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The Post Office Horizon IT Inquiry 5 November 2024
Tuesday, 5 November 2024 Northern Ireland and I think the CPS, but it did not
(10.00 am) cover the Department for Work and Pensions and RMGs who
‘SIMON DOMINIC RECALDIN (continued)
Questioned by MR BLAKE (continued)
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3 were also prosecutors. So if they ~ if cases came
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MR BLAKE: Good moming, sir. 5
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forward ~ cases from them could come forward through
the courts and therefore that number could expand
SIR WYN WILLIAMS: Morning. further because of that.
MR BLAKE: Mr Recaldin, I think you did a bit of homework
overnight. Are you able to assist us with the product
of that research? 9
But also, the Chair asked whether cautions were
included in the OC process, so we are in ongoing
discussions with Government about the non-postmaster PNC
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I hope to help the Inquiry, yes. So Sir Wyn queried 10 cohort, eg assistants and managers, and have sought
whether it is correct to say that 111 claimants is the "1 clarification on whether all cautions would fall into
closed number for the OC process and, quite rightly, 12 the definition of PNC — prosecuted not convictions ~
Sir Wyn pointed out that the PNC population would now 13 such that would be eligible for OC and therefore covered
expand that - potentially expand that number. 14 by the Government funding. We recognise that the PNC
But I've got a bit more colour on that. So 111 is 15 category is covered by Government funding.
the number of claimants in the OC process who have had 16 This is and always has been the working assumption
their convictions overturned by the courts, we knew 7 based on conversations with Government officials to date
that. As such, based on the current picture in the 18 but, currently, no formal agreement has been reached on
criminal courts, it's considered closed. However, the 19 that basis.
OC process also includes PNCs -- 20 @. So there is discussion currently ongoing --
That's prosecuted but not convicted? 21 A. Yeah.
-- prosecuted but not convicted -- and other appeals 22 @. ~about whether cautions are considered prosecuted but
that are excluded from the legislation. So I've been 23 not convicted?
reminded that the course that the legislation went 24 A. Yeah, within that cohort. Correct.
through, it covered England, Wales, Scotland and 25 Q. Are any of those cautions being dealt with or being
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referred to other schemes, as far as you're aware? 1 to a separate topic.
I think there is — this is my recollection. I think 2 So sticking with overtumed convictions. The stage
there has been one case that has gone through the HSS 3 we reached, we went through the non-pecuniary, the
scheme and the caution has been recognised and 4 pecuniary, we're now at the independent assessment panel
redressed 5 stage. If agreement can't be reached between the
Has that matter concluded, as far as you're aware? 6 parties, there is an independent panel. It's
Yes, as far as I'm aware it has, yes. There was also 7 a three-person panel that's chaired by Sir Gary
a question -- if I can go on? 8 Hickinbottom, is that correct?
Yes. 9 A. Correct.
There was also a question both numbers of pecuniary and 10 Q. I think Sir Gary was nominated by Hudgells Solicitors
non-pecuniary settlements in the OC space and I can "1 and the Post Office jointly; is that correct?
confirm there are ~ as of 31 October, there are 81 12 A. Proposed by Hudgells Solicitors and appointed
non-pecuniary claims that have been settled and 61 13 accordingly, yeah.
pecuniary claims have been settled, and, as advised 14 Q. Thank you. That hasn't yet considered any appeals?
yesterday, there have been 61 full and final 15 A. No.
settlements. So put another way, there are 61 full and 16 Q. We spoke yesterday about Lord Dyson and three cases that
final settlements; in addition to that, there are 17 the Post Office wanted to be referred to Lord Dyson and
a further 20 non-pecuniary claims settled. 18 that hadn't been agreed between the parties. Can you
Thank you. Were there any other matters arising from 19 assist us with why those cases haven't, in fact, gone to
yesterday that you wanted to clarify? 20 the independent assessment panel stage?
I think that was my homework, Thank you. 21 A. Because Lord Dyson is non-pecuniary and Sir Gary is
Thank you. We left off yesterday on the overturned 22 pecuniary.
convictions process. I have a few more questions on 23 Q. So the independent assessment panel only deals with
that. We will then go through very quickly the other 24 pecuniary cases?
schemes just to cover those off, and then we'll move on 25 A. Correct.
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Thank you. In terms of legal costs, I think you've said
in your witness statement that only one of the 111
claimants is not legally represented —
Yes.
-- and reasonable legal costs are paid when a claimant
seeks the full assessment of their claim?
Yes.
In respect of the Government offer that we spoke about
yesterday, there is effectively a fixed fee: it's
£20,000 of legal costs or I think, if they pre-dated the
announcement of the £600,006, it is reasonable costs
plus costs incurred prior to that date, is it?
Correct.
Thank you. Tax issues. On 16 March 2023, the Post
Office Horizon and Infected Blood Compensation Payment
Scheme regulations came into force, which effectively
solved the tax issues for those living in the United
Kingdom; is that correct?
Yes.
You've said in your witness statement that there are two
applicants living outside of the United Kingdom. Have
those matters been resolved or where are they at?
I don't know whether they've been resolved but I know
we're working with Government to find a solution for
those.
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that might be correct but, if it was inconsistent, then
the risk is we would have to reopen up the HSS in order
to correct that.
Why is it that the inclusion of somebody like Lord
Arbuthnot could build in those risks?
I -- forgive me, I don't know why Lord Arbuthnot's name
isin there. I don't know the context of why that's.
there.
Can you recall any specific concerns you had as at
February 2023 regarding the scheme?
About the GLO scheme?
Well, if we see there, the subject is "OHC
Remediation -- Engagement with Parliament”. Does that
assist you at all with knowing what your concer was?
I think, from recollection, this was a meeting that
I was being invited to with interested MPs and
postmaster campaigners, including Lord Arbuthnot and
others. And the debate was whether I should be invited
or not be invited, et cetera, and it was a critical time
at the Inquiry as well. I think the next compensation
hearing was imminent and this was about the - what were
the risks around me attending that meeting prior to
coming here for the redress hearings. And that's
what ~ and that's why Lord Arbuthnot might have crept
into that paragraph.
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Q. Thank you. We can then move on to the Group Litigation
Order scheme, the GLO scheme, not run by the Post
Office. Could we please turn to BEIS0000641. Thank
you.
If we could start on page 4, please. This is
an email chain from 20 February 2023. It's an email
from you, we see your name there, and it's the
highlighted passage that Id just like to ask you about.
You say
“There is also a more delicate issue of ensuring the
GLO is consistent with the HSS...”
That's something you spoke about yesterday, trying
to ensure consistency between the schemes:
*... and the risks associated if it is not - the
inclusion of {I think that’s Lord Arbuthnot] etc could
be building in risks to consistencies. I will be guided
if to raise such an issue and if so how. Whatever the
case we should mention that there is a risk of having to
reopen cases and the Inquiry oversight if the GLO does
not generate similar outcomes to Post Office.”
Can you assist us with what you were saying there
and what you meant by that?
Hopefully that's quite clear. It's a risk. That's what
Ido: I articulate risks. And the risk was that if the
GLO scheme was inconsistent with the HSS scheme -- and
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Thank you. One more email on the Group Litigation Order
scheme. It's BEISO000656. This is a note of a meeting
with Minister Hollinrake on 25 May 2023
Yeah.
So on a few months from the last email that we saw. If
we scroll down the page we can see there that you
attended a meeting. There's a GLO update over the page,
please, page 2. That says:
“[Minister Hollinrake] said he'd seen that Alan
Bates had been critical of the slow pace of the [GLO]
scheme and pointed towards disclosure as the issue.
“SR [I think that's you] said the issue is not the
slowness of disclosure at present ([the Post Office] has
committed to 32 weeks as an end-to-end process). The
issue is that they are waiting for cases to come in, as
the process of disclosure can only properly start once
cases are received. SR [I think you] said in the
meantime, his team are collecting the base data that
they know they will need. SR said his team are working
at risk as [the Post Office] hasn't received payment for
the work yet."
Just pausing there, that was a phrase we spoke about
yesterday.
A. Mm.
25 Q So, as at May 2023, had the Government not committed
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funding to the Post Office's work on the GLO scheme?
So this is -- as I said yesterday and in my statement,
this is a regular occurrence, and I want to be clear to
the Inquiry on this. You know, Government commit to the
funding verbally and in emails, et cetera, et cetera,
and, clearly, that commitment is well meaning and, of
course, Government will pay but, from a legal entity
perspective, that has to be crystallised by
formalisation. And therefore, working at risk is we
know we're going to be paid, we know its all going to
be sorted out, but the formal documentation has yet to
be in place.
Now, optically, I can't cross my arms and say,
“Well, until that formal documentation is in place I'm
not going to do anything", because that will be slowing
down redress, wouldn't it? So I can't do that and
I won't do that. But I have to explain that to the
Board to say — and get permission from the Board, to
say, "Look, 'm making a commitment here that we're
working a risk here, on the assumption that the
Government will pay us". And, of course, they will pay
us but it's getting those formalities and, indeed, legal
advisers more comfortable with that. But I want to be
clear: working at risk is not slowing down redress.
"CC [I think Mr Creswell] said {the Post Office]
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the Select Committee in February when I found it very,
very interesting and, hopefully, Post Office has helped
in that the challenges that the GLO scheme were very
similar to the challenges of the OC and HSS schemes, in
terms of getting cases in, and then lessons can be
leamt from that, in terms of the numbers that have come
in weren't as expected, at the pace expected.
Let's move on, then, to the Horizon Compensation Review
Scheme. Do you have anything to say on that: any
updates as far as you're aware? We'll be hearing from
Mr Creswell and others in due course but is there
anything you're aware of that you think is of note for
the Inquiry?
Apart from the fact that it’s an absolutely excellent
initiative, in terms of clearing this mess up, in terms
of the initiative and the impact it's made. It's been
absolutely fantastic.
I'd like to move on to a slightly different topic to
compensation and that is the Past Roles Review. Can we
please turn to POL00448307. This is the document of
30 October 2023, and it lists you as the Chair of the
Past Roles Review panel; is that correct? Were you
chair or are you chair of that panel?
lam indeed.
Please can we turn to POL00458391. When were you first
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received the contract in January; the delay has been on
due to going back and forth on specifics. But he
understand [the Post Office] is currently operating at
risk.”
Sorry, there’s the acceptance from Government, they
accept that we're working at risk and they sort of say,
“Don't worry, the money's on its way".
Thank you.
*[Minister Hollinrake] said he feels we need to be
getting on the front foot here comms-wise. If the issue
is that cases aren't coming through, then we should say
this. SR [you] said he would take this on board, as how
Alan Bates described the situation is slightly
misleading."
Can you assist us with what you meant there?
Well, I think it's the first bullet isn't it, where
Mr Bates had been critical of the slow pace of the
scheme and pointed towards disclosure as the issue.
Disclosure was not the issue because we weren't being
asked for disclosure.
Thank you. Finally on this scheme, what is your current
view of the progress of the scheme, as at today's date?
Of the GLO?
Yes.
I don't operate it. AllI can say is what I heard at
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appointed chair, approximately?
It would have been about the time but that is a draft
and some of those names are not on that committee but it
would have been around that time, yeah.
Thank you. So around October 2023.
Yeah, yeah.
This is an email chain from December 2023. If we scroll
down, please, we can see a number of different names on
this email chain. We see, for example, towards the
bottom there, on the left-hand side, Caroline Richards.
Mm-hm.
She's someone who the Inquiry has heard visited
a postmaster with Stephen Bradshaw, the Investigator.
If we scroll down, please, we see at the bottom of
the second page the name Melanie Corfield -- these are
all in alphabetical order, I think. Thank you very
much. Melanie Corfield was a member of the
Communications Team. She was involved in liaising with
press regarding issues relating to Paula Vennells,
Panorama. The Inquiry has seen an email from her
describing the remote access issue as "totally loony”
If we scroll over the page, please, we see, about
halfway down, Rodric Williams well known to the Inquiry,
a witness in the Inquiry: he received the Clarke Advice;
Project Zebra; he was involved in notifying the insurers
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about issues relating to Gareth Jenkins; he was involved
in briefing Paula Vennells on issues relating to bugs,
errors and defects.
We saw yesterday that email from Mark Underwood
regarding fees and criteria to be imposed in the
compensation schemes and he was a recipient of that
email.
If we scroll down, please, we see on the bottom of
page 7, it's an email from you, and it's relating to the
Remediation Unit. You say:
"Yesterday marked a significant milestone in the
[Remediation Unit's] journey ~ providing compensation
to postmasters and postmistresses all across our
remediation programmes.”
You say:
"Yesterday we issued the last HSS offer from the
original cohort. This is a significant milestone and
one [to be] recognised.”
You say a bit further down:
“It also calls for me to recognise all of you for
a job superbly executed ..."
Now, at that time, those names that I've just read
out, were they involved in matters relating to the
Remediation Unit?
‘A. So testing my dates, yeah. So to -- Mel Corfield in
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Remediation Unit?
Yes.
Did you see it as a high priority to address?
Yes.
If we could please turn to POLO0448864. This is a Group
Executive meeting from 13 March 2024. So we're moving
‘on a few months. It's page 3 that I'd like to look at.
If we scroll down, please, to the section on "Past
pPop
Roles". I think you attended this meeting and spoke to
the issue of Past Roles; is that correct?
A. Correct.
Q_ So “SR"is you; "NM" is Ms Marriott:
[Simon Recaldin and Nicola Marriott] spoke to the
paper which set out a recommendation on the approach to
be taken in relation to the Past Roles Review and
staffing at the [Remediation Uni] in the light of the
change in operational context and political
environment.”
We know that by then there had been the ITV drama.
Was that the operational context and political
environment, or was it something else?
A. Itwas absolutely the TV drama but, also, it was clear
that the Advisory Board were very uncomfortable.
Q. Thank you
“As a reminder, the Past Roles Review had been
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particular doesn't work in the Remediation Unit; she's
works in comms. So that distribution list would have
been an all RU and related because, again, Mel doesn't
work for RU. So that would have been a mailing list
that would have been used for anybody sort of involved
or helped in RU. And at the time, I certainly know that
Rod Williams wasn't in the business, and I know
certainly Caroline Richards now is not in the business.
But they would have been on that circulation list.
At the time, I don't know where ~- certainly Rod
would have been out; Caroline, I don't know whether she
was still in the business or not at the time. I think
she would have been in the business at that time still.
But Mel is communication; she's not within RU
Around that time, though, late 2023, did you have
concems regarding people working in the Remediation
Unit who had those kinds of past roles and past
involvements in matters that the Inquiry is
investigating?
Yes.
We see at the beginning of that chain — sorry, if we go
to the first page, we can see that it's forwarded to
Nick Read and Lorna Gratton. Were you aware at that
time of any concerns that Nick Read, for example, had
about those kinds of individuals working within the
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commissioned to look at the roles and activities of
current employees who may have previously undertaken
a role related to the subject of [the Inquiry], to
examine whether any conflicts, or perception of
conflict, arose.”
How long had that been going on by then? I mean,
this is March 2024.
So the issue about Past Roles first came to my attention
and the Inquiry had a role to play in that — I'm
grateful to the Inquiry for that - in an individual
called Brian Trotter came and gave evidence to the
Inquiry, and I think that was March 2023. So that's
when the issue first came to my attention.
I was concemed about that background and that Past
Roles risk that that raised, and I escalated that
straight to the Chief Executive, who then mandated the
then Chief People Officer to conduct whatever needed to
be conducted in terms of the review of the issue and the
risk and how we were going to mitigate that risk.
We're now here a year after that concem arose. Do you
think it was acting quickly enough?
Absolutely not.
What do you feel was the hold-up?
Inactivity. This is a very delicate area and the first
thing was to do the review -- and I was very much.
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involved in that review, I actually chaired the forum --
and to identify the individuals who might be of concern
in terms of — not the activity. Again, to be clear,
there’s no allegations here at all, that's separate.
This is nothing to do with Phoenix. This is —
there are no allegations against these people. There is
no wrongdoing, and we've got to make that really, really
clear. There is no evidence of any wrongdoing of these
individuals.
And therefore, the first thing we had to do is -- so
if these people were around at the time of interest for
the Inquiry, what roles were they performing? So we
then, we started that exercise by looking at roles. So
what roles at the time would the Inquiry be interested
in? And we came up with a list of Investigators,
Contract Managers, et cetera, et cetera, that we knew
the Inquiry was interested in and where there could be
potential conflict. So we said, right, here are the
roles and are any of those people -- did they occupy
those roles at the time?
Why does it take an Inquiry to realise that people who
worked as Investigators, for example, might be people
that you don't want in the team that's deciding
compensation and redress?
I think that's an excellent question, and one that
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business that that conflict check would have happened at
the time that team was being built, but it clearly
hadn't been,
Who built up that team, do you know?
I think it was my predecessor.
Who was that.
I can't remember the gentleman's name now.
If we look at the bottom two bullet points, we have
description about the red category:
“Colleagues were rated 'RED', however, if they were
identified as giving rise to a perceived risk in terms
of undermining the integrity and independence of
remediation and redress work being done and in those
cases, redeployment had been recommended.
"Since the review had been undertaken, there had
been a significant increase in late applications and
[the Remediation Unit] work driven by current external
scrutiny and the heightened awareness that was
generating, organisational design delays had meant
an increase in colleagues who were deemed as 'RED' and
there no clarity yet on the Government's role in
relation to redress going forward and associate
processes and procedures.
[Simon Recaldin and Nicola Marriott] noted the
implications arising from a reduction in headcount and
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certainly wasn't addressed at the time. So when that
team was built, I don't think that was taken formally
into consideration. Now, in my work ~ after Brian.
Trotter's evidence, in my work that I did, I did look
for conflicts policies, and there were conflicts
policies, and they were mainly about you can't work for
two employers at the same time. That sort of conflict
policies.
But I did discover there were conflict policies
agreed between team members that, if there was a case
that they had previously been involved in or previously
knew any information about, they then would pass it to
somebody else who didn't have any background knowledge
of those. I was concerned about the lack of formality
around that conflict policy and I escalated that as.
well
So my regret is -- and it is a genuine regret - is
that when I came in, in January 2022, that I didn't do
that conflicts check -- check back on my inherited
team ~ and challenge that. And that I absolutely
apologise for because I think that's something that
should have been done.
As I said yesterday, that team was sort of
leaderless for about eight months, whilst I was being
recruited, and I think there was an assumption by the
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the risks posed to redress claim processing times.”
So you were concerned at this point about — you had
two problems: one was people were live to the issue of
those working in past roles in the Remediation Unit, but
you also have an increased amount of work for the
Remediation Unit to deal with; is that a fair summary?
Yeah, and I think, if - to help the Inquiry, the
background here, which I think in Karen's evidence as
well was that these people were originally recruited in
this space because of their knowledge: their system
knowledge. And I talked yesterday about the SFA,
shortfall analysis, and their technical expertise and
‘experience required to do that in a professional and
appropriate way.
So they were there for good reasons and because of
their skill base, But as I did explain yesterday, as
well, we knew the volumes were dropping off and we also
had this issue where, through this process that we did
in identifying roles, I think the numbers have been well
articulated, there were 27 individuals who were around
at the time who were occupying what we deemed as “red”
roles who were still in the business. And, therefore,
a proposal was that you could potentially redeploy those
individuals to mitigate that risk, that perceived risk.
Again, to be clear, you know, we've got unemployment
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law and all of the rest of it. Now, a counter to that
would be, well, don't forget at the same time we're now
getting increasing volumes in because of the Bates Post
Office drama and, therefore, what we can't afford to do
is slow down redress. So if we redeploy those people,
is there a risk we'll slow down redress?
The decision as at March 2024, as shown here, was that,
there would be what's referred to as a "many-to-few"
approach, which is effectively getting rid of those
individuals, is it?
Or redeploying, yeah, redeploying those individuals.
But many-to-few is you would actually backfill, so you
would recruit people and these individuals would help
train the new individuals, and then move off. So you
would effectively ring-fence them.
Okay. Moving on to April 2024, can we please look at
POL00448649. We then have a Board meeting. It's a note
of a Board meeting that we've seen before, so I'l take
it pretty quickly but, if we go to the second page, it
sets out there, if we scroll down slightly, the three
categories: one is employees due to give evidence; the
second is the Past Roles people; and the third is those
who are in the Project Phoenix category.
If we go over the page there's discussion, page 3,
about halfway down. Were you involved in Phoenix at
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Did you have any concems about that?
Apologies, can you remind me of the date of this Board
meeting
This one is April
207
It's 29 April 2024.
I think I had concerns about the pace of the activity
and I was extremely aware of the optics and the concem
that I was receiving from the Advisory Board
Was there anything you were able to do about that?
I was part of the working party. I was engaged in
working this ~- the solution. So, and as previously
advised, I was actually chairing the forum that,
determined whether a role was red or not, and therefore
we went through, you know, religiously and in very fine
detail about the individuals that were occupying those
roles at the time, and therefore what category they were
to be determined.
It's a very, very sensitive area because you are
also ~ you're on the edge of employment legislation and
all sorts of things. It's a very, very delicate thing
and, you know, these people have done nothing wrong.
There were suggestions, especially from the
Subpostmaster Non-Executive Directors, that a suspend
first policy should have been approached. What's your
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all?
No. Well, if I can clarify that: I think as the
evidence of Mr Read said, during restorative justice
meetings, that myself and other Post Office Executives
attended, if there was any allegation of wrongdoing by
an individual member of staff current or indeed past,
then we would log that and that will be referred to
Project Phoenix. That's my only involvement
It says there, slightly further down, at the top:
"The Chair asked NM [Ms Marriott] to provide
an overview of category two [the Past Roles category].
[She] spoke through the category outlining the work that
had been undertaken to assess from conflicts arising
from roles associated with the activity covered by the
Inquiry in current roles and detailed the employee
population that this work had identified. NM noted
proposed restructuring however this had not been
actioned due to the need to retain the workforce given
the high number of new applications to HSS..."
So this is a month later, after the many-to-few
approach had been determined. Am I right to understand
from this that, in fact, that slowed down, to some
extent, because of the new applications to the Historic
Shortfall Scheme?
I think you can.
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view on that?
I'm aware of that approach. And, look, this was treated
as seriously as it should be, and these were Board
decisions.
Would you support a "suspend first” approach or not; did
you support a suspend first approach or not?
These were Board decisions and the Board made those
decisions. I personally would not support -- you know,
whilst investigations were going on, a suspension no,
I personally wouldn't. That would have not been one of
my recommendations for the paper.
Thank you. If we scroll over, we can see:
"NM detailed the proposed approaches in relation to
the different employee populations within category 2
noting the benefits and risk involved. For the 23 ‘red’
employees it was proposed that a preferencing exercise
was run to understand the appetite for voluntary
redundancy or redeployment. If neither of these options
were taken a forced change in employment would be
affected or as a last resort the employee would be
dismissed.”
It all seems to be dragging on a little bit at this
stage, doesn't it?
lagree.
25 @. Who do you say is responsible for that?
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I think the Grant Thornton report actually articulated
it better than I could possibly do. Is -- there is some
serious challenges in Post Office around decision making
and making very, very tough decisions and, therefore,
not wanting to make decisions, and therefore potentially
elongating processes. And, for lack of better words --
and this is not appropriate wording — but kicking
things into the long grass for a decision later, for
a decision later.
And think that, combined with some pretty serious
cultural issues in this space, I think it was a cauldron
of indecisiveness about of what to do, including, you
know, proper legal advice about employment law,
et cetera, et cetera, of what can be done on optics.
These conflicts -- this is optical because there is no
evidence here that -- these people are not involved in
decision making, they're just involved in the process
and, therefore, it is - I keep on saying it's
a sensitive area and it is, so there's a delegate path
here to travel
In the meantime, the political environment and what
{call the Man on the Clapham Omnibus, the public
opinion, optically, the message is clear.
can take you to an email chain specifically on the
topic of Brian Trotter, who is somebody you have already
25
his purely administrative role and do you recognise
that, even in that role, there is a problem if somebody
like that is employed in the Remediation Unit?
It doesn't matter what role he was employed in as
a Contract Manager. It's a problem, it should never
have happened. It's outrageous that that was allowed to
happen. It's a blatant conflict of interest. It should
have never happened.
Can you assist us with what kind of a role within your
unit he was performing?
I am reliably advised it was a purely admin role, there
wasn't any influencing in terms of what he was doing but
what I would add -- not that you've asked me, but what
I would add, and I've been very clear to the entire
Executive of Post Office, and I think, you know, it's
a reflection on probably the cultural environment that
we're dealing with here, is that sentence there, "BT
exited (by me) mid-2023", that was one of the most
difficult things I've had to do in Post Office, in terms
of working the system in order to exit Mr Trotter when
his fixed-term contract simply expired at mid-2023.
Itwas one of the most difficult things I had to go
through in terms of engagement with the right people and
the appropriate action to be taken.
25 @Q. You spoke about the Grant Thornton report and the
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mentioned. If we look at BEISO000851 and start on
page 2, please. On the bottom of page 2, you can see
an email from Mr Brightwell from the Department for
Business and Trade to yourself. He says:
"This from Richard Moorhead:
“An SPM approached me worried that two staff
involved in Horizon matters pre-Bates are, have been, or
may be involved in redress. Brian Trotter and Mervyn
Jones.
“Helpful to know where these stand, please.”
If we scroll up, you say:
[Brian Trotter] exited (by me) mid-2023 -- he gave
evidence at the Inquiry late 2022. Previously he had
been a Contract Manager -- hence why he was called as
a witness -- but after leaving Post Office he came back
as a contractor in [the Remediation Unit] but not in
a role with any influence/decision making -- purely
admin."
As you said, Mr Trotter was a witness in the
Inquiry, he was an Area Manager, he was a Contracts
Manager. We saw him involved in, for example, an email
chain in the context of Callendar Square; emails from
‘Anne Chambers of Fujitsu; he was involved in the
suspension of subpostmasters; he was, I think,
criticised by Mr Justice Fraser. What do you say was
26
indecisiveness. Did you experience any of that in
relation to Mr Trotter?
In spades.
Where was that coming from?
A lot of it by — an example was fortuitously, or by
accident, I actually met his line manager, who was
required to deliver the message because -- as line
manager, and she was clearly very, very uncomfortable
with being able to do it and advised me that it might
have implications on other people, and nobody has done
anything wrong, et cetera, et cetera, and therefore ~
it was clear from her body language and everything that
she was very, very uncomfortable with it.
And I said, "Look, you're uncomfortable, I don't
want to put you in a position where you're going to be
too uncomfortable, that's fine, and do you want to take
the opportunity for somebody else delivering the
message?" And she took that opportunity. So
escalated that up and somebody else had to deliver it.
But the whole process of getting Mr Trotter into that
position, appropriate position, was torturous.
In light of the time and in light of your evidence.
I won't take you to it, I have that whole series of
correspondence that you will have seen in your bundle
around this time: there's the letter to Professor
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Hodges; that BEIS0000843; there is an email chain
involving Professor Moorhead, Lord Arbuthnot, that's
BEIS0000846, that's July 2024; there's also BEISO000848;
an email from Professor Moorhead to Chris Hodges and
others, that’s BEIS0000849, that's August 2024
You'll have seen those chains in your bundle. Do
you think that you personally had a sufficient grasp of
the risks involved, irrespective of whether those
individuals were working in your unit, were involved in
specific allegations of wrongdoing, do you think that
you understood and were doing enough about the potential
risks that were posed by them working within the unit?
I absolutely understood the risks and the potential
risks. And, as a number of Board members will confirm,
in terms of making my views clear about what could be
done, what we should do about it, I've been very, very
clear.
Final topic from me today is Project Alder and I want to
deal with this very briefly. Could we please bring up
on to screen POL00448907. This is a report that we've
seen before from John Bartlett. It outlines various
investigations that were ongoing within the business.
If we could please turn to page 12 and onwards, it makes
clear that outside agencies have been involved in these
investigations and, therefore, we don't need to deal
29
[postmasters}, to the detriment of some [postmasters].”
Can you assist us with what the current position is
in relation to Project Alder? Any findings, if you
could just summarise those for us, that would be very
helpful.
Of course I can. The two ~ the two most significant
allegations — well, as advised there -- were that —
it's interesting in there the word "deliberate" is not
in there but the allegations were -- well, the word
“deliberate” is in the allegation -- is that RU senior
members of staff deliberately delayed redress in
a non-Horizon -- by the way, a non-Horizon compensation
scheme, suspension remuneration: they deliberately
delayed redress
And the second allegation was, actually ~ I think.
it was a named individual deliberately dragged their
feet in order to get their contract renewed. Those are
the two most significant allegations in there.
And I'm — you asked me yesterday about whether
I had enough time to deal with all the things I had to
do and whether I had an appropriate resource. It says
in that report I was interviewed four times. I was
interviewed for over 11.5 hours by DLA on this issue.
So you ask me what ~- to summarise what the outcome
was, which I'l get to straightaway. Those two serious
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with them in depth. But just to outline, Project Alder,
there are two slides there. It says:
“The principal allegation is that the senior
contractors in the [Remediation Unit] caused the
handling of compensation claims to go slow in order to
extend their well-paid tenure at [Post Office].”
"DLA Piper was engaged to conduct an independent
investigation.”
If we scroll over, there's an outline of the current
situation:
“A large number of interviews have been conducted
[including with you}.
"No evidence to date [about a gravy train.”
It does say here that:
"There is considerable evidence gathered so far
which shows that some delays could have been avoided and
that a contributing factor was the dysfunctional
relationship within [the Remediation Unit] between the
[Post Office] staff and contractors. There are two or
three key interviews remaining but this looks like
an established position
"There is also evidence of a failure of leadership
at several levels in the [Remediation Unit] and that
decisions made within the [Remediation Unit] were very
focused on value for money rather than best outcome for
30
allegations -- and you cannot make this up, Mr Blake --
those two serious allegations were actually withdrawn
during the investigation by the individual who made the
allegations. In addition, the report concluded that
there were no findings about whether redress - it said
that redress was not delayed at all and the individual
named did not deliberately drag their feet in order to
have their contract.
So there were no findings at all but those
allegations were actually withdrawn and the report in
the management summary, paragraph 3.2, makes it
absolutely crystal clear that the reason why the report
was commissioned in the first place was because of these
allegations, and the author recognised that the
withdrawal of those allegations made the report
superfluous
As you say -- as you can see, I'm quite passionate
about this because this was a direct poor reflection on
my team, which was totally inappropriate and uncalled
for,
I don't know if you've heard the evidence in the Inquiry
when we heard from the Subpostmaster Non-Executive
Directors. There was a suggestion of
an over-investigations culture within the Post Office.
Is that something that you agree with, that you share,
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or what are your views on that?
Mr Blake, I share with a passion.
Who do you hold responsible for that?
I've been here before with you, Mr Blake: it's
a cultural thing. I truly believe it's a cultural
thing. And it's interesting the new Senior Management
Team in have already mentioned it to me about a culture
of raising, you know - and absolutely within the rules
-- you know, raising grievances and raising
a whistleblowing on a number of issues because it's
there. And it is, you know, it's — we're in a very
sensitive environment. I mean, Post Office is shot to
pieces, okay. It absolutely ~ and, therefore,
everybody is extremely sensitive. Nobody wants to make
a decision, okay, and every decision, they worry about
> p>
the consequences of making a decision.
And it's been in this environment, quite
understandably, because of the bad place that Post
Office has been in. And by the way, you know, it's all
true,
So it's such a bad place but there's a culture, it's
absolutely -- you know, that I experienced, and I have
to caveat that, is that only the bit that I experienced,
that I have seen culture within Post Office elsewhere,
you know, in the retail business, in many ~ in
33
unfair, to say that culture is across Post Office
because it's not. You know, Post Office keep over
11,500 branches open every single day. It's amazing
what they do and how they do it. Cash centres,
distribution networks, motivating postmasters,
remuneration schemes. You know, I genuinely don't know
how. It's a very sophisticated business and it's
amazing how they do it and, you know, the culture in
there is absolutely appropriate.
I'm only talking about the culture that I have
experienced in the last three years.
MR BLAKE: Thank you. Mr Recaldin, I don't have any further
questions.
There are questions from Core Participants.
Sir, do you have any questions before we —-
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Yes, just one or two. I want to be clear
about that last long answer, Mr Recaldin, which included
the phrase "Post Office is shot to pieces". All right?
At one level, that could be taken as a description
of the whole of the organisation and, if that is
accurate, obviously, it is extremely concerning. But
you seem to have qualified i, in effect, to that part
of the Post Office with which you are most concemed,
which I take to be activities around the Remediation
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Procurement, et cetera, and many other areas,
‘Communications, where the culture is clearly not like
this. The area that I work in, the culture is very,
very challenging and, to answer your question, is there
is this environment.
You know, I feel very strongly about this. I have
worked for 35 years ~ 38 years now I've worked, and for
the best part of 35 years I've worked for NatWest Royal
Bank of Scotland, going through a number of different
management levels. And for 25 years of those, I've
managed people either from one team up to over 1,000.
During those 25 years of managing people, I've never
ever had a grievance against me. I've never had
an investigation about me about anything.
And this is very personal, Mr Blake, and I hope you
don't mind me sharing it, and I feel very strongly about
this. And in those 25 years, never an investigation,
never a grievance, nothing. In fact, 'm happy to
share, you know, 360 feedback on a consistent basis,
done annually has been outstanding.
I've worked for three years in Post Office and I've
been investigated five times, Mr Blake. You've asked me
“Who do you blame?" I don't blame an individual and
I don't blame anybody. I point to the culture that.
Hace. And I think it's really unfair, really, really
34
Unit.
So could you actually, as clearly as possible, try
to define whether you are making a general criticism of
the Post Office as an organisation or whether you are
making a specific criticism about a specific part of it?
I think -- thank you, Sir Wyn, for the opportunity for
clarification,
As I've said, I have caveated it and, in terms of —
there are -- yeah, almost the entire Post Office I do
not experience and therefore I cannot comment on the
culture in the other areas. I am restricting it to me:
But I look at the challenges — putting my leadership
hat on of Post Office, I look at the challenges around
governance and the issues that have been raised by the
Inquiry in terms of the Board and dysfunctional
behaviour at that level as well. And so when I say
“shot", I mean a number of issues during my tenure at
Post Office have been raised that, you know, in terms of
challenges of professionalism, of how you run
a business.
And so I think it’s a good challenge back, and thank
you for the opportunity of clarification, Sir Wyn, in
Ihave to say it's my challenge -- I don't see it as.
a criticism -- my cultural challenge is very much in the
space that I occupy, and that I am -- you know, I am
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frustrated by a number of aspects of it in terms of all
I want to do, all I want to do, is pay redress as much
as I possibly can to postmasters.
SIR WYN WILLIAMS: But are you telling me -- and I'm sorry
to put you on the spot -- in terms that the culture
related to the persons who are leading and determining
compensation in the Remediation Unit is such that it is
having a really serious, damaging effect on the ability
to pay compensation fully, fairly and promptly?
A. Sir Wyn, I'm not going to go that far because, if it —
if I was facing that situation, Sir Wyn, I would not be
here. I would not tolerate that; I would not be here.
But is it one of my many challenges? Yes.
SIR WYN WILLIAMS: So if I modified it to say that the
culture, as you describe it, is a significant
contributing factor to some of the difficulties which
have occurring in paying compensation fully, fairly and
promptly, would you agree with that?
A. I don't think it has impacted on fully, fairly and as
timely as possible. I don't think it has impacted on
that. But it is another issue to be dealt with, and has
impacted, in terms of my time, other people's time, in
dealing with those challenges. So for example, dealing
with the past roles issue, has been extremely time
consuming
37
A. Ofcourse you can, Sir Wyn.
SIR WYN WILLIAMS: Mr Salter.
‘A. Declan Salter. Thank you very much
SIR WYN WILLIAMS: Right. As I understand it, there was
a gap of about eight months between —
A. That's right.
SIR WYN WILLIAMS: -- Mr Salter departing and you arriving?
A. Yes, Sir Wyn.
SIR WYN WILLIAMS: All right. Those are my questions. Over
to the Core Participants.
MR BLAKE: Thank you very much. I think i's going to be
Mr Jacobs first.
Questioned by MR JACOBS
MR JACOBS: Thank you, sir.
Mr Recaldin, good morning. I want to ask you about
restorative justice.
A. Oh, right.
Q._ You deal with restorative justice meetings at
paragraph 35 of your sixth witness statement. These are
meetings where postmasters meet -- meet you and Mr Read
and other senior executives -- and relay their
experiences and concerns in relation to of the scandal;
that's right, isn't it?
A. itis.
@._ You may or may not know but Howe+Co, who instruct me,
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SIR WYN WILLIAMS: Right. So it's a constant challenge --
A
it's a constant challenge?
It's a con~ and, therefore, taking my bandwidth,
Sir Wyn, does that mean I'm not making decisions on
redress? Potentially. Do I feel that has delayed
redress or curtailed redress? No, I don't because
I just work harder.
SIR WYN WILLIAMS: Right. On Past Roles, just so I'm clear,
have you now completed any work you needed to do in
relation to Past Roles?
Yes, and a plan is now in place around those 27
individuals and that plan is in the course of being
executed as we speak, Sir Wyn.
SIR WYN WILLIAMS: Right. Well, that, in effect, is
A.
confirmation, I think, of what Ms McEwan told me ~
Correct.
‘SIR WYN WILLIAMS: -- that this was very close to the end of
A.
the process.
Correct.
‘SIR WYN WILLIAMS: So that's where we are, yes?
A.
Yes.
SIR WYN WILLIAMS: Right. Then, finally, just trying to
prop
pinpoint who your predecessor may have been, can
I mention a name and you tell me if I've got the right
person.
38
raised this issue with the Inquiry on 13 October 2022,
and since 22 June 2023, there have been 20 days of
restorative justice meetings that you have held.
I think you have been to every single meeting, haven't
you?
Ihave.
57 of our clients, along with at least one supporting
family member attended those meetings and over 114
individuals and victims have met you and other
directors; is that right?
That's right.
Here today are Maureen McKelvey, who sits next to me,
Heather Earley, and behind me Fiona Elliott and
Katherine McAlemey. They are three rows behind me,
there wasn't enough room on the row for them. They were
present at the first meeting with you in Belfast in June
2023; is that right?
Yes.
They're still awaiting for their compensation claims to
conclude and I know that you're going to meet them next
month, aren't you, to discuss —
Yes.
~ their —
I was hoping to meet them today.
You were indeed. Other matters have intervened.
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So very generally ~- I don't want to discuss their
individual cases, obviously you're going to be meeting
with them to talk about these cases -- where these
meetings take place and you or Post Office directors
give assurances that everything is being done to deal
with things very quickly in terms of compensation,
perhaps assurances are given that matters will be looked
at within months, what can you do to make good on those
assurances now, now that we're in 2024, coming into
2025, if claims are still ongoing?
What can I do? And I am grateful because the four
lovely ladies that you referred to, they do approach me
directly. You know, "We've had this meeting with you,
you know, can you help me with where is my case?" And
I'm very comfortable, by the way, with those sort of
approaches.
Again, we can't talk about individual cases.
Of course.
But they are split across -- to Mr Blake's point
yesterday, they are split across the Post Office and the
Government schemes. And in terms of if the case is in
the Government space, I am limited in terms of what
can do about that, but I will escalate within the
Government in terms of using my contacts within the
Government to say I've had a concerning email and
41
you to understand the wide-reaching and long-lasting
effects of the scandal on each person and their
families. What messages have you felt that it is
important to pass on from these meetings?
Where do you want me to start?
Well, what are the main take-home points? For example,
Ms McKelvey was acquitted in 2007 and there was no
inquiry, no publication of her trial, and other cases
where the Post Office secured convictions, they were
crowing from the rooftops. That sort of thing —
Yeah.
~- these stark issues.
So to be clear, Nick and I mandated ourselves ~
especially coming back from Belfast. It made a huge
impression. And we mandated ourselves that people
needed to ~ you know, people in Post Office needed to
hear these stories and that's exactly what we did. And
we started from the top. We started at Board meetings.
I can remember when we came back from restorative
justice, we mandated ourselves to communicate down,
cascade down, these horrific stories, okay?
And "stories" ~ you use the word "stories", if it
is made up. This isn't made up; this is real life. And
they're absolutely horrific. And my apologies again for
the experiences that you have -- you ladies have been
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approach about the speed, or whatever it is, can you
help? And I understand that they do proactively reach
out to people to say, "This is where your case and we
have this SLA of working within X days, et cetera,
et cetera”
In terms of the cases that are in my schemes ~ and
it's interesting I call them my schemes, isn't it ~ is
escalate within my teams to say "So why are we waiting
so long on this? What's going on on that case? Why
haven't we received the medical report on that?" So
I will escalate accordingly.
So your question is what can I do? I'm conscious
that I'm talking too fast, sorry. What I can do is
can escalate and intervene to try and help.
Okay. Thank you. The feedback from our clients who
have attended these meetings have been generally very
positive. People say, "I'm glad” -- I'm reading a quote
from a client now:
"They listened to our experiences and I felt they
were appalled by our stories. Nick and Simon were very
engaged with the impact the Post Office had on our lives,
I'm assuming that's Nick Read, who sits behind me as
well
You say in your statement that these meetings help
42
through.
it's unforgivable. And Nick and I made ourselves to
ensure that those messages got through. Indeed, as
a result of that, there is a sort of training programme,
a governance training programme that is now in place,
that actually tells some of these stories in — I think
they take snippets from the Panorama programme and
snippets from the Inquiry when people were giving their
witness statements, in terms of cascading those messages
back how serious this actually was.
And, you know, this is a bit of a wake-up call.
This is the place we've come from and we must ensure
this never ever happens again.
This is not -- of course, it's about the shortfall.
Of course, it's about the Horizon system. But you know
what this is really about? This is about the journey
that Post Office took people through, and that's the
issue. Of course, it's the IT issue. Of course, it's
the technology thing and the alleged potential cover-up
et cetera, et cetera.
But it actually is the way that Post Office spoke to
people and dealt with these issues. It's absolutely
disgraceful.
You talk about cascading back and, in your witness
statement, you say at paragraph 38 that, following the
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meetings, you ensure each of the victims’ experiences is,
shared with the Executive Team
Yes.
Which members of the Executive Team in particular do you
share this with; how does that work?
So I usually post a restorative justice meeting. It's
usually a SEG meeting, which was GE and now it's SEG,
and I have the opportunity to download, more often with
the senior executive who was with me at the time, so we
do a bit of a joint approach. So it will be the
Executive Team.
Part of our clients’ concerns are that there has been
a churn in the Executive Team, people move on, and these
experiences need to be shared throughout the whole
company; do you agree?
I agree.
Do you accept that the culture at the Post Office is
still very much a work in progress?
Yes.
You've heard the evidence of Mr Ismail and Mr Jacobs in
that regard?
Yes.
So what proposals do you have to ensure that the
experiences of people like my clients, who are with me
today, are communicated throughout the whole of the Post
45
they're embroiled and embedded in the understanding of
Post Office, and to ensure it never happens again.
I want to ask you about wider restorative justice and
this was something that was raised in correspondence
back in 2022 with the Inquiry. The proposals that those
instructing me have put forward are for a number of
measures that go beyond simple payments of compensation
It's not an exhaustive list but I'm just going to tell
you what they are and ask you questions about them
So the first proposal is for ongoing psychiatric and
counselling support for subpostmasters and their
families.
Mm-hm.
Second is bursaries to assist with the retraining of
postmasters and for the education of their children
whose education was disrupted by the scandal. Then
a tangible memorial scheme to mark this as the largest
miscarriage of justice in British legal history, that
sympathetically records the experiences of the
subpostmasters and how profoundly they and their
communities were affected.
Then steps to restore reputations within local
communities, engagement with the local press.
What steps have Post Office taken to bring these
sort of schemes about?
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Office, not just the executives who may move on in
a couple of years?
Yeah, and there are executives who have attended these
who have not moved on or who are not moving on, so there
are some there already who will not - Karen is a great
example, Karen has done couple of restorative justice
meetings and she is very proactive in communicating the
message down. And part of the -- part of one of our
many workstreams is to understand and help build a —-
whatever a legacy means, ie something permanent that
ensures that these stories are never ever forgotten
about.
Will these stories be dealt with within the strategic
review that the Post Office is conducting?
Not necessarily. It's yet to be determined about how
they are. I'll give you an example of, at a higher
level, in terms of in the Post Office Head Office at
Wood Street there is a timeline of where Post Office
came from, all the way from wagon and horses, et cetera,
all the way thorough. And in there, if you visit it,
there is a recognition of the Horizon scandal. So it's
formally on the timeline. It's formally embedded in
history.
Now it
important that these journeys that many
postmasters experienced, these awful journeys, that
46
So a number of those opportunities have already been
taken. So in a restorative justice meeting, we do offer
how can we ~is there anything we can do to help you?
Now, we also recognise, you know, money is not going
to fix this. These ladies know that: money ain't going
to fix this. So it is what else can you do? And it's
about ~- there's a journey here. And if those
restorative justice meetings mean they can move one
millimetre towards a better place on that journey, then
that’s a success.
And many what appear innocuous requests, actually we
can do it, and we have done: articles in local press
about complete exoneration because of the stigma in the
particular area. Done those sort of things. Offering
references, simple things like that.
One lady I met wanted to have the exoneration signed
by Nick Read that her conviction had been overturned
because she wanted to put it in her toilet next to the
conviction that she'd had.
These are -- but to your point, sorry, to your
point, all those other things you've mentioned are all
being considered in terms of so what legacy are we going
to leave here to reflect this?
The point I'm making is that this isn't really something
for individuals to ask for. There will be many people
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who are affected by the scandal who feel too traumatised
to even meet with Post Office. Is there a plan for
a wider restorative justice scheme, for example to
include straight-up compensation for the family members
who might not form part of the existing schemes; is
there any provision that's being planned for a wider
scheme, statement of principles, as to what Post Office
will do rather than just individual offers?
A. So there is a working party that is pulling together
proposed ideas of what legacy we should leave and
bursary, extra, in terms of the legacy, something to be
referred to, something to be used in the future. You
specifically talked about friends and immediate
relatives. We have had an approach from a group
representing the children of victims, and we are meeting
them shortly, to listen to their story.
Now, they've already met, I understand they've
already met with Fujitsu and their request is not
necessarily to talk about compensation, they just want
to tell the story and, absolutely, we should listen to
their story.
Q. What about Fujitsu? Paul Patterson has been recalled to
give evidence on 11 November. Has he contacted you or
has anyone in Fujitsu contacted you about restorative
justice proposals?
49
MR JACOBS: Thank you. I've got one question to ask you,
a very good point that Mr Stein has asked me to raise.
This Inquiry is going to finish at the end of this
year, isn't it?
A. Yes.
Q. The hearings. How can there be any clarity and
oversight by the Inquiry in relation to restorative
justice if the Post Office won't commit to a programme
between now and the end of this year?
A. Well, I can absolutely give you assurance it is an issue
that is live, and that is being discussed as we speak in
terms of what -- I had a meeting about it literally last
week. So I can give you that commitment that this issue
is not going away, this opportunity is not going away.
I mean, I am sure Sir Wyn will make his own mind up
around how that's incorporated into the Inquiry.
But you have my assurance that this is absolutely
a work in progress. I don't know what more I can give
there. Apologies.
Q._ Will you commit to providing a report in relation to
proposals and progress before the final report of this
Inquiry, so that this is something that will be
considered and subpostmasters will know what the
proposals are and it will be part of the Inquiry
process?
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A. Not tome, no. Not me personally.
Q. We'll hear what he says about this next week but my
question for you is: do you think it would be
appropriate for Post Office to speak to them about these
issues, to speak to Fujitsu?
A. I think all options should be explored.
Q. When do you think these restorative justice proposals
that you've outlined will be implemented?
A. If they're implemented -- and, you know, the thorny
issue of funding, as ever, will have to come up,
outrageous as it does seem to be — then it will
certainly -- I would suggest, you know, it would have to
be in the next year, they would have to establish
something. I don't know is the answer but I'm trying
not to put a timescale on it but it's recognised that
something that should be done
MR JACOBS: I need to ask if I have any further questions to
ask.
MR STEIN: Sir, just give me one moment to speak to my
junior.
SIR WYN WILLIAMS: Hang on, I can't quite hear.
MR STEIN: Sir, that was my interruption. I just need to
speak for one moment to Mr Jacobs about one matter of
further questioning for Mr Recaldin
SIR WYN WILLIAMS: Yes. (Pause)
50
A. I think that's absolutely reasonable.
Q_ So you will commit to do that?
A. Iwill commit to a proposal of what we should do in —
absolutely, yes.
MR JACOBS: I have no further questions. Thank you. I'm
grateful
MRBLAKE: Thank you. Sir, if we could take our morning
break now, and then we have questions from two further
Core Participants, I believe
SIR WYN WILLIAMS: Fine. So what time shall we resume?
MRBLAKE: 11.307
SIR WYN WILLIAMS: 11.30? Thank you.
MR BLAKE: Yes, thank you.
(11.15 am)
(A short break)
(11.30 am)
MRBLAKE: Thank you, sir. We're going to hear from Ms Page
and then Mr Moloney.
SIR WYN WILLIAMS: Yes.
Questioned by MS PAGE
MS PAGE: Mr Recaldin, do you take responsibility for the
mess that the Post Office compensation schemes are in?
