We have now
a financial projection of what that figure is going to
look like going forward, and there is clear acceleration
in there. There has been acceleration and I'm happy to
share the numbers with the Inquiry -- there has been
acceleration over the last six months, significant
acceleration of those numbers -- and by March 2025 —
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getting funding. So you call it “delay”, that was your
word. I don't necessarily call it delay. I just say
that's the process, that's the time it takes. But did
it stop the launch of those programmes until that was in
place? Yes.
We heard suggestions from Mr Staunton about needing to
hobble up until after the next election, in terms of
‘compensation ~ the election that's recently happened.
Was that something that was ever been mentioned to you?
No.
From your experience, is that something that is likely
or unlikely to have happened?
If was asked to do it, I wouldn't be here.
So you were never asked to do it. Is it something that
is likely to have happened or not, in your view?
That would be speculation and I can't speculate. This
is a public inquiry. I can't speculate. I think it's
highly unlikely.
You have funding, I think you've said in your witness
statement, committed to 31 March 2026; is that correct?
Sorry, what is committed to 31 March?
Funding from the Government for the compensation
schemes. Do you ever a definitive period in which
funding ends or funding has been agreed to? What is the
current --
34
there are a few caveats of traction from postmasters,
et cetera ~ that 302 million will exceed 650 million by
March 2025. Then, in the financial year '25 to '26, we
anticipate paying a further 500 million redress.
So looking at the sums that have recently been promised,
do you think there is sufficient funding to cover all of
those schemes that we have been looking at already this,
morning?
Ido.
Thank you. II'd like to tum, then, to the Horizon
Shortfall Scheme, and I think we'll go probably beyond
the first break just focusing on the Horizon Shortfall
Scheme. It was previously known as the Historical
Shortfall Scheme. Can you assist us with why the name
changed and whose idea that was?
Itwas feedback and I apologise to all the postmasters
for it. It was feedback from Lord Arbuthnot, actually,
when I met him and Lord Beamish, and he reminded me that
the term “historical” was offensive to postmasters
because, as we know now, you know, this is very much
a live issue now and it's not historical at all. And.
he — with clear direction, he suggested that I go and
consider the word "historical" and we just took it out
of everywhere, and I apologise to the postmaster
population for it.
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Q_ Thank you. You've addressed this scheme in your sixth
witness statement in particular and I'll be taking you
to references within your sixth statement. It was
launched on 1 May 2020, following the Group Litigation
and the conclusion of that; is that correct?
A. Correct.
Q._ I'd like to look at the Inquiry’s YouGov survey, and
that can be found at EXPG0000007, and it's page 48 of
that report. If we scroll down, please, we see a chart
there, figure 35, "Perceptions of applying to the
Scheme". These were answers given on a base of 1,483,
current applicants or applicants to the Historical
Shortfall Scheme and you can see there, in terms of
understanding the scheme, there is a lot more red than
there is purple 47 per cent net hard, they found it hard
understanding the scheme. In terms of completing the
paperwork, again, a significant number who found it hard
completing the paperwork: 26 per cent there very hard.
What is your view about those figures?
A. Apologetic.
Q._ Do you understand them? Do they take you by surprise?
A. No, they don't take me by surprise and I do understand
them and that's why we have completely redesigned the
application form for the recent ~ with the mailout that
we've just started.
37
assignee, personal representative, attorney or deputy of
the person you are making an application on behalf of
“[Fourth] You must agree to be bound by the Terms of
Reference for the scheme ...
“[Fifth] Your application and time with Post Office
must not involve or relate to any criminal conviction(s)
"[Sixth] You must not have been part of the Group
Litigation against Post Office that settled in December
2019."
Can we please return to your sixth witness
statement, that's WITN09890600, and page 52.
Paragraph 159, you say at the top there:
"When compared to previous years, 2023-2024 has seen
an increase in the number of applications being deemed
ineligible, whilst the ... terms have been unchanged.”
We see that there in a chart, if we scroll down
slightly. So the increase, I think, that you're
referring to can be seen by that blue nine; is that
correct?
A. Yes.
Q._ The blue line there has increased significantly in
relation to non-represented applicants in 2024. Do you
know or do you have any view as to why that might be?
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Q. How recently has that taken place?
A. So that was a week and a half ago, we started -- well,
this is all about the -- sorry, this all about the
£75,000 fixed sum offer, and the last cohort of that
population that we have now started to mass mail, and we
started that a week and a half ago. And we are now
ramping up the numbers in terms of that mass mailout,
and we have been mailing 30,000 past and current
postmasters with the opportunity to apply for the HSS
scheme, if they have not already.
Is it your evidence that that the information in
relation to that scheme, and also the application form
itself, have been simplified?
Absolutely, and they're also available online as well.
I'd like to tum to eligibility for the HSS scheme.
That's addressed in eligibility criteria. Perhaps we
could bring those onto the screen, that’s POL00448027.
We have there the “Eligibility Criteria”. First
"You must have, or have previously had, a contract
directly with the Post Office
"[Second] Your application must relate to shortfalls
which arose in respect of previous versions of Horizon
“[Third] If you are making an application on behalf
of another person, you must be a legally appointed
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I mean, it says in my paragraph 159:
“The data itself does not provide a clear
explanation for this trend, [but] it is worth noting
that the 2020 mailing was targeted in nature and
intentionally excluded postmasters known to fall outside
the eligibility criteria.”
So the mailing in 2020 was a lot more focused on
people who we thought were eligible. Since then, it's
been a lot wider and, therefore, you would expect more
to be ineligible.
Because, I mean, for example, we had the ITV drama in
early 2024: might there be some relationship between the
number of ineligible claims there to have risen in early
20247
I'm very grateful for the TV drama to raise interest, so
the more volumes you get then the more likelihood there
are cases that are eligible. Yes, that's the logic.
Is that the likely explanation for that peak?
I wouldn't say that. The peak in activity, absolutely,
is a result of the ITV drama. But I can't ~ I'm not
going to speculate about whether that's the reason for
more ineligible applications.
If we could scroll down, please, we can see the time
that is taken. If we keep on scrolling on to the next
page, page 53, there's a table there that sets out the
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days from application to eligibility confirmed, split by
legally represented and complainant complexity. It
seems there, from 2020 we can see, for example, those
who were represented in complex cases in 2020,
eligibility decisions took somewhere between 450 and 500
days to determine. Can you assist us with why it took
so long?
The original focus would be on cases we could get
through more quickly because they were more complex
cases. We were conscious of time and because they were
complicated they took more time to assess -- and for
eligibility. Theyre more complex cases.
Does that simply reflect the fact that in 2020 there
were a large number of claims being filed?
All cases.
Applications being filed?
Yes.
Yes. We don't see that in 2024. Is it possible we
might see that in a slightly later chart or has that
issue now been taken care of?
We try and leam our lessons -- I hope this is clear to
the Inquiry -- and the lesson there was that we needed
the right resource in the right place, and that's what
we did: we put the right resource in the right place:
And therefore, I am hopeful that we continue with that
41
-- anything to do with the level of compensation.
No.
So can you assist us with why it might take longer to
process just simply the question of eligibility?
No, I can't.
If we look at the paragraph below, you say:
“Of the 3,427 applications that [have been]
completed Eligibility assessment on 31 May 2024, there
are 3,194 (93%) confirmed as Eligible and passed to the
next stage to the process.”
If we scroll up and see that chart again, so you
have a 93 per cent current success rate in terms of
eligibility. Is that likely also to have been the case
earlier on and, if so, was there something going wrong
that it took so many days to process applications that
have such a high rate of eligible applications?
They took a long time to get through eligibility because
the scheme hadn't started. Because, although the scheme
opened in May 2020, of course, we didn't have funding in
place, and the scheme didn't actually operate until
after funding came in. So the clock will be ticking.
So those checks would probably have not started
happening until funding was put in place, which I think
was March 2021.
But even in 2022, we see ~
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modelling going forward and, therefore, we will have
a better process, a more efficient process going
forward.
We have to take into account the expectation in the
HSS is that in a significant portion of new claims
coming in, following the mass mailing and following the
exercises we go through at the moment, a huge proportion
of those will be under 75,000 and there is a completely
different quasi-automated process around that, which
will make the eligibility check and the payout a lot
quicker.
Can you assist us with why it might be that eligibility
decisions on represented applicants seem to take longer
than for those who are not represented.
I don't know.
I mean, in 2020 and 2022, in particular, very
significant differences between those who are not
represented and represented; can you give us any idea as
to why that might be?
I would be speculating and I'm not here to speculate.
I think the legal advisers do a very good job in terms
of ensuring that their clients apply for the appropriate
levels of compensation.
But eligibility doesn't have --
Yes, eligibility —
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Yes.
~ those two cases, those two charts, bars, that are
between 250 and 300 days just to confirm eligibility.
Ifyou have such a high rate that are confirmed as
eligible, why is it taking so long or why was it taking
0 long to confirm eligibility?
That would have been the result simply of volumes going
through.
Of what, sorry?
Of volumes going through at the time.
But I think we saw that the PEAKs in volumes, or we will
see, were quite early on and then again in 2024.
I don't think 2022, for example, was a particularly busy
year in terms of applications, was it?
No, but we were still dealing with the original cohort
of 2,500 that came in so they had to go down through the
process. So in — given the funding was not in place
until March 2021, the scheme wasn't properly productive
until the end of 2021. 2022 was the ~ effectively the
year when most of the work was done and, if you look at
the targeting that we delivered in 2022, you can see
when the offers went out, and 94.5 per cent of those
offers were actually issued by the end of 2022.
Thank you. If we look at 2024, on this chart we can see
that the average days from application to eligible, it's
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over 50 days waiting for an eligibility decision. If we
see below, it says that 93 per cent confirmed as
eligible. Might it not be easier, or possible to design
a quicker system, given the high volume or high
percentage that are or confirmed as eligible?
If, overwhelmingly, most are eligible, why must it
take over 50 days to confirm that eligibility?
don't think you can link the two. We are required,
for funding purposes, to ensure they are eligible, so we
have to go through a check. If the challenge is more
around why does it take 50 days and can't you do it
quicker, that is a fair challenge.
Yes, and what do you say to that challenge and how can
that be overcome?
And in -- we have ~ as I said earlier, we have
completely redesigned the process for the vast majority
or anticipation of the vast majority of claims of under
75,000, and the eligibility is a very ~ very much
slicker and quicker process and it will not take that
amount of time
If we could bring up on to screen your eighth witness
statement?
‘SIR WYN WILLIAMS: Before we do that, Mr Blake -- this is
POP
p>erop
QP
just me being curious, if you like, Mr Recaldin -- but
in the year 2021, there appears to be no represented
45
writing this witness statement, you had 373 applications
determined as ineligible, I think that has now risen to
397; is that correct?
If that's the number I've submitted, yes.
I will take you to the new chart shortly?
Yes, if that's the number I've submitted, then that's
fine, yes.
Yes. You've said in this statement or in the other
statement that you can't say how many have challenged
that decision; is that correct?
Correct.
Are you able to give us an indication as to how many,
whether it's a handful, tens, hundreds, or something
else?
Handfuls. If any. I'm not aware of any. If there are,
I would be made aware, and I'm not aware of many, but
maybe a handful. No more than that.
So there are some that you are aware of -
Yes.
-- who have challenged that decision?
Correct.
Can you assist us with whether some of all of those were
subsequently determined to be eligible?
I think all of them were.
In terms of legal representation, were all of those
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looking at, which seems a little odd to me.
A. I think, if I may, Sir Wyn, I think that might be down
to the fact that we weren't taking any new ones in.
Until it was confirmed that we were allowed to take in
late applications, we effectively had the original
cohort of 2,400 there waiting to be processed. They
were submitted in 2020. 2021 was a year of building the
scheme and getting funding in place, agreeing the
principles and going through the governance. So,
effectively, I could understand why no applications
would be -- no represented would have been submitted
during that period.
MR BLAKE: It looks as though at least some were --
A. Yes, some were ~
Q —butnot -
A. — but not represented ones, yes, which is Sir Wyn's,
point.
SIR WYN WILLIAMS: Yes, all right. Fine. I'll have to keep
my curiosity in abeyance for a little while.
MR BLAKE: Could we please bring up on to screen your eighth
witness statement WITNO9890800. If we could go to the
chart, please, on page 4. Thank you. That sets out the
number of applications that have been determined as
eligible and ineligible. At the point at the time of
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cases involving individuals who were legally
represented?
A. don't know but I don't think any of them were legally
represented.
Q. Can you assist us with what might have changed the
situation regarding their eligibility: was it about
provision of more information or something else?
A. Yeah, correct. They would have been asked for more
information, they clarified a piece of information.
Q. Thank you. One question is about branch assistants and
branch managers. Why aren't they included? Why are
they ineligible for the Historic Shortfall Scheme?
A. Because they're not funded, because they're not included
in the funding arrangements for Government
Q._ I'd like to take you to a number of documents addressing
this but, when you say they're not funded, what is their
redress?
A. So they ~- they didn't have a direct, my understanding
is they did not have a direct contract with Post Office
and, therefore, that excludes them from the HSS scheme.
Now, I can only -- my understanding of how things may
happen, and of what I've seen happen, is that, if
an assistant of a postmaster suffered a shortfall and,
as a result of that, maybe dipped into their own savings
or whatever they did in order to satisfy that but kept
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the postmaster aware, but ~ and the postmaster was
clear that that's what the assistant had to do, then.
they are — that individual is still — is not eligible
to apply but the postmaster has applied, effectively, on
their behalf and we have managed to resolve it that way.
But from a formality of the scheme, those assistants are
not eligible.
Can you see a problem with that?
Yes.
What do you see as the problem with that?
So I can see there are potentially assistants or
postmasters who may have suffered, may have been forced,
in a way, to make good, and are still out of pocket,
effectively
Can you also see an issue for subpostmasters in that
respect, that, having received redress, they might
themselves become the subject of litigation by those who
worked for them --
tam -
~ if the only route of claim is via the subpostmaster.
Yes, I am aware of that but I'm only ~ of that risk,
but I'm only aware of two cases where that has actually
happened.
What has happened in those cases?
They've ~ they have both been resolved satisfactorily
49
discussing, but we'll start with UKGI00031750. This is
correspondence from September 2020, from Melanie
Corfield.
between the Post Office and the Department for Business,
If we scroll down, there's an exchange
and she says as follows:
“I have not yet heard back from [I think that's
Herbert Smith Freehills] but essentially it is only
those with contracts with the Post Office who could
potentially be held liable by the Post Office, not those
they employed."
That is the justification for that limit. It says:
“Background: The scheme was open to people/companies
who had or have a direct contract with the Post Office,
including multiples. It is only people with such
contracts who would potentially have been held liable by
Post Office for shortfalls. Assistants of postmasters,
or employees of other companies who had no contract with
Post Office would not therefore be eligible, ie they had
no liability to Post Office. Claims in the scheme will
be assessed by the Independent Advisory Panel using
information available and in accordance with recognised
legal principles
“Line to take: postmasters and companies who had or
have a direct contract with Post Office, and therefore
could have been held liable for shortfalls, were
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directly with the postmaster.
Can you see a potential significant issue, therefore,
for those subpostmasters who had assistants and managers
who themselves were out of pocket and who can't claim
under the Historic Shortfall Scheme or, it seems, any
other scheme?
Ihave empathy and sympathy with that, and I can only
assume that those considerations were made when the
scheme was established.
Have there been efforts on behalf of the Post Office to
try to change that situation?
There has been representations to the Government around
that and I know that is something the Government are
considering and have considered in the past.
They've -- well, we'll go through the emails, or some of
the emails. Has it been explicitly rejected in the past
by Government?
Yes.
‘And how much confidence do you have that that situation
will change?
Ooh, um, I know it is under consideration now.
Government officials have advised me that it's under
consideration by the Minister.
I'll take you then quickly then through these documents
because they may simply say what we've just been
50
eligible for the scheme — multiples were included and
could apply. Claims can include consequential loss.
Employees of other organisations with no direct contract
with Post Office would have had no liability to Post
Office and would need to resolve any issues they had
with their employer."
It's that final sentence, really, that seems to
suggest that, if a manager or an assistant of
a postmaster suffered detriment as a result of
shortfalls from Horizon, they would have to take that up
with the subpostmaster themselves; is that correct?
That is. Would you mind just paging down because
I don't want — there are two issues potentially that
could be conflated here
Absolutely.
You're absolutely right in that, but I think this email
may be about what we call strategic partners - and
sorry for the additional jargon -- where we have
strategic partners who have a — run a number of post
offices.
Yes, and that's something that I'll come to shortly.
‘Okay, okay.
If we stick at the moment with just managers and
assistants, perhaps we could tum, please, to
BEIS0001093. Can you assist us with what this is, the
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“Quarterly Monitoring Meeting"?
It is what itis.
Who does that involve: that's between the Department for
Business and the Post Office?
Yes, of course I can. This is an extremely important
meeting, quarterly, as it says, that was between the
Post Office and Government. It's chaired by Government,
by POL — Department of Business and Trade, and it's the
sort of formal Government overview, a shareholder
overview, of the Post Office activity during that
quarter.
Thank you. This one took place on 7 September last
year. If we please turn to page 4, "SR", I think, is
a reference to you, and it says:
“SR also highlighted that [Post Office] had received
the first claim where a postmaster had waived their
right to claim and assigned this to an assistant. [You]
explained that a paper was due to go to HMC...”
Is that HMC; can you assist us with HMC and the
acronym there?
Horizon Matters Committee. The one I chair. Horizon
Matters Committee.
Thank you!
"... on this issue as it would mean a change in the
terms of reference, and eligibility criteria."
53
was consideration given to changing the eligibility
criteria in some way but there has been no change —
Correct.
-- and, if so, can you assist us with why there has not
been a change?
The ~ just the eligibility criteria hasn't been changed
since it was originally established. The process of
determining eligibility has become more efficient and
will become more efficient, but the eligibility criteria
have not changed
If you were a manager or an assistant, how would you
know what your rights were or how to make a claim for
the detriment that you have suffered?
Well, you would seek -- you could seek legal advice.
You could go to the website to understand whether or not
you will be eligible and, from there, you will see that
you were not eligible —
Yes.
because you do not have a direct contract with the
Post Office.
So how would you go about getting redress for a serious
matter that has affected your life? Perhaps you lost
your job, perhaps you lost your savings, perhaps you had
to fill the till with your own money because there were
shortfalls: how would you, as an assistant or manager,
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Can you assist us: was there a change to the terms
of reference and eligibility eligible criteria?
My recollection is there was not.
Can you recall this case at all or any like them where
a postmaster was able to assign their claim to
an assistant?
I cannot.
Could we please tun to POLO0448861. We're now in March
2024, and this is a Board meeting and a Board report.
Thank you very much. If we could please turn to
page 43. Actually, if we tum to page 31 first, you can
just see that it's a Board report.
It should be 31. If we perhaps go over the page,
there we go, there's the Board report, that's where it
begins. I'd like to ask you about paragraph 83, that's
at page 43. It says there:
“Late applications continue to come in, coupled with
enquiries about the HSS from current and former
postmasters, branch employees and strategic partners.
For now, {the Post Office] continues to decline HSS
applications from assistants/employees since the HSS
eligibility criteria requires applicants to have held
a direct contract with [the Post Office].”
So are we right to understand from those documents
that we've just seen that in September last year, there
54
go about claiming any redress?
So you -- I would go and speak to the postmaster, who
ultimately ran that, and understand the situation from
their perspective. That's what — and I might go and
get legal advice.
Do you think it's fair to put that burden on the
postmaster who may themselves have suffered shortfalls,
whose lives may have been impacted?
The point is, yes, clearly, but they didn't have
a contract with the Post Office, and the scheme is
designed —- it's clear — that the eligibility criteria
is that they had to have a contract with the Post,
Office. Their contract was with the postmaster.
Can I just clarify, when you said "yes, clearly", do you
mean ~
Ihave empathy to the situation that - and I completely
understand it and have empathy to that
Going forwards, having discussed that today, do you
think you would press for a change, or not, to the
eligibility criteria, or for some other form of redress?
Ultimately, that's a decision for the Government to
make. The Government provide the funding for the
scheme.
But as somebody who is head of the unit that runs some
of the schemes, for somebody who liaises with Government
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as to funding, what is your position, and what would be
your communication to the Government about those
employees and those managers?
My position is completely understandable —
understanding of the position those postmasters’
assistants find themselves in. I believe it's my -- my
personal view is that I need to understand the risks
associated with being able to open up that scheme wider,
in order to incorporate the significant number of people
that might come in as a result of that. And some of
them may have already been satisfied and some of them
may not have been.
‘And my ~ I think I've made it pretty clear to
Government what my view is and I think that's one of the
reasons -- not my view but I think these considerations,
it's exactly what the Minister is currently considering.
I think you've said already in terms of the new funds
that have been allocated that they will be sufficient.
Do you have a view as to whether they will be sufficient
if the schemes involved employees and managers?
So forgive me, I didn't say they were new funds. They
have always been in existence those funds.
The funds that were committed as part of the recent
budget?
Correct, and my understanding, if the scheme was opened
57
in any of your forms that they're able to claim in
respect of redress for their managers or assistants?
I don't believe they are.
We've seen that 397 applications have been deemed to be
ineligible. Can you assist us at all with the kind of
proportion that might involve either, on the one hand,
the employees and managers, or, as you've said, the
multiples?
No, I can't. I can't. I haven't got that split,
apologies.
Is it rare; is it common; more than halfless than half
that are ruled ineligible because they fall within this
category of not having a direct contract?
I really don't know.
Okay. As you said, another issue, and separate issue,
is issues that have been raised concerning multiples -
Yes.
-- or those who have had licences with somewhere like
Costcutter or McColl's. Is that a correct understanding
of that issue?
We call them strategic partners.
Yes.
Examples are McColls, WHSmiths, Co-op, et cetera, and
they have separate arrangements with Post Office.
They also fall outside the scheme; is that correct?
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up to assistants and people without contracts directly
with Post Office, a significantly larger provision would
be required.
Larger than has already been promised?
Correct. Not promised: that provision has been
delivered.
Thank you. So the announcement in the recent budget,
that amount has already been delivered?
So I had known that that funding for redress payments
has been available for some time, and it changes as our
modelling changes. As we get more experienced with the
schemes, we can anticipate with greater accuracy what
those redress payments are going to look like across all
four schemes. And we engage with Government
continuously on those projections and, therefore, they
adjust provisions, et cetera — along with the Finance
Team, adjust accordingly.
So forgive me, I don't want the Inquiry to be under
the impression that the £1 4 billion has any just
materialised. This has been number that was growing and
established some time ago, well before I came to Post
Office. So the recognition of that redress has been in
place many, many years.
Thank you.
Are subpostmasters told in any of your guidance or
58
No, they don't. So --
If you were an individual store that had a licence from
one of those organisations, they would fall outside the
scheme; is that right?
So my understanding of the scheme — and McColl's is
a great example ~ is that we do accept applications
from the strategic partner who coordinate the claims
from all the branches that they ~ the Post Office
branches they look after and, therefore, we get one
application in and that is considered in the scheme.
Have those applications come in; are you aware of those
applications being built up, as we speak; or what is the
current position?
So when the scheme was first launched, I know we had two
strategic partners who came in, and my understanding is,
that those two -- they have been resolved through the
HSS mechanism, through the scheme. I now understand one
other significant strategic partner is currently
engaging with Post Office around a potential claim they
have.
There are others who operated through corporate vehicles
who may not personally have a contractual relationship
with the Post Office. Are you aware of an issue arising
in relation to those circumstances?
No, if they're a corporate identity that might look
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after 10 or 15 branches, they can apply as their
corporate identity, and it's the same way with
partnerships as well.
What if there was, for example, a company that was the
corporate vehicle for running the Post Office but has
now been dissolved or went bankrupt, for example,
doesn't exist any more; is that possible?
Yes.
How about family members? Can they either claim in
their own right or on behalf of their own family members
and, if not, why not?
They're not eligible because they haven't got the direct
contract in terms of family members but, in the case of
an estate, for example, then they can apply on behalf -
for the estate.
If, for example, an applicant or somebody who wanted to
apply but couldn't because of, say, dementia or simply
because they didn't want to apply themselves on their
own behalf, is there a possibility that their family
members can pursue it on their behalf?
Providing the appropriate Powers of Attomey, et cetera,
are in place, absolutely, yeah,
We've heard about current issues with the Horizon
system, we've seen the results of our own survey in
relation to those who still experience discrepancies,
61
You —
Excuse me, no.
Can you approximate, in your view, what kind of ballpark
are we talking about?
All I can — not speculate ~ all I can say is that you
logically look at the post office, you look at the
postmaster and then you look at the numbers of people
they may employ to support them in that post office, and
you look at that across the country, across 11,500
branches and you do the maths, and that would be
a considerable population.
Have there been discussions between the Post Office and
the Department for Business and Trade or the Treasury
about that potential?
I think there have, yes. But I don’t think we've put
a number of potential redress on that.
In terms of likelihood of there being some sort of
change, is it likely or unlikely?
You would need to talk to the Government about that,
this is very much in the Government's hands.
How recently were those discussions with Government?
My understanding that those considerations were being
held at ministerial level a few weeks ago.
Thank you. Moving on from eligibility, providing that
you meet the eligibility criteria, you're given the
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unexplained shortfalls, on the current Horizon system,
we saw the Terms of Reference there and the eligibility
criteria are based on the old systems. Now, is there
any plan to put in place some sort of scheme addressing
current issues with Horizon?
‘A. That is under consideration as we speak, yes.
MR BLAKE: Thank you very much.
Sir, that might be an appropriate moment to take our
morning break.
SIR WYN WILLIAMS: Yes, by all means, yes.
MR BLAKE: Can we come back at, let's say, 11.47?
SIR WYN WILLIAMS: I think we can extend to then, Mr Blake.
MRBLAKE: Thank you very much.
SIR WYN WILLIAMS: All right, fine.
(11.35 am)
(Ashort break)
(11.50 am)
MRBLAKE: Thank you, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes.
MR BLAKE: Mr Recaldin, before we left off we were
discussing potentially extending the schemes to managers
and assistants or others, and you said you understood
that to be a much larger figure. Is there a figure that
has been discussed at all?
A. No.
62
opportunity to seek repayment for any losses caused by
any apparent shortfalls and also not just the shortfalls
themselves but also consequential losses; is that
correct?
A. Thatis correct.
Q. Thank you. Could we please tum to the "Consequential
Loss Principles and Guidance’, that's UKGI00033420. Is
it right to say that this guidance that's about to come
up on the screen was developed in the summer and autumn
2020 and that it followed a request, I think you've said
in your statement, from Hudgells Solicitors?
A. Correct.
Q._Ifwe scroll down please, can you assist us with who
developed these principles and guidance?
A. This would have been HSF with Post Office.
Q. Thank you. If we scroll down, please, we see there
a section on burden of proof. 3.1.2, if we scroll down,
it says:
"Where the postmaster is unable to satisfy the
burden of proof in relation to their claim, their claim
may nonetheless be accepted in whole or part if the
scheme considers it to be fair in all the
circumstances."
A. (The witness nodded)
Q._Ifwe keep on scrolling down, there's then a section
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that sets out established legal principles. If we keep
on scrolling down to the bottom of page 3, we can see
types of loss are outlined there. It says there's no
exhaustive list but it sets out, for example, loss of
earnings. If we scroll down, loss of profits, loss of
property, loss of opportunity, penalties, general
increased costs of financing, bankruptcy, insolvency.
If we scroll down, legal and professional fees, stigma,
damage to representation, personal injury/harassment.
‘Thank you very much that can come down:
In terms of categorisation, you've outlined in your
statements three types of cases. The first is something
called "below assessment threshold” or BAT. Can you
assist us with what that is?
It's effectively a de minimis case where, if a case
comes in where it's below a - where the claim is below
a certain amount, the operational cost of actually
processing that would probably be restrictive and,
therefore, a decision was made that if a claim below
a certain amount came in, we would automatically pay
that -- pay that amount.
Does that still exist?
That is now going to be superseded by the £75,000
opportunity.
Thank you. We'll get on to the 75,000 in due course.
65
2024 by date. It shows there quite graphically two
peaks: one in 2020 and one in 2024. We see there they
effectively stop in between 2020 and the end of 2022,
a very small number in 2021, and that might account for
those figures that Sir Wyn pointed to earlier today, in
terms of reference of the applications who were not
represented.
Yes,
You've outlined the publicity when it launched. We know
that the 2024 numbers occurred at a time after the ITV
Mr Bates drama. So that perhaps explains the peak, is
that your understanding of why —
Correct.
-- it occurred again? Thank you. We know that, for
example, Phase 2 of this Inquiry was in October to
December 2022. Do you think that that might have
triggered some of those figures in late 2022/2023, or is
there some other explanation for figures rising during
that period?
So that's when we confirmed that we would accept late
applications.
Thank you. Was there any publicity or anything done in
the 2021 and early 2022 periods to bring the schemes to
people's attention or did that stop altogether because
of the cut-off dates?
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The second type of case is a standard claim and the
third is a complex claim. Can you assist us with the
difference between a standard claim and a complex claim?
It's basically the number of heads of losses that are
applied for, in terms of the categorisation you've just
gone through. So ifit's 1 to §, it!l be standard; if
it's a5 to 10, itl be a complex; over 10, I think is
a super complex.
Super complex?
Yes, extra complex, I think.
In your charts and graphs, you've only provided,
I think, standard and complex, do those super complex
fall within —
Yes, included in the complex, yes.
Thank you. I'd like to look at the number of applicants
and their current status. At paragraph 51 of your sixth
statement you said that, when it launched, the Post
Office wrote to 7,100 current and 20,000 former
postmasters and you also arranged for publications in
newspapers; is that correct?
Itis.
Can we please bring up on to screen your sixth
statement, page 49. WITN09898600, page 49. Thank you.
if we scroll down, please, we can see there a chart.
That sets out the applications received up until 31 May
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We -- well, we had -- formally, of course, we had
actually closed -- the scheme had closed in November
2020. So what we were doing, we were receiving
applications that were coming in and we couldn't process
them because they had missed the deadline, effectively
So we wrote back to the people who were making these
applications saying, "Look, whether or not your claim
will be accepted isn't -- we don't know yet, so we're
effectively putting it on hold”, and then, towards the
end of 2022, we got permission from Government not to
reopen the scheme but to allow late applications. So at
that point we did and we did publicise that via the
website, et cetera, that we would now accept
applications that were late.
Originally, we did ask for them to describe why they
were late, why they'd missed the deadline, and then that
has vanished now. So now we just accept them as late
applications.
Thank you. If we scroll over to page 50, please, you
set out there the types of application. We can see
they're in that table. Am I right to say that
post-January there was a rise in the number of more
complex cases?
Yes.
Can you assist us with why that may be or what your
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understanding of that is?
I think people -- I don't know why that may be but
I think people might be more educated around the scheme.
When you say people might be -- what do you mean by
that?
They might have taken an opportunity to look at the
website to understand what they're entitled to claim
for.
Thank you. I'm going to take you to the overall figures
now. We can look at page 5 of your sixth witness.
statement, please, that’s WITN09890600. Thank you very
much. If we could zoom out of that slightly to have all
of the figures. Thank you. Is it possible also to
bring on screen, please, POL00460646. Ah, okay, that
can't be brought on screen at the same time. Perhaps if
you could have to hand your most recent figures; do you
have those in front of you?
Yeah, let me just ~ if I may. These are the ones.
I submitted on Friday?
Yes.
Yes, thank you, I have them.
So we start there with applications received and logged.
The figure as at May 2024 was 4,323; can you assist us
with what the figure is now?
4,971
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who are legally represented. It doesn't have to be
an exact figure but, if we see there the number of
disputes currently 319, can you approximate what kind of
a percentage of those figures might be legally
represented?
What I can help the Inquiry with is the cases that are
in our dispute resolution process, I am aware that
I think the number is 70 per cent are legally
represented.
Thank you. Is that different to your categorisation of
disputes here and, if so, why?
I don't think it is.
No. So about 70 per cent are legally represented?
Thank you very much.
Offers accepted. You have there 2,248.
2,341
Thank you very much. Again, are you able to assist with
the kind of percentage that are legally represented; is
it the same or is it a different type of figure for —
So legal representation across the entire HSS population
is approximately the same. It is something like
12 percent. So legal representation across the total
cohort is relatively modest, and yet the acceptance rate
is at now at 84 per cent.
84 per cent who are of —
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Thank you. Eligibility, work in progress. It was 896.
Can you assist us with what it is now?
It's 307.
Thank you. So a significant decrease in eligibility
work in progression?
Correct.
Applications ineligible, I think we've already covered
that today. That's now 397; is that correct?
Correct, which is 9 per cent.
Thank you very much. Applications eligible?
4,267.
Thank you very much. Offers sent?
2,792.
No response to offer?
123.
Applicant in contact/querying?
9.
So a much smaller number of applicant in
contact/querying?
Correct.
Disputes?
319.
Thank you very much. Can you assist us with
approximately, if you're able to, how many or what kind
of a percentage of those disputes involve individuals
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Offers. 84 per cent of offers that are issued are
accepted.
Of those, what kind of percentage are legally
represented, so far as you're able to?
I understand it's circa 10 per cent.
Thank you. Settlements, 2,085?
2,321.
Thank you very much. Total settlement figure?
118.5.
Thank you very much. Tax top-ups to HSS applicants?
14.8.
Thank you. Combined total paid?
230.1.
Thank you. We'll go through all of the charts that you
have provided in your witness statement or most of those
charts but can you assist us in your view what the
differences in those figures, in your mind, shows?
If may.
Yes.
Thank you. The one would like -- because at the moment,
when I got these Rule 9s, it was very much asking me
about trends and patterns —
Yes.
— and hopefully I can help the Inquiry here. So if you
look at the statement that's on the screen, you look at
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the combined payout of 121, if you then go down to the
notes ~- so that 121 was at the end of May 2024. If you
go down to the notes, you can see on the 27 August that
that 121 had turned to 139, and that's a difference
of -- rounding ~ that's a difference of about
18 million. So in those three months, in terms of
redress on this HSS scheme, there was £18 million paid
out.
The number I've just quoted as at end of October is
230 million, so the difference between the 139 and 230
is fairly significant, and I think what that does is —
so what's that? That's about 90 milion. Now, that is
over a period from August to end of October. So that's
a two-month period. So if you compare the 18 million
over three months and the 90 million over two months
I think what it illustrates is a rapid acceleration of
redress and that, of course, is purposeful, because we
need to speed this up and need to accelerate redress.
So that is a major trend I would like to use this
opportunity to point out to the Inquiry in terms of the
acceleration of redress, and I go back to a previous
statement I made this moming, that we expect across all
the schemes it's now 302 million redress and we expect
that to be 650 million by March 2025.
What do you see as a principal reason behind a speeding
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302 days."
So an average case took 470 working days, it's now
decreased, but we're still talking very significant time
periods, aren't we?
Yes.
What do you see as the principal reason for such delays,
I mean, we're well over a year for an average claim?
The 445 we referred to?
Well, those are only working days, so if we include
weekends, even more.
So they are not necessarily delays - and whatever
I say, please, I don't want to be taken as defensive at
all because it's not: this process takes too long, full
stop. It does take too long. However, there is
a process that has to -- it has to be gone through and
that's all defined and all operationally agreed and all
signed off. Could it be quicker and could it be more
efficient? Yes, and that’s what we tried to do
continuously and we will continue to do that.
So that's ~ and those days will include what I call
lapsed time, so when it's queueing -- so when a case is
queueing for the next shortfall analysis to be done, or
the next Case Assessor to be ready, so there will be
queues at each particular process point, and those days
will include those. So this is not a true end-to-end
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up of redress in that period?
That will be more efficiencies and a better process but
predominantly because of the £75,000 scheme, which
I know you want to talk about later.
Absolutely. So let's look at the average time it takes
from eligibility to a decision. That's at paragraph 64
of the same statement. If we could turn to page 22,
please. Thank you. You say:
“For all non-BAT claims ..."
So those are standard claims and the complex claims
"...from the eligibility confirmation letter being
issued it takes an average of 470 days to an offer
letter being issued. In respect of Complex Claims, this
process takes an average of 514 days improving to 306
days in 2024 although we note a lower volume of offers
were issued in 2024."
Can you assist us, in reference to days there, in
some places in your statement you refer to "working
days", in others just "days". Are you aware of whether
that is working days or all days?
Apologies it should be working days.
Working days.
“For Standard Claims, this process takes an average
of 445 days and the data shows that this has decreased
in 2024 with Standard Claims now taking an average of
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picture, this is a reality picture because this is what
the postmaster is experiencing. So I'm not going to say
well, actually, because it any takes two days in legal
review and three days in the SFA, that's a five day.
No, it's when it's queueing you have to include those
days. The process is too long.
We see they that there has been an improvement, and
I think some of the explanation within your statement is
that, for the early claims, there were delays -- you
don't call them delays but I will continue to call them
delays ~ relating to funding from the Department for
Business and Trade. To what extent did those slow down
the process from eligibility confirmation to the final
offer being issued in those early claims?
Well, of course it did because -- so to take -- if I may
add some colour to the whole thing and take a step back,
everybody in this room will understand that the HSS was
actually created from the GLO settlement agreement in
terms of a scheme to compensate those not represented in
the GLO, and that was effectively the activation date.
It was May 2020 when the whole thing started but the
scheme might have been announced and might have been
started but, as with many schemes, including the recent
appeal scheme announced by the Government, i's just
words on a piece of paper. There's no process, no
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anything behind it, no application behind it.
So, from May 2020, you've got to start building
something and that's exactly what was happening and,
initially, the view was thought that — the initial view
was that the number of claims would be relatively
modest, we're talking about a few hundred, and
therefore, an engine was built accordingly, and then, as
soon as the volumes started coming in, and mounting up
to 2,500 applications, it's at that point it was like,
“Well, actually, that engine is not going to be
appropriate any more and, by the way, Post Office
haven't got those sort of funds to be able to support
that, and therefore we have to go to Government and ask
for it", and that starts the whole process around
applying for funding.
Can you assist us with who was responsible for
underestimating the number of potential applicants?
No, I can't, before my time and I don't know who would
have been -- I know there was a predecessor to myself,
who was appointed but I understand that individual
wasn't around for about eight months before I started.
So I don't know who that would have been.
Was there anybody in your role in that eight-month
period?
Not that I'm -- no, not that I understand no.
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out?
So my operational team carry that out, and how the
process works is that a postmaster in their application
form will identify a time period when they thought they
had a shortfall. The operational team ~ my
understanding, I'm not an operator myself ~ my
understanding is that individual will go into the
system, into the Horizon system, and they are aware,
they have experienced of the Horizon system and
therefore know what they're looking for. Some of these
members of staff have been counter clerks previously at
Post Office. So they have sophisticated knowledge of
the Horizon system and how to look for the shortfalls.
So they go into the date where the postmaster has
identified, and they look six months before and six
months after that particular date, to look for that
shortfall, and identify the shortfall. And they have
the skill sets to be able to identify that, but also to
be able to identify whether or not that was a Horizon
shortfall or another type of shortfall. If there's any
doubt, the default is that it is a Horizon shortfall.
We've heard throughout this Inquiry about different
types of data being available to the Post Office, we've
heard about ARQ data, for example. What kind of data is
it that they are accessing?
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I'd like to take you through the various stages of the
application process and the offer process, unless you
have anything else to say at this stage?
What I would say is, please — and to help the Inquiry
in the colour ~ and, please, again, please do not take
this as being defensive at all, but the whole engine to
be produced has to go through a huge governance process,
So you talked about the consequential loss principles
and brought them up on the screen and, forgive me, I did
say HSF and Post Office built those but of course the
panel, the independent panel were heavily involved in
their creation as well, which helps from the
independence perspective.
That whole engine, in creating all those principles,
creating the funding, creating the process to build, to
make cases, allow cases to flow, took a considerable
amount of time and everything has to be agreed not only
through Post Office -- appropriate Post Office
governance, but also Government governance all the way
thorough to Treasury because, at the end of the day,
every process costs money.
Thank you. So moving on to the various stages, we'll
start with the shortfall analysis stage. That process
includes assessing or analysing whether a shortfall
occurred, and how much it's valued at. Who carries that
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So they are accessing Horizon data and accessing
a number of other ~ other data sources, and if they
want even further to go and get a branch file, they can
go and get the branch file, as well, to create — to be
assured of a shortfall
But when you refer to Horizon data, do you know what
that means? Do you know what kind of ~
Entries. So they can look at the physical entries.
From where?
From at the time, so when the postmaster said it was
24 July, in whichever year, they can go in and look at
the entries on that day but they recognise that the
postmaster that may be a guess at the date and,
therefore, they go in six months after. They look at
the whole year, six months after -- to look for those
entries.
Is that data provided by Fujitsu; is that data from the
Post Office's own archives or records?
So that will be Post Office and some of that will be
supported by Fujitsu.
You've said in your statement there's a low evidential
bar; what do you mean by that?
In a language that maybe I understand better than most,
is that, if the postmaster says it happened, it
happened.
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That seems like no evidential bar?
No, it is, because ~ and this is a panel thing, this is
an independent panel thing -- cases go to the panel
where we cannot find a shortfall. So it goes to the FSA
process and the postmaster said, "Look, there were five
occasions and here are the dates", and we've looked six
months after and six months before but we've looked at
it all but we'd always go to panel and say we can't find
it we can't find anything. The panel then will go to
the statements and all evidence that there has been
coordinated by the Case Assessor, and then they will
look at it in the round and said, "Okay, we can't find
any actual SFA technical evidence but, in the round, do
we believe, given all that evidence in the file, do we
believe a shortfall may have happened?"
Thank you, and we're used to legal terms: balance of
probabilities, reasonable doubt, prima facie case,
credible evidence; are any of those kind of legal terms
used in the shortfall analysis stage?
In the shortfall analysis, those -- yes, in terms of the
mindset of the individuals, and they're looking to be
positive about it. Is it formally in their terms of
reference for operating and what they're doing? No,
it's not. But they are, a bit like as I said, the
default is a Horizon shortfall, if they can't find
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Yeah.
Now, what we saw in the chart earlier is that after the
Bates drama, there was, again, a second spike in those
applications. We saw it earlier and then again in 2024.
Does that not mean -- and we see perhaps some affected
there on the far right-hand side -- that there is going
to be another spike in volume because they have to go
through the eligibility stage first, so there will be
an inevitable time lag. Will we not see a repeat of
what we saw in 2021/2022, later this year, or early next
year?
And later this year because of the mailing.
Because of the January 2024 and onwards spike in the
volume of applications?
You will see that spike, yes.
We'll see that in the number of calendar days it takes
to ~- for the shortfall analysis to take place?
So I hope not. I hope -- I think there will be a spike.
But we are busy, as we speak, making sure appropriate
resourcing is in place to avoid peaks in terms of
longevity of time and eligibility. In addition, as the
Interim Chair said in his statement, we are looking at
some automisation and efficiencies in this space as
well, in order to speed that process up significantly.
Can you assist us with quite what did he say meant by
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another reason. So it's an empathetic/sympathetic.
approach, they are looking for the shortfall. They are
not looking not to find the shortfall.
Looking forwards to the ultimate offer, is it the case
that the actual offers are, in any way, reduced because
of the uncertainty at that particular shortfall analysis
stage?
I believe not, no. The shortfall is just the trigger.
It's just the trigger for the consequences of that
shortfall.
So it won't be that, because of the form of words that's
used at that shortfall analysis stage, about the certain
or uncertainty of the shortfall, that is then used at
the offer stage to reduce or not ~
That's not my understanding, no.
Can we please turn to page 58 of your sixth witness
statement, so the same witness statement, please,
page 58.
This is the average number of days it takes for that
shortfall analysis to take place. We see there on the
barcharts the average number of calendar days was
significantly higher in 2021 and 2022; is that correct?
Yes.
But we do also see, from the volume, that that reflects,
albeit with a time lag, the volume of applications?
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that in terms of automation?
Ican. Well, firstly there's the automation of actual
payments that we have already improved on and we will
continue to do that. Secondly, and it is related,
forgive me for jumping your agenda, it is related to the
£75,000 process, where we have talked about the SFA
process. With the £75,000, we are not intending to do
an SFA. We are effectively doing a shorter version of
it~ and we're calling it an SFI for future
reference -- and that is - and that's all been approved
through governance, et cetera, for the £75,000 cohort,
which we believe will be the vast majority of cases.
And the big difference between the SFA and the SFl,
in terms of efficiency, is that you're only looking for
one shortfall. Under the SFA, if the postmaster is
saying "I had six", you look at all six. You look at
six months before, you look at six months after, you
draw up your report, et cetera, et cetera. On the SFI
is when you find a shortfall and, at that point, for all
cases under 75,000, we will not be doing a review with
HSF. So Post Office are going to be entirely doing that
process
So to clarify, and we will get to the 75,000, but you're
not granted 75,000 just on fulfilling the eligibility
criteria; you have to have the eligibility criteria plus
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a shortfall; is that right?
Correct, correct.
Thank you. And you've spoken about increased
resourcing. Can you assist us briefly with how you are
preparing for a spike later this year, early next year
and into next year?
Hiring people.
Can you give us an indication of numbers before/after?
So I know we're currently in the process of hiring
a further 20 individuals.
Okay, and when do you anticipate that will be completed?
My understanding is that will complete the hiring.
When, sorry?
Oh, apologies: when? They're being hired now. So
within the next few weeks they should be in place.
Thank you. The next stage is the legal case assessment.
Yes.
‘Am I right to understand that Case Assessor from Herbert
Smith Freehills will compile a pack which includes their
‘own assessment and analysis of the claim which is then
passed to the independent panel to consider?
I'm not quite sure whether it's an assessment. They
coordinate the information they have. They get the SFA
analysis and then they do a legal review of the case,
building the case on -- per heads of loss for
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Can we please turn over the page to page 59. We see
there the average days from starting legal case analysis
to the issuance of an offer. Again, we see perhaps
an increase in time, increase in number of calendar days
it takes, as a result of higher case volumes that have
reached that stage from late 2021 into 2022. So, again,
are we likely to be seeing a spike late 2024 into 2025
because of higher volumes and, if so, at the legal case
assessment stage, how are you going to avoid that?
I hope not because, as previously described, the
anticipation is on the existing cohort that are going
through the process and, indeed, future cohorts, the
vast majority will be under 75,000 and there will not be
subject to a legal case analysis.
Thank you. Moving on to the request for further
information. During this process, Herbert Smith
Freehills, the Case Assessor, might issue a request for
further information or they might request multiple
requests for further information; is that correct?
Correct.
Can you briefly describe what that involves?
That is designed to help the postmaster's application,
it's not designed to hold it up, please, it's not
designed to hold anything up. It's to seek further
information to support their case when it's being put
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consequential loss. The shortfall is the trigger, and
they look at the claim, and they assess, right, that
claim means it's that consequential loss and therefore
Il build the case around that, and what under each
heads of loss the assessor then outlines what the
options to the panel could be for consideration under
each heads of loss.
So there might be three options understand each
heads of loss that the panel might want to consider.
They're not guided to take those options but it's things
for their consideration
Once that pack is completed that goes off into the
independent panel.
Can you assist us with who at Herbert Smith is carrying
that out: is it junior solicitors, paralegals partners?
A range -- not partners but a range of Herbert Smith
appointees.
Do you have a view as to whether it's appropriate for
Herbert Smith to be involved in this process given their
involvement in the Group Litigation, as we discussed
earlier?
I think the two are completely separate.
Do you know of any overlap of individuals involved, for
example, in that process?
No.
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forward to panel. They are very empathetic approaches
in terms of, if we ~ if we can get more information in
this particular area, we might be able to assist you
further, and that's what those requests for information
are.
And there have been occasions and, unfortunately, it
does mean the case takes longer, where there maybe have
been two or three requests for further information, but
they are well meaning and well intended to ensure that,
those cases have the best information possible for
a positive outcome.
If we could turn the page, please, to page 60, we again
have a chart of the average days from starting a legal
case assessment to the RFI request. Again, very much
the same trend that we see a peak towards the end of
2022, and possibly a peak again starting in 2024. Once
again, I think your answer will be that those will be
cut down because of the £75,000 offer; is that correct?
Itwould be. If I may add something, if i's helpful to
the Inquiry?
Yes.
In terms of the full colour of the picture — and,
again, please, this is not being viewed as defensive,
please don't take this as defensive, it's just the
process that happens ~ with an RFI, you're going to out
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to postmaster and you're going ~- or indeed their legal
representatives -- to request further information. The
whole process at that point is sort of out of your hands
because you need that information to come back to help
that case. So we are relying on that tumaround and,
for good reasons, really good reasons, sometimes that's
not instantaneous. And therefore, you have to build
that lag in to,
‘And sometimes we do have a process of chasing down,
and it's wrong to call it chasing — following up is
a better term -- following up those requests for more
information, and that's all part of the process but what
it does is, in the words that you use ~ and I'm happy
to use those words — it creates a delay.
Thank you. If we go over the page, please, we can see
analysis of an average number of RF ls per case and also
average number of days from starting an RFI to the final
RFl response. We see at the top there, if we scroll up,
a gradual increase in the number of RFs that are
requested; is that correct?
Yes.
Can you assist us with why that is?
I think that will be down to complexity, in that, as the
easier cases go through quicker, if there is an easy
case -- I don't think there is -- the less complex cases
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So there are circa, I think, 300/350 odd cases in that
dispute resolution process. They are more intense
because the offer has been rejected and, therefore, they
are ~- those postmasters and their legal advisers are
suggesting that a more significant redress needs to be
paid. In order to justify that, in order to understand
that better, Post Office will be asking for further
information.
Why is it particularly in this year? Why is the average
time particularly higher this year?
Because the other normal cases, the non-disputed cases,
are less, and we've got a more efficient process around
those and, again, the RFI process, it will be in HSF, or
not at all, if i's under 75,000, whereas in the dispute
process, it's still under that process and therefore
requests for information are required
In your view, looking forward, how can you avoid that
increasing yet further?
The 75,000, again, I know we're going to get on to it,
will help massively in that space because we know number
of dispute cases will be able to be resolved with the
£75,000 offer, so that will help enormously, but we
absolutely need to get better and more efficient than we
are doing in that space.
So in that dispute resolution stage, can you assist us
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go through quicker, and therefore the more complex
cases, because their very nature and therefore the
likelinood of more RFls, is more prevalent.
