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The Post Office Horizon IT Inquiry 6 November 2024
Wednesday, 6 November 2024
(9.30 am)
SIR WYN WILLIAMS: Before we start with evidence, Mr Beer,
Ihave another sad announcement to make.
' have to inform all those who are following the
Inquiry that one of our Core Participants, Mrs Carol
Riddell, died on 25 October. Mrs Riddell became the
subpostmistress in her home village of East Boldon in
the northeast of England in 1991, and continued in post
until 2000. She was therefore in post when Horizon was
rolled out and she found dealing with Horizon
particularly difficult.
‘As a consequence of that and her own ill health, her
husband, Alan, took over as the subpostmaster in 2000
and continued in that post until 2013.
During her time as subpostmistress, Mrs Riddell had
to contend with a very serious armed robbery at her Post
Office during the course of which she was blinded by
having acid thrown in her face.
In latter years, and perhaps for many years, both
Mrs Riddell, and then her husband, Alan, were assisted
by Ms Jean Smith, who was a very close family friend,
and assisted considerably in the running of the post
office until, in 2013, her involvement ceased. All
three of those persons -- well, Mrs Riddell was a Core
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this regard, although the Post Office is not aware of
anything formal under consideration.”
By its letter, the Post Office apologises for what
it describes as the confusion in this regard.
The second announcement, sir, is that at 10.00 I'm
afraid we have the fire alarm. It will be in the course
of Mr Hollinrake’s evidence, and so I propose that we
sit here -- or, in my case, stand here rather
awkwardly ~ for five minutes whilst that is got out of
the way.
SIR WYN WILLIAMS: Well, perhaps I might invite you to sit
down, Mr Beer!
MR BEER: That would be very kind. Thank you, sir.
SIR WYN WILLIAMS: Right
MR BEER: With those two points, may I call Mr Kevin
Hollinrake, please.
KEVIN HOLLINRAKE MP (sworn)
Questioned by MR BEER
MR BEER: Good moming, Mr Hollinrake. My name is Jason
A
Beer. Can you give us your full name, please?
Kevin Hollinrake, Member of Parliament for Thirsk and
Malton.
Thank you. You have made kindly a witness statement for
us which should be in hard copy in front of you. It's
dated 7 October 2024. The URN is WITN11460100. It's
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Participant, and Mr Riddell and Ms Smith remain Core
Participants at the Inquiry.
Mr and Mrs Riddell were claimants in the Group
Litigation. I'm sorry to have to report that neither
have received full compensation under the relevant
scheme as of today.
On behalf of all members of the Inquiry Team, and on
my own behalf, I extend deepest sympathy to all
Mrs Riddell's family and friends.
Over to you, Mr Beer,
MR BEER: Thank you, sir. Before I start with the evidence
prop
of Mr Hollinrake MP, just two short matters.
Firstly, some clarification of the evidence of Simon
Recaldin that he gave on Monday. On Monday, 4 November,
Mr Recaldin gave evidence about the current position of
assistants and managers of postmasters who are unable to
claim under a redress scheme for shortfall payments
made. Mr Recaldin said in evidence ~- the transcript
reference for Monday is page 50, line 16 -- that the
position was under consideration by the Minister.
The Inquiry was informed by letter from the Post
Office's solicitors yesterday that this evidence was, in
the words of the letter, “not quite correct”. Instead,
and I again quote from the letter:
“There have been discussions with DBT officials in
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17 pages in length and I think there is one correction
to make, if we turn to page 12, please. It's at tab A2,
I think, for you
Page 12, paragraph 44.
Yes, got that.
‘About four or five lines in
Yeah.
~ it says in brackets at the end:
"... as I think there were 200 people earning over
£100,000 a year...”
Do you wish to correct that figure to 143 people?
Yes, that was from memory. It's 143, having seen the
actual documents that I was given at the time.
Thank you very much. So cross out "200" and add "143."
If you go to the last page, page 17; is that your
signature?
Yes, itis.
With that correction brought into account, are the
contents of the statement true to the best of your
knowledge and belief?