A. [feel very accountable for the state that the
compensation schemes are in. I make myself accountable
for them.
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Should you have resigned by now?
That's a good question. I think there is a very, very
strong argument that maybe I should have done.
Do you think your mistake was to accept the job, even
though you knew that the Post Office should not be
running the compensation schemes itself?
No, absolutely not.
Is that why they're not working, though?
I wouldn't say they're not working. Nobody has said to
me they're not working.
You tell us, no doubt sincerely, that the schemes you
run are not bureaucratic, that they are sympathetic.
You say you don't recognise the idea that they were set
up to deter applicants through tough eligibility
criteria, evidential requirements, and yet our clients
tell us the opposite and the fact is nowhere near enough
of their claims have been resolved after all this time.
Do you not accept that the problem is the very one that
you identified in your interview: too many of the people
administering the scheme are not independent?
No, I don't accept that. I don't accept that too many
people are not independent enough. I think ~ no,
don't accept that.
In one of the emails, and I'll just give the reference
rather than bring it up, BEISO000849, that's the email
53
Yes.
--ie roles which were of not interest to the Inquiry.
But, nevertheless, they grew up in a Post Office which
encouraged them to think of postmasters, subpostmasters,
as the enemy, and that's why your unit has a culture
which gives claimants a hard time, no?
I don't agree with that statement.
They are asked to provide documents from many years ago,
sometimes documents which the Post Office would have
sent to them in the first place, or surely should have
kept on file; they are asked to provide further and
further update medical records, as we've already heard
about Ms Skinner's case, but she’s not alone in this.
This is the sort of conduct where postmasters are made
to prove every point. Do you not recognise that?
No.
You've told this Inquiry that you are or were outraged
that Brian Trotter was still in the unit but you have
described how hard it was to get rid of him and how,
even at the end of his fixed-term contract, his line
manager, ie a member of your unit, would not deal with
it, felt that it would impact badly on others, felt that
he'd done nothing wrong. That shows the rot in your
unit, doesn't it, Mr Recaldin?
I think I've been clear with the Inquiry in the last
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chain with Professor Moorhead from the Horizon
‘Compensation Board, and in it you tell him that 73
people -
That's right.
~ who worked for the Post Office over the 20-year
period that the Inquiry is looking at, 73 of those
people were found to be working in the Remediation Unit.
Now, those are people who worked in the Post Office
when it maintained a fortress mentality towards
subpostmasters. So whatever they say to you and
whatever they say to themselves, they are effectively
the old guard, aren't they?
I don't know what “old guard” means. I recognise the
number -- I think that note was to Chris Hodges, the
Chair of the Advisory Board and that number is a number
of how many people were working in Post Office at the
time who were currently in RU at the time -- were in RU.
Yes.
That's not where they used to occupy roles that the
Inquiry — is of interest to the Inquiry. That's
a completely different number. That number is the 27
number that has been articulated here. So I was asking
the specific question that the Advisory Board were
asking me about how many were working at the time, and
many of these were counter clerks —
54
session about the culture that I face. And forgive me,
I've never used the term “get rid". That's
disrespectful. I've never used that term.
No, but the term is not the point; it's the people
around --
Itis the point because it’s about respect. It's about
the respect of individuals.
It's the people around Mr Trotter not just Mr Trotter
himself that's the issue. Everyone in the unit affects
the people around them. And you've described how his
line manager was unable to see the point, was unable to
see why he should be exited. I think that's the term
you like. She couldn't see the point, could she? "He's
done nothing wrong", she said.
I didn't say that, I said -- and hopefully the script
will help me -- I think I said she was clearly
uncomfortable with delivering the message, and I asked
her “Are you uncomfortable in doing this?" And she
said, "Yes". I said, "Would you like somebody else to
deliver it?" And she said, "Yes, I would”. So I took
her up on that option.
Here's an example of how having these people in your
unit can play out. Mr Shiju, one of our clients,
applied to the HSS, and Caroline Richards attended
a good faith meeting in his case ~ Caroline Richards,
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who Mr Blake pointed out to you had been
an Investigator. She attended that good faith meeting
to explain the frankly risible £2,000-odd offer that was
being made to Mr Shiju. Following that meeting, she was
the main point of contact for Mr Shiju and Mr Marshall,
his lawyer, and it then transpired that she had been
an Investigator, which had never been disclosed
Mr Marshall wrote to the Post Office asking about
her role and there was no reply from April 2024, all the
way through until September 2024, when Post Office
explained who she was, and that she had worked as
"Dispute Manager" from May 2022 to April 2024, so in
other words nearly two years.
Now, is it a coincidence that she was removed from
being the Disputes Manager in the same month that
Mr Marshall wrote about it or is it another case, like
Mr Trotter, of somebody only being exited once they had
been caught?
I don't know whether that's a coincidence or not.
I can't talk about individual cases, and apologies for
that. What I do know is that Caroline Richards is no
longer working in the Remediation Unit.
Why did it take so long to admit what had been going on?
I'm not quite sure what "going on" is.
Well, two years of her working as Disputes Manager and
87
These people are wonderful people.
In the circumstances of significant delays, interim
payments are crucial, aren't they, because it's what
makes the difference for people who are sometimes very
desperate, between being able to carry on to get full
and fair compensation and giving up, isn't it -
Yes.
-- that interim payment can be that difference?
Yes.
Yet you told us yesterday that the Department had
prevailed upon you not to offer interim payments and
countermanded interims that had been authorised?
I did.
You also told us that in the HSS scheme, if an offer is
made but not accepted, people will receive the offer as
an interim payment if they ask. Why make them ask,
Mr Recaldin?
don't think I said that. If I do, I apologise.
I think I said that, if they dispute their offer — if
we make an offer and they say, "No, we dispute it",
we --in that letter, we offer them 100 per cent interim
payments.
Why not just send them the money?
They have to accept it. So we have to -- they have to
sign something to say, "We accept that interim payment”.
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then many months before that was confirmed, why did it
take so long to admit that she was in that role when she
plainly shouldn't have been?
I don't think there's any -- so these individuals are
not -- they're not decision makers around that. They
are in roles which do not require decisions so --
She attended a good faith meeting
Yes, she did.
Do you not see the problem?
Good faith meetings are not decision making meetings.
I recognise the optic, of course I do. I recognise the
optic of that —
Is it about the optic or is it about the reality that
she should not have been in that role?
‘And the fact that that individual has been moved out is
a recognition of that. And I am aware of the case. It
is - look, it's really difficult to talk about
individual cases but I'm - you know, absolutely from my
understanding of the case and in terms of the
individual, I apologise that that risk has become
apparent and I believe that Post Office have dealt with
that risk.
These claimants are not difficult people, are they,
Mr Recaldin. They want to settle and move on but your
schemes are failing to deliver, aren't they?
58
So it's just an administration thing but the offer of,
that payment is in that dispute letter.
Well, then there's HSF.
Yes.
You've been told directly by our clients, Ms Felstead
and Ms Skinner, that HSF press every advantage on behalf
of their client, the Post Office, just as they did when
settling the GLO. Alan Watts, lead partner for Post
Office compensation, also responsible for negotiating
the 2019 GLO settlement. Catherine Emanuel, the
recipient of a highly contentious email from Rodric
Wiliams, has conduct of much of the compensation
arrangements. It was an obvious problem, it was
an obvious problem from the start, and yet there's HSF,
one of the most expensive firms in the country, stil
there, no doubt getting paid faster than the SPMs. Why?
Sorry, the question is why are HSF still there?
Why are they still there?
Because they are still instructed by Post Office on
certain cases. As you know, they operate the back
office, the working environment, the operational engine
of the HSS and they still advise Post Office on the OC
claims.
Much, much more of that OC process is — over the
time of my tenure, is now with Post Office. But there
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is the independent panel, and that's the key thing about
the OC, is that Sir Gary is there now to provide that
independence for anything. And it is -- and Mr Blake
mentioned it earlier, that Sir Gary's services in terms
of opining on those cases has yet to be utilised.
I would encourage, absolutely encourage, for the usage
of Sir Gary.
Q. There's another structural problem, I would suggest,
with the HSS scheme. You've told us that it's built on
the principle that redress can only be paid to the
person or legal entity that the Post Office contracts
with.
A. Mm
Q._ That might have worked perfectly well as a principle,
were it not for the history, because, as we've leamed,
at no stage over the 20-year period that we're looking
at did the Post Office make sure that every branch had
a clear and well-understood contract in place. Have you
taken that on board: are there any processes to ensure
that both the Post Office and the applicant agree that
the claim is actually based on the correct contract?
A. don't know how to answer that question. I go back to
the scheme, in terms of the scheme is there to deal with
any entity who has a contract with Post Office or had or
has a contract with Post Office.
61
problem?
A. Ido. I absolutely do see the problem and, in terms of
the — you know we're in engagement on the — I can't
talk about individual cases. I really apologise.
Q._ The principle is the point
A. lunderstand that and, in that first case, I do not ~
I recognise the second case, I do not recognise that
first case but you mentioned partnership there. If
you'd like to give me further details outside this, I'm
more than happy to look at that but I don't recognise
it
Q. Well, we can certainly give you details ~
SIR WYN WILLIAMS: Can I just interrupt a moment because
I don't want to be too bogged down in the individual
case, but I am interested in the process, Mr Recaldin,
that should follow when, for example, an applicant is
rejected on the basis, shall we say, that they were not
the contracting party. Now, if that is disputed, what
should be the next step and how quickly should it
happen?
A. So the ~ if - for an eligibility issue, it sounds as
though this is an eligibility issue —
SIR WYN WILLIAMS: Yes.
A. --then they can absolutely have the right to challenge
that rejection of eligibility and that would come into
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Well, here's the difficulty ~ and I'll give you two
examples, but they will by no means be the only people,
I'm sure, in this situation - applicants who didn't
necessarily have the contract are being rejected, even
though it's clear that there is no eligible person left
to claim.
So, first of all, Ill talk about Mr Colin Savage.
He worked in partnership with his father at a branch.
When his father became unwell he was treated as if he
was the postmaster. Importantly, he was reported to the
Procurator Fiscal as if he was the postmaster. He was
interviewed about the shortfalls, criminally, as if he
was the postmaster. His father has passed away, the
partnership no longer exists and his claim has been
rejected: Post Office say he has no contractual
relationship.
This is essentially the same problem faced by Gowri
Jayakanthan — who I'm sure you've already heard about,
the tragic case of the husband who took his life after
the Post Office goons came for him ~- and her claim was
rejected on the basis that the company who he operated
through has been dissolved. These are people who are
the obvious only person who could claim because there is
no other person or legal entity in existence that could
claim and yet they are being rejected; do you see the
62
my governance and then we would say -- well, we would
look at it to say, well, is there any more information
we need to clear up this eligibility challenge?
SIR WYN WILLIAMS: Right.
A.
I think in my evidence when I talked to Mr Blake, he
asked me how many of those cases there were, and I think
there were a handful of those cases.
SIR WYN WILLIAMS: Sure but —
A.
There is a process
SIR WYN WILLIAMS: So the process is to go back to Post
A.
Office. What about going to someone independent, at
what stage does that happen? If there's an impasse,
both sides are acting in good faith, they simply can't
agree, all right?
Yeah.
‘SIR WYN WILLIAMS: ‘At what point does an independent panel
or person cut the knot, so to speak, and make
a decision?
Well, then we can escalate it and I think we have
escalated similar issues into the panel, into the
independent panel, to make that call.
SIR WYN WILLIAMS: Right, so in the overturned conviction
process, that will go to Sir Gary and his panel?
A. Yes, in an overturned conviction, yes, that world be
an opportunity, yes, correct
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SIR WYN WILLIAMS: In HSS, it would go through the various
stages which ultimately would lead to a mediation or
arbitration. At the moment there's no appeal process
that you can use?
‘A. No, I'm suggesting, actually, that if it's
an eligibility issue, that can go to the independent
panel, for them to opine on.
SIR WYN WILLIAMS: Okay, the same panel that decides the
compensation?
A. Yes.
SIR WYN WILLIAMS: That would be non-binding, would it not,
because they don't bind anybody, but the Post Office
always, so far, has accepted what they've said?
A. Thank you, Sir Wyn. Correct.
SIR WYN WILLIAMS: Okay, fine. So I've got the process.
A. Yes.
SIR WYN WILLIAMS: Thank you, Ms Page. I think we have to
leave it with the process, if we may.
MS PAGE: Thank you, sir.
Just then two final bones of contention, if I may.
Firstly, for many subpostmasters who were
prosecuted, they gave the Post Office the money which
was said to be the Horizon shortfall, either as
compensation or confiscation.
A. That's right,
65
Q Yes.
So if they've had a shortfall and the used their savings
>
to make good ~
Q Yes
‘A. --to balance the books, then I might have missed the
point and I apologise if I have, is that not an HSS.
claim?
Q_ Well, as I understand it, the HSS claim only works if
the shortfall shows on Horizon but, if they've been
covering the loss, as many of them did, before they
started to say, "I just can't do this any more", Horizon
won't tell you how much they've done, have they?
A. The scheme activates when the shortfall has been
settled. So we can see the cash coming in, and so, you
know, the scheme is activated by a shortfall and it's
settlement.
I see.
‘And, therefore, that would be an HSS claim.
So~
I might have misinterpreted that and I apologise if
Ihave.
Pero
Q._ No, it may well be that I'm thinking about it from the
perspective of those who have had their convictions
overtumed.
A. Yeah, okay, understood.
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Q. Those who have had their convictions overtumed
obviously should receive that back with compound
interest, agreed?
A. Mm-hm,
Q. Why hasn't that been carried out proactively? Mr Kalia,
who sits at the end of the bench here, had his
conviction overturned in 2021. He borrowed £22,000 from
his late mother and he still hasn't had that money back.
Why hasn't this been done proactively; why does it wait
for the claimant to ask?
A. don't know, and I understand that others have been
done proactively. So it’s a good shout. Thank you.
Til look at that because I don't know why because
others, I know, have been.
Q. Well, thank you. No doubt Mr Kalia will look forward to
that and, no doubt, others too.
Then finally this, and this is a tricky one
I acknowledge, but many subpostmasters have described
how they spent weeks, months, sometimes even years
covering shortfalls from their own money before running
out or running out of people they could borrow from, and
obviously those figures won't show in Horizon. What
effort has been made to try to think about how to
compensate people for that?
‘A. Compensate them for the monies they've put into —-
66
Q._Under those circumstances, does that mean that they
should apply to the HSS?
A. No,no. They should get that redress. They should get
it through the OC process.
Q._Is that something that you can take forward because,
again, we have clients who have not had that sort to.
‘compensation repaid?
‘A. Well, I need to know about that then because, if that is
the case, they should have been and I apologise if they
haven't been. But that's the process. The process is
wrapped up in that. So I'd be very interested in
hearing about those cases, please.
SIR WYN WILLIAMS: But in relation to that, Mr Recaldin, it
surely is inherent in the fact that they were convicted,
that there was, at the time, alleged to be a loss ~
A. Correct.
SIR WYN WILLIAMS: — which has now been shown to be wrong
and so the figure simply needs to be accepted, does it
not?
A. Correct, correct,
MS PAGE: I'm looking at two slightly different losses, sir.
I apologise if 'm not making myself clear but there's
obviously the loss which showed, and they were --
SIR WYN WILLIAMS: I see —
MS PAGE: - prosecuted —
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SIR WYN WILLIAMS: But on other occasions when they put
money in —
MS PAGE: Yes.
SIR WYN WILLIAMS:
that's what you're talking about, is it?
MS PAGE: Exactly, so previous to whatever shortfall they
were prosecuted over. So that's the bit that I was
asking about but I think we're all clear now and you're
saying that they should be recompensed for that?
A. Okay.
MS PAGE: Thank you.
SIR WYN WILLIAMS: Yes, fine. Thank you, Ms Page.
Mr Moloney?
Questioned by MR MOLONEY
MR MOLONEY: Thank you, sir.
Mr Recaldin, I'd just like to ask you some questions
about aspects of the working of the schemes. The first
matter I'd like to ask you about is the £600,000 offer
in the OC context, if I can use that abbreviation, the
overtumed convictions.
The £600,000 offer is not a floor for contribution,
isit? You're not guaranteed £600,000 within the OC
process?
A. Correct.
Q Yes.
69
on to the independent panel?
A. MrMoloney, you know my views. My views were
articulated in the email which has been shared with the
Inquiry. So I do agree with you: that is a risk.
Q. Yes. Can I just give one more illustration —
Of course.
Q. ~of how, in particular, that might occur within the OC
>
process, that many of the claims involve heads of damage
associated with loss of opportunity.
A. Yes.
Q Yes. For example, a classic loss of opportunity is
a plan to take on another branch that didn't come to
fruition because all plans were interrupted by
shortfall, termination, prosecution, conviction, and so
on, yes? So there was that loss of opportunity.
Inevitably, such claims involve a degree of
estimation —
Yes.
of losses over many years, don't they?
Yes.
So there's a potential for significant difference
between the parties —
prop
Yes.
oP
-- in the estimation of those losses?
>
Yes.
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Well, sorry. You are if you accept it as full and final
settlement,
Il ask you a few more questions and then that will
elucidate essentially what I think you're able to say.
During the OC scheme, a schedule of loss is
submitted by the claimant, or can be -- and this was
always the case before the £600,000 offer - schedule of
loss is submitted, and there might be disagreement
between the claimant and Post Office about the
appropriate quantum for the different heads of loss.
As an example, and no more, it's possible that
a postmaster might submit a claim for, let's say,
£650,000, and Post Office might come back and say,
“Well, actually, we only think it's worth 550".
Once a postmaster has submitted a schedule of loss,
after the implementation of the £600,000 offer, once
a postmaster has submitted a schedule of loss, the
£600,000 offer is no longer available to them, is it?
Correct.
Yes. Would you agree that some postmasters who have
claims which are more than, but relatively close to,
£600,000, might feel pressure, in those circumstances,
to accept the offer of the £600,000 rather than risk
months of delay in negotiation, perhaps even ending with
an offer of less than £600,000 that they have to fight
70
Again, just to use an example, it might be that a claim
for £800,000, just to move it well beyond the 600, might
be assessed as worth only 450 in response.
Mm-hm.
Again, that's a classic situation where that pressure
might be felt by the postmaster to essentially resolve
the claim, rather than face stress upon stress of
pursuing negotiations around that figure and going to
the independent panel
Did you always understand that the 600,000 was not
a floor when it came in?
I think to be fair, yes. So - and, again, that email
which the Inquiry has kindly circulated in the bundle,
I think, you know, that was me clarifying that because,
if it is a minimum payment, then I've got 60 cases here
that I can quickly top up to 600,000, and they made it
clear, no, it's not. This is not a minimum payment.
And I think the Government have been quite clear on
that, in terms of the 600,000 was designed to get to
settlement,
Yes.
The — I call it the risk, I've shared the — the risk
of that is, as you have beautifully, if I might say,
articulated in those two examples, of does the
postmaster therefore feel under pressure to accept that
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because it's too much hassle to fight for your 800 —
you know what, because what happens if it does come out
as 450, I'm only going to get 450, as opposed to I could
take 600 now. So why take the risk?
Andis that pressure? You know, and I understand
that. And also the ones on the cusp, where the legal
advisers are saying, "You know what, it looks about
650/625, but you could settle for 600". Is that
pressure; is that fair?
You know, of course, don't you, Mr Recaldin, that
postmasters making applications are often, even now,
very vulnerable, aren't they?
Absolutely.
They face financial pressures, no matter the interim
payments because the interim payments are often having
to be used for debts that have been built up over many
years, as a result of what happened with the conviction.
So they are vulnerable in terms of those pressures,
aren't they?
They've been waiting too long, Mr Moloney.
Can I now move on to ask you some questions about the
HSS, the Horizon Shortfall Scheme, and, first of all,
about the relationship between — if we can describe it
as a relationship ~ as it were, legal representation,
the potential for increased determinations of
73
That's a nod, Mr Recaldin, but I believe you might be in
trouble for not saying the word "Yes"
I agree.
I've just seen that you would have been in trouble.
Thank you for saying "Yes", Mr Recaldin
It was a nod, yes.
Yes. Now, obviously, I can't speak for all claimants
but we've seen from the correspondence between Hudgells
Solicitors and you, that there have been substantially
increased offers in relation to cases where they've had
the benefit of legal advice and there's been
a redetermination of their claim. Could we please put
up HUJ00000007, please, that Mr Blakey took you to
yesterday, Mr Recaldin, and he identified four examples
of those increases.
That's right, yeah
There's one example I want to take you to in it
a moment, and thank you. If we could stay on that page
and go down towards the bottom. Just to, as it were,
examine why these figures may be so substantially
increased, it is sometimes, isn't it, because of the
identification of additional heads of loss?
There is a nod again there, Mr Recaldin. I'm sorry
but if you could put "Yes", as I believe is the
indication.
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compensation offers following a panel assessment
Yes.
Lawyers for claimants are not involved — just to
reiterate — lawyers for claimants are not involved
until after the first offer, are they?
Correct.
Yes.
Oh, sorry —
To putit another way —
~ they can be involved —
~ there is no funding available for lawyers in —
Thank you.
But, of course, looking at it realistically, most
postmasters are in the position where they can't
afford —
agree, I agree.
~ to instruct lawyers at that stage, can they?
No objections.
Post Office, you said yesterday, wanted the process to
be legally light. You accept, of course, though that
it's not so light on Post Office side, is it, because.
there are solicitors who have been instructed to, as it
were, deal with the initial application and assess it
before it goes to the panel?
(The witness nodded)
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indeed, you know that was something we alighted on
in our compensation submissions as long ago as 10 June
2022, for the Inquiry's compensation hearing in July
2022, that concer about missing heads of loss.
Ido recall that, yes.
Back in 2022, a number of small HSS claims had been
settled, and it was thought that the more complex claims
were the ones that were outstanding and would take
a long time to be dealt with. Can we just have a look
at number 4 on this page, Mr Recaldin, please. It's one
of those that Mr Blake took you to yesterday. It's just
4,500 to close to 134.
Now, would you agree, on the basis of that - and
I don't suggest this applies to all small settlements —
that it's not safe to assume that all small claims have
been properly settled?
So are you suggesting ~ sorry, can you repeat that
question again?
We see £4,000 is a relatively small claim?
Yeah.
Back in 2022, there was a degree to confidence that
a lot of the small claims had been properly settled ~
Yeah.
~ and that it was the more complex ones that were
outstanding. Would you agree, and I don't suggest this,
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applies to all the small settlements, but that is
an illustration of how it would be wrong to assume that
all of the small cases have been safely settled in the
absence of legal advice?
I think there is a case here, that looks like a small —
and I don't know whether that's an offer or
a settlement. I would need to know more context behind
this case because I think what may have happen is that
the lawyers have done their usual excellent job in
identifying additional heads of loss and additional
information to make that significant jump. So I'm not
quite sure whether you can there that into all small
offers are —
Quite.
-- unsafe.
No —
You're not going to that far?
-- I'm reversing that because I'm saying it would be
wrong to assume that they all are safe?
Correct, yes.
That, perhaps, I hope you'd agree, is an illustration of
why it would be wrong to assume why they all are safe —
Yes.
-- and we see because that is a revised offer in 2024
Now, if I can just use this as an example for another
77
been an informed decision.
Yes, yes. Are you able to help with this: it's right,
isn't it, that, so far as the IAP is concerned, the
independent appeals process, are you aware there's been
no consultation with postmaster legal representatives on
the proposed structure of it?
I'm pretty sure there hasn't been. It's very much
a Government initiative at the moment, so no doubt
I will suggest that might be coming. But I am not aware
of any engagement so far.
Thank you. Can I just deal very briefly with one issue
of evidential uncertainty?
Yes.
You said yesterday that you believed that evidential
uncertainty is always resolved in favour of the
postmaster. I don't suggest that evidential uncertainty
leads to, as it were, the complete dismissal of a claim
under a particular head of loss but it can reduce the
level of payment if there isn't sufficient, as it were,
documentary proof, can't it?
You are referring to potential discounts ~
Yeah.
-- to the amount being claimed because of the
evidential ~- the evidence that has been reduced?
That's it
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potential concern, is that that 4,500, going to 134,
would not be saved by the 75,000 offer, would it? So we
have a situation where we have small offers and then,
while the 75,000 will cover that, but that wouldn't save
that, would it?
No.
No. Just to slightly explain that in slightly more
detail, a person who had received £4,000, a postmaster
in financial difficulties, might consider £75,000 to be
an offer that could not be refused. It's a very
generous offer, it might be thought but, once that offer
was accepted, there would be no potential for appeal of
that, would there?
That's correct. So, again, this is the motivation
behind settlement.
Yes.
So they were keen to get settlement, so people can move
on in their lives and, therefore — but in that example,
absolutely, if there's -- if the 75,000 were offered on
your line 4, and they accepted it, they would be walking
away from their appeal rights.
Yes, and accordingly, given the process, they
essentially might be in the position where they'd lost
out on £58,000 by not being able to pursue that appeal?
Correct. But I would have hoped that that would have
78
I sort of - and I guess I would, wouldn't I,
Mr Moloney ~ but I might see it in a slightly different
way, if I can just share that?
Of course.
Itis a different optic on it to say ~ let's use
an example that the claim is for £100,000 but because
there's ~ and it does say this in the letters,
I appreciate it says this, but because of the evidential
uncertainty we're going to discount by 25 per cent and,
therefore, our offer is 75,000, that's an example that
you might be using.
Precisely. AllI wanted to just clear up,
Mr Recaldin -- and I'm not suggesting that anything that
you said yesterday was wrong ~ but there may be, as it
were, a reduction in the payment for the evidential
uncertainty —
Yes.
~ it wouldn't be a dismissal of the head —
Correct.
~ simply a reduction?
Correct. And I think there is another opportunity
here — but I would say this, wouldn't I -- is that,
actually, the evidence that's been adduced on those is
not enough -- is not enough -- is actually zero. So the
claim is for 100,000 but, on the evidence that has been
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adduced is zero. But because of the overall claim, the
overall story and the overall approach, actually, we
after going to pay 75,000 of that.
It's a different optic, I understand that, but it
is --it reflects on the evidential standards. So
because the panel understand that the bar is very, very
low, so it doesn't have to get much to get to a full
claim. So if there's virtually nothing then, actually,
well, we are going to go ~ in that example, we are
going to go to 75,000 anyway, despite the fact that
there's very, very little evidence.
I do appreciate, however, that when the letter comes
out, it does look like you claimed 100,000 and, because
of the evidence, we are discounting you by 25 per cent.
{do appreciate that.
If the Chair will forgive me, just moving from
a question in relation to the HSS back to the OC scheme,
just to try and help in terms of the clarification of
a question Ms Page just asked, shortfalls which are not
related to the shortfall that led to conviction are
routinely claimed in the OC scheme?
Yes.
Often, as Ms Page said, then there is no documentation
to support those shortfalls but a similar process
applies in relation to consideration of those shortfalls
81
more information to consider.
So to put it back into the same forum would seem
logical and seem the right thing to do, to maintain the
independence and to maintain the consistency and the
fair overview.
However, as I articulated to Mr Hudgell the other
day in my response to his — to this letter you've just
showed ~ is I think, you know, Post Office should be
more flexible about that now and -- not as a result of
delays but all the schemes maturing in a way, that that
could be now a choice of the legal representative and
the client around whether or not they want that to go to
panel or whether they prefer to have a mediation or
a face-to-face.
Because going back to panel does significantly increase
legal costs, doesn't it?
Which are paid.
Of course.
Yes.
But in terms of getting the money out there quickly, as
it were —
Yes, yes. I'm more concerned about the delay --
-- to get people into a room, without there being
additional legal costs, without there being the costs of
the panel, it may actually save money —
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within the OC process, as we've just examined within the
HSS?
That's my understanding.
Can I ask you about delay in HSS, and one particular
aspect of it, which is raised in the correspondence —
Of course you can.
~ which is about there being significant delay with
HSS, which you've acknowledged that there are occasions
‘on which there is significant delay, and one of the
aspects of that is cases going back to panel.
Yes.
Is the decision at the moment about cases going back to
panel being taken, essentially, by Post Office, rather
than it being a joint decision between Post Office and
the claimant?
I think that's a fair challenge, Mr Moloney. I think it
has been a Post Office decision and for good reasons, in
terms of consistency of outcomes, because as I've
described, I think, yesterday, the independent panel
have that moment when they opine, they recommend and
then they take that step back and say, "Right, how
consistent is this and how fair is this?" And if
something does go back to panel it is usually supported
with new information, a different take, a different —
a witness statement, et cetera, et cetera. So there is
82
Correct.
~ just to get people in the room and hammer out
a result, rather than going back to panel?
Ihave to say I'm more concerned about the time it takes
to get into panel and get out of panel. But yes, you're
absolutely right, it would save legal costs.
Yes. Just one other aspect of HSS costs, if I may.
It's only recently that people have been able to secure
treatment costs under HSS, isn't it?
Mm, yes.
That, whilst it was decided in June, was not essentially
communicated until September of this year?
Il take — forgive me, I don't know but you are --
you're usually very fact based, Mr Moloney.
Thank you very much for that, Mr Recaldin,
There's been delay on that. Have governance issues
slowed that down, in terms of -
Yes.
Yeah?
Yes.
Is it unduly pessimistic to think that it might take
another two years for all HSS decisions to work through
at current rates?
Yes. I think itis unduly ~
You think it is?
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Yeah.
What do you think is a realistic time limit?
For all the dispute cases?
I think you've said there are 1,300/1,400 cases left.
How long do you think they're going to take?
Oh, for all of the --
All of the HSS cases.
So that depends on incoming because, if you're talking
about the current cohort, but we've got 30 coming in
every day, and with the £75,000, which is an HSS case,
with that live on the system and live in terms of
mailing, we are expecting that the overall number to
grow significantly. Now, in terms of getting all that
done —- and we, you know, we are optimistic in our
forecasts about how much of that will be the 75,000 and,
therefore, we can automate as much as we can and be
efficient around that. So it does depend on those
numbers coming in, Mr Moloney, and that is an unknown,
But, you know, I think -- I shared with the Inquiry the
projections on the provisions, and that was pretty clear
that the - we are expecting to use those provisions at
least up to March 2026.
So I can't give you ~ I'm afraid, I can't give you
a precise answer because it depends how many come in.
So that's 18 months, potentially, rather than two years?
85
under the HSS scheme, and that's because the HSS is
based on contractual relationships.
That's right.
Ms Page asked you about this.
That absence of compensation for joint losses stands
in contrast to all the other schemes, doesn't it?
Mm. I appreciate that. Correct.
Do you think that inconsistency needs to be addressed?
I think it will be discussed. I think it needs to be
discussed. I don't know whether it will be addressed.
Finally, you've mentioned culture at Post Office and
I just want to ask you one aspect about that. I'm not
going to ask you to elaborate any further but there was
a serious data breach earlier this year when the GLO
settlement deed was published online and it included the
personal details of those parties in the GLO, their
names and addresses, and so on?
It did.
Was that data breach a reflection of culture at Post
Office in any way or not?
No, absolutely not. That was a genuine -- genuine human
error. And Post Office are so sorry that it happened.
It shouldn't have happened. We put in a process of who
should have been in place that would pick that up.
Genuinely, it was an upgrade of the website and the link
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A. But many of those cases we will be dealing with will be
new cases.
Q. Ofcourse. You're getting about 30 a week in terms of
new cases?
‘A. Atthe moment, we're getting about 30 a week but that's
going to ramp up significantly.
SIR WYN WILLIAMS: Isn't the reality, Mr Recaldin, that it's
wholly dependent on how many people take £75,000
quickly? If a lot of people decide that's not enough,
then we're still - I think Mr Moloney may be
underestimating in saying two years away from finishing?
A. It~ you're right, it does depend of the take-up of the
75,000. I would say, Sir Wyn, that other efficiencies
that we're putting in place in the over 75,000 cohort
will speed that up too.
SIR WYN WILLIAMS: No, I'm sure you're trying your best,
Mr Recaldin, to be as efficient as possible but the
overwhelming feeling I get from your evidence is that
a reasonably quick resolution of all cases in HSS is
very dependent upon many people accepting £75,000.
A Yes.
SIR WYN WILLIAMS: Fine.
MR MOLONEY: Just two very short matters to finish with,
please, Mr Recaldin
You've explained that joint losses aren't available
86
to the GLO settlement agreement had broken, which was on
the website. Just the link had broken and they were
refreshing that link. To refresh the link they had to
go and get the original document to put it there, and
they picked the wrong one, ie they picked the unredacted
as opposed to the redacted. And Post Office regret that
and are very, very sorry for that.
And you know we're in discussions with legal
advisers about what we need to do about that. And it
will be very regrettable and absolute apologies for
that. It was just ~ literally it was a human error,
they picked the wrong document.
MR MOLONEY: That's all I ask, sir. Thank you.
SIR WYN WILLIAMS: That's fine. Thank you.
Further questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: There are just a few more questions from
me, 'm sorry, Mr Blake. This is to make sure that
Ihave no misunderstandings about things that are
swirling around in my head and concerning me.
Let's start with HSS. As of today, a new applicant
can opt to accept £75,000, yes?
A. Correct.
SIR WYN WILLIAMS: What would I have to do, Wyn Williams, if
I was an eligible applicant to HSS, to get the £75,000?
A. So you would either pick up your post with all the
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application form in and explanatory notes, or you would
go to the website and you would fill in the form and, if
you believe that you want to accept the 75,000 offer,
then there are ~ there is a shorter version, there is
a short form, and you only have to fill in the first
number of questions and then you don't have to fill in
anything else. You send that in and then, providing
it's proved to be an eligible case, you will get
an offer of 75,000.
SIR WYN WILLIAMS: Right.
A. You sign the offer and you will be paid within ten
working days.
SIR WYN WILLIAMS: Right. If Wyn Williams had been a bit
quicker off the mark and had submitted an application
a month before the £75,000 offer scheme came into
existence, I would have submitted different information
to the Post Office, yes?
A. You would have submitted the same information but more.
SIR WYN WILLIAMS: Yes. At the point in time when the
£75,000 offer came into being, would I, in those
circumstances, be able to say, "Right, stop, I'm very
happy to take £75,000"?
A. Yes.
SIR WYN WILLIAMS: That would be by me just writing you
a letter saying that or
89
enough: I'm entitled to much more. So I fill in that
part of the form. I don't ask for the 75,000.
A. Yes, so you ~
SIR WYN WILLIAMS: Can I change my mind?
‘A. You would complete the entire form, as opposed to just
part of the form and —
SIR WYN WILLIAMS: Yes, because I think my claim is worth
150,000.
A. Yes, and you would make it clear.
SIR WYN WILLIAMS: As time is going along, I get fed up with
ital. Can I change my mind?
A. So, yes. So if you then get fed up, and your claim is
in for 150 and is being processed, as part of the
process, anyway, you will still, even though your claim
is for 150, you will still get a letter from Post Office
saying, "We know your you're claiming for 150 but,
actually, there is still this opportunity of 75,000, do
you want to take it or not?"
SIR WYN WILLIAMS: Yes.
A. That wil still be an offer to you -- made available to
you, even if your claim is for over 75.
SIR WYN WILLIAMS: Does that offer to me remain open right
up until you actually assess my claim?
A. No, it doesn't, because —
SIR WYN WILLIAMS: Because --
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‘A. No, so if your claim with all the questions answered, if
your claim is in the process today, you will actually
get a letter to say, "We've got your claim but would you
prefer to have the £75,000?" And so you will —
SIR WYN WILLIAMS: I will say ~
A. — be approached, Sir Wyn.
SIR WYN WILLIAMS: Right. Fine. In fact, I was one of the
earlier people to make an application, and so I had
accepted £53,000, all right?
A. And you've settled, Sir Wyn?
SIR WYN WILLIAMS: Yes. So I assume I get a letter saying
“In due course, you'll get another [if my maths is
right] £18,000"?
A. You do indeed, Sir Wyn. That's exactly what happens.
SIR WYN WILLIAMS: Right, and then I could accept that.
A. (The witness nodded)
SIR WYN WILLIAMS: That would be true whether it was £53,000
that I'd accepted or £2,000? I'm entitled to the
difference?
A. Or anything in between. Indeed.
SIR WYN WILLIAMS: Yes, exactly. Right.
One further variation on that. I have filled in the
form. I'm now back in making an application post the
offer of £75,000 being announced. So I've filled in the
form and, at that point in time, I decide £75,000 isn't
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A. You have to take ~ again, it's the settlement, Sir Wyn.
So if you then — you're not going to accept the 75, and
the jeopardy you face is your claim goes into panel at
150, and it comes out at 50.
SIR WYN WILLIAMS: Then that's it?
A. That's it: you get 50.
SIR WYN WILLIAMS: In between my decision to go for 150 and
the actual offer, I can't change my mind, in reality,
can I?
A. Well, unless you ~ again, part of the process is, "Yes,
you've applied for 150 but here's your opportunity to
take 75, do you want to take it?", you say, "No,
Idon't’. Fine, your 150 will continue in the process.
SIR WYN WILLIAMS: Yes, sure but I can't say I don't want to
take £75,000 on the day I fill in the forms but, say,
six months later, because I'm frustrated with the
process, I say "Okay, I'll take the 75". That
opportunity is gone?
A. You can intercept that. Again, even though you've
submitted 150, you will get a letter saying, "Yes,
you've submitted 150 but do you want to take" -- so that
is in the process
SIR WYN WILLIAMS: Yes, but it's -
A. Ifyou reject that, you're right.
SIR WYN WILLIAMS: — at the beginning of the process.
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A. Yes.
SIR WYN WILLIAMS: So once I say, "No, no, I'm carrying on
with it", then that's it?
A. Yes, correct.
SIR WYN WILLIAMS: So in that sense it's the same as the
‘overturned convictions process, where, once you go down
the road of trying to get more than 600, you are stuck
with whatever you ultimately get?
A. To Mr Moloney's point, yes
SIR WYN WILLIAMS: Yes, the two are the same?
A. Yes.
SIR WYN WILLIAMS: Right.
A. The jeopardy is there, yes.
SIR WYN WILLIAMS: It's the same jeopardy in both schemes,
which is what I was concemed about.
A. Yes, correct.
SIR WYN WILLIAMS: Okay, thank you very much Mr Recaldin.
Is that it, Mr Blake?
MR BLAKE: tis. Yes, sir. Can we take a five-minute
break before Ms Munby comes into the room?
SIR WYN WILLIAMS: Of course I'l can do that but, first,
I'd like to thank Mr Recaldin for giving evidence over
a considerable period of time about issues which are
close to the heart of very many people. So thank you
very much, Mr Recaldin, for your written and oral
93
these people have been managed and handled is
a disgrace. And we should make sure this never ever
happens again.
SIR WYN WILLIAMS: All right, thank you very much,
Mr Recaldin.
We will now have a few minutes break. I won't
wander away, so to speak. I'll just wait here,
Mr Blake, and then, when you're ready, in about five
minutes we'll reconnect. All right?
MR BLAKE: Thank you very much, sir.
(12.28 pm)
(A short break)
(12.35 pm)
MR STEVENS: Good afternoon, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes, I can. Thank you.
MR STEVENS: We will hear from Ms Munby.
SIR WYN WILLIAMS: Yes.
SARAH ANNE MUNBY (affirmed)
Questioned by MR STEVENS
MR STEVENS: Please can you state your full name?
A. Sarah Anne Munby
Q_ Ms Munby, thank you very much for attending the Inquiry
today to give oral evidence and thank you for producing
two written statements, to which I now would like to
turn. They should be in a bundle of documents in front
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evidence to this Inquiry
THE WITNESS: Sir Wyn, can I just take the opportunity of
saying one very short statement, please?
SIR WYN WILLIAMS: Of course, yes
THE WITNESS: I'm just very, very conscious for the Inquiry
prop
o>
that my statements, that my latest statements of 6, 7
and 8 -- get that right, 6, 7 and 8 -- are hugely number
based and the questions I was asked was about trends.
I hope I've helped the Inquiry with their cogitations on
it, in terms of that. But I would like to say the same
as I basically said to the Select Committee on Friday,
and this is not contrite in any way, please, is I am.
very, very conscious that it's all about numbers. How
many -- and I've been asked questions about numbers: how
many; how long. Behind every number there's a person
and there's a person whose been taken on a journey and
that journey is not a great journey.
And I would like to take this opportunity again to
apologise to all the post masters and postmistresses who
have had to experience that journey, not just about the
event itself in terms of the shortfall but, obviously
that -- the journey that Post Office have taken
everybody through, which is not a great journey, and
it's something that we really need to learn from because
it's not a great experience and, quite frankly, the way
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of you. Could I ask you, please, to turn your first
witness statement up and do you see 23 September 2024?
Yes.
For the record, the first statement is reference number
WITN11520100. Please can I ask you to tum to page 24
of that statement. Do you see a signature?
Ido.
Is that your signature?
Itis.
Now, can I ask you please to turn to your second witness
statement, dated 2 October 2024. Again, for the record,
the URN is WITN11520200. Please can I ask you to tum
to page 35. Do you see your signature?
Ido.
Are the contents of those statements true to the best of
your knowledge and belief?
Yes, they are.
Thank you, Ms Munby. Those statements now stand as your
evidence to this Inquiry. They will be uploaded onto
the Inquiry's website shortly. I'm going to ask you
a few questions about some parts of those statements now
and I'l start with your background, please.
You joined the Department of Business, Enterprise
and Regulatory Reform in July 2019?
At that time it was the Department for Business, Energy
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and Industrial Strategy but, yes, in principle, that's
exactly right.
Sorry, predecessor department. You'd spent 15 years at
that point as a managing consultant?
That's right.
Your first role at the Department in 2019 was as
Director General?
That's right.
What was your area of responsibility as Director
General?
The job title was Director General Business Sectors and
it was primarily a business facing role, looking after
the major sectors of the economy that BEIS then had
responsibility for, including the car industry, steel,
life sciences and various others. At that time, I would
say the primary focus of that role was on working with
business on the issues related to EU exit and
particularly the possibility of a no deal exit. That
was probably the single overriding priority of the
people in that Department at the time.
To what extent, when you were a Director General, were
you involved in postal affairs?
Not very much. You'll see from various of the documents
that I was copied in and kept informed, so I knew what
was happening but, at that point, the sort of channel of,
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statement, page 12, paragraph 24. You say:
“Historically, I understand from the record, there
had been serious inadequacies in [His Majesty's
Government's] oversight of Post Office."
Pausing there, what are the serious inadequacies
you're referring to in this paragraph?
Well, I think it's, first of all, important to say that,
you know, clearly a terrible, horrific miscarriage of
justice had occurred and, regardless of what the
arrangements had or hadn't been at that time, I think it
would be reasonable to say that there ~ you know, it
almost sort of goes without saying that there must have
been some serious inadequacies in order for that to have
taken place
But, specifically, I know there'd had been a kind of
series of conversations -- to which I wasn't party,
I only know this from the later record — about the
extent to which UKGI were able to access senior
officials within the Department, and that Carl
Creswell's team had been created as a policy team within
BEIS, in order to (a) make sure, frankly, that there
was, you know, broader and deeper oversight and (b) to
make sure that that connection between the activities of
UKGI and the Department was much stronger.
‘And that team was sort of in place and functioning
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decision making and advice was primarily running through
Carl Creswell, the Director, up to Alex Chisholm, who
was the then Permanent Secretary.
When Alex Chisholm moved on and Sam Beckett became
the acting Permanent Secretary, I stepped up my
involvement to make sure that there was the right level
of senior cover but, prior to that, I think it's fair to,
say that Alex had been involved in it for some time, it
was obviously a really serious priority issue for the
Department. I was new both to the Department and the
Civil Service, and so he was taking kind of primary
carriage of that issue.
{was kept informed but I think you'll see from the
record that I wasn't an active player on the scene,
really, until that point that Alex left the Department.
You were appointed Permanent Secretary to the Department
in July 2020?
That's right.
You remained there until 6 February 2023, when you moved
to the Department for Science, Innovation and
Technology, again as Permanent Secretary?
That's right, that was the point at which BEIS, the then
Department, ceased to exist.
I want to start by looking at the Department's oversight
of Post Office. Please can we look at your second
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by the time I joined the Department.
So you go on to say, immediately after that sentence,
about the dedicated Post Office policy team which had
been created in the Department. As you say, that was
established before you joined as a Director General.
How do you say that the establishment of the Policy Team
assisted the Department with its oversight
responsibilities of Post Office?
Well, there was a distinction between the primary role
of the UKGI Shareholder Team and the Policy Team. I'd
characterise it in a couple of ways. The first is that
UKGI were focused on, I suppose, the issues as they
relate to sort of looking at the Post Office itself:
governance, quality of the Board, quality of management,
financial performance, risk management, that sort of set
of corporate governance issues.
And the Policy Team had a broader remit, which you
might say is sort of looking outward at the issues as
they related to the Post Office, including the policy
framework set by Government, the relationship between
Government, not just BEIS -- because, of course, Post
Office was providing services to many other departments
as well -- that relationship between the Post Office and
Government. They did a lot of the work on securing
financial approvals, both within the Department and more
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broadly within Government, from the Treasury.
‘And I think the second distinction I would draw, and
this is true in general, where you have UKGI and
a Policy Team in the Department or, indeed, any other
Department in Government, I draw a sort of distinction
in personnel as well. So what you've got inside UKGI
are typically people who are involved in multiple
corporate governance situations who might be sitting on
multiple boards, supported in a community that’s made up
of people who do that kind of work. The Policy Team, by
contrast, would be made up of what civil servants would
recognise as sort of fairly kind of mainstream policy
colleagues who have sort of spent most of their career
thinking about how you deal with ministers, what are the
Parliamentary considerations, all of the sort of set of
issues like that.
And so I think that's just the other thing to note:
as well as having different areas of focus, I would
characterise those two teams as having a kind of
different backgrounds and skillsets. That's not
particularly commenting on the individuals involved;
it's more of a general point about the sorts of skills
and capabilities that you would look for from UKGI, as
a Permanent Secretary, versus those that you would look
for from your departmental Policy Team.
101
adequacy and effectiveness of the framework of
governance, risk management and control.”
Is this referring to effectively the Department's
oversight of Post Office itself?
I think that's right, yes.
We see there a series of bullet points at the bottom,
the first of which says — well, no, let's look at the
head before that:
"In the context of improving existing sponsorship
and shareholder activities, we have identified the
following areas for improvement for which corresponding
recommendations have been made in the action plan in
this report:
“[1] Improving communication links between the Post
Office Policy Team ..."
Pausing there, is that the team you were just
describing in distinction from the UKGI team?
Yes, that would be the team led by Carl Creswell
*... and the BEIS Partnerships Team.”
What is the BEIS Partnerships Team?
The BEIS Partnerships Team was a team that sat at the
centre of the Department, responsible for looking not
specifically at our relationship with the Post Office
but more broadly at the structures and capabilities
across BEIS for dealing with what we referred to in BEIS.
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‘Again, how does that split, as you've described it,
assist with improving oversight of Post Office itself?
I think probably, in part, by addressing the weakness
that I was talking about earlier, ie the extent to which
UKGI colleagues, who were obviously closely involved in
events at the Post Office, were able to sort of access
ministers and senior officials within the Department.
And the second is, frankly, it's a set of people who
are focused on where are ministers on this; where are
Parliament on this; what's the broader context? And
that isn't directly about kind of specifically
governance of the Post Office, but I do think it's
really important contextual work that you would want to
have in place as part of your overall system of
oversight.
Could we please look at UKGI0001 1874, please. You see
it's a document dated 31 October 2019, "BEIS, Partner
Organisation Governance & Sponsorship: Post Office’. We
don't need to turn it up but at page 23 you are listed
in the distribution list for this document. Would you
have read this at the time it was issued?
Yes, I would assume so.
Could we turn, please, to page 3. We have an “Executive
summary" of this document. It says, "Opinion"
“Some improvements are required to enhance the
102
as partner organisations, but you would more normally
see referred to as ALBs. So, in effect, it's sort of
centre of excellence for ALB management and governance.
So what they're commenting on here is the extent to
which the Post Office Policy Team is engaging with that
departmental internal central team who were looking at
how we look at the Post Office but, also, you know,
UKRI, the Met Office, Companies House, et cetera,
et cetera. There were around 40 such organisations that
that central team would have been looking at.
Some of the companies you referred to there, or public
corporations, were also assets that were overseen by
UKGI.
Yes. Some also had UKGI involvement. Some didn't —
Some didn't?
~ among that 40 group.
It says:
"Discussions between the Policy Team and the
Partnerships Team are infrequent with no regular
engagement around performance, risks, issues or
concems. This could result in risks or opportunities
to share good practice being missed, negatively
impacting [Post Office's] operations or BEIS’ oversight
of [Post Office}."
Do you know what, if any, steps were taken to
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address this point?
don't remember specifically but, typically, I mean
this was an internal audit report, so we would have
taken a series of actions around it and then tracked
them through. I think it's perhaps useful to say that
although, you know, this is absolutely a point that was,
you know, raised by internal audit and something that,
you know, I would have wanted us to address and would
assume that we did, I wouldn't put this point on a kind
of enormously serious level because what we're
discussing here isn't, you know, for example the extent
to which the Post Office Policy Team were engaged with
the Post Office, or the extent to which they were
engaged with UKGI.