If we look at the bottom table, please, we can see
a growing number of days spent on the RFI process and,
as recently as the second quarter of 2024 the average
time is nearly 120 calendar days. That's problem, isn't
it?
Yes, any delay is a problem. I think these figures will
also include the cases that are in dispute and they
naturally do take longer, and many of those, as I've
said in the dispute resolution process, are actually in
the hands of legal advisers as well, and that adds
a dynamic, in terms of their caseload as well. I'm
conscious that they have many clients as well.
But what we have there is, of all the years that this
scheme has been operating, the current year actually has
the highest number of days that are being spent on that
RFI process.
I think that may be down to that factor because a number
of cases are in the dispute resolution process and,
therefore, the time it takes for -- the engagement on
RFI and the return of RFI is more.
Can you assist us with what you mean by that, in
alittle more detail?
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with what kind of proportion are actually claiming for
less than 75,000?
1-1 think the numbers might be in my statement but
the ~ I think there are initially, we know ~ the
number that I've got in my head is 25 per cent of cases
could well be impacted positively by the 75,000 but that
is a determination to be had by the postmaster and
indeed their legal representative
Thank you. If we could turn back to our survey at
EXPG0000007. Page 60, please. Thank you. Figure 45.
We have there the third bar is "The time it took for the
Case Assessor to assess your claim”: net
dissatisfaction, 57 per cent; 40 per cent are very
dissatisfied with the time it took for the Case Assessor
to assess the claim. Does that surprise you?
No.
Why do you think that is?
Because it's not good enough.
Moving, then, to the independent panel assessment stage
could we please bring up onto screen POLO0448026. These
are the terms of reference for the shortfall scheme
Independent Advisory Panel. I'll just take you through
briefly, just to explain the background to this. We
have at A1:
“The task of the panel is to assess and recommend to
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Post Office a fair outcome for Eligible Claims made to
the Scheme for Shortfall Losses and Consequential
Losses.”
If we scroll down, it has there the panel's
membership, and that comprises of legal specialists,
forensic accounting specialists and retail specialists,
and it sets out below those who are involved.
If we scroll down further to page 3, please, there's
a section on general principles. At 31, it says:
“In formulating its recommended offer, the panel may
recommend the making of an offer to the postmaster if,
guided by broad considerations of faimess, the panel
considers that doing so would produce a fair result in
all the circumstances of the particular case. For the
avoidance of doubt, in doing so, the panel's discretion
will not be confined solely to the specific heads of
consequential loss claimed by the postmaster but will
take into account any facts and matters which the panel
considers will produce a fair result on the facts of
a particular case."
Have you known the panel to make a recommendation
that includes heads of loss that haven't been claimed by
subpostmasters?
I have known many cases where that clause 31 has been
proactively used. I can't say with certainty whether
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Loss Principles and Guidance which are included at
Appendix 1
“In relation to personal injury claims where
insufficient evidence has been provided for a claim to
succeed without further medical and/or expert evidence,
the panel may recommend the making of an offer to the
postmaster which the panel considers fair. The
postmaster will then have the option of either accepting
that offer or obtaining such further evidence and
pursuing a personal injury claim in accordance with the
ordinary legal standards relevant to such claims,
including as to proof of causation and assessment of
damages."
So it may be that the panel itself makes
a recommendation in respect of ~
Might do.
-- the personal injury aspect of an application.
To understand your statement correctly, am I right
to say that the recommendation that's made by the panel
doesn't need to be accepted by the Post Office?
Ihave not known a case where it has not been accepted.
But am I right to say that, technically, it's only
a recommendation, it doesn't have to be accepted?
Correct, correct.
Yes. As you say, you've never made —
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that means a new heads of loss but I have known that,
they -- part of the process is, once they've opined,
made their recommendation, they step back and they look
at two things: consistency with other outcomes and
fairness. And they -- and I have seen them use that
licence to say, "Right, to be fair, we believe we need
to adjust here, here and here”.
I also know that, once Post Office have signed those
recommendations off and the offer letter is produced,
the offer letter goes back to the panel for sanction,
and they take another moment then to assess the faimess
of that offer.
Thank you. If we scroll down, there's a section on
“Horizon Shortfalls’, and it says:
"Where:
“there is evidence that the shortfall in question
existed and was paid; and
“there is no evidence that the shortfall was caused
by something other than a potential issue with Horizon,
for the purpose of the Scheme the presumption is the
shorttall is a Horizon shortfall.”
I think that’s what you've already addressed.
Thank you.
“Consequential Loss claims
"The Panel should apply the Scheme Consequential
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I think we've increased a couple.
You've never made an offer, so far as you're aware, that
is less than the offer that is --
Never.
‘On how many occasions, as far as you're aware, has the
panel revised their recommendation on that second look
that you've already explained?
I don't know. But I know the process does take place
but I don't know how many times they've taken the
opportunity to revise it.
Thank you. What is your role in respect of the panel:
do you attend their meetings, are you able to
contribute/observe?
Absolutely not. They are completely independent.
Ihave no right of attendance to any of their meetings.
They are independent. If I had any engagement with
them, I could understand the optics of that, so
absolutely not. The only time I have met the panel was
when they presented to the Advisory Board.
Thank you. How about in respect of the Department for
Business and Trade? Do you know what interaction they
have with the panel?
They have no interaction at all
Thank you. Could we go back to your sixth witness
statement, WITN09890600, it's page 62. We're now
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looking at the situation at the independent panel
assessment stage. You set out the average number of
days from the last RF! applicant response to it being
sent to the panel. Thank you, it's page 62.
If we scroll down slightly we can see that chart
averaging, I think, 150 days from the last RFI response
to be sent to the panel in the last section before we
get to the right-hand side. Can you assist us with what
the shading means on the right-hand side at all?
I'm afraid I can't,
No.
I don't know why it’s shaded
So it may be those are accurate figures ~
I think they are.
-- for the fourth quarter and, in that case, we are now
averaging almost — is it 700 calendar days between RFI
application response and it being sent to the panel?
Are those three bars on the right-hand side showing
quite a problematic picture, as far as the current
situation is concerned?
Correct, and that's why we are redressing that.
Is that again the £75,000 offer or something else?
It is the £75,000 offer and so some cases have been
waiting for that to be activated and, therefore, they
will flow through accordingly, and I think the other one
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five to ten cases per session. Doing the maths, to get
through those 1,500 applications, it's going to take
more than a year, considerably more than a year, just to
get through the panel stage for those applications; is
that right?
No, it's wrong because ~ and, again, it's the overall
picture that now we need to look at. There are 1,500
cases but the vast majority of those are going to be
impacted by the 75,000. So the number is actually going
to be a lot less, so that will bring -- that ten per
week will be bringing that in significantly, correct.
As I say, we'll get to the 75,000 but do you think
you're putting a few too many eggs in one basket in
terms of that 75,000 offer?
The postmaster will have the choice about whether they
are prepared to accept the 75,000 or they go for full
assessment, My statement makes it clear on several
occasions that the average payout redress for the HSS is
£53,000. I sit here as a layman and I look at the
average of £53,000 redress versus an increase in that,
an offer of 75,000, and a slick, efficient, automated
process. I sit here as a layman and look at that
logically, and we have looked at our data in terms of
the numbers of claims that, actually, are under 75,000,
and they are the vast majority.
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is that ~- let's take a step back and see where we were
with HSF. We moved into 2023. We were - across 20 —
we were effectively winding down the scheme because what
we were doing was the later applications. So until the
Bates drama came out there was no peak, so we were
downsize -- and, indeed, HSF were downsizing as well
Then the drama happen and then the volumes started
coming in again, so we have effectively had to recreate
the business once again in order to deal with the
volumes. Now, it will be -- the 75,000 will help
enormously in terms of that, but that has meant
a knock-on effect and one of the things that we have
done is we have, in the month of September, we made sure
that the panel now sits twice a week, rather than once
a week, and that will be moving into three times a week
shortly.
Yes. I was going to address that. So there are about
1,500 applicants yet to receive an offer; is that
correct?
Yes. That's right, yeah
Til be taking you to some correspondence with Hudgells
Solicitors shortly.
Yes.
But in that letter you say that panel sessions recently
increased from one per week to two per week, and that's
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Now, there is some mathematics and there is some
logic in coming to the conclusion, therefore, that we
believe the £75,000 offer will make a significant impact
in terms of the operationalisation and the time of this
process.
We'll get in due course to --
Sorry.
~ to. a number of issues, one of them being that there
is potential for an appeals mechanism, so it's not
entirely clear that those figures that settled for lower
than that sum actually might not, in due course, seek to
appeal the figures that they accepted. We'll also, in
due course, see issues with legal representation --
Good.
~ and a high number of those that are accepted at that
early stage not having legal representation?
Understood
In light of those problems, those potential issues,
might it not be that, actually, that 50,000 or so figure
is wrong and that, actually, ultimately, people seek
more than 75,000?
I think that's a potential, yes.
Won't that throw a slight spanner in the works when it
comes to the predictions that you have for alleviating
those problems that are imminent?
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I think you can separate the two between appeals process
and between the applications that you're going to get in
under £75,000.
What do you mean by that?
I think the appeals ~ the potential appeals process,
it's been announced but there's no process behind it
yet, that will deal with any case independently in
Government with anybody who wants to appeal and they're
not prepared to take the 75,000. That's absolutely
fine. And if they're not prepared to take 75 in
an offer, then that will go through the full process,
and I think the numbers we anticipate in that we can
cope that.
Still -- separately, I still believe that our
anticipation is that a significant number of claims will
come in for under 75,000, which we'll be able to be
process quickly without a legal review. I hope that
answers your question
That anticipation is based on previous figures —
Yes.
-- previous figures which themselves may no longer be
accurate because people are going to seek to challenge
those figures?
They may do that. I repeat my statement, and
I recognise that only 10 to 12 per cent are legally
101
actually made very, very clear, we will have to automate
more and be more efficient and, indeed, for example,
introduce the SFI process more aggressively into that
population.
Thank you. You've said at paragraph 88 of your
statement — we don't need to get it up — on average it
takes 37 days from the panel assessment, panel
recommendation, to the offer being sent. Can we please
turn back to our expert report from YouGov, EXPG0000007,
page 62, if we scroll down we can see there satisfaction
figures, in respect of the information provided by the
Independent Appeals Panel and the length of time to
consider the claim. Again, a lot more red than there is
purple. Net dissatisfaction with how long it took for
the IAP to consider the claim, 46 per cent; amount of
information provided about the IAP process, 52 per cent
net dissatisfied?
Do you have any views on those figures and why that
might be?
I'l repeat myseff, it’s just not good enough, and
I apologise on behalf of Post Office and, in terms of
the process, that it takes so long. I do believe we get
full and fair outcomes out of it and, as Sir Wyn has
mentioned more than once on the previous witness
statements, it's the timeliness which is the issue and
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represented, I really do, and, please, this not
defensive at all, but 83 per cent accept their offer.
Do you read into that that 83 per cent are content with
their offer?
Ihave to draw some conclusion to that, that they ~ but
1-1 know what the legal advisers will say. You know,
that they're not well informed enough, and I absolutely
get that as well but they have made a conscious decision
to accept that. So I have to read something into that
And the appeals process, when it comes, will give them
the opportunity to say, "Well, actually, I wasn't sure
what I was signing at the time, and therefore I do feel
this is unfair, and therefore I want to launch" — and
great, that is fantastic. But they also might say,
actually, I don't believe that was fair but the 75,000
is now fair.
Have you planned for a scenario where, in fact, not as.
many people take up that £75,000 offer as you currently
expect?
Ihave to, yes.
How are you going to deal with that when we see figures
like this, the process, the RFI process, the case
assessment process, taking a considerable number of
days?
We have to be more efficient and, as the Interim Chair
402
Post Office apologise for the time it has taken, and it
has taken too long. Am I surprised by these?
Absolutely not. Am I doing something about it? Yes.
Thank you. The next stage is the Post Office review --
that can come down off the screen, please -- and that is
when the Post Office reviews the recommendations of the
IAP. Can you assist us with who at the Post Office
reviews those recommendations?
Of the Independent Panel?
Yes.
We are told who it's going to be.
You receive them, though, there must be some internal
discussion?
The names are put forward by HSF and the names are
circulated for interest. But we don't have a - we.
don't opine about whether we're supportive of that
appointment or not.
Sorry, I mean, in terms of the actual recommendation in
individual cases?
Oh, sorry. Apologies. Who sees those recommendations?
Yes, and who is involved in any kind of intemal
analysis or assessment of those recommendations?
There's no assessment of the recommendations. They are
what they are. There is no challenge to those
recommendations, it's me. I chair a committee, they
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look at all recommendations that come out of the
independent panel and we understand how the panel have
come to those recommendations, and sanction them.
Once the recommendation is made and accepted, does the
Post Office ever revisit those figures, even to increase
them once the offer has been accepted?
Where there may be -- the answer is yes. Where -- for
example, where we may have introduced a new heads of
loss, we may have adjusted a principle or adjusted the
heads of loss because of a new case that has got
a nuance in it that hasn't been considered before, then,
actually, we don't put anything on hold but we realise
that, actually, that might impact previous cases, so we
do -- we do a backward review, with the Panel's
assistance. We do a backward review on all cases that
might now have this additional nuance in it and we
adjust.
Approximately how many times have you had that backward
review process?
I don't know but we've definitely had one, but there is
the opportunity there for -- I'm sure it was more than
one but I can only recall one.
In that one, was there a revisiting of earlier
acceptances ~
Yeah.
around these numbers ~ and I looked at these numbers in
particular -- what concerns me more about this page is
that wanted the process just to finish is 51 -- that
really concerns me and that goes to what some legal
advisers have been saying to me as well: that people
just want this done and, therefore, whatever you put in
front of them they're going to sign because they just
want to talk away from it now, it's taken too long, it's
two legalistic, et cetera, you're putting too many
barriers. So that does concern me.
On the more optimistic side, what I'm hoping is that
the appeals process, when it's ready, hopefully in the
New Year, will be able to accommodate those people to
say, "Right, I wanted it to finish but now I've got the
appeals process, I wasn't satisfied with that, I wanted
it finished but I can now apply to that"
Thank you that can come now come down. I'm now going to
move on to the dispute resolution process. I'll
introduce that briefly before lunch but we'll have to
return to it after lunch, the Dispute Resolution
Procedure applies if the offer is not accepted by the
postmaster; is that correct?
Correct.
It's assigned to a case manager. Can you help us with
who a case manager is?
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Q._ —and communication made with those subpostmasters?
A. Correct, correct,
Q._If we go back again to the expert report, the
EXPG0000007, I think this is the final time I'l take
you to that report, page 63. Thank you. Page 63 has
the "Satisfaction with the amount of information
provided about how the application outcome was
determined”. If we scroll down, we can see, in terms of
the time it took, 52 per cent net dissatisfied; the
offer amount, 59 per cent dissatisfied; the amount of
information provided to you about how the outcome was
determined, 49 per cent net dissatisfied
If we go over the page on to page 65, please.
There's figure 49, "Reasons why applicants accepted the
offer in part/full", and we only have a figure of
15 per cent who say that they accepted because they were
satisfied with the offer.
What's your view of those figures?
A. Obviously extremely disappointed. I think where
I struggle ~ and I know it's simply an optic and it's
simply numbers on a piece of paper, I need to talk about
numbers on a piece of paper, please, if it helps the
Inquiry — is that the 15 per cent satisfied, it doesn't
tally in my mind with the 83 per cent acceptance rate.
That's where I struggle. But what concerns me more
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A. Itwill be a member of my team who has a broad knowledge
of Post Office and how it operates but, specifically,
around how to deal with disputes, and team —- the team
is currently 23 people, and they all have their own
portfolio of cases.
Q._ There is then a good faith meeting and the next level is
what's known as an escalation meeting; is that correct?
A. So there are four layers of dispute resolution process.
All determined, actually, by the GLO settlement, in
terms of when it was alll - when the HSS was established
it was agreed that a dispute resolution process would be
established and, therefore, it's pretty within, you
know, given terms that we had to create a four-layered
dispute process: so good faith, escalation, mediation,
arbitration.
Q._ Thank you. In terms of a good faith meeting, can that
result in an increased offer from the performance?
Sometimes, yes.
Has it resulted —
Yes.
After the good faith meeting or the escalation meeting,
it can then go back to the panel, can it; is that
prop
correct?
Itcan, yes.
Is there a maximum number of times it can go back to the
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panel?
No.
4 MRBLAKE: I'm going to return to this topic after lunch but
2 that's an appropriate moment to take our lunch
Is that set out anywhere in any of the terms of 3 SIRWYNWILLIAMS: Yes.
reference or guidance in respect of the process of it 4 MRBLAKE: Thank you, sir. 2.00, please
going back to the panel and how often that can happen? 5 SIRWYN WILLIAMS: Yes, sure.
Only the — going back to panel, only internally, into 6 (1.01 pm)
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say the process is, once we think we've gathered enough (The Short Adjournment)
information, that may change the view, then it goes back (2.00 pm)
to a panel. But, as no doubt you've picked up from 9 MRBLAKE: Good afternoon, sir.
recent correspondence with Dr Hudgell, is we are now 10 SIRWYN WILLIAMS: Good afternoon.
adjusting that to say if the legal representative or the 11 MRBLAKE: Mr Recaldin, we were on the topic of dispute
postmaster actually don't want it to go back to panel 12 resolution. 'd like to bring up on screen your sixth
and would prefer Post Office to take a commercial view 13 witness statement at page 67, please, paragraph 185.
on that, then that's fine as well. We're beholden to 14 You address there some figures in relation to dispute
what the postmaster and what their legal 15 resolution. It may be that they're slightly out of date
representatives’ preferred -- preferred option. There's 16 now because they were based on the position as at the
no set — it has to go back to panel, if that's the 7 time you wrote the statement. Actually, sorry before
question you're asking. 18 I get to that, just to say in your evidence earlier,
Then, finally, you have the formal mediation with 19 I asked you about calendar days and working days, and
Wandsworth Mediation Service? 20 it's been brought to my attention that, where you use
Yes. 21 the term "days" in your witness statement it's calendar
Does that takes place; has that taken place? 22 days rather than working days.
Yes, it has taken place quite a few times and, so far, 23 Okay, thank you.
successful in every occasion it's been used, and some 24 If we have look at that Dispute Resolution Procedure
positive feedback on it as well 25 section, it says:
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“Of the 2,720 offers made, 532 have been disputed 1 process, however, it's really important that we have
. 2 continuous engagement with the legal representation, and
It says: 3 also with the post masters, and that inevitably causes
"86% of legally represented applicants dispute their 4 delay -- your term. I call ita process but
offer compared to only 11% of non-represented 5 I understand why it can be viewed as a delay
applicants.” 6 That is deliberately put in there, the 261 that
So it's much more likely that there will be 7 hadn't yet gone to a good faith meeting because there
a dispute where somebody is legally represented; is that 8 are legal advisers who say "We actually -- we were not
correct? 9 in dispute, we just want to understand more. So we want
Yes. 10 to understand the offer better and we are waiting for
If we go over the page, please, to 185(d), you say "1 advice from our clients about whether or not it needs to
there: 12 enter into the dispute process". So it's almost like
“There remain 383 unresolved disputes with 13 a waiting room until the legal adviser gets clarity from
an average time in dispute of 14 months, of which 261 14 their clients around whether or not it is a dispute or
have not yet gone through a Good Faith Meeting. Some 15 not, and that's why they've yet to get to a good faith
feedback from legal representatives is to bypass Good 16 meeting.
Faith Meetings and go straight to next escalation stage 17 However, there are cases, quite rightly, where the
to speed up resolution, which is why the process is 18 good faith meeting is bypassed and that's why the
approached with a degree of flexibility.” 19 process is flexible and the opportunity is there to go
‘Average time in dispute of 14 months: I mean, that's 20 straight to a face-to-face escalation meeting
a very significant time period, isn't it? 21 Can you assist us, you have there the average time. Do
Yes. 22 you know how long the longest time period for
What do you say is the principal cause of that delay? 23 a particular case has taken?
I think — well, there are a number of things, ie could 24 No, I don't. But I know I would be very embarrassed to
itbe done quicker? Yes. I think in this part of the 25 know what it is.
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Q_ Because it may be -
SIR WYN WILLIAMS: I take it that there are cases still
unresolved which were part of the cohort of cases which
began within the original time frame, which would mean
that we're four years down the line, wouldn't it?
A. From May 2020 when they may have been submitted, yes,
Sir Wyn.
SIR WYN WILLIAMS: Yes, yes.
MR BLAKE: Do you think that's a handful, tens, hundreds?
A. Not hundreds but certainly tens, yes.
Q. Thank you. If we could please go over the page to
page 69. We have there the proportion of offers
disputed by date of first offer. It looks as though, in
parts of 2023 into the beginning of 2024, you have
somewhere approaching half of the offers being disputed;
is that right?
Yes.
We see there towards 45 per cent, for example?
Yes.
prop
We'll get to the letter from Dr Hudgell shortly, but one
of the complaints that was made in that letter is that
the escalation meetings are difficult to secure and
don't lead to tangible follow-up. I think you've
reflected on the number of meetings of those escalation
meetings, and you've said that there will be a further
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a consistency because the panel provide that consistency
and that optic of fair - that fairness of the outcome.
And, you know, we believe it's an important part of the
process for that consistency and for absolutely that
independence but we also recognise that could lead to
delay, there's another legal review requested in terms
of a resubmission into panel. It then has to wait for
their next panel meeting, then they opine, and then
they're recommended, and that's a process that does take
time. And we recognise that, to avoid that, we are now
offering an opportunity that, instead of going back to
panel, we can have a face-to-face negotiation with
the — directly with the legal advisers and the
postmasters.
Q._ Since when has that been in place or communicated?
A. So that's been in place consistently or has always been
there, by ~ we've always followed the process of going
back to panel. Not every time but we have a commercial
flexibility in order to settle. But most of the time we
do go back to panel for that consistency perspective.
So the -- in terms of additional flexibility and
allowing the legal advisers to make the call, and
obviously their clients, that is something which you
will have noticed was in my correspondence to Dr Hudgell
last week.
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increase in their frequency; is that correct?
Correct.
Do you recognise that those meetings have been difficult
to secure?
I'd say Hudgells and Post Office have worked what
I think collaborative together consistently and I don't
believe getting dates into diary, if that's what this
means, has been a struggle. I don't believe think that
is the case. I'd like to think we're very collaborative
in terms of getting those dates in diaries.
One of the cases that they highlighted was a case where
a figure was agreed but there had been months of
argument as to which head of claim that amount fell
under. Is that something that you're aware of?
1am aware of that case, yes.
What are your views as to what I would call delays in
that particular case?
I'm disappointed, and we need to be better at it.
Are there plans to resolve that
Yes.
~ imminently?
Yes.
What about the resubmission to the panel? Does that
build in further time?
Yes, it does. The resubmission to panel is a bit of
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So that's a relatively new process?
Yes, yes.
I won't bring back the survey onto screen but, in the
results, more were dissatisfied with the dispute
resolution process than satisfied. I think that it's
‘small in numbers but 16 against 4 who were satisfied.
‘Again, do you have any views on that?
I'm disappointed but not surprised.
We then have the arbitration level, that’s for claims
over £10,000; is that correct?
So we've never been to ~ we've never experienced
an arbitration, and the £10,000 is now ~ effectively is
ineffective now because of the 75,000 scheme, the offer
and, again, we have never actually been to
an arbitration, we've never formalised that process at
all.
Thank you. In terms of an appeal mechanism, there has
been discussion about an appeals mechanism.
Yes.
Can you assist us with what the current plan is for
that?
The appeals mechanism was ~ actually came out of this
Inquiry, and Sir Wyn and the Inquiry very helpfully
suggested some areas that might bring — he might bring
forward — the Inquiry might bring forward for
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attention, such as the fact that consequential loss.
principles were issued after the scheme was launched,
the fact that legal representation was not supported at
the point of submission of claims, and Sir Wyn very
helpfully listed a number of questions and challenges
around what could be the implications of these.
So Post Office, doing their best to listen, if I may
say that to the inquiry, went away to consider those
challenges and those issues, and said how could we
address those? And at the same time, actually, the
Advisory Board also came forward to advise the
Department of Business that, in their view, an appeals
process, an independent appeals process for HSS cases
would be appropriate because of the inherent mistrust —
use the word — the inherent mistrust of anything
coming out of the Post Office.
That might be slightly unfair on the Advisory Board,
in terms of their advice.
The ~ and at the same time, because of the
challenges that Sir Wyn and this Inquiry gave us around
these issues, we thought, well, actually, a resolution
to all these issues could well be an independent appeals
process, so even if cases have settled with us, then,
actually, if the recipient, the victim, feels they've
had an unfair outcome, despite the fact it's from
417
No.
Do you have a view as to how likely it is or not that
the numbers are going to be of significance?
I think, through the helpful YouGov survey and our live
experience, I think we can help very much in what that
may look like and, although it has not been agreed, one
step that has been discussed in this appeals process is
the potential transfer of the dispute resolution process
into that appeals process. It hasn't been agreed, it's
one thing that is being considered.
In terms of the overall perceptions, as you've said,
they're set out in the YouGov survey. Perhaps we can
bring that up. Again, that's EXPG0000007, page 67,
figure 50.
Page 67. If we scroll down, we can see overall
satisfaction levels, and I think this is something that
may give you, as you say, an indication. We have there
figures for those who said that they were fully informed
at every stage of the process, net dissatisfied 48 per
cent; that the scheme was easy to understand and
navigate, net dissatisfied 49 per cent; that you had
enough information to make informed decisions, net
dissatisfied 52 per cent; with the HSS overall, net
dissatisfied 49 per cent; with the time it took from
starting your application to reaching the end, net
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an independent panel, et cetera, et cetera, then they ~
that they have a right to an independent appeals
process.
Has that been implemented?
So the Government actually announced its intention to
bring that forward, I think under Minister Hollinrake at
the time, I think in March of this year, it was
announced in the House of Commons. We then had purdah
and we had an election and, therefore, new ministers had
to be appointed and new ministers had to be brought up
to speed, and they understand, and there has been
an announcement in the house, that the new Minister is
also supportive of such an appeal scheme, so that has.
formally been announced. The actual process behind that
has -- is being built, I understand, but, again, Post
Office is willing to help, are helping, to build that,
but that has to be independent. It cannot be tainted
with Post Office, I completely understand that, and that
will be run by the Government.
It will be run by the Government: who is building it at
the moment?
The Department of Business and Trade are building it
as ~I understand as we speak.
Have you made any projections as to anticipated take-up
of that mechanism?
118
dissatisfied 48 per cent; with the amount of
compensation received, net dissatisfied 43 per cent.
As you can see there, that was 1,430 respondents to
that part of the survey. Again, do any of those
surprise you?
What I can — maybe hopefully to help the Inquiry is
they disappoint me, again, but they don't surprise me.
My experience away from the Post Office in remediation
schemes, this sort of feedback is not unusual,
unfortunately. It's just not unusual. It's
remediation. Something has gone badly wrong, for
anything like this to be ~ and, boy, has it gone wrong
in this space, right, absolutely gone disastrously
wrong. And, therefore, any recoup from that position is
always going to be a struggle. So, yes, the figures are
just not good, in terms of, you know, 49 per cent are
overall dissatisfied; 51 per cent might be partially
satisfied
And that's what ~- in a remediation scheme, that's
what you have to hang on to, in terms of the positives.
So very disappointed, absolutely, but not surprised,
simply because of the nature of my experience before
Post Office of remediation schemes.
Thank you. That can come down. If we address issues of
delays, you've already addressed them this morning,
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You've set them out in detail from paragraph 104 onwards
in your statement, I won't bring that back on to screen,
I'ljust go through one by one of the various reasons
you give for delays. The first is the issue of funding
and it's a matter you've already addressed today, that,
for example, panel members are only appointed in June
2020, funding sign-off from the Department for Business
and the Treasury was not until March 2021.
So am I right to summarise it, in your view, one of
the reasons for what I call delay, what you call
process, is issues with funding?
Yes.
Second, you referred to high volumes of applications and
their complexity. You say that the 2,548 claims by
September 2020 was unanticipated. I think that's also
the evidence effectively you gave this morning; is that
right?
Yes.
There's been complexity, such as taxation issues, the
Official Receiver and bankruptcy issues, issues with
creditors. Can you very briefly summarise those kinds
of issues for us?
Well, when you -- any activity where you are required to
engage with a third party then an education process has
to take place and you are dependent on the third party
121
an offer;
"45 outstanding claims which were made between
28 November 2020 and 31 December 2023; and
"87 outstanding claims which have been made since
1 January 2024."
Is this a particularly problematic group of cases?
That's not the feedback I'm getting. I mean, clearly we
need -- there's a separate process for bankruptcy cases.
We need to understand what the bankruptcy court are
interested in, in terms of their take on this and we do
split the heads of loss to ~ heads of loss that we can
pay directly to the postmasters and ones that we need to
be committed to the bankruptcy court et cetera. So it
hasn't been raised to me as a particularly troublesome
area but, again, and I know we will get onto it,
a number of the — and in particular the 87, may be
resolved by the £75,000 process.
Thank you. That can come down.
1'm still going through the various reasons you give
for delay. The third is shortfall analysis. I think
we've already dealt with that, and you've said it could
possibly be sped up by just looking for one shortfall,
rather than multiple shortfalls in the future.
The fourth is later applications, so the scheme
reopened in October 2022, and you had 230 claims waiting
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So bankruptcy is a great example, and insolvency. So
that will always take time to feedback and how you were
going to deal with those cases.
If Lay, the one thing not on that list is the
governance around the establishment of the process, the
drawing up of the principles and we talked this morning
around HSF and the panel assisting us, and indeed, we
need to include the Government in that process as well,
in terms of drawing up all those principles and those
processes and getting them all signed off at a multitude
of levels. I think the last time counted there are 12
stakeholders that I need to keep happy and, in
particular, in this very sensitive space. That is
a challenge for any organisation to be able to do, to
keep those 12 stakeholders engaged and comfortable and
have a say in a process design.
Thank you. Sticking, though, with the bankruptcy issue,
you've addressed that in your eighth witness statement
and perhaps that can be brought up on screen it's
WITN09890800. It’s page 3 where the issue of bankruptoy
is addressed. You say there:
“In relation to claims conceming bankruptcy, there
are:
"56 outstanding claims which were made between 1 May
and 27 November 2020, all of which have received
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to be addressed straightaway, so those are ones that had
been stacked, effectively; is that correct?
Correct.
Following the Mr Bates ITV drama there were 1,345
applications between January and May 2024, so a large
number of applications.
In paragraph 120 of your sixth statement you accept
that you were not resourced for that increase in January
2024. Can you elaborate on that, please, for us?
Absolutely. So until that point, we were effectively
planning closure of the HSS and, indeed, had
a tentatively agreed date with the Government about when
we would close the scheme, simply because we knew how
many late applications we were getting in and,
therefore, could project how long the scheme needed to
last for. Now, we'd have still issued a reminder for
people to come in if they wanted to, but it was clear
from the traction that we were getting and the new
number of claims coming in, that it was -- and they were
‘coming down to a handful a week and, therefore, we were
planning to effectively close the HSS scheme with
Government permission, et cetera, et cetera.
So we downsized the people accordingly, we can't
have people sitting round not doing anything, so both
HSF and Post Office started decreasing the number of
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people on the scheme.
So in terms of your staffing and support, what was your
team size as at, say, December or the very beginning of
January 2024?
Beginning of January, it will be circa 200.
How has that changed since then?
Well, we're now increasing significantly. As I said
earlier, we're now recruiting in order to anticipate the
peak of activity that we have. That said, we are also
automating and, therefore, we are going through
a careful planning process around the people we
potentially release through automation, we're using ~
we're hopefully going to transfer their capabilities,
their abilities to other areas of the business.
If can pick you up though on the recruitment, I think
your evidence was the recruitment process was taking
place now?
Itis,
The increase in numbers took place in January/February
2024. Were you doing anything about those numbers in
the intervening period?
So the -- sorry, the numbers in 2024 are the consistent
numbers that we've had in the RU, Remediation Unit,
across, that's been fairly consistent. It's only the
recent recruitment where those numbers are going up.
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Is it most/some that fall under that?
So, that's a very good question. I would say some
But in the majority of cases, you still have to go back
to the Department for authorisation?
I would say more than that. So, certainly -- and I am
absolutely guessing here — but it feels like sort of
60 per cent still need to refer to further authority
levels. So I hadn't been — I haven't been ~ my
authorities matrix is very complex and I have certainly
haven't been given the mandate to settle at whatever
cost; that would be wrong as well. But I haven't been
given a complete flexibility in that, no.
Do you think the level that it is currently at is too
low, too high, just about right?
In order looking at the cases that we need to
resolve, I would say currently it's too low.
Are steps being taken, have you had discussions with the
Department about this?
Continuously.
Are they open to changing that?
Yes.
Do you foresee that changing soon?
hope so.
The sixth, and one that we're going to come back to and
possibly spend quite a lot of time on it, is the legal
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But in terms of the number of applicants, that shot up,
we saw those figures, after the ITV drama?
Yeah.
Did the number of people within your team shoot up
accordingly, or is it just more recently that you have
tumed your mind to increasing numbers in your team?
More recently, in terms of the impact of those cases
coming through.
Why do you think it is that thought wasn't given to
increasing numbers before now?
Ithas been and, forgive me, I was talking about Post
Office. So don't forget a lot of these processes are
within Herbert Smith and they had downsized and they had
started increasing at that time, so in early '24, they
were increasing their numbers to deal with the peak.
Thank you. The fifth reason you give is agreements
pertaining to tax treatment, interim payments,
eligibility, bankruptcy and insolvency. Under that.
heading, you've also discussed issues with having to
liaise with the Department for Business and Trade. Is
there a figure at which you have delegated authority to
settle cases without having to refer them or refer
matters to the Department for Business and Trade?
Yes
Is that something you are able to give an indication of?
126
representation and legal representation costs. Those
costs have only been available since October 2022; is
that correct?
Yes.
They're not available at the application stage, they're
only available at the offer stage; is that correct?
That is correct.
Could I please take you to page 39 of your sixth
statement. That's WITN09890600, page 39, paragraph 127.
So you say at paragraph 127:
“Some applicants have instructed legal
representation from the beginning of their application
process. While the data shows that this makes a minimal
difference to the eligibility outcome, we have received
proportionately more consequential loss claims as
a result. Although available to all upon request, the
data appears to show legal representation has also been
a driving force in applicants receiving an interim
payment."
So it seems as though those who do instruct their
‘own lawyers are more likely to claim for consequential
losses and are more likely to claim for interim
payments; is that a fair understanding of that
paragraph?
That is a very fair understanding of that paragraph.
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Q. Does that not suggest that the ability to claim for
those might not be sufficiently identified to those who
don't have legal representation, or sufficiently known
by those who don't have legal representation?
A. I think that could also be a fair conclusion. If it
helps the Inquiry, if I may step back slightly, and
I think the Inquiry will recognise that post the GLO and
the activation of this scheme, the term "legally light"
has been used quite a lot because the GLO membership was
so burnt by the legal process, which they were forced to
go through to get the absolute right outcome for them
and for the other post masters as well, and therefore,
their insistence was if -- for any other scheme, would
be legally light.
And that's why the HSS was originally built that
way, to say, "Well, we want to make this a legally light
process and, therefore, you don't necessarily need legal
advice for the submission but you can have legal advice
when the offer is made”. Now ~ and we'll support that.
That was the theory behind why there wasn't legal
advice. Now, I recognise the optics coming out of my
own statements, and instead the YouGov study, et cetera,
et cetera, it's pretty clear that that statement is
accurate, by looking at the data, that applicants who do
have legal representation apply for more consequential
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A. I think that was probably a consideration. I wasn't
there but I think it probably was a consideration.
Q. One thing that you've said at paragraph 139 is that it's
regrettable that the Post Office didn't send the
consequential loss guidance to all potential applicants.
Have you done anything to highlight what consequential
loss is to publicise its availability to those who may
not be aware?
A. Yeah, I mean it's comprehensively covered on the
website, and we direct everybody to that. We also have
a customer care line, in effect a customer support line,
when postmasters ring in, legal advisers ring in, and we
can point them in that direction.
Q._ We'll come to that. So that was your sixth reason,
legal representation issues. Seventh, in terms of delay
or time that things have taken, is the Dispute
Resolution Procedure. That can come down but, at
paragraph 130, you say:
“When an applicant rejects their offer, this is
often the time when an applicant obtains legal
representation [and that] has meant that ... further
information is then presented ... new heads of loss ..."
So when somebody instructs a lawyer, which is only
available as of right once an offer is made, then they
may, for example, provide new information or further
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heads of loss accordingly.
Q. Asa result, do you think a lesson leamnt is that,
actually, legal representation at an earlier stage could
positively benefit the scheme?
A. I think it can but, again ~ and again, please, this not
defensive at all — I struggle, therefore, with why
83 per cent seemed to be satisfied, and the vast
majority of those without legal advice.
Q. When you say satisfied, we saw from the survey results
they weren't necessarily satisfied. What you mean is
83 per cent accept the offers?
A. You're absolutely right, and I apologise: they have
settled.
Q. Yes.
A. And I just struggle with that sometimes. But I'm sure
you will go on to the fact that the ones who are legally
advised at the offer stage and beyond, their average
redress is greater, as well, and I absolutely get that
as well
Q._ I think you've said that the background to that is that
the subpostmasters wanted it to be legally light. Is it
not also part of the story that the Post Office and
Department for Business, or whoever else was involved in
designing the scheme, may also have wanted to avoid
having lawyers at an early stage in order to save costs?
130
heads of loss. That again builds in time to the
process. Reflecting on that, doesn't that justify the
instruction of lawyers at an earlier stage because, if
you had that information or heads of loss at an earlier
stage before the offer is made, that might avoid the
delay or time taken after the offer is made.
A. I cannot see a flaw in that.
Q._ I think you say in your statement that it elongates the
time that it takes to settle as a result of --
A. Correct.
Q. — that new information.
Moving on now to the fixed sum offer and top-ups —
SIR WYN WILLIAMS: Before you do that, Mr Blake, have you
left the topic of appeals because, if you have, I just
want to ask one or two more questions about that before
you start another topic.
MRBLAKE: Yes, please, sir. Please do.
SIR WYN WILLIAMS: Mr Recaldin, perhaps we could have
paragraph 139 of Mr Recaldin's witness statement on the
screen, and that's at page 42. This is simply to give
us a reference point, really, Mr Recaldin, for the point
I want to pursue with you. You'll see that the second
part of this paragraph actually deals with what,
an appeal may deal with.
MR BLAKE: We're just waiting for it to come up on screen.
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SIR WYN WILLIAMS: Sure. (Pause)
Right, so I'll come to this paragraph in a second.
Let me just ask you one or two basic questions to make
sure I've got it right. The possibility of an appeal
process was first mooted earlier this year and not
before that; is that correct, Mr Recaldin?
A. There was a recommendation from the Advisory Board,
forgive me, Sir Wyn, I don't know when, but it was
before March this year, and there was a recommendation
from Post Office about the same sort of time as well,
for an independent appeals process.
SIR WYN WILLIAMS: Right. Then the Government announcement
was March this year?
A. I think so, yes, that was Minister Hollinrake.
SIR WYN WILLIAMS: That's fine for these purposes. I'm
right in thinking, from what you've said, that the
appeal process will be both formulated and administered
by the Department, not by the Post Office?
A. You're absolutely correct, Sir Wyn.
SIR WYN WILLIAMS: Right, but this is now coming to the nub
of what I want to ask you about. Since March 2024 to
the current date, has the Department, in inverted
commas, consulted with the Post Office as far as you are
aware about the grounds upon which an appeal might be
brought?
133
there still a debate going on about which category of
HSS claimant might be eligible to appeal?
A. think that is being discussed. Whether or not it is
open for everybody or whether there -- my words,
Sir Wyn - whether there's a filter on that on what.
types of applicant can apply to it, I think that is yet
to be determined.
SIR WYN WILLIAMS: All right, well, when Mr Creswell gives
evidence on behalf of the Department, he may be able to
place more flesh on this particular bone. But, doing
the best you can, does it look to you as if we are some
months away from formulating both the criteria for
bringing an appeal and the process for bringing
an appeal, and, therefore, some months away from this
appeal process beginning?
A. Sir Wyn, on the limited engagement I've had with the
Department on this, I understand there is a strong
appetite to have something up and running in the new
calendar year.
SIR WYN WILLIAMS: Well, those are very carefully chosen
words, if I may say so, Mr Recaldin, because something
up and running in the new calendar year could span from
January until December, couldn't it?
A. Okay, let me be fairer to the Government's Department
for Business and Trade. Again, the limited engagement
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A. No, they -- sorry, since March -- yes, they have
recently, Sir Wyn.
SIR WYN WILLIAMS: When you say “recently”, do you mean
within the last few weeks, or what?
A. Ido mean within the last few weeks.
SIR WYN WILLIAMS: Right. So there is still work to be
done, if I can put it in that way, in formulating what
might be regarded as at the heart of any appeal process,
namely upon what grounds can you bring an appeal?
A. Correct.
SIR WYN WILLIAMS: Right, okay. I use this paragraph, 139,
because in it you say that the Post Office hopes that
the appeals process might assist with remedying people
who were unaware that they could bring, say,
consequential loss claims?
A. Yes, Sir Wyn.
SIR WYN WILLIAMS: Yes. So there's still a great deal of
uncertainty, am I right, about the basis upon which any
appeal can be brought?
A. There is uncertainty on the basis of which appeals can
be brought currently, yes.
SIR WYN WILLIAMS: Does that uncertainty extend to having to
decide whether the appeal process will be open to
everybody who has, thus far, participated in HSS,
regardless of whether they've settled or not, or is
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they've had with me and my team is that they are
certainly under pressure in order to produce a process,
and the articulation, the verbal articulation they have
is that they are under pressure to be able to do
something, to announce something in terms of a process
in Quarter 1 of the next calendar year.
SIR WYN WILLIAMS: All right, thank you. I wasn't trying to
tease you, Mr Recaldin
A. No, that's fine.
SIR WYN WILLIAMS: Do you know if -- if you don't, please
say 0 ~ but do you know if there has been any
consultation between the Government and any groups
representing postmasters about both the likely grounds
of appeal and the process generally?
A. No, Idon't.
SIR WYN WILLIAMS: Fine. All right, thank you very much,
sorry, Mr Blake.
MR BLAKE: Not at all.
Thank you, we'll move on to the fixed sum offers and
top-ups. As you've said already today, the average that
was paid was £52,000 and, from 9 August this year
a fixed sum offer of £75,000 was introduced and is also
provided as a top-up to those who had already settled
for a figure below that. So we have top-ups to those
who have already settled that increase the amount that
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they are provided up to £75,000; you have an offer to
those who haven't yet settled for 75,000 ~ for any
figure, an offer of £75,000, and you also have -- are
communicating this offer to those who haven't yet
applied for any redress; is that correct?
Correct.
Can you briefly explain the background to the 75,000 and
whose idea it was and where it came about?
So the background to the 75,000 was effectively
a minimum payment introduced into the new GLO scheme,
which, as we know, is operated by DBT, the Department
for Business and Trade. The Government recognised
straightaway, as the Post Office, that if that was being
offered in the GLO space, it would be absolutely
appropriate to also offer the same in the HSS space.
But, as ever, there are differences between the GLO
scheme and the HSS scheme. So we are grateful, willing
to adopt that but, of course, we had to incorporate that
new processes because the HSS cohort is a different
cohort to the GLO cohort.
If you accept the 75,000, are you foregoing other rights
and including, as Sir Wyn has said, in terms of those
potential appeal rights, might you be foregoing those
appeal rights?
So ~- and this is why I articulated the differences
137
communication, I accept that, to say, "Here is your
top-up, here is your offer of 75,000, however, but by
taking it you are waiving your rights to appeal process
which isn't built yet." And I understand the optics of
that. I absolutely understand the optics of that, and
we have spoken at length to Government about those
optics; I call them risks. And the Government are aware
of our concerns around that. Nevertheless, everybody
felt it's still appropriate to launch the £75,000 scheme
accordingly.
So an individual may accept the 75,000 figure now, in
the knowledge that they are foregoing an appeals process
that is not in fact yet developed?
Correct.
You've also addressed in your eighth witness statement
the letters that have been sent out, you say 266 letters
have been sent out to those whose applications have been
recently received and the Post Office considers may be
appropriate; 54 of those have already been paid. Can
you tell us very briefly about this assessment. How
have you assessed that certain current applications may
be appropriate for that £75,000?
Well, because of their claim, sorry. We've looked at
their claim and their claim appears to be under 75,000.
So that feels like an opportunity. So we've ring-fenced
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between the GLO and the HSS is yes, you're absolutely
right, as you've mentioned earlier, by accepting the
75,000 you're waiving your rights to a future appeal.
So you would call it delay and I understand that. One
of the reasons for delay on the 75,000 was we had to
take a step back and say while, actually, you know, how
are we going to operate that in the HSS scheme because
what we prefer to do is one communication to all the
postmasters and past post masters who had not applied, to
say, "Here is your opportunity to apply, here is what
the £75,000 scheme looks like, here is a closing date,
and here is the details of the appeals process”.
So if you decide to accept the 75, you are waiving
your right to this appeal process and this is what it
looks like.
Now, because of the timing issue, and I have to say
that the election has probably got something to do with
it that appeal process was not built sufficiently enough
to be able to be communicated and, therefore, all we can
talk about is a future appeals process that is going to
be built, and -- but in my view, quite appropriately, we
still felt we had to get out there with these offers.
It's all about timely redress because we were falling
short on the timeliness of this redress.
So, therefore, it's not the best piece of
138
that population, that cohort, and we've proactively gone
out to them and said, "Would a 75,000 offer satisfy your
claim?" We've had a very interesting and a very prompt
response to that, which is really encouraging, and we
continue to do that with the existing cohort. And we've
got a positive response back in many cases, and we
tured -- so as soon as they signed their offer, they
are presented with an offer, as soon as they sign, we
pay within ten working days.
Letters have also gone out to applicants who have
received but who haven't accepted offers of less than
75,000; is that correct?
Correct.
There is also a mass mailout that either was just about
to take place or has ~
Has taken -- we started it, i's up to 30,000. I can't
send 30,000 out on the same day but we are ramping that
up so we're at hundreds now. This week we'll send
thousands, next week we'll send -- so we're ramping all
that up to cover the 30,000 population —
To be sent to 30,000 people?
Circa it depends on that. We were doing all the data
analysis on the population, yes, so up to 30,000.
Thank you. In terms of the top-up payment those letters
are also being sent out to those who settled for less.
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than 75,000?
Yes.
Again, have they gone out, are they about to go out?
They've gone out.
They've all ~
They've gone out and, on that population alone, we've
paid out 87 million.
I think you have said in your eighth statement that
1,194 top-ups have been accepted. Presumably that's
also increased since ~
Yes.
-- the date that that was written?
Yes.
You have noted that 85 per cent of settled claims have
settled for less than 75,000. There might be
a suggestion that those delays that we've seen in the
process in 2024, you don't call them delays, but we saw
the figures, the charts, the bars, quite high, as at the
current period. It might be suggested that there is
a delay being builtin to the existing claims in the
hope that people will accept those £75,000 payments.
What do you have to say about that?
I think that's fair. I think there has been
an identified -- an exercise ~- I know there has been
an exercise that has gone through on that population to
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new thing, is this something that you would be
comfortable with accepting, given you'll be waiving your
rights to an appeal, et cetera, and if you hear all the
details and if you're comfortable with this, let us know
and we will immediately make you an offer of 75,000".
So they can interject into that process at any time
they want.
Do you think that that is fair to those that are
awaiting an imminent panel hearing, for example, or
panel decision, that their cases might now go back
slightly in the queue because you're waiting on the
response to that £75,000 offer?
I don't think it's as timely as that. I don't think
that would be a delay, and they have the right to
continue with the process ~ or not, we're not stopping
that process; we're just giving them another option
which they might wish to consider. So I don't see that.
And again, if they're queueing up for panel, and
I actually see, if they are ~ if 75,000 is a good offer
for them, I still would see that as being a quicker
redress than going to panel and waiting the 30 days from
panel to offer letter, et cetera, et cetera.
But just so we're absolutely clear, there isn't, is
there, a conscious decision on behalf of the Post Office
to not take forward those cases?
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say, "Is there a part of this population who think will
be appropriate to offer the 75,000 and, therefore, once
we've got the funding in place, we can jump on that
straight away?" Absolutely, yes.
But do you think that has actually resulted in a delay
to the processing of their applications through all the
stages that we've talked about?
No, I think it's actually sped it up, if I may be so
bold, because they won't have to go through the full
process, the full legal analysis, the full HSF review,
and the full panel session. So hopefully we go slow to
go fast on ~
But those that are awaiting a panel session, for
example, awaiting those various stages and meetings, is
any consideration given to the fact that it might be
that those are cases that will accept the 75,000 so we
won't be progressing them to those various stages?
Absolutely.
There is?
Yes.
Can you expand on that, please?
So, again, we look at the entire population that have
made a claim and, if we believe ~ if the claim is for
under 75,000 or we believe they may settle or under
75,000, we will approach them all to say, “This is the
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No. So only with - so only with their permission.
Only with the postmasters' permission.
Can we please turn to BEIS0000763. This is the minutes
of a meeting with Minister Hollinrake on 30 April 2024.
We can see there that you are one of the listed
attendees. If we scroll over the page, please, there's
a section on compensation. We have a couple of versions
of this document. There is a slight change made to the
minute, and I'll take you to that, but there's
a discussion of compensation here, and it records as
follows:
"Simon ...”
Is that you?
That will be me.
Yes:
"Simon explained the message from us on OC2 ...."
Is that the new Overturned Convictions process?
HORS.
*... happy to help. He noted that they are
communicating with Charlotte and Car's team. Need to
clarify within acceptable time about what that
disclosure looks like. Full disclosure big job and very
expensive ...
[Minister Hollinrake] noted that he was hopeful
that a lot of these people take the fixed sum award
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route anyway."
You say:
“... even toa place where no disclosure at all."
Then this is the bit that is changed in the
subsequent notes, it says:
“How can I advise my client that £600,000 is good
enough given no disclosure.”
The amendment in the later version, which I can take
you to, is making clear that you're saying that
claimants will say "How can I advise my client"?
I'm trying my best to identify a risk that the
Government might face in terms of something that a legal
adviser might say to them, "How do I know that — how
can I advise my client if £600,000 is a fair offer if
Ihave no disclosure? I don't know’.