Absolutely. Yes, they are.
Thank you very much. Can we start, please, with your
background, Mr Hollinrake. I think, after a career in
business, you were elected as the Member of Parliament
for Thirsk and Malton on 7 May 2015?
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That's correct.
You served as a Conservative backbencher for seven and
a bit years until, on 27 October 2022, you were
appointed by the then Prime Minister, Rishi Sunak as
Parliamentary Under-Secretary of State in the Department
for Business and Trade?
That's right.
Then you were promoted to the position of Minister of
State on 26 March this year, 2024, being Minister of
State for Enterprise, Markets and Small Business; is
that right?
That's correct.
A position you held until 5 July 2024, when a Labour
Government was formed on that day as a result of that
general election?
That's correct.
Is it right that in both positions, both as
Parliamentary Under-Secretary of State and then as
Minister, the Post Office Limited was amongst your wide
portfolio of responsibilities?
It certainly is, yes.
So, in short, you held ministerial responsibility for
Post Office in Government for one year and eight months
between October 2022 and early July 2024?
Yes, I did.
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"My appointment was manna from Heaven to me because
it meant I could actually help to fix something
important. There wasn't a day, night or weekend that
went by when I wasn't doing something on the Post Office
redress schemes and transformation. I would say at
least 25% of my overall time and during many periods
a much higher percentage [of time] was focused on this.”
You speak there about the Post Office being an issue
about which you cared personally from your time as
a backbencher. Can you help us: can you explain why
that was?
Well, my life has been small business. So one of the
nice things about being a Member of Parliament is when
you -- from the backbenches you can speak on virtually
whatever you'd like to speak on, and so I tend to focus
on small business, and one of the first things I tried
to help resolve with some of the banking scandals where
big banks had mistreated small businesses, particularly
Lloyds, HBoS and RBS GRG. So! spent many years on the
All-Party on Fair Business Banking on those particular
issues.
Just slow down a little bit. You mention, I think, the
APPG?
That's right.
Tell us very shortly about that APPG?
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Q. Thank you. In opposition, I think you held ~ so after
July 2024 until today -- in fact until yesterday -- you
held the position of Secretary of State for Business and
Trade?
That's right.
Bult I think the new party leader, Ms Badenoch, appointed
you yesterday to the role of Shadow Secretary of State
for Levelling Up, Housing and Communities?
That's true.
Can we please look at your witness statement, it's
page 3, paragraph 6.
Yes.
Paragraphs 6, 7 and 8. It will come up on the screen as,
well. In the preceding paragraphs you've set out the
extent of your ministerial responsibilities, but you say
in paragraph 6:
"During my entire time ... from 27 October 2022
until the General Election in July 2024, the Post Office
fell under my ministerial remit, and as part of this
I was responsible for leading the Government's action on
redress for subpostmasters and Post Office reform.
"This was my number one priority as Minister, no
question about it. It was of key importance to the
Department and it was also an issue which I cared about
personally from my time as a backbencher,
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Yes, so the APPG was an All-Party Parliamentary Group on
Fair Business Banking, which was there to try and make
sure that small businesses had a voice when they were
mistreated by large organisations, and there was some
terrible mistreatment of small businesses by those
particular banks.
So when I came across this particular scandal, which
I did as a result of a letter from Paul Marshall, who is
one of the barristers who got involved in this case and
sought to have injustices brought to light, and did so
successfully, I met with him, and realised how serious
this was, but also, the parallels that existed between
this scandal and previous scandals, where we'd sought to
get compensation for those people.
And so it then became something I talked about from
the backbenches and continued to do so until I was
appointed Minister, and that's why I said it was
something that I was very pleased to ~ that was part of
my portfolio because, as a backbencher, you have
influence but you don't have any power but, even as
a junior minister, you have some power to try and make
things happen and that's what I tried to do as the
Minister.
Thank you. Can we look at an example of what you did
from the backbenches. Can we look, please, at
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UKGI00030648. It will come up on the screen. If we
look at the foot of the page, we will see an email from
you to Darren Jones and others on 5 July 2020. This
would have been at the time that you were a backbencher?