What we're really talking about here, I suspect, is
a Post Office team who were dealing with quite a unique
asset. It doesn't have that much in common with the
majority of the other ALBs that BEIS were looking after,
and has its own, like, very serious and specific issues
at this time.
So I can imagine it seems plausible that the Post
Office Policy Team weren't making it their top priority
to engage with that central Partnerships Team within the
Department and, although that would be something you
would want to improve, I wouldn't have seen that as
105
a specific Post Office issue. Actually, there was just
more maturity needed around risk.
You know, later we, for example, created anew
Implementation Directorate with new SCS roles, who were
responsible for improving the system. It was something
that, you know, I, as Permanent Secretary, worked on —
When you say “the system", what system?
The risk reporting system, as in how do you make sure
that when a risk has been identified in one place in the
organisation, it is cascaded up through a Directorate
level risk register to a group, ie Director General
level risk register, and into the departmental risk
register? If I may just make one comment: I do not
think that, at this point, there was any lack of
visibility of the risks around the Post Office for the
Permanent Secretary.
It was one of the areas of the Department that the
then Permanent Secretary was very highly personally
involved in. So I think it is absolutely an important
sort of process point to address in the context of the
quality of risk reporting in the Department. But do
I think at this time there was any danger that there was
sort of invisible, unknown risks surrounding the Post
Office specifically, as it related to the Permanent
Secretary? I would not have been concerned about that
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a sort of critical failure point, and indeed, I think
that's reflected in the yellow RAG rating assigned here.
If we turn the page, please, there's a bullet point, the
first one on the screen:
"Providing greater visibility of [Post Office] risks
within BEIS. The BEIS Policy Team does not have
oversight of risk management activities conducted within
[Post Office] and/or concerning [Post Office] by UKGI or
the BEIS Partnerships Team ... This could impact the
Department's ability to influence/oversee the mitigating
actions in place to ensure risks are aligned to their
risk appetite and the quality of risk reporting to the
Permanent Secretary."
Would you agree that seems a more significant
concern?
Yes, absolutely.
What steps, if any, were taken to address that point
following the issuance of this document?
I think it probably makes sense to sort of put this in
context of wider work that was going on to improve risk
management in the Department at the time, including then
when I was Permanent Secretary. I mean, this feature
that you're seeing here of, you know, an insufficiently
clear risk escalation process, which is sort of one way
of describing what you're seeing here, I don't think was
106
at the time, given the frequency of interactions and the
level of personal attention that was being paid to these
issues.
That doesn't mean this isn't something that, you
know, needs looking at but I would see it more as a kind
of a challenge to the maturity of the risk processes,
rather than a kind of danger to Post Office oversight
specifically
On that, we have seen plenty of evidence of the approach
to Post Office, following the Common Issues Judgment and
the involvement of the Department in overseeing matters.
A lot of time was spent on it. Looking forward, one of
the things the Inquiry is investigating is what systems
are in place to ensure that risk is properly identified
in the Post Office going forward and so are there
systems in place in response to this document?
You said in your evidence then that it needs looking
at. My question is: has it been looked at and what
concrete steps have been put in place to ensure that
Post Office risks are properly visible within the
Department?
Well, ifI may say so, referring to current state, that
would be a question best put to the Permanent Secretary
for the Department for Business and Trade. I can't
comment on current state. I can only comment on what
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happened during my tenure, which I'm very happy to do.
I just wanted to clarify that.
Q. Let's limit it to by the time you left the Department.
A. I'mstruggling to recall in detail. I'm sorry, I wasn't
particularly prepared for this line of questioning, and
I'm happy to go back and look at the documents. I can't
remember exactly in detail what the kind of process
forms were by which the risk process went through but,
by that point, we had in place Directorate level, DG
level, risk registers, we that principal risks at
a departmental level, and we had a team responsible for
oversight of that overall system, and I would certainly
expect that the risks involving the Post Office would be
kind of flowed through that.
We, of course, also had an Audit and Risk Committee
within the Department. I know that they spent quite
some considerable time going around arm's-length bodies,
including the Post Office. I forget the exact details
but I think there were occasions where the chair of the
BEIS ARAC was involved in risk discussions at the Post,
Office. I'd have to check the record on the detail
So I would say it was a reasonably effective risk
management framework. My experience of risk management
in the Civil Service has been that, given the diversity
of risks that you are dealing with, it's quite difficult
109
catch-up with him, it would always be sort of the first
point on the agenda. You know, I saw from sort of the
flow of submissions and responses that it was something
that was getting very serious ministerial attention
I think I have heard, but I have -- I wasn't able to
kind of put together a record to demonstrate this from
the papers that DBT were able to supply ~ I think
Ihave heard that the portfolio had shrunk at that
point. But the change clearly wasn't really
significant, otherwise you would sort of see it in the
public portfolios very straightforwardly, and I couldn't
quite pick it up when I tried to check the record on
this point.
So I'm not sure I could say that with confidence but
I did not perceive, during my time as Permanent
Secretary, that we had a problem with a lack of
ministerial sort of time or energy on the Post Office
I -- others, of course, may have a different view but
I didn't see that problem.
MR STEVENS: Sir, I know we've only just started but I am
moving on to another topic, so I wonder if it's a good
time to break for lunch there?
SIR WYN WILLIAMS: Yes, by all means. 2.00 all right?
MR STEVENS: Yes, sir. Thank you.
‘SIR WYN WILLIAMS: Fine.
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to establish what I would call a really best practice
risk management framework. Just worth noting
UKGI, of course, also has its own risk management
approach, and you also see Post Office risks tracked
there. I just thought that was worth mentioning.
Q._ I'l move on to another point you raise at paragraph 24.
It doesn't need to come up on the screen, I'll read it
to you. One of the points, you say there's been serious
inadequacies in the oversight of POL, Post Office, by
the time you took over:
"I do think much of this had been addressed."
One of the points you make is:
"We had a minister leading on postal affairs
spending very significant time on the Post Office who,
for example, met monthly with the CEO."
Can I just clarify that. Was there a change in the
Minister's portfolio at that time to enable the Minister
to spend more time on Post Office or was it just that he
or she chose to do so at the time?
A. I'm not completely sure about that because I think that
changed -- I don't know if there was a change that sort
of predated my involvement. What I can say with
confidence is that for Paul Scully, who was the Minister
for the majority of this period, Post Office was ~ just
to give you some examples, when I would have a regular
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(1.00 pm)
(The Short Adjournment)
(2.00 pm)
MR STEVENS: Could good afternoon, sir. Can you see and
hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: Can we please bring up the second witness
statement at page 13, paragraph 26. You're discussing
governance arrangements at this point of your statement
and at paragraph 26 you say:
“I think the hard part tended to be actually getting
[Post Office] to do what ministers wanted. As described
above, the Department did, from 2020, have a power to
issue directions to [Post Office], but ministers could
not routinely become involved in the nuts and bolts of
operational decision making."
At paragraph 27, you give an example of this in
managing legal costs, which we'll come back to. But if
we could go over the page to the bottom of paragraph 27,
you say:
“For these kinds of important but ultimately
operational matters, if [Post Office] did not do as we
asked we had relatively few levers with ‘teeth’ other
than the ones that had other issues (like removing the
Chair or pushing the organisation into financial
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trouble)."
Did you experience similar problems with other ALBs,
namely finding it hard to get the ALB to do what the
Minister wanted, whilst you were Permanent Secretary?
I'm just sort of testing my mind for examples. Yes,
I think, is the right answer to that. It would be — it
varies according to the structure of the arm's-length
bodies and an example like Post Office is sort of quite
arm's length, so there will be other examples like
executive agencies where you might have, you know, much
more explicit clearances over salaries within the
organisation, for example.
But the idea that, you know, like in many situations
where you're in a supervisory or a management function
over somebody or another organisation, although you may
have a sort of set of formal levers at your disposal,
often sort of your first port of call is influencing.
You know, it's a bit like if you're managing
an employee, you might ultimately have the ability to
terminate them but that's a really drastic step and one
that you wouldn't take until you've gone through talking
to them about why you want them to do what you want them
to do, hearing what they think about it, trying to give
them some training, increase their capability.
You know, I think it's a very common journey and
113
effectively creating a capability for the Secretary of
State to say, "Post Office, you must do X"
I think the reason that has tended not to be that
relevant is there aren't that many decisions in
a complex organisation like the Post Office that are
sort of really, like, simple and binary: should I X or
should I Y? It's often much more complex. So if it
comes to something isolated and specific, a sort of
direction power, where you can say "You must X", works
well.
I think that direction power came about in response
to the events that surrounded earlier handling of the
litigation, where there were some quite specific
questions, including the one about recusal of a judge ~
I'm not over all of the detail. But those sorts of
matters, you can imagine a department being able to say
to an arms-length body "You must X, therefore X" but
something like "Reduce your legal costs", which is the
example I use in my witness statement, it's much more of
a sort of debatable point because the Post Office, not
illegitimately, would want to come back and say, "Well,
we need these legal costs for reasons X, Y, Z, we are
going to reduce them but not until next year because the
contract needs to come up for renewal", et cetera,
et cetera.
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I certainly saw it with other arm's-length bodies as
well. I do think it's particularly acute in this case
because the combination of being at the more extreme
end -- like a long arm, if that makes sense, in the
context of the Post Office, combined with being so
troubled and having, rightly, so much political
attention on it, I think that's a really difficult
combination, whereas if you took a body —
If I compared it to something like the Ordnance
Survey, just to take an example, you'd have a similar
set of levers and a similar degree of arm's lengthness,
but just a much lower level of heat, at least during
this period, around the organisation and its
performance.
So I think that's why it sort of comes quite acutely
in the case of Post Office, because you're combining
a long arm with a very great deal of legitimate
political interest
Reflecting on matters, have you thought or can you
assist us with whether there are any other levers that
would assist in managing Post Office in this way?
I's a good question. It's maybe worth just reflecting
for a minute on — you might say, if we had the ability
to make directions, why isn't that sufficient? I mean,
that's actually quite a strong lever, right? That's
414
So it's much more of a dialogue about what is and
isn't reasonable, rather than you can order people to do
things.
That tends to be over simplistic for what we're
talking about here, which is why, actually, the
influence, you know, presence on the Board matters,
being part of the discussion, understanding the nuance
and the detail. So I think I find it quite hard to
answer your question with a really specific, "If only we
had power X, we would be able to make everything okay”.
I don't think it's like that. I think it's more
like having a strong productive relationship with
respect on both sides and listening to each other has
got to be the right starting point and I don't think the
formal arrangements we had in this period precluded
that,
I want to look at one example, please. We don't need to
bring it up, actually. You refer to the review of Tim
Parker's decision not to share the Swift Report —
that's, for the record, paragraph 18 of your
statement — you describe it as a governance failure.
You say
“After learning of this and giving consideration to
whether we should advise ministers to fire Mr Parker,
formal censure was chosen as the appropriate course of
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action."
Was a minister involved in the decision to censure
Mr Parker rather than terminate his contract?
Yes. That decision would ultimately have gone to ~
I'm -- I know for sure it went to Paul Scully, the
Minister. I don't recall specifically whether it went
to Secretary of State. It may not have, it may have
been a delegated decision. But that was signed off by
ministers. But, as I do say -- you know, just for the
sake of clarity, I do say in my statement that was on
our advice, and our advice was formal censure. So you
might ~- I wouldn't wish to put it only on ministers.
but, yes, of course, any decision like that would be
signed off by ministers
Can we look, please, at POL00104180. This is your
letter to Tim Parker after that decision was made on
7 October 2020. In the second paragraph, please, you
refer to the background to that, which is well known.
Towards the end, you say:
“... we consider it was a mistake not to have
ensured that the whole Board had an opportunity to see
and discuss the detail of its findings and agree what
any next steps should be. With hindsight, this
information should have been seen by the Board and we
are disappointed that it wasn't.”
417
We'll come to that in a —
-- go further.
-- in amoment.
So I agree, in other words, that sort of looking at it
now, you wonder why we didn't go further, and that could
include either a sort of harsher drafting or, indeed,
a different decision altogether.
Was Mr Parker told that dismissal had been considered as
an option?
I couldn't say for sure.
You just said there about what you say in your statement
regarding whether that was the right decision. We don't
need to bring it up, sir, but, for your reference, it's
paragraph 18, page 10 of the second statement. You say:
“With the benefit of hindsight, it was perhaps the
wrong decision not to take the harsher course of action
and terminate Mr Parker's appointment."
So, again, you say “with the benefit of hindsight",
have you learnt anything since October 2020 that now
makes you doubt the decision that was made?
Well, yes.
What would —
I mean, I think probably lots of things fall into that.
category. So, first of all, I think all of us, at least
‘on the HMG and Post Office Management side, over time,
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You go on to matters about sharing documents said to
be legally privileged.
Firstly, why did you say "With hindsight this
information should have been seen by the Board"?
I think it's sort of felicitous drafting. I'm not sure
there is any deep significance to “with hindsight". Had
we been asked the question at the time, in possession of
the full data, one would have said the same thing at the
time. If you or I was transported back to the moment
where that decision was made, with the report in front
of us, I hope we would have decided that it should have
gone to the Board.
It might be said that this letter doesn't contain
a sufficient degree of criticism or disapproval to be
described as a formal censure. What would you say to
that?
It's certainly one of the harshest letters, if not the
harshest letter, I have ever written to a chair of
an arm's-length body I've been involved with, and I've
been involved with a very great many arm’s-length bodies
‘over some considerable period. So, you know, opinion
could differ, but I would say that as a matter of fact.
It's fair to say that, I think as I say in my
witness statement, as I reflect on it now, I actually
think the advice probably should have been to --
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you know, the full depth of the scandal in the first
place has been sort of further elucidated. So I'm not
saying it - obviously, at the time that this decision
was made, we knew this had been a very serious error
but, as the picture grows around it and you try to
isolate, what were the moments that could have made
a difference? I think now I would see that moment where
the Swift Report wasn't shared as a relatively critical
one in the story.
At the time, I don't think that was as clear to me,
simply because — I mean, I've obviously been following
the Inquiry closely and all of the events that have.
happened in HMG as well. That just wasn't as clear to
me at that time. I don't think there's one sort of
particular fact I've learnt but as just the picture
becomes deeper and clearer that looks like a critical
moment.
{also think at the time, you know, it was an in the
balance decision that was considered both ways, if you
see what I mean, and, at the time, the advice of the SID
was taken into account, and it was also kind of top
of -
When you say SID, do you mean Ken McCall?
Yes, I'm sorry, the Senior Independent Director, Ken
McCall. Thank you. It was also kind of the decision in
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the round was taken in recognition of the fact that, you
know, switching people out causes instability and that
there would have been all sorts of challenges with
trying to get another chair at that time. And I guess
that felt ike a very important issue in the moment.
‘And now, when you look back at the picture overall,
on lots of cases here I think you ask: should people
have been bolder in making changes? I think, therefore,
I probably see it with that perspective now.
SIR WYN WILLIAMS: At the time, Ms Munby, were there senior
people who were consulted about the issue, who actually
favoured terminating the chair, or was it more or less
a unanimous view that censure was appropriate?
‘A. I don't remember anybody sort of specifically pushing,
but it was certainly a decision on which many of us,
myself included, felt was very much in the balance, if
that makes sense. I don't think there was a sort of
a one -- there wasn't a censure side and a termination
side and we were having a face off. It was more like
a debated issue that we were discussing as a senior team
what we thought was best. And this was where we landed.
SIR WYN WILLIAMS: Okay. Thanks.
MR STEVENS: At the time, were you involved in any oversight
or investigation of whether officials within the
Department had knowledge of the Swift Review?
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Executive of Post Office was an Accounting Officer for
Post Office?
A. Yes, it's alittle bit more complicated than that
because you have a structure where you have a Principal
Accounting Officer at the departmental level and then,
depending on the nature of the status of an arm's-length
body, the CEO may be an Accounting Officer in their own
right. I think it might be the case in POL,
specifically, that they're more correctly described as
an accountable officer, which is ~ I think it's
a technicality.
But itis, of course, fair to say that what's in
here would represent principles that the CEO of the Post
Office should have in mind.
Q._ As Permanent Secretary and Principal Accounting Officer
for the Department, your responsibility was to make sure
that there were arrangements in place to satisfy
yourself that Post Office had systems adequate to meet
the standards required of Managing Public Money?
A. Yes, insofar as they applied to any particular aspect of
the Post Office's operations —
Q Yes.
A. -- because, obviously, much of the money that Post
Office was dealing with wasn't quite correctly described
as public money.
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No, or not that I remember.
Do you think such an investigation should have been
carried out?
Possibly. I don't remember enough of the facts
surrounding the case to give you a really confident
answer on that, if 'm honest.
I want to turn now to look at some of the compensation
schemes. [I'm going to deal with it at a relatively high
level because we've heard evidence from Simon Recaldin,
and Carl Creswell will be giving evidence on the issue
later this week.
In your statement, is it fair to say that a common.
theme that you point to as the reason for the delays in
compensation is what you describe as an underestimation,
initially, of the scale and depth of the challenge in
providing redress to subpost masters?
Yes.
I want to begin by looking at the effect of Managing
Public Money on compensation schemes, please. Could we
bring up POL00413475. This is "Managing Public Money",
the May 2021 edition. Would you agree a fair summary of
this is that it sets out the main principles for dealing
with financial resources in the public sector?
Yes.
During your time as Permanent Secretary, the Chief
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Could we look, please, at page 20. Paragraph 3.3.3
says:
“There are several other areas where Accounting
Officers should take personal responsible ..."
At points 1 and 3, we see, “regularity and
propriety" and “value for money".
In the documents that we'll go to, it's fair, isn't
it, that regularity and propriety, and value for money
are concepts that were applied to the establishment of
the various compensation schemes.
If I may, there are four core concepts that underpin any
Accounting Officer test, as I would put on any new
announcement that the Department was making. Those are
regularity, propriety, value for money and feasibility.
‘And any major new initiative by the Department needs to
be assessed against each of those four criteria and
needs to have personal sign-off from the Accounting
Officer before it can be launched
So I think, subject to you adding feasibility, the
answer to my question was yes?
Yes, I mean, I guess I'm saying yes, very, very much so.
If we turn, please, to page 15, in box 2.4, just sliding
down, we have a description of "Regularity. It says:
"Regularity: compliant with the relevant legislation
and wider legal principles such as subsidy control and
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procurement law, delegated authorities and following the
guidance in this document."
When we are considering compensation schemes, does
regularity apply in the sense that the question is
whether or not this legal authority to make compensation
payments themselves, or does it also apply to whether
any compensation payment that is made must itself be
justifiable in legal terms?
I don't think it follows from the principles of
regularity that you can any compensate people to the
extent of your legal obligation. And indeed, I'm sure
you know that, you know, within the sort of framework
for initially the HSS, the sort of core documents of the
scheme were about trying to offer fair compensation,
even insofar as that went above what was a strictly
legal obligation. And I have certainly never understood
regularity to mean that.
Where regularity has been very relevant in the
context of the Post Office, where this test has been
particularly live, is actually where you're talking
about payments from the Department to the Post Office
and then from the Post Office to members of the GLO
class, where the question of under what Parliamentary
authority were we making those payments -- I'm — this
is probably well known to the Inquiry -- was very kind
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Public Money, there's quite specific reference to
compensation schemes, in which, in effect, it says the
same processes apply in compensation schemes. They're
like any other form of public money expenditure and
value for money, regularity, et cetera, et cetera,
apply.
Again, value for money is always about value for
money for a given ministerial objective. So it's not
like you have to justify, you know, is it value for
money to deliver full and fair compensation? The
requirement is to deliver full and fair compensation
The question that an Accounting Officer would be asking
themselves, and I did ask myself, is: are we delivering
that full and fair compensation in a value for money
way? And there's probably a few aspects that come up
there.
Firstly, and very obviously, are the procedural
arrangements for running the scheme good value for
money? Normally you would want those costs to be as low
as possible, although clearly that's not an absolute
rule because, you know, being slow also adds cost.
The second thing you would usually have top of mind
when you're thinking about a scheme like this is the
area of fraud and error. That's been a really
substantial problem in a lot of Government schemes. In
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of extensively explored. That would be a regularity
issue: is the expenditure regular; is it properly
sponsored by Parliament?
Ihave never made any comment, I don't think, on
regularity in the context of individual compensation
payments, and the reason for that is, ultimately, the
Accounting Officer requirements come second to the
question of whether the policy intent of the Minister is
being fulfilled. So you're asking the question -- the
‘compensation needs to be full and fair, and then we need
to find a way of making it regular. You don't say, "I'm
going to use regularity as a way of not making it full
and fair”.
So if ministers think that fair goes beyond legal
liability -- and, ultimately, that's the sort of
question that is for ministers — then the only
regularity question is whether we have a piece of
Parliamentary authority that we can use to make those
payments. You would never use regularity to sort of
undermine that ministerial perspective.
Just out of that point, how does the value for money
aspect of managing public money fit in, in the context
of compensation schemes?
So basically the same point. It's worth mentioning
there's — at least in the latest edition of Managing
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this case, I want to be clear I'm not suggesting that
there was any fraud in any claims made but you would,
for example, want to be confident that you weren't
making payments to people who weren't postmasters, would
be a good example.
An error is another, like, very common
characteristic. That would be particularly things like
where you make the same payment twice, so you don't have
sufficiently good recordkeeping and you pay out a grant
and then you make the same grant again to the same
person without realising. That would be an example of
error and, again, that would be ~ regardless of what
sort of scheme you were looking at, that would be top of
your mind as an Accounting Officer.
I think with compensation schemes it gets more
complicated, when you get to what level of compensation
is value for money? And, ultimately, the first place
you look there is for what was the original policy
intent and, in this case, that was for the compensation
to be full and fair.
But is it fair to say that the value for money is
relevant to the question of the amount of compensation
that is paid: namely, when considering value for money,
does one have to consider whether compensation payments
made are too generous or overly generous?
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It would really depend on what the ministerial steer
was. So let me give you an example. In this context,
at the kind of early stages of HSS and indeed for some
time, this was not just a short-term thing, the sort of
principle on which the payments were being made was that
there should be fair compensation at an individual
level, ie the amount of compensation that an individual
received should relate directly to the injury and
suffering that they had experienced as an individual
Once you -- once that's your policy intent, then
yes, value for money principles would suggest that you
should compensate people to that point, and not further,
except insofar as that was a sort of reasonable, you
know, compromise in the grand scheme of things.
Whereas, you know, later, I know that the schemes
have moved to much more sort of fixed offers that move
away from the principle of sort of compensating
according to individual level of loss. Once you've made
that decision that that's your intent, then you would
look at value for money from a different angle.
So I guess you can't sort of discuss value for money
in the abstract without understanding the goal that
youre trying to achieve. But once you have specified
that goal and once you have specified a principle like
you're compensating on kind of an individual basis,
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an important point. I wasn't pushing a particular point
of view here. I was genuinely just seeking to clarify
the situation and to understand better, it's quite
a large, you know -- it's a significant piece of policy
work, significant money associated, and I felt I should
understand what was going on.
You'll see later I get a reply and I say "Sounds
good, go ahead”. I didn't have an agenda,
I'm going to look at that reply now, please. Could we
go to the bottom of page 1. It's an email from Tom
Cooper, 1 July 2020. It says that it won't prevent
claimants from pursuing a malicious prosecution claim
but goes on to say:
“The point is to provide a quicker and cheaper route
to redress/compensation than having to go through the
courts again. This is in the interests of all parties
of course ~- claimants, [Post office] and [His Majesty's
Government].
“To your last point, we would always expect
claimants to take some discount to the full potential
value of a malicious prosecution claim because:
[1] The outcome will be inherently uncertain as in
any litigation.
“[2] It will take a very long time (particularly if
there are appeals).
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then, yes, of course you would expect value for money to
be relevant, just as it is, I should say, in absolutely
every other aspect of any Government money spent
anywhere.
‘Can we look, please, at UKGI00018879. If we could go to
page 2, please. We see an email from you on 30 June
2020, and it says the subject is "FOR COMMENT CLOSE ...
[Post Office] Convicted Postmasters Compensation
Scheme". You say:
“One point of clarification from me. Does the
establishment of the compensation scheme prevent the
malicious prosecution claims? (le can it actually close
off the risk of larger sums materialising in any case).
“Is it that we expect claimants to prefer
a cheaperiless risky route even if for lower benefit?
If so how sure are we that will be true?"
What was the purpose of your questions at that
point; why did you seek those answers?
I hope this won't seem like a cheap answer. I mean,
because I was seeking to understand. So this is very
early on in my engagement with this scheme. I've just
been given a piece of advice. I actually remember,
interestingly, not getting, factually, whether it was
the case that, by running a scheme, you sort close off
the legal route or don't. And that seemed to me
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[3] It will involve substantial costs which
some/all claimants may have to fund externally and for
which they will end up having to give up a large share
of the proceeds if they win ...”
Is it fair to say that, at this point, one of the
policies behind the schemes was to seek to settle the
claims at a value less than they may have been at trial?
Yes, although I would caveat that by saying I don't
think the sort of overriding consideration was to settle
the claims at a value less than they would have received
at trial. It was that settlement is — I mean,
generally, I think — lawyers might disagree ~ but
generally a better approach for all parties. So I would
just ~ I don't think that's to negate what you just
said but I just think it was more that context than
a sort of, you know, financial minimisation, as the core
motivating factor.
Can we look, please, at BEIS0000961, please. It's
an email on 8 September referring to a meeting the day
before. We see there are attendees from Post Office,
including Nick Read and Tim Parker. You are listed
there as Perm Sec ~ Perm Secretary. Can we go to
page 2, please, for part of the readout. It says:
"Tom noted that although Alan has taken the thinking
on this quite a way, Tom is keen that BEIS/UKGI don't
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get too involved in the detail of the schemes but focus
more on the communication side of things.”
Pausing there, was that an accepted position within
BEIS at that time in September 2020?
Hmm, I'm not sure. Sometime around this time, and I'm
not sure I could put the chronology, you know, was it
exactly before this meeting or after this meeting, but
this was during the period where we moved from sort of
thinking "This is mostly a Post Office thing" to "We
really need to get across this in a very great deal of
detail". And I'm just not sure I could put exactly
where this fits in that chronology, apologies.
It goes on to say:
“Carl asked whether Perm Sec [referring to you] had
any views as Accounting Officer, and ensuring propriety
VEM [value for money], ethical considerations on any
comms statement. [Permanent Secretary] wanted to know
if the wording of the statement was consistent with only
mediating on the cases that would come up.”
Can you help us with what that means?
I don't remember.
It says:
“The Permanent Secretary noted that none of the
schemes are terribly attractive.”
Why did you think none of the schemes were terribly
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give more compensation to claimants than they would
actually be receiving.
“Carl/Perm Sec noted that through mediation, some
claimants would receive much less than they think they
are entitled to."
Again, can you recall what your -- precisely what,
your concern was here?
So I'm going more by reading the text and thinking what
it probably meant, rather than having an exact precise
recollection. But we were looking at a draft of
a public statement, which is very normal at this stage,
like what are you going to announce, basically. And
here this is, you know, talking about making sure that
the statement doesn't over-promise, relative to what
we're actually planning to do.
‘And without having the statement draft in front of
me, I'm not sure I could tell you what exactly the
problem with the statement was but what this looks to me
like is a discussion where we're saying, "Look, the two
need to match. If we're going to give this sort of,
like, very forwarded leaning statement are we confident
that what we're proposing, this mediation driven
process, are we confident that it actually delivers
against it?"
25 @Q. Can we move on slightly in the chronology, please, to
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attractive?
A. Atthat point, we were discussing a range of different
options, all of which were expensive, all of which were
onerous for everybody involved - you know, Government
and postmasters -- and kind of being given a set of
options to choose from about how we might approach
‘compensation, there wasn't one that I looked at and
thought, "Yeah, you know what? That's great". It was
choosing between, you know, sort of choosing between
difficult options, none of which were perfect.
SIR WYN WILLIAMS: I'm sorry to interrupt again but can I be
clear. At this point in time I think we're in early
July, are we, 2020?
MR STEVENS: This is September 2020, sir.
SIR WYN WILLIAMS: Right, so HSS has already launched. So
presumably you're here talking about what to do with the
people who were having their convictions quashed. Is
that it?
A. That's right. I think there was a presentation at this
meeting about various different approaches for dealing
with what later became the OHC.
SIR WYN WILLIAMS: Fine. Thanks.
MR STEVENS: It says:
"Carl said that ‘all options’ and ‘entitled to’ in
the statement suggests that Government is committing to
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UKGI00043126. Page 5, please. If we go down slightly,
please. So this is from Permanent Secretary: I assume
that's your private office email address?
A. That's right, yes.
Q. “Just had a conversation with Joshua. Sarah has some
concems with the AO assessment ..."
Presumably Accounting Officer assessment?
A. That's right.
Q. "... and isn't happy to clear yet.”
If you could go down, please.
“It has a high [value for money] risk, and we're not
sure why. What we need is an assessment of this
announcement, which leaves room to design a [value for
money] scheme."
It goes on to say:
"We need a clearer answer on why we are confident
this won't lead to a regularity challenge.”
Can you recall what was driving your concems in
respect of your Accounting Officer assessment of the
schemes at this time?
A. Yes. And with all due respect to those who wrote this
particular piece of advice, what this feedback is, is me
saying this advice is not good enough. So the advice
I received at that time, just to take VFM as the
‘example, had — what an Accounting Officer normally does
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itis take those four tests I was talking about earlier
and gives a rating against each of them. And this piece
of advice had a red rating against value for money.
You can't, as Accounting Officer, just let that pass
by. Ifithas a red rating for value for money or one
of the other tests, you need to engage. And,
ultimately, if you really thought it was a red rating
for value for money, if that was your considered opinion
after getting the best advice you could, then you would
actually need to ask for a ministerial direction.
Now, I absolutely did not think that was the case
here. And what I was asking for is for the team to come
back with basically a more intelligent piece of advice
What they had done at the time is they'd said, "We
haven't designed all the details of this scheme yet,
it's still quite uncertain. And so it feels risky so
we're putting a ‘red’ for value for money”.
But what I was trying to point out is all we're
doing is making one step forward: we're announcing the
scheme. We're not tying ourselves down to an exact set
of details. There's plenty of room within that to make
sure that we do design a scheme that passes the
Accounting Officer tests and, of course, that would be
our intent, and that's what we would do.
So I was asking them to go back and, I mean,
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conditions that we have had to mandate.”
Do you recall what Post Office's concerns were in
relation to Managing Public Money in relation to HSS?
I don't really remember them as being specifically about
Managing Public Money, but there had certainly been back
and forth around governance and our involvement in the
governance around HSS. I think, by this point, we had
started putting pressure on around legal costs and
administrative costs which had been a very kind of tense
set of discussions, and that certainly was a Managing
Public Money issue.
I think if I had characterised what I knew at this
point, I think I would have said more that they had sort
of concerns or frustration from a governance
perspective, maybe, rather than it being particularly
an explicit dispute about Managing Public Money. But,
you know, clearly the drafting here suggests that.
I just -- that would just be my perspective.
That document can come down. Thank you.
It's been suggested by some that the approach to the
compensation schemes has been litigious or legalistic.
Have you heard that criticism?
Yes.
Do you have sufficient knowledge of the operation of the
schemes to have a view on that?
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basically create a piece of paper, that rather than
saying this is all red and bad and you cannot announce
it, reflect the truth, which is that: this is fine from
an Accounting Officer point of view and it's perfectly
ready to be announced; which was my view.
So we take this as a criticism of a draft, rather than
a substantive position on the Managing Public Money
assessment?
100 per cent.
Please can we look at BEIS0000990. This a briefing on
410 June 2021, so we're jumping ahead again in the
chronology. It's a briefing which we will come back to.
You see it's on the ownership of criminal convictions
compensation, regarding who runs that scheme.
Could we please look at page 3, and paragraph 12 —
sorry, not paragraph 12, it's just a bit further down
where it says, “Efficiency”. Thank you. So this is one
of the pros, it says, of the Government taking on direct
‘ownership of compensation from Post Office:
"in either situation, we will need to scrutinise
aspects of the compensation closely from an MPM
[presumably ‘Managing Public Money'] perspective."
That's right.
"This has caused [Post Office] some frustration in
relation to the HSS scheme because of the process and
138
I think I do, although it's a partial one and I'l just
sort of say it as I see it. I think there's two aspects
to this. The first comes back to what I was talking
about earlier, about taking a case-by-case approach to
the schemes. And, I mean, in my witness statement
I talked about sort of if you went back, what might you
do differently? In a way, that original decision to
have a scheme that was based on individual applications
and assessments of individual applications, even if, for
a moment you put aside any concerns about how you do
that -- I'l come to those in a second, but just putting
those aside - just inherently asking people who have
been through something truly awful to go back over it as
part of an application process has challenges, even if
you do it in the absolute best possible way.
So I think that's sort of point one.
Point two, then, is actually, particularly through
the process here, I think there have been cases -- but,
you know, frankly, the Inquiry would be as well placed
to comment as I am ~- there have been places where you
look back and you think, you know, an individual case
was handled not as generously as would be sort of
properly viewed as compatible with full and fair.
{don't think, certainly from my perspective,
I never saw ministers or officials seek to achieve that
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outcome, and I didn't at the time see any evidence that
the Post Office, at a sort of corporate level, was
seeking to achieve that outcome. I think others are
probably better placed to sort of say what happened on
the ground and how it felt. But maybe a reflection
would be that, you know, once you pass intent through
a system, at the end you might not always sort of feel
the intent you started with, especially once you've gone
down the, you know, perhaps necessary or necessary at
the time, road of assessing each case individually
because, if you assess cases individually, it takes you
down a path of wanting to see some level of evidence.
And you can get into, and you may well wish to,
discussions about like what the bar ~ what the
evidential bar is. But the difficulty with a system
that assesses individual cases and has no bar whatsoever
for evidence, if you have no requirement, is then it is
100 per cent a matter of whatever is asked for, you will
pay out, without any process at all. And that is
difficult, from a Managing Public Money point of view
because, of course, everybody would always like to
receive more money and, if you don't ask for any
evidence at all, it's really hard to know are we
compensating fairly or are we starting to get to the
point of ~ I don't mean sort of minor over-compensation
441
Second, standard use of public money, as we would have
had to accept making payments that could not by any
normal standard of judgement be viewed as compatible
with the formal guidance for spending taxpayer money
({or] Managing Public Money).”
Do we take from your evidence at the time, so
putting ourselves back to September 2020 thereafter,
that there wasn't a discussion on these more blanket
approaches, which we've seen in sort of post-2024?
I think I remember we were talking about that meeting
earlier where you had the readout from it and you were
asking me what things meant.
Yes.
As I remember, there were options in there that went to
tranche-driven approaches, ie where you define a series
of classes and then have kind of flat payments within
class. I don't specifically recall but it could have
been. I don't specifically recall a proposal which was
around kind of a single very generous class, which is in
effect what I'm describing here.
So the proposal you're describing here wasn't put
forward to a minister?
It's not -- yes. I think it's important to say it's not
that lots of people were saying that this was what we
should do and I or somebody else and came out and said
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but, you know, really serious over-compensation based on
claims that aren't right.
And that I just ~ I think that's a really difficult
trade-off. And I do sort of wonder, looking back, you
know, how easy really is it to design a scheme that
looks case by case but that doesn't end up feeling
litigious to at least some of the participants in that
scheme?
If we look at your statement, I think you deal with some
of those issues. It's your second statement, please,
page 25. It's paragraph 51. You refer to other
approaches and the sort of application-based approach,
as it:
*... would necessarily have been much more ‘blanket’
in its nature, and probably would have meant we all had
to accept paying people whose circumstances were
different the same amount as each other. Likely the
only way it could have proved acceptable to
[subpostmasters] is if the numbers had in general been
much higher overall (‘levelling up’ ...). For [His
Majesty's Government] to have gone down this road
officials and Ministers would have had to have given up
‘on two quite funnel principles. First, fairness, both
as to between different applicants, and to as to between
[subpostmasters] and other victims of past injustices
142
no, that isn't compatible with Managing Public Money.
I think it was almost perhaps taken as read that we
would have a scheme that, broadly speaking, sought to
provide as close as possible to full and fair to.
individuals. And that that might - you might have gone
as far as a tranche-based approach, which obviously is
not quite as precisely gradated as an individual
approach, but is still gradated.
\ certainly don't remember an extensive debate. It
may have come up once. I couldn't swear to that but it
certainly wasn't extensively debated and I certainly
never said, "You can't do that because of value for
money reasons’, because the question was never put tome
in that anyway.
Looking back again at that time, do you think sufficient
consideration was paid to all the available options?
In one sense, the answer to that has to be no because
we've now -- we're much further down the path and you
look at where the schemes are now and, knowing that that
is where you're going to land, itis just undoubtedly,
irrefutably true that, if that’s where you're going to
land, you would have been much better doing it earlier,
for everybody's sake, and particularly for postmasters.
So, in that sense, you know, it was definitively
wrong. However, if you go back and look at the
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environment that we were operating in at the time, you
know, being absolutely frank, I think if the proposals,
as they are now, had been put on the table at that
moment in their current form, but sort of put back into
the historical context, I think we would have had
insurmountable difficulties with HMT, the Treasury, with
Ministers, actually, and possibly, although it's always
hard to answer this, possibly with me as an Accounting
Officer.
I think all of those ~ all of those sort of formal
clearance moments would have been very, very difficult
to get through. And so I don't think that kind of
radicalism was properly contemplated at the time. And
so the question I asked myself is what would have to
have been true to get the system as a whole to operate
in a more radical mode, faster?
Q. What changed between then and now, in the sense of you
said, if we know where we are now, it wouldn't have been
possible back then? What do you think the key
differences were between the two times?
A. I mean, ultimately, and sort of operationally, the
strength of the ministerial steer to address the problem
in full, sort of -- and I use these words sort of
appropriately but kind of at any cost.
Q_ What caused that change in position?
145
assessment.
A. Yes, I think fixed payment and interim payment options
were of course considered earlier and, indeed, at least
in the case of interim payments, implemented earlier.
So I think it's the combination of being fixed and also
the relative scale of them. I think that, it's that
combination that it would have been hard --I think,
even if we had had an official who was pushing that
agenda, I think they would have met obstacles in the
system, I just want to be honest about that.
SIR WYN WILLIAMS: Yes. So I don't mean this in any flip
sense at all but Mr Recaldin was talking about the
journey that postmasters have been on. You're almost
describing a journey that civil servants and politicians
have been on in terms of trying to achieve full and fair
compensation?
A. Yes, I think that's right although, like you, I wouldn't
compare the journeys in their, you know, challenge or
emotional cost or anything else, but I think the thing
I've reflected on is, when you get to the end, you
always look back and you think, "Well, why didn't we
just do that to begin with?", because, as I've said, if
you know that's the destination, it's much better to get
there quickly than more slowly. So the question really
is: why not; what was it that meant that that didn't
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‘A. That -- it wouldn't be for me to answer. It happened
after my involvement and I wasn't there.
Q._ Let's go to what you say —- you talk about some of the
reasons for the delay. If we could --
SIR WYN WILLIAMS: Before we do that, Mr Stevens, just so
I'm clear, what you mean by “the now’ are things like
having fixed offers of £600,000 for convicted people
whose convictions have been quashed, or fixed payments
of £75,000 for people in the HSS; that's the sort of
thing you mean in relation to “the now’, is it,
Ms Munby?
A. Yes, that's exactly right, Sir Wyn. I would add to that
list, although it's not a VFM issue, but the other kind
of fundamental overturning of the initial principles
would be the mass exoneration —
SIR WYN WILLIAMS: Yes, well —
A. —which would be another example.
SIR WYN WILLIAMS: that's the ultimate step, if I can put
it in that way.
A. Yes
SIR WYN WILLIAMS: But the steps to it were things like, in
inverted commas, what might be considered -- and
I choose my words carefully -- as “realistic” fixed
payment type options for postmasters to take up if they
didn't want to go through a process of individual
146
happen?
And I think, you know, there are probably a series.
of reasons to do with under estimating the scale of the
challenge, which you mentioned, Mr Stevens, earlier, but
also a belief that the processes would go better than
they actually did. A sort of - what now with hindsight
is obvious was an excessively high level of faith
I don't mean in the Post Office's ability to run those
operations, actually, because, as I said in my witness
statement, I think many of the challenges might have
been similar, even if they had been run by the.
Department or by an independent body, but a sort of
confidence that the application of sensible governance
and processes would lead to the correct outcomes.
And, actually, what we saw is that that application
of what looked, you know, broadly speaking from my point
of view at the time, like quite sensible arrangements,
there were quite a lot of errors made. There were
points missed, be that around impact on benefits or
insolvent businesses, you know, points missed, errors
made and approaches that didn't work out in practice how
they were originally envisaged
I guess, overall, I would look back and say you're
too optimistic about how well the processes would get
rolled out. And that's partly a critique of how they
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were rolled out but it is in equal part a critique of
the sort of optimism that can often plague us when we
begin schemes of any kind. I don't just mean
compensation schemes; I mean, a sort of confidence that
things will be okay, whereas, you know, perhaps a more
sceptical, pessimistic approach that said, "Look, this
is going to run into an absolute whole load of really
specific challenges and it's going to end up being slow
and painful, we've got to cut to the chase quicker".
If I could sort of put myself back in my own shoes,
I think that is the message I would want to have given
more.
SIR WYN WILLIAMS: Thank you
Sorry, Mr Stevens.
MR STEVENS: Not at all, sir. Can we please bring up
page 23 of the second witness statement. You've got
a section there "HSS and the slow beginning”, and at 47
you say:
“Ladd my own personal apology to the institutional
apology that [Post Office] has already made for slow
progress during the early part of the scheme's
operation. [Post Office] (and, in tum, [His Majesty's
Government]) had seriously underestimated the scale,
complexity and cost of the problem and consequently (His
Majesty's Government] did not press [Post Office] hard
149
It says that:
“As of 25 August, 2013 claims have been received
amounting to around £100 million", being what has been
claimed.
So in your statement you referred to the estimates
in July 2020 as being 500 claims costing £35 million.
So, already, there's a significant increase in the scale
of the claims facing Post Office by September 2020, yes?
A. Yes, that looks right.
Q._ It goes on to say:
“Please not that there are a few exceptions to the
deadline, notably the cohort of [circa] 6,200 former
postmasters who were identified late by [Post Office]
and notified about the scheme in July.”
So it must have been clear by September the
significance of the claims facing Post Office; would you
agree?
A. Yes.
Q_ The Inquiry will hear evidence that it became clear that
the Post Office could not afford to meet the HSS in
November 2020; do you recall that?
A. I don't remember the exact date but that sounds
perfectly plausible.
Q._ It then took four months to resolve funding within
Government to meet the HSS --
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enough to, and [Post Office] did not themselves, set up
a sufficiently robust operation at the start.”
I think that's part of what you were referring to
there.
Could we go, please, to UKGI00013178.
Sir, just for your note, this document is the note
for the meeting in September 2020 that we went to
earlier, the briefing note which sets out matters which
would have been discussed at that meeting. Not the
minutes, I should say, sorry, the briefing note
SIR WYN WILLIAMS: Sorry, Mr Stevens can you repeat that?
MR STEVENS:
2020--
SIR WYN WILLIAMS: Yes.
MR STEVENS: -- and you asked a question about the timing of
it.
SIR WYN WILLIAMS: Can you just give me the reference to
that, and then I can crossreference it in my note.
MR STEVENS: Yes, of course. It is BEISO000961.
SIR WYN WILLIAMS: Yes, fine. I've got it. Thanks.
MR STEVENS: So if we go, please, to page 10, we see what
was then the "Historical Shortfall Scheme Update
20 August, (Updated Version from 25 August)":
"Closure of Application Window: The HSS application
window officially closed on 14 August ..."
150
Earlier we went to a meeting in September
A. Yes.
Q. —do you remember that? Do you recall why it took four
months to resolve the funding issues?
‘A. I think this is going to be a not very attractive answer
but four months is not particularly slow, in the context
of resolving funding issues. Sort of in between
spending reviews, going back and asking for more money
for things is really difficult. So I sort of say that
by way of context.
The second issue is that, at this point, this is
effectively the first moment at which HMG says, "We are
fully taking on the financial responsibility that comes
with the" - you know, by this point, we knew, right,
that this was not the only compensation scheme that we
were talking about because the sort of other issues were
queueing up behind.
So that was quite an important principal decision
that was taking during that time. So yes, first of all
it's about getting money signed off and being able to
demonstrate why it's the correct number and, you know,
going back and forth on, you know, are you sure it's
really this number? How much money do you really need?
Where are we going to get it from? BEIS, can you find
it from your underspends? Do you really need extra
money from HMT, et cetera?
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But it's also quite a pivotal moment because it's
the moment where, in effect, HMG sort of takes like,
takes a financial liability that, you know, ultimately
by this point was clear was going to be, you know, over
£1 billion in aggregate, sort of takes it on to the
public purse.
Now, by the way, I'm not in any way suggesting that
that wasn't 100 per cent the right thing to do but it is
a swallow, and I think it took a bit of time for the
system to make that swallow.
Could we look, please, at page 28 of your second
statement.
Perhaps I might just add -- apologies, I was just
thinking while you were pulling the document up ~ that
it's also true to say that the kind of obligations that
the Treasury likes least are open-ended, difficult to
quantify ones. So that's why it's a difficult call,
because you sort of knew that the number was going to go
up. And however important, however worthy the case is,
those are not numbers Treasury likes to deal with
because they really make a mess of the kind of bigger
picture of the financial forecasts.
So it's just worth noting that. It's a sort of
it's not the just ~ if it was just a one-off bill and
you knew exactly the size of it, sort of one picture,
153
sort of do is go back and say "Are you sure? Is that
really the number? Are you sure it's not X minus
abit"
Those sorts of negotiations, sort of trying to make
the problem be less of a problem from a finance point of
view, you would expect that same kind of approach here.
Even though, arguably, it's completely inappropriate
here, I think that muscle is just like so deeply
ingrained that that will have been going on as well
If we could look, please, at paragraph 59, thank you.
You refer to an email from Carl Creswell to you, on
26 April 2021, "Update on the ... compensation next
steps", and you highlight:
“It looks increasingly likely to me that we should
consider taking on responsibility for the design and
delivery of the compensation scheme within BEIS, though
that would have large resource implications.”
Sorry, 58, just to orientate us, you're talking
about the question of ownership of OHCS. If we then go
to paragraph 60, please, over the page, you say:
“I agreed with Mr Creswell that this was an issue
What was your position on whether the Department
should take ownership of the design and running of the
scheme?
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but a bill you don't know the size of, that you're going
to be committed to over multiple years in
an unpredictable manner that's just particularly
challenging from a public finance point of view.
Right that the Government took it on but I think
that would be one of the reasons why it took a bit
So do we take it from your evidence that it took four
months because, firstly, it was a big decision; secondly
it was a difficult decision for the Treasury; and,
thirdly, four months, in the grand scheme of things for
the Government, isn't a long time for a funding
decision?
Yes, I'm not sure I would say it was a difficult
decision exactly because I don't really think there was
any sort of meaningful —- it's not like there was
a cohort of people who were saying, "We shouldn't pay
this", it was more just like, okay, really getting to
grips with it, and sort of, as you always do with these
things, kind of hoping that maybe the first number is
too big. You know, when people come to you and this is
true in any element of public finance, whether you're
the Treasury dealing with the Department, or the
Department dealing with an arm’s-length body, or
Director General dealing with the Directorate, people
come to you and say they want X, and the first thing you
154
I don't think at that point in the chronology of sort of
receiving Car's email I would necessarily have
immediately jumped to a position but I completely agreed
with Carl that we needed to look at it seriously and it
was a really important question and it was one we were
going to have to face into and address. That's what
I mean by “I agreed with Mr Creswell that this was
an issue".
If we look at the briefing that follows please, we've
looked at it already, it's BEIS0000990. Have you had
a chance to review this briefing recently?
Yes, I've seen this document recently.
Did you contribute to its drafting?
I couldn't tell you. I wouldn't imagine terribly
substantially. It wouldn't be usual for me to be
involved in the detail of a piece of drafting like this
but I may have commented on it
We see it's for the Secretary of State to
approve/decide, Post Office ownership of criminal
convictions. If we look, please, at page 3,
paragraph 12, which I erroneously tried to go to
earlier, it says at the end
"Whether or not to take on direct responsibility is
a delicate decision, so we would welcome your views, in
light of the following analysis.”
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Is it fair to say that, in this briefing, there
wasn't a suggested course offered for the Secretary of
State?
That's right.
That can come down. Thank you
Outside of this written briefing, did you advise the
Secretary of State on a position to take at any point in
respect of whether the Department should take over the
running of the scheme?
Not that I recall.
We know that, in your documents, it refers to the fact
that the Secretary of State made a decision. Were you
involved in the decision-making process, in the sense of
advising him on that?
Not that I recall, although I couldn't absolutely swear
to it. I mean, what I do know is that, at the time, you
know, perhaps you say this is sort of typical, but this
was another one which I thought was pretty finely
balanced. So I didn't have a kind of - I wasn't
pushing a particular perspective because I think if
had felt very strongly that one answer was correct,
then I would have pushed for the advice to offer
ministers a much kind of clearer perspective.