This is not in relation to the current scheme we're
looking at —
No.
-- but I just want to take you to some words from you
within that meeting. So we have what you've said there,
and it says:
"Simon said that they are hoping to help with
capture. Open and willing to let accountant in to have
a look. Also they are keen to see HSS Appeals that,
whenever it is ready."
145
. even to a place where no disclosure at all.
[This is the risk that you're highlighting] Claimant
lawyers may ask, ‘How can I advise my client that
£600,000 is good enough given no disclosure?"
Doesn't that also apply to the 75,000 figure that
we're talking about in relation to the HSS scheme? If
your plan is for that to be a quick process, doesn't the
risk that it's not going through that disclosure
process, that it somehow bypasses that process, isn't
that risk present here?
Yes.
Is there anything that you plan on doing about that
risk, or is that just a risk that —
I'l articulate that risk in a slightly different
anyway, if I may, that is legal representation at the
claimant stage, effectively. I think you called it
disclosure, I say it's legal representation at the offer
stage. I'm sure the Inquiry have seen the documentation
around this. Post Office have pushed hard on this with
DBT, and I'm sure Carl will support that as well. The
evidence is there. We pushed hard on this in terms of
wanting to have -- understanding the optics of having
legal advice at the claimant stage from the
perspective -- DBT, currently, their thinking is not
aligned with that, in terms of funding — in terms of
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Minister Hollinrake says:
*... still waiting for HMT I think?
“Carl [Cresswell] agreed with the Minister and noted
that we are working with [the Post Office] to see if we
can do the £75,000 top-ups (not new cases) in the
meantime.”
That is the issue we've just been discussing,
I think
Correct.
~ in relation to the appeals process and the £75,000
offer.
You say there, at the penultimate entry:
"Simon current proposal on the new £75,000 is to do
it in-house and not use the services of [Herbert Smith
Freehills).”
Is that still the case?
As in my statement and as advised earlier, yes.
Thank you. If we look at the amended version, that
BEIS0000764. It's not significantly amended but, if we
look at the bottom of page 2., we can see there that the
issue you post is:
"Kevin noted that he was hopeful that a lot of
postmasters whose convictions are overturned by the Bill
will take the fixed sum award route [away].”
You respond
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funding that ~ everything has to be funded of course
and it’s taxpayers money -- in terms of funding that,
and everything is under continuous review but, at the
moment, they're saying they want to stick to the current
process.
So is your evidence that in respect of the £75,000 fixed
‘sum offer or top-up, the Post Office's position is that
it will be preferable to have legal advice at the early
stage, whereas the Department for Business’ position is
different to that?
I don't want to elaborate on it, on a difference of
policy between -- that's not -- my job is to get redress
out to postmasters as quickly as possible. I really,
really cannot afford, and don't want to get involved in
sort of internal politics, but I need to answer your
question, okay. And the Post Office's view has always
been in this cohort that we should offer legal advice,
to pay for legal advice, in the offer stage, ie
learning from our lessons from the original cohort.
You say at the offer stage, do you mean prior to ~
Prior to the — at the claim stage. At the claim stage.
And the evidence is there and I'm sure the Inquiry have
seen it, the number of times I've written to the
Department to ask them to reconsider that position. And
they haven't.
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Q. Do you know why: is it purely funding; is it something
more than that?
A. I do believe -- and I think I articulated before --
I do--I understand, I do understand, I try to be
balanced. I understand that, if somebody has got
an offer and people who talk to me regularly will be
bored of me saying this story ~- if people have got
an offer of 40,000 and they've settled and they're
satisfied, I appreciate your definition of satisfaction
is different from mine — they've settled at 40,000, and
then they get a letter saying, "We want to top that up
to 75,000, sign here", I can understand why they may not
need to necessarily think twice about obtaining legal
advice. I get that and, certainly, the process is not
designed to encourage legal advice.
And so, you know, to make it simple and slick, fast,
and get redress out of the door, which is my job, I can
see how that can work. I worry when the legal advisers
come to me and say, "Hang on a minute, how can I advise
my customer — my client, whether that is a full and
fair?" And that's a risk to me.
Q. Thank you. That can come down. Thank you.
Moving on to interim payments. You've addressed
that at paragraph 22 of your sixth statement. I don't
need to go to the actual paragraph. At first it was
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If, essentially, people are getting £75,000 as of right,
albeit risking certain rights such as appeal rights,
does that justify a greater interim payment to those who
contest the 75,000 and say that their claim is worth
more?
‘A. That's where the jeopardy comes in and it's important
the Inquiry understand that, is that, if they decide not
to take the £75,000 offer and subsequently their claim
has gone through the independent panel and et cetera,
et cetera, and comes out at less than 75,000, they'll
get the lesser figure.
Q._ Reflecting on it, do you feel that there should be or
shouldn't be some sort of increase in the standard
interim payment for those who are contesting, in light
of the fact that they are contesting, but they have
rejected a £75,000 offer?
A. Well, it depends if they've got an offer or not. So if
they've got an offer already —
Q. They get 100 per cent?
‘A. [have strong views. As soon as an offer goes out, it's
not Post Office money, it's not Government money, it's
the postmaster's money. So as soon as that offer goes
out, they're entitled to the lot. The dilemma I think
you're articulating extremely well is the dilemma of
when you haven't got an offer, the 75,000 has been
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£10,000 limited to those in poor health or suffering
from financial hardship; is that correct?
Correct.
Those limits on availability were lifted in October
2022?
Yeah.
Since July 2023, interim payments of up to 100 per cent
are available to applicants who have received an offer?
Correct.
Does that mean 100 per cent of the amount you're offered
you will receive straightaway, irrespective of whether
you contest it further or not?
Yes, if you ask for it. Yes.
Thank you. What is the situation in respect of those
who haven't received an offer in respect of an interim
payment? How is that calculated now?
So we do offer interim payments prior to offer, upon
request, in particular in hardship cases, but it's not
limited to hardship cases. And we have a process where,
as long as we've identified the shortfall, i's the
amount of the shortfall we go up to, that we can pay
out -- we don't get many requests for pre-offer interim
payments. In fact, very, very few, for pre-offer
interim payments.
How is that now going to work with the £75,000 offer?
150
rejected, so that's a pre-offer interim payment and,
therefore, we would go back to the shortfall
Exactly.
Yes. That's right.
Looking at the £75,000 figure that's now going to be
offered, do you think limiting those interim payments
just to the shortfall figure is sufficient and is right?
I think it’s consistent, and it supports the jeopardy
that Government clearly want to put in place to say,
"You've got an opportunity of 75,000 but if you don't
believe that's sufficient, there is a risk that once the
case has gone through the full assessment, the risk you
face is it might be less”
Thank you. Can we bring up on to screen your sixth
witness statement at page 56. It's paragraph 167.
I just want to understand some figures that are given
there about interim payments.
Thank you, so it's page 56, paragraph 167. You say
there:
“In total, 474 interim payments have been paid to
312 applicants (7% of applicants). Of these Post Office
have offered 174 single payments equating to 100% of
their offer, with the balance being partial payments;
and 23% of complex applicants received an interim
payment compared to 10% for standard applicants.”
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Can you assist us, more interim payments have been
made than there are applicants. Can you help us with
that, please?
Absolutely. It is confusing and apologies, that is
a confusing paragraph. So an applicant can have number
of interim payments. So they -- even if they may have
an offer and they may ~- and they offer, let's say, is
£100,000, they say, "Can I -- I'm going to go into
dispute. In the meantime, can I have 50 per cent of my
offer?" Of course you can, so we pay out 50 per cent,
and they then may come back a few weeks later and say,
“Well, actually, can I have another £25,000 please?"
Of course you can: you can have up to 100 per cent
of your current offer.
Now, during the dispute process, for example, the
offer might go up a few times and, every time that offer
goes up, they're entitled to more -- another interim
payment, up to that offer amount. So that's why there
are more offers than cases.
Is there a number that you have for interim payment
applications that have been refused? I think that
7 per cent of applicants is referring to total
applicants, isn't it -
Yes.
-- it's not referring to applicants for interim
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very clear about the interim payments, but I do
understand we could always do more publicity and prompt
it more. I do accept that feedback.
If we scroll over the page, please, we can see a chart
there for the average days from interim payment requests
to payment. So that's the processing time of those
interim payments. We can see, even this year, it's
nearly a six-week wait from request to actual payment.
We've seen again the number of applications increasing
That's something we looked at earlier, in terms of the
2024 figures. What gives you confidence that itl
either stay the same or reduce?
As advised in my statement, the — we are going to adopt
much of the automation and efficiencies around the
£75,000 process, this will come down significantly.
I won't take you to our expert report again but it's
page 58 of that report. Lots of red again, in terms of
satisfaction levels with the interim payment process.
I assume your answer to that is the same as before, that
you understand it and something you recognise?
And disappointed.
Yes. Retuming to legal fees more broadly now ~ that
can come down, please -- the BAT ~- below assessment
threshold -- cases, are they provided with any legal
advice?
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payments. Are there a large number, a small number,
some ~
Small. Tiny.
A tiny number that are refused?
I think, to be fair to them, again, a lot of these are
legally advised, and the legal advisers understand
exactly the process and, therefore, they are advised
absolutely appropriately.
And if we scroll down we can see there in paragraph 168
you say:
“Overall, 4% of those without legal representation
have received an Interim Payment and 64% of those with
legal representation have received an interim payment.”
A very significant gulf between those who are
legally represented and those who aren't. Again, that
suggests, possibly, that the message isn’t being
communicated effectively to those without legal
representation. What's your view on that?
I think that's always going to ~- I think that's a fair
observation. I'm — I think the availability of interim
payments is well known. It is on the website,
et cetera, et cetera. It is out there and I know every
case that goes into the dispute resolution process, they
are all written to to say, "These interim payments are
available to you". In particular around hardship, it's
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So they are made an offer, and therefore at the offer
stage, they can still have -- yeah, they can still have
legal advice. They're all the same.
‘Are you aware of what kind of proportion of those cases
actually take legal advice?
No. I'm not. But, of course, that has now been taken
away by the 75,000.
Yes. You've explained the background to why legal fees
are only available at the offer stage, or why that was
formulated. Previously, there was £1,200 for legal
advice where the offer was less than the sum claimed; is
that correct?
Yes, that's right, yes.
There was a small amount --
Yeah.
~ only £400 ~
400, yeah ~
~ for where the offer was for the entire sum or for
more. Those caps were removed from all offers made from
10 October 2022; is that correct?
That is correct.
Applicants are now entitled to what's called reasonable
legal fees. Is that different to legal fees available
in the GLO scheme, where there are fixed sums for legal
advisers?
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We try and work collaboratively to the ranges in the
GLO, and we have used those, yes, but we still base ours
on reasonable, so there have been a number of occasions
when -- and I have been given authority to exceed
whatever reasonable is, but I take legal advice on
those. So we are still -- we use — we do use the GLO
guidelines as guidelines but there we are still -- you
know, we have reasonable fees.
If we could go back to your sixth statement, please, and
tum to page 10. At paragraph 27, you give figures for
the average legal fees. It may be quicker if I just
read it, It says:
“The average legal fees prior to 10 October 2022 was
£3,044 and after that date it was £4,575."
Can you assist us with that difference, why you
think it is that those figures have changed?
Just the submissions from the legal advisers. That's —
and very comfortable with them.
If we could please turn to page 66, paragraph 184.
Thank you. We see there that the take-up of legal
representation is low: 12 per cent
Yeah.
-- in respect of those that have had offers; 16 per cent
if you include legal support rather than legal
representation. Why do you think that take-up is low?
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Office on its own isn't coming up with the right
figures?
I wouldn't call it pushing. I'd call it representing,
Why should that be necessary to drive the figures up by,
in some cases, double?
Because there representing their clients and their
clients are providing a position for them, which they
are asking to be represented. I do see it as an issue.
Again, I ~ in my mind, I struggle with this.
I absolutely get it and that's the reason one of the —
the major reason why Post Office recommended, following
Sir Wyn's prompt, around an independent appeals process
where people, if they feel dissatisfied, now they see
these statistics, the transparency that this has
provided, and thank you for doing it, actually do they
feel they have an unfair offer, subject to Sir Wyn's.
challenge around, well, what's the parameters of that
appeal, who qualifies for the appeal? If, in the way
that I've articulated to the Government and Government,
you know, have accepted this, is that if they believe —
and the Advisory Board more importantly have said
this — if they believe they've had an unfair outcome
and seen these stats, they may feel they've had
an unfair outcome, then they have the option for the
appeal process.
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I really don't know.
If we go to page 63, please, paragraph 181. If we
scroll down, you say there that:
“In almost all instances a legally represented
applicant receives a higher offer even within the same
applicant types ..."
Correct.
Can you see an issue there?
Absolutely.
What's the issue?
Well, they are -- claimants are generally ~- the vast
majority, are not taking up the offer of legal -- of
free legal advice, funded by Post Office and, yet, the
stats are clear that, when they do have legal advice,
they get higher payouts. I absolutely understand that.
If we go to page 64 there's a table. We see there, in
2024, for example, in complex cases, similar in 2023,
it's almost double the same figure where those
individuals are legally represented. Is that something
that you were aware of before compiling this chart?
I think this makes it much more transparent but yes,
Iwas aware.
Yes. Does that, in some ways, suggest that
representations further pushing from people representing
individuals is necessary and that, actually, the Post
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One thing we spoke about earlier was legal advice at
an early stage. In the GLO schemes and the Overturned
Convictions Scheme, we understand that solicitors can
commission a report such as a forensic accountant
report —-
Yes.
~ from the outset. Might that, first of all, speed up
this process and, secondly, as you've highlighted, have
an impact on the final figures?
It might.
Why do you think there is that difference of approach?
I think there is an aspect of trying to keep this as
legally light as possible. I understand that. Much —
a lot of the feedback ~ in fact, I noticed in the
YouGov survey as well, there's a lot of feedback about
this is too legalese, you know, why can't we just cut
a deal on this, and make it a much more simpler? I get
that from many of the legal advisers as well: why do we
have to go through this process, why can't we just go
and shake hands on things? So I'm not trying to counter
it because I'm absolutely agreeing with you, but there
is this other aspect stil, that I still grapple with,
about how can we make this as simple and unlegalistic as
possible?
Thank you. Before we take our afternoon break, I'm
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going to take you to that letter from Dr Hudgell that
we've spoken about. It's HUJ00000007.
This the new bundle yes?
Yes. It's the letter of 23 October this year. So very
recent correspondence between you
Thank you. The letter includes various examples of
the differences between original offer and revised
offers. If we scroll down, please. These are in
respect of those who Dr Hudgell represents. We see
there alleged at number 2, for example, the original
offer 46,000 in December 2021, a revised offer of
140,000 by November 2022. Number 4, we see from £4,000
in the original offer to £133,000, within the space
of ~- i's taken two years, the original offer July
2022, and the revised offer September 2024.
If we scroll over the page, number 8. We have there
an original offer of 363,000, and revised two years
later to 649,000. Very significant increases in these
figures. Number 11, 298,000 to 421,000. 13, 260,000
again to 420,000. So quite similar increases in those
11 and 13, from 200 to 400 thousand.
Do you accept that they're big changes in these
offers, and the revised offers?
I absolutely accept them and think it's great.
Number 9, we see there the original offer 42,000 in
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would help the case. Many of these cases of course
have -- all the cases have originated from the
independent panel. That's where the original numbers
come from and many of these cases go back to the
original panel so again there's -- they have worked
within their terms of — the panel work within their
terms of reference to come up with these new offers.
So they are basing it on evidence that has been
produced by the postmasters and the legal advisers. So
this is a process taking too long, but is working.
It's working for those who are, in this case,
represented by Dr Hudgell and represented by others.
But if we can turn back to the YouGov report, that's
EXPG0000007 and, if we look at page 52 of the YouGov
report, it addresses legal advice.
Page 52. We have there only 33 per cent of
respondents said that they had been informed of their
right to obtain legal advice. Only 10 per cent were
provided with information about how they could contact
a legal representative. If we look at the bottom of
page 52, the author says:
“Reflecting the low awareness of the right to obtain
legal advice, just over one in eight (12%) actually
received legal advice during the application process.
Amongst those that did, 11% received financial support
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August 2022, 45,000 by May 2024, and we understand that
that now stands at £171,592. So a dramatic increase,
despite the fact that that figure not really changing
very much between 2022 and 2024. What's your view on
that?
My view on that is that the legal advisers are doing the
excellent job that they do and they're gathering the
information required for -- to enable the panel, in many
cases, if not Post Office, to increase the offers based
on the evidence that is provided with the help of the
legal advisers, maybe by forensic accountants or by
medical reports, et cetera, et cetera. So I think the
legal advisers are doing exactly what they should be
doing and doing a brilliant job at it.
Isn't something going a bit wrong, though, that there
have been such dramatic leaps in those figures taken so
long to negotiate?
So the --I think there are two separate issues here.
In something going wrong, no, it's going right, because
the evidence has been found in order to increase those
offers to get to the fair redress. Timeliness is
a separate issue, and I accept that challenge about how
long it's taken. But -- and, you know, this is
a two-way street here. We like to work collaboratively
with the legal advisers, and make it clear to them what
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that they felt was sufficient, but 63% did not receive
financial support.”
Then we can see the chart over the page, please.
Actually, yes, figure 39 "Received financial support for
legal advice during the application process”, the
‘overwhelming majority didn't and that's reflected in
your own figures.
If we go, please, to page 55. Even in respect of
those who received financial support for legal advice
when they received their offer, you have there
29 per cent saying no financial support received for
legal advice when they received their offer, there is
anet "Yes," but 23 per cent of those felt that the
financial support was not sufficient.
Looking at these and looking at your own figures,
and looking back at that letter from Dr Hudgell and the
impact that lawyers have had in that particular case,
and I think you've really already given your evidence on
this but do you think something is going a little wrong
there in respect of the availability, the take-up of,
legal advice, and the impact that it may have on those
who may have received offers, or those who are awaiting
offers?
Well, I think the first sentence, on page 52 of the
YouGov survey, it says, "One in three, 33 per cent,
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recall having been informed to their right". So that's
their recollection of being informed about their right
to obtain legal advice. The evidence which the Inquiry
has seen is that everybody was offered legal advice at
the offer stage. So this is — and — and, again,
I don't want to project this sort of corporate image
because it's not a corporate image, it genuinely is not,
but the offer of legal advice is there at reasonable
costs. And I haven't turned anybody down in terms of
the amount of legal fees. I have had the odd discussion
with legal advisers about their bills, yes, but we've
never fallen out about it.
And so the offer is always there. It's the take-up.
is the issue, and I think the challenge, quite rightly,
from the Inquiry, should be that it is how much have you
pushed the fact that -- the benefit of legal advice?
Maybe that's the challenge that I should go away and
consider, because it's clear from the stats, as I've
said earlier, my evidence is my evidence, is in that
there is a ~- there's clearly a benefit of it happening.
But to be clear, the offer is there.
How do you think you can improve that situation?
By being more upfront, as I possibly can, by making sure
the clients are -- yes, they are my clients -- my
clients are aware of that opportunity. Again, I still
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a peak of late applications, et cetera. So the date
that was originally discussed was actually March 2025,
and we have been advised by Government that that might
still be considered, but let's not take that as a date
that will be publicised. So yet to be determined.
Is that a date for potentially the applicant process to.
stop or the entire scheme to finish?
Applications to be in by.
Thank you. One thing you've mentioned is the postmaster
contact centre. You've addressed that in your witness
statement. You say it opened in September of this year.
Can I clarify is that simply for the HSS Scheme or for
all schemes?
It's for whatever the postmasters want so it! be for
all the schemes, currently it is predominantly to do
with HSS because that's the incoming, but we also
mandate outgoing calls, as well, to be helpful and
proactive. In the fullness of time, it will absolutely
be anything we can do on the OC side as well
What steps have you taken to publicise that contact
centre?
It's available on the website and available via
correspondence.
Would it surprise you that some subpostmaster Core
Participants were not aware of this centre until
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struggle, I've got an 83 per cent acceptance rate.
I need to grapple with that, and where people appear —
I'm not going to use your word any more ~ they appear
to want to settle at that rate.
MR BLAKE: Thank you
Sir, that might be an appropriate moment to take our
mid-afternoon break.
SIR WYN WILLIAMS: Yes.
MR BLAKE: If we come back at 3.40, please.
SIR WYN WILLIAMS: Certainly, yes.
MR BLAKE: Thank you
(3.25 pm)
(A short break)
(3.40 pm)
MR BLAKE: Thank you, sir.
Mr Recaldin, my last question in relation to the
Historic Shortfall Scheme concems an end date: when do
you expect it to close; is there a date fixed; and has
a date been publicised?
A. Expectation, I don't know. Is there a date fixed? No.
No, there has been discussions prior to the election
about when that date might be, and we did propose a date
which was sort of tentatively ~ nothing had been.
agreed, nothing has been accepted but it was understood
when that date might be. But then, of course, we had
166
receiving your witness statement?
A. Itwouldn't surprise me at all
Q._In light of that, is there anything that you have in
mind that you could do to publicise it?
‘A. So in the mass mailing which we've currently started,
absolutely included in all of that, so there will be
huge publicity because of the up to 30,000 letters going
ut, it's included in that, and they all point to the
website as well in terms of when that -- where that
number is available, including — and also in the
outbound calls they are effectively publicising their
availability to take inbound calls as well.
Q. Thank you. I'm going to move on now to the overturned
convictions redress. It's not known internally at least
as the Overturned Convictions Scheme; is that correct?
A. Correct.
Q._ On 11 December 2020 the first six convictions were
overtumed by Southwark Crown Court and then the
Hamilton judgment was on 23 April 2021. By 22 August
this year, you say in your seventh witness statement,
I think, 111 appellants had successfully appealed their
convictions and therefore fell within this scheme; is
that correct?
A. Thatis.
Q._ They fall within this scheme and not the Historic
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Shortfall Scheme because, as we saw in the eligibility
criteria, it doesn't include those with convictions?
Correct.
There is, however, another category also included in
this redress — I won't call ita scheme. What do you
call it if you don't call it a scheme?
Process.
Process, redress process. That is those who were
prosecuted but not convicted and who aren't postmasters
and, therefore, also fall outside of the Historic
Shortfall Scheme; is that right?
Correct.
What about those who weren't prosecuted but who received
cautions?
They are included in that cohort, prosecuted not
convicted. They are within that cohort.
Not convicted extends not just to those who had a trial
but also those who simply received a caution?
Caution, correct.
In terms of Government funding, you've said in your
witness statement that that became available in July
2021; was that difficult to obtain?
No.
That led to interim payments of £100,000 at that point
in time ~
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Company provided the postmaster meets all of the
following criteria:
"i, Their Horizon-related conviction has been
overtumed by the courts ..."
That's why we see the scheme doesn't involve those
that recently received the change following the
legislation:
“ii. They do not belong to the class of post masters
whose convictions were overturned but were not opposed
by the company on public interest grounds..."
Now, at this stage, that was an additional criteria,
that it couldn't have been any of those cases that
weren't opposed by the public interest on public
interest grounds. Can you briefly explain your
understanding of that?
So public interest cases -- and there are five of
them -- so these are cases that go to the Crown Court at
Southwark and, when the case is made to it's ~ a quirk,
almost, of the Southwark court, in that the cases that
go forward, you can either support the appeal, or you
can -- the alternative is a retrial and, clearly,
a retrial is not in the public interest and, therefore,
by default, you are going to a case where they or you
are supporting the appeal of the conviction. Or you're
raising no evidence against it.
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Yes.
— from that point in time. Then there was a second
funding agreement in December 2021, again, was that
difficult to obtain?
I wasn't around so I don't know but my understanding was
it was again, it followed the process and it was put in
place,
Could we please turn to POL00448914. As you say, this
was before your time but this was the funding commitment
as at 22 July 2021, communicated by the Department for
Business, Energy and Industrial Strategy, as it was
known then. If we scroll down, please, it says:
"The funding commitment letter confirms that the
[Department for Business] will provide funding for Post
Office to make interim compensation payments of up to
£100,000 to each postmaster, branch manner and/or
assistant who have their criminal convictions overturned
by the Court of Appeal or the Crown Court due to.
unreliability of evidence obtained from the Horizon
System operated by the company.”
Over the page, please, it sets out there the funding
structure, and says:
“Each interim payment, which shall be no greater
than the aggregate of £100,000 per any one affected
postmaster, will be eligible for BEIS funding to the
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Those cases were originally not included in the scheme,
but they are, I think, following the Mr Bates ITV drama,
there was a change in that position; is that correct?
There was a journey to get there but, yes, that is
correct.
When you say a journey, what was the Post Office's
position?
Because of this funding agreement, even though those
three cases that I mentioned earlier there, their
convictions were overturned but, because of the funding
arrangement, they couldn't be paid their £100,000. So
despite Dr Hudgell asking for it, the funding
arrangement would not allow us to do it. So you've got
cases which have been overtumed by Southwark court and
yet, because of the funding arrangement they weren't
entitled to the £100,000 because, technically, they
weren't Horizon related cases.
And that was an awlul position to put anybody in and
so we had to work our way through that and we went
through mediation to do that and we reached settlement
with two of them. Subsequently, due to the Bates and
the mass exoneration, those cases have now been reopened
and now back in OC.
I think you said there were five individuals. What is
the current status of those cases?
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All those five are within the OC, I think one of them
has been settled.
Thank you. Can we please turn to POLO0448915 this is,
the second letter of 20 December 2021, and itis the
funding commitment letter that confirms the Department
will provide funding of up to 685 million to the Post
Office when aggregated with the funding committed under
the interim payment, funding commitment letter, the
total funding amounts to 780 million.
Then it sets out below the criteria. So those who:
“.. have their criminal conviction/s overtumed
following the ‘Common Issues’ and ‘Horizon Issues’
judgments issued in the Post Office Group Litigation,
and/or the [Hamilton & Others] judgment issued by the
Court of Appeal; or.
"were prosecuted, but not convicted, of offences
connected to the Horizon IT System and suffered
detriment in respect of the actions of the Company.”
‘Am I to understand therefore that that has now
changed and we should add to that a third category of
those who received cautions because they wouldn't have
been prosecuted but not convicted?
My understanding is cautions are included.
‘Are you aware of any formal change to any agreements in
that respect?
173
More recently, it's increased for those who don't seek
what is referred to as a Government offer, and that's
the £600,000 payment, which we're going to come to as
well. It's been increased to 450,000 as an interim
payment, at the request of Sir Gary Hickinbottom; is
that correct?
That's my understanding.
You've set out in your seventh statement at 122(b) that
the average time between submitting interim payment
applications and the payment is 34 working days; is that
correct?
That's my recollection.
So let's look at the Government offer. Since
18 September 2023, there has been an offer of £600,000
to all overtumed conviction claimants; is that correct?
Correct.
Correct. That doesn't apply, though, to those who were
prosecuted but not convicted; is that right?
That is right.
Can you assist us with why there is that difference?
Because the difference is the actual conviction.
In respect of the rights, and we spoke about this in
respect of the HSS scheme, am I right to say that the
600,000 is only available to those who don't seek a full
assessment of their claim?
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No, I'm not.
If we go over the page, please, to the bottom of the
second page, it says there:
"[The Department] has agreed to fund the claim
payments made by the company to fulfil BEIS’ commitment
to delivering compensation to postmasters fairly and as
quickly as possible, and supporting and maintaining the
Post Office Network.”
It continues a couple of sentences on:
“This funding commitment letter specifically covers
the provision of funds for claim payments for the OHC
Liabilities only, and is provided to support the company
in delivering its rescue and restructuring plan ..."
Can you assist with how the redress for these cases
relates to supporting and maintaining the Post Office
Network, or the rescue and restructuring plan?
I'm sorry, I can't help you there.
Let's move on then to interim payments. Interim
payments under this scheme were introduced in July 2021,
as we've seen, for £100,000. They were increased to
163,000 in November 2014, following representations made
by Lord Dyson, who was carrying out the early neutral
evaluation, which we're going to come to; is that
correct?
Yes, itis.
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Correct.
You've said in your seventh statement that by 31 May
this year there were 40 accepted cases, and you've said
that the average length of time from receiving the offer
to payment is 20 working days; is that all correct?
Yes, that's right.
Pardon?
Yes, sorry.
Thank you. Can we please turn to BEIS0000719, please.
This is an email chain, and I want to ask you about your
initial views as to the £600,000 Government offer.
Yes.
If we tum to page 4 of that document, the background
is, I think, that ~ is it Herbert Smith Freehills have
drafted a letter relating to the £600,000 figure, is
that correct, or a letter has been drafted by somebody?
If we scroll, please, to page 4, we can see some of
the background. Do you recall this chain where you're
commenting on a statement that's being made in respect
of that £600,000.
I recall -- I saw this email the other day, I do recall
the email. I recall its construction. I cannot recall,
as a result of a letter.
Perhaps we'll go through it in a bit of detail. If we
start where we are, this is an email, if we scroll up
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slightly, from Emily Snow, who is a member of the Post
Office Compensation Team in the Department for Business,
and she says as follows:
“You will spot comments in both attachments on.
pitching as a DBT only intervention: I appreciate that
itis a DBT proposal and that the timescales at which
we're working have meant we haven't been able to do the
type of engagement and ironing out of issues that would
have been preferred, not least by {the Post Office].
However, I am somewhat cautious about the language which
goes quite far to pitch as a DBT proposal without
showing some interaction between [the Post Office] and
[the Department] (as you'll see in the core text). This
is from a view that we do not want to create
a perception that Government is ‘stepping in’ because it
has lost faith in [the Post Office] process ~ this is
not the case at all. We should send a positive message,
there are two good options for postmasters: £600,000 or
remediation (which Government supports), since
postmasters who do not wish to accept the upfront of
will still need to go through the remediation process.
I think the wording should uphold the faith in that
[Post Office-led] process.”
There's then a response and we see there i's the
email below from Neil McDaid, that says:
477
If we scroll down, we can see you've lifted
a paragraph from this statement and commented on it. So
it was going to be say, "Government having consulted
with the Post Office", and your feedback is:
“false, delete, only you have kindly told us the
bare essentials and then to a highly restricted
audience -- this is not consultation.”
It then was going to continue:
“... has decided that postmasters who have their
convictions on the basis of Horizon evidence overturned
should have the opportunity upfront to accept an offer
of £600,000 in full and final settlement of their claim
This will be delivered by the Post Office with funding
from the Government."
Your comment there is:
“This implies this is extra funding and again is
disingenuous -- this is not extra funding as you know —
the funding is already in place. It is just a different
(hopefully more efficient) way of paying it out. In
fact a quick look at the Post Office accounts will show
to anybody who wants to see that we are anticipating in
paying out in excess of this average. This is where
consultation would have helped.”
Just pausing there before we continue with this, can
you assist us with your position as set out there?
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"By way of an update, [Herbert Smith Freehills] have
crafted a high level heads up letter to claimant
representatives which [the Department] have commented
on. They have also provided comment on the core lines
for [the Post Office]."
It's above that that we see your response, and it's
that response I'd like to talk to you about. You say as
follows:
“Care with the statement please.
"You are absolutely right this does read as a DBT
proposal without showing interaction between [the Post
Office] and DBT as apart from you and an email exchange
between myself and Car [I think that’s Carl Creswell]
(initiated by me) there hasn't been any! Of course this
will create a perception that Government is ‘stepping
in’ because it has lost faith in the [Post Office]
process as this is precisely what itis! I don't think
we should be disingenuous -- we have to be honest and
transparent here. It is clear from this and the lack of
risk assessment to the [Secretary of State] that the
Government nor the Advisory [body] have any faith in
Post Office. This will come up at the Inquiry with
Government nowhere to be seen. The paragraph of most
concem I have lifted and pasted below -- my comments in
red.”
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Yes.
Please do.
So I think the 600,000 opportunity was brilliant,
I think it was an inspired idea, in terms of how to
speed up redress. It was --I think I'm clear in my
note — it's the way that it was imposed on Post Office
and yet we were told that there were ~ it was clear in
the correspondence that they had consulted with Post
Office. Government had not consulted with Post Office;
my statement is clear.
I was told about it literally in a quarterly
shareholder meeting that we had, I was advised that it
was going to be launched the next day. I knew about it
probably 24 hours before then because I did request DBT
whether or not we could see the press briefings around
it, and I think I was politely declined that as well
So it was all shrouded with secrecy in terms of its
actual launch, but Post Office were expected to
operationalise it, manage it and push it through.
And that came out in my note. There was no
consultation, which can be fine and doesn't mean to say
it's not a good idea ~ it was still a good idea, don't
get me wrong ~ and it came directly from the Secretary
of State, which is one of the reasons why we believed it
was confidential, et cetera, et cetera, it was kept
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under wraps, because it had to make an impact:
a positive impact.
Why do you raise a concern about the extra funding being
disingenuous or reference to extra funding being ~
Because the impression that was given by the statement
was that they had -- Government had proactively found
additional funds in order to be able to do this, and
that was not the case. The funds ~ as I articulate,
the funds were already available, it's just a different
way of doing it.
Thank you. Do you have a similar view in respect of the
budget announcement that's just happened in respect of
the extra funds?
Forgive me. My job is to pay out redress as fast as
can, and I know I'm being challenged on that and, as.
much as I can, I really do not -- and my preference is
massively not to get involved in politics, with a small
"P" and a large "P". But I have to answer your
questions and there are elements in this, and there are
obviously elements in the Chancellor's thing that are
political and I find myself in a really, really
difficult position around that, because the politicians
with a capital "P" are taking the opportunity and that's
their right -- they're politicians, that's what they
do -- to take advantage of that to -- I don't know what,
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a scheme we have to run! Does any actually exist?”
What do you mean by "simply not thought through"?
So the allegation that we were consulted, the Post
Office were consulted when we weren't, and part of not
thought through" was we immediately started asking
questions around "What did the 600,000 --is it
a minimum payment?" And it became apparent it wasn't
a minimum payment. Oh right, okay, so how are we as the
operation people going to administer this? And there
were questions that we were posing that had yet to be
worked out what the answers would be.
In addition, with the greatest respect to the legal
representatives in this room, is that I had a couple of
phone calls from them wanting to understand, and to my
point about the politicalisation of this, I got two
calls from legal representation sitting in this room
before I was advised of this scheme to say, "This is
about to be launched, what's your comment on this, this
and this, please? How is this going to work and how is.
this going to work?" And I'm afraid I had to say to
them, "I don't know because I'm not aware of this
scheme, I'm not aware of how we're going to
operationalise it, bear with me" ~ that's embarrassing
-- "bear with me, I'l come back to you as soon as.
I know the answers”.
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to give themselves publicity, to give themselves credit
for whatever. This 600,000, to your point, is
a Secretary of State decision.
Thank you. We'll move on. You say:
“I suggest we change to:
"Government has decided that postmasters who have
their conviction on the basis of Horizon evidence
overturned should have the opportunity upfront to accept
an offer of £600,000 in full and final settlement of
their claim’."
You say:
“I think this is damaging enough and is a bitmore
like the truth please -- I think somebody has to try and
cling to some morals here please. This is an imposition
and it should not be flowered up in any other way. [The
Department for Business/the Secretary of State] should
take the credit for this initiative.
“Let's not forget that this will be exposed at the
Inquiry where this will be seen for what it is —
a clear Political intervention into a Post Office scheme
with good/excellent intent but simply not thought
through which is how the legal representatives will view
it. Interestingly, despite the common interest and
direct request, Post Office have yet to be extended the
courtesy of seeing the legal advice given on this ~ on
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So that's where that comes from and there was some
publicity around this because, effectively, that
population out there of convictions, it became
immediately apparent that the spin on it was that
everybody was going to get a minimum payment of
£600,000. We had direct approaches from very distressed
postmasters, that because the people knew they were in
that cohort and that they knew they were making a claim,
they were going to get £600,000, and we did have reports
of people actual knocking on their door about it and
that was quite distressing, and I got that feedback
through the legal advisers as well
Do you mean they were concerned for their safety or for
being chased for money from third parties?
To that a point, that the vast majority were anonymous
and yet, if anybody knew they were making a claim or
part of the scandal, then they knew that they ~ that
effectively this was saying they were going to get
a minimum of £600,000.
You continue:
*[For your information] -- we had a pecuniary claim
in from Hudgells at the end of last week for £18,000.
Their non-pecuniary was settled for ... 195,000. Under
this proposal this individual will enjoy £600,000. I am
not saying this is wrong and as you know I want to pay
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out these sorts of sums but to date have been prevent by
[value for money] restrictions, evidence, governance,
etc."
Just pausing there, you addressed value for money at
the very beginning of your evidence today and you said
you didn't think that value for money restrictions were
being imposed in respect of the settlement of
compensation claims.
Yeah,
This reads somewhat like it did have a role to play?
Yeah, I can understand that. It's not meant that way.
It's a list of processes, restrictions that I had to go
through and governance that I had to go through. 1 do
understand your point about ~- but no, please, value for
money was not applicable in this.
You continue:
“Ata stroke, all credibility/professionalism is
gone, never mind the months of work put in by Post
Office and DBT on principles and working with postmaster
lawyers. The Inquiry will seal all this. I have to
assume that all are comfortable with this. I'm not."
It might be suggested that what you're saying there
is that you're not happy with the £600,000 scheme
because, for example, in that Hudgells case, the Post
Office could have got away with a lot less. What's your
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consult about it.
Can we please turn to BEIS0000738, and now moving to
January 2024, and there's an email chain regarding
whether it's a minimum payment or not a minimum payment.
If we start on page 4, we see at the bottom of that page
being forwarded to you an announcement from the
Government, "Government announcement re overtumed
convictions”:
“Once this legislation is passed and convictions
have been quashed, individuals will be entitled to at
least £600,000 in compensation to rebuild their lives.
“The Government has always been very clear
previously that there is no minimum amount, although in
reality the £600,000 upfront offer set that floor. If
they are saying publicly that individuals are entitled
to at least [I think that should be £600,000] it feels
uncomfortable to me that we cannot make interim payments
up to that amount.”
Now, is this the overturned convictions process or
is this the other process?
So this is the new process from the £600,000 that
effectively was — so in terms of interims, we couldn't
go up to the 600,000 — it wasn't a minimum payment; it
was very clear, to be fair, very clear, that this was
for full and final settlement only. So it's a bit like
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view on that?
No, I think that's the wrong interpretation of that.
I've been clear in the paragraphs above that I think
this is a good idea and this is exactly what I want to
do. I think I can argue that that sentence is more
around the process that you have implemented, that you
have agreed that I can follow, the governance that you
have put in place for me that I'll have to follow only
allows me to pay out this amount and yet, at a stroke,
you're completely undermining that and saying, actually,
you're going to get £600,000
You say
“Am I the only one worried about all this? Is it me
or is this really Emperor's New Clothes stuff? I think
we are sleepwalking into real difficulties."
What did you mean by that?
Again, it's around the Post Office are an operational
engine that delivers these outcomes, these fair
outcomes. Ata stroke, the Government were undermining
the confidence in that by ~ and it's in here — by
saying that, actually, you know, effectively we're
uncomfortable with this process and we've not -- it's
clearly not fit for purpose because it’s not paying out
enough and, therefore, what we're going to do is we're
going to impose this on, and we're not even going to
186
the 75,000: here's £600,000, providing you're prepared
to settle.
If we scroll up, we can see correspondence between
yourself and Carl Creswell, and you say:
"I know we're going through interesting times ..."
Is that a reference to the post-Bates television
drama: we're in January 2024?
Yes.
". but further to previous mails does not the
government link below translate to the current £600k
being a minimum payment?
“If so, we could pay [circa] 60 cases up to £600k
with fimminent] effect."
If we scroll up, the response to you is:
"The £600k is a fixed offer sum that postmasters can
choose to take, or they can seek to make a fully
assessed claim. It is not a minimum payment sum, and
therefore not suitable for an interim payment amount.
There is a £163k interim payment to relieve any
immediate financial pressures for those making a full
claim whilst that claim is developed and considered,
additionally, specific further interim/hardship payments
are also considered if requested by a claimant.”
If we scroll up, you say:
“Beth
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“OK ~ last go, I promise!
“{ do understand the initiative but it is not
logical.
"We don't have an expiry date on the £600k [full and
final] offer — we await to hear on this. So currently
there is no expiry date on this offer.
“if a victim decides to push their claim through
full evaluation and their offer is less than £600k they
will be advised to take the £600k in {full and final]
If their offer is above £600k they clearly will settle
above £600k.
"So whatever happens they get £600k -- as per the
‘mass exoneration’ scenario. Nicely aligned.
"So whatever happens they get £600k.
"So alleviate postmaster stress and media outrage by
being proactive and top all 60 up to £600k because they
are all going to get this anyway.”
If we scroll up, the response to you is:
"You asked yesterday whether the aim was to get
money as quickly to claimants, or to get {full and
final] settlements to the claimants. Our focus is on
achieving the latter. This proposal doesn't encourage
any pace or movement to full and final settlements does
it? Ministers and politicians as shown in the Select
Committee are keen to take steps to encourage victims
189
and final compensation — many of whom are coming up to
their 3rd anniversary of their conviction being
overtumed this spring.”
Can you assist us with what appears to be a dispute
between the Post Office or yourself and the Department
for Business?
Ican. So -- and it's pretty clear from the one below,
from the Department, around there's a choice here
between are you saying the objective is full and final
settlement: is that a priority over paying funds out
because there are -- because, in particular, in OC there
are many opportunities, as I explained earlier, to pay
out more -- further interim payments, and what the
Department was saying to me was "No, we don't want you
to do that. That's not the objective any more. We'd
rather you hold on to those and hold out for
settlement".
I was extremely uncomfortable with that, and I think
'm making my point, articulating, of what is the right
thing to do because I didn't want to delay — it seemed
to me I was getting an implication to delay redress in
order to hold out for full and final settlement. I was
saying, "Hang on a minute I'm not quite sure I'm
comfortable with that. If I've got the opportunity to
still pay out redress” -- a bit like my example if
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getting their full and final settlement as quickly as
possible. I don't believe this moves the dial on that.”
You respond slightly above:
"Beth
"So we hold the funds back that we could pay to
pressurise sorry ‘encourage’ [full and final]?
"No need to respond (but grateful for your two
responses!).
“Last word -- promise -- what is the right thing to
do?
"I've moved on."
if we scroll up, we can see the response:
"The policy position regarding the £600k was
announced by the Minister last year. Last week's
announcement doesn't change that policy. You asked
yesterday whether you should focus on maximising
payments or maximising settlements yesterday. We were
very clear that we would like you to focus on ensuring
that claimants are able to settle their claims as
quickly as possible, as this is what Ministers and other
politicians are keen to achieve, we need to ensure that
victims can complete the claims process. The proposal
that you have made does not speed up the overall claims
process, and indeed may actually further lengthen it,
that is not fair to those still waiting to achieve full
190
there's an offer there, I want to pay the offer
amount -- "then I don't want to feel restricted about
not paying that out because I'm only going to pay out
when I get a full and final settlement’
That, for me, was quite a strong moral dilemma, and
maybe I articulated it badly in there but that was the
moral dilemma that I was facing and they made it clear
to me, absolutely crystal clear, "No, Simon, the
objective, it's there. Black and white, full and final
settlement". So I then had to issue instructions
internally to say those potential interim payments, the
Government will not approve them now, and they didn't
approve them, because they were holding out for full and
final settlement.
What is the latest position on all of that?
It's changed.
How has it changed?
So Government now appear comfortable that, whenever we
can make payments via a head of loss, for example, so
there may be ten heads of loss and we may ~ the legal
advisers and we may be comfortable with eight of them,
we can pay those eight heads of loss, and we settle
effectively via each heads of loss.
Does that extend beyond £600,000, potentially?
Can do, yeah.
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When has that change been in place?
Forgive me, I don't know when, but for some time. But
this was the initial -- and, since then, the position
has eroded.
Can you give us an idea: was it in the summer; in
spring? This is January of this year.
Yes, this will have been during the summer, yeah.
Thank you. That can come down, thank you.
Moving on from interim payments. There's then
a full assessment for those who don't opt for the
Government offer.
Yeah,
Claims are made of pecuniary -- that's financial -~-
losses and non-pecuniary losses, such as physical and
mental loss/impact.
Let's start with non-pecuniary. You've addressed
this in your seventh statement at paragraph 100. You
describe the Early Neutral Evaluation scheme that was
set up in 2022. Lord Dyson was appointed to the role of
Evaluator and he evaluated, at that point, ten claims.
This led to Lord Dyson's evaluation of 29 July 2022,
which set out the ranges of redress for various heads of
claim.
Yes.
Is that correct?
There are three specific cases. Forgive me, I think
they all come from one legal adviser and we are very,
very keen, where the legal adviser is not agreeing with
the non-pecuniary offers that we are making, and in
order to resolve those, we have suggested that we go
back to Lord Dyson to help us evaluate, and we are
extremely supportive and we were trying to encourage
that proactively and, as yet, we haven't managed to get
the time in the diary from the legal adviser’s
perspective.
Is that something that Lord Dyson is happy to do ~
Yeah, absolutely. We've even got time - we've even
had, previously, time in his diary allocated to it.
Thank you. Paragraph 75 of your seventh statement, you
say that by 28 August of this year, 77 non-pecuniary
cases had been fully settled, including some who.
accepted the Government offer; is that correct?
That's right, yes.
I think you say 77 non-pecuniary; 9 non-pecuniary
haven't settled; 25 more expected but not yet submitted.
Perhaps we can bring that onto screen. That's the
seventh statement, WITN09890700. That's paragraph 75.
It's page 27.
That gives the figures there: 77 non-pecuniary
claims have been fully settled.
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Correct.
Lord Dyson considered matters again in December 2023
relating to whether the money from the Group Litigation
Order
Yes.
~ should be deducted. Can you summarise for us what
his finding was in that respect?
Well, that we -- that nobody should deduct the GLO
payments that had already been made from redress.
Do you know what the Post Office position was in respect
of those GLO payments prior to that decision?
That we were deducting them.
Were you in favour of deducting them or was there
internal discussion that you were party to as to whether
that was the right or wrong thing to do?
I wasn't ~ I was aware of the policy, the process to do
it. wasn't involved in any debate about whether to do
itor not. It was just accepted that that was ~ that
their overall redress would be discounted by the redress
that they'd already received
Thank you. The Post Office, you say in your statement,
has offered to refer three further cases to Lord Dyson
for his own review but that hasn't occurred. Can you
briefly assist us with what that involved and why it
hasn't occurred?
194
You also say in this statement that over 90 per cent
of non-pecuniary claims submitted were settled and paid
within 44 working days of application submission; is
that right?
That's right.
It appears from your statement that the non-pecuniary
cases that take a longer time are bankruptcy cases; is
that right?
Yes.
So whereas in the HSS scheme I think you weren't
particularly concerned about the bankruptcy cases and
delay, is there a concem there at the moment?
To be clear for the Inquiry, I am always concerned in
any delay, firstly and, again, where the bankruptcy has
evolved, we just have to engage with a third party and
that then elongates the process — builds in delay.
Is there anything there that you think would speed up
that process?
I think we're on this, and I have -- there will always
be things that we can do to speed up redress and, if
this is one of them, I'm more than comfortable to get
involved. But, at the moment, it's not being raised to
me as a significant risk.
Thank you. Moving on, then, to pecuniary. You've
explained that, prior to establishing the pecuniary
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principles, it was a slow process; is that right?
Yeah.
Those principles were established in October 2023 and
finalised in January of this year; is that right?
Correct.
We saw that non-pecuniary claims took an average of
44 days to complete. In terms of pecuniary claims,
you've said 305 working days. So over a year in
relation to pecuniary claims; is that your experience?
Well, in terms of -- but that -- my understanding is
that will be including the building of the pecuniary
principles. So that was the journey. So when -- and
I think Mr Cameron's witness statement also supported
this -- when I first arrived at Post Office, in this
space, obtaining settlement with postmasters on
overturned convictions was a negotiation, okay? It was
locking lawyers away in a room and working things out on
a heads of loss by heads of loss basis, and it was not
constructive and it was not collaborative.
So one of the first things I did -- and Mr Cameron's
evidence supported this -- was I proposed a different
approach, a remediation approach, very much
collaborative with the postmasters and their legal
advisers to walk in the journey between us, all of us,
being a party to that.
197
Yes. So we were absolutely aware that new nuances, new
principles, new heads of loss will appear, and we have
a process that wraps those in, as well, which again have
to go through governance. Now, as soon as a new
principle or new heads of loss has to be reviewed, of
course we have to understand the financial impact, and
we have a huge modelling exercise that we go through to
say, "Right, if you're going to now embrace that new
heads to loss" - to your point earlier ~ "what's the
impact on anything you've already done, and what's the
impact going forward, and how is that going to affect
the financial modelling, indeed the provisioning",
et cetera, et cetera? So all that exercise has to be
done with Government approval.
Thank you. Could we bring back up onto screen your
seventh witness statement, please. WITN09890700,
paragraph 86 on page 30:
“As at 28 August 2024, all Claimants except three
have received a payment in some form, whether an interim
payment or final settlement payment. These three
Claimants had their convictions overtumed between late
January and August 2024. All three have been sent
an interim payment application form with one Claimant
accepting the interim payment; this interim payment was
made on 2 September 2024."
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That took some time to establish, and then we built
the principles based on that principle, that this will
be a collaborative voice. So the principles were with
the legal advisers.
Now, the legal advisers would never agree to those
principles but their input was very, very valuable, and
we did adjust those principles with their feedback. So,
by the time we got to the October and by the time we got
to the end of 2023, we were in a position where we had
a bunch of principles which people appeared to be very
comfortable with working within, although they weren't
signed off but that they had input from a number of
third parties, including postmasters and, more
importantly, their legal advisers.
And that's where we shared all of that journey all
the way along, through governance in Post Office and
indeed with Government as well, to ensure everybody was
comfortable with the approach we were taking of that
process. And there was some really good behaviours were
seen by everybody in that respect, in getting to
an outcome, a remediation outcome, that we could take
the postmasters through.
I think you say in your seventh statement that full
claims not involving novel heads of loss now take around
40 working days; is that right?
198
Can you assist us with how many pecuniary claims
have finally settled and how many are outstanding, or
an indication of that?
So what I can hopefully assist with -- I haven't —
I probably have somewhere — got the complete breakdown.
I'm happy to supply that to you. What I can hopefully
help the Inquiry with, out of the 111 cases — because
that's a fixed population now because of mass
exoneration — so out of the 111 cases, 61 have settled,
The vast majority of those are the 600,000, but there
are other cases that are above 600,000 that have
settled. So 61 have settled but there remain 50 cases.