That's correct, yes.
If we look at the bottom of page 2, on to page 3, we can
see it's signed off by you as MP for Thirsk and Malton
and the Co-Chair of the APPG that you have just
mentioned?
Yes, that's right.
We see that this was primarily addressed to Darren
Jones, if we go back up to the distribution list. Can
you help us: at this time, in what capacity or context
were you writing to Darren Jones, July 2020?
Well, it was trying to highlight some deficiencies with
the compensation scheme, primarily —
Sorry, it's my fault for a poor question. In what
capacity were you writing to him?
Sorry. Yes, Darren Jones is the Chair of the Select
Committee for Business and Trade — Business, Energy and
Industrial Strategy Select Committee, as was then.
Thank you. So he was chair of the committee with
primary responsibility for essentially the business area
of the Post Office and its scandal?
Exactly right, and he was doing some work — the
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clear parallels between this affair and similarly
disgraceful abuse of power in the Post Office scandal.”
Just to note, we've got those documents that have
kindly been provided with Mr Marshall contacting you on
two occasions, and drawing parallels between the
Lloyds/HBoS scandals and this one:
“That some one should be prosecuted by a state
institution and imprisoned on the basis of false
evidence, known to be false, is antithetical to
everything that liberal democracy and the ‘rule of law’
stand for."
I should say that the purpose of me asking you
questions about this is to gauge the temperature of your
feelings whilst a backbench MP and see whether you
carried those forwards when you became a Minister.
Sure.
“Such things are rightly associated with authoritarian
and despotic regimes. And yet, for 20 years, the Post
Office conducted such prosecutions.”
Over the page you then give some examples:
“Tracy Felstead was imprisoned aged 19 in 2002.
Mrs Seema Misra was imprisoned when 8 weeks’ pregnant in
2010. Their cases have been referred to the Court of
Appeal by the [CCRC], together with 47 others, following
Sir Peter Fraser's judgments in the Bates v Post Office
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committee was doing work on the scandal, and it would
be -- as I said before, as a backbencher you don't have
the power which you need to draw together a coalition of
people to try and raise the issue ~ raise issues
through the various different channels, and this is one
of the channels we were trying to use to raise issues we
felt existed with the compensation schemes.
Thank you. You say:
*... thank you for the fine work that you and the
Select Committee are doing with regard to the Post
Office scandal.
"You may be aware of the above issue already ..."
By that, I think you mean the subject line "Another
Post Office scandal? Convicted claimants paid no
compensation by Post Office", is that right?
That's right.
*... but I have been contacted by Paul Marshall,
a barrister who has been informally assisting some of
the Post Office victims, about a further injustice
relating to this scandal in that convicted claimants
have been paid no compensation by the Post Office and
are specifically excluded from the Historic Shortfall
Scheme. Paul originally contacted me as a result of my
work (of the] Chair of the APPG on Fair Business Banking
‘on the Lloyds/HBoS Reading scandal where he highlighted
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litigation. Post Office Fujitsu witnesses have been
referred to the [DPP]. The CCRC has described these
prosecutions as ‘an affront to the public conscience’
“It has now emerged that, while many assumed that
the Post Office paid about £58 million (the vast
majority of which went to pay costs and expenses) in
‘compensation to its subpostmasters and
subpostmistresses, including to those who had been
convicted and imprisoned as a result of its seriously
flawed prosecutions, this assumption is incorrect.
Astonishingly, it is now apparent that under the terms
of the settlement, negotiated between Freeths LLP, for
the 550 claimants, and Herbert Smith Freehills LLP, for
the Post Office, it was agreed that the Post Office was
to pay no compensation at all to claimants in the Bates
v Post Office litigation who had been convicted of
criminal offences. The explanation for this remarkable
conclusion is provided by a note written by Paul, a copy
of which is attached to this email.”
You indeed attached a copy of that note to the
email
"Putting to one side any legal justification for
that extraordinary outcome (none being immediately
obvious), it is one that will offend anyone with a sense
of justice. Many of those convicted and imprisoned,
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perhaps understandably, have suffered serious ill health
including mental illness, as a consequence.