But, ultimately, I think we all thought that this
was a - quite a difficult call and one that ministers
187
Creswell's email of May 2021 we were clear we needed to
act. This proved difficult to make happen. It took
significant time to find a legal means to pay the
money.”
Which I think you were referring to earlier in your
evidence, when we were discussing a legal basis for
making payments.
Exactly. This was a ~ this is a very hard constraint,
in the sense that the Department literally just cannot
pay out money without a legal basis. It's not a sort of
matter for opinion or judgement, we didn't have a legal
basis as we understood it. We later found one.
Therefore we couldn't make the payment until we had
a legal basis.
And that's got ~ just to be clear, legal basis here
has nothing to do with the legal claims or anything like
that. It's a Parliamentary ability to spend. You can
only spend in line with the authority that Parliament
has given you.
At 66, you say’
“This problem was real (and I think BEIS and HMT
officials did a good job at locating the Appropriation
Act option). It does of course a raise the question why
[His Majesty's Government] didn't just legislate to
create spending authority, rather as eventually happened
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should make.
So from your perspective the decision to keep it with
Post Office was a ministerial decision without
significant steer from the Civil Service?
With advice around sort of the pros and cons, but not ~
I don't think we pushed ministers into one option or the
other.
Could we look, please, at your statement again,
page 31 -- second statement, sorry. At the bottom,
please, paragraph 64, you refer to the GLO scheme. You
say:
“Even at the beginning of my tenure, it was obvious
that the GLO settlement had (while being legally sound)
caught a deep natural injustice, as those involved
received so little money in their pockets are legal
bills were settled and the litigation funders received
their slice ..."
You refer to the scheme being announced.
If we go over the page, please:
“This was, in the early part, probably due to
a conceptual assumption by officials and Ministers that
the GLO settlement had closed the book on this issue.
Obviously this was legally true (the relevant
postmasters had no further legal claim against [Post
Office]) but it was not morally true. But by Carl
158
in 2024 under the Post Office (Horizon System)
Compensation Act. I think the answer comes back to my
point above about the extent of radicalism both
officials and Ministers were contemplating — emergency
legislation of this type is exceptionally difficult to
make happen, and, speaking frankly, requires an enormous
head of political steam to have built up."
Why do you think the sufficient amount of political
steam wasn't there to push through a specific piece of
legislation such as this?
I think two reasons. The first is, as indeed turned out
to be true, a sense that had we really turned over every
stone to make sure a spending power didn't really exist?
So it's obviously in the situation you find yourself
where you think, "Oh, I don't have a spending power,
it's obviously much preferable to find that you actually
do have one, rather than to run a very unusual, very
unusual, piece of legislation designed to create
a power, you know, very specifically around something
like this on an emergency basis".
That's -- you know, it’s very much out of the
ordinary. That doesn't mean it's not good thing to do
but people would always tun to "What do we have, what
do we have, what do we have?"
And I think there was a -- as there often is when
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you're searching for something, you think you might find
it in the first week, and then you think, "Oh, I'm going
to find it in one more week", and you sort of keep going
looking for it and, in the end, we did find it but it
took a while. How could you have shortcut that process?
We could have found it faster but it was pretty obscure,
or we could have just said, "Stop looking, I'm just
going to legislate". But finding Parliamentary time is
really hard and so I think all throughout, not that the
question particularly came up in that form, but I think
Ministers would have probably said, like, "Okay, just
before I go to what will be a very, like, difficult
Parliamentary journey, could you just be really, really
confident that you definitely haven't got one?”
Was there sufficient consideration of the effect the
delays were having on the subpostmasters who were
affected by the absence of compensation payments?
Good question. I think there's probably a bit of sort
of boiled frog going on here, in the sense that you --
each little individual bit of delay to look a little bit
longer, to avoid having to pass legislation, probably
didn't seem that bad. You know, you always think, "Oh,
it's worth looking a little bit more, it's worth looking
a little bit more, it's worth looking a little bit
more". Each marginal extra bit of time makes sense and
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Office] can demonstrate satisfactory control. Payments
would be made by BEIS following a shareholding approved
budget.”
So what you're referring to here is withholding the
network investment and network subsidy payment because
the Department's position was that Post Office hadn't
got control of its litigation costs; is that fair?
Yes, litigation costs meaning payments to lawyers.
Would you accept this was quite a drastic step to take
in terms of the levers that you can pull, withholding
payments to Post Office?
Yes, and only done after, shall we say, exhausting
persuasion as a tool. It is worth saying that, of
course, before we did this, we did analyse whether it
would actually sort of cause an immediate operational
challenge to POL, and it we didn't think it would.
Can I just pause you there. My question is: did you
ever consider doing something similar to put pressure on
Post Office to increase the efficiency with which it
dealt with the applicants to the various schemes?
No, I don't remember that being proposed.
Why not?
I don't know why people didn't propose it to me.
Why did you not consider it?
Indeed. Sorry, I just thought it was important to
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all of those little ones are manageable from
a postmaster point of view.
But when you look at how long the whole thing took
in aggregate, you say, "How can you have taken so long?
You should have done something completely different at
the start”.
But it doesn't -- the problem doesn't arrive at you
in that form. You think — you constantly think you're
about to find something
MR STEVENS: Sir, that’s probably a good time to take the
aftemoon break. If we could come back at 3.30.
SIR WYN WILLIAMS: Yes, certainly. Fine.
MR STEVENS: Thank you, sir.
(3.17 pm)
(A short break)
(3.30 pm)
MR STEVENS: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you
MR STEVENS: Thank you, I'll carry on.
Please can we bring up BEIS0000975. We see this is
a letter from Nick Read to you, dated 29 September 2021.
At paragraph 2, we see it says:
“However, on account of the management and controls
of [Post Office's] litigation costs not being adequate,
I am unable to release the payment due until [Post
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clarify. I don't know. Ultimately, probably, because
we never quite got to the point where there was
resistance from Post Office. So I would say, on legal
costs, by the point of this letter, there'd been a long
period of debate around it, and certain people on the
Government side, in both the Treasury and UKGI, felt
really strongly about this point, and felt they were
just never ever sort of breaking through and getting the
right traction and Post Office's position at the time
was like sort of resistive, as in, "We have done all we
can, there is no more. We are not doing more". And so
there was a kind of sufficiently clear clash to make
that feel like an appropriate move
{don't quite remember on pace ever reaching that
point where you had a sort of an ask and a resistance.
Itwas more like ongoing pressure, ongoing movement. It
got a bit better, it got a bit better, it got a bit
better, and so there was probably never quite like the
triggering moment where that sort of, like, specific
intervention felt like the right thing to do. That's my
best answer, although, as I say, it's always hard to
say, you know, if something didn't come up why it didn't
come up but that would be my best interpretation.
Q. Was the reason why the Department did not run into the
resistance as you've described, because it simply didn't
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push Post Office hard enough on the compensation
schemes?
I think it was probably more like, let's say on HSS.
during those relatively early days, you know, the scale
of the response set up in Post Office wasn't robust
enough as discussed, because they had underestimated the
scale of the challenge. But, as it became clear, they
were moving. It's not like the dynamic was we were
saying, "Get a move on, make this happen”, and the Post
Office was saying, "We don't agree, we don't think it's
important. We're not trying”.
‘They were saying, "Yeah, we're scaling up the team,
we're getting going, we're putting this in place". So
there was a sense of responsiveness. It was ongoing,
you know: you push a bit more, you get a bit more; you
push a bit more, you get a bit more. But I didn't feel
the Post Office was not responsive to asks. They
couldn't always enact them because sometimes you can't
kind of flick a switch and make something happen.
overnight. But they weren't kind of rebutting or
denying them, if that makes sense.
If we look, please, at BEISO000967. This is a letter to
you from Lisa Harrington, Chair of Post Office
Remuneration Committee of 4 October 2022. We see:
"... Lam writing to you to apologise for the
165
the STIP payment?
Yes, on the basis that it would have been approved in
the first place, had it been asked about in the proper
way by the Post Office, and the fact that a serious
mistake was made in governance in not asking for that
permission shouldn't ultimately be a reason not to do
what we would have done in the normal course of business
in terms of approving a ~- what is ultimately really
a Post Office decision about the STIP.
Did you have any similar meetings with members of the
Post Office Board to test Post Office's approach to the
compensation schemes?
No, and I'd like to say why this meeting took place,
because I think it’s important to understand. This
wasn't a meeting that took place because I thought, or
any of my team thought that the STIP was ultimately
a really important and strategic issue. It's because
failure to comply with your duties under Managing Public
Money and to do what's described here, that's the right
language, is a breach in Managing Public Money; it's
a really serious error in compliance.
Now, in this case, it's actually not that big
an error, right? I mean, in the grand scheme of the
things we're talking about this is, in my view,
an insignificant matter in the big picture, but the fact
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situation we find ourselves in regarding Managing Public
Money and the payment of the CEO's Short Term Investment
Plan."
Further down, it effectively says that the CEO's
STIP payment was paid without shareholder approval; is
that broadly the issue?
Yes.
That's been raised directly with you to deal with
because it’s a matter of Managing Public Money?
That's right. So it's come to me as Accounting Officer.
Could we look, please, at WITN11520201. This is
a readout of the call you had with Lisa Harrington on
this issue. The email is sent on 28 October 2022. If
we go to the bottom, please, it says that:
"SM [you] noted that if we looked at this cold,
without breach, the likelinood is we would've approved.
However noted that it will be tricky navigating
ministerial approval.”
It discusses issues of flight risks and then
“Suggested next steps", right at the bottom, it says:
"UKGI & BEIS to rework advice for ministers around
the retrospective approval ~ will need careful
handling.”
Do we take it from this that your position was that,
the Minister should be guided to retrospectively approve
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that an arm's-length body commits a breach of Managing
Public Money, I can't remember ever seeing it. And
I would absolutely expect, just as a matter of course,
that that would come with a letter of apology and
a personal meeting in order to apologise, frankly to
sort of put on record that the seriousness of the fault
had been recognised and that systems had been put in
place to make sure it didn't happen again, not in
relation to the STIP payment but in relation to the
bigger picture of -- back to the sort of regularity
issues we were talking about earlier — you just can't
have public bodies ignoring or flouting kind of core
rules of how public money is administered.
So, you know, the fault itself is ultimately
a relatively insignificant one in the big picture but
the fact that any fault of this type would take place is
a really serious matter and it's kind of
a disciplinary-type affair and so you're bringing in
a particular kind of energy, which is you are meeting
the Accounting Officer, this is kind of a moment of
formality, I would say,
You were the Permanent Secretary during a period of time
in which this Inquiry held compensation hearings; is
that right?
Yes.
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You were aware of various criticisms that had been made
against the Post Office and the Department in the way
the schemes were being funded and run?
Yes.
Why was that not of sufficient importance for you as
Permanent Secretary to meet with Board members to
discuss those matters in particular?
Well, I did meet with Board members. I met regularly
with the Chair. So that was a normal part of the course
of doing business and those were exactly the sorts of
things I would discuss regularly with Tim Parker. And
I met with the CEO, as well, so I was engaged in all
sorts of different ways.
My question was a specific meeting, such as this, set up
to discuss compensation schemes in particular?
Because the nature of this meeting was the right person,
sort of the offence was an Accounting Officer offence,
if you see what I mean. So I was the channel that this
needed to go through. So I was the appropriate
escalation point for this kind of issue. There were
a whole series of different bits of governance going on
around all of the various issues that came up with the
Inquiry, including the Inquiry itself, very regular
ministerial contact — regular contact with the Board
This was sort of quite a specific and different channel.
169
the outgoing Chair, setting out the strategic priorities
You say you attach that letter. You are, in effect,
asking him to take over and continue the work that you'd
set for Tim Parker; is that fair?
Yeah, with a particular focus on the three points that
I specified below.
Those three points that you specified below include:
“Effective financial management and performance,
including effective management of legal costs to ensure
medium-term viability."
I understand your evidence is that, when you say
“legal costs" you're referring to litigation costs,
namely the costs Post Office pays to its lawyers rather
than compensation payments?
Yes, that was very well understood between us and the
Post Office at the time.
Could we look, please, at the letter to Mr Parker which
you refer to, which is BEISO000984. I think it's
undated on this copy but in your statement you say this
was sent on 23 May 2023. If we could go to page 2,
please
It can't have been sent in May 2023.
Sorry to intervene, it must be 2022. Sorry, that's.
an error in my ~~
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I wouldn't have usually felt this was a normal approach
to an, you know, important issue. I would normally take
an important issue to the Chair, the CEO, sort of more
in the course of an ordinary series of meetings, rather
than have a kind of Accounting Officer censure moment.
I want to turn to one of those meetings, please, and
that's the meeting with Henry Staunton, which is
predominantly the focus of your first witness statement.
You say in your first statement, we don't need to bring
it up, page 6, paragraph 17, in response to the
allegation well known to the Inquiry, you say:
"I never told Mr Staunton directly or indirectly,
expressly or by implication, that Post Office should
stall on compensation or otherwise delay or reduce
‘compensation payments to subpostmasters. I did not say
anything that could sensibly have been understood to
convey that implication.”
That's completely correct.
Can we look, please, at BEIS0000607. This is your
letter to Henry Staunton congratulating him on his
appointment. If we see at paragraphs 2 and 3 you say:
“Each year, I write to the Chair to set out the keys
strategic priorities that BEIS, as sole Shareholder,
would like [Post Office] to focus on over the coming
12 months. Earlier this year, I wrote to Tim Parker,
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No probs.
Page 3, please. This is under the heading on the second
page, "Resolving historical litigation issues", and, if
you can go further down, it says at the bottom, we will
see
“Its right that these issues receive the attention
they require to ensure their swift resolution. For
{financial year 22/23], POL should ..."
Then there's an indented paragraph, if we could just
go down slightly. Thank you. The last entry there is:
“Challenge [Post Office] Management so their
activities are reflective of our shared objectives for
compensation: to see postmasters are treated with
consistency and they receive swift compensation that is
fair for claimants and taxpayers.”
What do you mean by fair for claimants and
taxpayers?
I think this probably goes back to what we talked about
earlier about value for money. I think you'll see it in
some other letters written to Tim at other times that
talk about value for money and, ultimately, this is
about saying we need you to pay full, fair and prompt
compensation but that should be done without wasting
money, without wasting money on lawyers, without wasting
money through fraud and error, and compensating
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fairly -- generously, fairly, appropriately.
But that clearly is different from a process that
starts from the premise of, you know, taxpayers have no
interest here whatsoever and it doesn't matter how much
you spend.
Q. How do you read "generously’ into that paragraph?
A. I'msort of paraphrasing to say that we -- our
objectives for compensation were for it to be full, fair
and prompt. It is consistent with that to care about
the interests of taxpayers and to want full and fair and
prompt compensation to be delivered in a way that
protects value for money, ie in a way that makes sure
that you're not wasting money as you do it, just as any
other Government goal. You know, if you want to build
a power station, build a nuclear power station, let's
say, you should do that in a way that, you know, is fair
for taxpayers but it should still be safe and it should
still be operational; it should still be full and fair.
Q._ MrStaunton evidence was that, effectively, this was, as
he took it, a message to say that the Government did not
want compensation to be overly generous; would you agree
with that?
A. No.
Q_ Whynot?
A. Well, I don't-- I'm shocked that, if that is what he
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doing it.
Q._ Can we look, please, at the briefing for your meeting
with Henry Staunton. It's —
SIR WYN WILLIAMS: Before we do, Mr Stevens, the paragraph
that follows that, Ms Munby, and it's use of the word
“balancing”, if you read that sentence to yourself.
A. Yes, I've looked at that and reflected on that. I'm not
sure that "balancing" is a good word to use in this
context and, as you can imagine, of course I signed the
letter and I stand by it but I didn't draft every line
myself, and as I sort of look back on it, I think sort
of “balancing” isn’t really the right way of talking
about this, certainly, when it comes to fair
compensation.
I do think that balancing has some role when it
comes to pace and swift compensation. It gets more
complicated in that case because you can go faster at
greater expense, or not. And that’s something that the
National Audit Office talk about in their Lessons
Learned Report. When it comes to full and fair, it's
quite straightforward to say that isn't a trade-off with
value for money or with faimess to taxpayers. I think
it's in pace of delivery that you start to see that
balance maybe begin to bite. And I think that’s,
probably -- the use of "swift" here I think indicates.
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thought, he never raised that with us at any point. So
I don't agree that he has that reading, although
I understand that is his evidence. And that isn't what
we meant in writing it because, if we were stepping back
from the ministerial objective of fulfilling full and
fair and prompt compensation, we would have needed to
say so. Nobody ever told us to step back from that.
Nobody ever indicated we should step back from that.
There wasn't any advice provided, either to me or to
ministers, that we were stepping back from that. So
there was ~ that wasn't our intent in writing this and
I don't believe that's how it was read by those
receiving it.
Q. Just so I understand your evidence: is your evidence
that “full, fair and prompt" also means generous
compensation?
‘A._No, I don't think I'm saying that. I'm saying that
full, fair and prompt compensation should be delivered
in a way that is fair for taxpayers but that doesn't,
mean that it should not be full, fair and prompt
“Full, fair and prompt" is sort of the first
requirement. Within that, like everything else,
whatever you're doing in Government, you want to do it
in a way that is as fair as possible for taxpayers,
which essential means don't waste money while you're
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that’s what's running through the mind of the person
drafting it.
SIR WYN WILLIAMS: Yes, all right. It's those two, the
indented last paragraph and that paragraph, which led me
to ask questions both of Mr Staunton and Mr Cameron
about whether they thought that issues like value for
money were being taken into account in terms of
individual payments or offers, rather, to postmasters,
and they both, at least as it seems to me at the moment,
thought that might be happening. Now, you wouldn't know
what was happening in the actual administration of the
HSS and the overtumed convictions process, obviously.
But do you think that those words in that letter might
have contributed to that sort of thought process?
A. If they did, I'm sorry. That's certainly wasn't the
intent in writing the letter. I think it's just maybe
useful to note that you're back to Managing Public
Money: it says very explicitly that value for money is
always a consideration, including in compensation
schemes. So, from my perspective when I was reading
either this drafting or the drafting in other letters,
I wouldn't have felt there was anything particularly
unusual or radical in mentioning value for money in the
context of a compensation scheme. Indeed, that's what,
Managing Public Money, which is sort of The Bible when
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it comes to managing these things, itself does. So I'm
reflecting that overall point of view of Government as
a whole.
I think there is a very big difference between
saying, you know, looked at as a whole, you should
deliver compensation in a way that is value for money
and doesn't waste money. That shouldn't be, but
I totally understand what you're saying, Sir Wyn, that
it may have been, but that shouldn't be taken to imply
that an individual claim should be settled at anything
less than full and fair, which was the ministerial
intent throughout.
SIR WYN WILLIAMS: Well, that was my last question, really.
Whatever may be said about those couple of sentences in
that letter, so far as you're concerned, when you were
Permanent Secretary, did your political masters ever
deviate from the policy objective of delivering full,
fair and prompt compensation?
‘A. No, I think they and we and the Post Office could all be
criticised for whether that was always, you know,
implemented in full. There's lots of debate about had
about that but in terms of intent, absolutely not.
SIR WYN WILLIAMS: All right, thank you very much.
MR STEVENS: Just one point arising from that. When you
were thinking about -- I think you said, “full fair and
477
briefing for your introductory meeting with Henry
Staunton. If we scroll down, please, we see the agenda.
We have, first, the CEO pay, then NED appointments,
finances, recent correspondence, and so on.
At page 4, please, if we go down, thank you, we see
under 4, which was “Recent Correspondence", we have
references to the Overtumed Historical Convictions and
Historical Shortfall Scheme, with some briefing on that.
Why was CEO pay at this stage at the forefront of your
agenda in the briefing, rather than the compensation
schemes?
‘A. Because Mr Staunton had just written to the Department
about it.
Q_ So it was reactive, basically to ~
A. Yeah, just this is an initial meeting with somebody.
haven't that anything from him so far, if you see what
I mean. It's a new slate but the one interaction we
have had is a letter from him to the Secretary of State
asking about CEO pay. So it would be just normal to
respond to that.
It's also perhaps worth saying that that’s an agenda
prepared for me by the team. You'll note, having seen
the read-outs from the meeting, that I didn't take the
agenda as a gospel of exactly what would be covered in
the meeting. I just think it's worth saying that.
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prompt”, when you refer to "fair", by what standard
would you refer an offer to or compensation to, to
determine whether it was fair?
Well, I mean, ultimately, I think that’s a question that
goes to ministers in what their intent was, just to be
clear. It's not for me to be sort of the arbiter of
fair. You know -- and indeed, I think the schemes, if
you look at what HSS says, it goes so far as to say that
fair may be greater than the sort of legal obligation
but it doesn't particularly give an exact, precise
definition of "fair". I think it uses ~ I'll get the
wrong exact expression -- but I think it uses something
like “fair, fully in the round, looking at everything
and bringing it altogether into a rounded view’.
"Fair" certainly means at least what you're legally
entitled to, that's probably a floor, as it were, on
“fair". But I don't think it defines exactly what
“fair" is. You would think that that would be sort of
set by kind of the moment of approval of the sort of
terms and arrangements of any individual scheme: you
know, what did "fair" mean in that context; you know,
“fair" means something different when you're talking
about overturned convictions than when you're talking
about shortfalls, for example.
Could we look, please, at BEIS0000631. This is your
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Okay, let's look at the readout then. It's BEIS0000752.
If we go to the bottom, please, this is the read-out
prepared by the Department, and we'll come to the first
sections in more detail shortly. As I understand your
evidence, but tell me if 'm wrong, the discussion on
‘compensation you say is further down. If we go down,
please.
Not quite, no. Actually, we didn't talk about
compensation at any great extent in this meeting.
Okay, that, I take that point and that's your evidence
on that, but where it says:
“HS mentions target ref in Inquiry hearing -- wasn't
looking for apology but wider point around being synced
up and acknowledging where each others roles lie. Was
keen him and Sarah strategically aligned where
{possible].”
Was that a discussion about compensation, something
that had been said in the Inquiry hearings regarding
Post Office meeting targets?
That's right. That was — I believe it was either
a BEIS or UKGI lawyer misspoke and suggested that
100 per cent was a target rather than an aspiration, and
POL were upset because it made them look like they
hadn't met the target when, in fact, they had met what
was the target, which was 95 per cent. So it was
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a relatively minor point in the grand scheme of things
but Post Office felt we had, you know, unfairly
represented them in front of the Inquiry and that was
a fair point. It was a mistake and we apologised for
it
Just to clarify, is your evidence that that was really
the extent of the discussion on compensation?
Yes.
Why did it play such a minor role in your first meeting
with the Chairman?
Well, I think there's probably two reasons for that: one
is -- and they sort of go one on each side, right? So
the first question: why did Mr Staunton not raise it as
a major issue with me? That would be a question for him
but he didn't. So it wasn't like I was responding to
any prompting around it.
My question is to you about your reading ~
Understood. So why didn't I raise it with him? It's
quite specific to the context, actually. So he had just
been recently appointed and I'd been involved in the
appointment process. And I was actually really at that
point very pleased with this appointment because
Mr Staunton had real hands-on experience, particularly
I from his role at WHSmith, in helping turn around
performance at a business that -- of course no business
181
its viability and future. And I was really worried
about that and I really thought Henry himself ~
Mr Staunton, I'm sorry -- would have a lot of value to
bring to it. And that was the conversation I most.
wanted to have with him.
So you most wanted to have a conversation with him on
commercial issues. We saw earlier in a letter, the
letter to Mr Parker and the letter to Mr Staunton, that
achieving settlements was a key strategic aim for the
Post Office?
Yes.
Did you see, as part of your role, ensuring that the
Chair took that strategic objective seriously?
Yes, I didn't use this as a meeting to run through the
strategic objectives for the Post Office. You can see
there isn't a sort of "Let me recap my letter", that
wasn't how the meeting went. I would have assumed that
he had sort of taken those points as read, they'd been
formally transferred over. This was meant to be more of
a—I don't mean off the record in a formal sense but,
you know, just a bit more of an informal chance to
exchange views about the situation, for him to offer me
some perspective and for me to offer him some advice as
someone new into role.
If we look at the start of the note, please. It's the
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is the same as Post Office but WHSmith has some quite
obvious commonalities with the Post Office.
And of the various perspectives that I wanted to get
from Mr Staunton particularly at this point, I was
really interested in what would a serious, experienced,
commercial leader, who had like sort of done a similar
kind of a job before, in turning around the performance
of a really challenged high street business, I really
wanted to understand his take on that and, in my mind at
this point, correctly or not, I imagine that
Mr Staunton's personal focus would be, in very
significant part, on the commercial tumaround of the
Post Office because that was his experience and that was
what he was bringing to bear.
So he was very new in role. At this point, I could
have asked and enquired lots of things about the
‘compensation work but I think my perception would have
been kind of he needed a bit more time on that to really
‘come up the curve. Whereas I was, to be honest, hungry
for what he was going to say about the commercial
performance of the Post Office because, as you'll see
from the briefing documents that run up to this meeting
as well as being concerned about compensation payments,
we were acutely concerned about the strategic and
financial position of the Post Office as a business, and
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bottom of page 1. It says that:
"SM flagged that the relationship and funding {with
the Treasury] is difficult, their view will always lean
towards the ‘begging bow!' type scenario, a dynamic
worsened by Horizon/Inquiry costs.”
What are you referring to by the "begging bowl"?
There had been a long goal of Government, including
Treasury but Government as a whole, that Post Office
should move to being self-sustaining from a financial
point of view, ie that it shouldn't be reliant on
Government subsidy. We can come to discussion about
whether that was a realistic or achievable goal but that
was the stated position of Government. And, in that
context, Treasury in particular, throughout this period,
long pre-dating this conversation, Treasury in
particular had a long record of basically being
sceptical of Post Office's claims that it needed
Government subsidy, and believing that what Post Office
should do was focus on improving their own performance,
sort of getting their own house in order, strengthening
their financial and strategic position, so that they
wouldn't need Government subsidy. And I think a real
sense that there was a risk of essentially sort of
creating easy money, and, you know, if you create a sort
of path of easy money for a corporation, you lessen
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their incentive to improve their own performance.
That perspective, that's what I'm getting at with
the begging bowl. They were always sort of asking for
more money. That was how Treasury saw Post Office when
it came to asks for subsidy. They believed those
subsidies should be going to zero and the Post Office
should be weaning themselves off those subsidies and
they were -- they were sort of ~ "irritated" is not
quite the right word. I can't bring the right word to
mind but they were frustrated by the constant asks for
more and more money.
I'm going to have to stop you there, given the time.
I've got that point.
The “dynamic worsened by Horizon/inquiry costs",
where it says Horizon costs, is that referring there to
settlement costs, namely costs associated with the
fallout from the Horizon issues?
I couldn't be 100 per cent sure. It could equally be
referring to Horizon replacement costs.
It would have been likely, wouldn't it? For those to be
together, it's more likely, would you not think, for
“Horizon/Inquiry costs" to refer to (i) the costs of the
Inquiry but that arises from the Horizon issues and (ii)
the costs associated with the compensation that arises
from the Horizon issues?
185
trade-offs within budgets, you've got to manage subsidy
control legislation and, specifically, HMT at the time
had very clear policy that they wouldn't provide more
subsidy to the Post Office in the absence of a long-term
strategy. And we didn't have a long-term strategy.
So what I was describing was a set of difficulties
about securing operational subsidy, I never said
anything both difficulties of securing money for paying
compensation and Mr Staunton himself never mentioned any
difficulties with funding for compensation. Indeed, as
you rightly point out, the issue of compensation was,
broadly speaking, not discussed, which you can criticise
for other reasons but it is inconceivable that you could
have understood me to be saying "Don't spent money on
compensation", when what I was saying, as is recorded in
the read-outs, is, "I'm going to try and get you a bit
more money to deal with these really big operational and
strategic challenges you're facing but I want you to
know it's not that easy to do that because of these kind
of practical difficulties of getting money over the
wall", none of which apply in the case of - like,
subsidy control, for example, isn't an issue in the case
of the compensation money.
Can we look, please, at Mr Staunton’s note of the
meeting. It's BEISO000918. If we go to the bottom, it
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Not necessarily, because Henry had just talked about
what the big financial pressures were on the Post Office
and he'd talked about Horizon replacement, and he'd
talked about rising Inquiry costs and he's talked about
telephony. He hadn't mentioned compensation costs
because, of course, those came from a different budget
and were not really part of this dynamic that we're
discussing here.
Mr Staunton's evidence was that effectively the message
was that he could not expect significantly more money to
be forthcoming from the Government, even if he thought
the remediation schemes needed it; would you agree with
that position?
Absolutely not. I do not believe that is a plausible
thing you could take away from the conversation we had
in any way.
Why are you so confident on that?
Because I don't think that explanation makes any sense,
given the conversation that we had. The conversation
that we had was about my efforts to try to secure more
money for the Post Office. So if you go further down in
the note, we're discussing how difficult it is,
basically this scenario of HMT don't want to give the
Post Office more operational subsidy, and I'm talking
about why is that difficult. You've got to make
186
says:
"She also referred to ‘operational’ issues colouring
{the Treasury's] thinking. (‘Trust' in the [Post
Office] Board and management has not been high). They
could see this is another ‘begging bow!’ [so you see the
same words used there] request from the [Post Office].
I said the funding issues revolved around poor decisions
made many years ago wrt Horizon and related legal
issues."
Do you accept that's an accurate note of the
conversation that happen?
I think it’s just further saying what we were talking
about there by Horizon and related legal issues. If we
go back to the beginning of the conversation,
Mr Staunton had laid out these three big new difficult
cost pressures that the Post Office were dealing with,
‘one which I think was sort of smaller and less relevant
was the telephony issues. One was the Horizon
replacement system, and one was the costs of responding
to the Inquiry, ie the costs of gathering the evidence,
working with the lawyers, et cetera. Those were the
three points that he laid out at the very beginning of
the meeting and he's playing back two of those here
towards the end.
25 @. So just so I'm clear on your evidence, your evidence is
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that what was discussed was, amongst other things, the
cost of replacing Horizon, was that -
Yes.
Yes? The costs associated with the Inquiry?
Yes.
But your evidence is compensation itself wasn't
discussed?
Yeah, I mean, it might be worth going in to the bit in
this note where those three points are laid out because
it makes it clear.
We can read them out, that's fine but just so we're
clear?
Absolutely, yes.
We have your evidence, thank you.
That document can come down. Thank you.
What are your views on Mr Staunton's competence as
Chair, while you were Permanent Secretary?
had very little interaction. We overlapped by a very
short period between his appointment late in 2022 and me
moving on to the Department for Science, Innovation and
Technology very early in 2023. So I think it would be
a totally unfair to draw any conclusions about his
performance as a chair during that period.
I want to look at a couple of points on what you say
about improvements in Post Office governance. We don't
189
In your view, that had been resolved by the time you
finished as Permanent Secretary?
No, and, if I may, I'll just expand very briefly on
that. We had had for some time work running, following
the settlement at SR2021, which was actually condition
on carrying out a review of POL's long-term ~ or rather
HMG's long-term strategy for POL, which is not quite the
same term as POL's long-term strategy, and we had done
a bit of work on that, including getting to the point
towards the end of 2022, ie briefly before that meeting
with Mr Staunton, just to put it in schedule, as it
were, of trying to go to right round across
Government -- that's the sort of approval process by
which you get Cabinet sign-off -- right round to launch
a formal, a more formal review of the long-term
requirements of the Post Office by Government.
‘And ministers had declined that opportunity and said
“No, now is not the right time”. So I really recognise
this complaint. I was very concerned, I was talking
earlier about my level of concem about the sort of
financial viability of the Post Office going forward.
Of course, that was like deeply associated with a lack
of clarity about what the Post Office was in the
long-term, there for.
And at the time -- and this is reflected in what
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need it up but paragraph 20, page 11 of your second
statement you say:
“I think Post Office's internal governance was very
much improved but still not adequate.”
I think that's by the time you left; is that right?
Yeah.
Can we look, please, at POL00446476. This is a Post
Office Limited Board Effectiveness Report, dated 19 June
2024, so you wouldn't have seen it in your role as.
Permanent Secretary, but have you had a chance to review
it in preparation for the Inquiry?
Yes, I've seen it after being provided with it by the
Inquiry.
Can we look, please, at page 8. We've got some key
findings there, including
“Lack of clarity on the purpose of the Board, with
the Shareholder relationship inhibiting the Board's
effectiveness due to perceived interference in [Post
Office's] work and limited visibility around the
longer-term funding and objectives of the organisation.”
Is that a problem of which you were aware as
Permanent Secretary, namely a query over the longer-term
funding and objective of the organisation from the
Department's perspective?
Absolutely 100 per cent, yes.
190
I said to Mr Staunton about the sort of we need to
hobble on, we need to find a way of managing under the
strategic steer we already have because, in the
short-term, ministers were not ready to carry out the
kind of full review of Post Office's roles and
responsibilities that was really needed in order for
Government to more clearly define, you know, not just
the branch footprint but the services provided, the
nature of the financial relationship. All of that
needed fundamental refresh, in my view, but it was
difficult to get ministers to sign off, I think partly
because of frankly the political toxicity around the
whole issue, and the fact that we knew that any review
sort of regardless of what it ended up concluding about
the corporate structure of the Post Office.
And I know there have been all sorts of proposals.
about, you know, different kinds of mutualisation, and
so on but, whatever you did, you faced quite
a fundamental challenge that you probably either needed
to really seriously increase the level of public subsidy
to the Post Office, which had its own challenges,
politically, or be prepared to say that you needed many
fewer Post Office branches, which is also a really
difficult thing to say politically and incredibly
difficult for postmasters as well, who were, of course,
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under enormous challenge during this period.
And I think ministers were sort of looking at that,
really, really difficult choice and saying, "Now isn't
the time, let's get through the Inquiry, let's get
through the compensation processes and let's come back
to this question in due course".
But that did leave a period of really challenging
ambiguity for Post Office and I think that's one of the
reasons why, ultimately, we did end up with, following
spending review 2021, a series of what you might
legitimately describe as sort of short-termist funding
interventions, giving over some more money to Post
Office to manage the Horizon replacement programme, to
deal with the rise in Inquiry costs, et cetera. You
know, sort of dealing with the problems as they arose
rather than fundamentally refreshing the strategy and
rebuilding the organisation towards that new strategy.
MR STEVENS: Thank you. That document can come down
Sir, I don't propose to ask any more questions.
I'l see if there's any -- yes.
Mr Henry and Ms Patrick have asked for five minutes
each, sir.
SIR WYN WILLIAMS: Fine. I look forward to their accuracy
in estimation.
Who is going first?
193
today from Mr Recaldin that such practices were
occurring in your successor Department from January this
year for some months. He said, among other things, and
the transcript, I don't think, is on Relativity but I'm
going to read out a little bit to you so that you're
familiar with it
J omit words but this is at page 48 of 86, beginning
at line 11, page 191 in the internal numbering:
"... im OC there are many opportunities, as
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 emphasise the words “hold out”:
“Iwas extremely uncomfortable with that, and
I think I'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.”
Then I omit words and this is the facing page,
line 7, 192:
"... that was the moral dilemma that I was facing
and they made it clear to me, absolutely crystal clear,
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MRHENRY: I'm being forced to go first by Ms Patrick, so
I shall go first, sir.
SIR WYN WILLIAMS: I've never known you to be forced to do
anything, Mr Henry, but there's always a first.
Questioned by MR HENRY
MRHENRY: Thank you, Ms Munby.
As Accounting Officer/Permanent Secretary until
6 February 2023, did you ever cancel an interim payment
‘owed or even due to a subpostmaster?
A. Not that I remember.
Q._Did anyone do so on your behalf, cancelling an interim
payment agreed with a subpostmaster?
A. They may have. I'm not sure what “on my behalf" means,
if you see what I mean, certainly not at my request.
Q. Certainly not at your request but, obviously, under your
aegis because, of course, you're the Permanent
Secretary, you're the Accounting Officer. Do I take it
from your answers that you were unaware, and I'm not
suggesting necessarily that this did occur on your watch
but that you -- I'll rephrase it, particularly since
I've got very little time?
Did you ever become aware of interim payments being
subject to a moratorium?
A. I don't recall that,
Q. Right. You see, we've heard evidence yesterday and
194
'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.”
Now that, coming from Mr Recaldin today and
yesterday, is an extraordinary state of affairs, you
would agree, in your successor Department, to cancel
agreed interim payments that had been notified but would
now not be approved because the Department was holding
out for a full and final settlement? Notice the absence
of the word "fair". That would be an extraordinary
situation developing from January this year. You must
accept that?
A. I mean, I haven't heard any of that until just now, so,
you know, I say ~
Q._ So what's your reaction?
‘A. Myreaction is that doesn't sound right, as you've just
put it to me there. The only thing I've heard of that's
similar, so I think the only thing I can sort of draw on
from my experience, is in the very early days of HSS,
I do remember there being discussions about the merits
of introducing interim payments or not. And one of the
arguments that was made at the time, and probably one of
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the reasons why we were, in my view, too slow to
introduce interim payments in the first place, was about
the question of whether kind of efforts to provide
interim payments would actually delay making final
payments and that that would be bad for postmasters —
Q. Or would it actually, worse than that, expedite
settlements at an unrealistically low level because
postmasters had been starved of cash, it was as if they
were in a famine with the purse strings being tightened
against them to force them into precipitate and
unrealistically low settlements?
‘A. I mean, the language that you just used in describing
the evidence just received, it does sound closer to that
than to -- you know, I'm making a balance of is
a smaller payment earlier or a bigger payment a bit
later better.
Q._ It does, doesn't it? Now, you know how the Civil
Service works. Who would have given the order to cancel
interim payments, even though those, most reprehensibly,
which had already been agreed?
A. [don't know. It-—
Q. Well, now, I must ask you to reflect very carefully on
the answer you have given. You know how the Civil
Service work. This is your successor department.
I realise that it's not the same department that you
197
example.
I'm not going to go back over that, and I know
you've said you can't really comment on things that
happened after you left your post as Permanent Secretary
and you don't want to comment necessarily on how the
change of approach came about. But I'd like to look at
a couple of your observations in your second witness
statement, if that's okay.
You don't have to tum it up. I'll read it for you
and you can trust me that I'm reading it from the page.
‘A. I know my witness statement reasonably well
Q._ Indeed. At paragraph 72, you say:
“In the round, looking back at events, an initial
underestimation of the scale and depth of the challenge
in truly delivering ‘redress’ was then followed up by
a plausible and incremental set of decisions on how to
deliver full and fair compensation. With those
decisions focused on deliverability, fairness,
appropriate use of public money, and good governance,
justifying and building up the response piece by piece.”
Just stopping there, you said something a little bit
like the "boiling frog" scenario.
A. Yes.
Q Yes.
"Such considerations are the mainstay of Government
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were Permanent Secretary of but can you help us please?
A. It could have come from a few different places --
Such as?
A. It could have come from the -- one of the oversight
bodies. It could have come from one of the officials in
©
the chain at, you know, a member of the senior Civil
Service or the Director General or the Permanent
Secretary. It could have come from a minister.
I suppose, in theory, it could have come from the
Treasury because they were involved in governance. I am
not trying to be unhelpful at all, I just --! don't
know much about the case and I don't know ~
Q._ So there's a whole host —
‘A. — therefore where it might have begun.
MRHENRY: Right, I see. Thank you. Nothing further.
SIR WYN WILLIAMS: Thank you, Mr Henry.
Ms Patrick.
Questioned by MS PATRICK
MS PATRICK: Thank you, sir, and thank you to Mr Henry.
Ms Munby, I have very few questions of you. I know
that Mr Stevens has covered quite a lot of detail about
your witness statement and your reflections on when
Government can and can't take a radical approach to
solving problems. We know your witness statement covers
the approach to Ukraine and the approach to Covid, for
198
and we should not leave them behind hastily. However,
had we begun down the path with a deeper and more
complete understanding at the start of the true human
impact of all that had happened previously, I wonder
whether both officials and Ministers might have taken
bolder, more radical decisions earlier, that would have
allowed us to reach towards full and fair redress faster
and with less distress for postmasters."
I just want to ask you, did Ministers, looking back
with your reflection, see this scandal, this scenario,
as a ‘business as usual’ project that could be
approached with ‘business as usual solutions, always
falling back to the usual principles of Government and
public restraint at the initial stages?
A. Broadly, yes, but ‘business as usual’ is a very, very
broad tent in Government, and includes doing absolutely
extraordinary things that are very unusual. So I don't
mean that they thought it was ordinary or
straightforward, or very much like everything else we
were doing. But the distinction I was seeking to draw
in my witness statement was I have seen a few-- very
few, but non-zero — number of things in my roughly five
years in the Civil Service where Ministers have very
explicitly said, you know, from almost day one, "I want
you to put precedent completely aside. I am not
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interested in any of your useful, practical points about
governance or Managing Public Money. You know, just do
it. Make it happen", and have sort of like broken the
frame.
‘And the two examples -- sorry, I know you said, and
don't want to waste time, but the two example where I've
seen that were at the very beginning of the Covid
crisis, as it related to the survival of small
businesses, and, secondly, after Russia's invasion of
Ukraine, as it related to preventing the very
precipitate rise in energy bills for households and
businesses across the country.
When I say "business as usual", I mean not that,
rather than sort of saying it was seen as a sort of in
a box with a load of things in the kitchen sink to be
dealt with in a very ordinary way.
Indeed.
What we can see ~- and I think, taking from your
evidence --is that it was only when ministers were
forced by the political pressure to face up to the
realities of this scandal and its impact on the
individuals concemed, the subpostmasters themselves and
their families, and the impact that that was having on
public consciousness, then it was seen that this was
an issue which needed a truly radical solution which
201
meeting postmasters at various points in this process
and, of course, you know, officials within the
Department and very extensively in the Post Office ~
I'm sure Simon Recaldin talked about the work that he
did on that front,
But I think that the straight answer to your
question is: yes, I think that same criticism is likely
to be true, indeed is true, of the briefings that were
provided to Ministers.
No matter what subpostmasters and those who are
representing them and others may have been saying about
this being the biggest miscarriage of justice in modern
history, and about the impact on individuals who'd lived
for decades, some of them, with the stigma and the harm
that resulted from the events of their prosecution, that
Ministers themselves, at the outset, may not have
appreciated that this was a truly unique set of
circumstances that really needed a radical solution?
I think it is difficult to calibrate when something
moves into that radical space. I'm trying to think of
sort of sensible analogies, but very terrible,
challenging things happen an awful lot in Government,
you know, dealing with, you know, widespread rioting
across the country or, you know, dealing with, you know,
a shortage of prison places. You know, just to take
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stepped beyond those ~ and I'm calling them ‘business
as usual’ prospects, and the underlying principles
behind them.
A. Yes, I think that's a fair summary of my evidence.
Q._ Can we look just at one other section of your evidence.
I just want to look at a part of your evidence on the
briefing that was being provided to you. At the very
earliest part of your second witness statement, you say:
“With hindsight, [you] have two .... reflections.
First, that the briefings were (perhaps unsurprisingly)
typical Civil Service briefings, focused on the facts
and next steps. I couldn't honestly say that they
brought home the ongoing human tragedies at the heart of
this case, and with hindsight I think I should have
personally pushed to meet with the postmasters myself.
Second, I am not sure that these ... emphasised
sufficiently the ongoing cultural challenge at [the Post
Office).”
Now, that's reflecting on the briefing provided to
you. Do you think there was a similar failing in the
briefing that was being provided to Ministers?
A. I think that sort of probably goes almost necessarily,
because there was a great deal of overlap in the
briefings. I suspect, though, Ministers, more
conventionally as part of their role, will have been
202
some examples, say, from the last six months or so.
So the scale of what we're talking about in terms of
kind of outrage, perception, really has to be very,
very, very high indeed. And I think itis true what you
say, but I also just really want to emphasise that that
doesn't mean that Ministers didn't understand that this
was a terrible, horrific injustice, or think that it was
a really important priority to fix. And even within
what I've described as a kind of incrementalist
approach -- and I appreciate that, you know, many would
criticise it but, nevertheless, it did involve
committing, you know, well over £1 billion of public
money, you know, even within that frame, and that was
a-
Q._ Ms Munby —
~ insufficient but serious response.
od
Q. Thank you for your response. I was simply reflecting on
your own evidence that there was a shift in perception.
A Yes.
MS PATRICK: Thank you. I don't have any further questions.
SIR WYN WILLIAMS: Is that it, Mr Stevens?
MR STEVENS: Yes, sir. That's it.
SIR WYN WILLIAMS: Well, thank you very much, Ms Munby, for
making two witness statements and for coming to the
Inquiry to give evidence — well, i's all been this,
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afternoon, although I dare say you may have been here
during part of the morning. Anyway, thank you very
much. I'm very grateful to you for helping the Inquiry
in the way that you have.
THE WITNESS: Thank you.
SIR WYN WILLIAMS: So we'll resume again at 10.00 tomorrow,
Mr Stevens?
MR STEVENS: Sir, I think its 9.30.
SIR WYN WILLIAMS: 9.30. I'm so sorry, you're quite right.
Yes. 9.30 tomorrow morning.
MR STEVENS: Thank you, sir.
(4.37 pm)
(The hearing adjourned until 9.30 am the following day)
INDEX
SIMON DOMINIC RECALDIN (continued) ..
Questioned by MR BLAKE (continued)
Questioned by SIR WYN WILLIAMS
Questioned by MR JACOBS .........
Questioned by MS PAGE .....
Questioned by MR MOLONEY ....
Further questioned by SIR WYN WILLIAMS ......
SARAH ANNE MUNBY (affirmed) .....
Questioned by MR STEVENS ..........000
Questioned by MR HENRY
Questioned by MS PATRICK ....
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MR BLAKE: [10] 1/5I‘all [1] 134/24 150,000 [1] 91/8 24 [3] 96/5 99/1 6‘.
1/7 35/12 39/11 52/7 I"begging [2] 184/4 16 March [1] 5/14 110/6 6.