Of the remaining 50 cases, every single one -- to
this point in paragraph 86, every single one has had at
least a minimum payment of £200,000. Many of them have
settled on non-pecuniaries and some of them have settled
‘on pecuniaries, as well. I haven't got that precise
breakdown here. I think it is in my statement as it was
at the end of May. I'm happy to provide the Inquiry
with updated figures on that.
MR BLAKE: Thank you very much.
Sir, we're going to shortly break for the day.
Mr Recaldin is able to come back tomorrow morning and we
are able to accommodate Ms Munby to be completed within
the day as well
200
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SIR WYN WILLIAMS: That's fine.
There's two rather pedantic points, Mr Recaldin.
When you say that the number 111 is now closed,
technically, that may not be right ~
A. Ooh, you're absolutely right.
SIR WYN WILLIAMS: -- in the sense that there could be
non-convicted but prosecuted postmasters who would come
forward still; and there could be, if you are right
about this, postmasters who had been cautioned who have
not have yet come forward.
A. You're absolutely right, of course, Sir Wyn.
SIR WYN WILLIAMS: Well, no, no, I could be wrong.
A. No, you're absolutely right. But in my head is.
absolutely the funding allows the prosecuted not,
convicted population into the OC funding space but
because they're not a convicted case, I haven't
included. So in terms of overtumed convictions, my
understanding is a locked down population. Thank you
for the clarity. You're absolutely right.
SIR WYN WILLIAMS: Yes, but the reason I was thinking about
that was — and I certainly may be wrong about this —
I hadn't appreciated previously that cautioned
postmasters were within OC and, when I was reading the
section of your witness statement, which deals with
prosecuted but non-convicted cohort at paragraph 29
201
Mr Recaldin. You're not supposed to speak about your
evidence, unless I specifically allow you to do so.
Certainly, in relation to the clarification which I have
provoked, you can speak to whoever you think is
appropriate. All right?
THE WITNESS: Thank you, Sir Wyn.
SIR WYN WILLIAMS: Thank you
MR BLAKE: Thank you, sir.
(4.31 pm)
(The hearing adjourned until 10.00 am the following day)
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onwards — don't bring it up now, I'll just ask you to
look at it overnight ~- there's no mention of cautioned
subpostmasters.
'm very happy that you may be right about it but
I would like you to clarify that for me, if you would.
A. And Sir Wyn, I would appreciate the opportunity for
clarity. And I think Mr Blake also pointed out in the
funding arrangement it didn't refer to the word
“caution” either. And, as soon as I've said that, I'm
now doubting myself. So I'm pretty sure it does but
I need to -- thank you for the opportunity for me to go
and seek clarity. I will do that overnight.
SIR WYN WILLIAMS: That's fine. Thank you
Well, thank you very much for giving evidence all
day.
Ill see you ~ I think it's 10.00, Mr Blake,
tomorrow?
MRBLAKE: Yes. We can accommodate both Mr Recaldin and
Ms Munby tomorrow, even with a 10.00 start.
SIR WYN WILLIAMS: That's fine then, so I'll see you at
10.00 tomorrow morning.
MR BLAKE: Sir, can I just clarify for Mr Recaldin:
obviously, he can't speak to anybody about his evidence,
subject to that one issue relating to the caution?
‘SIR WYN WILLIAMS: Yes, I think that must be right,
202
INDEX
SIMON DOMINIC RECALDIN (affirmed) 1
Questioned by MR BLAKE ......
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18 billion [1] 35/5 I463k [1] 188/19 156/20 157/13 161/12) 29 per cent [1]
WR BLAKE DTI 1/310 [6] 61/1 66/7 66/7 I467 [2] 152/15 161/15 162/1 162/4 I 164/11
MR BLAKE: 271,18 101/25 152/25 157/10] 152/18 193/19 193/21 29 September [1]
46/21 62/7 62/11 10 January [1] 3/18 I168 [1] 154/9 2022/2023 [1] 67/17 I 1/15
62/13 62/18 62/20 _I10 October [2] 171,592 [1] 162/2 — I2023 [13] 15/6 33/18 I298,000 [1] 161/19
4110/1 110/4 110/9 I 198/20 157/13 474 [4] 152/22 33/18 67/17 98/2, Ip
410/11 113/9 132/17 I10 per cent [2] 72/5 I 18 million [3] 73/6 I 113/14 123/3 150/7
432/25 136/18 166/5 I 163/18 73/7 73/14 158/17 175/14 194/2 I3 September [1] 1/22
4166/9 166/11 166/15 I10:000 [3] 116/10 I18 September [1] 197/3 198/9 3,044 [1] 157/14
200/21 202/18 202/22I 116/12 150/1 175/14 2023-2024 [1] 39/15 I3,194 [1] 43/9
203/8 10.00 [5] 1/2 202/16 I18,000 [1] 184/22 2024 [48] 1/11/21 I3,427 [1] 43/7
SIR WYN WILLIAMS; 202/19 202/21 203/10I481 [1] 158/2 1/22 1/23 1/24 1/25 I3.1.2 [1] 64/17
[39] 1/4 1/7 45/23 I100 [5] 150/7 150/10 I484 [1] 157/19 39/15 39/24 40/12 I3.25 [1] 166/12
46/19 62/10 62/12, I 151/19 152/22 193/17I185 [2] 110/13 40/14 41/18 43/8 3.40 [2] 166/9 166/14
62/14 62/19 10/3 I100 per cent [1] 111/11 44/12 44/24 54/9 67/130 [1] 199/17
110/5 110/10 113/2 I 193/13 49 [2] 6/24 7/1 67/2 67/10 69/23 73/2I 30 April [2] 24/6
4113/8 132/13 132/18 I100,000 [7] 153/8 I 195,000 [1] 184/23 I 74/15 74/16 74/25 I 144/4
433/1 133/12 133/15 I 189/24 170/16 170/24/5 I 83/4 83/13 87/7 88/16/30 days [1] 143/21
433/20 134/3 134/6 I 172/11 172/16 174/20I£ __I 90/6 113/14 123/5 _ I30,000 [7] 38/8
134/11 134/17 134/22I 104 [1] 121/1 2 September [1] 124/5 124/9 125/4 140/16 140/17 140/20}
4135/8 135/20 1360/7 I11 [4] 111/5 161/19 I 199/25 125/20 125/22 133/21] 140/21 140/23 168/7
136/10 136/16 166/8 I 161/21 163/25 2,085 [1] 72/6 141/17 144/4 155/11 I300 [1] 44/3
166/10 201/1 201/6 I11 December [1] 2,248 [1] 71/15 158/17 161/15 162/1 I300/350 [1] 91/1
201/12 201/20 202/13I 168/17 2,321 [1] 72/7 162/4 187/3 188/7 [302 [1] 75/1
202/20 202/25 203/7 I11-500 [1] 63/9 2,341 [1] 71/16 199/18 199/22 199/25I302 million [3] 35/19
THE WITNEss: [1] /11-35 [1] 62/15 2,400 [1] 46/7 2025 [5] 35/25 36/3 I 36/2 73/23
203/6 11.47 [1] 62/11 2,500 [2] 44/16 77/9 I 73/24 87/7 167/2 305 [1] 197/8
11.50 [1] 62/17 2,548 [1] 121/14 2026 [1] 34/20 306 [1] 74/14
: 114 [4] 168/21 200/7 I2,720 [1] 111/41 22 [4] 19/5 19/16 307 [1] 70/3
"24 [1] 126/14 200/9 201/3 2,792 [1] 70/13 TAIT 149/24 34 [4] 54/11 54/13
"25 [1] 36/3 118.5 [1] 72/9 2,00 [2] 110/4 110/8 I22 August [1] 168/19] 93/9 93/24
26 [1] 36/3 42 [3] 122/11 122/15 I20 [3] 85/1098/2 —I22 July [1] 170/10 I31 December [1]
‘any [1] 29/5 163/23 176/5 23 [2] 108/4 152/24 I 123/3
‘at [1] 25/3 12 per cent [3] 71/22I20 December [1] 23 April [1] 168/19 I31 March [2] 34/20
‘Common [1] 173/12 I 101/25 157/21 173/4 23 October [1] 161/4 I 34/21
‘encourage’ [1] 190/6I120 [2] 90/7 124/7 20,000 [1] 66/18 23 per cent [1] 31 May [3] 43/8
funds [4] 24/10 421 [3] 73/1 73/2 I200 [2] 125/5 161/21 I 164/13 66/25 176/2
“Government [1] 73/4 200,000 [1] 200/15 I 230 [2] 73/10 123/25 I312 [1] 152/21
182/6 122 [1] 175/8 2008 [1] 4/4 230 million [4] 73/10 I319 [2] 70/22 71/3
‘Horizon [4] 173/12 I123 [1] 70/15 2014 [1] 174/21 230.1 [1] 72/13 32 [2] 24/12 24/14
"How [1] 147/3 127 [2] 128/9 128/10 I2019 [1] 39/11 24 [1] 20/1 33 [1] 164/25
‘inadvertently [1] 13 [2] 161/19 161/21 I2020 [24] 22/20 24 hours [1] 180/14 I33 per cent [1]
20/11 13,500 [1] 4/9 22/21 37/4 40/4 40/7 I24 July [1] 80/11 163/16
‘mass [1] 189/13 I130 [1] 131/18 41/3 41/4 41/13 42/16I25 [4] 195/20 33 years [1] 3/22
‘nickel [2] 25/19 133,000 [1] 161/13 I 43/19 46/8 51/2 64/10/25 per cent [1] 92/5 I34[1] 175/10
31/11 139 [5] 73/4 73/10 I 67/2 67/3 68/3 76/21 I25,000 [4] 153/12 I35 [1] 37/10
‘stepping [2] 177/15 I 131/3 132/19 134/11 I 77/2 113/6 12177 I I 250 [1] 44/3 350 [1] 91/1
178/15 14 [4] 18/1 29/4 121/15 122/25 123/3 I26 per cent [1] 37/18 I363,000 [1] 161/17
11014 111/20 168/17 260,000 [1] 161/19 I37 [1] 103/7
114 May [1] 26/20 2021 [19] 13/11 261 [2] 111/14 112/6 I373 [1] 47/1
1 January [1] 123/5 I14.8 [1] 72/11 13/12 43/24 44/18 I 266 [1] 139/16 383 [4] 111/13
4 May [2] 37/4 140 [2] 10/3 10/7 44/19 45/25 46/8 67/4/27 [2] 157/10 195/23 I39 [3] 128/8 128/9
122/24 140,000 [1] 161/12 I 67/23 82/22 87/6 —_I27 April [1] 24/6 164/4
1,194 [4] 141/9 15 [2] 61/1 123/2 121/8 161/11 168/19 I27 August [1] 73/3 I397 [3] 47/3 59/4
1,200 [1] 156/10 15 May [1] 1/21 169/22 170/3 170/10 I27 November [1] 70/8
1,345 [1] 124/4 15 per cent [2] 173/4 174/19 122/25 3rd [1] 191/2
4,430 [1] 120/3 106/16 106/23 2021/2022 [1] 83/10 I28 August [1] 195/15], SS
1,483 [1] 37/11 150 [1] 97/6 2022 [28] 3/18 15/6 I28 August 2024 [1] I2——__________
1,500 [3] 98/18 99/2 159 [2] 39/14 40/1 20/2 42/16 43/25 199/18 4 September [2] 1/23
99/7 16 [1] 116/6 44/13 44/19 44/21 128 November [1] 1124
1.01 [1] 110/6 16 October [1] 1/25 I 44/23 67/3 67/16 123/3 4 years [1] 26/23
1.4 billion [3] 30/8/16 per cent [1] 67/23 68/10 82/22 29 [1] 201/25 4,000 [1] 161/12
35/12 58/19 157/23 83/10 87/6 88/16 I 29 July 2022 [1] 4,267 [1] 70/11
163,000 [1] 174/21 I 123/25 128/2 150/5 I 193/21 4,323 [1] 69/23
(52) MR BLAKE: - 4,323
INQ00001200
INQ00001200
4 57 per cent [1] 92/13I 101/9 101/16 102/15 Iabout [133] 6/24 8/20I acceleration [6]
4575 [4 Tez /58 13] 82/16 82/18 I 102/18 116/13 129/17) 12/25 14/10 14/12 I 35/21 35/22 35/24
4.974 [1] 69/25 155/17 136/22 137/1 137/2 I 14/18 17/21 20/24 _I 35/25 73/16 73/21
434 [1] 203/9 59 [2] 87/1 106/10 _I 137/3 137/7 137/9 _I 23/12 25/14 26/6 26/6I accept [24] 20/6 28/5
137/21 138/3 138/5 I 27/24 28/8 28/20 60/6 67/20 68/13
rien cone tty 82 3 I__I 138/11 13972 13919 I 29/25 30/7 30/14 —_I 68/17 99/16 102/2
i 6 December [1] 20/2 I 139/11 139/22 139/24] 30/14 30/15 30/22 102/9 124/7 130/11
40,000 12] 49/8 Jeo 14) 88129210 I 40/2 14012 1411 I 31/7 33/16 33/17 I 137/21 138/13 13011
400 [3] 156/16 188/12 189/16 141/15 141/21 142/2 I 33/22 34/6 35/8 37/19I 139/11 141/21 142/16
156/17 161/21 60 per cent [1] 127/7I 142/16 142/24 142/25) 38/3 38/3 40/21 48/6 I 155/3 161/22 161/24
41 [1] 19/16 600,000 [34] 8/24 9/2I 143/5 143/12 143/19 I 48/10 52/17 54/15, 162/22 177/20 179/11
42 [3] 10/6 10/7 9/4 9/8 145/6 145/14 I 146/5 146/10 146/13 I 54/18 55/21 56/1 57/2I 182/8
132/20 147/4 175/3 175/14 I 147/5 148/6 149/12 I 61/9 61/23 63/4 63/14I acceptable [2] 3/6
175/24 176/11 176/15] 150/25 151/1 151/4 I 63/19 64/8 71/13 144/21
az oe Pl 161220 176/20 177/18 179/12I 151/8 151/10 151/16 I 72/22 73/5 73/12 74/4I acceptance [3] 71/23
, 180/3 182/2 182/9 I 151/25 152/5 152/10 I 7/6 77/21 78/8 79/22I 106/24 166/1
421,000 [1] 161/19
43 [3] 54/11 54/16 183/6 184/6 184/9 155/15 156/7 188/1 I 79/24 81/22 82/12 _I acceptances [1]
1420/2 184/19 184/24 185/23I77 [4] 20/4 195/15 —_I 84/6 85/3 96/20 98/17I 105/24
44 [1] 196/3 186/11 187/11 187/14] 195/19 195/24 99/15 103/16 104/3 Iaccepted [22] 21/20
44 days [1] 197/7 187/16 187/21 187/23I780 million [1] 173/9 I 104/16 106/7 106/11 I 64/21 68/8 71/15 72/2
445 [2] 74/24 7518 I 188/1 192/24 200/10 II "106/21 107/2 110/19 II 95/20 95/21 95/23
200/11 112/11 114/23 116/18] 100/12 100/15 105/4
45 [2] 19/25 92/10
45 por cent [1] 600k [12] 188/10 I83 [1] 54/15 124/12 125/20 126/11) 105/6 106/14 106/16
113/18 188/12 188/15 189/4 I83 per cent [5] 102/2I 127/14 127/18 132/15I 107/21 140/11 141/9
189/8 189/9 189/10 I 102/3 106/24 130/7 I 133/10 133/21 133/24] 159/20 166/24 176/3
45,000 [1] 162/1 189/11 189/12 189/14] 130/11 134/18 135/1 136/13 I 194/18 195/17
4 Ot a75/4 189/16 190/13 84 per cent [3] 71/24I 137/8 138/20 138/23 I accepting [4] 95/8
‘eq } 4 64 [2] 200/9 200/12 I 71/25 72/1 139/6 139/20 140/14 I 138/2 143/2 199/24
1 Os i) 62 [3] 96/25 97/4 85 per cent [1] 141/3 141/22 142/7 I accessing [3] 79/25
46,000 1) 164/11 103/10 141/14 144/21 147/6 147/12 I 80/1 80/1
47 per cent [1] 37/15 63 [4] 106/5 106/5 I86 [3] 111/4 199/17 I 149/13 152/17 155/1 I accommodate [3]
Ps 158/2 164/1 200/14 160/1 160/15 160/23 I 107/13 200/24 202/18
0 i para 64 [3] 74/6 154/12 I87 [2] 129/4 123/16 I 161/2 162/22 163/19 Iaccordance [2]
aetare tiene I 12816 87 million [1] 141/7 I 165/2 165/11 165/12 I 51/21 95/10
8 13] 649,000 [1] 161/18 I88 [1] 103/5 166/22 169/13 175/22I accordingly [10]
air] 66236623 [6511 106/13 896 [1] 70/1 176/10 177/10 178/7 I 4/11 4/19 6/2 58/17
650 million [2] 36/2 Ig I 180/11 180/13 181/3 I 77/7 97/25 124/23
106/12 106/14 119/21 9
119/24 120/16 73/24 183/15 183/18 184/10] 126/5 130/1 139/10
———_——___I66 [1] 157/19 9 August [1] 136/21 I 185/14 186/13 187/1 Iaccount [4] 35/13
5 67 [3] 110/13 119/13 etn cent [t] 70/9 I 4192/2 194/17 196/11 I 42/4 67/4 93/18
SNIR GEGE I 119/15 201/9 201/20 201/21 I accountability [1]
onl gio Tart 4, I685 million [1] 173/6 I90 million [2] 73/12 I 2o2/4 202/23 20/1 I 14/3
153/9 200/12 200/13 69 [1] 113/12 73/15 above [6] 178/6 accountable [1]
50 per cent [1] 7 —___I93 [1] 43/9 186/3 189/10 189/11 I 14/24
153/10 “____I93 per cent [1] 45/2 I 190/3 200/11 accountant [2]
50,000 [1] 100/19 IZ Percent [1] 153/22 I94.5 per cent [1] absolute [1] 129/11 I 145/23 160/4
500 [1] 41/5 7 September [1] 44i22 absolutely [47] 20/19] accountants [1]
500 million [4] 36/4 I.5°/'2 9s [1] 72/21 32/17 33/11 38/14 I 162/11
51 [3] 66/16 107/3 I7:100 [1] 66/18 A 40/19 52/15 52/16 I accounting [1] 93/6
120/17 70 per cent [2] 71/8 Ma) ODBE I 8122 7415 91/23 accounts [1] 179/20
514 [1] 74/14 OT] 97/16 At [1] 92 wir 46720 I 26/14 9818 10419 accuracy {1] $8/12
52 [8] 39/13 103/16 I700 [1] 102/7 104/3 115/4 accurate [3] 97/13
75 [4] 101/10 138/13 Iabilities [1] 125/14 I 429/43 120/21 124/10I 101/22 129/24
195/14 195/22 ability [1] 129/1 127/6 130/12 130/18 Iaccused [1] 4/15
75,000 [82] 38/4 42/8 Iable [30] 5/23 5/25 I 433/19 137/14 138/1 Iachieve [3] 21/16
45/18 65/23 65/25 —_I B/S 23/20 35/2 47/12 I 439/5 142/4 142/18 I 190/21 190/25
106/9 119/23 163/14
163/16 163/21 164/24)
52,000 [1] 136/21
53 [1] 40/25
74/3 84/6 84/7 84/11 I 54/5 57/8 59/1 70/24 I 443/23 153/4 154/8 achieving [1] 189/22
ans {2} 99rt9 84/20 84/23 84/24 I 71/17 72/4 77/12 158/9 158/15 159/10 anew tt 58/20
532 [4] 111/14 87/13 88/18 91/14 Biot ene ae 160/21 161/24 167/18] acronyms [1] 2/14
54 [1] 139/19 2119 122 26 a oe at tomiosI 16816 178/10 192/8 across [10] 12/14
55 [1] 164/8 Ceeayto ona. tors A2a/t4 126/25) 196/12 190/1 20115 I 35/18 58/13 63/9 63/9
56 [4] 2/15 122/24 201/11 201/13 201/14] 71/20 71/22 73/22
99/16 99/21 99/24 I 17/7 181/7 19019 I So4/49 geo 195/04
152/15 152/18
4100/3 100/21 101/3 I 200/23 200/24 accelerate [1] 73/18 Iact [1] 28/1
(63) 4,575 - act
INQ00001200
INQ00001200
A administered [4] 85/8 107/20 108/21 I 32/22 35/8 35/8 35/18] 70/7 84/3 94/22 96/7
acting [1] 2018 13/7 18/16 18/21 110/1 117/2 126/2 36/6 36/16 36/21 38/3] 120/25 121/5 123/21
actions [1] 173/18 133/17 132/6 157/14 38/3 41/15 46/19 136/20 136/23 136/25)
activated [1] 97/24 administering [3] afternoon [4] 110/9 I 47/22 47/24 47/25 139/19 151/18 164/18)
activation [2] 76/20 14/19 15/11 15/18 110/10 160/25 166/7 I 54/4 58/13 59/5 60/8 I 179/18 181/9 194/9
129/8 administrating [1] I again [58] 2/25 3/22 I 62/10 62/14 62/24 194/20 199/10
activity [4] 40/19 16/14 8/14 20/17 37/17 63/5 63/5 64/22 69/12/also [59] 2/7 6/7 9/10
53/10 121/23 125/9 I@dministration [2] 43/11 44/12 67/14 72/14 73/22 74/9 9/20 9/20 14/9 22/20
actual [10] 81/13 12/25 13/3 71/17 78/5 83/3 83/4 I 74/20 75/13 75/16 26/6 28/20 38/12
82/5 84/2 104/18 adopt [2] 137/18 87/3 87/6 88/12 88/14) 75/16 75/16 78/6 38/14 43/13 49/15
118/14 149/25 155/8 I 195/13 88/16 88/17 88/23 78/14 78/19 81/8 53/15 59/25 64/2 64/3,
175/21 180/18 184/10I2dvantage [1] 181/25) 91/13 91/19 97/22 81/10 81/14 84/10 66/19 69/13 78/19
actually [52] 4/13 adversarial [1] 19/22 I 98/8 98/9 99/6 103/13I 84/16 84/19 89/12 79/18 82/24 89/16
22/15 36/17 43/20 I advice [36] 20/6 106/3 116/7 116/14 I 90/16 91/14 93/14 90/10 94/8 100/12
44/23 49/22 54/11 55/14 56/5 112/11 118/15 119/13 120/4 I 96/23 97/9 102/2 102/14 112/3 115/5
65/17 68/2 76/3 76/18) 117/18 129/18 129/18) 120/7 123/15 130/5 I 105/1 105/15 108/4 I 117/11 118/13 121/15
77/10 90/12 90/17 129/21 130/8 147/23 I 130/5 132/1 135/25 I 108/9 108/10 116/16 I 125/9 126/19 128/17
92/1 99/9 99/24 148/8 148/17 148/18 I 141/3 142/22 143/18 I 117/22 122/9 122/10 I 129/5 130/22 130/24
100/11 100/19 100/20I 149/14 149/15 155/25] 154/5 154/15 155/9 I 122/25 128/16 130/6 I 131/10 136/22 137/3
1402/11 102/15 103/1 I 1596/3 156/5 156/11 I 155/16 155/17 159/9 I 1341/5 135/8 136/7 137/15 139/15 140/10)
105/12 105/13 108/9 I 157/5 158/13 158/14 I 161/20 163/5 165/5 I 136/16 136/18 138/8 I 140/14 140/25 141/10
409/12 110/17 112/8 I 160/1 163/15 163/18 I 165/25 170/3 170/6 I 138/19 138/23 140/19] 145/24 147/5 167/16
116/14 116/22 117/10I 13/23 163/24 164/5 I 179/16 186/17 194/2 I 140/22 141/5 142/6 I 168/10 169/4 169/10
117/21 117/24 118/5 I 14/9 164/12 164/21 I 196/14 19/3 142/25 143/3 145/3 I 169/18 178/4 188/23
130/3 132/23 138/6 I 185/3 165/4 165/8 against [8] 9/23 147/1 154/24 156/3 I 196/1 197/13 202/7
4142/5 14018 143/19 I 165/16 182/25 14/15 20/11 20/20 I 156/19 158/4 160/7 _I alternative [1]
153/12 156/5 188/25 Iadvise [7] 27/10 33/4 39/10 116/6 163/2 167/13 167/15 I 171/21
189/15 163/23 164/4 I 117/11 145/6 145/10 I 171/25 168/2 168/6 168/8 —_Ialthough [7] 15/23
16712 183/1 te6/10 I 145/14 147/3 149/19 Iagenda [2] 18/10 I 1714/1 173/1 175/15 I 43/18 74/15 11916
jee/21 190/24 advised [12] 28/2 I 84/5 4176/5 177/17 180/17 I 128/16 187/13 198/11
add [3] 76/16 68/19 I 28/8 50/22 130/17 aggregate [1] 170/24] 185/17 185/20 185/21I altogether [1] 67/24
173/20 146/17 154/6 154/7_ Iaggregated [1] 173/7I 186/13 189/16 189/17I always [15] 25/16
addition [2] 83/21 I 195/13 167/3 180/12 aggressively [1] 192/15 195/2 197/24 I 32/18 57/22 81/8
183/12 183/17 189/9 103/3 198/15 198/15 199/13I 115/16 115/17 120/15
additional [7] 7/2 [adviser [4] 112/13 ago [5] 27/3 38/2 I 199/18 199/22 202/14) 122/2 148/16 154/19
3715 sar 108/16 I 145/13 195/2 195/3 I 38/6 58/21 63/23 203/5 155/2 165/13 187/12
adviser's [1] 195/9 Iagree [3] 12/8 39/4 _Iallegation [2] 27/21 I 196/13 196/19
additionally advisers [30] 8/20 198/5 183/3 am [26] 1/2 28/24
188/22 9/7 9/19 23/7 42/21 Iagreed [14] 14/21 allegations [2] 4/19 I 29/11 41/25 49/19
address [4] 98/17 90/13 91/4 102/6 16/21 34/24 75/16 6/19 49/21 62/15 62/17
110/14 117/10 120/24 107/5 112/8 115/13 I 78/17 108/11 114/12 Ialleged [2] 4/7 68/21 71/7 85/18
addressed [13] 37/1 115/22 131/12 149/18] 119/6 119/9 124/12 I 161/10 95/18 95/22 104/2
38/16 94/22 120/25 154/6 156/25 157/17 I 146/3 166/24 174/4 allegedly [1] 22/8 104/3 114/15 121/9
4121/5 122/18 122/21 160/18 162/6 162/11 I 186/7 alleviate [1] 189/15 I 127/5 134/18 173/19
4124/1 139/15 149/23 162/13 162/25 163/9 Iagreeing [3] 46/9 alleviating [1] 100/24) 175/23 177/10 184/24}
167/10 185/4 193/16 165/11 184/12 192/21] 160/21 195/3 allocated [2] 57/18 I 186/13 196/13 203/10}
addresses [1] 163/15 197/24 198/4 198/5 Iagreement [9] 14/9 I 195/13 amended [2] 146/18
addressing [3] 4/24 198/14 14/13 14/16 15/15, allow [6] 25/23 26/11} 146/19
48/15 62/4 Advisory [8] 51/20 16/13 33/2 76/18 68/11 78/16 172/13 I amendment [1]
adds [1] 90/13 92/22 96/19 117/11 170/3 172/8 203/2 145/8
adequate [1] 12/2 117/17 133/7 159/21 Iagreements [2] allowed [1] 46/5 amendments [2] 2/9
adjourned [1] 203/10 178/21 126/16 173/24 allowing [1] 115/22 I 2/12
Adjournment [1] affect [1] 199/11 Ah [1] 69/14 allows [2] 186/9 Amongst [1] 163/25
1107 affected [3] 55/22 Iaim[1] 189/19 201/14 amount [31] 8/25
adjust [5] 58/16 83/5 170/24 albeit [2] 82/25 151/2Ialmost [5] 97/16 25/2 30/1 30/4 30/17
58/17 94/7 105/17 affirmed [2] 1/9 aligned [2] 147/25 112/12 158/4 158/18 I 31/19 31/21 35/2
198/7 204/3 189/13 171/19 45/20 58/8 65/17
adjusted [2] 105/9 afford [1] 148/14 all [133] 2/1 2/4 6/18 Ialone [1] 141/6 65/20 65/21 78/17
1405/9 afraid [2] 97/10 11/10 11/11 12/7 along [2] 58/16 103/15 106/6 106/10
adjusting [1] 109/11 183/20 12/12 13/5 15/2 15/2 I 198/16 106/10 114/13 120/1
admin [2] 25/20 after [21] 27/12 29/2 I 17/6 18/21 18/24 already [29] 3/12 136/25 150/10 150/21
31/12 34/7 43/21 60/9 61/1 I 20/14 20/18 22/18 18/12 21/4 21/10 153/18 156/14 165/10)
67/10 79/16 80/14 22/24 23/7 29/4 29/7 I 35/14 36/7 38/10 186/9 187/13 187/18
administer [1] 183/9 I 0/45 84/7 83/2 84/17I 29/18 30/16 31/24 I 57/11 57/17 58/4 58/8I 188/18 192/2
(64) acting - amount
INQ00001200
INQ00001200
A 134/18 136/11 136/12I Appendix [1] 95/2 appreciate [3] 149/9 I 155/14 159/12 159/17
amounts [3] 30/14 I 137/2 13715 142/15 IAppendix 1 [1] 95/2 I 177/5 202/6 170/5 180/15 181/22
73/9 143/6 155/24 166/3 Iappetite [2] 24/18 _ Iappreciated [1] 183/6 184/2 186/6
analyse [1] 32/18 I 170/24 174/12 173/24I 135/18 201/22 186/17 191/8 198/24
analysing [1] 78/24 I 173/24 178/14 178/21Iapplicable [1] 185/15 approach [6] 82/2 IARQ [1] 79/24
analysis PI7) 75/22. I 182/15 189/1 188/19 /applicant [14] 61/16 I 142/25 160/11 197/22] arranged [1] 66/19
78/39 B119'81/20 I 189/23 191/15 194/17] 70/16 70/18 97/3 __I 197/22 198/18 arrangement [4]
82/6 82/12 82/20 I 196/14 1341/19 131/20 135/6 Iapproached [1] 172/11 172/13 172/15}
83/17 85/20 85/24 [Anybody [7] 77/23 I 153/5 158/5 158/6 I 111/19 202/8
a72 87/14 s9/16 I 1071/8 165/9 172/18 _ I 167/6 approaches [2] 88/1 I arrangements [2]
104/22 123/20 140/23) 179/21 184/16 202/23I applicants [30] 21/12) 184/6 48/14 59/24
442/10 anyone [1] 20/18 I 21/19 37/1237/12 Iapproaching [1] _Iarrival [2] 22/17
Angela [1] 22/21 anything [18] 35/2 I 39/24 42/13 54/22 I 113/15 22/18
anniversary [1] 43/1 67/22 77/1 78/3 I 66/15 72/10 77/17 Iappropriate [20] _Iarrived [1] 197/14
1312 81/9 87/24 105/12 I 98/18 106/14 111/4 I 23/15 24/9 29/4 31/2 Iarticle [1] 25/21
announce [1] 136/5 I 117/15 120/12 124/24] 111/6 126/1 128/11 I 42/22 61/21 62/8 articulate [3] 32/19
announced [8] 36/3 I 125/20 131/6 147/12 I 128/18 129/24 131/5 I 77/11 78/18 83/19 I 147/14 18118
76102 76/24 101/68 I 167/19 168/3 196/17 I 140/10 150/8 152/21 I 86/18 110/2 117/14 articulated [11] 15/7
4118/5 118/8 118/14 199/10 152/21 152/24 152/25) 137/15 139/9 139/19 I 15/8 15/9 15/13 16/2
190/14 anyway [3] 145/1 153/2 153/22 153/23 I 139/22 142/2 166/6 I 16/6 20/21 137/25
announcement [7] 147/15 189/17 153/25 156/22 203/5 149/3 159/19 192/6
SBI? 118/12 133/12 Ianywhere [1] 109/3. I application [24] appropriately [6] articulating [2]
181/12 187/6 187/7 Iapart [A] 178/12 37/24 38/12 38/21 11/18 28/8 30/21 33/6I 151/24 191/19
190/15 Apologetic [1] 37/20 I 38/24 39/2 39/6 41/1 I 138/21 154/8 articulation [3] 17/8
anonymous [1] apologies [10] 2/17 I 44/25 60/10 68/20 appropriateness [1] I 136/3 136/3
184/15 3/1 15/8 27/17 35/1 77/1 78/2 79/3 87/22 I 14/18 as [264]
another [12] 38/25 59/10 74/21 85/14 95/17 97/17 106/7 approval [1] 199/14 Iask [12] 12/24 54/15
59/15 79/20 82/1 83/7! 104/20 153/4 119/25 128/5 128/12 Iapprove [2] 192/12 I 68/15 77/13 132/15
94/11 115/6 132/16 apologise [6] 12/14 I 163/24 164/5 196/3 I 192/13 133/3 133/21 147/3
143/16 153/12 153/17 36/16 36/24 103/21 199/23 approved [1] 84/10 I 148/24 150/13 176/10
4169/4 104/1 130/12 applications [49] approximate [2] 63/3I 202/1
answer [6] 29/23 apparent [3] 64/2 39/16 40/22 41/16 71/3 asked [11] 13/17
88/17 105/7 148/15 183/7 184/4 43/7 43/15 43/16 approximately [3] 16/17 16/18 24/11
155/19 181/18 appeal [33] 76/24 44/14 46/6 46/11 70/24 71/21 105/18 I 30/6 34/13 34/14 48/8
answers [4] 37/11 100/12 101/8 116/17 I 46/24 47/1 54/17 April [6] 15/6 17/9 110/19 189/19 190/15)
101/18 183/11 183/25I 118/13 132/24 133/4 I 54/21 59/4 60/6 60/11) 24/6 24/6 144/4 asking [7] 29/5 72/21
anticipate [6] 17/18 133/17 133/24 134/8 I 60/12 66/25 67/6 168/19 91/7 109/18 159/8
36/4 58/12 85/11 134/9 134/19 134/23 I 67/21 68/4 68/7 68/11I arbitration [4] 108/15) 172/12 183/5
101/12 125/8 135/2 135/13 135/14 I 68/14 68/18 69/22 116/9 116/12 116/15 Iaspect [5] 29/21 32/2
anticipated [1] 135/15 136/14 137/23] 70/7 70/10 77/9 82/25I Arbuthnot [1] 36/17 I 95/17 160/12 160/22
118/24 137/24 138/3 138/14 I 83/4 83/14 98/4 99/2 Iarchives [1] 80/18 Iassess [6] 41/11
anticipating [1] 138/18 139/3 143/3 I 99/4 101/2 121/13 are [308] 86/2 92/12 92/15
179/21 151/2 159/18 159/18 I 123/24 124/5 124/6 Iarea [2] 88/3 123/15 I 92/25 94/11
anticipation [4] 159/25 170/18 171/20) 124/14 139/17 139/21Iareas [3] 9/10 116/24I assessed [3] 51/20
45/17 87/11 101/15 171124 173/15 142/6 153/21 155/9 I 125/14 139/21 188/17
101/19 appealed [1] 168/21 I 167/1 167/8 175/10 Iaren't [4] 48/11 75/4 Iassessing [1] 78/24
any [79] 9/9 10/13 appeals [27] 9/11 applied [5] 31/20 154/15 169/9 assessment [21]
15/3 17/11 17/13 19/6) 100/9 101/1 101/5 49/4 66/5 137/5 138/9Iargue [1] 186/5 43/8 65/13 85/16
19/14 21/22 27/15 101/5 102/10 103/12 Iapplies [2] 6/12 arguing [1] 33/4 85/20 85/22 87/9
29/18 30/3 30/10 107/12 107/15 116/18] 107/21 argument [2] 29/15 I 88/14 92/19 95/12
31/21 32/2 33/21 39/7 116/22 117/12 117/13] apply [16] 32/11 38/9] 114/13 97/2 99/17 102/23
39/25 42/18 46/4 117/22 118/2 119/7 I 42/22 49/4 52/2 61/1 Iarising [1] 60/23 103/7 104/22 104/23
47/15 47/15 48/3 50/5 119/9 132/14 133/11 I 61/14 61/17 61/18 arose [1] 38/22 139/20 152/12 155/23)
52/5 54/4 56/1 58/19 I 134/13 134/20 138/12) 94/25 107/16 129/25 Iaround [46] 6/19 175/25 178/20 193/10)
58/25 59/1 61/7 62/4 I 198/20 139/12 145/24I 135/6 138/10 147/5 I 7/10 8/8 12/1 17/22 Iassessor [7] 75/23
146/10 159/12 175/17 30/4 30/11 30/21 81/11 85/18 86/5
ont ae eee appear [4] 166/2 _ applying [2] 37/10 I 30/24 31/8 31/19 87/17 92/12 92/14
81/18 82/5 86/23 90/9 166/3 192/18 199/2 I 77/15 32/18 32/21 33/9 42/9I assign [1] 54/5
93/18 96/15 96/16 appeared [2] 1/14 appointed [5] 38/25 I 45/11 50/12 60/19 assigned [2] 53/17
1401/7 103/18 104/21 198/10 77/20 118/10 121/6 I 69/3 77/14 77/21 86/4) 107/24
1409/3 116/7 118/24 I@Ppears [7] 2/4 24/23] 193/19 91/12 107/1 108/3 assignee [1] 39/1
1420/4 120/14 121/23 45/25 128/17 139/24 Iappointees [1] 86/17 I 112/14 117/6 117/20 Iassist [50] 3/19 5/22
422/14 129/13 134/8 191/4 196/6 appointment [3] 122/5 122/7 125/11 I 6/17 7/15 8/5 10/23
appellants [1] 168/21) 23/17 23/18 104/17 I 139/8 147/19 154/25 I 11/14 36/14 41/6
(55) amounts - assist
INQ00001200
INQ00001200
A automating [1] 76/16 89/4 92/9 94/3 I 169/21 183/7 184/3 I 76/22 76/22 77/19
assist... [41] 42/12 _ 125/10 94/10 96/24 98/1 because [113] 8/21 I 77/22 79/11 81/10
43/3 47/22 48/5 52/25I automation [4] 84/1 I 103/9 106/3 108/22 I 8/22 11/18 13/23 84/10 88/6 88/8 90/17,
53/19 54/1 55/4 59/5 I 84/2 125/12 155/14 I 108/25 109/5 109/6_ I 14/15 16/12 27/19 91/3 93/22 93/24 95/4,
64/13 65/14 66/2 automisation [1] 109/8 109/12 109/17 I 28/6 28/16 33/19 95/21 97/23 101/6
68/25 69/23 70/2 83/23 115/11 115/18 115/20) 36/20 40/11 41/9 105/6 105/11 107/5
70/23 71/17 72/16 Iautumn [1] 64/9 116/3 121/2 127/3 41/10 43/17 43/18 109/24 110/20 111/1
74/17 77/16 83/25 IaVailability [5] 1314/7 I 127/24 129/6 138/6 I 48/13 48/13 50/25 113/6 114/3 114/8
85/4 86/14 88/3 89/22I 190/4 154/20 164/20 I 140/6 143/10 152/2 I 52/12 55/19 55/24 114/12 115/15 115/16)
90/24 91/25 97/8 168/12 153/11 157/9 163/4 I 59/12 61/12 61/17 115/16 116/11 116/14)
104/7 112/21 116/20 I@Vailable [24] 11/2 I 163/13 164/16 166/9 I 61/18 67/24 68/5 116/18 118/4 118/11
134/13 153/1 157/15 I 30/1 30/4 30/8 32/8 I 172/23 183/24 190/5 I 72/20 73/17 74/3 118/14 119/6 119/7
174/14 175/20 179/25] 38/14 51/21 58/10 195/6 199/15 200/23 I 75/13 76/1 76/3 76/15I 119/9 121/19 123/4
4191/4 194/24 200/1. I 79/23 128/2 128/5 I background [8] 78/20 81/2 82/5 82/11) 123/14 124/2 125/24
20014 128/6 128/16 131/24 I 51/12 92/23 130/20 I 83/7 83/12 83/13 87/8] 126/11 127/8 127/8
assistance [1] 150/8 154/25 156/9 I 137/7 137/9 156/8 _I 87/10 88/18 89/4 90/2I 127/10 127/11 128/2
a 156/23 167/22 167/22I 176/13 176/18 90/20 91/3 91/11 128/17 129/9 136/11
assistant [8] 48/23 I 168/10 169/21 175/24] backward [3] 105/14 I 91/20 92/18 98/3 99/6 139/16 139/17 139/17
4912 52/8 53/17 5416 I 1819 105/15 105/18 101/22 105/10 106/16I 139/19 141/9 141/23
55/11 55/25 170/17. Iaverage [32] 44/25 Ibad [1] 7/5 4107/7 110/16 12/7 I 141/24 146/7 148/17
assistants [11] 48/10] 74/5 74/12 74/14 badly [2] 120/11 113/1 115/1 116/13 151/25 152/20 153/1
10/6 40/11 60/3 51/16) 74/23 74/25 75/2 75/7I 192/6 117/14 117/19 120/22I 153/21 156/6 157/3
52/24 54/21 57/6 59/1] 82/19 82/21 87/2 I balance [2] 81/16 I 124/13 129/9 132/3_I 157/4 162/16 162/20
59/2 62/22 88/13 89/16 89/17 I 152/23 132/14 134/12 135/21] 163/8 163/17 165/1
agsistants/employee I 906 91/9 97/2 99/18 Ibalanced [1] 149/5 I 137/19 138/7 138/16 I 166/19 166/21 166/23
si 5421 99/20 103/6 111/14 Ibalances [1] 20/6 I 138/23 139/23 142/9 I 166/24 167/3 171/3
assisting [1] 122/7 111/20 112/21 130/17I ballpark [1] 63/3 143/11 159/6 160/21 I 171/12 172/14 172/22
associated [3] 24/17 I 136/20 188/5 157/11 IBank [3] 3/21 3/24 I 162/19 165/7 165/18 I 173/2 173/22 175/4
OTI13 87/8 157/13 175/9 176/4 I 4/15 167/16 168/7 169/1 I 175/14 176/16 17/7
assume [4] 35/7 50/8) 179/22 197/6 bankrupt [1] 61/6 I 172/8 172/10 172/15 I 17/9 178/14 185/1
155/19 185/21 averaging [2] 97/6 Ibankruptcy [13] 65/7) 172/16 173/21 175/21) 186/3 187/10 187/12
97/16 121/20 122/1 122/17 I 177/15 178/16 180/14I 193/1 193/7 194/9
assumption [2] 35/7 I avoid [6] 83/20 87/9 I 122/20 122/22 123/8 I 1841/1 181/5 181/22 I 195/16 195/25 199/22
assured [1] 80/5 91/17 115/10 130/24 I 123/9 123/13 126/18 I 183/21 184/2 184/7 I 201/9
at [245] 132/5 196/7 196/11 196/14 I 185/24 186/23 189/16I before [35] 12/24
ATM [1] 7/17 avoidance [1] 93/15 Ibar [3] 80/22 81/1 191/11 191/11 191/20] 13/2 22/17 23/17 24/2
attachments [1] await [1] 189/5 92/11 192/3 192/13 200/7 I 26/15 32/20 45/23
1477/4 awaiting [4] 142/13 Ibarcharts [1] 82/21 I 200/8 201/16 58/21 62/20 77/18
attend [1] 96/12 142/14 143/9 164/22 Ibare [1] 179/6 become [3] 49/17 77/21 79/15 81/7
attendance [1] 96/15 award [2] 144/25 barriers [1] 107/10 I 55/8 55/9 84/17 85/8 97/7
attendees [1] 144/6 146/24 bars [3] 44/297/18 Ibeen [186] 2/17 2/19 I 105/11 107/19 110/17
attention [3] 67/24 {aware [29] 47/15 141/18 2/21 2/24 3/2 3/4 3/12I 120/22 126/10 132/5
110/20 117/1 47/16 47/16 47/18 base [2] 37/11 157/2 I 3/18 5/8 5/16 8/10 132/13 132/15 133/6
attitude [1] 19/1 49/1 49/21 49/22 based [5] 62/3 13/5 13/8 13/11 14/1 I 133/9 149/3 155/19
attorney [2] 39/1 60/11 60/23 71/7 101/19 110/16 162/9 I 14/2 14/5 14/16 15/10I 158/20 160/25 170/9
61/21 74/19 79/8 96/2 96/5 I 198/2 16/4 16/5 16/16 17/9 I 179/24 180/14 183/17
audience [1] 179/7 114/14 114/15 131/8 Ibasic [1] 133/3 17/13 17/16 18/12 before/after [1] 85/8
August [8] 73/3 133/24 139/7 156/4 I basically [1] 66/4 18/13 20/7 22/13 27/3I began [1] 113/4
73/13 136/21 162/1 I 198/20 158/22 165/25I basing [1] 163/8 27/23 32/18 32/21 begin [1] 1/18
168/19 195/15 199/18I 167/25 173/24 183/21Ibasis [7] 24/10 30/20] 33/19 34/9 34/24 35/3I beginning [6] 113/14
199/22 183/22 194/16 199/1 I 134/18 134/20 179/10I 35/14 35/22 35/23 125/3 125/5 128/12
author [1] 163/21 awareness [1] 182/7 197/18 36/5 36/7 38/8 38/13 I 135/15 185/5
authorisation [1] 163/22 basket [1] 99/13 39/9 39/17 40/9 41/20I begins [1] 54/15
4127/4 away [13] 16/25 BAT [3] 65/13 74/9 I 43/7 43/13 44/7 46/12) behalf [14] 20/18
26/24 107/8 117/8 155/23 46/24 48/8 49/12 28/1 29/12 38/24 39/2
authorising [1] 32/4 I 0/8 135/12 135/14 IBates [7] 67/11 83/3 I 49/25 50/10 50/12 I 49/5 50/10 61/10
authorit tooo 142/4 146/24 156/7 I 98/5 124/4 172/2 50/16 50/25 51/15 I 61/14 61/19 61/20
12717 tA7IA 165/17 185/25 197/17I 172/21 188/6 51/25 55/2 55/5 55/6 I 103/21 135/9 143/24
automate [1] 103/1 Ia@Wful [1] 172/18 BAU [1] 32/23 56/8 57/11 57/12 behaviours [1]
automated [2] 429 IB st*«~S=«d PC 57/18 57/22 58/4 58/5I 198/19
99/21 Bs Beamish [1] 36/18 I 58/8 58/10 58/20 behind [7] 21/13
automatically [2] back [49] 3/22 13/11 Ibear [2] 183/23 58/22 59/4 59/16 73/25 77/1 77/1 101/6
iT a0 15/5 29/25 33/9 51/6 I 183/24 60/16 61/6 62/24 118/14 129/20
62/11 68/6 73/21 became [5] 3/21 18/9] 63/12 64/15 76/7 beholden [1] 109/14
(66) assist... - beholden
INQ00001200
INQ00001200
B 67/3 73/10 84/13 200/22 32/24 32/24 33/12 28/18 29/3 54/7 81/4
being [53] 13/18 97/16 101/1 101/2 breakdown [2] 200/5I 51/4 53/4 53/8 63/13 I 118/17 132/7 148/14
23/20 24/10 24/23 122/24 123/2 124/5 I 200/18 76/12 96/21 98/9 176/22 187/17
27/9 27/22 29/22 136/12 137/16 138/1 Ibreaks [2] 27/7 32/25I 117/12 118/22 121/7 I capabilities [1]
39/16 41/14 41/16 148/12 154/14 161/5 Ibrief [1] 19/12 125/14 126/20 126/23] 125/13
45/24 57/8 60/12 161/7 162/4 175/9 briefing [1] 12/13 130/23 135/25 137/12I capital [3] 4/17 4/18
63/17 63/22 74/11 177/12 178/11 178/13] briefings [1] 180/15 I 170/11 170/14 177/2 I 181/23
74/13 76/14 78/6 188/3 191/5 191/9 briefly [12] 1/19 9/14 I 182/16 191/6 caps [2] 4/8 156/19
79/23 85/14 87/25 197/24 199/21 24/22 85/4 87/21 Business’ [2] 24/25 Icapture [1] 145/23
88/23 90/18 97/3 beyond [3] 36/11 92/23 107/19 121/21 148/9 care [3] 41/20 131/11
97/17 100/8 103/8 130/17 192/24 137/7 139/20 171/14 IBusiness/the [1] 178/9
113/15 118/15 119/10 Bickerton's [2] 25/16] 194/24 182/16 careful [1] 125/11
427/17 135/3 137/13 26/12 brilliant [2] 162/14 I businesses [1] 4/16 Icarefully [1] 135/20
140/25 141/20 143/20) ig [31 84/13 144/22 180/3 bust [1] 4/17 Carl [5] 146/3 147/20
152/23 154/16 165/2 161/22 bring [29] 4/22 9/23 Ibusy [2] 44/13 83/19 I 178/13 178/13 188/4
165/23 176/19 181/3 IPiggest [3] 11/16 10/5 12/21 17/24 but [222] Carl's [1] 144/20