“lam also very concemed about the involvement of
Herbert Smith Freehills ..."
1am not going to read that paragraph but,
essentially, you say that you fear that they have
adopted an overtly and overly adversarial approach
You say:
“Lurge the Select Committee to lead the calls for
a proper compensation scheme that will enable all the
victims of this terrible tragedy and injustice to
receive reparation for the injury done to them by the
Post Office that is, shor of niceties, a state
institution. The continuing absence of such a scheme
will augment injustice with injustice and be
inexcusable. It is an outrage that some victims should
now be left to their own devices to pursue an uncertain
claim against the Post Office for malicious prosecution.
Further, the circumstances of settlement, and the denial
of recompense to those most grievously injured by the
Post Office, now adds to the requirement for a proper
public inquiry into this shameful episode.
“At the very least, the time period for the [HSS]
should be extended by 3 months to 14 October 2020. This
will provide a reasonable opportunity for those affected
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the detriment to people's lives is often completely
unique. Of course it's completely unique. So, if
you're going to set about putting in place
a compensation scheme that's going to assess everybody's
loss individually, that's going to take time. And it's
bureaucratic process. You need to ~
Sorry to interrupt you. So, essentially, the first part
of your answer there was it's the nature of the
exercise, so it's not somebody hindering me, or
an institution —
Yes.
-- hindering progress: you're saying it's a natural
consequence --
Yes.
- of the problem that needs to be solved?
Yes. I never experienced anybody -- if the question
is -- I never experienced anybody in Government or the
Civil Service who tried to hinder compensation to any
individual. It's a result of a complex process, that
inevitably is the case between an individual whose life
has been affected in many, many different ways, both in
terms of financially, in terms of their health, their
mental health, their physical health, that of their
family, that -- in terms of the impact upon their
livelihood, all those things have to be taken into
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to be able to properly evaluate the courses open to
them. The issues demand careful and mature
consideration.”
Then you say you copied in the Business Secretary,
Alok Sharma, the Small Business Minister, Paul Scully
and the Justice Secretary, Robert Buckland:
*... who clearly have an interest and I hope will
also take up these matters.”
You expressed, I think it is fair to say, very
strong opinions on this scandal in the course of this
email, didn't you?
Idid.
Did you carry those very strong opinions into Government
when you became a Minister two years later?
Yes, I did.
Itis apparent from the evidence that we've got that you
tried to resolve what might be described as issues with
compensation and redress?
Yes, I certainly tried to do that.
What hindered you?
I think the nature of any compensation scheme, and I saw
it in the previous compensation schemes we had dealt
with, at Lloyds, HBoS and RBS, is that any compensation
of any individual is complicated because everybody's
life is different, everybody's lives are complex, and
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account.
And I think one of the things we need to leam from
this, and I've covered this in my statement in later
stages, is how we do this better if this - God forbid
this should ever happen again.
And so I think, Sir Wyn, you have said in your
earlier remarks on this is that, in terms of the
compensation schemes, you know, if you're going to go
there you wouldn't start from here, in terms of how
we've done this, but nevertheless we are where we are —
we find ourselves, and so it is ~ as I say, it's the
complexity is the biggest problem, and the adversarial
nature of putting a claimant's lawyer arguing the case
with the Department or the Post Office's lawyers. And
that doesn't help either.
And so there are ways, I believe, to expedite that,
some of which we found through things like fixed-sum
awards, which have had a great deal of success, but
there are other things we need to do as well to try to
expedite this process now and for future compensation
schemes.
In the course of that answer you said you didn’t come
across anyone in Government, and you included with that
the Civil Service, who hindered you. Did you
deliberately exclude the Post Office?
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No, I didn't. I mean, I don't believe anybody in the
Post Office sought to prevent compensation flowing and,
again, that’s something I covered in my witness
statement. I think there were some failures within Post
Office. You know, some of the disclosure failures,
which have been well publicised, for the Inquiry, but
also in the individual cases, took too long, and were
flawed, and mistakes were made.