52/11 52/13 52/17 I 188/5 47 [1] 170/10 25 [3] 80/981/14 —_I6 February [2] 98/19
93/19 95/10 ‘blanket’ [4] 142/14 [18 [3] 85/25 116/20 I 142/11 194/8
MR HENRY: [3] ‘business [4] 200/11 I,119/14 25 August [2] 150/23I6,200 [1] 151/12
4194/1 194/6 198/15 I 200/12 200/15 202/1 I 18,000 [1] 90/13 151/2 60 [2] 72/15 155/20
MR JACOBS: [4] ‘entitled [1] 134/24 ‘9 une (i) 1008 25 May [1] 8/3 600 [4] 72/2 73/4
39/14 50/17 51/1 52/5] levelli 142/2 ] 195 25 years [3] 34/10 3/8 93/7
levelling [1] 142/20 II 492 [4] 195/23 34/12 34/17 600,000 [14] 5/11
MR MOLONEY: [3] _I'Managing [1] 138/22
69/15 86/23 86/13 I"No [2] 195/12 196/1 I 26 [2] 112/8 112/10 I 69/18 69/21 69/22
26 April [1] 155/12 I 70/7 70/16 70/18
MR STEIN: [2] 50/19] ‘operational’ [1 Dd october iM) 96/17
50/22 a 188/2 tonal (1) 2 October [1] 96/11 I27 [5] 20/20 38/11 70/22 70/23 70/25
. 4 . 2,000 [1] 90/18 54/21 112/17 112/19 I 72/10 72/16 72/19
5/14 GSB 9520 I BANS TATHIT I2000-0dd [1] 57/9 2a [4] 153/11 14617
111/20 111/24 112/4 I'redress' [1] 199/15 2.00 [2] 111/23 112/3/28 October [1] 61 [3] 3/13 3/15 3/16
4112/7 121/23 134/14 teeth’ [1] 112/23 [24 LN) 124122 166/13 625 [1] 73/8
134/23 149/15 150/12I"Trust' [1] 188/3 {20,51 3/18 23/5 40/2 I29 April [1] 23/6 I 64 [1] 158/10
450/15 150/19 150/242 2 19001 29 September [1] I650,000 [1] 70/13
162/10 162/13 162/17 20 August [1] 150/23) 162/21 650/625 [1] 73/8
462/19 177/24 193/18) billion [2] 153/5 _I20 February [1] 6/6 66 [1] 159/20
204/22 205/8 205/11 I 204/12 20,000 [1] 5/10 2
MS PAGE: [7] 52/21 I1 July [1] 131/11 I20-year [2] 54/5 3.47 [1] 162/14 ————_____
Ge719 ob/21Gu/28 (1,000 [1] 34/11 61/16 3.2 [4] 32/11 7 October [1] 117/17
69/3 69/6 69/11 4'300/1,400 [1] 95/4. I2007 [1] 43/7 3.3.3 [1] 124/1 72 [1] 199/12
MS PATRICK: [2] 11400 [1] 85/4 2013 [1] 151/2 3.30 [2] 162/11 73 [2] 54/2 54/6
198/19 204/20 1'00 [1] 12/1 2019 [4] 60/10 96/24 I 162/16 75 [4] 91/21 92/2
SIR WYN WILLIAMS:/10 [2] 119/14 150/21 I 97/6 102/17 30 [3] 85/9 86/3 86/5 I 92/12 92/17
[106] 1/6 35/17 37/4 /10 June [2] 76/2 {2020 [15] 98/17 30 June [1] 130/6 I75,000 [27] 78/2 78/4
oy 38/1 safe 30/14) 138/11 112/13 117/17 119/19I30 October [1] 11/21 I 78/9 78/19 80/10 81/3
Be/17 38/20 38722 [10.00 [2] 1/2 20816 I 130/7 134/11 13314 [34 [2] 3/12 1589 I 81/10 85/10 85/15
39/2 39/4 39/7 30/9 I100 [4] 138/9 141/18 I 134/15 134/14 143/7 I 34 October [1] 86/8 86/13 Bal4
apt soos ein I 183/8 145/18 4150/7 150/13 151/6 I 102/17 86/20 88/21 88/24
4151/8 151/21 32 [1] 8/14 89/3 89/9 89/15 89/20
52/12 52/19 63/13 100 million [1] 151/3
63/23 64/4 64/8 64/10I100 per [1] 180/22
64/16 64/22 65/1 65/8/100 per cent [2]
2021 [7] 66/7 122/21 I35 [2] 39/19 96/13 89/22 90/4 90/24
138/11 155/12 159/1 I35 million [1] 151/6 I 90/25 91/2 91/17
65/11 65/15 65/17 I 59/21 190/25 162/21 193/10 35 years [2] 34/7 I 92/15 146/9
2022 [14] 18/18 34/8
68/13 68/17 68/24 I100,000 [3] 80/6 8
69/1 69/4 69/12 86/7 I 80/25 81/13 26/13 40/1 47/5 57/12I360 [1] 34/19 So
76/3 76/4 76/6 76/21 I38 [1] 44/25 8 September [1]
86/16 86/22 88/14 I 11 [2] 190/1 195/8
165/24 166/13 171/24I38 years [1] 34/7 _I 132/19
88/16 88/23 89/10 _ I11 November [1]
189/19 191/10 800 [1] 73/1
89/13 89/19 89/24 I 49/23 4
90/5 90/7 90/11 90/15I11,500 [1] 35/3 2023 [20] 5/146/6 I= _____________/800,000 [1] 72/2
, 7/10 8/3 8/25 11/21 I4 October [1] 165/24 I81 [1] 3/12
90/17 90/21 91/4 91/7I11.15 [1] 52/14
91/10 91/19 91/22 41.30 [3] 52/11 52/12 12/5 12/7 14/15 16/12I4,000 [2] 76/19 78/8 I86 [1] 195/7
26/12 27/18 27/21 4,500 [2] 76/12 78/1 9
1/2 52/16
oes ore care ourelts Tay 31/23 40/2 40/17 98/19 —_I4.37 [1] 205/12 Qo
471/21 171/23 189/21I40 [2] 104/9 104/16 I 9.30 [4] 205/8 205/9
93/10 93/12 93/14 [144 [3] 1/11 1/15 5/2 °
194/8 450 [3] 72/3 73/3 05/10 205/13
93/17 93/21 94/4 95/4]114 [1] 40/8 os
95/15 95/17 111/23 I12 [5] 29/23 99/1 I2024 [18] 1/1 15/6 I 73/3 per cent [1]
16/7 21/7 21/16 23/6 I47 [1] 149/17 180/25
191/28 1412/6 121/10 I 138/15 138/16 186/21) 56/5 59/5 44/9 57/9 I48 [1] 195/7
121/22 134/11 134/15I12 months [1] 5 41/9 57/9/48 [1] 1 A
57/10 57/12 77/24
134/22 146/5 146/16 I 170/25 96/2 96/11 143/90. «I abbreviation [1]
146/18 146/21 147/11/12.28 [1] 95/11 5 November 2024 11) I 69/19
160/1 190/9 5 November 2024 [1]
149/13 150/11 150/14I12.35 [1] 95/13 bili 37/8
150/17 150/20 162/12I13 [1] 112/8 2025 [1] 41/10 WW ability
2026 [1] 85/22 50 [2] 92/4 92/6 106/10 113/19 114/23
162/18 175/4 176/3 I13 March [1] 15/6 148/8 159/17
22 June [1] 40/2 500 [1] 151/6
177/13 177/23 193/23I13 October [1] 40/1 1
22,000 [1] 66/7 54 [1] 142/11 able
194/3 198/16 204/21 I134 [2] 76/12 78/1 ; 28/9 59/5 70/4 78/24
22/23 [1] 172/8 53,000 [2] 90/9 90/17
204/23 205/6 205/9 I14 August [1] 150/25
23 [4] 24/15 102/19 I550[1] 70/14
THE WITNESS: [3] [15 [2] 97/3 124/22 102/61
94/2 94/5 205/5 150 [9] 91/13 91/15 I 149/16 172/8 57 (1) 40/7
91/16 92/4 92/7 92/11]23 May [1] 171/21 /S8 1] 155/18 fbout (228)
23 September [1] [58,000 [1] 78/24 I about [228]
(63) MR BLAKE: - about
INQ00001201
INQ00001201
A 184/12 addressed [4] 18/1 Iagain [34] 14/3 17/3 I 48/21 50/6 53/17 57/9
above [3] 112/13 achieve [4] 129/23 I 87/8 87/10 110/11 20/25 41/17 43/24 62/7 64/14 69/8 71/13
425/15 160/3 140/25 141/3 147/15 Iaddresses [1] 87/17 I 44/13 47/2 68/6 72/1 I 73/22 75/7 76/14
absence [5] 77/4 achieving [1] 183/9 Iaddressing [1] 102/3I 72/5 72/12 75/23 76/15 77/1 77/3 7/12
87/5 161/17 187/4 acknowledge [1] adds [1] 127/21 76/18 78/14 92/1 77/19 77/22 80/12
196/12 66/18 adduced [2] 80/23 92/10 92/19 94/18 83/10 84/22 85/3 85/6)
absolute [4] 88/10 acknowledged [1] 81/1 95/3 96/11 98/21 85/7 85/13 86/19 87/6)
127/20 140/15 149/7 I 82/8 adequacy [1] 103/1 I 102/1 119/18 127/7 I 88/13 88/25 90/1 90/9
absolutely [41] 11/14]4¢knowledging [1] _ Jadequate [3] 123/18 I 128/10 128/12 131/16) 91/11 94/13 94/19
44/17 15/22 16/22 180/14 162/24 190/4 134/11 135/6 138/11 I 95/4 95/9 99/7 101/15)
48/20 29/13 32/12 acquitted [1] 43/7 adjourned [1] 205/13] 144/15 158/8 168/8 I 111/23 111/23 115/15
33/8 33/13 33/22 35/9I4eross [9] 13/13 35/1] Adjournment [1] 205/6 119/24 119/24 120/12)
43/24 44/22 49/20 41/19 41/20 103/25 I 112/2 against [9] 17/6 121/3 131/16 132/2
51/10 51/17 52/1 52/41 133/10 191/12 201/12] admin [2] 26/18 34/13 124/16 135/24 I 132/13 134/3 134/3
53/7 58/18 61/6 63/2 203/24 27/11 . 137/2 137/3 158/24 I 136/21 137/15 137/18}
63/24 73/13 78/19 act [3] 159/2 159/23 Iadministered [1] 169/2 197/10 138/2 141/19 141/23
84/6 87/21 105/6 160/2 168/13 agencies [2] 29/24 142/15 144/16 145/10)
1406/16 107/19 130/2 acting [3] 16/21 administering [1] 113/10 145/10 147/12 149/15)
437/11 145/2 157/15 64/13 98/5 53/20 agenda [7] 111/2 152/18 157/24 161/9
1468/3 177/22 186/14 action [4] 27/24 administration [2] 131/8 147/9 179/2 162/1 164/10 169/12
489/13 190/25 195/25 103/12 117/1 119/16 I 60/1 176/11 179/10 179/21 179/24I 169/22 176/3 177/19
200/16 actioned [1] 22/18 I administrative [2] aggregate [2] 153/5 I 177/23 192/9 192/16
abstract [1] 129/22 actions [2] 105/4 27/1 139/9 162/4 198/11 200/4 204/25
accept [22] 10/6 106/11 admit [2] 57/23 58/2 Iago [3] 55/8 76/2 allegation [5] 22/5
45/17 53/4 53/18 activated [1] 67/15 Iadvantage [1] 60/6 I 188/8 30/3 31/10 31/15
53/21 53/21 53/23 activates [1] 67/13 Iadvice [21] 12/24 agree [26] 24/24 170/11
59/24 59/25 70/1 active [1] 98/14 25/13 75/11 77/4 98/1I 32/25 37/18 45/15 allegations [12] 17/4
70/23 72/25 74/20 activities [6] 16/1 117/11 117/11 118/25) 45/16 55/7 61/20 17/6 29/10 31/7 31/9
88/21 89/3 90/15 92/2 35/25 99/23 103/10 I 120/20 130/22 136/22] 64/14 70/20 71/4 31/18 32/1 32/2 32/4
142/16 143/2 163/9 106/7 172/12 136/23 136/23 137/3 I 74/16 74/16 75/3 32/10 32/14 32/15
488/10 196/15 activity [3] 17/3 137/9 137/13 157/22 I 76/13 76/25 77/21 alleged [2] 44/19
acceptable [1] 22/14 23/7 158/5 166/21 174/9 I 106/14 117/22 119/4 I 68/15
142/18 actual [2] 92/8 183/23 122/21 151/17 165/10) allowed [2] 27/6
acceptance [1] 10/5 176/11 advise [3] 60/22 173/21 174/2 186/12 I 200/7
accepted [8] 59/15 actually [52] 17/1 116/24 157/6 196/9 almost [6] 36/9 99/12)
65/13 68/18 78/12 21/12 23/13 25/1 28/6I advised [5] 3/14 agreed [9] 4/18 18/10I 144/2 147/13 200/24
78/20 90/9 90/18 31/15 32/2 32/10 36/2) 23/13 27/11 28/9 31/7) 66/3 155/21 156/3 202/22
133/3 44/6 44/10 44/21 advisers [3] 9/23 156/7 194/12 196/10 Ialone [1] 55/13
accepting [1] 86/20 48/11 61/21 65/5 73/7 88/9 197/20 along [2] 40/7 91/10
access [3] 12/21 70/14 80/23 80/24 _ advising [1] 157/14 Iagreement [3] 2/18 I alphabetical [1]
99/18 102/6 81/2 81/8 83/25 90/2 I Advisory [4] 15/23 4/5 88/1 12/16
accident [1] 28/6 91/17 91/23 107/1 23/9 54/15 54/23 ahead [2] 131/8 already [14] 25/25
according [2] 113/7 112/11 114/25 116/5 Iaegis [1] 194/16 138/11 33/7 46/5 48/1 49/17
429/18 116/18 118/24 121/11] affair [1] 168/18 aim [1] 183/9 49/18 55/12 62/18
accordingly [3] 4/13 I 125/20 130/12 130/22 I affairs [3] 97/22 ain't [1] 48/5 134/15 149/20 151/7
42/11 78/22 135/2 135/15 135/23 I 110/13 196/8 Alan [4] 8/9 10/13 156/10 192/3 197/20
account [3] 120/21 137/10 140/17 145/7 Iaffected [4] 24/20 60/8 132/24 also [37] 1/20 2/3 2/7
162/23 176/7 148/6 148/9 148/15 I 47/21 49/1 161/17 ALB [2] 104/3 113/3 I 3/7 3/10 6/10 13/20
accountable [3] 160/16 163/15 167/22I affects [1] 56/9 ALBs [3] 104/2 15/22 20/5 20/17
52/23 52/24 123/10 180/8 181/19 181/21 I affirmed [2] 95/18 105/18 113/2 23/20 29/3 30/22 48/4)
Accounting [24] 191/5 197/4 197/6 206/16 Alder [3] 29/18 30/1 I 59/14 60/9 73/6 104/7,
423/1 123/5 123/7 acute [1] 114/2 afford [3] 21/4 74/15 I 31/3 104/12 104/14 109/15)
123/15 124/3 124/12 acutely [2] 114/15 151/20 Alex [4] 98/2 98/4 110/3 110/4 120/18
424/17 126/7 127/12 182/24 afraid [1] 85/23 98/8 98/15 120/21 120/25 125/6
428/14 133/15 136/7 add [5] 27/13 27/14 Iafter [21] 16/20 18/3 I alighted [1] 76/1 127/21 147/5 148/5
1436/19 136/25 137/4 146/12 149/19 153/13] 22/20 26/15 53/17 aligned [2] 106/11 153/1 153/15 174/15.
137/23 138/4 145/8 adding [1] 124/19 62/19 70/16 74/5 81/3} 180/15 179/21 188/2 192/23
addition [2] 3/17 32/4) 97/12 100/2 105/18 I all [100] 2/11 7/14 204/5
oe oar roar additional [4] 75/22 I 116/23 117/16 133/7 I 9/10 10/25 12/16 although [14] 105/6
accuracy [1] 193/23 77/10 77/10 83/24 137/9 146/2 163/12 I 13/13 13/20 14/3 17/4I 105/24 113/15 127/20)
accurate (2) 35/22 Iaddress [8] 15/3 190/12 199/4 201/9 I 21/1 22/1 23/21 24/22) 132/8 132/24 140/1
188/10 105/1 105/8 106/17 I afternoon [5] 95/14 I 31/20 32/6 32/9 33/19] 145/7 146/13 147/17
achievable [1] 107/20 136/3 145/22 I 112/4 162/11 162/17 I 35/19 37/1 37/2 39/9 I 157/15 164/21 174/2
156/6 205/1 46/19 46/20 48/21 205/1
(4) above - although
INQ00001201
1NQ00001201
A answers [2] 130/18 I 106/12 approvals [1] 100/25] 115/5 115/22 117/25
7 I 194/18 applicant [4] 61/20 Iapprove [4] 156/19 I 124/3 124/9 124/11
altogether [2] 119/7 I any [89] 2/25 3/19 I 63/16 88/20 88/24 I 166/25 196/4 196/5 I 124/13 125/3 127/13
always [23] 216 I 4/147/9 11/9 14/24 applicants [5] 5/21 approveldecide [1] I 127/17 128/25 130/16
pita 70/7 72/10 16/4 17/8 17/19 18/12I 53/14 62/3 142/24 156/19 131/25 132/20 132/21
Faris 11 97/7 I 18/13 22/5 23/1 26/17I 163/20 approved [4] 163/2 I 133/24 134/13 135/5
431/19 1441/7 141/21 I 27/12 28/1 31/3 35/12I application [11] 166/16 167/2 196/11 I 135/12 135/21 135/23
4145/7 147/21 154/18 I 39/15 38/9 49/6 50/17I 74/23 89/1 89/14 90/8I approving [1] 167/8 I 136/16 141/3 141/23
160/23 161/22 164/21I 91/6 58/4 61/19 61/24) 90/23 140/14 142/12 I approximately [1] 141/24 144/19 145/3
64/2 67/11 79/10 148/13 148/15 150/24] 12/1 145/18 146/6 148/2
eo, fee waa 87/13 87/20 94/12 I 150/24 April [6] 21/16 23/4 I 151/11 152/11 152/21
200/12 101/4 104/25 106/17 Iapplication-based [1]I 23/6 57/9 57/12 152/23 153/16 153/20
am (24) 1/2 11/24 I 107/14 107/22 114/20I 142/12 155/12 155/1 155/2 158/15
20121 27/11 36/11 I 117/13 117/23 118/6 Iapplications [6] ARAC [1] 109/20 162/1 164/11 168/19
36/25 36/25 41/11 I 121/23 123/20 124/11) 19/16 22/19 22/23 arbiter [1] 178/6 17413 172/12 172/13
41/22 51/15 52/14 124/12 124/15 125/7 I 73/11 140/8 140/9 arbitration [1] 65/3 I 184/6 186/17 189/9
52/16 58/16 63/15 125/10 126/4 127/4 Iapplied [4] 56/24 Arbuthnot [5] 6/15 I 189/16 195/9 199/25
79/9 94/12 111/20 128/2 128/2 130/3 92/11 123/20 124/9 I 7/5 7/17 7/24 29/2 200/17 203/10
140/20 162/25 165/25I 130/13 131/23 133/15I applies [3] 76/14 Arbuthnot's [1] 7/6 Iarea [8] 16/24 23/19
133/16 140/10 144/1 I 77/1 81/25 are [206] 1/8 1/23 2/8I 25/19 26/20 34/3
oot 200/25 202/16) 44749 141/22 143/2 apply [6] 68/2 125/4 I 2/22 2/25 3/12 3/12 I 48/14 97/9 127/24
145/24 147/11 149/3 I 125/6 127/3 127/6 I 3/16 3/17 5/5 5/20 areas [6] 34/1 36/11
tiie (2) 35/3 I asar7 154/15 154/21 I 187/21 5/22 8/15 8/17 8/18 I 101/18 103/11 107/17
-_ 157/7 167/10 167/16 Iappointed [4] 4/12 I 8/19 11/23 12/3 12/15I 124/3
ambiguity [1] 193/8 ;
among [2] 104/16 I 168/16 173/13 174/1 I 12/1 98/16 181/20 I 17/6 17/18 17/19 aren't [10] 10/11
195/3 174/9 178/20 180/9 _Iappointment [5] 21/23 23/19 25/16 I 40/21 54/12 58/25
amongst [1] 19/1 I 181/16 186/16 186/18] 119/17 170/21 181/21] 26/7 30/2 30/19 31/17) 59/3 73/12 73/19
amount [6] 20/5 187/9 189/22 192/13 I 181/22 189/19 33/1 35/14 35/24 36/3) 86/25 115/4 142/2
79/23 128/22 129/7 I 193/19 193/20 195/13] appointments [1] I 36/4 36/9 37/4 37/6 I arguably [1] 155/7
142/17 1860/8 196/16 201/1 204/20 I 179/3 38/20 39/9 39/19 argument [1] 53/3
anybody [4] 14/5 appreciate [5] 80/8 I 40/1240/14 41/7 _I arguments [1]
amounting [1] 7151/3 I'a4794 66/12 121114 I 81/1281/15 87/7 I 411041119. 41/20 _I 196/25
analogies [1] 203/21
anyone [2] 49/24 I 204/10 42/6 42/8 43/6 45/12 Iarises [2] 185/23
arse a I agait4 appreciated [1] 45/24 45/25 46/3 46/4I 185/24
se oe anything [20] 9/15 I 203/17 46/5 46/11 46/16 47/6I arising [4] 3/19 19/25
angle [1] 12920 I 114911/12 25110 approach (29) 15/14 I 47/9 48/20 48/21 I 22/13 177/24
Ande Lat 26/23 05/18 I 28/11 34/14 48/3 61/3) 21/9 22/21 24/2 24/6 I 48/22 49/1 49/15 I arm [2] 114/4 114/17
pA ete 80/13 89/7 90/20 _I 24/6 41/12 42/1 45/10I 51/24 52/22 52/24 arm's [11] 109/17
announce [2] 136/12I 119/19 147/19 159/16) 49/14 81/2 1089 I 53/12 891253720 I 11397 113/9 T14/1
1438/2 170/16 176/22 177/10) 110/4 132/13 134/6 53/22 54/8 54/11 55/8) 114/11 115/17 118/19)
announced [3] 90/24I 179/16 187/8 19474 I 139/20 14014 142/12 I B6/11 55/14 55/17 I 118/20 1236 154/23
1388 IeBiIb anyway [4] 81/10 I 144/6 144/8 149/6 I 56/18 58/4 58/6 58/10I 168/1
announcement [3] 91/14 144/14 205/2 I 155/6 167/11 170/1 I 58/23 58/23 58/25 I arm's-length [5]
5/11 124/13 136/13 [anywhere [1] 130/4 I 198/23 198/25 198/25] 59/1 59/3 59/4 60/17 I 109/17 113/7 114/1
announcing [1] AO [1] 136/6 199/6 204/10 60/18 60/19 61/19 115/17 118/20
437/19 Apart [41] 11/14 approached [4] 62/4 62/22 62/22 arms [1] 9/13
annually [1] 34/20 apologies [7] 23/2 I 23/25 26/6 90/6 62/25 64/13 70/1 arose [3] 16/5 16/20
another [18] 3/16 43/24 51/19 57/20 200/12 70/21 73/7 73/11 193/15
37/21 57/16 61/8 88/10 133/12 153/13 Iapproaches [7] 73/15 73/18 74/3 74/4I around [48] 7/22
71/12 74/9 77/25 apologise [11] 18/21 I 24/13 41/16 134/20 I 74/5 74/14 74/22 12/4 12/5 14/15 17/11
80/21 84/22 90/12 58/20 59/18 63/4 67/6) 142/12 143/9 143/15 I 76/17 77/13 77/19 18/15 20/20 25/3
110/6 111/21 113/15 I 97/20 68/9 68/22 148/21 77/22 79/2 79/4 79/21] 28/25 35/25 36/13
4121/4 128/6 146/17 I 94/19 165/25 168/5 I appropriate [13] 81/9 81/9 81/14 81/19] 38/11 51/16 56/5 56/8
1457/18 188/5 apologised [1] 181/4 I 20/14 25/7 27/24 81/20 82/8 83/17 56/10 58/5 72/8 83/12
apology [4] 149/19 I 28/21 31/21 35/9 50/4I 84/13 85/4 85/12 85/17 88/19 104/9
answer [20] 34/4
35/18 50/14 61/22 149/20 168/4 180/13 I 70/10 116/25 121/13 I 85/14 85/21 87/22 104/20 105/4 107/2
85/24 113/6 116/9 _IaPPalled [1] 42/20 164/13 169/19 199/19) 88/7 88/16 88/18 89/4I 107/15 109/17 114/13}
122/6 124/20 130/19 I@PParent [1] 58/21 I appropriately [2] 93/7 93/10 93/23 94/7I 120/5 133/5 139/6
136/16 144/17 145/g I@PPeal [4] 65/3 78/12) 145/24 173/1 96/15 96/17 99/5 139/7 139/8 143/19
1446/1 152/4 157/21 I “8/21 78/24 Appropriation [1] 101/7 101/7 101/14 I 148/19 151/3 158/5
1460/2 164/21 197/23 [appeals [4] 1/22 4/14) 159/22 102/9 102/9 102/9 160/19 164/5 166/21
203/6 79/4 131/25 approval [5] 166/5 I 102/19 102/25 104/19] 169/22 180/13 181/16
answered [1] 90/1 IaPPear [4] 48/11 166/18 166/22 178/19] 106/11 108/14 108/15) 181/24 182/7 188/7
appetite [2] 24/17 191/13 108/20 109/25 114/20] 190/19 192/12
(65) altogether - around
INQ00001201
INQ00001201
A 140/9 awareness [1] 19/18 I 160/20 167/2 30/16 33/4 33/17
arrangements [e] I@sset[1] 105/17 away [8] 51/14 51/14 IBates [5] 8/10 10/13 I 33/19 34/20 34/22
60/13 99/10 112/9 Iassets [1] 104/12 I 62/13 78/21 86/11 I 10/17 21/3 26/7 36/14 36/18 37/24
116/15 123/17 127/18/@8Signed [1] 106/2 I 95/7 129/17 186/15 I be [256] 38/23 40/2 40/4 42/16
448/17 178/20 assist [11] 1/8 4/19 Iawful [3] 46/25 bear [1] 182/14 43/25 45/12 48/1
arrive [1] 162/7 6/21 7/14 10/15 27/9 I 140/13 203/22 beautifully [1] 72/23 I 48/17 49/22 53/17
arriving [1] 39/7 31/2 47/14 1022 [I__I became [8] 62/9 98/4) 54/22 55/25 57/1 57/6
114/20 114/21 Bo __I 434/21 151/19 165/7 I 57/7 57/18 57/23 58/3
arenas 6/24 assistants [1] 2/10 Iback [68] 10/2 18/19 Ipecause [120] 2/6 I 58/14 58/15 59/12
‘ assisted [1] 100/7 I 26/15 36/21 43/14 I 4/21 9/15 10/19 14/3 I 60/5 62/14 62/22 66/5
rncuaared te associate [1] 19/22 I 43/19 44/10 44/24 I 18/21 20/10 20/15 _I 66/9 66/11 66/14
83/6 associated [8] 6/14 I 47/5 60/20 61/22 21/3 22/23 23/19 66/23 67/9 67/13 68/9}
articulating [1] 22/14 71/9 131/5 64/10 66/2 66/8 70/13) 25/15 28/7 32/13 68/10 68/17 71/3
195/17 185/16 185/24 189/4 I 76/6 76/21 81/17 32/18 33/10 33/18 I 72/18 73/16 73/20
as [300] 191/22 82/10 82/12 82/21 35/2 37/10 38/6 41/11I 74/22 75/4 75/9 75/11
aside [3] 140/10 assume [8] 76/15 I 82/23 83/2 83/15 84/3) 48/13 48/18 56/6 59/3 76/6 76/16 76/22 77/3
140/12 200/25 77/2 77/19 77122 90/23 109/6 112/18 I 60/19 61/15 62/23 I 79/1 79/4 79/7 79/24
ask [35] 6/8 31/24 I 90/11 102/22 105/9 I 115/21 118/9121/6 I 63/13 65/12 66/13 I 80/23 80/25 82/17
30/15 47/3 47/9 48/25I 136/2 137/13 137/25 138/12I 66/13 68/5 68/8 71/13] 84/8 84/16 87/24
50/17 50/18 51/1 assumed [1] 183/17 I 139/5 140/3 140/6 72/14 73/1 73/2 73/15I 89/13 94/14 94/16
59/16 59/16 66/10 [assuming [1] 42/23 140/13 140/21 142/4 I 74/21 75/21 77/8 95/1 98/8 99/3 99/10
69/16 69/18 70/3 assumption [4] 2/16 I 143/7 144/15 144/25 I 77/18 77/24 79/23 99/13 99/15 99/20
73/24 82/4 87/12 9/20 18/25 158/21 I 145/4 145/19 147/21 I 80/6 80/8 81/1 81/6 I 100/4 103/12 104/10
87/13 88/13 91/2 96/1I28Surance [2] 51/10 I 148/23 149/10 152/7 I 81/13 82/18 83/15 _I 107/9 107/25 108/18
96/5 96/10 96/12 51/17 152/21 155/1 160/2 I 85/8 85/24 87/1 91/7 I 108/19 109/24 110/8
96/20 121/7 127/13 [assurances [3] 41/5 I 162/11 168/10 172/18] 91/24 91/25 92/16 I 110/11 117/8 117/24
137/10 141/22 164/15] 41/7 41/9 174/4 174/7 174/8 _I 94/24 100/21 105/10 I 118/4 118/7 118/19
4176/5 193/19 197/22 Iat [305] 174/10 175/11 176/17I 110/20 114/3 114/16 I 118/20 118/25 119/8
200/9 attach [1] 171/3 188/14 188/23 193/5 I 115/20 115/23 120/11] 120/2 120/4 120/11
asked [24] 2/7 10/20 attended [9] 8/7 15/9I 199/2 199/13 200/9 I 122/9 123/4 123/23 I 121/3 121/8 122/2
22/10 27/13 31/19 I 22/5 40/8. 42/16 46/3 I 200/13 127/21 130/20 131/21] 125/18 125/19 127/24
34/22 51/2 56/8 55/11) 06/24 57/2 58/7 backfill [4] 21/12 138/25 141/11 141/21] 130/22 132/7 139/5
56/17 64/6 81/19 87/4 attendees [1] 132/20 Ibackground [5] 144/12 144/13 144/17I 139/9 139/20 139/21
94/8 94/14 112/23. Iattending [2] 7/22 I 16/14 18/13 20/8 147/22 148/9 152/15 I 140/13 140/18 140/20
11877 133/14 144/18 I 95/22 96/22 117/18 153/1 153/18 153/21 I 142/14 142/19 143/18
145/14 150/15 167/3 [attention [6] 16/8 I backgrounds [1] 154/8 154/14 157/20 I 144/22 145/3 145/11
182/16 193/21 16/13 108/2 111/4 I 101/20 163/5 164/1 164/25 I 145/15 145/18 146/8
asking [15] 54/22 I 14/7 172/6 bad [5] 33/18 33/21 I 165/6 165/18 166/9 I 147/7 147/13 147/15
54/24°57/8 69/8 126/9I Attractive [3] 133/24 I 138/2 161/22 197/5 I 167/14 167/15 167/17) 148/11 148/11 150/9
127/12 137/12 137/25I 134/1 152/4 badly [1] 55/22 169/16 174/4 175/17 I 151/2 151/3 151/15
440/12 143/12 152/7 I@udit [4] 105/3 105/7 Ibalance [5] 67/5 179/12 180/23 181/22] 155/9 164/4 166/8
467/85 17114 179/19 I 109/15 175/19 120/19 121/16 175/24I 182/13 182/21 186/1 I 167/2 167/3 168/7
4185/3 August [5] 29/5 197/14 186/6 186/18 187/19 I 168/7 169/1 170/16
asks [3] 165/17 150/23 150/23 150/25] balanced [1] 157/19 I 189/9 192/3 192/12 _ I 171/23 17/9 180/18
185/5 185/10 151/2 balancing [4] 175/6 I 194/16 195/18 196/5 I 181/20 181/20 182/18}
aspect [6] 82/5 84/7 [August 2024 [1] 29/5) 175/8 175/12 175/18 I 196/11 197/7 198/10 I 183/18 184/7 185/20
87/12 123/20 126/22 [author [1] 32/14 bandwidth [1] 38/3 I 202/23 188/4 191/1 192/16
130/3. authorised [1] 59/12 IBank [1] 34/9 Beckett [1] 98/4 196/10 197/8 197/20
aspects [6] 37/1 authorities [1] 125/1 Ibar [4] 81/6 141/14 Ibecome [3] 58/20 I 202/25 203/11 204/25
69/17 82/10 127/15 [authority [5] 125/5 I 141/15 141/16 112/15 194/22 205/1
138/21 140/2 125/24 126/18 159/18IBartlett [1] 29/21 — Ibecomes [1] 120/16 Ibefore [23] 21/18
159/25 base [2] 8/18 20/16 Ibeen [204] 1/23 2/16 I 29/21 33/4 35/15
aspiration [1] 180/22
assess [4] 22/13 automate [1] 85/16 Ibased [10] 1/18 2/17 I 2/18 3/3 3/4 3/13 3/14) 51/21 58/1 66/20
74/23 91/23 141/11 [available [5] 70/18 I 61/21 84/14 87/2 94/8) 3/15 4/18 5/22 5/23 _I 67/10 70/7 74/24
assessed [2] 72/3 I 74/11 86/25 91/20 140/8 142/1 142/12 I 8/10 10/1 10/17 11/16] 89/15 93/20 100/5
124/16 144/16 144/6 12/2 12/4 14/3 14/4 I 103/8 124/18 132/20
assesses [1] 141/16 I@void [1] 161/21 basically [8] 94/11 I 14/5 14/9 14/11 14/13] 133/7 146/5 161/12
assessing [1] 141/10I2volded [1] 30/16 126/24 135/12 137/13] 15/19 15/25 16/6 163/14 175/4 182/7
assessment [11] 4/4 [awaiting [1] 40/19 I 138/1 179/14 184/16 I 18/11 18/22 19/3 191/10
4/20 4/23 5/6 74/1 Iaware [14] 3/1 3/6 I 186/23 19/14 19/15 19/16 I begging [2] 184/6
4136/6 136/7 136/12 I 3/7 11/10 11/12 14/23] basis [13] 2/19 34/19] 20/19 22/13 22/17 I 185/3
436/19 138/8 147/11 I 23/8 24/2 58/16 79/4 I 62/21 63/17 76/13 I 22/21 23/25 24/10 I begin [4] 122/18
assessments [1] 79/9 169/1 190/21 I 129/25 159/6 159/10 I 26/7 26/14 27/14 147/22 149/3 175/24
194/22 159/12 159/14 159/15I 29/16 29/24 30/11 I beginning [8] 14/21
(66) arrangements - beginning
INQ00001201
1NQ00001201
B BEIS0000851 [1] 201/11 142/23 160/3 164/6 I building [2] 6/16
beginning..[7]__ 26/1 binary [1] 115/6 176/5 176/9 187/8 199/20
92/25 149/17 158/12 IBEIS0000918 [1] bind [1] 65/12 200/5 built [6] 18/2 19/2
188/14 188/22 195/7 I 187/25 binding [1] 65/11 Ibottom [16] 12/10 _ I 19/4 61/9 73/16 160/7I
2017 BEIS0000961 [2] bit [37] 1/7 115 12/14 13/8 19/8 26/2 Ibullet [4] 10/16 19/8
begun [2] 198/14 132/18 150/19 13/19 24/22 33/23 I 75/19 103/6 112/19 I 103/6 106/3
200/2 BEIS0000967 [1] 44/11 45/10 69/7 131/10 158/9 166/14 Ibundle [4] 28/24 29/6
behalf [3] 60/6 165/22 89/13 113/18 123/3 I 166/20 172/4 180/2 I 72/13 95/25
194/11 194/13 BEIS0000975 [1] 138/16 153/9 154/6 I 184/1 187/25 bureaucratic [1]
behaviour [1] 36/16 I 162/20 155/3 161/18 161/20 Ibowl [2] 184/6 185/3 I 53/12
behind [10] 40/13 IBE!S0000984 [1] 161/20 161/23 161/24I bow! [2] 184/4 188/5I bursaries [1] 47/14
‘40/14 42/23 77/7 171/19 161/24 161/25 164/17I box [2] 124/22 bursary [1] 49/11
78/15 94/15 132/6 I BEIS0000990 [2] 164/17 164/17 165/15I 201/15 business [24] 14/7
482/16 200/1 202/3. I 138/10 156/10 165/15 165/16 165/16I Bradshaw [1] 12/13 I 14/8 14/12 14/13 19/1
being [65] 2/25 2/25 IBelfast [2] 40/16 182/18 183/21 187/16Ibranch [4] 61/17 20/22 26/4 29/22
716-10/19 18/24 19/2I 43/14 189/8 191/9 195/5 I 62/8 71/12 192/8 33/25 35/7 36/20
19/13 28/9 38/12 41/5 Pelief [2] 96/16 148/5] 197/15 199/21 branches [2] 35/3 I 96/23 96/25 97/11
48/22 49/6 51/11 57/4IPelieve [9] 33/5 52/9 Ibite [1] 175/24 192/23 97/12 97/17 108/24
57/15 57/17 59/5 62/4I 08/21 75/1 75/24 89/3I bits [1] 169/21 breach [5] 87/14 167/7 169/10 181/25
62/25 78/24 79/23 I 174/12 180/20 186/14I Black [1] 196/1 87/19 166/16 167/20 I 181/25 182/8 182/25
82/7 82/13 82/14 believed [2] 79/14 IBLAKE [14] 1/4 32/1 I 168/1 201/13
33/23 83/24 89/20 I 185/5. 33/2 33/4 34/15 34/22I break [8] 52/8 52/15 Ibusinesses [3]
90/24 91/13 104/22 Ibelieving [1] 184/18 I 57/1 61/3 64/5 76/11 I 93/20 95/6 95/12 148/20 201/9 201/12
108/2 114/3 14/5 [below [2] 171/7 88/17 93/18 95/8 111/22 162/11 162/15] but [270]
415/16 116/7 1269 I 17/8 206/4 breaking [1] 1648 [G7
427/21 129/5 13/5 Ibench [1] 66/6 Blake's [1] 41/19 [Brian [6] 16/11 18/3 I¥
4139/4 139/15 145/2 Ibenefit [4] 75/11 Blakey [1] 75/13 25/25 26/8 26/12 Cabinet [1] 191/14
4147/5 149/8 151/3,_ I 119/15 119/18 130/15] blame [3] 34/23 55/18 calibrate [1] 203/19
151/6 152/19 158/13 IPenefits [2] 24/15 I 34/23 34/24 briefing [17] 13/2 Ieall [10] 25/22 42/7
488/18 162/24 163/21I 148/19 blanket [1] 143/8 138/10 138/12 150/8 I 44/11 64/21 72/22
4169/3 176/7 180/13 Pest [11] 30/25 34/8 Iblatant [1] 27/7 150/10 156/9 156/11 I 110/1 113/17 153/17
482/23 184/9 184/16 I 86/16 96/15 108/23 [Blood [1] 5/15 157/1 157/6 175/2 I 157/25 166/12
1490/12 194/1 194/22 I 110/1 121/21 137/9 I board [31] 9/18 9/18 I 179/1 179/8 179/10 called [2] 16/11
196/23 197/9 202/7_ I 140/15 164/21 164/23] 10/12 15/23 21/17 182/22 202/7 202/19 I 26/14
202/21 203/12 better [13] 25/2 25/6 I 21/18 23/2 23/9 24/3 I 202/21 Callendar [1] 26/22
BEIS [24] 97/13 48/9 131/3 132/13 24/7 24/7 29/14 36/15I briefings [4] 202/10 Icalling [1] 202/1
98/22 99/21 100/21 I 141/4 144/22 147/23 I 43/18 54/2 54/15 202/11 202/24 203/8 Icalls [1] 13/20
102/17 103/19 103/20I 148/5 164/17 164/17 I 54/23 61/19 100/14 I briefly [4] 29/19 came [21] 2/3 5/16
103/21 103/25 103/25] 164/18 197/16 116/6 117/21 117/24 I 79/11 191/3 191/10 I 16/8 16/11 16/13
105/18 106/6 106/6 Ibetween [31] 4/5 118/4 118/12 167/11 IBrightwell [1] 26/3 I 17/15 18/18 26/15
1406/9 109/20 132/25 I 4/18 6/13 18/10 30/18] 169/6 169/8 169/24 I bring [12] 29/19 43/19 46/19 62/20
133/4 152/23 155/16 I 39/5 51/9 59/5 70/9 I 188/4 190/8 190/16 I 47/24 53/25 112/7 72/11 89/15 89/20
159/21 163/2 166/21 I 71/22 73/23 75/8 Board's [1] 190/17 I 116/18 119/13 122/20] 115/11 143/25 161/10
1470/23 180/21 82/14 90/20 92/7 boards [1] 101/9 149/15 162/20 170/9 I 169/22 185/5 186/6
BEIS' [1] 104/23 99/23 100/9 100/20 Ibodies [6] 109/17 I 183/4 185/9 199/6
BEIS/UKGI [1] 100/23 103/14 104/18] 113/8 114/1 118/20 I bringing [3] 168/18 ICameron [1] 176/5
132/25 134/9 134/9 142/24 I 168/12 198/5 178/14 182/14 campaigners [1]
BEIS0000607 [1] 142/24 145/17 145/20I body [8] 28/12 114/8 IBritish [1] 47/18 77
170/19 152/6 171/16 17/4 I 115/17 118/19 123/7 Ibroad [1] 200/16 —_Ican [156] 3/8 3/11
BE1S0000631 [1] 189/19 148/12 154/23 168/1 Ibroader [3] 99/22 I 4/18 6/1 6/21 7/9 8/6
178/25 beyond [4] 47/7 72/2 Ibogged [1] 63/14 I 100/17 102/10 8/16 10/15 10/25 11/5}
BEIS0000641 [1] 6/3 I 126/14 202/1 boiled [1] 161/19 I broadly [7] 1014/1 I 11/19 11/25 12/8
BEIS0000656 [1] 8/2 /Bible [1] 176/25 boiling [1] 199/22 I 103/24 144/3 148/16 I 14/22 21/16 22/2
BEIS0000752 [1] Dig [9] 154/8 154/20 Ibolder [2] 121/8 166/6 187/12 200/15 I 22/25 23/2 24/12
180/1 167/22 167/25 168/15I 200/6 broken [3] 88/1 88/2 I 25/14 25/24 26/2 27/9I
BE1S0000843 [1] 177/4 186/2 187/17 Ibolts [1] 112/15 201/3 31/2 31/6 32/17 37/3
29/1 188/15 bones [1] 65/20 brought [1] 202/13 I 38/23 39/1 41/8 41/11
Beisooo0sae [1] —_IPigger [3] 153/21 [book [1] 158/22 BT [1] 27/17 41/14 41/23 42/1
29/3 168/10 197/15 books [1] 67/5 budget [2] 163/3 I 42/12 42/13 42/14
BeIsooo0sas [1] _IPiggest [1] 203/12 [borrow [1] 66/21 186/6 43/19 48/3 48/3 48/6
29/3 bill [2] 153/24 154/1 Iborrowed [1] 66/7 budgets [1] 187/1 48/8 48/12 51/6 51/10)
BEISo000849 [2] __ [billion [2] 153/5 both [15] 3/10 61/20 Ibugs [1] 13/2 51/13 51/18 56/23
29/5 53/25 204/12 64/13 93/14 98/10 I build [4] 7/5 46/9 59/8 61/10 63/12
bills [2] 158/16 100/25 116/13 120/19] 173/14 173/15 63/13 63/24 64/19
(67) beginning... - can
INQ00001201
1NQ00001201
c 156/4 158/25 caveat [2] 33/23 _Ichallenged [1] 182/8 I 61/21 62/6 62/14
Carl's [1] 156/2 132/8 challenges [14] 11/3 I 62/20 62/23 62/25
can... [101] 65/4 65/6
67/14 68/5 69/19 70/6ICat/Perm [1] 135/3
71/5 72/16 73/21
73/23 74/10 74/17
76/9 76/17 77/12
77/25 78/17 79/11
79/18 80/3 82/4 82/6
85/16 85/16 88/21
91/4 91/11 92/9 92/19)
93/19 93/21 94/2
95/14 95/15 95/20
96/5 96/10 96/12
98/25 105/21 108/25
110/16 110/22 112/4
112/7 114/19 115/9
115/16 116/2 117/15
124/18 125/10 126/18}
130/5 130/12 132/18
132/22 133/20 134/11
135/6 135/25 136/18
138/10 139/19 141/13}
146/18 149/2 149/15
150/11 150/17 150/18)
152/23 157/5 159/17
162/4 162/17 162/20
163/1 163/10 163/17
164/11 170/19 172/4
175/2 175/9 175/17
183/15 184/11 187/12)
187/24 189/11 189/15)
190/7 190/14 193/18
196/21 198/1 198/23
199/10 201/18 202/5
can't [31] 4/5 9/13
9/16 18/6 19/7 21/4
41/17 50/21 57/20
63/3 64/13 67/11
74/14 75/7 79/20
85/23 85/23 92/8
92/14 108/24 109/6
129/21 137/4 144/12
165/18 168/2 168/11
171/23 185/9 198/23
199/3
cancel [3] 194/8
196/9 197/18
cancelling [1] 194/11
cannot [4] 32/1 36/10!