4181/4 181/15 184/14 I 32/20 33/1 23/10 24/2 38/17 Ibypass [1] 111/16 I carries [1] 78/25
4185/7 187/6 188/11 _ (Bill [1] 146/23 45/21 46/21 66/22 bypassed [1] 112/18 Icarry [3] 10/22 11/11
489/16 191/2 196/22 [billion [4] 30/8 36/5 I 67/23 69/14 92/20 I bypasses [1] 147/9 I 79/2
197/25 35/12 58/19 99/10 110/12 116/3 cc. carrying [4] 14/18
BEIS [1] 170/25 bills [1] 165/11 116/24 116/24 116/25) I «16/15 86/14 174/22
BEIS' [1] 174/5 bit [10] 23/6 24/1 118/6 119/13 121/2 Icalculated [2] 18/15 Icase [59] 23/8 32/14
BEIS0000719 [1] 81/24 114/25 145/4 I 134/9 134/14 152/14 I 150/16 I 33/12 43/13 54/4
1476/9 162/15 176/24 182/12I 195/21 199/15 202/1 Icalculating [1] 31/20 I 61/13 65/15 65/15
BEIS0000738 [1] 187/25 191/25 bringing [3] 99/11 calendar [10] 82/21 I 66/1 75/2 75/21 75/23}
4187/2 Black [1] 192/9 135/13 135/13 83/16 87/4 90/7 97/16] 81/11 81/17 82/4
BEIS0000763 [1] BLAKE [8] 1/10 broad [3] 12/25 110/19 110/21 135/19) 85/16 85/18 85/24
1444/3 45/23 62/12 132/13 I 93/12 108/1 135/22 136/6 85/25 86/4 87/2 87/5
BEIS0000764 [1] 136/17 202/7 202/16 I broadly [3] 9/25 call [23] 6/21 27/11 I 87/8 87/14 87/17
146/19 204/5 23/12 155/22 34/1 34/2 52/17 59/21] 87/25 88/7 88/14 89/5
blue [2] 39/20 39/23 Ibrought [11] 20/14 I 75/20 76/10 76/10 —_I 89/16 89/25 92/12
BEIS0001093 [1] Board (20) 10/15 I 2017 2413 69/15 I 89/10 112/4 114/16 I 92/14 93/14 93/20
belief [2] 2/8 3/9 20/2 20/12 24/17 78/9 110/20 118/10 I 115/22 121/10 121/10] 95/21 97/15 101/7
believe [23] 21/14 I 27/11 27/15 28/1 28/5] 122/19 139/25 134/19] 138/4 139/7 141/17 I 102/22 105/10 107/24
27/8 57/6 513 81/14 I 28/6 28/10 29/11 54/9I 134/21 159/3 159/3 169/5 I 107/25 112/23 114/9
81/15 82/8 84/12 94/6) 04/9.54/12 54/14 —_ I budget [4] 35/4 57/24] 169/6 169/6 114/11 114/15 114/17
4100/3 101/14 102/15 I 96/19 117/11 117/17 I 58/7 181/12 called [10] 4/6 4/12 I 146/16 152/12 154/23
403/22 114/7 114/8 I 1393/7 159/21 build [7] 23/21 33/21 I 5/12 7/3 13/13 17/5 I 163/4 163/11 164/17
4115/3 142/23 142/24 [boards [1] 10/8 78/15 86/4 89/7 17/6 65/13 147/16 I 171/18 171/23 177/17
4149/3 152/11 159/20 Ibody [1] 178/21 114/24 118/16 156/22 181/8 185/24 201/16
159/22 190/2 Bogerd [1] 22/21 building [6] 46/8 77/2Icalling [1] 84/9 caseload [1] 90/14
believed [1] 180/24 Ibold [1] 142/9 85/25 118/20 118/22 Icalls [5] 167/17 cases [95] 8/21 8/22
belong [1] 17/8. IPone [1] 135/10 197/11 168/11 168/12 183/14) 14/4 11/2 20/7 40/17
below [14] 43/6 45/2 [bored [1] 149/7 builds [2] 132/1 183/16 41/4 41/8 41/10 41/12I
65/13 65/16 65/16 both [10] 4/20 19/21 I 196/16 came [13] 4/13 7/2 41/15 44/2 48/1 49/22)
65/19 93/7 136/24 24/22 49/25 124/24 I built [11] 33/19 60/12) 43/21 44/16 58/21 49/24 65/12 68/23
155/23 173/10 177/25I 133/17 135/12 136/13] 77/7 78/10 118/15 60/15 65/20 98/5 71/6 78/16 78/16 81/3
178/24 188/10 191/7 I 17/4 202/18 129/15 138/18 138/21I 116/22 117/11 137/8 I 84/12 84/20 88/10
benefit [3] 13/4 [Pottom [14] 19/17 I 139/4 141/20 198/1 I 180/20 180/23 89/24 89/25 90/2
165/16 165/20 21/8 24/7 25/12 26/18I bullet [1] 24/21 Cameron [5] 26/17 I 90/10 90/21 91/1
best [7] 2/8 3/8 88/10] 5/2 90/4 146/20 bunch [1] 198/10 I 26/20 28/12 33/15 I 91/11 91/11 91/21
17/7 135/11 138/25 I 163/20 174/2 187/5 Ibundle [1] 161/3 33/22 92/5 93/24 97/23 99/1
145/11 bound [1] 39/4 burden [3] 56/6 Cameron's [2] 99/8 104/19 105/13
Beth [2] 188/25 [Poy [1] 120102 84/17 64/20 197/13 197/20 105/15 108/5 112/17
4190/4 branch [6] 48/10 bureaucracy [1] 32/4Ican [243] 113/2 113/3 114/11
better [11] 15/10 I 48/11 54/19 80/3 80/4I bureaucratic [3] can't [24] 34/16 117/13 117/23 122/3
15/22 37/9 42/2 74/2 I 170/16 18/16 18/22 21/24 _I 34/17 35/1 40/20 43/5I 123/6 123/8 126/7
80/23 89/11 91/7 branches [4] 60/8 I burnt [1] 129/10 45/11 47/9 50/4 59/9 I 126/22 127/3 127/15
91/23 112/10 114/18 I 60/9 61/1 63/10 business [43] 2/20 I 59/9 69/15 77/18 81/8] 140/6 142/16 143/10
between [38] 14/9 [brand [1] 25/24 3/5 3/15 5/4 7/20 8/3 I 81/9 81/12 81/25 143/25 146/5 150/18
24/23 26/16 40/12 I breach [1] 20/8 8/23 10/12 11/19 I 93/25 97/10 124/23 I 150/19 153/19 155/24I
4115 42/17 44/3 91/4 Ibreak [10] 13/2 24/2 I 15/10 21/15 23/25 I 140/16 160/16 160/19I 156/4 158/17 159/5
53/3 53/6 63/12 66/3 I 20/4 36/12 62/9 62/16] 26/4 27/3 28/14 28/14] 174/17 202/23 4162/9 163/1 163/2
160/25 166/7 166/13 I 32/3 32/10 32/14 cannot [10] 21/11 163/4 171/12 171/16
(87) being - cases
INQ00001200
INQ00001200
Cc 129/23 143/3 143/22 I 125/5 140/22 188/12 Iclause [1] 93/24 88/22
cases... [22] 171/17 143/22 151/9 151/10 Icirculated [1] 104/15 Iclause 34 [1] 93/24 Icombined [2] 72/12
174/19 172/1 1472/9 I 194/22 154/22 162/12Icircumstances [3] _Iclauses [1] 14/11 73/1
472/14 172/17 172/22! 162/12 167/1 180/25 I 60/24 64/23 93/14 clauses 5[1] 14/11 Icome [46] 4/25 12/14
472/25 174/14 176/3 180/25 199/13 199/13] civil [1] 9/21 clear [48] 13/14 13/1 23/23 29/9 29/16)
488/12 194/22 195/1 chain [6] 24/4 25/15 I claim [59] 5/23 5/25 I 13/17 14/2 14/9 14/11) 29/24 52/21 54/17
195/16 196/7 196/7 26/16 176/10 176/18 I 6/2 9/6 49/20 50/4 14/21 15/20 15/21 57/10 60/11 62/11
196/11 200/7 200/9_ I 187/3 53/16 53/17 54/5 16/13 17/20 18/9 29/1I 64/8 65/10 89/4
200/41 200/12 200/13) Chair [7] 10/21 16/6 I 55/12 59/1 60/19 61/9) 29/6 30/5 33/22 35/21) 101/16 104/5 105/1
cash [1] 32/10 17/20 53/21 83/22 64/20 64/20 65/16 36/22 40/2 41/21 49/2) 105/3 107/17 107/17
categorisation [3] 102/25 104/25 65/19 66/1 66/2 66/3 I 56/11 57/13 99/17 120/24 123/18 124/17)
65/11 66/5 71/10 chaired [1] 53/7 66/3 68/7 69/7 75/7 I 100/10 103/1 124/17 I 127/24 131/14 131/17,
category [5] 7/3 chairman [2] 19/10 I 85/20 86/2 86/3 92/12I 129/23 143/23 145/9 I 132/25 133/2 149/19
59/13 135/1 169/4 19/23 92/15 95/4 95/10 155/1 158/14 162/25 I 149/22 153/11 155/15
173/20 challenge [12] 31/5 I 103/13 103/15 114/13) 165/18 165/21 178/19] 155/23 163/4 163/7
causation [1] 95/12 32/18 45/10 45/12 128/21 128/22 129/1 I 180/5 180/7 180/10 I 166/9 174/23 175/3
cause [1] 111/23 45/13 101/22 104/24 I 139/23 139/24 139/24) 182/20 186/3 187/12 I 178/22 183/24 193/8
caused [2] 64/1 122/14 159/17 162/22I 140/3 142/23 142/23 I 187/24 187/24 190/18) 195/2 200/23 201/7
94/18 165/14 165/17 148/21 148/21 151/4 I 191/7 192/7 192/8 201/10
causes [1] 112/3 challenged [3] 47/9 I 151/8 174/4 174/11 196/13 comes [7] 31/15
caution [4] 169/18 47/20 181/15 175/25 179/12 184/8 Iclearer [1] 15/24 65/16 100/24 102/10
169/19 202/9 202/24 challenges [3] 117/5 I 184/16 184/21 188/17I clearly [12] 12/16 151/6 151/10 184/1
cautioned [3] 201/9 117/9 117/20 188/21 188/21 189/7 I 15/13 21/17 27/11 comfort [1] 28/4
201/22 202/2 challenging [2] 21/14I 193/23 56/9 56/14 123/7 comfortable [13] 9/7
cautions [3] 169/14 31/1 claim’ [1] 182/10 152/9 165/20 171/21 I 27/15 122/15 143/2
1473/21 173/23 Chancellor's [1] claimant [9] 9/7 46/1 I 186/23 189/10 143/4 157/18 185/21
cautious [1] 177/10 181/20 135/2 147/2 147/16 Iclerks [1] 79/11 191/24 192/18 192/21
caveats [1] 36/1 change [20] 17/13 147/23 178/2 188/23 Iclient [7] 23/8 23/8 196/21 198/11 198/18)
cent [56] 37/15 37/18 17/18 17/23 25/1 199/23 145/6 145/10 145/14 Icoming [14] 18/5
43/12 44/22 45/2 70/9 50/11 50/20 53/24 claimants [8] 145/10 I 147/3 149/20 42/6 68/4 77/8 98/8
7418 71/13 71/22 54/1 55/2 55/5 56/19 I 158/11 175/15 189/20) clients [11] 4/11 100/2 117/16 124/19
71/24 71/25 72/1 72/5 63/18 109/8 144/8 189/21 190/19 199/18) 42/22 90/15 112/11 124/20 126/8 129/21
92/5 92/13 92/13 171/6 172/3 173/24 I 199/21 112/14 115/23 159/6 I 133/20 159/1 191/1
101/25 102/2 102/3 182/5 190/15 193/1 Iclaimed [3] 93/17 159/7 165/24 165/24 Icommas [1] 133/23
103/15 103/16 106/9 changed [11] 28/14 I 93/22 156/11 165/25 comment [4] 23/21
1406/10 106/12 106/16) 36/15 48/5 55/6 55/10) claiming [2] 56/1 cling [1] 182/14 178/4 179/15 183/18
106/23 106/24 113/18 125/6 145/4 157/16 I 92/1 clock [2] 26/22 43/21 Icommented [3] 12/4
419/20 119/21 119/23 173/20 192/16 192/17Iclaims [54] 9/1 9/2 Iclose [3] 124/13 178/3 179/2
419/24 120/1 120/2 changes [3] 58/10 9/23 20/11 20/16 124/21 166/18 commenting [1]
120/16 120/17 127/7 58/11 161/22 20/20 40/13 41/14 closed [3] 68/2 68/2 I 176/19
1430/7 130/11 141/14 changing [4] 55/1 42/5 45/17 51/19 52/2) 201/3 comments [2] 177/4
4150/7 150/10 151/19 127/20 127/22 162/3 I 60/7 74/9 74/10 74/10I closely [1] 8/19 178/24
1453/9 153/10 153/13 charged [1] 4/18 74/13 74/23 74/25 closing [1] 138/11 commercial [3]
453/22 157/21 157/23 Charlotte [1] 144/20 I 76/9 76/14 77/5 93/1 Iclosure [1] 124/11 27/25 109/13 115/18
1463/16 163/18 164/11 chart [15] 37/9 39/18 I 94/24 95/3 95/11 Clothes [1] 186/14 I commission [1]
41/19 43/11 44/24 I 99/24 101/15 116/9_ ICo [1] 59/23 160/4
ise 164/26 166/1 I seis 46/23 47/5 66/24I 117/4 121/14 122/22 ICo-op [1] 59/23 commitment [7]
centre [3] 167/10 I 83/28/13 97/5 155/4I 122/24 123/2 123/4 cohort [19] 8/4 38/4 I 16/16 170/9 170/13
167/21 167/25 158/20 164/3 123/25 124/19 128/15I 44/15 46/7 71/23 4173/5 173/8 174/5
certain [5] 65/17 charts [5] 44/2 66/11 I 134/15 141/14 141/20) 84/11 87/11 113/3 174/10
65/20 82/12 139/21 I 72/14 72/16 141/18 I 185/8 190/19 190/22 I 137/19 137/20 137/20I committed [7] 14/4
1451/2 chased [1] 184/14 190/23 193/13 193/20) 140/1 140/5 148/17 I 27/22 34/20 34/21
certainly [9] 30/11 chasing [2] 89/9 195/25 196/2 197/6 I 148/19 169/15 169/16) 57/23 123/13 173/7
113/10 127/5 127/9 89/10 197/7 197/9 198/24 I 184/8 201/25 committee [12]
1436/2 149/14 166/10 cheaper [1] 31/3 200/1 cohorts [1] 87/12 10/17 10/18 10/19
201/21 203/3 check [2] 42/10 clarification [1] collaboration [1] 10/20 10/23 11/1 11/7)
certainty [1] 93/25 45/10 203/3 24/10 16/17 53/21 53/22
cetera [32] 13/24 checks [1] 43/22 clarified [1] 48/9 collaborative [5] 104/25 189/25
31/4 36/2 58/16 59/23 Chief [1] 13/25 clarify [6] 56/14 114/6 114/9 197/19 Icommittees [1] 11/8
61/21 68/13 84/11 choice [2] 99/15 84/23 144/21 167/12 I 197/23 198/3 common [2] 59/11
84/18 84/18 107/9 191/8 202/5 202/22 collaboratively [2] 182/23
118/1 118/1 123/13 [choose [1] 188/16 I clarity [4] 112/13 157/1 162/24 Commons [1] 118/8
424/22 124/22 129/22Ichosen [1] 135/20 I 201/19 202/7 202/12 Icollars [1] 4/8 communicated [7]
circa [5] 72/5 91/1 class [1] 171/8 colour [3] 76/16 78/5 I 14/17 18/20 21/18
(68) cases... - communicated
INQ00001200
INQ00001200
Cc 89/23 121/14 121/19 I 18/9 31/16 31/22 56/12 56/13 59/13 111/9 114/1 114/2
communicated fa) Icomplicated [2] 31/24 50/21 50/23 61/13 116/10 124/2 124/3
communicated. (4 12/17 41/11 55/1 62/6 86/6 86/11 \contracts [4] 20/8 I 128/3 128/6 128/7
1470/10 comprehensively [1] I 131/1 131/2 142/15 I 51/8 51/15 58/1 132/10 133/6 133/19
communicating [3] 131/9 considerations [4] _Icontractual [1] 60/22] 134/10 137/5 137/6
27/8 137/4 144/20 comprises [1] 93/5 I 50/8 57/15 63/22 contribute [1] 96/13 I 139/14 140/12 140/13)
communication [4] concern [7] 20/9 93/12 contribute/observe I 146/9 150/2 150/3
57/2 106/1 138/8 27/18 28/20 107/10 Iconsidered [8] 50/14/ [1] 96/13 150/9 156/12 156/20
139/1 178/24 181/3 196/12 I 60/10 105/11 119/10 Icontrolled [1] 16/20 I 156/21 158/7 168/15
community [1] 29/5 concerned [5] 18/25 I 167/4 188/21 188/23 I conversation [4] 168/16 168/23 169/3
companies [4] 4/17 I 97/20 184/13 196/11 I 194/2 18/24 19/9 19/11 169/12 169/19 172/3
51/12 51/17 51/23 196/13 considering [2] 30/23 172/15 174/24 175/6
company [8] 18/6 concerning [2] 59/16I 50/14 57/16 convicted [12] 9/5 175/11 175/15 175/16)
61/4 170/20 171/1 122/22 considers [5] 64/22 I 18/13 169/9 169/16 175/17 176/1 176/5
174/10 173/18 174/5 Iconcerns [10] 19/14 I 93/13 93/19 95/7 169/17 173/16 173/22I 176/16 193/25 194/1
1474/12 19/15 20/17 33/16 139/18 175/18 201/7 201/15 I 195/17 197/5
compare [1] 73/14 I 33/17 106/25 107/2 _Iconsistency [5] 94/4 I 201/16 201/25 correctly [1] 95/18
compared [3] 39/15 107/4 139/8 166/17 I 115/1 115/1 115/4 conviction [8] 39/7 I correspondence [8]
4111/5 152/25 conclusion [4] 37/5 I 115/20 171/3 171/24 173/11 I 51/2 98/21 109/10
compensate [2] 4/11 100/2 102/5 129/5 consistent [5] 30/23 I 175/15 175/21 182/7 I 115/24 161/5 167/23
conviction/s cost 7
Sooo neatine 6/1) confidential [1] consistently [2] 173/11 127/11
4/19 180/25 114/6 115/16 convictions [25] 5/11/Costcutter [1] 59/19
compensation [33] confined [1] 93/16 Iconstruct [1] 28/6 5/13 5/16 8/10 18/12 Icosts [8] 25/20 31/12
4/3 6/9 8/9 8/24 12/5 confirm [5] 2/4 2/7 Iconstruction [1] 18/18 144/17 146/23 I 65/7 78/21 128/1
12/11 13/13 15/5 44/3 44/6 45/7 176/22 160/3 168/14 168/15 I 128/2 130/25 165/9
45/12 16/4 16/9 24/5 [Confirmation [2] constructive [1] 168/17 168/22 169/2 Icould [67] 10/22
25/18 25/20 25/24 74it4 76/13 197/19 170/17 171/9 172/10 I 13/21 17/10 17/24
29/20 31/13 31/15 confirmed [9] 1/15 Iconsult [1] 187/1 179/10 184/3 187/8 18/1 19/5 19/16 24/3
32/5 34/8 34/22 35/10! 7/3 41/1 43/9 44/4 consultation [4] 187/9 187/19 197/16 I 24/13 38/17 40/23
42/23 43/1 120/2 45/2 45/5 46/5 67/20 I 136/12 179/7 179/23 I 199/21 201/17 41/8 45/21 46/11
4144/7 144/10 170/15 confirms [2] 170/13 I 180/21 convoluted [1] 25/20I 46/21 46/22 51/8
1474/6 177/2 185/8 173/5 consulted [6] 133/23 Icoordinate [2] 60/7 I 51/25 52/2 52/14
487/11 191/1 conflated [2] 29/23 I 179/3 180/8 180/9 85/23 52/24 54/8 54/10
compile [1] 85/19 52/14 183/3 183/4 coordinated [1] 55/14 55/15 64/6
compiling [1] 158/20 COMflict [1] 13/21 Icontact [5] 70/16 81/14 69/12 69/16 74/7
comp! nt [1] 41/2 conform [1] 13/10 70/19 163/19 167/10 Icope [1] 101/13 75/17 75/17 86/6
complaints [2] 6/19 confused [1] 29/25 I 167/20 copies [1] 2/1 88/12 92/6 92/9 92/20
413/21 confusing [3] 23/1 Icontact/querying [2] Icore [3] 167/24 96/17 96/24 111/24
complete [6] 6/7 153/4 153/5 70/16 70/19 177/13 178/4 113/11 115/5 117/6
85/12 127/12 190/22 connected [1] content [1] 102/3 Corfield [1] 51/3 117/9 117/22 123/21
197/7 200/5 173/17 contest [2] 150/12 [corporate [7] 26/11 I 124/15 128/8 129/5
completed [8] 8/2 8/6 conscious [5] 13/8 I 151/4 60/21 60/25 61/2 61/5I 130/3 132/18 134/14
8/7 8/8 43/8 85/11 41/10 90/15 102/8 contesting [2] 165/6 165/7 135/22 155/2 157/9
86/12 200/24 143/24 151/14 151/15, correct [113] 3/16 157/19 163/19 168/4
completely [11] consequences [1] context [1] 28/13 3/17 4/3 5/4 5/5 5/10 I 170/8 180/15 185/25
13/18 26/1 37/23 42/8) 82/9 Continually [1] 27/23) 5/13 5/17 5/20 5/21 188/12 190/5 198/21
45/16 56/16 57/4 consequential [17] _Icontinue [13] 25/19 I 6/14 6/15 7/22 7/23 199/15 201/6 201/8
86/22 96/14 118/18 52/2 64/3 64/6 78/8 =I 31/11 41/25 54/17 8/12 8/13 9/12 9/13 I 201/12
186/10 86/1 86/3 93/2 93/17 I 75/19 76/10 84/4 9/21 9/22 24/15 24/16I couldn't [6] 61/17
completing [2] 37/16 94/24 94/25 117/1 140/5 143/15 179/8 I 25/11 28/22 34/20 68/4 135/23 171/12
37/18 128/15 128/21 129/25) 179/24 184/20 185/16) 37/5 37/6 39/21 47/3 I 172/11 187/22
complex [23] 12/23 131/5 131/6 134/15 Icontinues [2] 54/20 I 47/10 47/11 47/21 counted [1] 122/11
18/11 25/21 41/4 41/9 consider [10] 24/18 I 174/9 48/8 52/11 55/3 57/25I counter [2] 79/11
41/12 66/2 66/3 6/7 I 27/13 36/23 85/21 Icontinuing [1] 20/6 I 58/5 59/19 59/25 64/4) 160/20
66/8 66/9 66/10 66/12 86/9 103/13 103/15 Icontinuous [2] 112/2I 64/5 64/12 66/20 country [1] 63/9
66/12 66/14 68/23 117/8 143/17 165/18 I 148/3 67/13 70/6 70/8 70/9 Icouple [7] 2/9 2/14
74/10 74/13 89/25 considerable [4] continuously [3] 70/20 82/22 85/2 85/2I 19/4 96/1 144/7 174/9
90/1 127/9 152/24 25/2 63/11 78/16 58/15 75/19 127/19 I 87/19 87/20 88/18 183/13
158/17 102/23 contract [14] 24/23 I 89/20 95/24 95/24 coupled [1] 54/17
complexity [7] 12/6 considerably [1] 38/19 48/19 51/13 97/21 98/19 99/11 course [22] 23/6
42/11 12/20 41/2 99/3 51/17 51/24 52/3 106/2 106/2 107/22 I 24/11 43/19 53/5
consideration [13] 54/23 55/19 56/10 107/23 108/7 108/23 I 65/25 68/1 73/17
(69) communicated... - course
INQ00001200
INQ00001200
Cc 90/17 97/19 116/20 I 198/25 2/24 3/4 75/16 designing [1] 130/24
course... [15] 76/15 133/22 139/21 141/19IDBT [15] 2/19 3/4 definitely [1] 105/20 Idesired [1] 21/17
78/10 1400/6 100/11 145/16 146/13 148/4 I 25/1 27/3 32/9 137/11 I defi n[1] 149/9 Idespite [5] 20/6
100/13 137/18 148/1 153/14 172/25 188/10] 147/20 147/24 177/5 I definitive [1] 34/23 I 117/25 162/3 172/12
currently [16] 4/24 I 177/6 177/11 178/10 Idegree [2] 14/3 182/23
eo cee ee 20/5 46/1 57/16 60/18] 178/12 180/14 185/19] 111/19 detail [3] 90/25 121/1
199/6 201/11 71/3 85/9 102/18 de [1] 65/15 delay [25] 32/3 33/17I 176/24
court [9] 123/9 108/4 127/13 127/16 Ideadline [2] 68/5 I 33/21 34/1 34/2 89/14I details [2] 138/12
123/13 168/18 170/18I 134/21 147/24 167/15] 68/16 90/9 111/23 112/4 I 143/4
470/18 171/17 171/19] 168/5 189/5 deal [9] 98/9 101/7 I 112/5 115/6 121/10 I determination [1]
172/14 173/15 customer [3] 131/11 I 102/21 108/3 122/3 I 123/20 131/15 132/6 I 92/7
courtesy [1] 182/25 I 131/11 149/20 126/15 132/24 134/17I 138/4 138/5 141/20 _I determinations [1]
courts [3] 5/16 9/17 ICut{4] 29/1 67/25 I 160/17 142/5 143/14 191/20 I 31/25
74/4 88/18 160/16 dealing [1] 44/15 191/21 196/12 196/14I determine [1] 41/6
cover [2] 36/6 140/20ISut-off [1] 67/25 deals [2] 132/23 196/16 determined [8] 46/24
covered [3] 2716 Ip. ~~—~~«(: 204/24 delayed [1] 22/23 I 47/2 47/23 106/8
70/7 131/9 ——____________dealt [2] 10/2 123/21 Idelays [11] 33/19 106/12 108/9 135/7
overs [1] 174/10 damage [1] 65/9 debate [10] 30/3 75/6 75/11 76/9 76/10) 167/5
crafted a] 17a/2 [damages [1] 95/13 II 30/11 30/14 30/18 I 76/11 114/16 120/25 Idetermining [1] 55/8
create [5] 7/4 80/4 damaging [1] 182/12 I 30/19 31/1 31/6 31/19] 121/4 141/16 141/17 Idetriment [11] 6/21
danger [2] 13/21 135/1 194/17 delegated [1] 126/21 I 6/23 7/1 7/1 7/4 7/8
created 131, eos 29/22 December [11] 20/2 {delete [1] 179/5 26/23 26/24 52/9
vei dare [1] 31/3 39/10 67/16 123/3 I deliberately [3] 4/15 I 55/13 173/18
creates [2] 11/17 data [15] 40/2 74/24 I 125/3 135/23 161/11 I 22/8 112/6 developed [4] 64/9
89/14 79/23 79/24 79/24 _ I 168/17 170/3 173/4_ Ideliver [1] 14/25 64/14 139/13 188/21
ting [3] 78/14 I 80/1 80/2 80/6 80/17 I 194/2 delivered [5] 25/25 I development [1]
ben ting [3] 80/17 99/23 128/13 IDecember 2021 [1] I 44/21 58/6 58/8 24/4
tion [1) 7a/12_ I 128/17 129/24 140/22] 161/11 179/13 dial [1] 190/2
creation 1 195/17 {date [25] 67/1 76/20 I December 2023 [1] I delivering [3] 28/15 ies [1] 114/10
i] 79/14 79/16 80/13 I 494/2 17416 174/13, diary [3] 114/7 195/9
ylprofessionI 449/45 113/13 124/12I deci i
alism [4] 185/17 decide [3] 134/23 delivers [1] 186/18 195/13
dible [1] 31/18 I 139/22 138/11 141/12) 138/13 151/7 dementia [1] 61/17 I did [28] 6/21 14/7
credit (2182/4 187/14 166/17 166/18Idecided [2] 179/9 Iden [1] 22/21 18/24 19/14 21/22
credit ] 166/19 166/20 166/22I 182/6 department [50] 2/20I 34/3 41/24 48/19
creditors [1] 121/21 I 16/22 166/25 167/1 Idecides [1] 189/7 I 3/5 5/3 7/19 7/24 8/3 I 48/25 67/24 68/12
Cc t ] 4146/3. I 167/4 167/6 185/1 I deciding [1] 29/3 8/14 8/23 10/11 15/10] 68/12 68/15 76/12
Creewell tH Lye I 189/4 18916 ecision [12] 10/23 I 16/25 23/25 24/25 I 76/15 78/9 83/25
178/13 188/4 dated [6] 1/21 1/22 I 45/1 47/10 47/20 26/4 27/2 32/3 32/9 I 126/4 163/25 164/1
criminal [3] 9/11 1¢/7I 1/23. 1/24 1/25 24/6 I 56/21 65/19 74/6 51/4 53/3 53/8 63/13 I 166/22 180/14 183/6
39/7 170/17 173/11 {Sates [5] 21/5 67/25 I 102/8 143/10 143/24 I 76/11 96/20 117/12 I 184/9 185/10 186/16
isis [1] 4/4 81/6 114/7 114/10 182/3 194/11 118/22 121/7 126/20 I 197/20 198/7
crisis I te aig {dating [1] 15/5 decisions [4] 11/19 I 126/23 127/4 127/18 Ididn't [16] 6/12 12/15
omer L AW 38/18I David [2] 25/16 26/12) 41/5 42/13 119/22 130/23 133/18 133/22I 20/23 23/18 43/19
40/6 53/25 54/2 54/22I44Y [11] 29/2 76/4 decline [1] 54/20 135/9 135/17 135/24 I 43/20 48/18 56/9
55/2 55/6 55/9 56/11 I (8/20 80/12 140/17 declined [2] 17/11 I 137/11 148/9 148/24 I 57/21 61/18 131/4
56/20 62/9 63/25 176/21 180/13 200/22] 180/16 170/10 170/14 173/5 I 164/6 185/6 191/20
84/25 84/25 135/12 I 200/25 202/15 203/10Idecrease [1] 70/4 I 174/4 177/2 177/13 I 192/12 202/8
4169/2 1714/2 171/11 I4ays [56] 41/1 41/6 I I decreased [2] 74/24 I 178/3 182/16 191/5_ Idie [1] 14/14
i730 43/15 44/3 44/25 45/1I 75/3 4191/8 191/14 difference [11] 66/3
sn 45/7 45/11 74/12 Idecreasing [1] dependent [1] 73/4 73/5 73/10 84/13
criticised [1] 25/17 I 7aryq 7ai15 74/17 I 124/25 121/25 128/14 148/11 157/15
criticism i oan 74/19 74/19 74/20 Ideduct [1] 194/8 Idepends [2] 140/22 I 160/11 175/20 175/21
cropped (it) eyo, I 7412074121 74/22 Ideducted [1] 194/6 I 151/17 differences [5] 42/17
cropper I 1 3 74/24 75/1 75/2 75/9 I deducting [2] 194/12Ideputies [1] 11/22 I 72/17 137/16 137/25
Fe vie ‘s74)17I 75/20 75/24 76/3 76/4) 194/13 deputy [1] 39/1 161/7
tal [1] 1928 I 76/6 82/19 82/21 I deemed [2] 39/16 describe [4] 25/6 I different [17] 5/24
crystal [1] 83/16 87/2 87/4 88/13) 59/4 68/15 87/21 193/18 I 6/8 6/24 20/22 29/24
culture [1] 20/15 ,
curiosity [1] 46/20 I 89/17 90/5 90/7 90/18] default [3] 79/21 I described [1] 87/10 I 42/9 71/10 74/19
eeety] aging I 97/3.97/6 97/16 81/25 171/23 design [7] 22/8 22/8 I 79/22 137/19 147/14
curious oy 34/25 I 102/24 103/7 110/19 I defend [1] 29/13 23/3 23/4 23/16 45/3 I 148/10 149/10 156/23
curren 3 os 2 110/19 110/21 110/22I defensive [6] 75/12 I 122/16 179/18 181/9 197/21
54/18 60/13 61/23 I 110/22 140/9 143/21 I 7e/6 88/23 BB/24 designed [6] 30/25 I difficult [9] 12/6
62/1 62/5 66/16 66/18) 129/5 175/10 176/5 I 102/2 130/6 56/11 87/22 87/23 I 12/12 23/3 32/19
196/3 197/7 197/8 I defined [5] 2/19 2/21 I 87/24 149/15 113/22 114/3 169/22
(60) course... - difficult
INQ00001200
INQ00001200
D 111/8 111/14 111/20 I 146/13 148/20 149/1 I 52/13 58/18 59/3 176/16
difficult... [2] 170/4 112/9 112/12 112/14 I 149/3 149/4 149/4 59/14 60/1 63/15 68/8I drama [11] 40/11
181/22 116/4 119/8 131/16 I 150/17 151/12 152/6 I 69/2 71/12 75/12 40/15 40/20 67/11
difficulties [1] 186/15 153/9 153/15 154/23 I 155/1 155/2 155/3 76/10 77/18 77/22 83/3 98/5 98/7 124/4
191/4 157/6 157/25 158/14 I 88/24 89/25 96/8 96/9I 126/2 172/2 188/7
dilemma [4] 151/23 I I 7
re ety Idisputed [4] 91/11 I 159/8 159/15 160/11 I 97/12 102/15 103/6 I dramatic [2] 162/2
dime' [2] 25/19 31/12 111/14 113/13 113/15 I 160/18 161/22 162/7 I 104/15 104/16 105/12) 162/16
dipped [1] 48/24 disputes [6] 70/21 164/19 165/22 166/17) 105/20 109/12 112/24I draw [2] 84/18 102/5
direct [12] 48/18 70/25 71/3 71/11 167/15 167/19 168/4 I 113/23 114/6 114/8 I drawing [2] 122/6
48/19 51/13 51/24 108/3 111/13 169/5 171/8 172/13 I 120/7 126/12 129/3 I 122/9
52/3 54/23 55/19 dissatisfaction [2] 172/20 176/18 176/21) 129/4 129/17 133/8 Idreadful [2] 14/4
59/13 61/12 131/10 I 92/13 103/14 177IT 177/14 177/20 I 136/10 136/15 141/17I 14/5
182/24 184/6 dissatisfied [14] 180/2 181/3 181/7 143/13 143/13 143/17Idrive [1] 159/4
direction [3] 14/2 92/14 103/17 106/9 I 181/11 181/16 181/25) 145/15 148/11 148/14) driving [1] 128/18
36/22 131/13 106/10 106/12 116/4 I 183/2 184/13 185/13 I 149/24 150/22 152/10IDRP [2] 2/21 10/23
directly [8] 5/2 13/25 119/19 119/21 119/23] 186/5 186/24 189/2 I 158/1 165/6 166/20 IDRT [1] 2/23
38/20 50/1 58/1 119/24 120/1 120/2 I 190/10 191/15 191/20) 169/6 170/5 175/1 due [10] 24/25 27/5
115/13 123/12 180/23I 120/17 159/13 192/25 194/10 194/15) 175/24 178/17 180/22I 27/7 53/18 65/25
. dissolved [1] 61/6 194/16 194/17 195/11) 181/25 183/21 189/4 I 100/6 100/11 100/13
diecgree ty ae distinguish [1] 28/18I 196/20 202/12 203/2 I 190/2 191/14 192/2 I 170/18 172/21
disappoint [1] 120/7 distressed [1] 184/6 Idocument [6] 18/19 I 193/2 193/10 202/1 I during [10] 6/18 33/7
disappointed [5] distressing [1] 22/20 23/11 23/23 done [13] 8/19 14/5 I 46/13 53/10 67/18
106/19 114/18 116/8 I 184/11 144/8 176/13 32/20 44/20 67/22 87/16 153/15 163/24
120/21 155/21 do [189] 2/1 2/3 2/11 Idocumentation [4] I 75/22 98/13 107/6 164/5 193/7
disastrously [1] 6/1 6/2 6/7 7/47/12 I 15/14 21/19 25/10 111/25 131/6 134/7 Idynamic [1] 90/14
120/13 11/10 11/15 11/17 147/18 199/10 199/14 Dyson [6] 174/22
disclosure [21] 7/25 11/21 11/24 15/17 documented [1] 17/6Idoor [2] 149/17 193/19 194/2 194/22
8/2 8/2 8/6 8/16 8/17 I 19/5 16/10 17/18 documents [4] 20/22I 184/10 195/6 195/11
8/25 9/8 9/9 9/17 17/23 19/6 20/13 22/1I 48/15 50/24 54/24 double [2] 158/18 Dyson's [1] 193/21
22/11 22/13 22/18 does [32] 25/6 40/2 I 159/5
are thoes Mae 22/23 23/14 23/20 41/13 45/11 53/3 doubt [4] 79/21 81/17I E
145/15 147/1 147/4_ I 23/20 26/21 28/25 65/22 73/11 75/14 93/15 109/9 each [7] 75/24 86/4
1447/8 147/17 30/19 32/10 33/10 83/5 88/7 89/13 92/15Idoubting [1] 202/10 I 86/7 86/8 170/16
disclosures [1] 8/20 34/13 34/14 34/23 96/8 105/4 107/10 down [62] 7/2 10/21 I 170/23 192/23
discounted [1] 35/1 35/5 36/6 36/9 I 109/22 114/23 114/25] 14/1 18/4 21/3 21/9 earlier [22] 8/7 43/14
194/19 37/21 37/21 37/22 115/9 129/1 134/22 I 23/23 24/13 25/1 27/1) 45/15 67/5 83/2 83/4
discrepancies [1] 39/24 39/25 42/21 135/11 150/10 151/3 I 29/16 29/19 32/4 37/9] 86/21 105/23 110/18
61/25 43/1 45/11 45/13 158/23 178/10 183/1 I 39/18 40/23 44/16 125/8 130/3 132/3
discretion [1] 93/15 45/23 49/2 49/10 188/9 189/23 190/23 I 46/3 51/3 52/12 64/13) 132/4 133/5 138/2
discuss [1] 10/13 50/19 55/19 56/6 192/24 202/10 64/16 64/17 64/25 146/17 155/10 160/1
1 56/14 56/18 57/19 Idoesn't [17] 29/14 I 65/2 65/5 65/8 65/10 I 165/19 172/9 191/12
discussed [6] 2122 I ole 63/10 66/12 I 29/24 42124 61/7 71/1] 66/24 73/1 73/3 76/12] 199/9
Tov? soetg sera I 67/16 69/4 69/16 I 95/20 95/23 106/23 I 88/18 89/9 89/23 _ earliest [2] 27/6 27/7
4167/2 73/25 7516 75/18 132/2 147/5 147/7 I 90/20 93/4 93/8 94/13I early [16] 18/9 40/12
discussing [5] 24/4 I 75/19 78/5 80/6 80/7 I 169/2 171/5 175/17 I 97/5 98/3 103/10 40/13 44/12 67/23
33/16 51/1 62/21 80/22 81/13 81/14 I 180/21 189/22 190/15] 104/5 106/8 107/17 I 76/9 76/14 83/10 85/5}
146/7 82/24 84/4 84/7 85/11Idoing [27] 3/19 3/23 I 113/5 119/15 120/24 I 100/16 126/14 130/25
discussion [6] 20/3 I 85/24 86/18 86/23 I 14/12 31/3 68/3 81/23) 123/18 124/20 131/17] 148/8 160/2 174/22
104/13 116/18 144/10] 89/9 90/11 92/17 84/8 84/20 84/21 149/22 154/9 155/15 I 193/18
465/10 194/14 95/16 96/12 96/21 I 91/24 93/13 93/15 _I 155/23 158/3 161/8_ Iearnings [1] 65/5
discussions [4] 99/12 101/4 101/24 I 98/4 99/1 104/3 117/7I 165/9 170/12 179/1 easier [2] 45/3 89/24
63/12 63/21 127/17 I 102/1 102/3 102/12 I 124/24 125/20 136/10] 193/8 201/18 easy [2] 89/24
166/24 103/18 103/22 105/14] 140/22 147/12 159/15Idownsize [1] 98/6 I 119/20
disingenuous [3] 105/14 105/15 111/23] 162/6 162/13 162/14 Idownsized [2] educated [1] 69/3
178/18 17917 114 I 112/21 113/9 114/3 I 162/14 181/10 124/23 126/13 education [1] 121/24
disposal [1] 29/7 115/20 116/7 119/2 IDOMINIC [3] 1/9 1/13/ downsizing [1] 98/6 I effect [3] 98/12
dispute [33] 2/22 120/4 122/14 123/10 I 204/3 Dr [8] 109/10 113/20 I 131/11 188/13
2/24 10/95 71/7 90/10] 126/9 127/13 127/22 Idon't [88] 5/11 7/13 I 115/24 161/1 161/9 effective [1] 26/7
90/12 90/24 91/2 128/20 129/24 130/2 I 16/9 22/10 22/10 163/12 164/16 172/12I effectively [28] 4/17
91/14 91/21 91/25 I 132/13 132/17 134/3 I 22/16 22/25 23/9 29/8 Dr Hudgell [8] 44/19 46/6 46/11 49/4
107/18 107/20 108/8 I 134/5 136/4 136/10 I 29/25 30/3 30/10 109/10 113/20 115/24] 49/14 65/15 67/3 68/5
408/11 108/14 110/11] 136/11 138/8 138/17 I 30/18 32/6 33/9 34/2 I 161/1 161/9 163/12 I 68/9 76/20 84/8 98/3
410/14 110/24 111/4 I 140/5 141/22 142/5 I 37/22 41/18 42/15 I 164/16 172/12 98/8 116/12 121/16
143/8 145/13 146/5 I 44/13 45/8 48/3 48/3 Idrafted [2] 176/15 I 124/2 124/10 124/21
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1437/9 447/16 454/17 [emails [3] 32/23 entitled [8] 6/4 69/7 Iever [8] 11/16 32/19 I 21/7
168/11 184/2 184/18 50/15 50/16 151/23 153/17 156/22I 32/21 33/2 34/9 34/23I exercise [6] 8/3
186/21 187/22 192/23) embarrassed [1] 172/16 187/10 187/15) 105/5 137/16 26/14 141/24 141/25
efficiencies [3] 74/2 112/24 entity [1] 27/25 every [8] 78/21 199/7 199/13
83/23 155/14 embarrassing [1] entries [4] 80/8 80/8 I 109/24 115/18 119/19I exercises [1] 42/7
efficiency [1] 84/14 183/23 80/12 80/16 153/16 154/22 200/13I exhaustive [1] 65/4
efficient [12] 26/7 embedded [1] 15/14 Ientry [1] 146/12 200/14 exist [3] 61/7 65/22
31/2 42/2 55/8 55/9 embrace [1] 199/8 Iequating [1] 152/22 Ieverybody [9] 76/17 I 183/1
75/18 91/12 91/23 [emerge [1] 27/6 eroded [2] 26/1 131/10 134/24 135/4 Iexisted [1] 94/17
99/21 102/25 103/2 IEmily [1] 177/41 193/4 139/8 165/4 184/5 existence [1] 57/22
179/19 empathetic [2] 82/1 Iescalation [7] 108/7 I 198/17 198/20 existing [3] 87/11
efforts [1] 50/10 88/1 108/14 108/21 111/17Ieveryone [2] 25/18 I 140/5 141/20
eggs [1] 99/13 empathy [3] 50/7 112/20 113/22 113/24I 29/6 exoneration [3] 18/8
eight [5] 77/21 77/23 56/16 56/17 essentially [2] 51/7 Ieverything [3] 78/17 I 172/22 200/9
163/23 192/21 192/22IEmperor's [1] 186/14) 151/1 148/1 148/3 exoneration’ [1]
employ [1] 63/8 __ essentials [1] 179/6 Ieverywhere [1] 36/24) 189/13
employed [1] 51/10 Iestablish [1] 198/1 evidence [40] 12/4 expand [1] 142/21
eighth [7] 1/20 1/25 employees [7] 51/17 established [9] 19/12] 13/9 15/20 17/7 18/3 /expect [6] 17/23 40/9
48/21 46/21 122/18 I 52/3 54/19 54/21 57/3] 31/8 50/9 55/7 58/21 I 18/3 38/11 81/10 73/22 73/23 102/19
eight-month [1]
77/23
139/15 1441/8 57/20 59/7 65/1 108/10 108/12 I 81/13 81/14 81/18 I 166/18
either [7] 59/6 61/9 /emPloyer [1] 52/6 I 197/3 94/16 94/18 95/4 95/5I expectation [2] 42/4
95/8 140/14 155/12 [enable [1] 162/8 establishing [1] 95/9 110/18 121/16 I 166/20
1471/20 202/9 encourage [4] 196/25 125/16 135/9 147/21 Iexpected [4] 8/7 27/5
elaborate [2] 124/9 I 149/15 189/22 189/25Iestablishment [1] I 148/6 148/22 162/10 I 180/18 195/20
148/11 195/7 12215 162/20 163/8 164/18 Iexpensive [1] 144/23
election [5] 34/7 34/8Iencouraging [1] estate [2] 61/14 165/3 165/19 165/19 Iexperience [10] 6/12
118/9 138/17 166/21 I 140/4 61/15 170/19 171/25 179/10) 12/19 12/19 18/6
elements [2] 181/19 [nd [18] 4/1 13/11 esteemed [1] 23/19 I 182/7 185/2 185/5 I 34/11 61/25 119/5
181/20 44/19 44/23 67/3 —_Iet [32] 13/2431/4 I 197/21 202/14 202/23] 120/8 120/22 197/9
68/10 73/2 73/9 73/13I 36/2 58/16 59/23 203/2 experienced [4] 6/6
eligibility [48] 21/18 )
DOD 228 38/18 38/16I 75/25 75/25 78/20 I 61/21 68/13 84/11 evidenced [1] 18/18 I 58/11 79/9 116/11
38/18 40/6 41/1 41/5 I 88/15 119/25 166/17 I 84/18 84/18 107/9 evidential [2] 80/21 Iexperiencing [1]
41/12 42/10 42/12 184/22 198/9 200/19 I 118/1 118/1 123/13 I 81/1 76/2
42/24 42/25 43/4 43/8/e"9s [1] 34/24 124/22 124/22 129/22Ievolved [1] 196/15 Iexpert [4] 95/5 103/9
43/13 43/17 44/3 44/6I Energy [1] 170/11 129/23 143/3 143/22 Iexact [1] 71/2 106/3 155/16
45/1 45/7 45/18 48/6 Iengage [3] 58/14 143/22 151/9 151/10 Iexactly [6] 57/16 EXPG0000007 [6]
53/25 54/2 54/22 55/1 121/24 196/15 154/22 154/22 162/12I 77/3 152/3 154/7 37/8 92/10 103/9
55/6 55/8 55/9 56/11 engaged [1] 122/15 I 162/12 167/1 180/25 I 162/13 186/4 106/4 119/13 163/14
56/20 62/2 63/24 engagement [7] 180/25 199/13 199/13Iexample [31] 7/5 expiry [2] 189/4
63/25 70/1 70/4 74/6 17/17 90/22 96/16 et cetera [32] 13/24 I 9/17 18/14 23/16 189/6
74/11 76/13 83/8 112/2 135/16 135/25 I 31/4 36/2 58/16 59/23) 33/15 40/11 41/3 explain [6] 12/6
83/21 84/24 84/25 177/18 61/21 68/13 84/11 44/13 60/6 61/4 61/6 I 12/12 33/11 92/23
126/18 128/14 169/1 Iengaging [1] 60/19 I 84/18 84/18 107/9 61/14 61/16 65/4 137/7 171/14
eligible [24] 40/8 engine [5] 77/7 77/10I 118/1 118/1 123/13 I 67/15 79/24 86/24 _I explained [7] 12/15
rae 43/9 43/16 44/5I 78/6 78/14 186/18 124/22 124/22 129/22) 103/2 105/8 113/18 I 53/18 96/7 144/16
44/25 45/3 45/5 45/6 Ienioy [1] 184/24 129/23 143/3 143/22 I 121/6 12/1 131/25 I 156/8 191/12 196/25
45/9 46/25 47/23 49/3\ enormously [2] 143/22 151/9 151/10 I 142/14 143/9 153/15. Iexplains [1] 67/11
49/7 51/18 52/1 54/2 I 91/22 98/11 154/22 154/22 162/12I 158/17 161/10 185/24I explanation [4] 40/3
55/16 55/17 61/12 enough [11] 12/16 162/12 167/1 180/25 I 191/25 192/19 40/18 67/18 76/8
70/10 93/1 135/2 92/18 102/7 103/20 I 180/25 199/13 199/13/examples [4] 7/14 I explicitly [1] 50/16
1470/25 109/7 119/22 138/18 Iete [3] 27/7 28/17 18/19 59/23 161/6 exposed [1] 182/18
elongates [2] 132/8 145/7 147/4 182/12 I 185/3 exceed [2] 36/2 extend [3] 62/12
196/16 186/24 evaluate [1] 195/6 157/4 134/22 192/24
elongating [1] 23/2 enquiries [1] 54/18 Ievaluated [1] 193/20 Iexcellent [3] 21/2 extended [1] 182/24
else [5] 47/14 48/7 ensure [7] 12/21 23/4Ievaluation [4] 174/23) 162/7 182/21 extending [1] 62/21
78/3 97/22 130/23 I 25/24 45/9 88/9 189/8 193/18 193/21 Iexcept [1] 199/18 extends [1] 169/17
elsewhere [1] 18/19 I 190/21 198/17 Evaluator [1] 193/20 excess [1] 179/22 _ extent [6] 17/15
email [16] 21/3 21/6 ensuring [2] 42/22 Ieven [18] 24/19 exchange [4] 7/16 I 23/14 29/18 32/2
24id 25/13 25/15 190/18 27/21 43/25 75/10 I 33/1551/3 178/12 I 33/19 76/12
26/16 26/19 31/10 enter [1] 112/12 80/3 105/5 117/23 excluded [1] 40/5 external [1] 19/21
52/16 176/10 176/21 \entire [5] 27/23 71/20] 145/3 147/1 153/6 excludes [1] 48/20 extra [6] 66/10
142/22 156/18 167/7 I 155/7 158/5 164/8 Excuse [1] 63/2 179/16 179/17 181/3
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45/1 21/43 53/5 160/15 179/4 184/11 I 197/4 64/10 115/17 170/6 I 158/13