So there are logistical problems, and some that has
to be described as incompetence as well as fairly for
other reasons. But I don't think ~ I haven't met
anybody who didn't want to compensate postmasters as
quickly as possible.
Thank you. Can we look, please, at BEIS0001023. This
is an email exchange from, in fact, earlier this year.
You'll see that it's dated 5 February 2024 and it's from
Minister Hollinrake, that email address, to Rob
Brightwell, who is a senior servant within the
Department, along with Carl Creswell ~ who we are to
hear from later today -- and others.
If you look at the foot of the page, please, and
over to the next page, you'll see it's from Jamie Lucas,
who was then your Deputy Head of Office and Private
Secretary; is that right?
That's right.
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that last bullet point.
That's right.
So the passages in italics there, that's essentially you
speaking directly?
Yes
So, what: you would have read a submission, not liked
some of what you had seen in it, and passed this on to
your private secretary?
That's right.
Did you do this frequently, this kind of thing, get
actually into the details of individual claims?
Yeah, where necessary. I mean, obviously ministers are
not there to resolve individual claims but I was
concemed -- as concerned, I think, as anybody when you
felt things were not working as quickly as they should,
and so ~ and, you know, the bureaucratic nature of
things, as I say, I expressed some frustration within
those paragraphs about, you know, just really arguing
about very small elements of a claim, which, you know,
speaking frankly ~ and listen, this isn't a criticism
of lawyers, so I hope you don't think itis. There's,
a lot of lawyers in this room right now, I wouldn't want
to do that! But it can be the case that things take too
long and for the wrong reasons.
So arguing about the mileage claim for somebody
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If we go back to page 1, please, it refers to
"slightly impromptu meeting with the Minister’, ie
you, “just now”, and it's apparent that a submission has
gone up to you, and you've provided comments and he's
passing these on to the civil servants, yes?
That's right.
You comment essentially in five bullet points. You say:
"I'd like to see how we calculated Alan Bates’
‘compensation please? Even a ready reckoner of £50,000
a year for 18 years plus interest seems to be
considerably in excess of the offer we made. Not sure
we aren't making all this too complicatedigetting into
the weeds too much at times.
"The £450,000 interim on receipt of a full claim is
a good idea, we should the same for the GLO, say
£50,000?
"Why does it take 30 weeks to respond to a late HSS
claim?
“I think we need an appeal mechanism in addition to
the HSS FSA. I think we should consult the HCAB
[Advisory Board] before implementing either.
"Please can I have a table showing a comparison of
tariffs for non-pecuniary [Overturned Convictions] v HSS
[schemes].”
I think that's essentially what you're describing in
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going ~ which I heard is one claim because somebody had
had to put their mileage going from their place of home
to a place of work while they were trying to ~ while
they were waiting for their compensation, is not the
kind of thing we should be doing.
I just felt there wasn't a sense check about -- you
know, when I dug down in some of the claims, as I would
do. You know, I didn't-- I think at times we have to
get into the weeds as ministers, myself, we can't just
rely on everything we are told. And so it would be the
case that people would contact me through various
different sources, could be email or social media, and
I would be willing to go in and say, "Okay, tell me
about that case and tell me why it's taking so long and
tell me why that offer is at that level when it doesn’t
sound like anywhere near the level it should be"
And I think I expressed that frustration in Sir Alan
Bates’ case, in that, you know, it's the level of offer
that I established that had been made didn't seem to
make sense when you took a common sense view of it
Your Private Secretary continues, skipping over the next
lines:
“He [that's you] has also expressed to me that he'd
like the detail behind a number of high-profile claims.
For example, Jo Hamilton claims that her original offer
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went from 20% of her original claim to 80%, why is that?
Christopher Head's was on 15% of what he claimed, why?
And obviously, as referenced above, Alan Bates’ claim
There's a note already being drafted on this, your
private secretary understood.
So one can understand why you would wish to know the
detail of what you described here as high profile cases,
because you might be asked about them. Was that the
reason that you were getting into the weeds here?