138/2 159/9
capabilities [2]
101/23 103/24
capability [2] 113/24
115/1
car [1] 97/14
care [1] 173/9
career [1] 101/13
careful [1] 166/22
carefully [2] 146/23
197/22
Carl [10] 98/2 99/19
103/18 122/10 133/14
134/24 135/3 155/11
Caroline [6] 12/10
14/8 14/11 56/24
56/25 57/21
carriage [1] 98/12
carried [2] 66/5
122/3
carry [3] 59/5 162/19
192/4
carrying [2] 93/2
191/6
cascade [1] 43/21
cascaded [1] 107/10
cascading [2] 44/9
44/24
case [46] 3/3 6/18
18/10 41/14 41/21
42/3 42/9 55/13 56/25
57/16 58/16 58/19
62/19 63/6 63/7 63/8
63/15 68/9 70/7 77/5
77/8 85/10 89/8 114/2
114/16 122/5 123/8
128/1 128/19 130/13
130/24 137/11 140/4
140/4 140/21 141/10
142/6 142/6 147/4
153/19 167/22 175/17)
187/21 187/22 198/12)
202/14
cases [41] 2/3 2/4
4/16 4/19 4/24 6/19
8/15 8/17 10/11 11/5
19/14 41/2 41/3 41/17)
42/6 43/8 57/20 58/18
60/20 61/5 63/4 64/6
64/7 68/12 72/15
75/10 77/3 82/10
82/12 85/3 85/4 85/7
86/1 86/2 86/4 86/19
121/7 133/19 140/18
141/11 141/16
cash [3] 35/4 67/14
197/8
catch [1] 111/1
catch-up [1] 111/1
categories [1] 21/21
category [9] 2/15
19/9 21/23 22/11
22/11 22/12 23/17
24/14 119/24
Catherine [1] 60/10
caught [2] 57/18
158/14
cauldron [1] 25/11
cause [1] 163/15
caused [3] 30/4
138/24 145/25
causes [1] 121/2
caution [1] 3/4
cautions [4] 2/7 2/11
2/22 2/25
caveated [1] 36/8
CC [1] 9/25
ceased [1] 98/23
censure [7] 116/25
4117/2 117/11 118/15
121/13 121/18 170/5
cent [10] 59/21 80/9
81/14 138/9 141/18
153/8 180/22 180/25
185/18 190/25
central [3] 104/6
104/10 105/23
centre [2] 103/22
104/3
centres [1] 35/4
123/13 169/12 170/3
179/3 179/9 179/19
CEO's [2] 166/2
166/4
certain [2] 60/20
164/5
certainly [23] 14/6
14/8 14/10 18/1 50/12
63/12 109/12 114/1
118/17 121/15 125/16
139/5 139/10 140/24
144/9 144/11 144/11
162/12 175/13 176/15
178/15 194/14 194/15
cetera [26] 7/19 9/5
9/5 17/16 17/16 25/14
25/14 28/11 28/11
34/1 42/4 42/5 44/20
44/20 46/19 82/25
82/25 104/8 104/9
115/24 115/25 127/5
127/5 152/25 188/21
193/14
chain [9] 6/6 12/7
12/9 14/21 25/24
26/22 29/1 54/1 198/6
chains [1] 29/6
chair [21] 2/7 11/21
11/23 11/23 12/1
22/10 54/15 81/16
109/19 112/25 118/18
121/4 121/12 165/23
169/9 170/3 170/22
171/1 183/13 189/17
189/23
chaired [2] 4/7 17/1
chairing [1] 23/13
Chairman [1] 181/10
challenge [21] 18/20
36/21 36/23 36/24
38/1 38/2 63/24 64/3
82/16 108/6 122/15
136/17 147/18 148/4
163/16 165/7 172/11
192/19 193/1 199/14
202/17
CEO [8] 110/15 123/7Ichanges [1] 121/8
11/4 25/3 36/12 36/13)
36/19 37/13 37/23
121/3 140/14 148/10
149/8 187/18 192/21
challenging [4] 34/4
154/4 193/7 203/22
Chambers [1] 26/23
chance [3] 156/11
183/21 190/10
change [10] 15/17
24/19 91/4 91/11 92/8
110/16 110/21 111/9
145/25 199/6
changed [2] 110/21
145/17
channel [3] 97/25
169/18 169/25
characterise [2]
100/11 101/19
characterised [1]
139/12
characteristic [1]
128/7
charge [1] 69/4
chase [1] 149/9
cheap [1] 130/19
cheaper [2] 130/15
131/14
check [5] 18/19
18/19 19/1 109/21
111/12
Chief [3] 16/16 16/17
122/25
children [2] 47/15
49/15
Chisholm [2] 98/2
98/4
choice [2] 83/11
193/3
choose [2] 134/6
146/23
choosing [2] 134/9
134/9
chose [1] 110/19
chosen [1] 116/25
Chris [2] 29/4 54/14
chronology [5] 133/6
133/12 135/25 138/12)
156/1
churn [1] 45/13
circa [1] 151/12
circulated [1] 72/13
circulation [1] 14/9
circumstances [6]
59/2 68/1 70/22 89/21
142/16 203/18
civil [10] 98/11
101/11 109/24 147/14)
158/4 197/17 197/23
198/6 200/23 202/11
claim [34] 5/6 20/1
67/7 67/8 67/18 70/12
72/1 72/7 75/12 76/19
79/17 80/6 80/25 81/1
81/8 90/1 90/2 90/3
91/7 91/12 91/14
91/21 91/23 92/3
131/12 131/21 158/24)
177/10
claimant [5] 5/5
66/10 70/6 70/9 82/15
claimants [17] 1/11
1/16 5/3 55/6 58/23
74/3 74/4 75/7 130/14,
131/12 131/17 131/20)
132/2 135/1 135/4
172/15 172/16
claimed [4] 79/23
81/13 81/21 151/4
claiming [1] 91/16
claims [26] 3/13 3/14
3/18 30/5 40/19 41/10)
53/17 60/23 70/21
71/8 71/16 76/6 76/7
76/15 76/22 128/2
130/12 132/7 132/10
142/2 151/2 151/6
151/8 151/16 159/16
184/17
Clapham [1] 25/22
clarification [5] 2/11
36/7 36/22 81/18
130/10
clarify [7] 3/20 22/2
109/2 110/16 131/2
164/1 181/6
clarifying [4] 72/14
clarity [5] 19/21 51/6
117/10 190/16 191/23)
Clarke [1] 12/24
clash [1] 164/12
class [3] 125/23
143/17 143/19
classes [1] 143/16
classic [2] 71/11
72/5
clear [49] 6/23 9/3
9/24 15/22 17/3 17/8
20/25 25/23 27/14
28/12 29/15 29/17
29/24 32/12 35/17
38/8 43/13 55/25
61/18 62/5 64/3 68/22
69/8 72/17 72/18
80/12 85/20 91/9
106/24 120/10 120/13)
128/1 134/12 136/9
146/6 151/15 151/19
153/4 159/1 159/15
164/12 165/7 178/6
187/3 188/25 189/10
189/12 195/25 195/25)
clearance [1] 145/11
(68) can... - clearance
INQ00001201
INQ00001201
c 92/4 93/20 114/15 compatible [3] compromise [1] consciousness [1]
clearances [1] 115/8 140/3 152/12 140/23 143/3 144/1 129/14 201/24
413/14 160/2 175/13 175/16 I compensate [4] con [1] 38/3 consequences [1]
clearer [3] 120/16 175/20 177/1 66/24 66/25 125/10 Iconcepts [2] 124/9 I 33/16
436/16 157/23 comfortable [2] 9/23 I 129/12 124/11 consequently [1]
clearing [1] 11/15 41/15 compensating [4] conceptual [1] 149/24
clearly [12] 9/6 19/2 coming [12] 7/23 129/17 129/25 141/24) 158/21 consider [7] 78/9
28/8 34/2 36/2 56/16 10/11 28/4 41/9 43/14) 172/25 concern [9] 7/14 83/1 117/20 128/24
99/8 1141/9 127/20 67/14 79/9 85/9 85/18] compensation [112] I 16/20 17/2 23/8 76/4 I 155/15 163/18 163/24,
1439/17 173/2 192/7 170/24 196/7 204/24 I 5/15 7/20 11/8 11/19 I 78/1 106/15 135/7 considerable [4]
clerks [1] 54/25 commas [1] 146/22 I 13/6 13/12 17/24 30/5I 191/20 30/15 93/23 109/17
client [3] 42/18 60/7 comment [9] 36/10 I 31/12 37/7 37/9 37/17Iconcerned [14] 118/21
83/12 107/13 108/25 108/25) 40/19 41/6 47/7 49/4 I 16/14 18/14 20/2 consideration [7]
clients [7] 40/7 42/15 126/4 130/7 140/20 I 49/19 52/22 52/24 35/24 79/3 83/22 84/4I 18/3 81/25 116/23
45/24 53/15 56/23 199/3 199/5 53/6 54/2 59/6 60/9 I 93/15 107/25 177/15 I 132/9 144/16 161/15
60/5 68/6 commented [1] 60/12 65/9 65/24 68/7I 182/23 182/24 191/19] 176/19
clients" [1] 45/12 156/17 - 74/1 76/2 76/3 87/5 I 201/22 considerations [3]
close [8] 38/17 70/21 commenting [2] 122/7 122/14 122/19 Iconcerning [4] 35/22I 101/15 133/16 199/25)
76/12 93/24 130/7 101/21 104/4 124/10 125/3 125/5 I 41/25 88/19 106/8 considered [10] 1/19
430/12 130/24 144/4 commercial [4] 125/7 125/14 126/5 Iconcerns [13] 7/9 2/22 4/14 48/22 51/23
closed [4] 1/12 1/19 182/6 182/12 182/20 I 126/10 126/23 127/2 I 14/16 14/24 23/1 23/7I 119/8 120/19 137/8
150/25 158/22 183/7 127/3 127/10 127/11 I 39/22 45/12 104/21 146/22 147/3
closely [3] 102/5 commissioned [2] 127/14 128/15 128/16) 136/6 136/18 139/2 I considering [2]
420/12 138/21 16/1 32/13 128/19 128/22 128/24) 139/14 140/10 125/3 128/23
closer [1] 197/13 commit [5] 9/4 51/8 I 129/6 129/7 130/8 conclude [1] 40/20 Iconsistencies [1]
Closure [1] 150/24 51/20 52/2 52/3 130/11 131/15 134/7 Iconcluded [2] 3/6 6/16
Co [1] 39/25 commitment [3] 9/6 I 135/1 138/14 138/19 I 32/4 consistency [4] 6/13
cogitations [1] 94/9 9/19 51/13 138/21 139/21 141/25I concluding [1] 82/18 83/4 172/14
cohort [7] 2/10 2/24 commits [1] 168/1 142/1 147/16 149/4 I 192/14 consistent [5] 6/11
13/17 85/9 86/14 committed [3] 8/14 I 152/14 155/12 155/16Iconclusions [1] 34/19 82/22 133/18
451/12 154/16 8/25 154/2 160/2 161/17 165/1 189/22 173/9
coincidence [2] committee [5] 11/1 167/12 168/23 169/15) concrete [1] 108/19 Iconstant [3] 38/1
57/14 57/19 12/3 94/11 109/15 170/14 170/15 171/15) condition [1] 191/5 I 38/2 185/10
cold [1] 166/15 165/24 172/13 172/14 172/23I conditions [1] 139/1 Iconstantly [1] 162/8
Colin [1] 62/7 committing [2] 173/8 173/11 173/21 Iconduct [4] 16/17 constraint [1] 159/8
colleagues [4] 19/10 134/25 204/12 174/6 174/16 174/18 I 30/7 55/14 60/12 consultant [1] 97/4
19/20 101/13 102/5 Icommon [5] 105/17 I 175/14 175/16 176/19) conducted [3] 16/18 Iconsultation [1] 79/5
collecting [1] 8/18 108/10 113/25 122/12I 176/24 177/6 177/18 I 30/11 106/7 consulted [1] 121/11
colour [4] 1/15 128/6 178/2 179/10 180/6 Iconducting [1] 46/14I consuming [1] 37/25
colouring [1] 188/2 commonalities [1] 180/9 180/17 181/7 Iconfidence [5] 76/21 I contact [3] 57/5
combination [4] 182/2 182/17 182/23 185/24) 110/23 111/14 148/13) 169/24 169/24
1414/3 114/8 147/5 comms [3] 10/10 186/5 187/9 187/10 I 149/4 contacted [2] 49/23
4147/7 14/2 133/17 187/11 187/15 187/23I confident [7] 122/5 I 49/24
combined [2] 25/10 Icomms-wise [1] 189/6 193/5 199/17 I 128/3 135/21 135/23 Icontacts [1] 41/24
1414/5 10/10 competence [1] 136/16 161/14 186/17I contain [1] 118/13
combining [1] communicate [1] 189/16 confirm [2] 3/12 contemplated [1]
114/16 43/20 complaint [1] 191/19 I 29/14 145/13
come [42] 2/4 8/15 communicated [2] Icomplete [4] 48/13 I confirmation [1] contemplating [1]
11/6 44/12 50/10 45/25 84/12 I 79/17 91/5 200/3 38/15 160/4
63/25 70/13 71/12 communicating [1] Icompleted [1] 38/9 Iconfirmed [1] 58/1 contention [1] 65/20
73/2 85/24 110/7 46/7 completely [7] 54/21 Iconfiscation [1] contentious [1]
412/18 115/21 115/24Icommunication [3] 110/20 155/7 156/3 I 65/24 60/11
4149/1 126/7 127/15 14/14 103/14 133/2 I 162/5 170/18 200/25 I conflict [7] 16/5 contents [1] 96/15
433/19 137/12 138/12 Communications [2] I complex [4] 76/7 17/18 18/7 18/9 18/15I context [24] 7/7
1439/19 140/11 144/10) 12/18 34/2 76/24 115/5 115/7 19/1 27/7 15/17 15/20 26/22
454/20 154/25 157/5 communities [2] complexity [1] conflicts [6] 16/4 69/19 77/7 102/10
162/11 164/22 164/231 47/21 47/23 149/24 18/5 18/5 18/19 22/13] 103/9 106/20 107/20
166/10 168/4 180/3 community [1] 101/9I compliance [1] 25/15 114/5 125/19 126/5
182/19 184/11 189/15ICompanies [2] 104/8 I 167/21 congratulating [1] I 126/22 129/2 132/15
1493/5 193/18 198/2 104/11 compliant [1] 124/24 I 170/20 145/5 152/5 152/9
1498/4 198/5 198/8 company [2] 45/15 I complicated [3] connection [1] 99/23] 175/9 176/24 178/21
198/9 62/21 123/3 128/16 175/17 Icons [1] 158/5 181/19 184/14
comes [12] 81/12 compare [1] 147/18 Icomply [1] 167/18 Iconscious [3] 42/12 I contextual [1]
compared [1] 114/9 Icompound [1] 66/2 I 94/5 94/13 102/13
(69) clearances - contextual
INQ00001201
1NQ00001201
c corporate [4] 100/16 I 162/11 166/11 170/16ICreswell's [2] 99/20 Idating [1] 184/15
ag 10178 141/2 192/15 I 174/18 171/21 172/9 I 159/1 day [7] 35/3 83/7
conunue [2] 92/13 I rporation [1] 177/19 178/25 182/15] criminal [3] 1/19 85/10 92/15 132/19
continued [4] 1/3 1/4] 184/25 185/18 186/10 186/15I 138/13 156/19 200/24 205/13
206/2 206/4 corporations [1] 187/13 188/5 198/2 I criminally [1] 62/12 Idays [5] 40/2 42/4
contract [15] 10/1 I 104/12 198/4 198/5 198/8 crisis [1] 201/8 89/12 165/4 196/22
T76 26/1427/5 \eorrect [38] 1/11 198/9 200/11 criteria [3] 13/5 DBT [1] 111/7
27121 31/17 32/8 2/24 4/8 4/9 4/11 4/25Icouldn't [10] 56/13 I 53/15 124/16 deadline [1] 151/12
sso eiie61/21 I 9135/18 7/1 7/3 111/11 119/10 144/10] critical [6] 7/19 8/10 Ideal [21] 20/6 29/19
81/24 61/25 62/4 11/22 15/10 15/11 I 156/14 157/15 159/13I 10/17 106/1 120/8 I 29/25 31/20 39/18
115/24 11713 38/16 38/19 61/21 I 165/18 185/18 202/12) 120/16 41/5 55/21 61/23
contracting [1] 63/18) 64/25 65/14 68/16 counselling [1] 47/11Icriticise [2] 187/12 I 74/23 79/11 97/18
contractor [1] 26/16 I 68/20 68/20 69/24 counter [2] 21/1 204/11 101/14 114/17 122/8
contractors [2] 30/4 I 70/19 74/6 77/20 54/25 criticised [2] 26/25 I 133/10 142/9 153/20
3019 78/14 78/25 80/19 _Icountermanded [1] I 177/20 166/8 187/17 193/14
contracts [2] 26/20 I 80/21 84/1 87/7 88/22] 59/12 criticism [7] 36/3 I 202/23
uit 93/4 93/16 148/14 Icountry [3] 60/15 I 36/5 36/24 118/14 I dealing [17] 27/17
contractual [2] 62/15] 152/20 187/21 170/18) 201/12 203/24 138/6 139/22 203/7 I 37/23 37/23 86/1
87/2 correctly [3] 123/9 Icouple [6] 46/2 46/6 Icriticisms [1] 169/1 I 103/25 105/16 109/25]
contrast [2] 87/6 I 123/24 182/10 100/11 177/14 189/24 critique [2] 148/25 I 122/22 123/24 134/20}
101/11 correspondence [6] I 199/7 149/1 154/22 154/23 154/24)
contribute [1] 156/13] 28/24 47/4 75/8 82/5 Icourse [53] 1/24 9/7 Icross [1] 9/13 188/16 193/15 203/23
contributed [1] 179/4 17916 9/21 11/11 31/6 38/12/crossreference [1] I 203/24
176/14 corresponding [1] 39/1 41/18 44/14 150/18 deals [1] 4/23
contributing [21 103/11 44/15 44/18 44/18 Icrowing [1] 43/10 _Idealt [8] 2/25 37/21
30/17 a7Ne cost [6] 127/21 58/11 71/6 73/10 crucial [1] 59/3 44/22 46/13 58/21
contribution [1] 145/24 147/19 149/24I 74/13 74/20 80/4 82/6I crystal [2] 32/12 76/9 163/20 201/16
69121 188/16 189/2 83/18 86/3 90/12 195/25 debatable [1] 115/20
contrite [1] 94/12 costing [1] 151/6 93/21 94/4 100/21 crystallised [1] 9/8 Idebate [4] 7/18 144/9
control [6] 103/2 costs [41] 5/1 5/5 109/15 110/3 111/18 Icultural [6] 25/11 164/5 177/21
124/25 163/1 163/7_ I 9/10 5/11 5/12 83/16 I 116/25 117/13 119/16) 27/16 33/5 33/5 36/24I debated [2] 121/20
1487/2 187/22 83/24 83/24 84/6 84/7I 123/12 130/1 131/17 I 202/17 144/11
controls [1] 162/23 84/9 112/18 115/18 I 137/23 141/21 147/3 Iculture [18] 32/24 Idebts [1] 73/16
conventionally [1] 115/22 127/19 132/1 I 150/19 157/2 159/23 I 33/7 33/21 33/24 34/2I decades [1] 203/14
202/25 139/8 139/9 162/24 I 163/14 167/7 168/3 I 34/3 34/24 35/1 35/8 IDecember [1] 12/7
conversation [9] 163/7 163/8 164/4 169/9 170/4 175/9 35/10 36/11 37/5 decide [3] 86/9 90/25
136/5 183/4 183/6 171/10 171/13 171/13] 181/25 186/6 191/22 I 37/15 45/17 55/5 56/1) 156/19
171/14 184/5 185/14 I 192/25 193/6 194/16 I 87/11 87/19 decided [2] 84/11
teens wero rene 185/15 185/16 185/16I 203/2 current [13] 1/18 118/11
conversations [2] _ I 185/19 185/22 185/22I courts [4] 1/17 1/19 I 10/21 16/2 19/17 22/6Idecides [1] 65/8
2117 99/16 185/24 186/4 186/5 I 2/5 131/16 22/15 30/9 31/2 84/23I deciding [1] 17/23
convey [1] 170/17 I 188/19 188/20 189/4 /cover [5] 2/23/25 I 85/9 108/22 108/25 I decision [47] 21/7
convicted [6] 1/21 I 199/14 44/19 78/4 98/7 145/4 25/3 25/8 25/9 25/17
1122 2/23 68/14 130/8I COUld [86] 2/4 2/5 6/3I cover-up [1] 44/19 currently [4] 2/18 I 26/17 33/15 33/15
14617 6/5 6/15 7/5 15/5 covered [6] 1/25 2/13) 2/20 10/3 54/17 33/16 58/5 58/10
conviction [8] 48/17 I 17/17 20/23 26/2 2/15 22/14 179/24 curtailed [1] 38/6 I 64/18 79/1 82/12
48/19 64/22 64/24. I 20/15 29/19 29/23 I 198/21 curve [1] 182/19 82/14 82/17 92/7 98/1
66/7 71/14 73/17 30/16 31/4 35/20 36/2I covering [2] 66/20 Icusp [1] 73/6 112/16 116/19 117/2
81/20 52/7 56/13 62/23 67/10 cut [2] 64/17 149/9 I 117/4 117/8 117/13
convictions [16] 1/17I 82/24 66/21 73/3 73/8Icovers [1] 198/24 I) I 117/16 118/10 119/7
2123/23 4/2 43/9 I 75/12 75/18 75/24 ICovid [2] 198/25 = I_I 119/12 119/16 119/20
66/1 67/23 69/20 93/6I 78/10 83/11 90/15 I 201/7 damage [1] 71/8 120/3 120/19 120/25
134/17 138/13 14678 I 26/1 102/16 102/23 ICPS [1] 2/1 damaging [1] 37/8 I 121/15 129/19 140/7
456/20 176/12 178/23} 104/21 106/9 111/14 Icreate [4] 138/1 danger [2] 107/22 152/17 154/8 154/9
4179/7 112/4 112/14 112/19 I 159/25 160/18 184/24I 108/7 154/12 154/14 156/24
Cooper [1] 131/11 I 118/22 119/5 120/6 created [3] 99/20 Idare [1] 205/1 157/12 157/13 158/2
copied [1] 97/24 122/19 124/1 130/5 I 100/4 107/3 data [4] 8/18 87/14 I 158/3 167/9
copy [1] 171/20 131/9 133/6 133/11 Icreating [2] 115/1 I 87/19 118/8 decision-making [1]
core [7] 35/14 39/10 I 135/17 136/10 137/9 I 184/24 date [6] 2/175/12 I 157/13
52/9 124/11 125/13 I 138/15 142/18 143/2 Icrept [1] 7/24 10/22 23/2 30/13 decisions [14] 24/4
132/16 168/12 143/17 146/4 149/10 ICreswell [8] 9/25 151/22 24/7 24/8 25/4 25/5
150/5 151/20 153/11 I 11/11 98/2 103/18 dated [5] 5/10 96/11 I 30/24 38/4 58/6 84/22)
155/10 158/8 161/5 I 122/10 155/11 155/21] 102/17 162/21 190/8 I 115/4 188/7 199/16
161/6 161/7 161/13 I 156/7 dates [1] 13/25 199/18 200/6
Corfield [3] 12/15
12/17 13/25
(60) continue - decisions
INQ00001201
INQ00001201
D 98/10 98/10 98/15 I details [6] 63/9 63/12I 169/21 169/25 173/2 Idiscussing [7]
Declan [ay 303 I 98/16 98/20 98/23 I 87/16 109/18 137/18 I 178/22 186/6 192/17 I 105/11 112/8 121/20
declined [1] 191/17 I 99/19:99/24 100/1_ I 137/21 198/2 134/2 159/6 186/8
dedicated [1] 100/3 I 199/4 100/7 100/25 Ideter [1] 53/14 differently [1] 140/7 I 186/22
deed [1] 87/15 101/4 101/5 102/7 __ Ideterminations [1] _Idifficult [28] 27/19 discussion [9] 2/20
deemed [2] 19/20 I 103/22 105/24 106/21] 73/25 27/22 58/17 58/23 I 21/24 116/7 135/19
par 107/17 107/21 108/11Idetermine [1] 178/3 I 109/25 114/7 134/10 I 143/8 180/5 180/17
deep [2] 118/6 108/21 108/24 109/3 Idetermined [4] 22/21] 141/20 142/3 145/11 I 181/7 184/11
188/14 109/16 112/13 115/16I 23/14 23/18 46/15 —_I 152/8 153/16 153/17 Idiscussions [7] 2/9
deeper [3] 99/22 121/25 123/16 124/13I determining [1] 37/6 I 154/9 154/13 157/25 I 88/8 104/18 109/20
12016 20/2 124/15 125/21 148/12Idetriment [1] 31/1 I 159/2 160/5 161/12
deeply [2] 155/8 154/22 154/23 155/23I developing [1] 184/3 186/22 186/25
1912 157/8 159/9 164/24 I 196/14 188/15 192/11 192/24
defects [1] 13/3 169/2 179/12 180/3 Ideviate [1] 177/17 I 192/25 193/3 203/19 Idismissal [3] 79/17
define [3] 36/3 189/20 195/2 195/11 IDG [1] 109/9 difficulties [7] 37/16 I 80/18 119/8
143/15 192/7 196/9 196/11 197/24 Idialogue [1] 116/1 I 78/9 145/6 187/6 _Idismissed [1] 24/21
defines [1] 178/17 _ I 197/25 203/3 did [67] 1/7 2/1 14/15] 187/8 187/10 187/20 Idisposal [1] 113/16
Department's [5] 15/3 17/19 18/4 18/4 Idifficulty [2] 62/1 I dispute [6] 57/12
definitely [1] 161/14
definition [2] 2/12 98/24 103/3 106/10 I 18/9 20/16 20/18 23/1I 141/15 59/19 59/20 60/2 85/3)
1478/11 163/6 190/24 24/5 28/1 32/7 43/17 Idilemma [1] 195/24 I 139/16
definitively [1] departmental [5] 57/23 58/1 58/8 59/13] direct [3] 32/18 disputed [1] 63/18
144/24 y 101/25 104/6 107/12 I 60/7 61/17 67/10 138/18 156/23 Disputes [2] 57/15
degree [4] 71/16 109/11 123/5 72/10 87/18 100/24 direction [3] 115/9 57/25
701 414/11 118/14 departments [1] 105/9 111/15 112/13 I 115/11 137/10 disrespectful [1]
delay [13] 10/1 70/24 100/22 112/22 113/2 118/3 Idirections [2] 112/14I 56/3
B21 aor 82/9 83/20 [depend [3] 85/17 I 127/13 130/18 133/25] 114/24 disrupted [1] 47/16
84/16 146/4 161/20 86/12 129/1 137/11 148/6 149/25 Idirectly [6] 41/13
170/14 195/18 195/19) dependent [2] 86/8 I 150/1 156/13 157/6 I 60/5 102/11 129/8
4197/4 86/20 159/22 161/4 163/14 I 166/8 170/12 101/2 101/5 103/17
delayed [4] 31/11 depending [1] 123/6 I 163/14 163/17 163/24IDirector [10] 97/7 200/20
aie 32/6 38/5 depends [2] 85/8 164/24 167/10 169/8 I 97/9 97/11 97/21 98/2I distress [1] 200/8
delays [6] 19/19 85/24 170/15 173/20 176/15) 100/5 107/11 120/24 I distribution [3] 14/2
30/1 59/2 83/10 depth [4] 30/1 120/1 I 177/16 178/21 181/9 I 154/24 198/7 35/5 102/20
122/13 161/16 122/15 199/14 181/13 183/12 192/18] Directorate [4] 107/4 I diversity [1] 109/24
describe [5] 37/15 I 193/7 193/9 194/8 107/10 109/9 154/24 IDLA [2] 30/7 31/23
delegate [1] 25/19 "73/93 116/21 122/14 I 194/11 194/19 194/22I directors [4] 23/24 Ido [177] 6/24 9/15
delegated [2] 117/8
1281 193/11 200/9 203/5 204/11 I 32/23 40/10 41/4 9/16 9/17 11/9 16/20
deliberate [2] 31/8 [described [13] 10/13]didn't [37] 18/13 Idisagree [1] 132/12 I 16/23 16/25 17/5
31/10 55/19 56/10 66/18 I 18/18 56/15 62/3 —Idisagreement [1] _I 17/10 18/18 19/4
deliberately [4] 31/11] 82/19 102/1 112/12 I 74/12 104/14 104/18 I 70/8 20/13 21/4 23/10
31/18 "16 SEIT 118/15 123/9 123/24 I 111/19 119/5 1314/8 Idisappointed [1] 24/25 25/2 25/12
delicate [4] 6/10 164/25 167/19 204/9 I 141/14 146/25 147/21 I 117/25 26/25 27/1 27/19 28/9}
16/24 23/21 156/24 Idescribing [8] 12/21 I 147/25 148/21 157/19I disapproval [1] 28/16 29/6 29/10
deliver [8] 28/7 28/19] 103/17 106/25 143/20] 159/11 199/24 160/13) 118/14 29/16 31/21 33/3
56/20 58/25 127/10 I 143/21 147/14 187/6 I 161/22 163/16 163/23I disciplinary [1] 34/23 35/4 35/4 35/8
te7iit 1716 199/17 I 197/12 164/22 164/22 164/25I 168/18 35/15 36/9 37/2 37/2
deliverability [1] description [3] 19/9 I 165/16 168/8 175/10 Idisclosed [1] 57/7 I 38/5 38/9 41/8 41/11
199/18 35/20 124/23 179/23 180/8 181/15 Idisclosure [6] 8/11 I 41/12 41/23 42/2
delivered [2] 173/11 I4esign [6] 19/19 181/18 183/14 187/5 I 8/13 8/16 10/18 10/19I 42/12 42/13 43/5 45/4I
174/18 136/13 137/22 142/5 I 195/18 196/5 204/6 I 10/20 45/10 45/15 45/17
delivering [5] 28/17 I 185/15 155/24 differ [1] 118/22 discount [2] 80/9 I 45/23 48/2 48/3 48/6
86/17 129/13 177/17 Idesigned [3] 72/19 Idifference [6] 59/4 I 131/20 48/12 49/8 50/3 50/7
199/15 137/15 160/18 59/8 71/2190/19 I discounting [1] 52/2 52/3 52/21 53/4
delivers [1] 135/23 [desperate [1] 59/5 I 120/7 177/4 81/14 53/18 55/15 57/21
delivery [2] 155/16 [espite [1] 81/10 I differences [1] discounts [1] 79/21 I 58/6 58/9 58/11 59/18
175/25 destination [1] 145/20 discover [1] 18/9 I 62/25 63/2 63/2 63/6
147/23 different [31] 11/18 Idiscuss [7] 40/21 I 63/7 67/11 71/4 76/5
demonstrate [3] .
1411/6 152/20 163/1 detail [13] 23/16 78/8I 12/8 24/14 34/9 54/21I 41/1 117/22 129/21 81/12 81/15 83/3 85/2
denying [1] 165/21 109/4 109/7 109/21 I 68/21 70/10 80/2 80/5I 169/7 169/11 169/15 I 85/5 87/8 88/9 88/23
departing [1] 39/7 115/15 116/8 117/22 I 81/4 82/24 82/24 discussed [8] 51/11 I 90/14 91/17 92/12
department [58] 2/2 133/1 133/11 156/16 I 89/16 101/18 101/20 I 87/9 87/10 150/9 92/21 93/21 96/2 96/6
26/3 59/10 96/23 180/4 198/21 111/18 119/7 129/20 I 165/6 187/12 189/1 I 96/7 96/13 96/14
96/25 97/3 97/6 97/20I 4etalled [2] 22/15 134/2 134/20 142/17 I 189/7 100/6 101/10 102/12
24/13 142/24 162/5 169/13 Idiscusses [1] 166/19] 104/25 107/8 107/13
(61) Declan - do
INQ00001201
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D 144/22 163/18 164/11] 84/17 93/6 124/23 130/21 134/12 149/21) 166/13
do... [76] 107/21 169/10 174/23 175/1 I 136/1 136/10 137/20 I 158/20 165/4 189/21 Iemails [3] 9/5 26/22
1409/1 110/11 110/19 I 200/16 200/20 138/16 139/19 141/9 I 196/22 53/24
112/12 112/22 113/3 [DOMINIC [2] 1/3 141/12 142/21 144/18) easy [4] 142/5 Emanuel [1] 60/10
413/22 113/23 114/2 206/2 157/5 166/4 172/4 184/24 184/25 187/19] embedded [2] 46/22
4115/2 1146/2 117/9 Idon't [122] 5/23 7/6 I 172/10 179/2 179/5 Ieconomy [1] 97/13 I 47/1
117/10 120/23 122/2 I 7/7 10/7 10/25 14/10 I 180/6 180/6 186/21 Iedge [1] 23/20 embroiled [1] 47/1
134/16 135/15 137/22I 14/11 17/23 18/2 21/2I 189/15 193/18 200/2 Iedition [2] 122/21 emergency [2] 160/4
137/24 139/2 139/24 I 28/14 29/25 32/21 download [1] 45/8 126/25 160/20
1440/1 140/7 140/10 _ I 34/16 34/23 34/24 draft [5] 12/2 135/10 Ieducation [2] 47/15 Iemotional [1] 147/19
140/15 142/4 143/6 I 39/6 35/12 36/23 135/16 138/6 175/10 I 47/16 emphasise [2]
4143/25 144/12 144/15I 37/19 37/20 38/6 41/1I\drafting [8] 118/5 _ effect [10] 35/23 37/8] 195/15 204/5
1as/t9 146/5 147/22 I 50/14 51/18 53/13 I 119/6 139/17 156/13 I 38/14 104/2 122/18 Iemphasised [1]
taaia 151/21 12/9 I 53/21 53/21 53/23 I 186/16 176/2 176/21 I 127/2 143/20 153/2 I 202/16
54/13 55/7 57/19 58/4 176/21 161/15 171/3 employed [2] 27/3
tee we prs 59/18 61/22 63/10 drag [1] 32/7 effective [3] 109/22 I 27/4
1455/1 157/16 159/16 63/14 65/12 66/11 dragged [1] 31/16 171/9 171/10 employee [4] 22/15
1460/8 160/17 160/22 66/13 71/19 73/10 dragging [1] 24/22 Ieffectively [11] 5/9 I 24/14 24/20 113/19
1460/23 160/24 160/24 76/14 76/25 77/6 drama [3] 15/19 5/16 21/9 21/15 54/11/ employees [3] 16/2
164/20 166/24 167/6 79/16 84/13 87/10 15/22 21/4 103/3 115/1 152/11 I 21/21 24/16
1467/19 172/16 173/6 89/6 91/2 92/13 92/14/ drastic [2] 113/20 166/4 173/19 186/9 Iemployers [1] 18/7
173/13 173/16 174/23 102/19 105/2 106/25 I 163/9 effectiveness [3] employment [3]
1475/4 175/15 176/13 110/21 116/11 116/14] draw [5] 101/2 101/5 I 103/1 190/8 190/18 I 23/20 24/19 25/13
1484/19 186/14 187/19 116/17 117/6 119/12 I 189/22 196/21 200/20I effects [1] 43/2 enable [1] 110/17
488/10 194/3 194/11 120/10 120/14 121/14] driven [3] 19/17 efficiencies [1] 86/13Ienact [1] 165/18
494/17 195/12 195/18 121/17 122/4 125/9 I 135/22 143/15 efficiency [2] 138/17 Iencourage [2] 61/6
1496/23 201/2 202/20 126/4 126/11 128/8 I driving [1] 136/18 163/19 61/6
document [15] 11/20 130/25 132/8 132/14 Idropping [1] 20/17 Iefficient [2] 85/17 I encouraged [1] 55/4
ga/4 88/12 102/17 I I 132/25 133/21 1394 Idue [14] 10/2 11/11 I 86/17 end [19] 8/14 8/14
1402/20 102/24 106/18 140/24 141/22 141/25] 21/21 22/18 90/12 effort [1] 66/23 38/17 51/3 51/9 55/20)
108/16 125/2 139/19 143/17 143/18 144/9 I 136/21 158/20 162/25I efforts [2] 186/20 66/6 114/4 117/19
450/6 153/14 156/12 145/12 147/11 148/8 I 190/18 193/6 194/9 I 197/3 132/3 141/7 142/6
489/15 193/18 149/3 151/22 154/1 Iduring [17] 22/3 32/3Ieg [1] 2/10 147/20 149/8 156/22
documentary [1] 154/14 156/1 158/6 I 34/12 36/17 70/5 eg assistants [1] 161/4 188/24 191/10
160/15 163/21 163/23] 109/1 111/15 114/12 I 2/10 193/9
documentation [3] I 164/1 164/14 165/10 I 122/26 1339/8 149/21 eight [2] 18/24 39/5 ended [2] 153/16
ott O14 81/23 165/10 170/9 173/25 I 152/18 165/4 168/22 Ieither [9] 34/11 65/23) 192/14
documents [10] 56/8) 174/2.174/12 174/17 I 189/23 193/1 205/2 I 88/25 119/6 138/20 I ending [1] 70/24
55/9 95/25 97/23 174/25 178/17 183/20Iduties [1] 167/18 I 174/9 176/21 180/20 Ienemy [1] 55/5
109/6 118/1 124/7 I 186/18 186/23 187/14Idynamic [4] 165/8 I 192/19 energy [4] 96/25
425/13 157/11 182/22 189/25 193/19 194/24I 184/4 185/14 186/7 Ielaborate [1] 87/13 I 111/17 168/19 201/11
does [33] 6/19 7/13 195/4 195/12 197/21 I dysfunctional [2] element [1] 154/21 Iengage [2] 105/23
198/11 198/12 199/5 I 30/17 36/15 eligibility [6] 53/14 I 137/6
ant one ane. 5) 199/9 200/17 20/6 IDyson [3] 4/16 4/17 I 63/21 63/22 63/25 Iengaged [6] 23/11
@6/9 68/1 68/18 72/24) 204/20 4/21 64/3 65/6 30/7 42/21 105/12
73/2 80/7 81/13 82/23/4ONe [28] 18/22 E [eligible [4] 2/13 62/5 I 105/14 169/12
83/15 85/17 86/12 I 19/13. 23/22 26/14 I= ___________I 88/24 89/8 engagement [7] 7/13
91/22 102/1 106/6 I 28/10 29/16 34/20 each [13] 43/2 45/1 I Elliott [1] 40/13 27/23 47/23 63/3
125/13 125/6 126/21 I 21/5.46/6 48/12 48/14] 116/13 124/16 137/2 Ietongating [1] 25/6 I 79/10 104/20 130/21
428/24 130/10 136/25] 90/16 53/3 55/23 141/10 142/17 161/20] else [41] 15/21 18/13 Iengaging [1] 104/5
459/23 177/1 197/13 I 96/14 66/9 66/12 161/25 170/22 180/14I 28/17 28/19 48/6 _Iengine [1] 60/21
197/17 67/12 77/9 85/14 181/12 193/22 56/19 89/7 143/25 —_IEngland [1] 1/25
doesn't [25] 14/1 137/14 162/5 163/12 IEarley [1] 40/13 147/19 174/22 200/19I enhance [1] 102/25
14/3 24/23 27/4 55/24I 164/10 167/7 172/23 Iearlier [24] 61/4 elsewhere [1] 33/24 Ienormous [2] 160/6
81/7 83/16 87/6 91/24I 182/6 191/8 87/14 90/8 102/4 elucidate [1] 70/4 I 193/1
105/17 108/4 10/7 IAoubt [6] 53/11 60/16) 115/12 137/1 140/4 elucidated [1] 120/2 Ienormously [1]
118/13 135/14 1426 I 96/15 66/16 79/8 143/11 144/22 147/3 Iemail [28] 6/6 6/6 8/1I 105/10
160/22 162/7 162/7_ I 119/20 147/4 148/4 150/8 I 8/5 12/7 12/9 12/20 Ienough [15] 16/21
tyaat7ario 177m [down [44] 8/6 9/16 I 150/12 156/22 15915 I 13/4 13/7 13/9 25/24 I 29/11 31/20 40/15
478/10 196/19 197/17] 9/24 12/8 12/14 12/23] 168/11 170/25 172/19I 26/3 26/21 29/1 29/4 I 53/16 53/22 80/24
2046 13/8 13/19 15/8 21/5 I 183/7 191/20 195/10 I 41/25 53/25 60/11 I 80/24 86/9 91/1 12/4
doing [12] 27/12 2116 21/20 21/25 2/9I 197/15 200/6 71/3 72/12 130/6 136/23 150/1 165/1
Dart, Serie 137/19 I 22/22.43/20 43/21 earliest [1] 202/8 I 131/10 132/19 136/3 I 165/6
46/8 63/14 75/19 early [8] 129/3 155/11 156/2 159/1 enquired [1] 182/16
(62) do... - enquired
INQ00001201
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E 193/14 204/25 existing [2] 49/5 externally [1] 132/2
a 49) 6/14 da/aiet cetera [25] 7/19 I evidential [9] 53/15 I 103/9 extra [3] 49/11
core te ee ana] 959517716 17/16 I 7912 79/14 79/16 exists [1] 62/14 152/24 161/25
61/19 106/11 108/14 I 25/14 25/14 28/11 I 79/24 80/8 80/15 81/5Iexit [3] 27/20 97/17 I extraordinary [3]
Toa19 171/10.172/7 I 28/11 42/4 42/5 44/20) 141/15 97/18 196/8 196/13 200/17
ensured {1} 117/21 I 44/2046/19 82/25 exact [6] 109/18 exited [4] 26/12 extreme [1]_114/3
ensures [1] 46/11. I 82/25 104/8 104/9 I 136/9 137/20 181/22 I 27/18 56/1257/17 extremely [5] 23/8
eneurinetal rio I 115/24 115/25 12715 I 178/10 178/12 exoneration [3] 33/14 36/22 37/24
13318 eat2 127/5 152/25 188/21 Iexactly [16] 43/17 I 48/13 48/16 146/15 I 195/16
Enterprise (1) 96/23 I 199/14 69/6 90/14 90/21 97/2/expand [4] 1/14 1/14 I=
entire [3] 27/14 36/9 [ete [1] 8/15 109/7 133/7 133/11 I 2/5 191/3 __
91/5 ethical [1] 133/16 I 135/17 146/12 153/25Iexpect [7] 109/13 _ Iface [10] 34/25 56/1
entitled [4] 901g [EU [1] 9717 154/14 159/8 169/10 I 130/1 130/14 131/19 I 72/7 73/14 83/14
Oi 3H 17a leven [24] 27/249/2 I 178/17 179/24 155/6 168/3 186/10 I 83/14 92/3 121/19
entity [4] 9/7 61/11 I 53/4 55/20 62/4 66/19Iexamine [2] 16/4 expected [2] 11/7 I 156/6 201/20
Ste aD 70/24 73/11 91/14 I 75/20 417 faced [2] 62/17
entry (1 17210 I 91/21 92/19 125/15 Iexamined [1] 82/1 expecting [2] 86/12 I 192/18
environment [8] 130/15 140/9 140/14 example [40] 12/9 I 85/21 facing [7] 37/11
Tete Tet Dept I 147/8 148/17 1595/7 I 14/24 17/22 26/21 expedite [1] 197/6 I 97/12 151/8 151/16
27/16 33/12 33/17 I 158/12 186/11 194/9 I 28/5 37/23 43/6 46/6 Iexpenditure [2] 187/18 195/22 195/24
sais eoiet dari. I 197/19 204/8 204/13 I 46/16 49/3 56/22 I 126/2 127/4 fact [19] 4/19 11/14
envieaged [1} 148/22,e¥ent [1] 94/21 63/16 70/11 71/11 expense [1] 175/18 I 22/22 34/18 53/16
equal fy 19/1 events [5] 102/6 I 72/1 75/17 77/25 _ expensive [2] 60/15 I 58/15 68/14 81/10
cqually [1] 185/18 I 115/12 120/12 199/13] 78/18 80/6 80/10 81/9) 13473 84/14 90/7 118/22
enoneously {1} 203/15 105/11 107/3 110/15 Iexperience [10] 120/15 121/1 157/11
sbeatie eventually [1] 159/25] 112/17 113/8 113/12 I 20/13 28/1 36/10 I 167/4 167/25 168/16
error [10] 87/22 ever [15] 34/13 44/13) 114/10 115/19 116/17I 94/20 94/25 109/23 I 180/24 192/13
88/11 120/4 127/24 I 46/11 50/10 95/2 128/3 128/5 128/11 I 113/2 181/23 182/13 I factor [3] 30/17
1428/6 128/12 167/21 118/18 163/18 164/8 I 129/2 136/25 146/17 I 196/22 37/16 132/17
167/23 171/25 172/25I 164/14 168/2 174/7 I 178/24 187/22 199/1 Iexperienced [6] facts [2] 122/4
errors [3] 13/3 174/8 177/16 194/8 I 201/6 33/22 33/23 35/11 202/11
148/18 148/20 194/22 examples [8] 62/2 46/25 129/9 182/5 factually [1] 130/23
escalate [5] 41/23 every [11] 33/15 35/3I 72/24 75/14 110/25 experiences [7] failing [2] 58/25
42/8 42/11 42/14 40/4 55/15 60/6 61/17I 113/5 113/9 201/5 I 39/22 42/19 43/25 I 202/20
64/19 85/10 94/15 130/3 204/1 45/1 45/14 45/24 failure [4] 30/22
escalated [4] 16/15 160/12 175/10 excellence [1] 104/3 I 47/19 106/1 116/21 167/18
18/15 28/19 64/20 [everybody [4] 33/14 Iexcellent [3] 11/14 expertise [1] 20/12 [fair [65] 20/6 59/6
escalation [2] 106/24I 94/23 134/4 141/21 17/25 77/19 expired [1] 27/21 72/12 73/9 82/16
169/20 everybody's [1] except [1] 129/13 explain [4] 9/17 82/22 83/5 98/7
especially [3] 23/23 144/23 exceptionally [1] 20/16 57/3 78/7 118/23 122/12 122/21
43/14 141/8 Everyone [1] 56/9 I 160/5 explained [3] 57/11 I 123/12 124/7 125/14
essential [1] 174/25 everything [6] 28/12 Iexceptions [1] 86/25 195/10 126/10 126/13 126/14)
essentially [7] 62/17 41/5 116/10 174/22 151/11 explanation [1] 127/10 127/11 127/14)
70/4 72/6 78/23 82/13 178/13 200/19 excessively [1] 148/7) 186/18 128/20 128/21 129/6
84/11 184/23 evidence [60] 16/11 Iexchange [1] 183/22 Iexplanatory [1] 89/1 I 132/5 140/23 144/4
establish [2] 50/13 17/8 18/4 20/8 21/21 Iexcluded [1] 1/23 explicit [2] 113/11 147/15 157/1 163/7
410/1 22/3 25/16 26/13 executed [2] 13/21 139/16 17115 172/15 172/16
established [2] 30/21 28/22 30/13 30/15 38/13 explicitly [2] 176/18 I 172/22 173/8 173/10
1400/5 30/22 32/21 45/20 executive [13] 15/6 I 200/24 173/16 173/18 174/6
establishment [3] 49/23 64/5 79/24 16/16 23/24 27/15 explored [2] 50/6 174/15 174/18 174/19)
1400/6 124/9 130/11 80/23 80/25 81/11 32/22 45/2 45/4 45/9 I 126/1 174/20 174/21 174/24)
estimates [1] 151/5 81/14 86/18 93/22 45/11 45/13 102/23 Iexpression [1] 175/13 175/20 177/11
estimating [1] 148/3 94/1 95/23 96/19 113/10 123/1 178/12 177/18 177/25 178/1
estimation [3] 71/17 108/9 108/17 122/9 Iexecutives [4] 22/4 Iexpressly [1] 170/13 I 178/3 178/7 178/9
71/24 193/24 122/10 141/1 141/12 I 39/21 46/1 46/3 extend [1] 30/6 178/11 178/13 178/15)
et [26] 7/19 9/5 9/5 141/17 141/23 143/6 Iexercise [2] 17/13 Iextensive [1] 144/9 I 178/17 178/18 178/21
17/16 17/16 25/14 151/19 154/7 159/6 I 24/16 extensively [3] 126/1I 178/22 181/4 196/13
25/14 28/11 28/11 171/12 173/19 174/3 Iexhausting [1] 144/11 203/3 199/17 200/7 202/4
34/1 42/4 42/5 44/20 174/14 174/14 180/5 I 163/12 extent [11] 22/23 fairly [7] 37/9 37/17
44/20 46/19 82/25 180/10 181/6 186/9 Iexhaustive [1] 47/8 I 97/21 99/18 102/4 37/19 101/12 141/24
82/25 104/8 104/9 188/20 188/25 188/25) exist [2] 98/23 104/4 105/11 105/13 173/1 173/1
415/24 115/25 127/5 189/6 189/14 194/25 I 160/13 125/11 160/3 180/9 Ifairness [3] 142/23
427/5 152/25 188/21 197/13 201/19 202/4 Iexistence [2] 62/24 I 181/7 175/22 199/18
202/5 202/6 204/18 I 89/16 external [1] 19/17 faith [6] 56/25 57/2
(63) ensure - faith
INQ00001201
1NQ00001201
F figures [2] 66/22 I Fiscal [1] 62/11 formality [2] 18/14 I 173/10 173/18 174/5
faith... [4] 58/7 58/10 I 79/20 fit [1] 126/22 168/21 174/15 174/18 174/20
faith... [4] 8817 58/10 lite [4] 55/11 fits [1] 133/12 formally [4] 18/2 174/21 175/20 177/11
fall (2) 2/11 119/23 {fill [5] 89/2 89/5 89/6 Ifive [5] 34/22 93/19 I 46/22 46/22 183/19 I 177/17 177/21 177/25
falling [1] 200/13 91/1 92/15 95/8 193/21 200/22 Iformer [1] 151/12 I 192/5 195/20 196/2
fallout [1] 185/17 _Ifilled [2] 90/22 90/24 Ifix [3] 48/5 48/6 forms [2] 92/15 196/6 196/12 199/17
familiar [1] 195/6 {final [14] 3/15 3/17 I 204/6 109/8 200/7
families [3] 43/3 29/18 51/21 65/20 —_Ifixed [9] 5/9 27/21 Iforth [3] 10/2 139/6 I fully [5] 37/9 37/17
‘47/12 201/23 70/1 195/20 196/2 I 55/20 129/16 146/7_ I 152/21 37/19 152/12 178/13
family [21 40/8 49/4 I 196/6 196/12 197/4 I 146/8 146/23 147/2 forthcoming [1] function [4] 113/14
famine [1] 197/9 finally [4] 10/21 147/5 186/11 functioning [1] 99/25
fantastic [1] 11/17 I 38/22 66/17 87/11 fixed-term [2] 27/21 Ifortress [1] 54/9 Ifund [1] 132/2
far [14] 3/1 3/6 3/7 finance [3] 154/4 55/20 fortuitously [1] 28/5 Ifundamental [3]
41/10 30/15 37/10 I 194/21 155/5 flagged [1] 184/2 I forum [3] 17/1 23/13 I 146/14 192/10 192/19}
65/13 77/17 79/3 finances [1] 179/4 I flat [1] 143/16 83/2 fundamentally [1]
79/10 144/6 177/16 financial [18] 73/14 Iflexible [1] 83/9 forward [12] 2/4 2/4 I 193/16
178/8 179/16 78/9 100/15 100/25 I flick [1] 165/19 19/22 47/6 66/15 68/5Ifunded [1] 169/3
fast [1] 42/13 112/25 122/23 132/16Iflight [1] 166/19 108/12 108/15 137/19Ifunders [1] 158/16
faster [5] 60/16 152/12 153/3 153/22 Iflip [4] 147/11 143/22 191/21 193/23] funding [16] 2/14
145/16 161/6 175/17 I 171/9 172/8 182/25 Ifloor [3] 69/21 72/11 Iforwarded [2] 14/22 I 2/15 9/1 9/5 50/10
200/7 184/9 184/21 186/2 I 178/16 135/21 74/11 151/24 152/3