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fact [18] 20/14 22/14 I 156/8 186/23 156/23 Ifinancing [1] 65/7 forced [2] 49/12 Fujitsu [2] 80/17
25/8 41/13 46/4 157/8 157/11 157/13 Ifind [10] 31/357/6 I 129/10 80/20
402/17 117/1 117/3 I 165/10 81/4 81/8 81/9 81/12 Iforegoing [3] 137/21 I fulfil [4] 174/5
417/25 130/16 139/13Ifeet [2] 14/6 14/23 I 81/25 82/3 84/19 137/23 139/12 fulfilling [1] 84/24
142/15 150/23 151/15] fell [2] 114/13 168/22) 181/21 foreign [1] 7/16 full [35] 1/11 23/4
460/14 162/3 165/16 Ifelt [5] 20/12 138/22 Ifinding [1] 194/7 _Iforensic [3] 93/6 75/13 88/22 99/16
179/20 139/9 164/1 164/13 Ifine [13] 33/11 46/19 I 160/4 162/11 101/11 103/23 106/15
factor [1] 90/20 fenced [1] 139/25 I 47/7 62/14 101/10 _Iforesee [1] 127/22 I 142/9 142/10 142/10
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41115 111/17 12/7 Ifigures [39] 37/19 I 197/20 66/18 27/16 27/20 28/15
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future [6] 29/14 84/9 76/18 76/20 108/9 184/5 184/9 184/18 I 178/15 178/21 178/23)
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143/9 188/13 increase [15] 39/16 I 109/8 119/22 131/22 Iinteraction [4] 96/21 I 107/19
imminently [1] 39/19 87/4 87/4 89/19) 131/25 132/4 132/11 I 96/23 177/12 178/11 Iintroduced [4] 105/8
114/21 99/20 105/5 114/1 162/8 163/19 184/21 Iinterest [9] 19/15 136/22 137/10 174/19)
impact [13] 30/1 124/8 125/19 136/25 Iinformed [6] 102/7 I 40/15 104/15 171/10 Iinverted [1] 133/22
1400/3 105/13 126/7 151/13 162/2 162/9 I 119/18 119/22 163/17I 171/13 171/14 171/16] investigate [1] 4/9
1460/9 164/17 164/21 I. 162/20 165/1 165/2 171/22 182/23 investigated [2] 6/24
181/1 181/72 193/15. IiN¢reased [10] 39/23 Iingredient [2] 26/8 interested [1] 123/10I 20/7
4199/6 199/10 199/11 I 69/7 85/3 96/1 98/25 I 26/14 interesting [2] 140/3 investigating [2] 4/6
impacted [6] 5/8 108/17 141/10 174/20I inherent [2] 117/14 I 188/5 4/18
29/19 32/5 56/8 92/6 175/1 175/4 117/15 Interestingly [1] investigations [1]
99/9 increases [2] 161/18 Iinitial [3] 77/4 176/11) 182/23 6/18
implemented [2] 161/20 193/3 interests [2] 13/22 Iinvolve [5] 39/7 53/3
118/4 186/6 increasing [7] 91/18 lly [2] 77/4 92/4 I 27/13 59/6 70/25 171/5
implication [1] 125/7 126/6 126/10 ated [1] 178/14 interim [51] 17/20 involved [19] 4/2 4/5
191/21 126/14 126/15 155/9 Iinitiative [2] 182/17 I 83/22 102/25 126/17 I 7/24 9/20 10/4 18/6
implications [2] 28/9 indeed [11] 24/9 189/2 128/18 128/22 149/23] 22/13 57/20 78/11
1417/6 87/12 89/1 92/8 98/6 Iinjury [4] 65/9 95/3 I 150/7 150/15 150/17 I 86/19 86/23 93/7
implied [4] 20/8 103/2 122/7 124/11 95/10 95/17 150/22 150/24 151/3 I 104/21 130/23 148/14
implies [1] 179/16 190/24 198/17 199/12) injury/harassment [1] 151/14 152/1 152/6 I 181/17 194/17 194/24,
important [5] 15/2 independence [2] 65/9 152/17 152/20 152/24I 196/22
53/5 112/1 115/3 78/13 115/5 injustice [1] 19/20 153/1 153/6 153/17 involvement [4] 9/14
151/6 independent [28] input [2] 198/6 153/20 153/25 154/12I 13/6 23/12 86/20
importantly [2] 13/19 15/23 15/24 198/12 154/13 154/20 154/24I involves [5] 5/19
159/21 198/14 30/12 30/13 31/23 inquiry [37] 1/15 2/14) 155/1 155/5 155/7 6/17 9/10 9/11 87/21
impose [1] 186/25 51/20 78/11 81/3 15/5 21/4 22/20 34/17I 155/18 169/24 170/15) involving [2] 48/1
imposed [2] 180/6 85/21 86/13 92/19 35/15 35/23 41/22 170/23 173/8 174/18 I 198/24
1485/7 92/22 96/14 96/16 58/18 67/15 71/6 174/18 175/4 175/9 _ Iironing [1] 177/8
imposition [1] 97/1 103/12 104/9 72/24 73/20 78/4 187/17 188/18 188/19] irrespective [1]
182/14 105/2 117/13 117/22 I 79/22 88/20 106/23 I 188/22 191/13 192/11) 150/11
impression [4] 19/18 118/1 118/2 118/17 I 116/23 116/23 116/25) 193/9 199/19 199/23 Iis [704]
21/23 58/19 181/5 133/11 151/9 159/12 I 117/8 117/20 120/6 I 199/24 199/24 is the [2] 33/1 147/2
improve [1] 165/22 163/3 129/6 129/7 147/18 I interim/hardship [1] Iis under [1] 50/21
improved [1] 84/3 independently [1] 148/22 151/7 165/3 I 188/22 isn't [10] 68/8 90/7
improvement [1] 101/7 165/15 178/22 182/19Iinterims [1] 187/22 111/21 139/4 143/23
76/7 indicated [1] 20/14 I 185/20 196/13 200/7 Iinterject [1] 143/6 147/9 153/23 154/16
improving [1] 74/14 indication [5] 47/12 I 200/19 internal [5] 19/21 159/1 162/15
in’ [2] 177/15 178/16 85/8 119/17 126/25 IInquiry's [3] 3/13 104/12 104/21 148/15] issuance [1] 87/3
inadvertently [4] 200/3 24/5 37/7 194/14 issue [26] 27/24
20/20 individual [8] 31/21 Iinsistence [1] 129/13]internally [3] 109/6 I 36/21 41/20 49/15
inappropriate [1] 49/3 60/2 77/20 79/7 Iinsolvency [3] 65/7 I 168/14 192/11 50/2 53/24 59/15
23/15 104/19 139/11 184/24] 122/1 126/18 interpretation [2] 59/15 59/20 60/23
inbound [1] 168/12 individuals [12] 9/23 Iinspired [1] 180/4 23/1 186/2 87/17 94/19 103/25
include [9] 52/2 75/9 28/10 48/1 70/25 instances [1] 158/4 [intervening [1] 121/4 122/17 122/20
75/20 75/25 76/5 81/21 85/10 86/23 instantaneous [1] 125/21 138/16 146/7 146/21
90/10 122/8 157/24 158/19 158/25 172/24I 89/7 intervention [2] 158/8 158/10 159/8
1469/2 187/10 187/15 instead [3] 18/10 177/5 182/20 162/22 165/14 192/10)
included [12] 48/11 industrial [2] 19/20 I 115/11 129/22 interview [2] 13/14 I 202/24
48/13 52/1 66/14 95/1I.170/11 instruct [1] 128/20 I 13/18 issued [11] 7/6 44/23
ineffective [1] 116/13Iinstructed [3] 23/7 interviewed [2] 13/10} 72/1 74/12 74/13
(G7) ie... - issued
INQ00001200
INQ00001200
1 167/22 168/8 168/14 I 66/5 68/17 69/18 73/9I 112/24 112/25 115/3 Ilayers [1] 108/8
issued... [6] 74/16 171/18 175/1 175/4 I 74/19 76/24 82/8 82/9I 120/16 123/15 133/8 Ilayman [2] 99/19
76/14 4147/2 124/16 177/24 178/6 178/6 I 84/24 88/24 92/22 136/10 136/11 137/11] 99/22
173/13 173/14 180/6 180/22 181/9 I 92/23 99/3 103/20 138/6 141/24 143/4 Ilead [2] 113/23 115/5
issues [26] 6/19 7/10 185/11 185/12 186/17I 107/3 107/6 107/7 145/13 145/15 149/1 Ileadership [1] 3/24
10/14 19/22 29/22 186/20 186/22 186/23) 110/18 112/9 120/10 I 149/16 154/22 157/8 Ileaps [1] 162/16
52/5 52/13 sa/16 I 187/4 187/25 191/7 I 120/16 121/3 123/22 I 158/1 159/20 160/16 Ilearn [1] 41/21
81/23 62/5 100/8 I 192/9 192/16 195/23 I 126/5 127/14 130/15 I 162/23 166/20 170/5 Ilearning [1] 148/19
100/13 100/18 117/9 I 196/22 202/16 132/14 132/25 133/3 I 179/17 181/15 181/25Ilearning from [1]
its [9] 33/13 33/14 140/14 143/16 143/23) 183/21 183/25 184/25) 148/19
foal touao are 93/10 118/5 131/7 145/19 146/7 147/13 I 186/21 188/5 193/2 Ilearnt [1] 130/2
159/1 174/13 176/22 I 152/7 152/16 157/11 I 194/10 least [6] 46/14
Taras tong trore I 180/17 157/17 160/16 160/19I knowing [1] 25/7 I 168/14 17/9 187/11
Issues" [2] 173/12 _ itself [6] 25/20 31/13 I 163/23 169/17 179/18] knowledge [5] 2/8 I 187/16 200/15
t73/2 31/16 38/13 40/2 I 179/24 181/9 181/12 I 3/8 79/12 108/1 led [3] 169/24 177/23
it [476] 95/14 185/4 194/18 196/15 I 139/12 193/21
itil [4] 66/6 6er7 —_‘I!TV{6] 40/11 40/20 I 20ar1 202/22 known [13] 3/15 _Ileft [3] 5/6 62/20
tsar 467/14 67/10 124/4 126/2 Ijustice [5] 11/16 _I 36/13 40/5 58/9 93/21] 132/14
ite [174] 213 512 I 17212 25/25 29/7 32/20 33/2I 93/24 94/1 95/21 I left-hand [1] 5/6
5/12 8/22 10/5 106 Ig [lustification [1] 108/7 129/3 154/21 legal [131] 8/20 9/7
51/11 168/14 170/12 9/19 23/7 25/19 27/25}
14/8 14/23 15/20
January [15] 3/18 justify [5] 32/14 31/12 42/21 47/25
a opn ais one I 88/22 83/13 1235 I 33/10 91/6 13272 — I __I 51/22 55/14 56/5 65/1
26/17 31/7 31/7 31/18) [24/5 124/8 125/4 I 151/3 lack [1] 178/19 65/8 71/20 71/22 76/3
32/17 32/18 33/5 125/5 125/19 135/23 I/ —_____~ lag [3] 82/25 83/9 I 81/16 81/18 85/16
34/17 36/21 37/8 40/8) 87/3 188/7 1936 I__I 89/8 85/24 87/2 87/8 87/14
44/25 47/13 50/22 197/4 199/22 Karen [1] 12/4 language [2] 80/23 I 88/13 89/1 90/13 91/4
52/7 53/7 53/8 54/12 IYanuary 2024 [2] keen [4] 145/24 177110 92/8 93/5 95/11
neyo caytt erie syle) 187/3 18/7 189/25 190/21 195/3 Ilapsed [1] 75/21 400/13 100/16 101/17
61/2 65/15 65/16 66/4 January/February [1]Ikeep [8] 33/1 40/24 Ilarge [4] 41/14 124/5 I 102/6 107/4 109/11
Oe Cee oe 125/19 46/19 64/25 65/1 154/1 181/18 409/15 111/16 112/2
SOE ee ea > jargon [1] 52/18 422/12 122/15 160/12Ilarger [3] 58/2 58/4 I 112/8 112/13 1156
ae ee et einqlleopardy [2] 151/6 Ikept [2] 48/25 180/25] 62/23 415/13 115/22 11713
oe vane Bulod wort] 15218 Kevin [1] 146/22 Itast [22] 1/154/4 I 127/25 128/1 128/11
Coe Bee pala Bevtoliob [9] 25/23 42/21 Ikicked [1] 25/1 26/20 35/18 35/24 I 128/17 129/3 12914
86/18 87/23 87/23 55/23 144/22 148/12 Ikind [15] 8/14 8/17 I 38/4 53/12 54/25 97/3) 129/10 129/17 129/18,
87/24 87/25 88/19 149/17 162/7 162/14 I 29/12 59/5 63/3 70/24I 97/6 97/7 115/25 429/20 129/25 130/3
gaia sorio 114 I 181/14 71/3 71/18 72/3 79/24I 122/11 124/16 134/4 I 130/8 131/12 131/15
91/15 92/18 95/22 JOined [1] 21/23 80/7 81/18 92/1 134/5 166/16 184/22 I 131/20 142/10 145/12
96/25 97/4 97/12 99/2 /ourney [5] 172/4 I 104/21 156/4 189/1 190/9 190/14 I 147/15 147/17 147/23
99/6 99/6 100/9 101/6I 1226 197/12 197/24 Ikindly [1] 179/5 190/14 148/8 148/17 148/18
103/20 103/25 104/11].198/15 kinds [2] 33/17 late [13] 46/6 54/17 I 149/13 149/15 149/18
404/25 106/20 106/20 Judge [1] 13/23 121/21 67/17 67/20 68/11 154/6 154/11 154/13
40718 107/8 107/12, [Judgment [3] 26/22 Iknew [6] 124/13 68/14 68/16 68/17 I 154/17 155/22 155/24
407/24 108/12 109/24I 168/19 173/14 180/13 184/7 184/8 I 87/6 87/7 124/14 156/3 156/5 156/8
410/20 110/21 1114/7 Judgments [1] 184/16 184/17 167/1 199/21 156/10 156/23 156/23
173/13 knock [1] 98/12 later [11] 23/14 41/19) 156/24 157/5 157/11
112/1 112/12 115/3
116/5 117/25 119/9
120/10 120/10 121/5
July [9] 15/6 27/6 knocking [1] 184/10 I 74/4 83/10 83/12 85/5I 157/13 157/17 157/20
80/11 150/7 161/14 I know [86] 14/8 16/10) 98/4 123/24 145/8 157/24 157/24 158/12)
469/21 170/10 174/19I 16/23 17/22 22/25 I 153/11 161/18 158/13 158/14 160/1
eae tors the 193/21 27/16 30/5 32/6 32/7 Ilatest [1] 192/15 160/18 162/6 162/11
Taio iseme rgee ump [1] 1423 32/22 35/8 35/9 35/9 Ilatter [1] 189/22 462/13 162/25 163/9
(eos Leet Lane. [lumping [1] 84/5 I 35/11 36/20 36/20 IIaunch [4] 34/4 163/15 163/18 163/20
Hae ceo tae dune [2] 8/8 121/6 I 39/25 42/15 48/3 I 102/13 139/9 180/18 I 163/23 163/24 164/5
ors abo teone [unior [2] 3/23 86/15 I 50/13 50/21 55/12 launched [7] 37/4 I 164/9 164/12 164/21
jury [1] 13/23 59/14.60/1467/9 I 60/14 66/1767/9 _I 4165/3 165/4 1658
150/20 151/6 151/20
151/21 151/21 152/8
152/15 152/18 153/25)
154/25 155/7 155/16
just [78] 1/18 5/12 67/14 68/8 69/2 74/4 I 117/2 180/13 183/18 I 165/10 165/11 165/16
7/15 8/2 19/6 22/10 I 77/18 77/19 77/22 lawyer [1] 131/23 182/22 182/25 183/12)
23/10 26/15 27/3 79/10 80/6 80/7 85/9 Ilawyers [10] 19/21 I 183/16 184/12 192/20
158/18 161/2 161/4 29/13 34/2 36/12 86/23 91/19 91/20 28/4 31/3 128/21 1495/2 195/3 195/9
161/14 161/24 162/19 36/23 37/25 43/4 44/3I 92/4 94/8 96/8 96/8 I 130/25 132/3 147/3 I 197/23 198/4 198/5
162/23 163/11 165/7 45/24 50/25 52/12 96/9 96/21 97/12 164/17 185/20 197/17I 198/14
165/13 165/18 167/14 52/23 54/12 54/25 102/6 102/6 105/20 Ilayer [1] 27/5 legalese [1] 160/16
55/6 56/14 58/19 64/2I 106/20 108/13 112/22Ilayered [1] 108/13 I legalistic [1] 107/9
(68) issued... - legalistic
INQ00001200
1NQ00001200
L like [47] 1/18 2/10 I 88/7 90/11 101/21 __I 199/5 199/9 55/12 56/22 78/16
jegally [24y 266 I 4/21 18/2 19/4 211 I 196/7 loss/impact [1] 93/21 100/3 115/22
3/28 41/2 48/1 49/3 I 23/24 26/15 28/25 longest [1] 112/22 I 193/15 119/22 129/16 133/3
74/1 74/4 71/8 71/13 I 29/14 35/21 36/10 longevity [1] 83/21 Ilosses [10] 18/14 I 143/5 149/16 160/17
7448 72/3 101/25 I 37/7 38/15 45/24 look [61] 4/21 11/1 I 20/4 64/1 64/3 66/4 I 160/23 162/25 170/15}
4111/4 111/8 1209/8 I 48/15 54/4 54/15 17/1 17/1 19/16 24/6 I 93/2 93/3 128/22 181/1 187/17 188/16
429/14 129/16 130/16] 08/13 59/18 66/15 I 24/12 27/12 33/12 I 193/14 193/14 192/19
430/21 1546 154/15 I 71/2172/20 73/19 I 35/11 35/21 37/7 43/6Ilost [5] 18/13 55/22 Imakes [4] 95/14
4158/4 158/19 160/13 I 77/9 78/1 81/1 81/24 I 44/20 44/24 58/13 I 55/23 177/16 178/16 I 99/17 128/13 158/21
legislation [2] 171/7 I 102/22 110/12 112/12I 60/9 60/25 63/6 63/6 Ilot [24] 11/15 11/15 Imaking [15] 7/25
4187/9 114/9 119/6 120/12 I 63/7 63/9 66/15 68/7 I 11/17 11/17 19/15 _I 31/9 38/24 39/2 68/6
length [3] 103/12 I 127/6 138/11 138/15 I 69/6 69/10 72/25 I 37/14 40/7 40/9 42/10) 83/19 93/11 95/6
1309/6 176/4 139/25 144/22 162/24] 72/25 74/5 79/13 99/10 103/13 126/12 I 145/9 165/23 184/8
lengthen [1] 190/24 I 1787 182/13 185/10 I 79/15 79/16 80/8 127/25 129/9 144/25 I 184/16 188/20 191/19
less [18] 9/1 9/1 187/25 190/18 191/25] 80/11 80/14 80/15 I 146/22 151/23 154/5 I 195/4
24/23 28/25 59/11 I 202/5 81/5 81/12 84/16 160/14 160/15 185/25I manage [2] 30/21
89/25 91/12 92/2 96/3IIikelihood [3] 40/16 I 84/16 84/17 86/2 90/4I ots [2] 33/9 155/17 I 180/19
99/10 140/11 140/25 I 63/17 90/3 94/3 96/6 99/7 99/19 Ilow [6] 80/21 127/14 Imanaged [2] 49/5
444/15 151/10 152/13) ikely [13] 9/3 27/6 I 99/22 105/1 110/24 I 127/16 157/21 187/25] 195/8
156/11 185/25 1809/8 I 34/11.34/15 40/18 I 119/6 135/11 142/22 I 163/22 management [4]
lesser [1] 151/11 43/13 63/18 87/7 145/24 146/18 146/20Ilower [2] 74/15 3/23 3/24 10/17 10/18
lesson [2] 41/22 1114/7 119/2 128/21 I 163/14 163/20 175/13I 100/10 manager [5] 52/8
7130/2 128/22 136/13 179/20 202/2 lunch [4] 107/19 55/11 55/25 107/24
lessons [2] 41/21 _Iimit [1] 51/11 looked [8] 21/5 21/10I 107/20 110/1 1140/2 I 107/25
148/19 limited [6] 8/24 9/8 I 81/6 81/7 99/23 107/1I 54 managers [8] 48/11
let [5] 69/18 133/3 I 135/16 135/25 150/1 I 139/23 155/10 Mo __) 50/3 52/23 57/3 57/20
135/24 143/4 145/23 I 150/19 looking [23] 14/25 Imade [48] 12/6 12/11] 59/2 59/7 62/21
let's [9] 62/11 74/5 Ilimiting [2] 26/6 19/20 36/5 36/7 46/1 I 13/14 14/21 15/21 I managing [7] 18/6
98/1 153/7 167/4 152/6 46/2 79/10 81/21 82/2I 16/13 16/16 16/18 I 26/5 26/13 29/18
174/18 175/13 182/18] limits [1] 150/4 82/3 82/4 83/22 84/14) 19/21 47/16 50/8 29/21 31/16 32/2
193/16 line [5] 39/23 51/23 I 91/17 97/1 123/22 I 57/13 65/19 73/22 I mandate [2] 127/10
letter [23] 7/7 74/11 I 1913/5 131/11 131/11 I 127/15 129/24 145/17] 93/1 94/3 95/19 95/25) 167/17
74/13 94/9 94/10 lines [1] 178/4 152/5 164/15 164/15 I 96/2 98/13 102/8 mandated [1] 16/25
98/24 113/20 113/21 Ilink [2] 45/8 188/10 I 164/16 103/1 105/4 106/1 manner [1] 170/16
143/22 149/11 161/1 {list [3] 65/4 122/4 looks [5] 46/14 4111/1 113/21 118/24 I manual [2] 7/6 7/7
4161/4 161/6 164/16 I 185/12 113/13 138/11 138/15I 122/24 123/2 123/4_ I many [32] 8/21 22/22
170/13 173/4 173/5 _Ilisted [2] 117/5 144/5I 144/22 129/19 131/24 132/5 I 27/3 43/45 47/9 47/12
4173/8 174/10 176/16 Ilisten [1] 117/7 Lord [9] 36/17 36/18 I 132/6 142/23 144/8_ I 47/16 58/23 58/23
176/16 176/23 178/2 Iliterally [2] 16/24 174/22 193/19 193/21I 153/2 156/1 156/19 I 70/24 76/23 90/11
letters [7] 28/4 28/17 I 180/11 194/2 194/22 195/6 I 171/18 174/5 174/21 I 90/15 93/24 96/5 96/9
139/16 139/16 140/10] tigation [9] 5/8 7/21I 195/11 176/19 190/23 192/7 I 99/43 102/18 105/18
140/24 168/7 23/14 37/4 39/10 Lord Arbuthnot [1] I 193/13 194/9 199/25 I 107/9 124/14 140/6
level [6] 43/1 63/23. I 49/17 86/20 173/13 I 36/17 mail [1] 38/5 150/22 160/18 162/8
108/6 116/9 127/13 I 194/3 Lord Beamish [1] __ I mailing [6] 38/8 40/4 I 163/1 163/4 191/1
4178/2 little [8] 10/10 14/15 I 36/18 40/7 42/6 83/12 168/5I 191/12 200/1 20/2
levels [5] 42/23 19/18 27/1 46/2 46/20ILord Dyson [6] mailout [3] 37/24 I 200/15
119/16 122/11 127/8 I 90/25 164/19 174/22 193/19 194/2 I 38/7 140/14 March [16] 17/9
155/18 live [2] 36/21 119/4 I 194/22 195/6 195/11 Imails [1] 188/9 34/20 34/21 35/25
Liabilities [4] 174/12 Ilives [2] 56/8 187/11 ILord Dyson's [1] Imain [1] 29/2 36/3 43/24 44/18 54/8
liability [5] 9/21 lobbied [1] 17/22 193/21 maintain [1] 21/15 I 73/24 118/7 121/8
27/15 28/7 51/19 52/4Iocked [1] 201/18 Lorna [1] 25/14 maintaining [2] 133/9 133/13 133/21
liable [3] 51/951/15 [locking [1] 197/17 Iloss [43] 52/2 64/7 174I7 174/15 134/14 167/2
51/25 logged [1] 69/22 65/3 65/4 65/5 65/5 IMajesty's [3] 27/4 IMarch/April [1] 17/9
liaise [1] 126/20 logic [2] 40/17 100/2 I 65/6 78/8 85/25 86/1 I 27/4 29/14 Mark [1] 21/6
liaises [1] 56/25 logical [1] 189/3 86/3 86/5 86/7 86/9 Imajor [2] 73/19 mass [7] 38/5 38/7
licence [2} 60/2 94/6 I!9gically [2] 63/6 93/17 93/22 94/1 159/11 42/6 140/14 168/5
licences [1] 59/18 99/23 94/24 95/1 105/9 majority [12] 45/16 I 172/22 200/8
life [1] 55/22 long [18] 11/24 41/7 I 105/10 117/1 123/11 I 45/17 84/12 87/13 I massively [2] 91/20
lifted [3] 150/4 43/17 44/5 44/6 75/13] 123/11 128/15 130/1 I 99/8 99/25 127/3 181/17
178/24 179/1 75/14 76/6 103/14 I 1341/5 131/7 131/22 I 130/8 158/12 164/6 I materialised [1]
light [8] 100/18 129/8I 193/22 104/2 107/8 I 132/1 132/4 134/15 II 184/15 200/10 58/20
9/14 129/16 130/21I 112/22 124/15 150/20] 192/19 192/20 192/22Imake [28] 4/17 11/19/ mathematics [1]
454/14 160/13 168/3 I 162/17 162/23 163/10] 192/23 193/15 197/18I 29/11 29/12 30/5 32/8) 100/1
longer [6] 42/13 43/3 I 197/18 198/24 199/2 I 33/5 42/10 49/13 maths [2] 63/10 99/1
(69) legally - maths
INQ00001200
INQ00001200
M 149/6 149/7 149/19 Imessage [4] 16/5 _Imissing [1] 26/8 128/21 128/22 129/25
matrix [a] 1271 I 149/21 168/2 178/14 I 144/16 184/16 177/17Imissold [1] 4/10 132/15 135/10 149/2
matter [3] 21/7 56/22I 180/23 181/14 183/23 met [2] 36/18 96/18 I mistrust [2] 117/14 I 151/5 153/1 153/17
12118 183/24 186/8 186/9 Imid [1] 166/7 117/15 153/19 155/2 155/3
matters [12] 3/15 5/9I 186/13 187/17 191/14] mid-afternoon [1] I modelling [4] 42/1 I 165/22 196/19 158/21
Told 1418 10/20 I 191/21 192/5 192/8 I 166/7 58/11 199/7 199/12 I 159/21 160/17 165/23
23/1 33/18 53/21 193/2 195/1 196/23 Imight [72] 5/25 7/4 Imodest [2] 71/23 I 166/3 175/1 179/19
53/22 93/18 126/23. I 202/5 202/11 76 7/16 8/17 11/2 I 77/6 182/12 186/5 191/13
194/2 mean [27] 31/10 40/1I 11/3 20/11 39/25 Imoment [12] 4/25 _ I 191/15 195/20 196/21
maximising [21 40/11 42/16 53/24 I 40/12. 41/19 42/12 __I 42/7 52/23 62/8 72/20I 198/13
190/16 190/17 56/15 69/4 75/7 80/22I 42/19 43/3 45/3 46/3 I 94/11 110/2 118/21 I morning [11] 1/3 1/4
maximum [1] 108/25 I 83/5 88/7 90/24 101/4) 48/5 49/16 56/4 57/10) 148/4 16/6 196/12 I 1/5 36/8 62/9 73/22
may [90] 1/21 a/24 I 104/18 111/20 13/4 I S9V6 60/25 62/8 67/4 I 196/22 120/25 121/16 122/6
9/1 19/8 26/20 27/21 I 123/7 130/10 131/9 I 67/16 69/3 69/4 69/6 Imomentum [1] 26/25] 200/23 202/21
29/23 37/4 43/8 43/19) 134/3 134/5 148/20 I 71/4 76/22 76/22 86/8IMonday [1] 1/1 most [8] 44/20 45/6
4eI3 43/21 49/12 150/10 180/21 183/2 I 86/9 87/17 87/18 88/3Imoney [35] 18/13 I 69/16 72/15 80/23
49112 50/28 52/17 I 184/13 186/16 92/3 95/16 100/11 I 23/24 23/25 26/5 115/19 127/1 178/23
56/7 56/8 67/11 87/12 Meaning [2] 25/2 I 100/19 102/14 103/19] 26/13 29/19 29/19 I most/some [1] 127/1
80/22 63/8 64/21 88/9 105/13 105/16 116/24] 29/20 29/21 30/2 30/3I mould [2] 26/4 32/25
66/25 68/25 69/2 Imeans [8] 13/15 116/24 116/25 117/17I 30/10 30/15 30/18 Imounting [4] 77/8
69/18 69/23 72/18 I 22/25 62/10 80/7 86/3] 120/17 129/2 132/5 I 30/19 30/21 31/1 31/6I move [6] 23/24
7312 76/18 76121 77/2I 94/1 97/9 11418 133/24 134/8 134/13 I 31/17 31/17 31/18 I 107/18 136/19 168/13
80/13 81/18 88/19 [Meant [5] 83/25 4135/2 137/23 141/15 I 32/2 55/24 78/21 174/18 182/4
90/20 93/10 95/6 I 98/11 131/21 17/7 I 141/19 142/15 143/10] 148/2 151/21 151/21 Imoved [2] 98/2
96/14 97/13 101/21. I 185/11 143/17 145/12 145/13] 151/22 184/14 185/2 I 190/11
101/24 105/7 105/8 IMeantime [2] 146/6 I 152/13 153/16 160/7 I 185/4 185/6 185/15 I movement [1]
4105/9 10978 110/15 I 13/9 160/10 16/6 166/22 I 189/20 194/3 189/23
113/1 11376 113/6 [Mechanism [6] 60/17] 166/25 167/3 185/22 Imonitoring [2] 10/11 Imoves [1] 190/2
1177 119/68 119/17. I 1009 116/17 116/18 I million [15] 35/19 I 53/1 moving [10] 63/24
12214 120104 123/16 I 116/22 118/25 36/2 36/2 36/4 73/6 Imonth [3] 73/14 78/22 87/15 92/19
1245 12916 130/24, IMedia [2] 21/16 73/7 73/10 73/12 I 77/23 98/13 98/15 132/12 149/23
4131/7 131105 132/04 I 189/15 73/14 73/15 73/23 IMonthly [2] 10/11 I 187/2 193/9 196/24
4135/9 135/21 139/11 IMediation [5] 11/4 I 73/24 141/7 17316 I 11/6 Mr [51] 1/6 1/10 1/14
139/18 139/21 142/8 I 108/14 109/19 109/20] 173/9 months [21] 27/3 I 13/9 14/17 14/21
taping 14713 147/15 I 172/20 mind [7] 52/12 72/17 I 33/7 35/24 73/6 73/15I 17/25 18/2 18/20
449/12 153/6 153/7_ IMedical [2] 95/5 106/24 126/6 159/9 I 73/1577/21 79/15 I 18/24 19/7 19/23,
453/11 187/11 159/23) 182/12 168/4 185/18 79/16 80/14 80/15 I 20/18 20/23 21/1
162/1 164/21 164/22 [Meet [1] 63/25 mindset [1] 81/21 I 81/7 81/7 84/17 84/17) 25/13 26/9 26/17
4176/2 190/24 192/20 \meeting [21] 16/23 Imine [1] 149/10 111/14 111/20 114/12] 26/20 28/12 33/15
al [1] 128/13 I 135/12 135/14 185/18) 33/22 34/6 45/23
mooted [1] 133/5 45/24 62/12 62/20
moral [2] 192/5 192/7I 67/11 110/11 124/4
192/20 192/21 200/19I 16/24 19/12 20/2 53/1
53/6 54/9 108/6 108/7
201/4 201/21 202/4 I 8/16 108/21 108/21
maybe [9] 29/23
47/17 48/24 80/23 111/15 112/7 112/16 Iminimum [12] morals [1] 182/14 132/13 132/18 132/19)
88/7 120/6 162/11 112/18 112/20 115/8 I 137/10 183/7 183/8 Imore [99] 9/4 9/25 132/21 133/6 135/8
165/17 192/6 144/4 145/20 180/12 I 184/5 184/19 187/4 I 15/23 15/23 15/24 135/21 136/8 136/17
McColl's [2] 59/19 meetings [13] 10/4 I 187/4 187/13 187/23 I 19/4 19/25 23/12 166/16 172/2 197/13
60/5 10/8 10/11 11/7 11/9 I 188/11 188/17 200/15) 24/19 27/6 30/22 197/20 200/23 201/2
McColls [1] 59/23 96/12 96/15 111/17 IMinister [13] 15/21 I 30/24 31/2 31/8 37/14) 202/7 202/16 202/18
McDaid [1] 177/25 113/22 113/24 113/25I 16/2 16/22 50/23 40/7 40/9 40/16 40/16] 202/22 203/1 204/5
MeEwan [1] 1244, I 114/3 142/14 57/16 118/6 118/12 I 40/22 41/9 41/9 41/11IMr Bates [3] 67/11
me [61] 12/2 16/17 meets [1] 171/1 133/14 144/4 144/24 I 41/12 42/2. 45/10 I 124/4 17212
Tene 18/16 20/14 IMelanie [1] 51/2 I 146/1 146/3 190/14 I 47/17 48/7 48/8 55/8 IMR BLAKE [8] 1/10
20/19 20/24 29/28 IMember [3] 10/8 —_I ministerial [1] 63/23 I 55/9 58/11 59/11 61/7I 45/23 62/12 132/13
30/20 30/24 seria I 108/1 17/1 ministers [5] 16/23 I 68/22 69/3 74/2 75/10I 136/17 202/7 202/16
37/22 45/24.46/2, IMembers [6] 61/9 I 118/9 118/10 189/24 I 75/17 7/11 88/2 I 204/5
50122 67/21 serie I 01/1061/13 61/20 I 190/20 89/11 90/1 90/3 90/3 IMr Cameron [5]
sangesizeona I 79/11 12116 minute [3] 144/9 I 90/23 90/25 91/2 91/5I 26/17 26/20 28/12
72/21 78/9 84/5: (Membership [2] 93/5) 149/19 191/23 91/12 91/23 99/3 99/3] 33/15 33/22
104/28 106/25 10712 I 129/9 minutes [1] 144/3 I 100/21 102/25 103/2 IMr Cameron's [2]
107/4 107/5 107/10. IMental [1] 193/15 Imiscarriage [3] 103/2 103/3 103/13 I 197/13 197/20
too 120/7 123/14. Imention [1] 202/2 I 11/16 32/20 33/1 —_I 103/24 105/21 106/25IMr Creswell [1]
126/11 133/3 133/86 [Mentioned [5] 34/9 missed [2] 68/5 107/2 107/11 111/7 I 138/8
195/24 1301 14414 I 103/24 1386/2 167/9 I 68/16 112/9 116/4 126/5_IMr Read [5] 13/9
17219 misselling [1] 4/7 I 126/7 127/5 128/15 I 14/17 14/21 19/23
(70) matrix - Mr Read
INQ00001200
INQ00001200
M 127/8 129/21 135/4 I 106/12 119/19 119/21I 162/19 164/11 166/20) 47/2 48/21 50/21 54/8I
Mr Read... [1] 25/13 136/1 138/21 145/6 I 119/22 119/23 119/25I 166/21 169/23 170/23) 54/20 60/17 61/6 62/3}
Mr Recaldin [16] 1/6 145/10 145/11 145/14] 120/2 164/13 171/25 174/1 180/20 I 65/23 68/13 68/17
4/14 45/24 62/20 146/17 147/3 148/12 INetwork [2] 174/8 185/14 186/2 187/13 I 68/17 69/10 69/24
410/11 132/18 132/21 149/17 149/20 149/20) 174/16 189/6 190/7 191/14 70/2 70/8 71/24 73/12,
133/6 135/21 136/8 I 1599/9 155/13 159/9 _ Ineutral [2] 174/22 192/8 201/12 201/12 I 73/23 74/25 75/2 83/2
166/16 200/23 201/2 I 162/6 165/19 165/19 I 193/18 201/13 202/2 85/14 96/25 97/15
202/18 202/22 203/1 I 165/24 165/24 166/16) never [13] 33/21 nobody [2] 32/19 98/10 98/14 99/7
Mr Recaldin's [1] 170/5 173/23 175/7 I 33/21 34/14 95/25 194/8 1400/1 102/16 105/16
132/19 175/12 178/24 180/5 I 96/2 96/4 116/11 nodded [1] 64/24 107/8 107/14 107/16
Mr Staunton [9] 180/10 180/20 181/14] 116/11 116/14 116/15Inon [20] 32/23 33/24 I 107/17 107/17 109/10)
17/08 18/20 19/4 I 181/16 183/14 191/19] 165/12 185/18 198/5 I 39/24 74/9 91/11 140/46 115/10 116/12
49/7 20/18 20/23 21/1I 191/25 197/10 200/18Inevertheless [2] 111/5 184/23 193/14 I 116/13 124/16 125/7
26/9 34/6 201/13 201/17 6/13 139/8 193/16 195/4 195/15 I 125/8 125/17 126/10
Mr Staunton's [1] I"YSelf [7] 16/24 new [35] 42/5 46/4 I 195/19 195/19 195/24] 120/19 129/21 132/12
18/2 77/19 79/6 103/20 I 47/5 57/17 57/21 94/1) 196/2 196/6 197/6 I 133/20 138/16 139/11
Ms [2] 200/24 202/19I 178/13 181/21 202/10] 105/8 105/10 107/13 I 200/16 201/7 201/28 I 140/18 143/10 150/16
SI 1116/1 118/9 118/10 Inon-BAT [1] 74/9 I 150/25 152/5 153/15
Peal {2} 200/24 No) 448/42 124/18 131/22Inon-convicted [2] 155/22 156/6 156/22
much [44] 1/11 1/14 Iname [2] 1/11 36/14 I 131/25 132/11 135/18] 201/7 201/25 159/13 162/2 168/13
namely [1] 134/9 135/22 137/10 137/19Inon-disputed [1] 171/11 172/22 172/23
1
2/11 3/7 3/11 4/1 4/21
7/18 25/17 26/11 names [2] 104/14 143/1 144/17 146/5 I 91/1 173/19 187/2 187/19
146/13 161/3 163/7_ Inon-Horizon [1] 192/12 192/18 198/5
260 een narrow [1] 22/3 186/14 187/21 199/1 I 33/24 198/24 199/4 199/8
62/23 63/20 65/10 (/Maturally [1] 90/11 I 199/1 199/2 199/4_Inon-pecuniaries [1] I 200/8 201/3 202/1
69/12 70/10 70/12 [ature [4] 12/16 40/4] 199/5 199/8 200/16 202/10
70/18 70/23 71/14 90/2 120/22 newspapers [1] non-pecuniary [11] Inowhere [1] 178/23
TANT 7218 72/10 NatWest [2] 3/21 66/20 184/23 193/14 193/16] nuance [2] 105/11
52101 78/25 88/14 I 3/22 next [18] 16/24 34/7 I 195/4 195/15 195/19 I 105/16
4147 19/8 136/16 Navigate [1] 119/21 I 40/24 43/10 75/22 __I 195/19 195/24 196/2 Inuances [1] 199/1
485/14 158/21 160/13] NBIT [2] 28/15 28/21 I 75/23 83/10 85/5 85/6) 196/6 197/6 nub [1] 133/20
460/17 162/4 165/15 IMearly [2] 90/7 155/8 I 85/15 85/16 104/4 _Inon-represented [2] [number [78] 3/23
4184/16 197/22 200/21I Necessarily [5] 34/2 I 108/6 111/17 115/8 I 39/24 111/5 6/18 6/20 6/22 12/5
202/14 75/11 129/17 130/10 I 136/6 140/19 180/13 Inonetheless [2] 12/10 20/22 22/12
multiple [2] 87/18 I 149/13 Nicely [1] 189/13 18/13 64/21 25/5 29/17 33/10
123/23 necessary [2] 158/25) Nick [1] 31/10 nonsense [1] 27/7 I 37/17 39/16 40/13
multiples [4] 51/14 159/4 nine [1] 39/20 nor [2] 32/10 178/21 I 41/14 46/24 47/4 47/6)
52/1 59/8 59/16 need [40] 24/18 no [108] 6/9 6/9 7/13 Inormal [1] 91/11 48/15 52/19 57/9
multitude [1] 122/10 I 26/21 29/13 29/15 I 8/2 11/13 13/8 18/6 not [254] 58/20 63/16 66/4
Munby [2] 200/24 I 30/21 32/13 32/14 I 18/23 19/3 19/9 19/15Inote [3] 74/15 180/6 I 66/15 67/4 68/22
202/19 32/15 32/15 32/16 —_I 20/19 20/23 21/25 I 180/20 70/18 71/2 71/8 73/9
must [10] 25/3 38/19 52/5 57/7 63/19 73/18] 22/19 23/21 24/10 —_Inoted [5] 141/14 77/5 77/17 80/2 82/19}
38/21 38/25 39/4 39/7I (3/18 89/4 91/23 94/6] 25/17 26/11 29/12 I 144/19 144/24 146/3 I 82/21 83/16 87/4
39/9 45/6 104/12 95/20 99/7 103/6 29/13 30/13 30/14 146/22 89/16 89/17 89/19
202/25 106/21 114/18 122/8 I 31/23 34/10 37/22 —_Inotes [4] 16/21 73/2 I 90/5 90/18 90/20
my [99] 2/25 4/4 16 I 122/12 123/8 123/9 I I 43/2 43/5 44/15 45/25) 73/3 145/5 91/20 92/5 97/2 99/9
1OB 111 14/19 123/12 127/7 127/15 I 46/11 46/12 47/17 _Inothing [6] 10/1 10/1I 100/8 100/15 101/15
42/18 12/19 14/21 I 129/17 144/20 148/15) 51/17 51/19 52/3 52/4] 30/15 36/8 166/23 I 102/23 108/25 111/24
16/12 19/18 20/2 149/13 149/25 166/2 I 55/2 59/9 60/1 60/25 I 166/24 113/24 117/5 123/16
21/11 23/17 25/03__I 177/21 190/7 190/21 I 62/25 63/2 65/3 70/14/noticed [2] 115/24 I 124/6 124/19 124/25
97/10 27/23 29/2 202/11 71/13 76/5 76/25 160/14 126/1 126/4 148/23
9/12 30/20 31/18 \needed [2] 41/22 76/25 77/1 77/18 notified [1] 20/10 153/5 153/20 154/1
3a/18 32/21 32/23—«I 124/15 77/25 77/25 81/1 81/2\noting [1] 40/3 154/1 154/4 155/9
33/23 35/9 36/9 40/1 [needing [1] 34/6 81/23 82/8 82/15 novel [1] 198/24 157/3 161/10 161/12
46/20 48/18 48/21 Reeds [3] 33/14 91/5 I 86/25 92/16 94/18 [November [6] 1/1 I 161/16 161/19 161/25
54/3 57/4 57/6 57/6 I 112/11 96/15 96/23 97/11 I 68/2 122/25 123/3 I 168/10 198/12 201/3
57/13.57/1457/15 _ Inegatively [2] 29/20 I 98/5 99/6 101/6 161/12 174/21 Number 11 [1]
37/25 60/5 60/15 3215 101/21 104/23 104/24INovember 2022 [1] I 161/19
63/22 77/18 79/2 79/5) negotiate [1] 162/17 I 109/2 109/9 109/17 I 161/12 number 111 [1]
79/6 82/15 85/12 92/3I Negotiation [2] 112/24 119/1 127/12 INovember 2024 [1] I 201/3
92/5 99/17 101/24. I 115/12 197/16 134/1 136/9 136/15 I 1/1 number 2 [1] 161/10
106/24 108/1 110/20 INeil [1] 177/25 142/8 144/1 145/3_—_Inow [89] 13/13 27/6 INumber 4 [1] 161/12
415/24 120/8 120/22 {Ret [13] 37/15 92/12 I 145/7 145/15 145/18 I 31/6 35/19 36/20 number 8 [1] 161/16
103/14 103/17 106/9 I 147/1 147/4 156/6 I 36/21 38/5 38/6 41/20INumber 9 [1] 161/25
(71) Mr Read... - Number 9
INQ00001200
INQ00001200
N 96/2 96/3 97/22 97/23] 28/10 30/9 32/11 Jone [61] 2/154/5 I 30/2 65/17 79/2 79/5
a ag) I 98/18 99/14 99/21 I 35/11 38/20 39/6 19/9 19/25 25/17 186/17
nao 4) 8 100/3 101/11 102/2 I 39/10 48/19 50/10 I 26/13 26/16 48/10 _I operationalisation [1
85/8 92/3 99/24 102/4 102/18 103/8 I 51/4 51/8 51/9 51/13 I 53/12 53/21 57/14 I 10/4
To1/12 106/21 106/22) 105/6 106/10 106/15 I 51/16 51/18 51/19 I 59/6 60/3 60/9 60/17 I operationalise [2]
407/1 107/1 11616. I 106/17 107/21 108/17I 51/24 52/4 52/5 53/4 I 67/2 67/2 72/20 84/15I 180/19 183/23
11973 125/19 128/20 I 111/5 112/10 113/13 I 53/7 53/10 53/15 I 97/25 98/12 98/25 _I operationally [1]
jo5/22 125/03 125)95I 116/13 123/1 128/6 I 54/20 54/23 55/20 I 99/13 100/8 105/20 _I 75/16
126/6 126/10 126/15 I 129/19 130/17 131/19] 56/10 56/13 58/2 I 105/22 105/22 105/23I Operations [1] 4/20
ieais 131/24 132/5 132/6 I 58/22 59/24 60/8 _I 113/20 114/11 119/6 I operator [1] 79/6
— + _I 132/12 136/22 137/1 I 60/19 60/23 61/5 63/6] 119/10 121/3 121/3 I opine [2] 104/16
° 137/3 137/4 137/15 I 63/8 63/12 64/15 I 121/9 122/4 123/22 I 115/8
object [4] 24/10 I 1392 140/2 140/7 I 66/18 77/11 78/10 I 127/24 1341/3 132/15 opined [1] 94/2
objective [3] 191/9 I 140/8 142/2 143/5 I 78/18 78/18 79/12 I 133/3 138/4 138/8 _I opportunities [1]
191/15 192/9 143/12 143/19 143/22] 79/23 80/19 84/21__I 14/5 159/10 160/1_ I 191/12
obliged [1] 27/12 145/14 146/11 147/17I 91/7 93/1 94/8 95/20 I 163/23 164/25 167/9 I opportunity [24] 17/1
observation [3] 148/7 148/17 148/18 I 103/21 104/1 104/4 I 170/24 173/1 180/24 I 17/11 38/9 64/1 65/6
25/16 26/13 154/20 I 148/20 149/6 149/8 I 104/6 104/7 105/5 186/13 191/7 195/2 I 65/24 69/6 73/20
observe [1] 96/13 150/8 150/15 150/17 I 108/2 109/13 114/5 I 196/21 197/20 199/23) 96/10 102/11 105/21
obtain [5] 163/18 150/17 150/22 150/23) 117/7 117/16 118/16 I 200/13 200/14 202/24I 112/19 115/11 138/10}
163/22 165/3 169/22 I 150/25 151/8 151/16 I 118/18 120/8 120/23 jones [6] 46/4 46/17 I 139/25 152/10 165/25
1470/4 151/17 151/18 151/20) 124/25 126/12 130/22I 69/18 123/12 124/1 I 179/11 180/3 181/23
obtained [1] 170/19 151/22 151/25 152/1 I 131/4 133/10 133/18 I 130/16 182/8 191/24 202/6
obtaining [3] 95/9 152/23 153/7 153/7 I 133/23 134/12 137/13] online [2] 24/12 202/11
149/13 197/15 153/10 153/14 153/16] 139/18 143/24 146/4 I 38/14 opposed [2] 171/9
obtains [1] 131/20 153/16 153/18 156/1 I 147/19 151/21 152/21I only [42] 18/11 26/13) 171/13
obvious [1] 18/7 156/1 156/9 156/11 I 158/13 159/1 159/11 I 35/7 48/21 49/20 opt [1] 193/10
obviously [6] 8/22 156/18 158/5 158/12 I 162/9 170/15 173/7 I 49/21 49/22 50/7 51/7I optic [2] 106/20
14/25 106/19 115/23 I 159/16 161/7 161/11 I 173/13 174/8 174/15 I 51/14 66/11 75/9 115/2
481/20 202/23 161/11 161/13 161/14] 177/2 177/9 177/12 78/17 84/14 95/22 Optically [1] 21/13
oc [7] 30/13 167/19 I 161/15 161/17 161/25) 17/16 177/23 178/65 I 96/18 101/25 105/22 Ioptics [6] 96/17
172/33 173/1 191/11 I 164/10 164/12 165/5 I 178/12 178/16 178/22I 106/15 109/6 109/6 I 129/21 139/4 139/5
201/15 201/23 165/8 165/13 165/21 I 179/4 179/13 179/20 I 111/5 121/6 125/24 I 139/7 147/22
0¢2 [1] 144/16 175/2 175/13 175/14 I 180/6 180/9 180/9 I 128/2 128/6 131/23 Ioptimistic [1] 107/11
occasion [1] 109/24 I 176/4 176/11 179/11 I 180/18 182/20 182/24] 144/1 144/1 144/2 option [4] 95/8
occasions [5] 81/6 I 182/9 187/14 188/16 I 183/4 185/19 185/25 I 156/9 156/16 163/16 I 109/16 143/16 159/24
88/6 96/5 99/18 157/3) 189/5 189/6 189/8 I 186/17 191/5 194/10 I 163/18 174/12 175/24I options [5] 11/1 86/6
occurred [5] 67/10 I 189/10 192/1 1921 I 194/21 197/14 198/16] 177/5 179/5 186/8 I 86/8 86/10 177/18
193/11 195/17 Office's [6] 19/19 I 186/13 187/25 192/3 Ior [178] 5/23 6/25 7/1
sane 8125 104/23 I ffered [6] 137/14 I 19124 80/18 148/7 onto [10] 4/22 17/24 I 7/4 7/24 9/18 9/18
October [12] 1/25 _ I 150/10 152/6 152/22 I 148/16 172/6 24/2 28/11 38/17 9/25 10/18 12/8 14/19
67/15 73/9 73/13 165/4 194/22 Office-led [1] 177/23 I 92/20 116/3 123/15 I 15/17 18/12 20/18
123/25 128/2 150/4 Offering [1] 115/11 I offices [1] 52/20 195/21 199/15 22/14 22/17 23/15
456/20 157/13 161/4 IOffers [27] 44/22 I Official [1] 121/20 Ionwards [3] 83/13 I 27/21 29/3 29/12