Not -- of course, that's, you know ~- we're public
servants, we react to public concem quite rightly, but
it was more about how the schemes were operating: were
they operating effectively; were they operating on
a basis of common sense; were they operating on a basis
that the benefit of the doubt was given to the claimant?
All the things we had committed to do, and I would
expect a compensation scheme to operate on that basis.
So it was really trying to not resolve that particular
claim to get it out to the newspapers, it was a case of,
you know, let's improve these schemes across the board,
and so these were just examples of things I was aware
of.
I took the same view on things that didn't —
weren't necessarily as high profile as Sir Alan Bates or
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people when they are mistreated, terribly, especially
the big companies and the individual. And, yet, when it
comes to the compensation, the people who are
responsible for the compensation, I felt treat those
people, hide behind the law, in terms of properly
compensating those individuals.
And I think there's something fundamentally wrong
with that, and it's not ~ this isn't the only time we
did it. You know, in fact, in the Lloyds scheme we
handed the compensation back to Lloyds to provide the
compensation but, in fact, in the HSS scheme we handed
the compensation scheme back to the Post Office to
deliver the compensation.
I think (a) that doesn't give anybody confidence
that the compensation will be delivered properly but,
also then, it becomes very legalistic, and I think
there's something very fundamental we need to learn from
that. Some of that was covered under the National Audit
Office report on this, but we should never do it like
this again
Can I ask you two questions arising from that answer.
You said that, when providing compensation for those
that have been wronged, we tend to “hide behind the
law’. That tends to suggest that you have taken the
view that those that are providing compensation or
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Jo Hamilton; it was on people that I say contacted me
directly, I would try and get the same answers in those
cases.
So is this kind of thing that we read here typical of
you essentially carrying forward the rather strong
sentiments that we saw expressed in your backbencher MP
from when you went into office as a minister?
Yes, that's exactly right.
Thank you. That can come down.
(Pause for fire alarm test)
Mr Hollinrake, I think we can continue now. We're
about to turn to a new topic, which is Post Office
governance, and the provision of information to you from
or by the Post Office, and decision making. If we can
start by looking at your witness statement, please. It
will come up on the screen, page 6, paragraphs 19 and
20.
Before I do that, can I just add to what I was going to
say earlier —
Absolutely.
~ that was probably cut off by the fire alarm.
I suppose what I felt through this, having been through
what I saw in the Lloyds compensation scheme, that the
legal system, for whatever reason ~ and, you know, I'm
not sufficiently qualified to opine on it, but it treats
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determining compensation are not applying the law, as
they would see it, that —
Idon't think that. I don't think that - they're not
applying ~ I think they're applying the law too
strictly, in that this is how we compensate people
according to the principles of how a court would deal
with this, and this is how we arrive at the calculation
that we would do a very complex assessment of loss. But
I think, to me, that is too much. We need to -- too
much, too legalistic, too adversarial and it doesn't
give the benefit of the doubt to the claimant, and it
becomes very, very bureaucratic.
And there are some basic principles how you
compensate people through the courts, I understand that.
But I think applying purely legal principles to this,
I'm sure there are very good reasons why that happens,
but does mean that these compensation schemes to me can
be flawed.
Can I explore that part of the answer a little further.
Is your view or your complaint that the law is used,
ie common law and statute law, in determining the amount
of compensation, or is it that lawyers are involved in
the administration of the scheme?
Yeah, I think it's a bit of both but, you know, if two
lawyers are arguing that can take some time. And,
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again, I'm outnumbered in this room, so I'm not trying
to be critical of legal processes but, to me, there
should be, as the National Audit Office said and why ~
one of the things we tried to do, and probably failed to
do ~- I've made mistakes here, I'm not saying, you know,
Iwas the only person who did anything positive in this
space, not at all. Many good things were done by many
people, both by the ministerial and through the civil
service, through this process.
But I think, you know, you need somebody independent
of the legal processes sat in the middle somewhere to be
able to sense check some of these things that are
happening, rather than applying the strict rules of
engagement, rules of compensation, in these situations,
because that will just take too long and not properly
reflect the situation that people have faced or the
losses that they have incurred.