father [3] 62/8 62/9 I 191/21 192/9 flouting [1] 168/12 found [4] 11/1 54/7 I 152/6 154/11 184/2
e2hia find [13] 5/24 116/8 Iflow [4] 111/3 159/12 161/6 187/10 188/7 190/20
fault [3] 168/6 168/14I 126/11 152/23 159/3 Iflowed [1] 109/14 four [14] 31/22 41/11] 190/23 193/11
168/16 160/14 160/16 161/1 Ifocus [8] 97/16 75/14 124/11 124/16 Ifunnel [1] 142/23
favour [1] 79/15 161/3 161/4 162/9 I 101/18 133/1 170/8 I 137/14 151/24 152/2 I further [31] 2/6 3/18
favoured [1] 121/12 166/1 192/2 170/24 171/6 182/11 I 152/5 154/7 154/10 13/19 22/9 35/12
feasibility [2] 124/14 finding [2] 113/3 184/19 frame [2] 201/4 50/17 50/24 52/5 52/8
424/19 161/8 focused [5] 30/25 204/13 55/11 55/12 63/9
feature [1] 106/22 _ findings [5] 31/3 32/5] 100/12 102/9 199/18 framework [5] 87/13 88/15 90/22
February [5] 6/6 7/10I 22/9 117/22 190/15 I 202/11 100/20 103/1 109/23 I 119/2 119/5 120/2
4111 98119 194/8 fine [16] 23/15 28/16 Ifollow [1] 63/16 110/2 125/12 129/12 138/16 144/18
fed {2} 91/10 91/12 I 52/1065/15 69/12 followed [1] 199/15 frank [1] 145/2 158/24 166/4 172/4
fee [1] 5/9 86/22 88/14 90/7 _I following [13] 44/25 Ifrankly [8] 57/3 94/25] 180/6 186/21 188/12
feedback [3] 34/19 I 92/13 111/25 134/22 I 57/4 74/1 103/11 99/21 102/8 140/19 I 195/10 198/15 204/20}
42/15 136/22 138/3 150/20 162/12 I 106/18 108/10 120/11] 160/6 168/5 192/12 I 206/14
feel [11] 16/23 34/6 I 189/11 193/23 125/1 156/25 163/2 IFraser [1] 26/25 future [2] 49/12
34/16 38/5 49/1 52/231 191/4 193/9 205/13 Ifraud [3] 127/24 183/1
70/22 72/25 141/7 follows [3] 125/9 128/2 172/25 G
164/13 165/16 156/9 175/5 frequency [1] 108/1
feeling [2] 86/18 foot [1] 10/10 Friday [1] 94/11 gap [1] 39/5
142/6 Fiona [1] 40/13 footprint [1] 192/8 friends [1] 49/13 Gareth [1] 13/1
feels [2] 10/9 137/16 Ifire [1] 116/24 force [2] 5/16 197/10 Ifrog [2] 161/19 Gary [6] 4/7 4/10
fees [1] 13/5 firms [1] 60/15 forced [4] 24/19 199/22 4/21 61/2 61/7 64/23
feet [2] 31/17 32/7 _ {first [57] 10/16 11/25 I 194/1 194/3 201/20 Ifront [6] 10/10 95/25 IGary's [1] 61/4
felicitous [1] 11/5 I 14/22 16/8 1613 forecasts [2] 85/15 I 118/10 135/16 181/3 Igathered [1] 30/15
Felstead [1] 60/5 16/24 17/10 23/25 I 153/22 203/5 gathering [1] 188/20
felt [16] 42/19 43/3 I 24/5 24/6 32/13 39/12Iforefront [1] 179/9 [fruition [1] 71/13 Igave [3] 16/11 26/12
55/22 55/22 72/6 40/16 47/10 55/10 __ I forget [2] 21/2 frustrated [3] 37/1 I 65/22
1241/5 121116 131/5 I 82/7 63/6 63/8 69/17 I 109/18 92/16 185/10 GE [1] 45/7
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4164/7 164/20 17011. I 96/1 96/4 97/6 99/7 I 81/16 84/13 138/24 139/14 97/7 97/10 97/14
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6/19 6/25 7/11 87 I 118/12 141/8 142/21 I 41/11 52/6 205/3 139/13 142/15 142/19I harshest [2] 118/17
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420/15 173/15 180/1 193/4 I 182/6 187/21 191/22 I 191/24 loss [16] 67/10 68/15
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114/12 119/24 126/25] letter [29] 28/25 201/3 long-term [5] 191/6 I 70/15 70/17 71/9
1442/7 147/3 153/16 59/21 60/2 81/12 83/7Ilikelihood [1] 166/16 I 191/7 191/8 191/15 I 71/11 71/15 75/22
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65/18 193/7 200/1 118/13 118/18 162/21I 203/7 62/14 70/18 161/21 losses [5] 68/21
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193/11 94/18 95/24 101/16 I live [5] 20/3 51/11 1419/4 122/18 128/13 Imainstream [1]
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4113/7 113/9 114/1 113/9 113/13 113/18 Ilived [1] 203/13 161/4 161/7 161/23 Imaintain [2] 83/3
415/17 118/19 118/20 114/4 114/9 115/5 lives [2] 42/21 78/18 I 161/23 161/24 178/13] 83/4
1423/6 154/23 168/1 115/6 115/18 116/11 Iliving [2] 5/17 5/21 180/13 193/2 199/13 Imaintained [1] 54/9
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114/11 121/5 121/19 127/4 Ilocal [3] 47/22 47/23 Ilooks [8] 30/20 73/7 I 131/17 142/21 149/22
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432/10 135/4 155/5 135/12 135/19 135/21] log [1] 22/7 loony [1] 12/21 124/15 181/14
477/11 188/17 200/8 141/14 141/21 146/6 Ilogical [1] 83/3 Lord [9] 4/16 4/17 majority [2] 105/18
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91/9 95/2 98/6 99/21 IManner [1] 154/3 maybe [7] 53/3 183/19 message [8] 25/23
99/23 107/8 107/13 Imany [41] 21/8 21/12] 114/22 139/15 141/5 Imeantime [2] 8/18 28/7 28/18 46/8 56/17
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123/16 125/5 126/18 I 37/13.46/9 46/24 I McAlerney [1] 40/14 Imeasures [1] 47/7 Imessages [3] 43/3
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71/8 71/19 73/16 43/7 55/12 169/8 169/12 180/24
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186/18 189/10 March [6] 5/14 15/6 I 37/4 38/15 38/24 151/25 169/6 169/8 I 17/2 17/22 28/9 49/5
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126/11 126/12 129/4 IMarriott [4] 15/12 88/19 89/24 91/22 132/19 133/7 133/7 I 117/12 118/13 123/8
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20/24
mitigating [1] 106/10
Mm [8] 8/24 12/11
47/13 61/13 66/4 72/4
84/10 87/7
Mm-hm [4] 12/11
47/13 66/4 72/4
mode [1] 145/16
modern [1] 203/12
modified [1] 37/14
Moloney [11] 52/18
69/13 69/14 71/2
73/20 80/2 82/16
84/14 85/18 86/10
206/12
Moloney's [1] 93/9
moment [24] 50/19
50/23 63/13 65/3
75/18 79/8 82/12
82/20 86/5 118/9
119/3 120/7 120/17
121/5 140/10 145/4
152/11 153/1 153/2
164/19 168/20 170/5
176/9 178/19
moments [2] 120/6
145/11
money [100] 30/25
48/4 48/5 59/23 65/22
66/8 66/20 69/2 83/20
83/25 122/19 122/20
123/19 123/23 123/25)
124/6 124/8 124/14
126/21 126/22 127/1
127/4 127/5 127/7
127/8 127/10 127/14
127/19 128/17 128/21
128/23 129/11 129/20)
129/21 130/1 130/3
131/5 133/16 136/11
136/14 137/3 137/5
137/8 137/17 138/7
139/3 139/5 139/11
139/16 141/20 141/22
143/1 143/4 143/5
144/1 144/13 152/7
152/19 152/22 152/25)
158/15 159/4 159/10
166/2 166/9 167/19
167/20 168/2 168/13
172/19 172/21 172/24'
172/24 172/25 173/12)
173/13 174/25 175/22)
176/7 176/18 176/18
176/23 176/25 177/6
ATTIT 184/24 184/25
185/4 185/11 186/10
186/21 187/8 187/14
187/17 187/20 187/23)
193/12 199/19 201/2
204/13
Money’ [1] 138/22
money's [1] 10/7
monies [1] 66/25
month [4] 22/20
40/21 57/15 89/15
monthly [1] 110/15
months [18] 8/5 15/7
18/24 39/5 41/8 58/1
66/19 70/24 85/25
92/16 151/24 152/3
152/5 154/8 154/10
170/25 195/3 204/1
Moorhead [4] 26/5
29/2 29/4 54/1
moral [1] 195/24
morally [1] 158/25
moratorium [1]
194/23
more [98] 1/15 3/23
6/10 8/1 9/23 45/8
51/18 60/24 63/10
64/2 67/11 70/3 70/11
70/21 71/5 76/7 76/24
77/7 78/7 83/1 83/9
83/22 84/4 88/16
89/18 91/1 93/7
100/25 101/22 103/24)
104/1 106/14 107/2
108/5 110/18 113/11
114/3 115/7 115/19
116/1 116/11 121/12
121/19 123/3 123/9
128/15 129/16 132/15)
133/2 135/1 135/8
137/13 139/13 141/22
142/14 143/8 145/16
147/24 149/5 149/12
152/7 154/17 161/3
161/23 161/24 161/25
164/11 164/11 164/16
165/3 165/15 165/15
165/16 165/16 170/3
175/16 180/4 182/18
183/19 183/21 185/4
185/11 185/11 185/21
186/10 186/20 186/24:
187/3 187/17 191/15
192/7 193/12 193/19
195/10 195/13 200/2
200/6 202/24
morning [6] 1/5 1/6
39/15 52/7 205/2
205/10
most [11] 27/18
27/22 31/6 31/18
35/24 60/15 74/13
101/13 183/4 183/6
197/19
mostly [1] 133/9
mother [1] 66/8
motivating [2] 35/5
132/17
motivation [1] 78/14
move [18] 3/25 6/1
11/8 11/18 21/14
45/13 46/1 48/8 58/24
72/2 73/21 78/17
110/6 129/16 135/25
164/13 165/9 184/9
moved [6] 46/4 58/15
98/4 98/19 129/16
133/8
movement [1]
164/16
moves [1] 203/20
moving [7] 15/6
21/16 46/4 81/16
111/21 165/8 189/20
MPM [1] 138/21
MPs [1] 7/16
MR [133] 1/4 1/7 9/25)
10/17 11/11 22/3 26/3
26/19 26/25 27/20
28/2 28/20 32/1 33/2
33/4 34/15 34/22
35/12 35/18 39/2 39/7
39/12 39/13 39/15
39/20 41/19 45/20
45/20 50/23 50/24
51/2 52/18 52/21
55/24 56/8 56/8 56/23
57/1 57/4 57/5 57/5
57/8 57/16 57/17
58/24 59/17 61/3 62/7
63/15 64/5 66/5 66/15
68/13 69/13 69/14
69/16 71/2 73/10
73/20 75/1 75/5 75/13
75/14 75/23 76/10
76/11 80/2 80/13
82/16 83/6 84/14
84/15 85/18 86/7
86/10 86/17 86/24
88/17 93/9 93/17
93/18 93/22 93/25
95/5 95/8 95/19
116/24 117/3 119/8
119/17 146/5 147/12
148/4 149/14 150/11
155/21 156/7 170/12
171/18 173/19 175/4
176/5 176/5 179/12
181/13 181/23 182/4
182/11 183/3 183/8
183/8 186/9 187/9
187/24 188/15 189/16)
191/11 192/1 193/21
194/4 194/5 195/1
196/7 198/16 198/19
198/21 204/21 205/7
206/4 206/8 206/12
206/18 206/20
Mr Bates [1] 10/17
Mr Blake [12] 32/1
33/2 33/4 34/15 34/22
57/1 61/3 64/5 76/11
88/17 93/18 95/8
Mr Blake's [1] 41/19
Mr Blakey [1] 75/13
Mr Brightwell [1]
26/3
Mr Cameron [1]
176/5
Mr Colin [1] 62/7
Mr Creswell [4] 9/25
11/11 155/21 156/7
Mr Henry [5] 193/21
194/4 198/16 198/19
206/20
Mr Hudgell [1] 83/6
Mr Ismail [1] 45/20
Mr Jacobs [3] 39/12
45/20 50/23
Mr Justice Fraser [1]
26/25
Mr Kalia [2] 66/5
66/15
Mr Marshall [3] 57/5
57/8 57/16
Mr Moloney [11]
52/18 69/13 69/14
71/2 73/20 80/2 82/16
84/14 85/18 86/10
206/12
Mr Moloney's [1]
93/9
Mr Parker [5] 116/24
117/3 119/8 171/18
183/8
Mr Parker's [1]
119/17
Mr Read [2] 22/3
39/20
Mr Recaldin [30] 1/7
35/12 35/18 39/15
50/24 52/21 55/24
58/24 59/17 63/15
68/13 69/16 73/10
75/1 75/5 75/14 75/23)
76/10 80/13 84/15
86/7 86/17 86/24
93/17 93/22 93/25
95/5 147/12 195/1
196/7
Mr Salter [2] 39/2
39/7
Mr Shiju [3] 56/23
57/4 57/5
Mr Staunton [13]
170/12 173/19 176/5
179/12 181/13 181/23)
182/4 183/3 183/8
187/9 188/15 191/11
192/1
Mr Staunton’'s [4]
182/11 186/9 187/24
189/16
Mr Stein [1] 51/2
MR STEVENS [10]
95/19 146/5 148/4
149/14 150/11 175/4
198/21 204/21 205/7
206/18
Mr Trotter [7] 26/19
27/20 28/2 28/20 56/8
56/8 57/17
Ms [31] 15/12 22/10
38/15 43/7 52/17
52/20 55/13 60/5 60/6)
65/17 69/12 81/19
81/23 87/4 93/20
95/16 95/22 96/18
121/10 146/11 175/5
193/21 194/1 194/6
198/17 198/18 198/20)
204/15 204/23 206/10
206/22
Ms Felstead [1] 60/5
Ms Marriott [2] 15/12
22/10
Ms McEwan [1]
38/15
Ms McKelvey [1]
43/7
Ms Munby [10] 95/16
95/22 96/18 121/10
146/11 175/5 194/6
198/20 204/15 204/23)
Ms Page [6] 52/17
65/17 69/12 81/19
81/23 87/4
Ms Patrick [3]
193/21 194/1 198/17
Ms Skinner [1] 60/6
Ms Skinner's [1]
(73) ministers... - Ms Skinner's
INQ00001201
INQ00001201
M 186/20 191/20 192/10Ineither [1] 24/18 75/23 119/19 120/7 121/6
Ms Skinner's...[1]__ 194/13 194/14 195/17I network [2] 163/5 nodded [2] 74/25 121/9 122/7 131/9
55/13 i 196/19 196/22 197/1 I 163/5 90/16 137/11 144/18 144/19)
much [54] 12/17 _ I 199/11 200/21 200/22/networks [1] 35/5 Inominated [1] 4/10 I 145/3 145/17 145/18
16/25 36/24 37/2 39/3 202/4 never [27] 27/5 27/8 Inon [12] 2/9 3/11 146/6 146/10 148/6
39/11 45/18 60/12 I Myself [9] 22/4 52/24) 34/12 34/13 34/17 3/13 3/18 4/3 4/21 153/7 167/22 176/10
60/24 60/24 67/12 68/22 121/16 127/13 I 34/18 44/13 46/11 23/24 31/12 31/12 191/18 193/3 196/4
73/1 79/7 81/7 84/15 I 145/14 149/10 175/11] 47/2 56/2 56/3 57/7 I 32/22 65/11 200/22 I 196/7 196/11 196/16
85/15 85/16 91/1 202/15 95/2 125/16 126/4 _Inon-binding [1] 197/17 197/22 202/19
93/17 93/25 95/4 N I 126/19 140/25 144/12) 65/11 nowhere [1] 53/16
95/10 95/22 97/23 I= I 144/13 164/2 164/8INon-Executive [2] [nuance [1] 116/7
99/24 105/17 110/11 ame [6] 6/7 7/6 164/18 170/12 174/1 I 23/24 32/22 nuclear [1] 173/15
113/10 114/6 114/12 12/15 19/7 38/24 187/7 187/9 194/3 Inon-pecuniary [5] [number [33] 1/12
4145/7 115/19 16/1 I 92/20 nevertheless [2] 3/11 3/13 3/18 4/3 1/14 1/16 2/5 12/8
424/16 123/23 124/21IMamed [2] 31/16 32/7I 55/3 204/11 4/21 22/19 29/14 30/11
429/16 135/4 142/14 [Namely [5] 113/3 new [18] 21/14 22/19Inon-postmaster [1] I 33/10 34/9 36/17 37/1
442120 144/18 144/22I 128/23 171/14 185/16] 22/23 33/6 82/24 86/2) 2/9 47/6 48/1 54/14 54/15
147/23 152/22 157/23 190/22 86/4 88/20 98/10 non-zero [1] 200/22 I 54/15 54/21 54/21
460/18 160/21 173/4 [names [4] 12/3 12/8 I 107/3 107/4 124/12 _Inone [4] 133/23 54/22 76/6 76/10
477/23 190/4 198/12 I 13/22 87/17 124/15 179/17 182/15I 133/25 134/10 187/21I 85/12 89/6 94/7 94/15
National [1] 175/19 I 183/24 188/15 193/17Inormal [6] 135/11 I 96/4 152/20 152/22
cultipte I ton natural [1] 158/14 [next [12] 7/20 40/12 I 143/3 167/7 169/9 153/18 154/19 155/2
101/9 154/2 nature [4] 123/6 40/20 48/18 50/2 170/1 179/19 200/22
Munby [14] 93/20 142/15 169/16 192/9 I 50/13 63/19 115/23 Inormally [4] 104/1 Inumber 4 [1] 76/10
95/16/95/18 95/21 INatWest [1] 34/8 117/23 155/12 166/20I 127/19 136/25 170/2 Inumbering [1] 195/8
navigating [1] 166/17] 202/12 Northern [1] 2/1 numbers [8] 3/10
ee oe awe near [1] 53/16 Nick [9] 14/23 14/24 Inot [260] 11/6 20/19 85/18
4198/20 204/15 204/23) Neatly [1] 57/13 42/20 42/23 43/13 Inotably [1] 151/12 I 94/13 94/14 142/19
2068/16 necessarily [9] 46/15I 44/2 48/17 132/21 _Inote [17] 8/2 11/12 I 153/20
muscle [1] 15/8 49/19 62/4 142/14 162/21 21/17 54/14 101/17 Inuts [1] 112/15
[10] 44/12 156/2 186/1 194/19 I Nicola [2] 15/13 150/6 150/6 150/8 I
must [10] 199/5 202/22 19/24 150/10 150/18 176/17/O
99/12 115/2 115/9 Toe a
415/17 125/7 151/15 Inecessary [2] 141/9 INM [4] 15/12 22/10 I 179/22 183/25 186/22) objections [1] 74/18
141/9 22/16 24/13 187/24 188/10 189/9 I objective [7] 127/8
aoe eeon Cy [NED [1]. 17913 no [85] 2/18 4/15 noted [7] 19/24 22/16] 174/5 177/17 183/13
021 a ton (1] need [34] 8/19 10/9 I 17/4 17/6 17/7 17/8 I 132/24 133/23 135/3 I 190/23 195/13 196/1
4104) 3/2 3/21 9/2I 22/18 29/25 45/14 I 19/21 22/2 24/9 25/15] 166/15 166/17 objectives [4] 172/12
mye bed 16/8 16/13) 20/17 50/22 64/3 68/8] 30/13 32/5 32/9 38/6 Inotes [1] 89/1 173/8 183/15 190/20
18/3 18/4 18/17 19/19] 72/7 88/9 94/24 43/7 43/8 50/1 52/5 Inothing [8] 17/5 obligation [3] 125/11
19/5 22/8 24/11 29/15I 102/19 110/7 115/22 I 53/7 53/11 53/21 23/22 34/18 55/23 I 125/16 178/9
32/19 36/12 36/17 116/17 119/13 126/10] 53/22 55/6 55/16 56/4I 56/14 81/8 159/16 _I obligations [1]
36/23 36/24 37/13. I 139/10 135/20 136/12) 57/9 57/21 59/20 198/15 153/15
136/16 137/6 137/10 I 60/16 61/16 62/2 62/5INotice [1] 196/12 Iobscure [1] 161/6
37/22 38/3 39/9 41/14 i i
41/24 42/6 42/7 42/3 I 138/20 152/22 152/24) 62/14 62/15 62/24 __Inotified [2] 151/14 I observations [1]
43/24 45/24 50/2 166/22 170/9 172/22 I 65/3 65/5 66/15 66/16] 196/10 199/7
50/19 50/22 51/17 I 184/22 190/1 192/1 I 67/22 68/3 68/3 70/11I notifying [1] 12/25 obstacles [1] 147/9
58/18 60/25 64/1 64/5I 1292/2 70/18 72/17 73/14 Inoting [3] 24/15 obvious [6] 60/13
71/2 71/2 82/3 83/7 Ineeded [18] 16/17 I 74/11 74/18 77/16 110/2 153/23 60/14 62/23 148/7
88/19 90/12 91/4 91/7I 389,49/16 43/16 78/6 78/7 78/12 79/5 INovember [3] 1/1 I 158/12 182/2
91/11 91/23 92/7 92/8) 107/2 156/4 159/1 I 79/8 81/23 86/16 49/23 151/21 obviously [19] 35/22
94/6 94/6 98/5 108/18] 169/19 174/6 182/18 I 87/21 88/18 90/1 now [75] 1/13 4/4 I 41/2 66/2 66/22 68/23
4109/1 109/23 110/22 I 184/17 186/12 192/6 I 91/24 92/12 93/2 93/2I 9/13 13/22 14/8 16/20I 75/7 94/21 98/9 102/5}
41115 11375 115/19 I 192/10 192/19 192/22] 97/18 103/7 104/19. I 18/3 19/7 21/1 21/2 I 120/3 120/11 123/23
417/10 113/23 124/20I 221/25 203/18 122/1 141/16 141/17 I 34/7 38/9 38/11 41/9 I 127/17 144/6 158/23
430/21 138/5 139/18 (Needs [9] 68/18 87/8 I 144/14 144/17 158/24 I 41/9 42/18 44/5 45/7 I 160/14 160/16 176/12)
4140/5 140/24 146/2. I 87/9 108/5 108/17 I 463/21 164/11 167/13] 46/24 48/4 49/17 51/9] 194/15
146/23 148/9 148/16 I 115/24 124/16 124/17] 4172/1 173/3 173/23 _ I 52/8 53/1 4/8 57/14 IOC [19] 1/12 1/16
449/10 149/19 150/18) 126/10 174/17 177/19 180/8 I 60/25 61/2 63/18 1/20 2/8 2/13 3/11
488/12 10/2 163/17 IRegate [1] 132/14 I 181/25 191/3 191/18 I 68/17 69/8 73/4 73/11] 11/4 60/22 60/24 61/2
164/20 164/23 167/16I" ly [1] 104/22) 203/10 73/21 75IT 76/13 68/4 69/19 69/22 70/5
167/24 169/14 171/25I"™ nobody [5] 28/10 I 77/25 83/9 83/11 74/7 81/17 81/21 82/1
176/20 177/13 181/17I Negotiati 33/14 53/9 174/7 85/13 90/23 95/6 195/9
182/9 182/17 183/16 I"egotiations [2] 72/8) 174/8 95/24 96/10 96/18 _ Ioccasions [3] 69/1
155/4 nod [3] 75/1 75/6 96/21 118/24 119/5 I 82/8 109/19
(74) Ms Skinner's... - occasions
INQ00001201
INQ00001201
{e) Officials [12] 2/17 I 76/24 112/24 153/17 Ioptimistic [2] 85/14 I 107/10 112/25 113/12
occupy [3] 1719 99/19 102/7 121/24 162/1 148/24 113/15 114/13 115/5
36/25 54/19 140/25 142/22 158/21] ongoing [10] 2/8 _ option [4] 56/21 190/20 190/23 193/17
occupying 2) 20/21 I 159/22 160/4 198/5 I 2/20 29/22 41/10 119/9 158/6 159/23 _I organisational [1]
23/16 200/5 203/2 47/10 164/16 164/16 Ioptions [9] 24/18 19/19
occur [2] 71/7 194/19] offs [1] 187/1 165/14 202/13 202/17) 50/6 134/3 134/6 organisations [2]
occurred [1] 99/9 often [8] 45/8 73/11 Ionline [1] 87/15 134/10 143/14 144/16] 104/1 104/9
occurrence [1] 9/3 73/15 81/23 113/17 Ionly [30] 4/23 5/2 146/24 147/2 orientate [1] 155/18
occurring [2] 37/17 115/7 149/2 160/25 I 8/16 22/8 33/23 35/10I options’ [1] 134/24 I original [4] 13/17
1495/2 Oh [6] 39/17 74/8 57/17 61/10 62/2 or [133] 2/25 5/10 88/4 128/18 140/7
October [10] 3/12 85/6 160/15 161/2 62/23 67/8 70/14 72/3) 5/22 7/19 11/23 14/6 I originally [2] 20/9
41/21 12/5 40/1 96/11 161/22 73/3 84/8 89/5 99/17 I 14/12 15/21 16/4 148/22
402/17 117/17 119/19 OHC [2] 7/12 134/21 I 108/25 111/20 116/9 I 18/11 21/11 22/6 other [51] 1/22 3/1
165/24 166/13 OHCS [1] 155/19 117/12 126/16 133/18) 23/14 24/5 24/6 24/18) 3/19 3/24 22/4 28/10
odd [1] 57/3 okay [19] 21/16 142/18 152/14 159/18) 24/20 26/7 28/5 30/19) 34/1 36/11 37/22
off [19] 3/22 3/25 33/13 33/15 42/15 163/12 196/20 196/21) 33/1 35/17 36/4 38/6 I 39/21 40/9 40/25 43/8,
20/17 21/14 89/14 43/21 65/8 65/15 201/19 39/25 41/4 42/1 46/4 I 48/21 57/13 62/24
4117/8 117/14 121/19 67/25 69/10 92/17 onto [1] 96/19 49/23 55/10 55/17 69/1 83/6 84/7 86/13
424/17 130/13 130/24] 99/17 116/10 121/22 Ionwards [1] 29/23 I 57/16 57/19 58/13 87/6 100/22 101/4
142/4 152/19 153/24 I 149/5 154/17 161/11 Iopen [3] 35/3 91/22 I 61/11 61/24 61/24 101/17 105/18 112/23)
180/1 180/10 199/8 I 153/16 62/24 64/17 65/2 112/24 113/2 113/9
toad font 185/7 old [2] 54/12 54/13 I open-ended [1] 65/24 66/21 70/6 77/6I 114/1 114/20 116/13
offence [2] 169/17 omit [2] 195/7 195/22) 153/16 83/12 83/13 83/13 119/4 124/3 127/4
169/17 Omnibus [1] 25/22 Ioperate [3] 10/25 87/20 89/1 89/25 130/3 137/6 142/11
on [313] 60/20 145/15 90/18 90/20 91/18 142/17 142/25 146/13)
ones Loa) ae eet once [15] 8/16 57/17 Ioperated [1] 62/21 I 99/10 101/4 104/11 I 152/15 158/7 172/20
59/15 59/19 59/20 70/15 70/16 78/11 operating [2] 10/3 104/20 104/21 104/23] 172/20 173/14 176/21
5921601 oa/ia I 9929/6 129/10 I 145/1 105/13 106/8 106/8 _I 187/13 189/1 195/3
bot 70/7 7016 I 129/10 129/18 129/23I operation [3] 139/24 I 110/18 110/19 111/17) 202/5
70/18 70/23 70/25 129/24 141/6 141/8 I 149/22 150/2 112/25 113/14 113/15] others [12] 7/18
TUS Te TriDa 7ei2 I 44/10 operational [10] I 114/19 115/6 118/9_ I 11/11 29/5 55/22
Jeo 7/14 7/1. one [94] 3/3 5/281 I 15/17 15/20 60/21 I 118/14 119/6 121/12 I 66/11 66/14 66/16
S010 89/3 89/9 go/11I 13/18 17/25 20/3 I 112/16 112/22 163/15) 121/12 121/24 122/1 I 97/15 111/18 141/3
89/15 89/20 90/24 I 21/21 23/4 24/10 I 173/18 186/24 187/7 I 125/5 125/6 128/25 I 180/14 203/11
gio oiozene I 27/1827/22 34/11 I 187/17 130/25 133/7 137/5 _I otherwise [2] 111/10
125/14 187/22 178/2 I 35/17 35/20 37/13 operationally [1] _I 139/14 139/21 140/25] 170/14
183/22 183/23 40/7 46/8 48/8 48/16 I 145/21 141/9 141/24 143/5 jour [23] 13/13 40/7
offered [2] 78/19 I 90/19 $0/23 50/23 operations [3] 143/25 146/8 147/18 I 42/15 42/19 42/20
e713 51/1 53/18 53/24 I 104/23 123/21 148/9 I 147/19 148/12 148/19] 42/21 45/12 46/8 52/7
Offering [1] 48/14 I 99/23.60/15 66/17 opine [2] 65/7 82/20 I 154/22 154/23 186/23] 53/15 56/23 60/5 76/2
71/5 75/17 76/10 _Iopining [1] 61/5 _I 158/6 159/11 159/16 I 80/10 85/14 103/23
offers [8] 49/8 74/1 Aa
75/10 77/13 78/3 79/11 82/4 82/9 84/7 I opinion [5] 25/23 161/7 165/20 167/15 I 117/11 117/11 137/24)
129/16 146/7 176/8 I 87/12 88/5 90/7 90/22I 102/24 118/21 137/8 I 168/12 170/12 170/13) 139/6 172/12 173/7
office [225] 94/3 106/4 106/24 I 159/11 170/14 170/14 174/9 I 174/11
Office's [12] 9/1 107/9 107/13 107/17 Iopportunities [3] 175/18 175/22 176/8 I ourselves [7] 43/13
104/03 423/21 139/2 I 108/12 110/8 110/12 I 48/1 104/21 195/9 I 176/21 176/23 178/2 I 43/15 43/20 44/2
148/8 162/24 164/9 I 113/20 115/14 116/17I opportunity [18] 180/21 182/10 184/12I 137/20 143/7 166/1
467/11 184/17 190/3 I 118/8 118/17 120/9 I 28/17 28/18 36/6 191/6 192/22 194/9 I out [52] 1/13 9/11
190/19 192/5 120/14 121/18 128/24] 36/22 45/8 51/14 196/24 197/6 197/15 I 13/23 14/11 15/14
officer [25] 16/17 I 130/10 132/5 134/7_ I 64/25 71/9 71/11 198/7 198/7 200/18 I 21/20 42/3 56/23 57/1
P31 12315 123/7 I 137/5 137/19 138/17 I 71/15 80/21 91/17 I 200/19 201/2 203/24 I 58/15 66/5 66/21
423/10 123/15 124/12I 140/1 140/16 144/17 I 92/11 92/18 94/2 204/1 204/7 66/21 73/2 78/24
124/18 126/7 127/12 I 193/24 153/25 154/6 I 94/18 117/21 191/17 oral [2] 93/25 95/23 I 81/13 83/20 84/2 84/5
428/14 133/15 136/7 I 196/5 157/18 157/21 Iopposed [3] 73/3 order [16] 6/2 7/2 8/1I 92/4 121/2 122/3
136/19 136/28 137/4 I 157/25 158/6 159/12 I 88/6 91/5 12/16 27/20 30/5 122/22 126/21 128/9
137/23 138/4 145/9 I 160/17 161/3 161/14 Iopposite [1] 53/16 I 31/17 32/7 99/13 137/18 141/19 143/25
186/10 168/20 169/17] 188/15 170/6 177/24 Iopt [1] 88/21 99/21 116/2 168/5 I 148/21 148/25 149/1
4170/5 194/7 194/17 I 179/17 181/11 181/12] optic [5] 58/11 58/12 I 184/20 192/6 195/20 I 150/8 159/10 160/11
Officer/Permanent I 188/17 188/18 188/19] 58/13 80/5 81/4 197/18 160/21 170/22 171/1
[i] 1947 193/8 196/24 196/25 Ioptical [1] 25/15 ordinary [4] 160/22 I 180/2 187/11 188/15
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official [1] 147/8 202/5 25/23 Ordnance [1] 114/9 I 191/6 192/4 195/5
ii onerous [1] 134/4 I optics [2] 23/8 25/14 I organisation [12] 195/10 195/14 195/15)
officially [1] 150/25 I oes [6] 73/6 76/8 optimism [1] 149/2 I 35/21 36/4 10218 I 195/20 196/5 196/12
(75) occupy - out
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oe I 108/7 109/12 110/9 Ipage 25 [1] 142/11 I 44/25 Partnerships [6]
outcome [5] 3078 121/23 198/4 page 28 [1] 153/11 I paragraph 54 [1] 103/19 103/20 103/21
141/3 overturned [14] 1/17 Ipage 3 [6] 15/7 21/24I 142/11 104/19 105/23 106/9
outcomes [3] 6/20 I 3/22 4/2.48/17 64/22 I 102/23 138/15 156/20 paragraph 59 [1] parts [1] 96/21
82/18 148/14 64/24 66/1 66/7 67/24) 172/2 155/10 party [4] 23/11 49/9
outgoing [1] 171/1 69/20 93/6 176/12 page 31 [1] 158/9 Paragraph 60 [1] 63/18 99/16
sutene ral 30/1 30/9 I 178/23 17917 page 35[1] 96/13 I 155/20 pass [5] 18/12 43/4
outlined [1] 50/8 overturning [1] page 4 [2] 6/5 179/5 Iparagraph 64 [1] 137/4 141/6 161/21
outlines [1] 29/21 I 146/14 page 48 [1] 195/7 I 158/10 passage [1] 6/8
outlining [1] 22/12 [overview [2] 22/11 Page 5 [1] 136/1 paragraph 72[1]__ passed [1] 62/13
outrage [1] 204/3 83/5 page 6 [1] 170/10 199/12 passes [1] 137/22
outraged [1] 55/17 overwhelming [1] page 7 [1] 13/9 paragraphs [1] passion [1] 33/2
outrageous [2] 27/6 I 86/18 page 8[1] 190/14 I 170/21 passionate [1] 32/17
50/11 owed [1] 194/9 paid [11] 5/5 9/10 paragraphs 2 [1] past [18] 11/19 11/22
outs [2] 179/23 own [12] 51/15 66/20I 30/6 60/16 61/10 170/21 14/17 14/17 15/8
rts 105/19 110/3 123/7_ I 83/17 89/11 108/2 I paraphrasing [1] 15/10 15/15 15/25
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standing [3] ownership [5] 4/20 4/23 11/22 11/23I 132/21 169/11 170/25I path [5] 25/19 141/12
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outward [1] 100118 I 195/24 156/19 64/21 64/23 65/7 65/8IParker's [2] 116/19 IPatrick [5] 193/21
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21/24 24/12 30/9 —________I 81/6 82/10 82/13 Parliament [4] 7/13 I 206/22
31/23 32/24 34/11 IPace [7] 8/10 10/17 I 82/19 82/23 83/13 _I 102/10 126/3 159/18 I Patterson [1] 49/22
35/2 39/9 40/8 54/5 I 11/7 23/7 164/14 83/15 83/25 84/3 84/5IParliamentary [6] _ I Paul [3] 49/22 110/23}
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145/15 1186/4 118/21 I 21/24 21/24 26/2 26/2) 138/14 46/8 49/5 51/24 91/2 I pausing [4] 8/22 99/5I
419/25 135/14 140/13] 22/23 52/17 52/20 I papers [1] 111/7 91/6 91/13 92/10 103/16 133/3
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baie 124/1 124/22 130/6 I 124/1 138/15 138/16 I 202/8 202/25 205/2 I 195/10
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over-compensation I 138/45 142/11 149/16I 156/21 158/10 162/22 participants [4] 142/16 187/8
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over-promise 0) 156/20 158/9 158/19 I 175/4 176/4 176/4 I 142/7 8/20 59/8 59/16 59/25
overall [10] 81/1 81/2 170/10 171/21 172/2 I 190/41 199/12 particular [17] 14/1 I 60/2 72/15 72/17
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overlap [1] 202/23 I page 1 [2] 131/10 paragraph 18 [2] 171/6 184/14 184/16 I 167/1 168/9 194/8
overjapped m1 184/1 116/20 119/14 particularly [18] 194/12 197/15 197/15}
overly [2] 128/25 page 10 [2] 119/14 I paragraph 2 [1] 97/18 101/21 109/5 Ipayments [36] 47/7
Aas 150/21 162/22 114/2 125/20 128/7 I 59/3 59/11 59/22
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105/20. page 12 [2] 29/23 I 190/1 144/23 152/5 154/3 I 125/21 125/24 126/6
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1432/9 9 page 13 [1] 112/8 99/1 110/6 181/23 182/4 194/20 I 129/5 143/2 143/16
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100/7 102/2 102/15 IPage 23 [2] 102/19 I paragraph 35 [1] 102/17 104/1 197/5 197/19
149/16 39/19 partnership [3] 62/8 Ipays [1] 171/14
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21/22 23/22 25/16 190/22 191/2 194/7 I 141/4 106/1 106/3 106/17 I 114/18 160/7 160/8
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34/12 42/3 42/17 199/4 198/2 203/25 110/6 111/2 111/9 politically [2] 192/22
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44/17 44/22 45/13 167/6 plainly [1] 58/3 116/14 122/13 126/21I politicians [1] 147/14I
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182/17 204/3 204/18 I 149/6 130/6 131/9 132/18 IPOL [6] 110/9 123/8 I possibly [5] 25/2
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(77) pecuniary - postmistresses
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principles [10] 49/7 I 148/24 193/5 131/21 203/15 149/10 163/18 168/6
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premise [1] 173/3 I 1414 142/15 1482 I 13/14 public [40] 25/22 I 81/17 81/19 108/18
preparation [1] 158/20 161/11 161/18] progress [5] 10/22 I 104/11 111/11 122/19] 108/23 114/22 116/9
190/11 161/21 162/10 164/1 I 45/18 51/18 51/21 I 122/20 122/23 123/19] 118/7 124/20 125/4
164/18 165/3 172/18 I 149/21 123/25 126/22 127/1 I 125/23 126/8 126/9
prepared [4] 109/5 )
179/22 180/3 192/22 I 175/25 178/16 181/11Iproject [7] 12/25 4127/4 135/11 138/7 I 126/16 126/17 127/12
presence [1] 116/6 192/19 196/25 202/22I 21/23 22/8 29/18 30/1I 138/22 139/3 139/5 I 128/22 144/13 145/14
present [2] 8/13 problem [21] 27/2 31/3 200/11 139/11 139/16 141/20] 147/24 150/15 155/19
‘40/16 27/5 53/18 58/9 60/13) projections [1] 85/20) 143/1 143/5 144/1 156/5 159/23 161/10
presentation [1] 60/14 61/8 62/17 63/1Ipromise [1] 135/14 I 153/6 154/4 154/21 I 161/18 163/17 169/14)
134/19 63/2 111/16 111/19 Iprompt [10] 172/22 I 166/1 166/9 167/18 I 177/13 178/4 181/13
127/25 135/18 145/22I 173/9 173/11 174/6 I 167/20 168/2 168/12 I 181/14 181/17 193/6
MBN? 6016 149/28 I 149/24 155/5 155/5 I 174/15 174/18 174/20] 168/13 176/17 176/25] 197/3 203/7
pressure [9] 70/22 I 199/21 162/7 190/21 I 174/21 177/18 178/1 I 192/20 199/19 200/14I questioned [18] 1/4
118 72/28 73/5 73/9 [Problems [4] 20/3 I prompting [1] 181/16] 201/2 201/24 204/12 I 35/16 39/13 52/20
139/8 163/18 164/16 I 113/2 193/15 198/24 I promptly [2] 37/9 I publication [1] 43/8 I 69/14 88/15 95/19
press [5] 12/19 47/23
201/20 probs [1] 172/1 37/18 published [1] 87/15 I 194/5 198/18 206/4
pressures [4] 73/14 [Procedural [1] proof [1] 79/20 pull [1] 163/10 206/6 206/8 206/10
73/18 186/2 188/16 I 127/17 proper [2] 25/13 pulling [2] 49/9 206/12 206/14 206/18
presumably [3] procedures [1] 19/23] 167/3 153/14 206/20 206/22
134/16 136/7 138/22 [Proceeds [1] 132/4 I properly [8] 8/16 purely [3] 26/17 27/1 Iquestioning [2]
pretty [6] 21/19 25/10)Process [57] 112 I 76/16 76/22 108/14 I 27/11 50/24 109/5
1/16 1/20 2/8 3/23 108/20 126/2 140/23 Ipurpose [2] 130/17 Iquestions [24] 3/23
(78) postmistresses... - questions
INQ00001201
INQ00001201
Q 193/16 195/13 201/14] 193/3 193/7 199/3 7/15 135/10 references [2] 48/15
ew actinng Joa) I rating [5] 106/2 203/18 204/3 204/5 Irecommend [1] 179/7
Saar a. 137/2 137/3 137/5 I 204/8 82/20 referred [11] 3/1 4/17
39/9 47/9 50/17 52/5 137/7 reason [6] 32/12 recommendation [1] I 21/8 22/7 41/12 49/12
52/8 69/16 70/3 73/21 reach [2] 42/2 200/7 I 115/3 122/13 126/6 15/14 103/25 104/2 104/11
88/16 89/6 90/1 94/8. reached [3] 2/18 4/3 I 164/24 167/6 recommendations 151/5 188/2
94/14 96/21 115/14 45 reasonable [6] 5/5 [2] 24/11 103/12 referring [13] 79/21
130/17 176/5 193/19 reaching [2] 43/1 5/11 52/1 99/11 116/2Irecommended [1] 99/6 103/3 108/22
198/20 204/20 164/14 129/13 19/14 132/19 133/14 150/3
queueing [1] 152/16 IFeaction [2] 196/18 Ireasonably [3] 86/19 Irecompensed [1] 159/5 163/4 171/13
uick [1] 86/19 196/19 109/22 199/11 69/9 184/6 185/15 185/19
cuicker [3] 89/14 reactive [1] 179/14 Ireasons [12] 20/15 Ireconnect [1] 95/9 refers [1] 157/11
Waid 149/9 read [22] 13/22 14/23I 82/17 115/22 144/13 Irecord [12] 96/4 reflect [4] 48/23
quickly [9] 3/24 14/24 22/3 39/20 146/4 148/3 154/6 96/11 98/14 99/2 118/24 138/3 197/22
16/21 21/19 41/6 42/23 48/17 102/21 160/11 181/11 187/13) 99/17 109/21 111/6 I reflected [4] 106/2
63/19 72/16 83/20 110/7 132/21 144/2 I 193/9 197/1 111/12 116/20 168/6 I 147/20 175/7 191/25
86/9 147/24 162/21 173/6 174/12 Irebuilding [1] 193/17) 183/20 184/16 reflecting [5] 114/19
ite [45] 1/12 6/23 I 175/6 179/23 180/2 Irebutting [1] 165/20 Irecorded [1] 187/15 I 114/22 177/2 202/19
oit7 33/17 50/21 I 183/18 187/16 189/11]RECALDIN [36] 1/3 Irecordkeeping [1] I 204/17
57/24 72/18 77/12 195/5 199/9 1/7 15/13 19/24 35/12) 128/9 reflection [5] 27/16
77/14 94/25 105/16 read-out [1] 180/2 35/18 39/15 50/24 records [2] 47/19 32/18 87/19 141/5
109/16 109/25 111/12 read-outs [2] 179/23 I 52/21 55/24 58/24 55/12 200/10
413/8 114/15 114/25 187/16 59/17 63/15 68/13 recruit [1] 21/13 reflections [2]
115/13 116/8 123/24 Ireading [6] 42/17 69/16 73/10 75/1 75/5Irecruited [2] 18/25 I 198/22 202/9
1427/1 131/3 132/25 135/8 174/2 176/20 I 75/14 75/23 76/10 20/9 reflective [1] 172/12
137/16 142/23 144/7 I 181/17 199/10 80/13 84/15 86/7 recusal [1] 115/14 reflects [1] 81/5
148/17 148/18 152/17Ifeadout [4] 132/23 I 86/17 86/24 93/17 red [7] 19/9 20/21 Reform [1] 96/24
153/1 157/25 163/9 I 143/11 166/12 180/1 I 93/22 93/25 95/5 23/14 137/3 137/5 refresh [2] 88/3
ready [3] 95/8 138/5 I 122/9 147/12 195/1_ I 137/7 138/2 192/10
Teas s7aot sso I 1924 196/7 203/4 206/2 redacted [1] 88/6 _I refreshing [2] 88/3
Tete 1o/1 as5/a. IFeal [4] 43/23 159/21 Irecall [14] 7/9 76/5 Iredeploy [2] 20/23 I 193/16
ToT torte topo I 181/23 184/22 4109/4 117/6 135/6 I 21/5 refused [1] 78/10
3059 realise [2] 17/21 _I 136/18 139/2 143/17 Iredeploying [2] regard [1] 45/21
ete [1] 42/17 25 143/18 151/21 12/2 I 21/11 21/11 regarding [8] 7/10
quote [1] 42/17 157/10 157/15 194/24I redeployment [2] _ I 12/19 13/5 14/16
R realistic [3] 85/2 Irecalled [1] 49/22 I 19/14 24/18 119/12 138/14 16/1
sais (7) 1456 I 146/23 184/12 recap [1] 183/16 _ redetermination [1] I 180/18
radical 17] Jos ponie Irealistically [1] 74/13Ireceive [6] 59/15 I 75/12 regardless [3] 99/9
201/25 203/18 203/20I"ealities [1] 201/21 I 66/2 135/4 141/22 Iredress [24] 7/23 I 128/12 192/14
radicalism (2) 145/13\"eality [3] 58/13 86/7 I 172/6 172/14 9/16 9/24 17/24 19/13I register [3] 107/11
be 92/8 received [13] 8/17 I 19/22 20/1 21/5 21/6 I 107/12 107/13
RAG [1] 106/2 really [76] 17/7 17/7 I 8/20 10/1 12/24 42/10I 26/8 31/11 31/14 32/5I registers [1] 109/10
raise [6] 6/17 51/2 I 24/2534/26 34/25 I 78/6 12978 132/10 I 32/6 37/2 38/5 38/6 Iregret [3] 18/17
whore 159/23 181/13 I 37/8 44/16 48/24 I 136/24 151/2 158/15 I 38/6 61/10 68/3 18/17 88/6
tai 58/17 63/4 94/24 98/9I 158/16 197/13 122/16 131/15 195/20] regrettable [1] 88/10
raised [9] 1615 I 98/15 102/13 105/15 Ireceiving [4] 23/9 I 200/7 regular [7] 9/3
36/14 36/18 40/1 47/4I 110/1 111/9 113/20 I 135/2 156/2 174/13 Iredress/compensatioI 104/19 110/25 126/2
32/5 105/7 1660/8 I 114/7 11516 116/9 recent [2179/4 In [1] 131/15 126/11 169/23 169/24
tar" 122/5 127/24 12911 I 179/6 redressed [1] 3/5 I regularity [17] 124/5
raising [3] 33/8 39/9 I 139/10 137/7 139/4 recently [4] 84/8 reduce [4] 79/18 I 124/8 124/14 124/23
339 141/23 142/1 14213 I 156/11 156/12 181/20I 115/18 115/23 170/14] 124/24 125/4 125/10
ramp [1] 86/6 142/5 147/24 149/7_ Irecipient [2] 13/6 Ireduced [1] 79/24 I 125/17 125/18 126/1
range [1] 134/2 12/8 152/22 152/22 I 60/11 reduction [3] 19/25 I 126/5 126/12 126/17
rated [Hy 19/10 152/24 153/21 154/14I recognise [14] 2/14 I 80/15 80/20 126/19 127/5 136/17
fates [1] 84/23 154/17 155/2 156/5 I 13/20 27/1 48/4 53/13Iredundancy [1] 168/10
father [26] 30/25 I 160/12 160/13 161/9 I sanis5sii5 58/11 I 24/18 regularly [2] 169/8
39/8 SeiDs 70/03 7217I 161/13 161/13 164/7 I 58/11 63/7 63/7 63/10Iref [1] 180/12 169/11
82/13 84/3 85/25 I 167/8 167/17 167/21 I 101/12 191/18 refer [10] 116/18 _ regulations [1] 5/16
108/7 1162 117/3 I 168/17 175/12 177/13] recognised [5] 3/4 I 117/18 142/11 155/11IRegulatory [1] 96/24
4135/9 138/1 13/6 I 181/6 181/21 182/5_ I 13/18 32/14 50/15 I 158/10 158/18 171/19}reiterate [1] 74/4
139/15 159/25 160/17] 182/8 182/8 182/18 I 168/7 178/1 178/2 185/22 I reject [1] 92/24
170/4 171/14 176/8 I 183/1 183/2 186/7 _I recognition [3] 46/21Ireference [5] 53/24 Irejected [5] 62/4
179/10 180/22 1916 I 187/17 191/18 192/6 I 58/16 121/1 96/4 119/13 127/1 I 62/15 62/21 62/25
192/20 192/23 193/3 Irecollection [3] 3/2 I 150/17 63/17
(79) questions... - rejected
INQ00001201
INQ00001201
R remit [1] 100/17 resolved [5] 5/22 192/5 192/13 193/10 I 107/21 108/6 108/14
wachian 11 Aa/o5 [remote [1] 12/21 5/23 53/17 79/15 reviews [1] 152/7 109/8 109/10 109/15
relate [2] 1H ee8 removed [1] 57/14 I 191/41 revised [1] 77/24 109/20 109/22 109/23
129/8 removing [1] 112/24 Iresolving [2] 152/6 Irevolved [1] 188/7 110/2 110/3 130/13
related [11] 14/3 16/3 remuneration [3] 172/3 rework [1] 166/21 136/11 184/23
37/6 81/20 97/17 31/13 35/6 165/24 resort [1] 24/20 Richard [1] 26/5 risks [22] 6/14 6/16
100/19 107/24 188/8 renewal [1] 115/24 Iresource [2] 31/21 IRichards [5] 12/10 I 6/24 7/5 7/22 20/1
188/13 201/8 201/10 renewed [1] 31/17 155/17 14/8 56/24 56/25 29/8 29/12 29/13
relating [5] 12/19 reopen [2] 6/19 7/2 Iresources [1] 122/23] 57/21 29/14 104/20 104/21
13/1 13/2 13/9 13/23 \rePaid [1] 68/7 respect [7] 5/8 56/6 Irid [3] 21/9 55/19 106/5 106/11 107/15