4197/3 198/8 44/23 70/12 71/15 I officials [3] 16/25 I 121/14 202/1 29/19 29/19 29/20
October 2023 [1] 72/1 72/1 74/15 82/5 I 30/20 50/22 oodles [1] 32/10 30/3 30/14 31/16 32/4
19713 1141/4 113/12 113/15 often [2] 109/5 Ooh [2] 50/21 201/5 I 32/4 34/12 34/15,
odd [3] 46/2 91/1 I 130/11 136/19 138/22) 131/20 op [1] 59/23 34/24 35/13 37/12
165/10 140/11 153/19 156/19IOh [4] 12/1.85/14 open [6] 51/12 57/8 I 38/19 39/1 39/7 39/25
off [10] 28/24 62/20 I 157/23 161/8 161/23 I 104/20 1839/8 127/20 134/23 135/4 I 41/19 44/5 44/11 45/3
67/25 75/17 86/12 I 161/23 162/9 162/21 IOHC [1] 174/11 145/23 45/4 45/5 45/17 47/8
94/9 104/5 1241/7 163/7 164/22 164/23 IOK [1] 189/1 opened [3] 43/19 I 47/13 48/7 48/25
122/10 198/12 195/4 okay [13] 2/10 52/22 I 57/25 167/11 49/11 50/5 50/15
offence [1] 27/21 [office [155] 6/16 9/24] 52/22 59/15 69/14 operate [5] 14/10 I 51/13 51/17 61/23
offences [2] 18/7 I 11/8 13/7 13/19 13/23) 81/12 85/11 110/23 I 15/25 35/18 43/20 I 52/8 54/4 55/11 66/12]
173/16 14/4 14/10 14/12 I 134/11 135/24 148/16I 138/7 55/15 55/25 56/19
offensive [1] 36/19 I 14/13 14/18 15/7 15/9I 18378 197/16 operated [4] 16/19 I 56/20 58/25 59/2 59/7
offer [136] 9/8 38/4 I 15/13 15/18 15/20 Jold [1] 62/3 60/21 137/11 170/20 I 59/18 59/19 60/12
7014 74/12 76/14 I 19/22 16/13 16/14 __Ion [254] operates [1] 108/2 I 61/1 61/6 61/10 61/16
78/2 82/4 82/14 87/3 I 16/19 17/2 17/5 18/25Ionce [14] 86/12 _ operating [2] 81/23 I 61/17 62/22 63/13
88/18 01/3 91/22 I 19/13 21/5 23/5 23/9 I 88/16 94/2 94/8 98/9 I 90/17 63/18 64/21 65/13
93/10 93/11 94/9 I 23/13 24/17 25/2 25/7I 98/14 103/24 105/4 operation [1] 183/9 I 67/17 67/22 67/24
94/10 94/12 95/6 95/9I 26/1 27/11 27/13 I 105/6 109/7 131/24 _ operational [9] 14/9 I 68/7 68/25 70/24
27/19 27/22 28/1 142/2 152/11 187/9 I 14/13 15/15 16/12 I 71/19 72/15 74/20
(72) numbers - or
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fe) others [8] 6/29/18 I 10/14 122/24 123/2 I 106/5 106/5 106/13 I 35/19 72/12 73/7 91/6)
or... [91] 75/22 78/24 30/24 60/21 62/22 123/4 200/2 106/13 107/2 110/13 I 94/17 136/21 139/19
79/19 79/20 80/18 74/19 163/12 173/14 Iover [29] 9/2 17/16 I 111/11 113/11 113/12) 141/7 152/20 172/11
82/13 82/14 83/10 Iothers' [1] 29/5 22/12 35/24 45/1 45/7I 119/13 119/15 122/20] 196/2
87/18 88/8 89/1 91/13/0Ur [25] 6/18 9/19 54/13 66/7 68/19 128/8 128/9 132/20 I panel [76] 13/14
95/5 95/9 97/22 99/16I 24/2 28/13 28/18 29/7) 73/13 73/15 73/15 144/6 146/20 152/15 I 30/12 30/13 51/20
100/19 104/17 104/22I 41/21 58/10 61/24 75/7 87/1 89/15 152/18 155/4 155/17 I 78/11 78/11 81/2 81/3
4105/9 108/21 109/4 I ©2/8 71/7 92/9 99/23 I 106/13 111/11 113/11) 157/10 157/19 158/2 I 81/3 81/8 81/9 85/21
409/11 112/11 112/14I 101/14 103/9 110/2 I 116/10 144/6 155/4 I 158/16 161/16 163/14] 86/6 86/9 86/13 88/1
112/14 115/15 115/16I 112/11 119/4 139/8 I 161/16 163/23 164/3 I 163/16 163/21 164/3 I 92/19 92/22 92/25
1419/2 125/3 126/5 148/19 155/16 160/25I 170/21 174/2 191/10 I 164/8 164/24 170/21 I 93/10 93/12 93/18
426/22 129/3 130/23 166/6 172/19 189/21 I 196/1 197/8 174/2 174/3 176/13 I 93/21 94/10 94/25
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1432/6 132/15 133/3 Iout [88] 5/2 10/7 119/11 119/15 119/23] 195/23 199/17 96/6 96/11 96/18
1434/4 134/25 134/25 11/11 14/19 16/15 120/17 154/11 190/23Ipage 10 [1] 157/10 I 96/22 97/1 97/4 97/7
1435/3 135/4 140/15 19/24 31/19 35/19 194/19 page 2 [2] 24/4 97/17 98/14 98/24
442/24 142/24 143/9 36/23 40/25 44/22 overcome [1] 45/14 I 146/20 99/4 103/7 103/7
143/15 147/13 148/7 I 46/23 49/13 50/4 65/1 overlap [1] 86/23 page 22 [3] 19/5 103/12 104/9 105/2
450/1 150/12 151/12 65/4 66/25 68/20 overly [1] 19/22 19/16 74/7 105/2 108/22 109/1
451/17 155/12 156/9 69/12 73/8 73/20 79/1I overnight [2] 202/2 Ipage 24 [1] 20/1 109/5 109/6 109/9
156/18 162/11 164/22! 79/2 86/15 88/25 89/3) 202/12 page 27 [1] 195/23 I 109/12 109/17 114/23
1467/7 167/12 170/16 93/7 97/2 98/5 103/23] oversee [1] 10/12 page 3 [3] 65/2 93/8 I 114/25 115/1 115/7
470/18 171/20 171/23 105/1 109/3 110/15 oversees [1] 11/1 122/20 115/8 115/12 115/18
171/24 173/14 173/15] 118/22 117/16 119/12I oversight [1] 9/15 I page 30 [1] 199/17 I 115/20 118/1 121/6
174/16 176/16 177/18I 121/1 129/21 138/22 I overturned [27] 5/11 Ipage 34 [1] 54/11 122/7 142/11 142/13
180/15 181/4 184/13 I 199/16 139/17 140/2 I 5/12 5/16 8/11 18/12 I page 39 [2] 128/8 143/9 143/10 143/18
184/16 186/14 187/4 140/10 140/17 140/25) 18/18 144/17 146/23 I 128/9 143/21 143/22 151/9
187/19 188/16 189/20I 141/3 141/3 141/4 160/2 168/13 168/15 Ipage 4 [5] 46/23 162/8 163/3 163/5
189/23 190/17 191/5 I 1417/6 141/7 148/13 I 168/18 170/17 171/4 I 53/13 176/13 176/17 I 163/6
149/17 150/22 151/10I 171/9 172/10 172/14 I 187/5 panel's [3] 93/4
Tele 1eob0 aoDm I 151/20 151/23 153/10] 173/11 175/15 179/10Ipage 42 [3] 10/6 10/7I 93/15 105/14
oral [2] 12/3 18/3 154/22 165/12 168/8 I 182/8 187/7 187/19 I 132/20 panels [1] 31/23
order [21] 4/16 12/21] 170/21 173/10 174/22I 191/3 197/16 199/21 Ipage 43 [2] 54/11 paper [5] 21/7 53/18
15/3 21/20 32/7 48/25I 175/8.177/8 179/19 I 201/17 54/16 76/25 106/21 106/22
57/9 83/24 91/6 91/6 I 179/22 179/25 180/20I overview [2] 53/9 I page 48 [1] 37/8 Papers [1] 30/22
98/9 115/19 1265/8 I 181/14 183/11 184/3 I 53/10 page 49 [2] 66/23 I paperwork [2] 37/17
127/15 130/25 136/2 I 185/1 186/9 186/23 Ioverwhelming [1] I 66/23 37/18
462/20 181/7 191/22 I 191/10 191/13 191/16] 164/6 page 5 [1] 69/10 paragraph [42] 10/3
4194/4 195/5 191/22 191/25 192/3 Ioverwhelmingly [1] Ipage 50 [1] 68/19 I 10/7 18/1 19/16 26/10
ordinary [1] 95/11 I 192/3 192/13 193/22 I 45/6 page 52 [5] 39/13 I 39/14 40/1 43/6 54/15
organisation [3] 13/5] 197/17 200/7 20/9 Jown [17] 18/14 32/17] 163/14 163/16 163/21] 66/16 74/6 103/5
G8 124 202/7 48/24 55/24 61/10 I 164/24 110/13 121/1 124/7
organisations [2] [outbound [1] 168/11 I 61/1061/19 61/24 Ipage §3[1] 40/25 I 128/9 128/10 128/24
52/3 60/3 outcome [13] 21/17 I 80/18 85/20 108/4 page 55[1] 164/8 I 128/25 131/3 131/18
original [14] 12/13. I 88/11 99/1 106/7 128/21 129/22 159/1 Ipage 56 [2] 152/15 I 132/19 132/23 133/2
At 44/15 46/6 113/4I 106/11 115/2 117/26 I 164/7 164/15 194/23 I 152/18 134/11 149/24 149/25
148/19 161/7 161/10 I 128/14 129/11 159/22; —______~"I page 58 [3] 82/16 I 152/16 152/18 153/5
161/13 161/14 161/17I 159/24 198/21 198/21]" ___I 82/18 155/17 154/9 157/10 157/19
161/25 163/3 163/5 outcomes [5] 12/22 Ipace [1] 189/23 page 59 [1] 87/1 158/2 178/23 179/2
originally [5] 55/7 94/4 103/23 186/18 Ipack [2] 85/19 86/12 I page 60 [2] 88/12 193/17 195/14 195/22)
6815 120/15 167/2 I 186/19 page [85] 10/6 10/7 I 92/10 199/17 200/14 201/25
4172/1 outgoing [1] 167/17 I 18/1 19/5 19/16 19/17I page 62 [3] 96/25 _I paragraph 100 [1]
originated [1] 163/2 IUtlined [4] 10/4 65/3) 20/1 21/8 24/4 24/7 I 97/4 103/10 193/17
other [30] 7/3 7/14 65/11 67/9 25/12 25/13 26/18 page 63 [3] 106/5 paragraph 104 [1]
9/10 10/7 11/41 12/20] Utlines [1] 86/5 26/18 26/19 28/11 I 106/5 158/2 1211
outrage [1] 189/15 I 37/8 39/13 40/25 page 64 [1] 158/16 I paragraph 120 [1]
te ee outrageous [2] 22/6 I 40/25 46/23 53/13 page 65[1] 106/13 I 124/7
22/7 54/11 54/11 54/13 Ipage 66 [1] 157/19 I paragraph 127 [2]
aera evs 11) cutset [1] 160/7 54/16 65/2 66/23 I page 67 [3] 110/13 I 128/9 128/10
Toa 199/19 129/131 Outside [8] 9/24 10/1 I 66/23 68/19 69/10 I 419/13 119/15 paragraph 130 [1]
137101 160/22 176/211 10/1 33/23 40/5 9/25] 74/7 82/16 82/18 87/1I page 69 [1] 113/12 I 131/18
182/15 187/20 190/20I 90/3 169/10 87/1 88/12 88/12 I page 7 [1] 18/1 paragraph 139 [2]
20011 outsider [1] 18/5 I 89/15 92/1093/8 paging [1] 52/12 __I 131/3 132/19
outstanding [5] 96/25 97/4 103/10 I paid [13] 25/24 31/19] paragraph 14 [1]
(73) or... - paragraph 14
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paragraph 14...[1] __ 44/13 91/9 91/10 188/22 190/17 191/13) 70/25 71/4 71/18 72/3I 170/7 179/18 186/8
18/1 _ 123/6 123/14 196/11 I 192/11 192/19 193/9 Iperception [2] 193/1
paragraph 140 [2] parties [3] 24/11 194/9 194/11 177/15 178/15 places [2] 25/6 74/18
10/3 10/7 184/14 198/13 payout [3] 42/10 73/1I perceptions [2] plan [8] 22/14 29/8
paragraph 159 [2] partner [2] 60/7 99/18 37/10 119/11 62/4 116/20 147/7
39/14 40/1 60/18 payouts [1] 158/15 I performance [2] 147/12 174/13 174/16)
paragraph 167 [2] partners [7] 52/17 peak [9] 40/18 40/19 I 10/13 108/17 planned [1] 102/17
152/15 152/18 52/19 54/19 59/21 67/11 88/15 88/16 perhaps [18] 7/15 planning [3] 124/11
paragraph 168 [1] 60/15 86/15 86/16 98/5 125/9 126/15 7/25 10/5 38/16 52/24) 124/21 125/11
1454/9 partnerships [1] 61/3] 167/1 54/13 55/22 55/23 plans [1] 114/19
paragraph 181 [1] parts [2] 29/17 peaks [3] 44/11 67/2 I 55/23 67/11 69/15 play [1] 185/10
158/2 113/14 83/20 83/5 87/3 119/12 please [97] 1/12 2/11
paragraph 184 [1] party [5] 121/24 pecuniaries [2] 122/19 132/18 176/24] 4/22 10/22 11/14 12/9
157/19 121/25 194/14 196/15] 200/16 200/17 195/21 17/24 18/1 19/5 19/16)
paragraph 185 [1] 197/25 pecuniary [19] period [15] 11/25 20/25 21/3 24/2 24/3
110/13 passage [1] 19/25 184/21 184/23 193/13) 25/4 26/2 34/23 46/13) 25/12 29/24 33/11
paragraph 22 [1] passages [1] 19/4 193/14 193/16 195/4 I 67/19 73/13 73/14 35/7 37/9 39/12 40/23,
149/24 passed [3] 43/9 195/15 195/19 195/19) 74/1 77/24 79/4 46/21 46/23 52/24
paragraph 27 [1] 85/21 187/9 195/24 196/2 196/6 I 111/21 112/22 125/21I 53/13 54/8 54/10 64/6)
157/10 past [5] 19/9 38/8 196/24 196/25 197/6 I 141/19 64/13 64/16 66/22
paragraph 29 [1] 50/14 50/16 138/9 197/7 197/9 197/11 Iperiods [2] 67/23 66/24 68/19 69/11
201/25 pasted [1] 178/24 200/1 75/4 69/14 74/8 75/12 78/4
paragraph 41 [1] patterns [1] 72/22 pedantic [1] 201/2 permission [4] 68/10) 78/5 78/5 82/16 82/17
49/16 pause [3] 20/10 penalties [1] 65/6 124/22 144/1 144/2 I 87/1 87/23 88/12
paragraph 51 [1] 20/13 133/1 penultimate [1] person [2] 38/25 88/23 88/24 89/15
66/16 pausing [2] 179/24 I 146/12 39/2 90/4 92/10 92/20 93/8;
paragraph 64 [1] 185/4 people [39] 24/20 Ipersonal [7] 28/7 _I 102/1 103/8 104/5
T7AI6 pay [19] 5/20 6/4 27/10 40/8 51/12 39/1 57/7 65/9 95/3 I 106/13 106/22 110/4
paragraph 75 [2] 65/20 65/21 123/12 I 51/14 57/9 58/1 63/7 I 95/10 95/17 110/13 111/11 113/11
195/14 195/22 140/9 148/18 150/21 I 68/6 69/2 69/3 69/4 _I personally [2] 28/17 I 124/9 128/8 130/5
153/10 181/14 184/25) 85/7 100/20 101/22 I 60/22 132/17 132/17 136/10)
paragraph 83[1] I 46/9 188/12 190/5 I 102/18 107/5 107/13 Iperspective [6] 17/5 I 142/21 144/3 144/6
191/12 191/25 192/1 I 108/4 124/17 124/23 I 56/4 78/13 115/20 153/3 153/12 155/4
paragraph 86 [2]
199/17 200/14 192/3 192/22 124/24 125/1 125/11 I 147/24 195/10 155/23 157/9 157/19
paragraph 88 [1] paying [8] 25/17 126/4 134/13 140/21 I pertaining [1] 126/17I 158/2 161/8 164/3
1403/5 26/24 36/4 179/19 141/21 144/25 149/6 IPhase [1] 67/15 164/8 166/9 170/8
paragraphs [1] 186/3 179/22 186/23 191/10) 149/7 151/1 158/24 IPhase 2 [1] 67/15 170/12 170/21 173/3
aralegals [1] 86/15 192/3 159/13 166/2 183/9 Iphone [1] 183/14 174/2 176/9 176/9
oerameters (1) payment [42] 21/11 I 184/7 184/10 198/10 I phrase [2] 20/19 25/5) 176/17 178/9 180/2
realty 30/4 128/19 137/10 Ipeople's [1] 67/24 I physical [2] 80/8 182/13 182/14 183/19)
Pardon [1] 176/7 140/24 150/16 151/3 Ipeople/companies I 193/14 185/14 187/2 199/16
part [20] 5/7 7/21 151/14 152/1 152/25 I [1] 51/12 pick [1] 125/15 plenty [1] 30/22
9/15 13/19 35/3 39/9 I 199/18 153/20 154/12I per [64] 37/15 37/18 I picked [1] 109/9 ploughing [1] 18/14
57/23 64/21 89/12 154/13 155/5 155/6 I 43/12 44/22 45/2 70/9I picture [6] 15/17 plus [1] 84/25
94/2 106/15 111/25 I 195/8 155/18 170/23 I 71/8 71/13 71/22 76/1 76/1 88/22 97/19I pm [5] 110/6 110/8
113/3 11513 12014 I 173/8 175/3 1785/5 I 71/24 71/25 72/1 72/5) 99/7 166/12 166/14 203/9
430/22 130/23 14211 I 175/9 175/10 176/5 I 85/25 89/16 92/5 —_Ipie [3] 22/22 22/25 I pocket [2] 49/13 50/4
jea/4 184/17 183/7 183/8 184/5 I 92/13 92/13 98/25 I 23/9 point [31] 14/14
artifull [1] 106/15 187/4 187/4 187/23 I 98/25 99/1 99/10 piece [5] 48/9 76/25 I 14/15 14/21 24/21
partial [1] 152/23 188/11 188/17 188/18] 101/25 102/2 102/3 I 106/21 106/22 138/25I 29/2 29/11 46/18
partially [1] 120/17 188/19 199/19 199/20] 103/15 103/16 106/9 I pitch [1] 177/11 46/25 56/9 68/12
Participants [1] 199/20 199/23 199/24] 106/10 106/12 106/16I pitching [1] 177/5 73/20 75/24 77/9
167/25 199/24 200/15 106/23 106/24 113/18) place [39] 22/15 84/19 89/3 117/4
participated [1] payments [39] 20/10 I 119/19 119/21 119/23) 22/16 22/17 28/4 34/5) 124/10 131/13 132/21
134/24 58/9 58/13 84/3 119/24 120/1 120/2 I 38/1 41/23 41/24 132/21 168/8 169/24
particular [18] 37/2 126/17 128/23 141/21] 120/16 120/17 127/7 I 43/20 43/23 44/17 170/2 182/2 183/15
42/16 75/24 79/16 149/23 150/7 150/17 I 130/7 130/11 141/14 I 46/9 53/12 58/23 184/15 185/14 191/19)
82/6 88/3 93/14 93/20I 190/23 150/24 152/6 I 150/7 150/10 151/19 I 61/22 62/4 82/20 193/20 199/9 200/14
4107/2 112/23 114/17 I 152/17 152/20 152/22] 153/9 153/10 153/13 I 83/17 83/20 85/15 pointed [2] 67/5
122/13 123/16 135/10I 152/23 13/1 153/6 I 153/22 157/21 157/23] 96/8 109/22 109/22 I 202/7
150/18 154/25 164/17I 1094/1 154/21 154/24 I 163/16 163/18 164/11) 109/23 115/15 115/16] points [1] 201/2
191/11 155/1 155/7 169/24 I 164/13 164/25 166/1 I 121/25 125/17 125/19IPOL [1] 53/8
170/15 174/5 174/11 I 170/24 189/12 196/1 I 135/10 140/15 142/3 IPOL00155397 [1]
(74) paragraph 14... - POLO0155397
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P positives [1] 120/20 Ipost-January [1] 181/16 problem [4] 49/8
Pol 00155397 141 I Possibility [3] 17/1 I 68/22 preferred [3] 109/16 I 49/10 90/7 90/9
Foo 185397.. iW) 61/19 133/4 postmaster [42] 7/6 I 109/16 177/9 problematic [2]
PoLooz93i69 [1] [Possible [11] 41/18 I 12/18 20/3 29/5 36/24I prepared [4] 99/16 I 97/19 123/6
23/11 45/3 61/7 69/13 88/10I 48/23 49/1 49/1 49/4 I 101/9 101/10 188/1 I problems [3] 6/23
POL00423920 [1] 148/13 160/13 160/24) 50/1 52/9 53/16 54/5 Ipreparing [1] 85/5 100/18 100/25
26/17 174/7 190/2 190/20 I 56/2 56/7 56/13 63/7 Ipresent [2] 16/4 Procedure [4] 2/22
POL00448026 [1] possibly [5] 88/16 64/19 76/2 79/3 79/14I 147/10 107/21 110/24 131/17)
92/20 123/22 127/25 154/16] 80/10 80/13 80/24 presented [3] 96/19 I process [204] 6/16
POL00448027 [1] 165/23 81/5 84/15 89/1 92/7 I 131/22 140/8 7/16 9/11 10/25 19/23)
38/17 post [167] 6/16 9/23 I 93/11 93/17 95/7 95/8I press [2] 56/19 22/23 23/3 23/4 25/21
POL00448861 [1] 11/8 13/7 13/19 13/22I 99/15 107/22 109/12 I 180/15 30/25 31/2 32/7 32/9
54/8 14/4 14/10 14/12 109/15 167/9 170/16 Ipressed [1] 14/22 32/9 32/13 32/17
POL00448914 [1] 14/12 14/18 15/7 15/9] 170/25 171/1 185/19 Ipressure [3] 21/16 I 32/19 32/22 32/24
170/8 15/13 15/18 15/20 189/15 136/2 136/4 32/24 32/25 33/7 33/8)
POL00448915 [1] 15/22 16/13 16/14 postmaster's [2] pressures [1] 188/20} 33/13 33/13 33/14
173/3 16/19 17/2 17/5 18/25) 87/22 151/22 pressurise [1] 190/6 I 33/20 33/25 34/3 42/2
POL00458427 [1] 19/13 19/19 19/24 Ipostmasters [46] IPresumably [2] 7/24 I 42/2 42/9 43/4 43/10
Al 21/5 21/7 23/5 23/9 I 5/19 5/22 6/22 12/22 I 141/9 43/15 44/17 45/16
POL00460645 [1] 23/13 24/17 25/2 25/6I 20/5 20/10 25/18 36/1I presumption [1] 45/19 55/7 68/4 71/7
4/23 26/1 27/11 27/13 36/16 36/19 38/9 40/5) 94/20 74/2 74/14 74/23
POL00460646 [1] 27/19 27/22 28/1 49/12 51/16 51/23 pretty [5] 57/13 75/13 75/15 75/24
69/14 28/10 30/9 32/11 54/19 66/19 91/4 108/12 129/23 191/7 I 76/6 76/13 76/25
policy [5] 28/16 35/11 38/20 39/6 112/3 115/14 123/12 I 202/10 77/14 78/2 78/2 78/7
148/12 190/13 190/15 39/10 48/19 50/10 129/12 131/12 136/13) prevalent [1] 90/3 78/15 78/21 78/23
194/16 51/4 51/8 51/9 51/13 I 138/9 138/9 146/23 I prevent [1] 185/1 79/3 81/5 83/24 84/6
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es lithe! 13] 21/15 51/24 52/4 52/4 52/19) 169/9 171/8 174/6 38/22 39/15 73/21 86/24 87/12 87/16
veto 182/20 53/4 53/7 53/10 53/15I 177/18 177/20 179/9 I 101/19 101/21 103/24) 88/25 89/3 89/9 89/12
yet Nee 54/20 54/23 55/20 I 182/6 184/7 188/15 I 105/13 188/9 90/5 90/12 90/19
poe tsation [1] I 56/10 56/12 58/2 197/15 197/23 198/13I previously [10] 3/15 I 90/21 91/2 91/12
politicians [4] 181/22I 58/21 59/24 60/8 198/22 201/7 201/9 I 11/6 36/13 38/19 91/13 91/15 91/15
181/94 189/24 190/21] 00/19 60/23 61/5 63/6] 201/23 79/11 87/10 156/10 I 94/2 96/8 99/22 100/5
politics [2] 148/15 I 69/8 63/1264/15 I postmasters' [3] 187/13 195/13 201/22I 101/1 101/5 101/6
att? 66/17 68/22 77/11 I 20/8 57/5 144/2 prima [1] 81/17 101/41 101/17 102/10
oor [1] 150/1 78/10 78/18 78/18 Ipotential [19] 7/1 _I principal [3] 73/25 I 102/22 102/22 102/23
oo ulavion [16 79/12 79/23 80/18 I 24/19 27/24 28/3 28/7) 75/6 111/23 103/3 103/16 103/22
Pees 38/5 va 80/19 84/21 91/7 93/1I 50/2 60/19 63/14 I principle [3] 105/9 I 105/19 107/3 107/12
71120 103/4 14011 I 94/8. 95/20 103/21 I 63/16 7/17 94/19 _ I 198/2 19915 107/15 107/18 108/8
140/20 140/23 141/6 I 104/1 104/4 104/6 100/9 100/18 100/22 I principles [22] 46/10I 108/11 108/14 109/4
141/25 142/1 142/22 I 104/7 105/5 108/2 101/5 119/8 131/5 51/22 64/7 64/14 65/1] 109/7 111/18 112/1
1484/3 200/8 201/15 I 109/13 114/5 1147/7 I 137/23 192/11 78/8 78/14 93/9 95/1 I 112/4 112/12 112/19
201/18 117/16 118/15 118/18) potentially [9] 27/14 I 117/2 122/6 122/9 115/4 115/9 115/17
120/8 120/23 124/25 I 49/11 51/9 51/15 185/19 197/1 197/3 I 116/1 116/5 116/15
portfolio [1] 108/5
ertion [1] 42/5 426/11 129/7 130/22 I 52/13 62/21 125/12 I 197/12 198/2 198/3 I 117/13 117/13 117/23
oo rhee try tego I 131/4 133/10 133/18 I 167/6 192/24 198/6 198/7 198/10 I 118/3 118/14 119/7
posing [ 31 3i1g I 133/23 134/12 137/13IPowers [1] 61/21 199/2 119/8 119/9 119/19
PRT tare 12/9 15/13 I 139/18 143/24 146/4 Ipre [4] 21/5 150/22 Iprior [10] 3/19 18/6 I 121/11 121/24 122/5
45/21 16/2 20/21 146/21 147/19 148/7 I 150/23 152/1 27/9 148/20 148/21 122/8 122/16 123/8
24/14 28/13 29/18 I 148/16 151/21 152/21Ipre-dates [1] 21/5 I 150/17 157/13 166/21) 123/17 125/11 125/16
28/18 28/25 57/1 57/4I 158/13 158/25 159/11I pre-offer [2] 150/22 I 194/11 196/25 128/13 129/10 129/17
57/5 60/13 110/16 I 162/9 170/14 172/6 I 150/23 priority [1] 191/10 I 132/2 133/5 133/11
toota 148/7 149/9 I 1736 173/13 174/8 Iprecise [1] 200/17 Iproactive [3] 18/8 I 133/17 134/8 134/13
tagio4 189/7 17273 I 174/15 177/1 177/9_I precisely [1] 178/17 I 167/18 189/16 134/23 135/13 135/15
1727 172/18 179105 I 177/12 177/16 177/23I predecessor [1] proactively [5] 6/21 I 136/2 136/5 136/14
481/22 190/13 192/16] 178! 178/11 178/16 I 77/19 93/25 140/1 181/6 I 138/12 138/14 138/18
19373 194/10 198/9 I 178/22 179/4 179/13 I predictions [1] 195/8 138/20 139/3 139/12
sition’ [1] 20112 I 179/20 180/6 180/8 I 100/24 probabilities [1] 441/17 142/10 143/6
oeritive (61.81/22 _ I 180/9 180/18 182720 Ipredominantly [2] I 81/17 143/15 143/16 144/17
Perit 10925 14016 I 182/24 189/3 185/18 I 74/3 167/15 probably [12] 13/19 I 146/10 147/7 147/9
T77INT7 18112 185/24 186/17 188/6 I prefer [3] 15/18 14/14 17/9 23/6 36/11] 147/9 148/5 149/14
positively [2] 92/6 I 191/5 194/10 194/21 I 109/13 138/8 43/22 65/18 131/1 I 150/19 153/15 154/7
30/4 197/14 198/16 preferable [1] 148/8 I 131/2 138/17 180/14 I 154/23 155/15 155/18,
post-Bates [1] 188/6 I preference [1] 200/5 159/12 159/25 160/8
(75) POL00155397.... - process
INQ00001200
1NQ00001200
P 184/24 189/22 190/22] 95/10 R 133/6 135/21 136/8
—__—__ propose [1] 166/22 Ipush[2] 180/19 I__I 466/16 200/23 201/2
process... 26] 463/24I Proposed [1] 197/21 I 189/7 raise [3] 19114 40/15 I oooi1g 202/22 203/1
prosecuted [9] 169/9Ipushed [3] 147/19
ior eon 16 169/13 169/15 173/16] 147/21 165/16
477/16 177/24 177123) 173/22 175/18 201/7 Ipushing [4] 14/15
178/17 1e6/6 186/22 I 201/14 201/25 26/23 158/24 159/3
487/19 187/20 187/21 prosecution [3] 9/18 I put [18] 22/15 32/6
490/22 190/24 194/16) 13/23 18/7 41/24 43/23 56/6 62/4
toe/ie 196/18 197/1 [Protect [1] 25/24 I 63/15 87/25 104/14
198/19 19913 provide [9] 15/1 105/12 107/6 112/6
processed [1] 46/7 I 21/2040/2 56/22 I 134/7 152/9 170/6
rocesses [7] 23/2 I 115/1 131/25 170/14 I 172/18 185/18 186/8
er 30/8 129/10 173/6 200/19 putting [3] 68/9
Togs 137/19 198/12I Provided [17] 66/11 I 99/13 107/9
Processing [3] 65/18 foa/tt 1086 10607
142/6 155/6 ——_—_____-
produce [3] 93/13 I 106/11 136/23 137/1 Iqualifies [1] 159/18
95/19 138 155/24 159/15 162/10I quarter [4] 53/11
6 204/3
19/1
Cone Pata 19622 Recaldin's [1] 132/19
raising [1] 171/25 IFeeall [9] 35/1 54/4
Tampleg (31 39/7, I 108/22 168/1 176N18
et set 176/21 176/21 176/22
ran [2] 1913563 I 178/22
receive [4] 98/18
tert. 18) soait2 150/11 164/1
received [29] 6/19
soni [1] 73/16 49/16 53/15 66/25
tare [1] 59/11 69/22 120/2 122/25
rate [7] 43/12 43/16 I 128/14 130/18 140/11
———— 150/8 150/15 152/24
Q eT TRS 10824 I s5a/12 154/13 163/24
163/25 164/4 164/9
rather [6] 98/14
T10/22 123/23 157/24] 164/10 164/11 164/12
463/19 1741/1 174/12 I 90/6 97/15 136/6 164/22 169/13 169/18
Feed ee I 17814 Quarter 1 [1] 136/6 I TONG 2002 I 17116 173/21 194/20
sae ceat aayig [Provides [2] 5/15 quarterly [3] 53/1 I‘ationale [2] 499/19
pro hictive t 1 ap I 814 53/6 180/11 4) 187/7 Receiver [1] 121/20
Foot ting [Providing [5] 9/17 quashed [1] 187/10 [felt] 18777 I lreceives [1] 158/5
625 712 714 711 7112I 0121 63/24 159/7 — Iquasi [1] 42/9 reached [2] receiving [4] 68/3
: 188/1 quasi-automated [1] ‘ 128/18 168/1 176/4
professional [1] 65/8 I Vision [8] 30/8 I 42/9 reaching rine recent [10] 8/11
Proaeceionalism M11 I'36/9 36/9 35/12 48/7 Iquerying [2] 70/16 /fead [10], 13/0 3. I 17/16 37/24 57/23
58/2 58/5 174/11 I 70/19 58/7 69/16 76/23
professionals [1] provisioning [1] question [12] 16/17 I 31/10 102/3 102/98 I 4 qai49 495/25 161/5
199/12 20/28 26/16 30/6 43/4] 187112 118/00 recently [15] 13/2
provisions [1] 58/16 I 48/10 94/16 101/18 reading [ LG 34/8 35/3 36/5 38/1
provoked [1] 203/4 I 109/18 127/2 148/16 ITeads [1] 63/21 90/6 98/24
public [13] 26/5 166/16 ready 14] 20/8 75/23 I 12615 12617 134/2
26/19 29/19 29/21 Questioned [2] 110 I 1071 Teas 134/3 139/18 171/6
profits [1] 65/5
programme [2] 4/12
10/15
programmes [3] 4/5
4/20 34/4
30/21 31/17 32/2 ‘I 204/5 , 4175/1
progress [2] 29/4 I 34/47 171110 171/13 Iquestions [8] 12/25 Ifealse 2] 12/15 I ecinient (1) 117/24
ing (1 171/13 174/16 171/22] 33/9 117/5 132/15 Wty [2] 76/1 recognise [14] 22/16
ie allied mM publications [1] 133/3 181/19 183/6 realty [ 1 22/18 23/9 30/10
66/19 183/10 30/18 30/19 80/12
progression [1] 70/5
project [5] 4/6 4/12
17/6 124/15 165/6
publicise [4] 68/12 Iqueue [1] 143/11 really (1 et 5217I 194/25 114/3 115/5
131/7 167/20 168/4 Iqueueing [4] 75/21 115/10 129/7 129/21
4107/4 112/1 132/21
Oe ublicised [2] 166/19I 75/22 76/5 143/18 155/20
projection [1] 35/20 IPublic [2] queues [1] 75/24 I 140/4 148/13 148/14 I ARMM oe sai04
projections [2] 58/15 publicising [1] quick [2] 147/7 158/1 162/3 164/18 4137/12
e242) ion I 168/11 179/20 Teale ead {recognition [2] 19/19
promise [2] publicity [6] 67/9 Iquicker [10] 42/11 58/22
190/9 67/22 1552 1687 I 45/4 45/12 45/19 Ifeason [12] 16/10 Ie tection [3] 54/3
promised (3] 365 I gait t84/2 75/17 89/24 90/1 Won saeson I 16512 175/12
£13] 14073 [Publicly [1] 187/15 I 111/26 143/20 187/11) sea 134/14 159/10Irecommend [3]
aie published [2] 3/12 Iquickly [8] 41/9 tSe/1t 201/90 92/25 93/11 95/6
3/12 50/24 101/17 148/13 recommendation
pro 64/17 I Surdah [1] 118/8 I 174/7 189/20 190/1 abt Ur ee [11] 93/21 94/3
purely [1] 149/1 190/20 95/15 95/19 95/23
Proper [1] 33/5 purple [2] 37/15 I quirk [1] 171/18 15715 157/8 165/8 I oei6 103/8 104/18
property (i) eee. I 103/14 quite (20) 14/21 24/1 [reasonably [1] 33/8 I so514 13977 133/9
sabia AN Py \purpose [3] 23/11 I 33/8 44/12 67/1 83/25I"easens [11] 335 I recommendations
poe eyo I 94/20 186/23 86/22 97/19 109/23. I 39/4 S7/15 89/6 8916 I Tar" ga/9 10476 104/8
purposeful [1] 73/17 I 112/17 127/25 129/9 404/20 104/22 104/23)
rt purposes [2] 45/9 I 138/21 141/18 161/20I 123/10 188/5 180/24 I J a4os 4105/1 105/3
proportionately (1) I"433/15 465/14 17/11 184/11)rebuild [1] 187/17 secommended [3]
117] 146/13 [Pursue [3] 17/11 191/23 192/5 pera S Ioo} 93/10 115/9 159/11
Props TN an, I 61/20 132/22 quote [1] 26/12 1 in 95/24 62120) reconsider [1]
pursuing [2] 29/7 I quoted [1] 73/9 448/24
(76) process... - reconsider
INQ00001200
INQ00001200
R
records [2] 80/18
144/10
recoup [1] 120/14
recreate [1] 98/8
recruiting [2] 24/19
125/8
recruitment [3]
red [4] 37/14 103/13
155/17 178/25
45/16
redistribution [1]
redress [71] 5/13
5/15 6/10 7/10 8/9
15/25 16/15 16/19
30/1 30/4 30/9 30/9
30/17 30/18 30/25
33/22 35/10 35/19
36/4 48/17 49/16
58/13 58/22 59/2
63/16 73/7 73/17
73/18 73/21 73/23
130/18 137/5 138/23
169/5 169/8 174/14
180/5 181/14 191/21
191/25 193/22 194/9
redressed [1] 7/9
redressing [1] 97/21
reduce [2] 82/14
155/12
reduced [1] 82/5
reducing [1] 26/6
refer [13] 2/21 2/23
2/25 3/3 25/16 35/5
74/18 80/6 126/22
126/22 127/7 194/22
202/8
reference [17] 31/24
33/23 39/5 53/14
53/25 54/2 62/2 67/6
74/17 81/23 84/10
92/21 109/4 132/21
163/7 181/4 188/6
references [2] 30/12
37/3
referred [5] 2/16 2/19)
75/8 121/13 175/2
referring [3] 39/20
153/22 153/25
reflect [1] 41/13
reflected [3] 18/3
record [1] 23/20
redesigned [2] 37/23
17/2 18/11 19/13 23/4)
113/24 164/6
Reflecting [3] 132/2
151/12 163/22
reflects [1] 82/24
refused [2] 153/21
154/4
regarded [1] 134/8
regarding [4] 20/3
48/6 187/3 190/13
125/15 125/16 125/25I"egardless [2] 21/12
134/25
regrettable [1] 131/4
regular [1] 30/20
regularly [1] 149/6
reimbursement [1]
6/4
rejected [4] 50/16
91/3 151/16 152/1
8/10 10/15 13/13 15/3I"elects [1]_ 131/19
relate [3] 7/12 38/21
39/7
related [8] 5/15 7/17
9/21 33/24 84/4 84/5
17113 172/17
31/7 3119 31/19 32/12 relates [2] 5/7 174/15] 129/25 130/3 131/15
relating [6] 5/9 9/24
55/21 56/1 56/20 58/9I 76/11 176/15 194/3
202/24
relation [17] 8/1 9/3
18/17 38/12 39/24
74/1 91/5 99/18 99/20] 90/24 61/25 64/20
95/3 110/14 122/22
145/16 146/10 147/6
138/24 143/21 148/12
149/17 162/21 168/14I 186/16 197/9 203/3
relationship [3] 21/1
40/12 60/22
relatively [3] 71/23
194/19 194/19 196/20I 77/5 116/1
release [4] 30/25
31/8 32/8 125/12
relevant [3] 12/7
12/12 95/11
relieve [1] 188/19
relying [1] 89/5
remain [2] 111/13
200/12
remaining [1] 200/13
remediation [22]
3/14 4/5 5/1 9/16 11/6
12/20 13/16 19/19
20/9 20/15 22/10
23/21 28/19 120/8
120/11 120/19 120/23)
125/23 177/19 177/21
197/22 198/21
remedying [1]
134/13
reminded [1] 36/18
reminder [1] 124/16
reminding [1] 30/20
removed [1] 156/19
Remuneration [2]
5/18 6/11
reopen [1] 68/11
reopened [2] 123/25
172/22
repaying [1] 20/5
repayment [3] 5/19
20/7 64/1
repayments [2] 20/3
20/13
repeat [4] 12/9 83/9
101/24 103/20
report [16] 4/14 4/14
84/18 103/9 106/3
106/5 155/16 155/17
160/4 160/5 163/13
163/15
reporting [1] 13/20
reports [2] 162/12
184/9
representation [27]
27/12 47/25 65/9
71/20 71/22 100/13
100/16 112/2 117/3
128/1 128/1 128/12
128/17 129/3 129/4
representations [4]
7/25 50/12 158/24
174/21
representative [4]
39/1 92/8 109/11
163/20
representatives [5]
89/2 111/16 178/3
182/22 183/13
representatives’ [1]
109/16
represented [31]
42/13 42/14 42/18
42/18 45/25 46/12
46/17 48/2 48/4 67/7
71/1 71/5 71/9 71/13
71/18 72/4 76/19
102/1 111/4 111/5
111/8 154/15 158/4
158/19 159/8 163/12
163/12
representing [4]
136/13 158/24 159/3
159/6
represents [1] 161/9
request [13] 27/2
64/10 87/15 87/17
87/18 88/14 89/2
128/16 150/18 155/8
175/5 180/14 182/24
requested [4] 20/10
89/20 115/6 188/23
requests [7] 87/19
88/4 88/8 89/11 91/16
150/22 155/5
37/9 54/9 54/12 54/14) 174/16
134/21 147/15 147/17I 41/24
154/11 154/13 154/18I resourced [1] 124/8
157/21 157/25 183/16I resourcing [2] 83/20
23/13 39/24 41/2 41/4) 198/20
require [1] 8/21
required [10] 8/3
8/17 9/9 15/3 18/8
45/8 58/3 91/16
121/23 162/8
requirements [2]
21/19 22/2
requires [1] 54/22
requiring [1] 9/4
rescue [2] 174/13
resolution [21] 2/22
90/21 91/2 91/25
107/18 107/20 108/8
110/24 111/18 116/5
117/21 119/8 131/17
154/23
resolve [6] 11/2 49/5
52/5 114/19 127/16
195/5
resolved [4] 49/25
60/16 91/21 123/17
resource [2] 41/23
85/4
respect [32] 13/2
28/21 31/20 35/2
38/22 49/16 59/2
74/13 95/15 96/11
96/20 103/11 109/4
148/6 150/14 150/15
157/23 161/9 164/8
164/20 173/18 173/25)
175/22 175/23 176/19)
181/11 181/12 183/12)
185/7 194/7 194/10
respond [3] 146/25
190/3 190/7
respondents [2]
120/3 163/17
response [18] 14/23
26/9 28/12 30/17
70/14 89/18 97/3 97/6
97/17 140/4 140/6
143/12 177/24 178/6
178/7 188/14 189/18
190/12
responses [1] 190/8
responsible [1]
77/16
restricted [2] 179/6
192/2
restriction [1] 30/13
restrictions [4] 30/3
185/2 185/6 185/12
restrictive [3] 22/9
33/7 65/18
restructuring [2]
174/13 174/16
2/24 10/25 71/7 90/12I retrial [2] 171/21
108/11 110/12 110/15] 90/23 107/20 110/1
resubmission [3]
114/23 114/25 115/7
result [13] 40/20 44/7I
48/24 52/9 57/10 87/5
93/13 93/19 108/17
128/16 130/2 132/9
176/23
resulted [2] 108/19
142/5
results [3] 61/24
116/4 130/9
retail [1] 93/6
171/22
return [4] 39/12
Returning [1] 155/22
review [18] 5/18 6/11
6/16 6/22 7/1 9/11
76/4 84/20 85/24
101/17 104/4 105/14
105/15 105/19 115/6
142/10 148/3 194/23
reviewed [1] 199/5
reviews [2] 104/6
104/8
revise [1] 96/10
revised [6] 96/6
161/7 161/11 161/15
161/17 161/23
revisit [1] 105/5
revisiting [1] 105/23
RFI [13] 88/14 88/25
89/17 89/18 90/5
90/19 90/23 90/23
91/13 97/3 97/6 97/16)
102/22
RFls [3] 89/16 89/19
90/3
right [93] 9/4 12/18
19/1 20/13 26/12
41/23 41/23 41/24
41/24 46/19 52/16
53/17 54/24 60/4
61/10 62/14 64/8
68/21 83/6 85/1 85/18
86/2 94/6 95/18 95/22
96/15 97/8 97/9 97/18,
98/20 99/5 107/14
113/16 118/2 120/13
121/9 121/17 127/14
129/11 130/12 131/24)
133/2 133/4 133/12
133/16 133/20 134/6
134/11 134/18 135/8
136/7 136/16 138/2
138/14 143/14 151/1
152/4 152/7 156/13
159/1 162/19 163/18
163/22 165/1 165/2
169/11 175/18 175/19)
175/23 176/6 178/10
181/24 183/8 190/9
191/19 194/15 195/18)
(77) record - right
INQ00001200
INQ00001200
R s 98/24 99/12 102/6 _I 57/25 59/25 60/4 60/5] 188/24 189/18 190/12I
; 102/11 102/14 106/16] 60/10 60/14 60/17 _I scrolling [3] 40/24
right [) wen oorep nnn I fy Boro 107/14 109/7 109/11 I 62/4 64/22 68/2 68/11I 64/25 65/2
197/4 198/25 19918 \eaia ran ap rae I 110/18 111/11 111/23] 69/3 73/7 74/3 76/19 Iseal [1] 185/20
201/4 201/5 201/8 14/22 16/11 19/8 112/8 114/5 117/8 76/22 76/24 90/17 second [15] 1/17
204/41 201/13 201/19] 19/14 22/1 34/11 119/17 121/14 122/16] 92/21 93/2 94/20 4/12 26/18 26/19
202/4 202/25 203/5 I 31/12 32/1 34/19 122/21 125/3 127/2 I 94/25 98/3 116/13 38/21 66/1 83/3 90/6
right-hand [4] 83/6 I 45/15 47/8 56/14 127/5 127/16 128/10 I 117/2 118/13 119/20 I 96/6 121/13 132/22
g 129/16 130/9 131/18 I 120/19 123/24 124/13] 133/2 170/2 173/4
97/8 97/9 97/18 57/17 59/7 59/15
rightly [3] 20/12 62/22 64/10 66/17 132/8 134/3 134/12 I 124/15 124/21 125/1 I 174/3
112/17 165/14 80/10 80/21 81/5 134/14 135/21 136/11) 129/8 129/13 130/4 Isecondly [2] 84/4
; 138/6 138/10 138/16 I 130/24 137/10 137/17I 160/8
rights [10] 55/12 81/12 81/24 83/22 I 36/4 439/16 141/22 I 137/17 138/7 138/11 Isecrecy [1] 180/17
137/21 137/23 137/24] 90/12 103/5 113/25
138/3 130/3 14373. I 11719 119/14 119/18 I 142/1 142/25 145/2_ I 139/9 145/16 147/6 I Secretary [4] 178/20
tet 181/2 175/02 I 125101 195/7 1285/9 I 145/10 145/13 146/12] 156/24 160/3 166/17 I 180/23 182/3 182/16
" 147/17 148/20 149/19I 167/7 167/12 168/15 Isection [10] 7/19
ing 13] type 1300 toyoo cao 151/4 152/9 152/18 I 168/22 168/25 169/1 I 21/9 64/17 64/25 93/9)
ring-fenced [1] 141/8 145/20 145/22 I 1939/7 153/8 153/11 I 169/5 169/6 169/11 I 94/13 97/7 110/25
139/25 159/21 163/17 165/19I 154/10 154/24 158/3 I 1741/5 172/1 174/19 I 144/7 201/24
rise [1] 68/22 169/20 172/24 176/2 I 197/11 168/20 170/8 I 175/23 182/20 183/1 Isecure [2] 113/22
risen [2] 40/13 47/2 I 176/3 185/5 197/8 172/6 175/23 178/7 I 183/17 183/22 185/23) 114/4
rising [1] 67/18 202/9 179/3 180/21 182/4 I 193/18 196/10 secured [1] 27/19
7 182/11 183/17 183/20Ischemes [57] 4/3 see [99] 5/1 5/6 21/8
risk [16] 20/21 25/5 Isame [21] 2/18 21/16
28/5 49/21 145/11 29/6 33/25 61/2 69/15I 186/12 188/4 188/24 I 4/24 5/2 6/8 6/18 7/18) 24/7 25/5 25/13 25/21
192/11 194/21 195/15] 7/19 9/24 10/1 125 I 26/9 26/19 28/11 30/3
Meee Te ei sal morte Bolas vtuvtg I 195/19 196/1 198/23 I 12/11 12/20 12/24 I 32/14 3719 37113
Tarot 1So/tt 1eort9I Ta7/19 498/10 139/16) 199/8 201/3 13/1 13/6 13/13 13/14] 39/18 40/23 41/3
17800 196/23 Taort7 seer4 tserr9I saving [19] 28/24 I 14/11 14/19 14/20 I 44/18 41/19 43/11
ie (1) 283 Tee tte ropran I 33/1 68/7 84/16 10715] 15/3 15/12 1518 I 43725 44/2 44/21
145/9 148/4 149/77 I 15/19 16/1 16/15 _I 44/24 45/2 49/8 49/10
risking [1] 151/2 sanction [2] 94/10
risks [7] 10/14 24/17 I 105/3 149/11 164/11 184/18) 16/19 17/2 18/11 49/11 49/15 50/2
, 184/25 185/22 186/10] 18/21 19/13 21/23 I 54/12 55/16 62/18
27/14 26/2 26/9 97/7 ISapphire [1] 4/13 I 486/04 187/15 191/9 I 23/21 25/7 27/20 _I 64/16 65/2 66/24 67/2
oad [1] 25/1 Sa action ong I 19114 191/23 28/19 30/9 32/12 I 68/20 71/2 73/3 73/25
role [7] 3/20 13/11 I 149/9 185/18 says [36] 11/3 18/4 I 33/23 33/2434/23 I 75/6 76/7 82/20 82/24
Tate 77128 96/11 Ieatigfacterily (ry I 12/17 2071 21/10 I 35/10 35/18 3677 I 83/5 83/9 83/15 83/16
185/10 193/19 1008 25/14 26/10 27/1 I 56/25 57/20 58/12 I 87/1 87/3 8B/15 89/15
roles [1] 3/23 catisfied [11] 67/11 I 28/12 28/23 29/10 I 8/14 62/21 67/23 I 89/18 90/4 97/5 9BIt
40/1 45/2 51/5 51/11 I 73/23 76/23 120/9 I 100/13 102/21 103/10
room [7] 16/5 16/22 I 106/17 106/23 107/15
MOT 112/13 183/13 I 116/5 116/68 120/18 I 03/6. 53/14 54/16 I 120/23 160/2 167/13 I 106/8 113/18 119/15
64/18 65/3 80/24 93/9) 167/15 4120/3 132/7 132/22
Rosetta (11. Ve to 130/9 130/10 I 4/44 110/25 11/3 IScotland [3] 3/22 I 143/17 143/19 143/20]
round [3] 81/12 satisfy [3] 48/25 145/5 145/21 146/1_ I 3/25 4/15 144/5 145/24 146/4
B1/13 124/24 4/18 140/2 157/12 163/21 164/25Iscreen [26] 4/23 4/25I 146/20 149/18 154/9
rounding [1] 735 save [1] 130/25 170/12 170/22 174/3 I 10/5 17/24 23/10 24/3] 155/4 155/7 157/20
route [4] 14/1 49/20 lsavings [3] 18714 I 177/38 177/25 38/17 45/21 46/21 I 158/8 158/16 159/8
145/1 146/24 48/24 55123 scale [1] 19/21 64/9 66/22 69/14 159/13 161/9 161/12
Royal [3] 3/21 3/24 Isaw [12] 31/10 44/11 [Scandal [1] 184/17 I 69/15 72/25 78/9 161/25 164/3 171/5
415 62/2 83/2 83/4 83/10 scenario [2] 102/17 I 92/20 104/5 110/12 176/17 177/13 177/24
RU [A] 125/23 4126/2 130/9 141/17 I 189/13 116/3 121/2 122/19 I 178/6 179/1 179/21
Rule [2] 2/1872/21 I 169/1 176/21 197/6 IScheme [116] 5/7 I 132/20 132/25 152/14] 180/15 187/5 18/3
Rule 9 [1] 2/15 say [120] 12/19 5/12 5/23 5/24 6/1 6/3I 195/21 199/15 190/12 202/16 202/20
Rule 9s [1] 7221 I 16/11 24/9 23/2 23/18) £!10 7/9 7/20 8/9 8/18I scroll [41] 10/21 21/3I seeing [2] 87/7
ruled [1] 59/12 24/8 24/21 26/20 28/4I 9/3 10/13 13/16 21/21] 21/8 25/12 26/9 28/11] 182/25
tun [11] 512 5/3 7/19 I 30/29 31/4 3ai2 agra I 23/16 24/15 28/21 I 37/9 39/18 40/23 I seek [12] 21/11
8/22 1316 1347 39/14 40/19 43/6 35/10 36/11 36/13 I 43/11 51/3 64/13 55/14 55/14 64/1
15/16 52/19 118/19 I 45/13 47/9 48/16 36/14 37/1 37/11 64/16 64/17 65/5 65/8I 87/24 100/11 100/20
419/20 1843/1 50/25 57/21 61/17 I 37/1337/14 37/16 I 66/24 68/19 89/18 I 101/22 175/1 175/24
running [5] 4/25 82/11 69/5 64/8 68/21] 38/10 38/12 38/15 I 93/4 93/8 94/13 97/5 I 188/16 202/12
tert eis 135/18 I 69/4 74/8 75/12 7el2 I 39/5. 43/18 43/18 103/10 106/8 119/15 Iseem [1] 42/13
435/22 78/3 78/4 78/10 81/8 I 43/20 44/18 46/9 144/6 154/9 155/4 Iseemed [5] 18/7
runs [1] 56/24 83/25 93/25 adie 48/12 48/20 49/6 50/5I 158/3 161/8 161/16 I 18/16 19/18 130/7
tush [4] 28/24 95/19 95/22 95/25 I 50/6 50/9 51/12 51/19) 170/12 176/17 176/25] 191/20
52/1 56/10 56/23 57/8] 179/1 188/3 188/14 Iseems [8] 20/19
(78) right... - seems
INQ00001200
INQ00001200
Ss
41/3 46/2 50/5 52/7
81/1 128/20
seen [24] 15/20 17/7
21/4 22/12 22/12
22/20 32/22 39/15
39/20 48/22 54/25
59/4 61/24 94/5
155/9 159/23 165/4
198/20
sees [1] 104/20
SEG [2] 2/16 3/1
Select [2] 16/17
189/24
send [5] 131/4
ATTN
senior [3] 2/16 3/1
3/24
sense [4] 29/8 30/2
31/9 201/6
sensitive [1] 122/13
sent [10] 70/12 97/4
97/7 97/17 103/8
139/16 139/17 140/21
140/25 199/22
sentence [4] 19/6
52/7 164/24 186/5
sentences [2] 18/4
separate [11] 6/8
13/21 13/22 27/25
59/15 59/24 86/22
101/1 123/8 162/18
162/22
September [14] 1/15
1/22 1123 1/24 27/6
51/2 53/12 54/25
98/13 121/15 161/15
167/11 175/14 199/25)
September 2024 [1]
161/15
serious [1] 55/21
Service [2] 9/18
109/20
services [1] 146/14
session [3] 99/1
142/11 142/13
sessions [1] 98/24
set [18] 5/2 7/10 10/7
14/14 21/18 21/24
33/5 68/20 97/2 109/3,
109/17 119/12 121/1
175/8 179/25 187/14
193/19 193/22
sets [9] 40/25 46/23
65/1 65/4 66/25 79/18
93/7 170/21 173/10
settle [10] 115/19
seems... [7] 28/20
141/16 147/18 148/23)
174/20 178/23 182/19)
separately [1] 101/14
126/22 127/10 132/9
142/24 166/4 188/2
settled [26] 14/16
39/10 100/10 117/23
136/25 137/2 140/25
141/14 141/15 149/8
149/10 173/2 184/23
196/2 200/2 200/9
200/16
settlement [18] 21/7
72/8 76/18 108/9
172/20 179/12 182/9
185/7 187/25 190/1
140/17 140/18 140/19] 192/4 192/10 192/14
197/15 199/20
settlements [4] 72/6
settling [1] 27/9
seventh [13] 1/20
1/23 2/25 3/3 131/15
168/20 175/8 176/2
198/23 199/16
several [1] 99/17
SFA [7] 76/4 81/13
85/23
SFI [4] 84/9 84/13
84/18 103/3
shaded [1] 97/12
shading [1] 97/9
shake [1] 160/20
shall [1] 170/23
share [1] 35/23
shared [1] 198/15
shareholder [2] 53/9
180/12
she [2] 51/5 177/3
sheer [2] 12/4 12/10
shoot [1] 126/4
short [4] 62/16 110/7
138/24 166/13
shorter [1] 84/8
shortfall [61] 5/6
5/23 5/24 5/25 6/3 6/6
6/10 6/13 7/17 10/13
23/16 36/11 36/12
36/14 37/13 48/12
48/23 50/5 75/22
78/23 78/24 79/5
79/17 79/17 79/20
79/20 79/21 80/5 81/4
81/15 81/19 81/20
81/25 82/2 82/3 82/6
82/8 82/10 82/12
82/13 82/20 83/17
84/15 84/19 85/1 86/1
92/21 93/2 94/16
94/18 94/21 94/21
130/13 134/25 136/23)
150/21 152/2 152/7
189/10 190/19 192/22] 166/17 169/1 169/11
shortfalls [13] 5/9
38/21 51/16 51/25
123/23
shortly [7] 3/13 47/5
195/16 195/20 195/25I 52/21 98/16 98/22
113/20 200/22
200/12 200/12 200/16Ishot [1] 126/1
2/21 2/23 3/2 3/4 6/5
7/9 13/6 16/20 20/13
32/11 54/13 74/21
191/10 191/17 191/22I 85/15 94/25 148/17
151/12 159/4 162/13
194/6 194/8
shouldn't [1] 151/13
show [4] 16/21 26/15
193/17 195/14 195/22] 128/17 179/20
showing [3] 97/18
177/12 178/14
shown [1] 189/24
84/6 84/8 84/13 84/15) shows [4] 67/1 72/17
74/24 128/13
shrouded [1] 180/17
side [7] 5/6 83/6 97/8
97/9 97/18 107/11
167/19
sign [4] 107/7 121/7
140/8 149/12
sign-off [1] 121/7
signature [1] 2/4
signed [9] 14/13
15/14 16/13 24/24
75/17 94/8 122/10
140/7 198/12
significance [1]
119/3
significant [18] 4/5
35/24 37/17 42/5
42/17 50/2 57/9 60/18
70/4 73/11 75/3 91/5
100/3 101/15 111/21
154/14 161/18 196/23
significantly [9] 9/1
39/23 58/2 82/22
83/24 99/11 125/7
146/19 155/15
signing [1] 102/12
similar [3] 158/17
161/20 181/11
SIMON [8] 1/9 1/13
144/12 144/16 145/22
146/13 192/8 204/3
simple [2] 149/16
160/23
52/10 55/25 56/7 62/1
64/2 64/2 79/13 94/14
123/20 123/22 150/20I simpler [1] 160/17
simplified [1] 38/13
simply [17] 9/5 26/5
50/25 61/17 106/20
182/21 183/2
since [15] 3/18 40/8
54/21 55/7 115/15
123/4 125/6 128/2
133/21 134/1 141/10
should [38] 2/17 2/19] 150/7 175/13 177/19
193/3
single [3] 152/22
20/21 27/8 29/3 29/25) 200/13 200/14
sir [34] 1/3 16/7 30/6
67/5 103/23 110/4
165/15 165/17 173/20) 110/9 113/7 116/23
ATTINT 177/22 178/18) 117/4 117/20 132/17
189/21 189/23 190/17I 179/11 182/8 182/15
133/8 133/19 134/2
182/16 187/16 190/16] 134/16 135/5 135/16
166/6 166/15 175/5
200/22 201/11 202/6
202/22 203/6 203/8
Sir Wyn [19] 16/7
113/7 116/23 117/4
117/20 133/8 133/19
134/2 134/16 135/5
135/16 137/22 201/11
202/6 203/6
Sir Wyn's [3] 46/17
159/12 159/16
sit [2] 99/19 99/22
sits [1] 98/14
sitting [2] 124/24
183/16
situation [12] 17/13
17/19 25/6 48/6 50/11
50/19 56/3 56/16 97/1
97/20 150/14 165/22
six [13] 35/24 79/15
79/15 80/14 80/15
81/6 81/7 84/16 84/16
84/17 84/17 155/8
168/17
sixth [23] 1/19 1/22
2/13 2/15 10/3 10/5
37/1 37/3 39/9 39/12
66/16 66/22 69/10
82/16 96/24 110/12
124/7 127/24 128/8
131/14 149/24 152/14)
157/9
size [1] 125/3
skill [4] 79/18
slaughtered [2]
25/19 31/11
sleepwalking [1]
186/15
slick [2] 99/21
28/25 41/13 43/4 44/7I slight [2] 100/23
106/21 120/22 124/13] slightly [13] 21/9
132/20 167/12 169/18] 29/24 39/19 41/19
46/3 46/17 62/8 62/18I smaller [1] 70/18
137/22 159/12 159/16I Smith's [1] 23/12
30/6 46/3 67/5 103/23] 86/15 98/22 160/3
149/16
slicker [1] 45/19
slide [1] 4/23
144/8
69/12 97/5 110/15
117/17 129/6 143/11
147/14 177/1 190/3
slow [3] 76/12
142/11 197/1
slowed [2] 29/19
32/4
small [7] 21/12 67/4
116/6 154/1 154/3
156/14 181/17
Smith [12] 22/22
23/2 51/7 85/19 86/14
86/16 86/19 87/16
126/13 146/14 176/14)
178/1
Snow [1] 177/1
so [287]
solely [1] 93/16
solicitors [4] 64/11
solution [1] 14/25
some [73] 4/3 7/12
7/14 12/2 12/25 13/1
14/5 17/7 17/17 18/18)
20/4 22/2 22/23 24/7
26/25 31/9 40/12
46/14 46/15 47/18
47/22 50/15 55/2
56/20 56/24 57/10
57/11 58/10 58/21
62/4 63/17 67/17
67/18 74/18 76/8
76/16 79/10 80/19
83/5 83/23 97/23
98/21 100/1 100/1
102/5 104/12 107/4
109/24 110/14 111/15)
116/24 127/1 127/2
128/11 135/11 135/14)
145/19 151/13 152/16}
154/2 158/23 159/5
167/24 176/17 177/12)
182/14 184/1 193/2
195/16 198/1 198/19
199/19 200/16
somebody [8] 56/24
56/25 61/16 111/8
131/23 149/5 176/16
182/13
somehow [1] 147/9
something [41] 12/7
18/8 21/10 22/14 30/5)
34/9 34/11 34/14
43/14 47/13 48/7
50/13 52/21 65/12
(79) seems... - something
INQ00001200
INQ00001200
s sped [2] 123/22 124/25 126/14 140/16I 124/16 127/3 127/7 I subsequently [3]
something... [27] 142/8 168/5 183/5 134/6 134/17 135/1 47/23 151/8 172/21
741/24 7713 88/19 speed [11] 29/7 starting [5] 87/2 138/22 139/9 143/20 Isucceed [1] 95/5
94/19 97/22 102/9 29/13 73/18 83/24 88/13 88/16 89/17 146/2 146/16 156/2 Isuccess [2] 15/4
1404/3 114/14 115/23 111/18 118/11 160/7 I 119/25 156/2 157/2 157/6 43/12
419/16 120/11 126/25 180/5 190/23 196/17 Istarts [1] 77/14 157/7 160/22 160/22 Isuccessful [1]
135/18 135/21 136/5 196/20 State [4] 178/20 165/25 167/4 177/21 I 109/24
1436/5 138/17 143/1 speeding [1] 73/25 I 180/24 182/3 182/16 I 180/22 190/25 191/25) successfully [1]
speedy [1] 25/25 statement [86] 1/17 I 201/8 168/21
145/12 149/1 155/10
155/20 158/19 162/15)
162/19 164/19 195/11
sometimes [5] 12/22
89/6 89/9 108/18
130/15
somewhat [2] 177/10)
185/10
somewhere [4] 41/5
59/18 113/15 200/5
soon [9] 77/8 127/22
140/7 140/8 151/20
151/22 183/24 199/4
202/9
sophisticated [2] 4/7
79/12
sorry [18] 10/20
26/19 34/21 38/3 44/9
52/18 85/13 100/7
104/18 104/20 110/17)
125/22 134/1 136/17
139/23 174/17 176/8
190/6
sort [16] 4/3 14/1
14/6 14/23 53/9 62/4
63/17 77/12 89/3
120/9 127/6 133/10
148/15 151/13 165/6
166/23
sorts [1] 185/1
sources [1] 80/2
Southwark [4]
168/18 171/18 171/19}
172/14
space [11] 17/21
83/23 91/20 91/24
120/13 122/13 137/14}
137/15 161/13 197/15}
201/15
span [1] 135/22
spanner [1] 100/23
speak [8] 56/2 60/12
62/6 83/19 118/23
202/23 203/1 203/4
specialists [3] 93/5
93/6 93/6
specific [4] 12/24
93/16 188/22 195/1
specifically [3] 108/2
174/10 203/2
speculate [5] 34/16
34/17 40/21 42/20
63/5
speculating [1] 42/20
speculation [1] 34/16
spend [4] 11/17 26/6
32/14 127/25
spent [3] 35/14 90/5
90/18
spike [7] 83/3 83/7
83/13 83/15 83/18
85/5 87/7
spin [1] 184/4
spirit [1] 24/9
split [3] 41/1 59/9
123/11
spoke [2] 160/1
175/22
spoken [3] 85/3
139/6 161/2
spot [1] 177/4
spring [2] 191/3
193/6
squeeze [1] 32/23
SR [2] 53/13 53/15
stacked [1] 124/2
staff [2] 11/22 79/11
staffing [1] 125/2
stage [39] 43/10 78/3
78/23 81/19 82/7
82/12 82/14 83/8
85/16 87/6 87/9 91/25
92/19 97/2 99/4
100/16 104/4 111/17
119/19 128/5 128/6
130/3 130/17 130/25
132/3 132/5 147/16
147/18 147/23 148/9
148/18 148/20 148/21
148/21 156/2 156/9
160/2 165/5 171/11
stages [7] 23/14 32/1
78/1 78/22 142/7
142/14 142/17
stakeholders [2]
122/12 122/15
standard [9] 66/1
66/3 66/6 66/12 74/10
74/23 74/25 151/13
152/25
standards [1] 95/11
stands [1] 162/2
start [11] 24/3 27/8
51/1 69/22 77/2 78/23
132/16 176/25 187/5
193/16 202/19
started [16] 37/25
38/2 38/5 38/6 43/18
43/22 76/21 76/23
77/8 77/21 98/7
417 1/18 2/13 2/16
2/18 2/23 2/25 3/3
10/3 10/6 11/3 12/3
16/12 16/18 17/25
19/5 28/17 34/20 37/2
37/3 39/13 45/22
46/22 47/1 47/8 47/9
64/11 66/17 66/23
69/11 72/15 72/25
73/22 74/7 74/18 76/8
80/21 82/17 82/17
83/22 92/3 95/18
96/25 99/17 101/24
103/6 110/13 110/17
110/21 121/2 122/18
124/7 128/9 129/23
132/8 132/19 139/15
141/8 146/17 149/24
152/15 155/13 157/9
167/11 168/1 168/20
169/21 175/8 176/2
176/19 178/9 179/2
180/10 181/5 193/17
194/21 195/14 195/22
196/1 196/6 197/13
198/23 199/16 200/18
201/24
statements [11] 1/16
1/20 2/2 2/5 2/7 3/8
3/11 65/12 81/10
103/25 129/22
statistics [1] 159/14
stats [3] 158/14
159/23 165/18
status [2] 66/16
172/25
statute [1] 8/11
Staunton [9] 17/25
18/20 18/24 19/7
20/18 20/23 21/1 26/9
34/6
Staunton's [1] 18/2
stay [1] 155/12
step [7] 25/8 76/16
94/3 98/1 119/7 129/6
138/6
steps [3] 127/17
167/20 189/25
stick [2] 52/23 148/4
Sticking [1] 122/17
stigma [1] 65/8
still [36] 44/15 49/3,
49/13 61/25 65/22
75/3 91/15 101/14
101/14 113/2 123/19
stimulating [2] 20/11
20/20
stop [5] 34/4 67/3
67/24 75/14 167/7
stopping [1] 143/15
store [1] 60/2
story [2] 130/22
149/7
straight [3] 111/17
112/20 142/4
straightaway [3]
124/1 137/13 150/11
strategic [10] 2/18
3/2 11/9 52/17 52/19
54/19 59/21 60/7
60/15 60/18
Strategy [1] 170/11
street [1] 162/24
stress [1] 189/15
stroke [3] 185/17
186/9 186/19
strong [6] 21/11 22/4
31/18 135/17 151/20
192/5
structure [2] 15/3
170/22
struggle [9] 21/15
106/20 106/25 114/8
120/15 130/6 130/15
159/9 166/1
study [1] 129/22
stuff [1] 186/14
subcommittees [1]
10/22
subject [6] 3/7 21/6
49/17 87/14 159/16
202/24
submission [3] 117/4I
129/18 196/3
submissions [1]
157/17
submitted [9] 17/8
46/8 46/12 47/4 47/6
69/19 113/6 195/20
196/2
submitting [1] 175/9
subpostmaster [4]
6/6 49/20 52/11
167/24
subpostmasters [8]
19/2 49/15 50/3 58/25)
93/23 106/1 130/21
202/3
subsequent [2]
16/23 145/5
such [15] 4/8 19/8
43/16 44/4 51/14 75/6
95/9 95/11 117/1
118/13 121/19 151/2
160/4 162/16 193/14
suffered [7] 7/8
48/23 49/12 52/9
55/13 56/7 173/17
suffering [1] 150/1
sufficient [14] 11/10
11/21 11/21 11/22
11/24 12/1 28/15 36/6)
57/18 57/19 152/7
152/11 164/1 164/14
sufficiently [3] 129/2
129/3 138/18
suggest [4] 52/8
129/1 158/23 182/5
suggested [6] 19/22
36/22 116/24 141/19
185/22 195/5
suggesting [1] 91/5
suggestion [1]
141/16
suggestions [1] 34/6
suggests [2] 22/21
154/16
suitable [1] 188/18
sum [13] 8/24 38/4
100/11 132/12 136/19)
136/22 144/25 146/24}
148/7 156/11 156/18
188/15 188/17
summarise [3] 121/9
121/21 194/6
summer [5] 27/7
33/18 64/9 193/5
193/7
sums [4] 35/14 36/5
156/24 185/1
super [3] 66/8 66/9
66/12
superseded [1]
65/23
supply [1] 200/6
support [24] 8/25 9/9
11/21 11/24 12/1 12/2)
27/16 28/17 63/8
77/12 87/25 125/2
129/19 131/11 147/20)
157/24 163/25 164/2
164/4 164/9 164/11
164/14 171/20 174/12)
supported [4] 80/20
117/3 197/13 197/21
(80) something... - supported
INQ00001200
INQ00001200
s 165/13 166/6 167/4 I 113/10 53/23 54/10 58/7 141/23 148/12 149/21
supporting [3] I 168/12 181/25 182/17] tentatively [2] 124/12] 58/24 62/7 62/13 151/6 152/1 152/4
T7704 t7al7 174/15 I 188/16 189/9 189/25 I 166/23 62/18 63/24 64/6 152/5 152/11 153/18
supportive [4] 15/1. I 196/7 198/21 198/24 Itenure [1] 27/23 64/16 65/10 65/25 I 154/19 154/19 155/6
104/16 118/13 195/7 Itake-up [5] 118/24 Iterm [6] 20/8 36/19 I 66/15 66/23 67/14 I 155/10 156/13 157/17
supports [2] 152/8. I 157/20 187/25 164/20) 89/11 110/21 112/4 I 67/22 68/19 69/9 159/10 163/3 163/13
177/19 165/13 129/8 69/11 69/13 69/21 I 164/6 165/1 165/17
supposed [1] 203/1 taken [23] 19/7 19/23Iterms [95] 12/1 17/16) 70/1 70/4 70/10 70/12I 167/16 171/5 175/2
sure [18] 17/7 21/4 38/1 40/24 41/20 69/6) 19/1 21/19 22/10 70/23 71/10 71/14 175/7 175/12 176/6
33/5 83/19 85/22 75/12 96/9 104/1 22/16 22/17 25/10 TAIN7 72/6 72/8 72/10I 176/19 178/13 181/12
98/13 102/11 105/21 104/2 107/8 109/22 27/18 30/8 30/11 72/12 72/14 72/20 181/23 181/24 183/23)
110/5 130/15 133/1 I 109/23 112/23 127/17] 30/17 31/23 33/14 74/8 78/22 81/16 85/3] 184/1 186/2 191/15
133/4 147/18 147/20 I 131/16 132/6 140/16 I 33/23 33/25 34/7 85/16 87/15 89/15 193/13 195/18 195/21
148/22 165/23 191/23I 1596/6 161/14 162/16 I 37/13 37/16 38/7 39/4) 92/9 92/10 94/13 195/22 196/5 198/15
202/10 162/23 167/20 39/17 42/21 43/12 94/23 96/11 96/20 200/8 201/1 202/13
surprise [7] 37/21 takes [19] 33/7 33/13I 44/14 47/25 53/25 96/24 97/4 103/5 202/20
37/22 92/15 120/5 33/13 34/3 74/5 74/12) 54/1 57/17 61/13 62/2) 104/4 106/5 107/17 I their [124] 4/16 8/23
4120/7 167/24 168/2 I 74/14 74/23 75/13 63/17 65/11 66/5 67/6] 108/16 110/4 110/23 I 9/7 12/6 12/11 12/16
surprised [3] 104/2 76/3 82/19 83/16 87/5) 73/6 73/20 76/19 113/11 116/17 120/24] 13/2 15/21 16/19
116/8 120/21 88/7 90/22 103/7 81/16 81/18 81/20 122/17 123/18 126/16] 18/14 23/17 31/24
103/22 109/22 132/9 I 81/22 83/20 84/1 136/7 136/16 136/19 I 32/4 32/16 42/22 48/6
survey [10] 37/7 :
61/24 92/9 116/3 taking [17] 1/19 3/19 I 84/14 88/2 88/22 140/24 146/18 149/22 48/16 48/24 49/5 52/6)
119/4 119/12 12014 I 4/16 35/13 37/2 44/5 I 90/14 92/21 98/11 149/22 150/14 152/14! 53/16 54/5 56/4 56/13
130/9 160/15 164/25 I 44/5 46/4 74/25 98/21I 99/14 99/23 100/4 152/18 157/20 159/15I 59/2 61/1 61/10 61/10
suspended [5] 5/20 102/23 125/16 139/3 I 103/21 104/18 106/8 I 160/25 161/6 166/5 I 61/18 61/19 61/20
6/3 6/5 6/7 6/13. 158/12 163/10 181/23] 108/10 108/13 108/16] 166/11 166/15 167/9 I 64/20 64/20 66/16
Suspension [2] 5/18 198/18 109/3 114/10 115/6 I 168/13 173/3 176/9 I 78/12 79/3 81/22
ey. talk [8] 20/23 63/19 I 115/21 116/17 117/18] 181/11 182/4 193/8 I 85/19 86/11 86/19
74/4 106/21 107/8 119/11 120/16 120/20) 193/8 194/21 195/14 I 87/25 89/1 90/2 90/14
138/20 149/6 178/7 I 122/9 123/10 125/2 I 196/24 199/15 200/21I 91/4 92/8 94/3 96/6
talked [4] 78/8 84/6 I 126/1 126/7 131/15 I 201/18 202/11 202/13) 96/12 96/15 102/2
swaps [1] 4/8
sympathetic [1] 82/1
sympathy [1] 50/7
system [12] 18/15 122/6 142/7 136/5 137/22 140/24 I 202/14 203/6 203/7 I 102/4 108/4 109/15
33/19 33/21 45/4 talking [6] 33/22 63/4I 145/12 147/21 147/25) 203/8 111/4 112/14 114/1
61/24 62/1 79/8 79/8 I 79/3. 77/6 126/11 147/25 148/2 155/10 I that [1407] 115/8 115/23 117/7
79/9 79/13 170/20 147/16 155/17 163/6 163/7 Ithat's [145] 1/16 2/10) 117/12 117/18 121/14
173/17 tally [1] 106/24 165/9 168/9 169/20 I 6/15 7/21 7/23 10/25 I 123/10 125/13 125/14!
tangible [1] 113/23 I 180/4 180/17 187/22 I 10/25 16/2 17/6 19/25) 126/15 128/12 128/20)
systems [1] 62/3 ltargeted [1] 40/4 I 197/7 197/10 201/17 I 22/9 23/6 24/1 24/14 I 129/13 130/17 131/19
T targeting [1] 44/21 Itest [1] 31/20 26/16 27/22 29/8 I 139/23 139/24 139/24
table [4] 40/25 68/21 Itask [1] 92/25 tested [1] 32/17 30/24 31/6 33/11 I 140/7 142/6 143/10
90/4 158/16 tax [2] 72/10 126/17 Itext [1] 177/13 33/18 34/3 34/3 34/8 I 144/1 147/24 151/4
tainted [1] 118/17 _ Itaxation [1] 121/19 [than [43] 8/7 9/1 9/5 I 37/23 38/16 38/17 I 151/8 152/23 19/6
take [80] 2/11 18/2 {taxpayer [1] 31/17 I 23/22 27/10 29/1 I 39/13. 40/17 40/21 I 19/6 163/6 163/6
19/4 19/25 29/17 32/1Itaxpayers [2] 30/15 I 30/23 37/14 42/14 I 41/23 47/4 47/6 47/6 I 163/17 164/10 164/12
37/21 37/22 42/4 I 148/2 47/17 58/4 59/11 I 49/2 51/6 52/21 53/3 I 165/1 165/2 165/2
42/13 43/3 45/7 45/11]taxpayers' [1] 23/24 I 59/11 80/23. 91/23 I 54/14 54/15 56/4 I 165/11 168/11 168/21
45/19 46/5 47/5 48/15Iteam [21] 2/24 4/22 I 92/2 94/19 96/3 98/14) 56/21 57/14 64/7 64/8I 170/17 171/3 172/9
50/24 51/23 52/10 I 9/20 10/2 12/1 19/19 I 99/3 99/3 100/11 _I 67/20 69/11 70/8 _—_I 172/11 173/11 175/25}
62/8 69/9 75/14 76/15I 20/9 20/15 30/20 I 100/21 103/13 103/24] 72/25 73/4 73/5 73/12I 179/9 179/12 181/24
76/16 78/1 78/5 82/20I 58/17 79/2 79/5 108/1I 105/21 110/22 116/5 I 73/13 74/6 75/16 _I 182/7 182/10 184/10
83/17 86/10 88/24 I 108/3 108/3 125/3 I 123/23 127/5 140/11 I 75/18 75/20 76/4 7/3I 184/13 184/23 187/11
90/11 92/22 93/18 I 126/4 126/6 136/1 I 141/1 141/15 143/21 I 82/11 82/15 84/10 _I 189/7 189/8 189/10
94/11 96/8 98/1 99/2 I 144/20 177/2 149/2 151/10 153/2 I 88/4 89/6 89/12 90/7 I 190/1 190/19 191/2
1401/9 101/10 102/18 Iteams [1] 9/10 153/19 156/11 157/24) 94/22 95/19 97/21 191/2 194/19 197/23
1406/4 109/13 110/2 Itease [1] 136/8 170/24 189/8 196/21 I 98/20 98/25 100/22 I 198/6 198/7 198/14
413/2 115/9 119/24 Itechnical [1] 81/13 Ithank [134] 1/8 1/11 I 101/9 106/25 109/14 I 199/21
421/25 122/2 123/10 Itechnically [3] 95/22 I 1/14 2/11 3/7 3/11 4/1) 109/17 110/2 111/20 Ithem [62] 6/23 23/15
4128/8 138/6 140/15. I 172/16 201/4 4/21 6/11 7/14 7/18 I 112/15 112/18 113/9 I 25/9 37/21 37/23
143/25 144/9 144/25 Itelevision [1] 188/6 I 8/5 9/109/20 10/3 I 114/7 115/9 115/16 I 47/24 48/3 48/20
4145/8 145/19 146/24 {tell [1] 139/20 10/6 10/20 11/5 17/13] 116/1 116/9 119/13 I 49/18 54/4 57/11
4151/8 155/16 156/5_ \ten [8] 7/2 7/3 7/10 I 17/25 20/25 23/23 I 120/19 120/19 121/15] 57/11 59/21 63/8 68/5I
4157/5 157/20 157/25 I 99/199/10 140/9 I 23/23 28/11 29/16 I 123/7 125/24 127/2__ I 68/15 68/17 69/21
160/25 161/1 164/20 I 192/20 193/20 36/10 37/1 44/24 I 128/9 129/15 132/20 I 76/10 76/10 78/9 94/5I
tens [3] 47/13 113/9 I 46/23 48/10 53/12 I 133/15 136/9 141/9_ I 96/17 100/8 102/10
(81) supporting - them
INQ00001200
INQ00001200
T therefore [58] 6/4 194/15 197/13 198/23 200/18Itight [1] 21/17
them... [37] 104/12 _ 6/12 7/8 8/25 14/6 —_Ithings [12] 14/4 14/5 I 202/7 202/16 202/25 Itill [1] 55/24
1405/3 105/6 107/7 14/24 27/25 28/2 28/3I 48/21 86/10 94/4 203/4 time [95] 4/1 11/10
120/25 121/1 122/10 I 28/24 40/9 41/25 42/1I 98/12 111/24 131/16 Ithinking [4] 28/16 11/17 12/2 14/6 14/24)
426/22 129/11 131/13} 48/20 50/2 51/18 160/20 196/20 197/17I 133/16 147/24 201/20) 15/21 16/22 17/10
1439/7 140/2 141/17 I 91/24 58/15 60/9 197/20 third [11] 1/17 38/24 I 21/5 21/22 25/2 25/4
142/17 142/25 143/16I 99/19 77/7 7/13 think [189] 4/2 5/12 I 66/2 92/11 121/24 29/6 33/13 33/14 34/3
443/20 145/13 148/24I 79/10 80/14 86/3 89/7) 8/8 9/20 12/16 12/17 I 121/25 123/20 173/20) 39/6 40/23 41/10
154/5 157/18 159/7 I 90/1 90/2 90/22 91/3 I 12/17 14/8 14/11 184/14 196/15 198/13] 41/11 43/17 44/10
161/24 162/25 171/17I 91/15 97/24 100/2 15/17 16/5 16/9 16/11) Thirdly [1] 2/20 45/20 46/25 58/10
472/21 173/1 183/14 102/12 102/13 107/6 I 16/12 16/21 17/14 this [294] 58/21 67/10 69/15
183/21 192/12 192/13I 198/12 118/9 120/14 I 17/20 21/16 22/9 thorough [1] 78/20 I 74/5 75/3 75/21 77/18)
192/21 194/12 194/13I 124/15 124/20 125/10] 22/25 23/5 23/6 24/14Ithose [240] 78/17 79/4 80/10
196/21 200/15 200/16I 129/12 129/17 130/6 I 25/3 29/9 29/22 29/25Ithough [9] 46/14 82/25 83/9 83/21 87/4
themes [1] 13/1 135/14 138/19 138/25] 34/17 34/19 36/6 104/12 113/13 122/17I 90/7 90/22 91/10
themselves [13] 142/2 152/2 154/7 36/11 39/19 42/21 125/15 128/20 162/15] 92/11 92/14 96/18
14/19 14/20 25/9 156/1 168/22 169/10 I 43/23 44/11 44/13 172/18 175/17 100/4 102/12 103/12
49/17 50/4 52/11 56/7I 171/22 173/19 186/24) 45/8 46/3 46/3 47/2 Ithought [10] 17/10 I 104/1 106/4 106/9
57/6 61/18 64/3 188/18 47/24 48/3 51/6 52/16I 29/1 40/8 77/4 79/4 I 110/17 111/14 111/20)
101/21 182/1 182/1_ Ithese [47] 8/21 8/21 I 53/13 56/6 56/19 117/21 126/9 182/21 I 111/21 112/21 112/22
then [90] 3/21 3/22 10/1 12/17 14/4 15/15) 57/13 57/14 57/15 183/2 183/5 113/4 114/24 115/10
4/10 5/11 5/18 6/16 I 18/15 25/7 33/24 57/17 62/12 63/15 Ithousand [1] 161/21 I 115/18 115/19 117/10
7/18 8/9 9/8 13/13 37/11 50/24 57/15 63/15 64/10 66/7 thousands [1] 117/19 118/7 119/24
28/5 28/10 30/23 31/4I 64/14 68/6 69/18 66/10 66/12 67/16 140/19 122/2 122/11 126/14
31/6 31/12 32/15 72/21 79/10 90/9 69/2 69/3 70/7 71/8 Ithree [17] 1/16 18/10 I 127/25 131/16 131/20
32/16 36/3 36/10 40/8) 92/20 104/2 107/1 71/12 73/11 73/16 65/12 73/6 73/15 76/4I 132/1 132/6 132/9
40/16 44/12 47/6 49/2) 107/1 117/6 117/21 I 76/8 83/18 86/22 86/8 88/8 97/18 98/15] 133/10 143/6 144/21
50/24 50/24 61/14 117/22 126/12 133/15] 88/17 89/23 89/25 164/25 172/9 194/22 I 153/16 155/6 167/18
138/22 144/25 152/21I 90/9 90/20 91/1 92/3 I 195/1 199/18 199/20 I 169/25 170/2 170/9
Cea cat crea na I 18415 154/24 189/14 I 92/4 92/17 94/22 96/1] 199/22 175/9 176/4 19312
Bate Oris eave U” I 189/23 161/8 161/18 I 97/6 97/14 97/25 threshold [2] 65/13 I 195/9 195/12 195/13
Soo cca eee I 161/22 16371 163/4 I 99/12 100/22 1011 I 155/24 196/7 198/1 198/8
163/7 164/15 171/17 I 101/5 101/12 106/4 Ithrough [74] 1/19 198/8
nt ott on 087 174/14 185/1 186/18 I 106/19 109/7 111/24 I 2/10 2/11 3/23 6/9 _I timeliness [3] 103/25I
108/6 108/22 109/8_ I 186/18 199/20 111/25 113/9 113/23 I 6/10 11/20 21/17 138/24 162/21
409/14 109/19 115/7 Ithey [286] 114/6 114/8 114/9 25/15 26/1 27/3 32/13/timely [5] 12/22 23/5
115/8 115/8 116/9 _Ithey'd [2] 68/16 116/5 118/6 118/7 33/14 41/9 42/7 43/17I 25/24 138/23 143/13
117/23 118/1 118/8 I 194/20 119/4 119/5 119/16 I 44/8 44/10 44/16 times [10] 11/20
tata 1285/6 131/22 {they'll [1] 151/10 I 121/15 122/11 123/20I 45/10 46/10 50/15 I 25/22 96/9 98/15
431/24 139/12 145/4 {they're [35] 12/19 I 125/15 126/9 127/13 I 50/24 60/16 60/17 _I 105/18 108/25 109/23
149/11 153/11 159/24] 98/14 41/12 48/13 129/5 129/7 130/2 60/21 66/6 72/14 148/23 153/16 188/5
164/3 166/25 168/18 I 48/13 48/16 59/1 130/5 130/20 131/1 I 75/15 78/1 78/7 78/18I timescales [1] 177/6
1470/2 170/12 173/10 I 99/25 61/12 68/21 131/2 132/8 133/14 I 83/8 84/11 87/12 timing [1] 138/16
174/18 177/24 17916 I 89/7 79/10 81/21 135/3 135/6 141/8 89/24 90/1 92/22 tiny [2] 154/3 154/4
1479/8 180/14 184/17 I 81/23 85/14 86/10 141/23 141/23 142/1 I 97/25 99/2 99/4 today [7] 1/18 56/18
192/2 192/10 193/3 I 191/8 101/10 102/7 I 142/5 142/8 143/8 101/11 111/15 119/4 I 67/5 70/8 121/5
193/9 196/16 196/24 I 107/7 110/15 115/9 I 143/13 143/13 146/2 I 121/3 123/19 125/10 I 136/20 185/5
1498/1 202/20 119/12 128/5 128/5 I 146/8 147/16 149/3 I 125/12 126/8 129/11 Itoday's [1] 25/21
theory [1] 129/20 143/18 148/4 149/8 149/13 151/23 152/6 I 141/25 142/6 142/9 together [3] 24/12
there [312] 151/23 153/17 156/3 I 152/8 153/21 154/5 I 147/8 151/9 152/12 I 26/3 114/6
there's [38] 2/14 161/22 162/7 181/24 I 154/19 154/19 154/20) 160/19 172/19 172/20) told [6] 20/4 58/25
11/15 11/15 29/22 201/16 157/16 157/25 158/21) 176/24 177/21 180/19] 104/11 179/5 180/7
30/14 40/25 51/3 they've [18] 23/20 160/11 160/12 161/24) 182/22 183/2 183/5 I 180/11
54/14 64/25 65/3 49/25 50/15 94/2 96/9] 162/12 162/18 164/18) 184/12 185/13 185/13I Tomlinson [1] 4/14
76/25 79/20 80/21 112/15 117/24 134/25] 164/19 164/24 165/14I 188/5 189/7 198/16 I tomorrow [4] 200/23
84/2 93/8 94/13 101/6I 1959/1 141/4 141/5 165/22 168/21 172/2 I 198/22 199/4 199/7 I 202/17 202/19 202/21
104/23 106/14 109/16I 141/6 149/8 149/10 I 172/24 173/1 176/14 Ithroughout [3] 11/25 Itoo [15] 22/3 22/22
115/6 121/19 123/8 I 194/17 151/18 159/22) 177/22 178/13 178/17) 13/6 79/22 25/17 75/13 75/14
134/17 135/5 144/6 I 199/23 180/3 180/4 180/5 —_I throw [1] 100/23 76/6 99/13 104/2
1444/9 158/16 160/15 Ithing [16] 12/18 19/8 I 180/16 182/12 182/13) Thursday [2] 24/5 107/8 107/9 127/13
1463/5 165/20 177/24 I 76/16 76/21 81/2 81/3] 185/6 186/2 186/3 24/22 127/14 127/16 160/16)
1487/3 191/8 192/1 119/10 122/4 131/3 I 186/5 186/14 187/16 Ithus [1] 134/24 163/10
1493/9 201/2 202/2 143/1 160/1 167/9 191/18 195/1 195/19 Iticking [2] 26/22 took [19] 13/2 24/2
181/20 190/9 191/20 I 196/10 196/17 196/19] 43/21 36/23 41/5 41/6 41/11
(82) them... - took
INQ00001200
INQ00001200
T
43/17 53/12 75/2
78/16 92/11 92/14
103/14 106/9 119/24
125/19 197/6 198/1
top [15] 5/1 39/14
72/10 89/18 132/12
139/2 140/24 141/9
146/5 148/7 149/11
189/16
top-up [3] 139/2
140/24 148/7
top-ups [6] 72/10
14119 146/5
topic [6] 23/24 24/1
110/14 110/11 132/14
132/16
torrid [1] 26/1
total [6] 71/22 72/8
72/12 152/20 153/22
173/9
68/9 88/15 113/18
track [1] 23/20
traction [2] 36/1
124/18
Trade [19] 2/20 3/5
5/4 7/20 8/4 8/23
10/12 15/11 26/4
32/10 53/8 63/13
76/12 96/21 118/22
137/12
Trade's [2] 23/25
32/3
trades [1] 4/9
trading [9] 27/14
28/13 28/16 28/21
33/16
‘traditionally [2]
13/15 13/15
training [2] 7/5 7/7
transcript [1] 23/11
transfer [2] 119/8
125/13
transferring [1] 17/2
translate [1] 188/10
transparency [2]
15/25 159/14
transparent [2]
158/21 178/19
Treasury [6] 27/4
27/4 32/16 63/13
78/20 121/8
treatment [1] 126/17
trend [3] 40/3 73/19
88/15
trends [1] 72/22
trial [1] 169/17
took... [13] 43/15
136/20 136/23 136/24] trust [1] 25/25
132/12 136/20 136/24}
towards [5] 4/1 23/14]
126/20 126/23 135/25I 44/2 45/8 49/22 52/13
27/18 27/24 28/3 28/9I 162/18 162/24 172/21
tried [2] 32/17 75/18
igger [3] 82/8 82/9
86/1
triggered [1] 67/17
troubled [1] 11/20
troublesome [1]
123/14
true [3] 2/7 3/8 75/25
truth [2] 1/16 182/13
try [6] 20/15 41/21
50/11 149/4 157/1
182/13
trying [6] 32/23 136/7,
145/11 160/12 160/20)
195/7
Tuesday [1] 24/12
turn [28] 12/24 18/1
19/5 20/25 26/15
36/10 38/15 52/24
53/13 54/8 54/10
54/11 64/6 74/7 82/16
87/1 88/12 92/9 103/9
144/3 157/10 157/19
163/13 170/8 173/3
176/9 176/13 187/2
turnaround [1] 89/5
turned [4] 73/4 126/6
140/7 165/9
TV [1] 40/15
twice [2] 98/14
149/13
two [34] 4/5 6/7 6/8
7/18 10/21 29/22 44/2
60/14 60/16 67/1
73/14 73/15 76/3
86/22 88/8 94/4 98/25
101/1 107/9 132/15
133/3 161/14 161/17
177/18 183/15 190/7
201/2
type [4] 66/1 71/19
79/20 177/8
types [6] 65/3 65/12
68/20 79/23 135/6
158/6
U
UK [1] 11/16
UKG100031750 [1]
51/1
UKG100033420 [1]
64/7
ultimate [2] 9/15 82/4)
ultimately [3] 56/3
56/21 100/20
um [1] 50/21
unable [1] 64/19
unacceptable [1]
25/4
unanticipated [1]
121/15
unaware [1] 134/14
uncertainty [5] 82/6
82/13 134/18 134/20
134/22
unchanged [1] 39/17
uncomfortable [3]
186/22 187/17 191/18
under [38] 3/3 5/23
5/25 6/3 7/19 15/14
21/15 42/8 45/17 50/5
50/21 50/22 58/18
62/6 84/15 84/20 86/4
86/6 87/13 91/14
91/15 99/24 101/3
101/16 114/14 118/6
126/18 127/1 136/2
136/4 139/24 142/24
142/24 148/3 173/7
174/19 181/1 184/23
underestimating [1]
TNT
undermining [2]
186/10 186/19
understand [60] 4/9
6/24 8/22 31/7 32/15
33/6 33/9 37/21 37/22
46/11 54/24 55/15
56/3 56/17 57/7 60/17
69/7 72/5 76/17 77/20
77/25 80/23 85/18
86/8 91/6 95/18 96/17
105/2 112/5 112/9
112/10 118/11 118/15
118/18 118/23 119/20
123/9 135/17 138/4
139/4 139/5 149/4
149/4 149/5 149/12
151/7 152/16 154/6
155/2 155/20 158/15
160/3 160/13 162/1
173/19 183/14 185/11
185/14 189/2 199/6
understandable [1]
57/4
understandably [1]
33/8
understanding [30]
9/6 19/7 26/5 27/10
33/24 37/14 37/16
48/18 48/21 57/5
57/25 59/19 60/5
60/15 63/22 67/12
69/1 79/6 79/7 82/15
85/12 128/23 128/25
147/22 170/5 171/15
173/23 175/7 197/10
201/18
understood [3] 62/22)
100/17 166/24
Underwood [1] 21/6
unexplained [1] 62/1
unfair [7] 23/6
102/13 117/17 117/25
159/16 159/22 159/24:
unfortunately [2]
88/6 120/10
unfunded [2] 20/12
20/20
unit [10] 3/14 3/16
4/22 5/1 5/3 7/24 9/16I uphold [1] 177/22
11/12 56/24 125/23
unlegalistic [1]
160/23
unless [2] 78/2 203/2Iups [6] 72/10 132/12
unlikely [3] 34/12
34/18 63/18
unreconciled [2]
20/4 20/5
unreliability [1]
170/19
unresolved [2]
111/13 113/3
unsympathetic [2]
18/17 18/22
until [15] 34/4 34/7
43/20 43/23 44/18
44/19 46/5 66/25 98/4I 68/25 69/23 70/2
112/13 121/8 124/10
135/23 167/25 203/10I 77/16 83/25 85/4 85/8
unusual [2] 120/9
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Tee g oa eS ont e I 133/18 135/19 136/22I'71123 91/18 98/18 I §5/23 55/24 87/1 57/2
136/6 136/21 155/7 I 101/7 111/15 112/7 I 58/25 59/1 63/3 64/11
poeta tiara doartg) 1614 167/11 168/20 I 112/18 135/6 137/2 I 65/11 66/11 66/16
Toy 1ovle woyrtt I 176/3 190/14 19316 I 13714 13974 139/13 I 66/22 67/12 68/7
195/15 197/4 197/8 I 158/13 167/5 172/15 I 68/25 69/10 69/16
127/16 129/13 137/14) ears [10] 3/22 4/4 I 180/7 182/24 183/10 I 71/10 72/15 72/16
138/4 140/2 143/1
22/12 26/23 39/15 184/16 186/9 195/8 I 72/17 74/18 76/8
143/14 143/20 152/2 I 58193 99/16 113/5
195/20 201/10 77/23 80/21 82/16
om teen tee 161/14 161/17 you [686] 84/5 84/18 88/17 89/3)
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4198/5 201/7 02/5, I 0/14 6/15 9/19 11/23 I 1432 17/13 96/11 96/24 101/18
202/5 202/6 12/2 16/8 17/14 17/23I you're [43] 10/4 103/5 106/18 110/12
25/10 31/10 31/14 13/23 14/24 33/16 110/18 110/21 112/4
wouldn't [9] 5/22 I 34/5 35/6 35/16 39/22I 39/19
52/16 63/25 I 114/16 119/25 121/2
13/16 23/18 34/13 I agia7 44/17 41/18
70/24 72/4 84/14 ‘I 121/9 122/18 124/7
seae at I 42/25 44/1 45/13 I @a/23 88/25 89/1 96r2I 125/2 125/2 125/16
wane [2181/1 46/15 46/17 46/19 I 96/5 99/13 101/2 I 126/4 126/6 126/6
wraps 47/4 47/6 47/7 4718 I 10719 109/18 114/14 I 128/8 131/14 132/8
ving [t) 47/1 47119 49/9 49/21 I 130/12 133/19 138/1 I 138/3 138/10 138/14
writing (y 50/18 52/21 53/5 I 4138/3 143/4 143/11 I 139/1 139/2 139/3
written [4] 55/18 56/9 56/14 I 145/9 147/2 150/10 I 139/15 140/2 141/8
14112 Ween 59/17 59/22 61/8 62/6] 151/24 171/24 176/18) 143/2 147/7 148/6
eng ei 100/20 62/10 62/10 62/19 185/22 185/23 186/10] 148/15 149/9 149/24
63/15 66/10 66/14 I 186/11 188/1 199/8 I 152/14 153/14 154/18
120/11 120/12 120/14)
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69/20 69/21 72/19 I 201/19 203/1 164/7 164/15 164/18
tear eee 72/23 75/5 75/18 Iyou've [60] 3/18 4/2 I 166/3 167/10 168/1
201/21 81/20 82/23 83/15 I'5/2 10/7 16/4 22/12 I 168/20 169/20 170/9
85/17 88/21 89/21 22/13 32/22 34/19 171/14 175/8 176/2
wrongful [9] 27/14
27/18 27/24 28/3 28/9 coreg cues 00/92 37/1 47/8 57/17 59/7 I 176/10 178/6 179/4
64/10 65/11 66/5 I 179/15 179/25 181/18
ate 28/16 28/20 I 494/20 102/20 104/3 I 66/11 67/9 77/2 80/21I 182/2 183/18 184/21
104/10 104/21 105/7 I 85/3 94/22 95/25 96/2) 185/5 185/14 185/25
wrongly [1] 18/15 I 498/18 108/20 108/24] 96/7 103/5 109/9 190/7 193/17 194/21
wae Dsl 86/18 68/6 I sq9/21 109/23 110/3 I 113/23 113/25 119/11] 195/14 196/6 197/9
110/5 111/10 111/22 I 120/25 121/1 121/5 I 198/23 199/9 199/15
vey el one 111/25 113/6 113/8 I 122/18 123/21 126/19I 201/24 203/1
tay Mess ti7ig I 113/8 113/10 113/17 I 130/20 131/3 133/16 Iyourself [3] 27/21
Ta100 Ione iaitg I 11319 114/15 114/20] 136/20 13872 139/15 I 188/4 191/5
Tao gate tone. I 114/22 114/25 11672 I 145/20 149/23 152/10
116/2 116/19 120/15 I 156/8 160/8 164/18
(86) worth - zoom