relation [19] 15/15 repeat [2] 76/17 56/7 116/13 136/19 I 56/2 107/23 108/20 109/10)
19/22 24/13 28/2 31/3 150/11 136/21 157/8 right [95] 17/18 109/13 109/25 110/4
38/10 39/22 51/7 rephrase [1] 194/20 Irespond [1] 179/20 I 22/21 27/23 35/19 166/19
51/20 68/13 75/10 replacement [4] responding [2] 38/1 38/8 38/14 38/22I risky [2] 130/15
81/17 81/25 138/25 185/19 186/3 188/19 I 181/15 188/19 38/24 39/4 39/6 39/9 I 137/16
139/3 139/3 146/10 193/13 response [9] 72/3 39/17 39/23 40/10 RMGs [1] 2/2
1468/9 168/9 replacing [1] 189/2 I 83/7 108/16 115/11 I 40/11 40/17 54/4 road [3] 93/7 141/10
relationship [11] reply [3] 57/9 131/7 I 165/5 170/10 199/20 I 63/24 64/4 64/14 142/21
30/18 62/16 73/23 131/9 204/16 204/17 64/22 65/25 75/16 robust [2] 150/2
73/24 100/20 100/23 Ireport [18] 25/1 responses [1] 111/3 I 79/2 82/21 83/3 84/6 I 165/5
103/23 116/12 184/2 I 27/25 29/20 31/22 responsibilities [2] I 86/12 87/3 89/10 Rod [2] 14/7 14/10
190/17 192/9 32/4 32/10 32/12 100/8 192/6 89/13 89/21 90/7 90/9IRodric [2] 12/23
relationships [1] 32/15 42/10 51/20 responsibility [7] 90/13 90/15 90/21 60/11
87/2 51/21 103/13 105/3 I 52/21 97/9 97/14 91/22 92/24 93/12 role [25] 16/3 16/9
relative [2] 135/14 116/19 118/10 120/8 I 123/16 152/12 155/15) 94/7 95/4 95/9 97/2 I 19/21 23/14 26/17
147/6 175/20 190/8 156/23 97/5 97/8 98/6 98/18 I 27/1 27/2 27/4 27/9
relatively [8] 70/21 reported [1] 62/10 Iresponsible [7] 98/22 103/5 111/23 I 27/11 57/9 58/2 58/14
76/19 112/23 120/8 reporting [3] 106/12 I 24/25 33/3 60/9 113/6 114/25 116/14 I 97/6 97/12 97/16
122/8 165/4 168/15 107/8 107/21 103/22 107/5 109/11 I 119/12 123/8 134/15 I 100/9 175/15 181/9
1481/1 reprehensibly [1] 124/4 134/19 136/4 136/8 I 181/24 182/15 183/12)
relatives [1] 49/14 197/19 responsive [1] 138/23 142/2 146/12 I 183/24 190/9 202/25
Relativity [1] 195/4 represent [1] 123/13 I 165/17 147/17 151/9 152/13 Iroles [32] 11/19
relay [1] 39/21 representation [1] responsiveness [1] I 153/8 154/5 157/4 11/22 14/17 15/9
release [1] 162/25 73/24 165/14 164/9 164/20 166/10 I 15/10 15/15 15/25
relevant [7] 115/4 representative [1] rest [1] 21/1 166/20 167/19 167/23 16/1 16/8 16/15 17/12)
124/24 125/18 128/22! 83/11 restorative [14] 22/3 I 168/24 169/16 172/6 I 17/13 17/14 17/19
1430/2 158/23 188/17 representatives [1] I 39/16 39/18 40/3 175/12 176/3 177/23 I 17/20 20/4 20/19
reliably [1] 27/11 79/5 43/19 45/6 46/6 47/3 I 180/20 181/12 185/9 I 20/22 21/22 22/11
reliant [1] 184/10 represented [2] 5/3 I 48/2 48/8 49/3 49/24 I 185/9 190/5 191/12 I 22/14 22/15 23/17
religiously [1] 23/15 181/3 50/7 51/7 191/14 191/18 194/25] 37/24 38/8 38/10
remain [1] 91/22 representing [2] restore [1] 47/22 195/18 196/19 198/15] 54/19 55/2 58/6 107/4)
remained [1] 98/19 49/15 203/11 restraint [1] 200/14 I 205/9 180/14 192/5
remaining [1] 30/20 reputations [1] 47/22I restricting [1] 36/11 Irightly [3] 1/12 114/6 Irolled [2] 148/25
remediation [24] request [4] 49/18 restructuring [1] 187/11 149/1
718 13/10 1312 188/6 194/14 194/15 I 22/17 rights [1] 78/21 rooftops [1] 43/10
13/14 13/24 14/1 requests [1] 48/11 Iresult [5] 44/4 73/17 Iring [1] 21/15 room [6] 40/15 83/23
14/16 15/1 15/16 require [2] 58/6 83/9 84/3 104/21 ring-fence [1] 21/15 I 84/2 93/20 136/13
19/13 19/17 20/4 20/6! 172/7 resulted [1] 203/15 [rioting [1] 203/23 137/21
26/16 27/3 30/4 30/18 required [4] 20/13 Iresume [2] 52/10 rise [3] 19/11 193/14 Irot [1] 55/23
30/23 30/24 35/25 28/7 102/25 123/19 I 205/6 201/11 roughly [1] 200/22
37/7 54/7 57/22 requirement [3] retail [1] 33/25 risible [1] 57/3 round [5] 121/1
186/12 127/11 141/17 174/22Iretain [1] 22/18 rising [1] 186/4 178/13 191/12 191/14}
remember [20] 19/7 requirements [3] retraining [1] 47/14 Irisk [52] 6/18 6/23 199/13
43/19 105/2 109/7 53/15 126/7 191/16 Iretrospective [1] 6/24 7/2 8/20 9/9 9/20I rounded [1] 178/14
121/14 122/1 122/4 requires [1] 160/6 166/22 9/24 10/4 10/6 16/15 Iroute [3] 130/15
430/22 133/21 139/4 research [1] 1/9 retrospectively [1] 16/19 16/19 19/11 130/25 131/14
143/10 143/14 144/9 resigned [1] 53/1 166/25 20/24 20/24 21/6 routinely [2] 81/21
151/22 152/2 163/21 resistance [3] 164/3 Ireversing [1] 77/18 I 24/15 58/20 58/22 112/15
164/14 168/2 194/10 164/15 164/25 review [19] 11/8 70/23 71/4 72/22 row [1] 40/15
196/23 resistive [1] 164/10 I 11/19 11/22 15/15 72/22 73/4 100/15 rows [1] 40/14
remind [1] 23/2 resolution [2] 86/19 I 15/25 16/18 16/25 103/2 106/7 106/12 IRoyal [1] 34/8
reminded [1] 1/24 172/7 17/1 19/15 46/14 106/12 106/20 106/24IRU [7] 14/3 14/4 14/6
reminder [1] 15/25 resolve [3] 72/6 116/18 121/25 156/11) 107/2 107/8 107/9 14/14 31/10 54/17
151/24 152/3 190/10 191/6 191/15 I 107/11 107/12 107/12) 54/17
(80) rejection - RU
INQ00001201
INQ00001201
R saved [1] 78/2 135/19 136/23 138/2 I 87/6 93/14 122/8 186/20
rule [1] 127/27 ISavings [1] 67/2 143/24 154/16 163/13I 122/19 124/10 125/3 Isecured [1] 43/9
rules [2] 33/8 168/13 /S2™ [9] 8/5 13/4 165/9 165/10 165/12 I 126/23 127/2 127/3_Isecuring [3] 100/24
run [12] 6/2 24/17 26/21 111/2 114/41 172/22 174/17 174/17) 127/25 128/15 129/15I 187/7 187/8
36/19 53/12 148/8 140/25 148/15 183/7 I 177/5 177/8 179/21 132/6 133/1 133/24 I see [79] 6/7 7/12 8/6
149/14 149/7 160/17 I 185/4 179/25 187/14 187/15] 133/25 136/20 139/21] 12/8 12/9 12/14 12/22
4164/24 169/3 182/22 ISay [160] 1/11.6/9 I 188/12 193/3 195/11 I 139/25 140/5 144/19 I 13/8 14/21 14/22 15/3
test 9/13 9/18 9/19 10/6 I 201/14 203/11 149/3 149/4 163/20 I 24/12 26/2 32/17
running [10] 53/6 I 10/11 10/25 11/9 says [34] 8/8 22/9 I 165/2 167/12 169/3_I 36/23 56/11 56/12
ea20 cei gai I 13/10 13/1 13/19 I 26/4 30/2 31/21 50/2 I 169/15 176/20 178/7 I 56/13 58/9 62/25 63/2
1427/18 130/24 155/24) 24/25 26/11 26/25 80/8 102/24 103/7 179/11 186/12 67/14 67/17 68/24
15719 76/1 19114. I 30/14.32/17 35/1 I 104/17 124/2 124/23 IScience [2] 98/20 I 76/19 77/24 80/2
runs [1] 138/14 36/16 36/23 37/14 _I 127/2 130/7 131/11 _I 189/20 95/14 96/2 96/6 96/13
Russia's [1] 201/9 I 41/25 42/3 42/8 42/17I 132/23 133/22 134/23Isciences [1] 97/15 I 97/23 98/13 102/16
aS I 42/25 44/25 53/9 I 138/17 138/18 151/1 IScotland [2] 1/25 I 103/6 104/2 108/5
s 53/13 64/10 54/11 I 152/11 156/22 162/22I 34/9 110/4 111/10 111/19
safe [4] 76/15 77/19 I 56/15 59/20 59/25 I 166/4 166/14 166/20 Iscreen [3] 29/20 I 1412/4 117/21 120/7
77122 173/17 62/15 63/17 64/1 64/2I 172/4 176/18 178/8_ I 106/4 110/7 120/20 121/9 124/5
safely [1] 77/3 67/11 70/4 70/12 —_I 180/11 184/1 185/15 Iscript [1] 56/15 130/6 131/7 132/20
said [63] 5/1 5/20 8/9I 70/13 72/23 80/5 80/7I 188/1 scroll [11] 8/6 12/7 I 138/13 140/2 141/1
8/12 8/17 8/19 9/2 I 80/22 82/21 84/4 —_I scale [9] 122/15 12/14 12/22 13/8 15/8I 141/12 150/21 156/18
9/25 10/9 10/12 17/18I 86/13 89/21 90/3 90/5) 147/6 148/3 149/23 I 21/20 24/12 26/11 I 162/17 162/20 162/221
18/23 22/3 26119 I 92/12 92/14 92/15 I 151/7 165/4 165/7 I 30/9 179/2 165/24 169/18 170/21
28/14 32/5 36/8 53/9 I 92/17 93/294/10 _I 199/14 204/2 scrutinise [1] 138/20] 172/5 172/13 172/19
56/14 56/15 56/16 I 97/16 98/8 99/1 99/7 Iscaling [1] 165/12 Iscrutiny [1] 19/18 I 175/23 179/2 179/5
56/19 56/19 56/20 I 99/11 100/2 10/4 I scandal [8] 39/22 Iscs[1] 107/4 179/16 182/21 183/12
59/18 59/19 65/13 I 100/6 100/18 105/5 I 43/2 46/21 47/16 49/1]Scully [2] 110/23 I 183/15 188/5 188/5
65/23 74/19 79/14 I 107/7 108/22 109/22 I 120/1 200/10 201/21 I 117/5 193/20 194/14 194/25
80/14 81/23 85/4. I 110/8 110/22 111/14 Iscenario [4] 184/4 Isearching [1] 161/1 I 198/15 200/10 201/18
94/11 108/17 18/1 I 112/10 112/20 114/23] 186/23 199/22 200/10ISec [3] 132/22 seeing [3] 106/23
118/8 118/13 119/11 I 1195/2 115/9 115/16 Iscene [1] 98/14 133/14 135/3 106/25 168/2
132/15 134/24 137/14] 118/21 116/22 117/9 Isceptical [2] 149/6 Isecond [27] 12/15 I seek [3] 130/18
439/13 143/25 144/12] 117/10 117/19 118/3 I 184/17 21/19 21/22 3115 I 132/6 140/25
1445/18 147/22 148/9 I 118/15 118/22 118/23Ischedule [5] 70/5 47/14 63/7 96/10 seeking [4] 130/20
1449/6 161/7 161/11 I 118/23 119/10 119/11] 70/7 70/15 70/17 98/25 101/2 102/8 131/2 141/3 200/20
477/14 177/25 180/18] 119/14 119/18 120/23] 191/11 112/7 117/17 119/14 Iseeks [1] 5/6
1487/7 188/7 191/17 I 122/12 123/12 126/11Ischeme [67] 3/4 5/16I 126/7 127/22 140/11 Iseem [6] 35/23 50/11
1492/1 195/3 199/3 128/21 130/2 130/9 I 6/2 6/2 6/25 6/25 7/10I 142/10 143/1 149/16 I 83/2 83/3 130/19
131/7 131/13 132/5_ I 7/11 8/2 8/11 9/1 152/10 153/11 158/9 I 161/22
come) MIO 133/13 136/15 140/2 I 10/18 10/21 10/22 I 172/2 190/1 19/7 Iseemed [2] 130/25
144/23 141/4 143/23 146/3_I 11/3 11/9 22/24 31/13] 202/8 202/16 195/19
salaries [1] 113/11 I 148/23 149/18 150/10I 47/17 49/3 49/7 53/20] secondly [2] 154/8_Iseems [4] 24/22
Salter [3] 39/2 39/3. I 151/10 152/8 163/15 I s9/14.61/961/23 I 201/9 105/21 106/14 176/9
30/7 154/13 154/25 155/1 I 61/23 67/13 67/15 I Secretary [39] 98/3 Iseen [22] 8/9 12/20
Sam [1] 98/4 155/20 157/1 157/17 I 70/5 73/22 81/17 I 98/5 98/16 98/21 __I 21/18 28/24 29/6
same [24] 18/7 21/2 I 158/11 159/20 162/4 I 81/21 87/1 89/15 I 101/24 106/13 106/22I 29/21 33/24 75/4 75/8
57/15 62/17 65/8 83/2) 163/12 164/3 164/21 I 125/14 127/18 127/23] 107/6 107/16 107/18 I 105/25 108/9 117/24
39/18 93/5 93/10 I 164/22 165/3 167/13 I 128/13 129/14 130/9 I 107/25 108/23 111/16) 18/4 143/9 156/12
93/14 94/10 118/8 168/21 170/9 170/11 I 130/11 130/21 130/24) 113/4 115/1 117/7 179/22 190/9 190/12
126/24 127/3 128/8 I 170/15 170/21 171/3 I 136/14 137/15 137/20I 122/25 123/15 132/22I 200/21 201/7 201/14
428/10 128/10 142/17] 171/12 171/20 173/7 I 137/22 138/14 138/25I 133/17 133/23 136/2 I 201/24
4155/6 182/1 18/6 I 173/16 173/20 174/7 I 140/8 142/5 142/8 I 156/18 157/2 157/7_ I SEG [2] 45/7 45/7
4918 197/25 203/7_ I 175/21 178/8 180/6 I 144/3 150/22 151/14 I 157/12 168/22 169/6 ISelect [2] 11/1 94/11
SARAH [5] 95/18 I 182/20 189/24 190/2 I 182/14 184/10 155/16] 17/16 179/18 189/17Iself [1] 184/9
95/21 136/5 180/15 I 192/22 192/24 196/3 I 155/25 157/9 158/10 I 190/10 190/22 191/2 I self-sustaining [1]
206/16 196/17 199/12 201/13] 158/18 167/23 176/24) 194/7 194/17 198/1 I 184/9
sat [1] 103/21 202/8 202/12 204/1 I 178/20 179/8 181/1 I 198/8 19/4 send [2] 59/23 89/7
satisfactory [1] 204/5 205/1 scheme's [1] 149/21 Isection [3] 15/8 _I senior [12] 30/3
saying [40] 6/21 __Ischemes [50] 3/1 I 149/17 202/5 31/10 33/6 39/21 45/9
satisfy [1] 123/17 I 25/18 69/9 73/7 75/2 I 3/25 6/13 11/4 13/6 Isections [1] 180/4 I 98/7 99/18 102/7
Savage [1] 62/7 75/5 77/18 86/11 35/6 41/21 42/6 42/7 Isector [1] 122/23 I 120/24 121/10 121/20)
save [3] 78/4 83/25 I 89/2590/11 91/16 I 47/25 49/5 52/22 Isectors [2] 97/11 I 198/6
846 92/20 94/3 99/12 I 52/24 53/6 53/11 97/13 sense [19] 93/5
120/3 124/21 132/8 I 58/25 69/17 83/10 _ I secure [2] 84/8 106/19 114/4 121/17
(81) rule - sense
INQ00001201
1NQ00001201
s settled [11] 3/13 3/14I 22/24 44/14 65/23 __I significance [2] situation [12] 10/13
sense... [15] 125/4__ 3/18 67/14 76/7 76/16] 67/2 67/9 67/13 67/15] 118/6 151/16 30/10 37/11 62/3 72/5)
144/17 144/24 145/17] 76/22 77/3 90/10 69/6 71/14 73/22 _I significant [20] 13/11] 78/3 131/3 138/20
447/12 157/13 159/9 I 158/16 177/10 81/20 94/21 150/22 I 13/17 19/16 31/6 160/14 166/1 183/22
160/12 161/19 161/25I Settlement [18] 179/8 31/18 37/15 59/2 196/14
465/14 165/21 183/20I 60/10 67/16 70/2 shortfalls [6] 62/12 I 71/21 77/11 82/7 82/9) situations [2] 101/8
184/23 186/18 72/20 77/7 78/15 66/20 81/19 81/24 I 106/14 110/14 111/10] 113/13
sensible [3] 148/13. I 78/17 87/15 88/1 92/1) 81/25 178/24 131/4 131/5 151/7 I six [2] 92/16 204/1
148/17 203/21 132/11 158/13 158/22I shortly [3] 49/16 158/4 159/3 182/12 I sixth [1] 39/19
sensibly [1] 170/16 I 185/16 191/5 195/21 I 96/20 180/4 significantly [4] size [2] 153/25 154/1
sensitive [4] 23/19 I 1966 196/12 shot [3] 33/12 35/19 I 83/15 85/13 86/6 —_I skill [1] 20/16
25/19 33/12 33/14 [Settlement [2] 36/17 186/10 skills [1] 101/22
sent [4] 55/10 166/13] 195/14 196/2 should [76] 6/18 7/18I similar [13] 6/20 11/4Iskillsets [1] 101/20
174/24 174/23 settlements [8] 3/11 I 10/11 18/22 23/25 I 64/20 81/24 113/2__I Skinner [1] 60/6
sentence [3] 27/17 I 9/16 3/17 76/14 77/1 I 24/3 27/5 27/7 29/16 I 114/10 114/11 148/11) Skinner's [1] 55/13
100/2 175/6 183/9 197/7 197/11 I 49/10 49/20 50/6 163/18 167/10 182/6 ISLA [1] 42/4
sentences [4] 177/14ISettling [1] 60/8 50/16 52/3 53/1 53/3 I 196/21 202/20 slate [1] 179/17
separate [2] 4/1 17/4 {Several [2] 30/23 53/5 55/10 56/12 I SIMON [8] 1/3 15/13 Islice [1] 158/17
September [12] 124/3 58/14 63/16 63/19 I 19/24 42/20 122/9 I slides [1] 30/2
S710 84/12 96/2 [SFALA] 20/11 63/19 66/2 68/2 68/3 I 196/1 203/4 206/2 _Isliding [4] 124/22
132/19 133/4 134/14 [Shall [4] 52/10 63/17 I 68/3 68/9 69/9 83/8 Isimple [3] 47/7 48/15) slightly [11] 10/13
4143/7 180/7 150/12 I 163/12 194/2 87/24 95/2 95/25 115/6 11/18 21/20 22/9
4181/8 181/15 162/21 (Share [8] 32/25 33/2 I 11/6 115/7 116/24 Isimplistic [1] 116/4 I 68/21 78/7 78/7 80/2
September 2020 [2] I 24/19 45/5 80/3 117/23 117/24 118/4 Isimply [7] 27/21 135/25 136/1 172/10
133/4 143/7 104/22 116/19 132/3 I 118/11 118/25 121/7 I 64/13 68/18 80/20 _ I slow [14] 8/10 10/17
series [9] 28/23 shared [7] 45/2 45/14] 122/2 123/14 124/4 I 120/11 164/25 204/17) 21/5 21/6 30/5 127/21
99/16 103/6 105/4 I 71/3. 72/22 85/19 129/6 129/8 129/12 Isince [4] 19/15 40/2 I 149/8 149/17 149/20
143/15 148/2 169/21 I 120/8 172/12 130/2 131/5 143/25 I 119/19 194/20 152/5 197/1
4170/4 193/10 shareholder [5] 150/10 155/14 155/24I sincerely [1] 53/11 Islowed [2] 22/22
serious [22] 25/3 _I 100/10 103/10 166/5 I 157/8 158/1 162/5_Isingle [4] 35/3 40/4 I 84/17
5/10 31/25 32/2 37/8) 170/23 190/17 166/25 170/13 172/8 I 97/19 143/19 slowing [2] 9/15 9/24
44/10 87/14 98/9 99/3I Shareholding [1] 172/23 173/16 173/17I sink [1] 201/15 slowly [1] 147/24
99/5 99/13 105/10 I 19/2 173/17 173/18 174/8 Isir [62] 1/5 1/10 1/13 Islowness [1] 8/13
105/19 110/8 111/4 {Sharing [2] 34/16 I 174/18 174/20 17/5 I 4/7 4/10 4/21 35/15 ISM [2] 166/15 184/2
4204 142/1 167/4. I 118/1 177/10 184/9 184/19 I 35/16 36/6 36/22 —_—I small [11] 76/6 76/14
467/21 168/17 182/5 IShe [28] 12/18 14/11 I 185/6 185/7 200/1 I 37/10 37/11 38/4 76/15 76/19 76/22
204/16 14/13 22/12 28/8 202/14 38/13 39/1 39/8 39/14) 77/1 77/3 77/5 7/12
seriously [5] 24/3 28/13 28/18 46/7 shouldn't [7] 58/3 50/19 50/22 51/15 78/3 201/8
149/23 156/4 183/13 I 48/18 56/13 56/13 87/23 154/16 167/6 I 52/7 52/17 61/2 61/4 I smaller [2] 188/17
192/20 56/14 56/16 56/18 177/7 177/9 184/10 I 61/7 64/23 65/14 197/15
seriousness [1] 56/20 57/2 57/4 57/6 Ishout [1] 66/12 65/19 68/21 69/15 Isnippets [2] 44/7
168/6 57/11 57/11 57/14 show [1] 66/22 86/13 88/13 88/15 44/8
servants [2] 101/11 58/2 58/2 58/7 58/8 Ishowed [2] 68/23 90/6 90/10 90/14 92/1Iso [283]
147/14 58/14 110/19 188/2 I 83/8 93/19 94/2 95/10 sole [1] 170/23
Service [8] 98/11 she'd [1] 48/19 shown [2] 21/7 68/17I 95/14 111/20 111/24 Isolicitors [4] 4/10
109/24 158/4 197/18 IShe's [4] 12/12 14/1 Ishows [3] 30/16 112/4 119/13 134/14 I 4/12 74/22 75/9
197/24 198/7 200/23 I 14/14 55/13 55/23 67/9 146/12 149/15 150/6 Isolution [4] 5/24
202/11 shift [1] 204/18 shrunk [1] 111/8 162/10 162/13 162/17I 23/12 201/25 203/18
services [3] 61/4 Shiju [3] 56/23 57/4 ISID [2] 120/20 177/8 193/19 193/22 Isolutions [1] 200/12
100/22 192/8 57/5 120/23 194/2 198/19 204/22 Isolved [1] 5/17
session [1] 56/1 shocked [1] 173/25 Iside [8] 12/10 74/21 I 205/8 205/11 206/6 I solving [1] 198/24
set [20] 15/14 53/13 shoes [1] 149/10 119/25 121/18 121/19) 206/14 some [49] 12/3 22/22
100/15 100/20 101/15IShort [12] 52/15 133/2 164/6 181/12 I Sir Gary [4] 4/21 61/2I 25/2 25/10 30/16 31/1
1402/8 113/16 114/11 I 85/23 89/5 94/3 95/12I sides [2] 64/13 61/7 64/23 37/16 44/6 46/5 69/16
4134/5 137/20 139/10 I 112/2 129/4 162/15 I 116/13 Sir Gary's [1] 61/4 I 70/20 73/21 96/21
4150/1 165/5 169/14 I 1896/2 189/19 192/4 _Isign [5] 59/25 89/11 ISir Wyn [19] 1/10 I 98/8 99/13 102/25
470/22 171/5 178/19 I 199/11 124/17 191/14 192/11] 1/13 36/6 36/22 37/10I 104/11 104/14 104/14
4187/6 199/16 20/17 [Short-term [1] 192/4 Isign-off [2] 124/17 I 37/11 38/4 38/13 39/1] 104/15 109/17 110/25
sets [3] 21/20 122/22IShort-termist [1] 191/14 51/15 65/14 86/13 113/24 115/13 118/21
50/8 193/11 signature [3] 96/6 I 90/6 90/10 90/14 92/1I 122/7 129/3 131/20
shortage [1] 203/25 I 96/8 96/13 94/2 146/12 177/8 I 132/2 135/3 136/5
setting [1] 171/1
shortcut [1] 16/5 Isigned [5] 48/16 _ sits [3] 40/12 42/23 I 138/24 139/20 141/12
settle [4] 8/24 7318 I chorter [1] 89/4 117/8 117/14 152/19 I 66/6 4142/7 142/9 146/3
shortfall [15] 20/12 I 175/9 sitting [1] 1041/8 172/20 175/15 179/8
(82) sense... - some
INQ00001201
INQ00001201
s 132/9 132/16 133/8 I 129/24 171/7 171/8 I 96/11 99/1 112/8 STIP [5] 166/5 167/1
some... [9] 1682/1 134/9 135/20 139/13 Ispeed [2] 42/1 86/15 I 112/9 115/19 116/21 I 167/9 167/16 168/9
183/23 183/23 190/14I 140/2 140/6 140/16 Ispend [4] 110/18 117/10 118/24 119/11Istone [1] 160/13
1491/4 193/12 195/3 I 140/22 141/2 141/4 I 159/17 159/18 173/5 I 119/14 122/12 133/17I stop [3] 89/21 161/7
203/14 204/1 141/7 141/25 142/4 Ispending [7] 110/14 I 133/18 134/25 135/11) 185/12
somefall [1] 132/2 142/12 143/9 145/4 I 143/4 152/7 159/25 I 135/14 135/16 135/18] stopping [1] 199/21
somebody [11] 7/4 145/10 145/21 145/23) 160/13 160/15 193/10I 135/21 140/5 142/9 I stories [8] 42/20
1813 25/05 2712 145/23 146/9 148/6 Ispent [7] 66/19 97/3 I 142/10 148/10 149/16] 43/17 43/21 43/22
2817 28/19 5619 I 148/12 149/2 149/4 I 101/13 108/12 109/16] 151/5 153/12 158/8 I 43/22 44/6 46/11
57/17 113/18 143/25 I 149/10 152/6 152/8 I 130/3 187/14 158/9 170/8 170/9 I 46/13.
q79/15 152/15 153/2 153/5 _Isplit [3] 41/19 41/20 I 171/20 190/2 198/22 Istory [5] 49/16 49/20
someone [3] 12/12 I 153/18 183/23 153/26] 102/1 198/24 199/8 199/11 I 49/21 81/2 120/9
64/11 183/24 154/15 154/18 155/1 ISPM [1] 26/6 200/21 202/8 straight [3] 16/16
something [39] 6/12 I 195/4 196/1 157/17 ISPMs [1] 60/16 statements [8] 44/9 I 49/4 203/6
18/21 18/51 32/25 I 198/5 159/10 161/3 Ispoke [9] 4/16 5/8 __I 94/6 94/6 95/24 96/15Istraight-up [1] 49/4
48/10 47/4 43/04 161/18 163/15 164/8 I 6/12 8/22 15/9 15/13 I 96/18 96/21 204/24 I straightaway [1]
49/11 49/12 50/14 I 164/10 164/15 164/19] 22/12 27/25 44/21 _I station [2] 173/15 I 31/25
50/16 51/22 59/25 I 168/6 168/10 169/17 Isponsored [1] 126/3 I 173/15 straightforward [2]
88/5 76/1 62/23 94/24) 169/25 170/3 173/7 I sponsorship [2] status [1] 123/6 175/21 200/19
1085/7 105/24 107/5 I 174/21 175/11 175/11] 102/18 103/9 Staunton [17] 170/7 Istraightforwardly [1]
1408/4 111/3 114/9 176/14 176/25 178/6 Ispot [1] 37/5 170/12 170/20 173/19I 111/11
115/8 118/18 140/13 I 178/9 178/18 178/19 ISquare [1] 26/22 _I 175/3 176/5 179/2 _Istrategic [11] 46/13
460/19 161/1 1962/5 I 181/12 182/6 183/16 ISR [5] 8/12 8/17 8/19] 179/12 181/13 181/23] 167/17 170/23 1714/1
1462/9 163/18 164/22 183/18 184/20 184/23) 10/12 15/12 182/4 183/3 183/8 182/24 183/9 183/13
465/19 175/18 178/12 184/24 185/3 185/8 ISR2021 [1] 191/5 187/9 188/15 191/11 I 183/15 184/21 187/18)
178/22 180/17 199/21 188/17 191/13 191/20I staff [4] 22/6 26/6 192/1 192/3
203/19 192/1 192/14 193/2 I 30/19 31/11 Staunton's [4] strategically [1]
Sometime [1] 133/5 193/11 193/15 196/21I staffing [1] 15/16 182/11 186/9 187/24 I 180/15
sometimes [5] 55/9. I 201/3 201/14 201/14 Istage [9] 4/2 4/5 4/20) 189/16 strategy [7] 97/1
59/4 66/19 75/21 202/22 203/21 24/23 61/16 64/12 stay [1] 75/18 187/5 187/5 191/7
165/18 sorted [1] 9/11 74/17 135/11 179/9 _Isteam [2] 160/7 191/8 193/16 193/17
sophisticated [1] sorts [8] 23/21 stages [3] 65/2 129/3I 160/9 street [2] 46/18 182/8I
35/7 101/22 115/15 121/3 I 200/14 steel [1] 97/14 strength [1] 145/22
sorry [30] 10/5 14/21 155/4 169/10 169/13 Istall [1] 170/14 steer [4] 129/1 strengthening [1]
37/4 42/13 48/20 192/16 stand [3] 26/10 96/18] 145/22 158/4 192/3 I 184/20
60/17 70/1 74/8 75/23I Sought [2] 2/10 144/3I 175/10 Stein [1] 51/2 stress [2] 72/7 72/7
76/17 87/22 88/7 [Sound [3] 158/13 I standard [3] 143/1 _Istep [8] 63/19 82/21 I strictly [1] 125/15
88/17 97/3 109/4 196/19 197/13 143/3 178/1 113/20 137/19 146/18] strings [1] 197/9
120/24 134/11 138/16) sounds [3] 63/21 standards [2] 81/5 163/9 174/7 174/8 strong [3] 53/3
149/14 150/10 150/11 1341/7 151/22 123/19 Stephen [1] 12/13 114/25 116/12
155/18 158/9 163/25 ISPace [6] 3/11 20/10 Istands [1] 87/5 stepped [2] 98/5 stronger [1] 99/24
171/24 171/24 176/15) 25/11 36/25 41/22 stark [1] 43/12 202/1 strongly [4] 34/6
1483/3 201/5 205/9 203/20 start [13] 6/5 8/16 stepping [2] 174/4 34/16 157/21 164/7
sort [149] 10/6 14/5 spades [1] 28/3 26/1 43/5 60/14 88/20} 174/10 structural [1] 61/8
18/7 18/23 41/15 speak [9] 38/13 50/4 I 96/22 98/24 150/2 steps [10] 47/22 structure [4] 79/6
43/10 44/4 47/25 50/5 50/19 50/23 162/6 175/23 183/25 I 47/24 104/25 106/17 I 113/7 123/4 192/15
48/14 55/14 68/6 80/1 51/11 64/17 75/7 95/7I 200/3 108/19 117/23 146/21Istructures [1] 103/24
97/25 99/12 99/25 ISPeaking [4] 144/3 Istarted [7] 17/13 155/13 166/20 202/12! struggling [1] 109/4
100/13 100/15 100/18I 148/16 160/6 187/12 I 43/18 43/18 67/11 STEVENS [10] 95/19 I stuck [1] 93/7
1401/5 101/12 101/13 ISPecific [17] 7/9 111/20 139/8 141/8 I 146/5 148/4 149/14 I subject [6] 7/12 16/3
101/15 102/6 104/2_ I 29/10 36/5 36/5 54/23Istarting [2] 116/14 I 150/11 175/4 198/21 I 69/4 124/19 130/7
1406/1 106/19 106/24 I 105/19 107/1 115/8 I I 141/24 204/21 205/7 206/18 I 194/23
407/20 107/23 110/21I 115/13 116/9 127/1 starts [1] 173/3 sticking [1] 4/2 submissions [2] 76/2
4111/1 111/2 111/10 _ I 149/8 160/9 164/19 I starved [1] 197/8 stigma [2] 48/13 111/3
4114/17 113/5 1113/8 I 169/14 169/25 181/19]state [12] 52/23 203/14 submit [1] 70/12
413/16 113/17 114/15I SPecifically [16] 95/20 108/22 108/25 Istill [24] 14/12 14/13 I submitted [9] 70/6
115/6 11818 118/20 I 20/24.49/13 99/15 I 116/2 117/7 156/18 I 20/22 40/19 41/10 I 70/8 70/15 70/17
118/5 119/4 11916_I 102/11 103/23 105/2 I 187/3 157/7 157/12 I 45/18 55/18 60/15 _I 89/14 89/16 89/18
q2012 20/14 121/14 I 107/24 108/8 117/6 I 179/18 196/68 60/17 60/18 60/19 I 92/20 92/21
421/17 125/12 125/13] 121/14 123/9 139/4_ Istated [1] 184/13 I 60/22 66/8 86/10 _I subpostmaster [4]
426/15 126/19 128/13] 143/17 143/18 160/19I statement [51] 5/2 I 91/1491/15 91/17 _I 23/24 32/22 194/9
4129/4 129/13 129/16 I 187/2 5/20 9/2 39/19 42/25 I 91/20 137/16 144/8 I 194/12
429/17 129/21 130/24ISPecifics [1] 10/2 I 44/25 49/7 55/7 82/25I 173/17 173/18 173/18] subpostmasters [15]
specified [4] 129/23 I 94/3 96/2 96/4 96/6 I 190/4 26/24 47/11 47/20
(83) some... - subpostmasters
INQ00001201
INQ00001201
s 101/9 58/2 68/5 71/12 73/4 I 34/11 45/2 45/4 45/11I 94/10 94/21 125/8
subpostmasters... supporting [1] 40/7 I 73/4 75/17 76/8 82/21I 45/13 99/20 99/20 147/15 163/10 167/8
[12] 51/23 54/10 [Suppose [2] 100/12 I 82/24 84/13 84/21 99/25 100/3 100/6 176/7 177/22 178/20
55/4 65/21 66/18 198/9 85/5 86/8 86/12 89/22) 100/10 100/10 100/17I 204/2
122/16 142/19 142/25I Sure [43] 51/15 57/24) 91/18 92/1 92/12 101/4 101/10 101/25 Iterrible [3] 99/8
161/16 170/15 201/22I 61/17 62/3 62/18 64/8I 92/12 92/15 92/17 103/15 103/16 103/17I 203/21 204/7
203/10 77/12 79/7 86/16 92/21 93/19 94/2 103/18 103/19 103/20) terribly [3] 133/24
88/17 92/14 95/2 98/6I 94/18 113/21 114/10 I 103/21 103/21 104/5 I 133/25 156/14
99/21 99/23 107/8 119/16 124/4 131/20 I 104/6 104/10 104/18 Itest [3] 124/12
110/20 111/14 117/5 I 131/24 136/24 137/1 I 104/19 105/12 105/16] 125/19 167/11
163/5 184/11 184/18 I 118/5 119/10 123/16 I 138/6 143/6 146/24 I 105/22 105/23 106/6 I testing [2] 13/25
184/22 185/5 186/24 I 125/11 130/16 133/5 I 154/7 155/24 156/23 I 106/9 109/11 121/20 I 113/5
4187/1 187/4 187/7 133/6 133/11 135/13 I 157/7 157/8 162/10 I 137/12 165/12 167/16 tests [3] 137/1 137/6
187/22 192/20 135/17 136/12 137/22] 163/9 166/24 168/16 I 179/22 137/23
subsidies [2] 185/6
185/7
subsidy [12] 124/25
substantial [2] 152/21 154/13 155/1 I 170/2 171/4 179/23 Iteams [2] 42/8 text [1] 135/8
127/25 132/4 155/2 160/13 168/8 I 180/10 182/9 186/15 I 101/19 than [43] 25/2 30/25
substantially [3] 75/9] 173/12 175/8 185/18 I 194/17 198/23 203/25I technical [1] 20/12 I 49/8 53/25 60/16
75/20 156/16 194/13 202/16 203/4 Itake-home [1] 43/6 Itechnicality [1] 63/10 70/21 70/23
substantive [1] 138/7/ Surely [2] 55/10 take-up [1] 86/12 I 123/11 70/25 727 82/14 84/3
Success [1] 48/10 I 88/14 taken [24] 15/15 18/2I technology [3] 44/19I 85/25 93/7 108/7
successor [3] 195/2 [Surrounded [1] 24/19 27/24 35/20 I 98/21 189/21 112/24 116/2 117/3
198/9 197/24 115/12 47/24 48/261/19 _Itelephony [2] 186/5 I 123/3 131/15 132/7
such [15] 1/18 2/13. [Surrounding [2] 82/13 94/16 94/22 I 188/18 132/10 132/15 135/1
6/17 33/21 37/7 71/16I 107/23 12/5 99/14 104/25 105/4 Itell [10] 38/24 47/8 I 135/4 135/9 138/1
104/9 122/2 124/25 I Survey [1] 114/10 106/17 120/21 121/1 I 49/20 53/11 53/16 138/6 139/15 147/24
160/10 169/14 181/9 [Survival [1] 201/8 132/24 144/2 162/4 I 54/2 67/12 135/17 148/5 160/17 170/5
suspect [2] 105/15 176/7 177/9 183/18 156/14 180/5 171/15 177/11 178/9
suffering [1] 1209. I 202/24 200/5 telling [1] 37/4 478/23 179/10 180/22
Seg Corr [Suspend [3] 23/24 takes [5] 84/4 141/14tels [1] 44/6 199/16 19716 197/14
24/5 2416 15372 153/3 153/5_Iten [1] 89/11 201/14
79/19 114/24 118/14
suspension [3] 24/9 I taking [8] 38/3 98/11 Itended [2] 112/11 I thank [80] 3/19 3/21
one toon 16018 56124 31/13 138/18 140/4 152/12 I 115/3 3/22 4/14 5/1 5/14 6/1
sufficiently [4] 128/9 [Sustaining [1] 184/9 I 152/18 155/15 201/18Itends [1] 116/4 6/3 8/1 10/8 10/21
150/2 164)12 202/17 [Swallow [2] 153/9 talk [12] 41/3 41/17 Itense [1] 139/9 12/5 12/16 15/24
suggest [7] 50/12. I 193/10 44/24 49/19 57/20 _Itent [1] 200/16 24/12 35/12 36/6
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79/16 129/11 157/15 172/21 175/19 180/8 I 60/25 109/1 158/12 I 39/14 42/15 51/1 52/5
swift [7] 116/19 talked [10] 20/11 I term [20] 27/21 55/20) 52/7 52/12 52/13
suggested [4]
139/20 157/2 166/20 I 120/8 121/25 172/7 I 49/13 64/5 140/6 56/2 56/3 56/4 56/12 I 52/17 65/14 65/17
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suggesting [6] 65/5 swirling [1] 88/19 186/4 186/4 203/4 187/4 187/5 190/20 I 69/11 69/12 69/15
ate B03 1428/1 switch [1] 165/19 talking [26] 35/10 190/22 191/6 1191/7 I 74/12 75/5 75/18
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suggestion [1] 32/23IS¥mpathetic [1] 105/15 113/21 116/5 I 191/24 192/4 88/14 93/17 93/22
suggestions [1] 53/12 125/20 134/16 135/13I terminate [3] 113/20 I 93/24 95/4 95/10
23193 sympathetically [1] I 137/1 140/3 143/10 I 117/3 119/17 95/15 95/22 95/23
suggests [2] 134/25 47119 147/12 152/15 155/18I terminating [1] 96/18 111/24 112/6
130/17 synced [1] 180/13 I 167/24 168/11 175/12I 121/12 120/25 138/17 139/19
summarise [2] 31/4 IS¥Stem [17] 20/10 I 178/22 178/23 186/24Itermination [2] 71/14] 149/13 155/10 157/5
27/20 44/15 85/11 I 188/12 191/19 204/2 I 121/18 162/13 162/18 162/19
31/24 . ‘
summary [5] 20/6 102/14 107/5 107/7 Itangible [1] 47/17 _Itermist [1] 193/11 172/10 177/23 179/5
32/11 102/24 122/21 I 107/7 107/8 109/12 Itarget [4] 180/12 terms [51] 5/1 11/5 I 189/14 189/15 193/18)
202/4 141/7 141/15 145/15 I 180/22 180/24 180/25I 11/6 11/15 11/15 194/6 198/15 198/16
sums [1] 130/13 147/10 153/10 160/1 Itargets [1] 180/19 16/18 17/3 19/11 198/19 198/19 204/17)
superbly [1] 13/21 188/19 tax [2] 5/14 5/17 27/12 27/19 27/23 204/20 204/23 205/2
superfluous [1] systems [4] 108/13 Itaxpayer [1] 143/4 I 29/15 36/8 36/15 205/5 205/11
108/16 123/18 168/7 Itaxpayers [8] 172/15 I 36/18 37/1 37/5 37/22I Thanks [3] 121/22
oes iso (1 T 172/17 173/3 173/10 I 41/6 41/21 41/22 134/22 150/20
3/14 ——_________I 173/17 174/19 174/24] 41/24 42/6 44/9 46/17I that [1271]
table [1] 145/3 175/22 48/22 49/1151/12 —_Ithat [1] 36/25
See als 2a/6Itake [67] 10/12 17/21] team [53] 8/18 8/19 I 58/19 61/4 61/23 63/2I that's [144] 1/21 4/7
odie 47/11 8124 21/18 25/24 28/16 I 12/18 17/23 18/2 72/19 73/18 81/18 I 6/12 6/15 6/23 6/23
supported [2] 82/23 28/23 35/25 41/4 43/6] 18/10 18/20 18/23 I 82/18 83/20 84/17 __I 7/7 7/23 7/24 8/12
44/7 52/7 52/21 57/23I 19/2 19/4 32/19 33/7 I 85/11 85/13 86/3 16/12 17/4 17/23
(84) subpostmasters... - that's
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144/21 146/9 146/12 I 64/1 64/19 65/20 they [175] 2/35/10 I 66/25 67/2 67/9 67/12I 155/4 158/14 162/1
146/18 147/17 147/23I 65/17 67/5 68/8 70/3 I 5/22 8/15 8/19 8/19 I 73/20 75/10 165/4 169/7 169/10
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171/24 174/12 175/18I 196/21 107/18 108/17I 40/14 40/15 41/12 146/10 147/19 153/8 I 196/3 197/19 199/17
175/24 176/1 176/15 I 123/5 125/22 126/10 I 41/19 41/20 42/2 154/25 160/22 162/3 I 202/1 203/10
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179/21 180/10 180/20I 129/19 130/1 137/9 I 46/16 47/9 47/20 48/8) 195/18 196/20 196/21) 53/5 53/8 62/5 63/22
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202/4 202/19 204/22 I 157/22 161/2 166/19 I 55/3 55/8 55/11 57/17) 48/15 48/21 88/18 I thought [19] 76/7
their [60] 1/17 5/6 172/9 179/3 180/1 58/5 58/23 58/24 108/13 116/3 119/23 I 78/11 110/5 114/19
20/10 20/10 20/12 195/22 196/2 199/15 I 58/25 59/3 59/16 128/7 129/14 133/2 I 121/21 134/8 137/7
20/16 30/6 31/16 201/24 59/19 59/20 59/24 143/12 146/6 146/21 I 157/18 157/24 163/25
31/17 32/7 32/8 39/21Itheory [1] 198/9 59/24 60/7 60/18 149/5 152/8 154/10 I 167/15 167/16 174/1
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60/7 66/1 66/20 67/2 I 17/4 21/24 25/19 67/10 67/12 68/1 68/3} 203/22 35/11 40/14 171/6
67/23 75/12 77/9 28/25 29/3 30/9 33/21) 68/3 68/9 68/9 68/14 Ithink [267] 171/8 188/15 188/22
78/18 78/21 87/16 48/7 58/4 60/3 60/14 I 68/23 69/1 69/6 69/9 Ithinking [9] 67/22 189/9
94/9 101/13 105/22 I 91/8 64/12 65/3 68/22 70/25 71/19 72/16 101/14 127/23 132/24I through [42] 1/25 2/4
106/11 113/24 123/7 I 71/21 75/11 75/17 73/12 73/14 73/18 133/9 135/8 153/14 I 3/3 3/24 4/3 10/11
134/17 145/4 147/18 I 78/19 79/4 80/7 81/8 I 73/19 74/5 74/10 177/25 188/3 20/18 22/12 23/15
158/15 158/17 172/7 I 81/11 84/16 94/15 74/14 74/17 77/19 — Ithird [1] 21/22 27/23 34/9 44/1 44/3
172/11 175/19 178/5 I 24/16 106/3 110/8 77/22 78/17 78/20 I thirdly [1] 154/10 44/17 53/14 57/10
1484/3 184/19 184/20 I 120/14 126/25 127/1 I 78/20 78/22 82/20 _I this [329] 62/22 65/1 68/4 84/22
184/21 185/1 1895/1 I 127/15 137/21 140/2 I 82/20 82/21 83/12 I Thornton [2] 25/1 94/23 98/1 105/5
193/23 201/23 202/25I 151/7 161/18 172/9 I 83/13 88/2 88/3 88/5 I 27/25 107/10 109/8 109/14
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194/4 198/13 96/17 96/19 100/12 Ithorough [1] 46/20 I 140/13 140/17 141/6
them [48] 2/4 21/15 thereafter [1] 143/7 I 100/19 100/24 105/13Ithose [119] 2/25 3/25I 145/12 146/25 160/9
(85) that's... - through
INQ00001201
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T 111/6 185/21 Treasury [13] 101/1 I 35/17 52/8 57/13 72/25 79/18 84/9 87/1
through... [7] 164/8 toilet [1] 48/18 145/6 153/16 153/20 I 57/25 62/1 65/20 125/23 148/3 160/1
169/19 172/25 176/1 Itold [9] 38/15 55/17 I 154/9 154/22 164/6 I 68/21 72/24 84/22 167/18 172/2 179/6
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throughout [5] 45/14 119/8 170/12 174/7 I 184/15 185/4 198/10 I 93/10 95/24 101/19 I underestimated [2]
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tightened [1] 19719. I 13224 132125 172/13 176/3 181/11 188/23 I 86/11
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170/25 174/5 172/20 (too [15] 28/16 42/13 Itrial [3] 43/8 132/7 Itwo years [1] 86/11 underlying [1] 202/2
time [113] 7/19 12/2 I 49/1 53/19 53/21 132/14 tying [1] 137/20 undermine [1]
13/4 13/22 14/6 14/10I 83/14 66/16 73/1 __Itricky [2] 66/17 type [5] 146/24 160/5) 126/20
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jaa tziiizna I 133/1 148/24 154/20 Itried [2] 111/12 typical [2] 157/17 I 19/12
17/20 18/1 18/7 19/2 I 197/1 156/21 202/11 underpin [1] 124/11
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141/10 143/6 144/15 ra a i
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timeline [2] era _ {tragic [1] 62/19 95/25 96/1 96/5 96/10] 56/11 162/25 unfairly [4] 181/2
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times [5] 20/1 31/22 113/24 149/22 160/23 170/6 Iunaware [1] 194/18 I unique [2] 105/16
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timescale [1] 50/15 144/6 turnaround [1] uncertain [2] 131/22 I unit [28] 13/10 13/24
timing [1] 150/15 Itanche-driven [1] I 182/12 137/16 14/1 14/17 15/1 15/16
title [1] 97/11 143/15 turned [2] 160/11 uncertainty [5] 79/12I 19/17 20/4 20/6 26/16
to’ [1] 134/24 transcript [1] 195/4 I 160/12 79/15 79/16 80/9 27/3 27/10 29/9 29/12
today [9] 29/18 40/12 transferred [1] turning [1] 182/7 80/16 30/4 30/18 30/23
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together [3] 49/9 _Itaumatised [1] 49/1 I 30/2 30/19 31/6 31/6 /undated [1] 171/20 IUnit's [1] 13/12
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(86) through... - United
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unless [1] 92/10 133/20 149/2 155/18 I 35/7 36/24 38/17 39/3I volumes [2] 20/17 I 20/14 31/12 33/19
unpredictable [1] 162/17 171/16 174/1 I 39/11 41/1 41/6 41/15I 21/3 41/15 44/21 46/19
154/3 174/7 198/1 200/7 I 42/16 42/20 45/18 _I voluntary [1] 24/17 I 46/20 57/10 74/9 80/3
unrealistically [2] [USage [1] 61/6 46/7 51/2 52/23 53/2 Ivulnerable [2] 73/12 I 83/10 87/20 94/12
4197/7 197/11 use [18] 43/22 65/4 I 53/2 53/18 59/4 68/11I 73/18 94/25 106/24 114/21
unredacted [1] 88/5 I 99/19 72/1 77/25 80/5] 73/12 78/10 79/7 II 126/11 126/12 127/15}
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160/18 176/23 200/17/4Ses [2] 178/11 113/25 114/17 118/20Iwander [1] 95/7 we [392]
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144/10 146/24 149/8 I 130/11 136/13 137/3 I 204/4 204/23 2056/2 I 4/17 48/16 48/18 21/18 29/20 41/13
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469/14 169/22 170/10I 1829/3 183/1 191/21 wanting [2] 25/5 190/14 194/25
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up' [1] ere 55/12 I 169/1 169/22 182/3 I 138/4 138/5 139/25 I 99/16 109/4 111/5 I 86/3 86/5 122/11
update (4) 97 203/1 441/20 148/17 154/4 I 111/9 117/25 120/8 I 1641/2 161/3
Vennells [2] 12/19 I 155/6 162/2 167/24 I 120/13 121/18 123/24I weeks [2] 8/14 66/19
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sett} a7i2s verbally [1] 9/5 184/10 191/1 192/10 I 143/21 144/11 146/2 Iwell [73] 7/12 7/20
upgrade [1] version [2] 89/4 4197/1 153/8 157/2 157/19 I 9/6 9/14 10/16 12/23
uploaded [1] bare 150/23 viewed [2] 140/23 I 160/9 165/5 167/15 I 18/16 20/9 20/17
upon ] versus [1] 101/24 I 143/3 174/9 174/11 176/15 I 20/19 21/2 22/2 30/6
try te0723 (Very. [154] 3/24 11/1 I views [8] 29/15 33/1 I 180/12 181/15 183/17I 31/7 31/9 36/16 38/14
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