The second follow-up was that you said, in your first
answer after the fire alarm, that "We handed back" or
“handed to Lloyds and then the Post Office,
responsibility for administering the scheme or, in our
case, some of the scheme". Can you develop, please,
your complaint or view there?
Well, I mean, the culture of the Post Office has been
discussed at length, so people are bound to feel there
25
contest the compensation they had been provided with,
and that some -- and, latterly, we also pushed for
a fixed-sum award for those people, so compensation
could be topped up to at least a minimum level.
So yes, it's very much the case that we ~- that
I felt that shouldn't have been given to the Post Office
originally but it was. And later schemes, the GLO
scheme, was given -- as in agreement with the claimants’
lawyers, was done by DBT, operated by DBT, which I think
was -- was better, I'm not saying even then you
shouldn't do something slightly different from that in
the future.
But one thing that I was surprised about, early on
in my tenure as minister, I think this decision might
have already been made, but the Overturned Conviction
‘Scheme was then given back to the Post Office to handle,
which again, to me, was a step backwards from
understanding the GLO scheme should be handled by the
DBT, so independent of the Post Office, then, you know,
the first Overturned Conviction Scheme was handled back
by the Post Office, and that, to me, is the wrong thing
to do.
Was it ever passed on to you that Mr Read as CEO and his
Board, corporately, did not wish for the Post Office to.
administer either the HSS or the GLO scheme?
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is some of that remaining within -- in terms of the
claimants, and I think that probably some of that was
remaining. You know, I think -- but there's going to be
little confidence from the claimant when they feel
they're being compensated by the organisation that has
been responsible for the huge suffering that they've
experienced, that they're going to get properly
‘compensated and that suffering has been is properly
recognised, so I just don't think that is the right way
to doit.
Was it an active question within your 18 months as
a Minister under consideration of whether the Post
Office should be given or should retain
responsibility —
Yes.
~ for administration of certain of the schemes?
Yes, certainly. And, again, I know you've stated this
in the past, you know, we are where we find ourselves.
So revisiting the HSS scheme, which had largely, by that
point in time, made offers to the vast majority of
people who had put claims in, you know, starting that
all again, although we did, as you referred to in my
earlier — some of my earlier comments on this is that
we should have put in place an appeal mechanism, so
people who feel they have been shortchanged could
26
I think the Post Office, including Nick Read, would have
been very happy if they weren't dealing with the
compensation. That was certainly the conversations
I had with Nick in the past.
So why was it, if there was a meeting of minds between
you and him, that that didn't happen?
Because the decision had already been taken. The HSS.
had already been largely ~ like you say, most claims
had been either resolved or offers had been made. The
GLO would decide to do externally, which I think
‘everybody was happy with, and the Overturned Convictions
Scheme, the original one, although it came across my
desk, I remember making some comments on brief that I'd
had of "I don't understand why this is going back to the
Post Office" but I think the decision had already been
taken by the Secretary of State at that point to do it
that way.
The Secretary of State at that time being?
I think the original decision had probably been made by
Kwasi Kwarteng. I can't be sure of that but, certainly,
it was something -- a comment I made to ~ on the brief
received that I didn't understand why we — this was
going back to the Post Office.
Thank you. Can we then turn to the topic I was going
to~
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SIR WYN WILLIAMS: Before we do, Mr Beer, I understand your
concem about each side arming themselves with lawyers
and arguing it out. I don't think I am a lawyer any
more. I can say that: I used to be one but I'm not
more. Anyway, it was both the Post Office’s choice and
the Department's choice to arm themselves with lawyers.
They didn't have to have a room full of lawyers to argue
this out. That was, if I can use the word, your choice.
A. Yes.
SIR WYN WILLIAMS: "You" collectively, you understand?
A. Yes, that's right.
SIR WYN WILLIAMS: So why?
A. Well, as I say, I don't think we should do that in the
future. You know, I think we should have some
independence in the middle of it, and something that
we -- I certainly —
SIR WYN WILLIAMS: Well, I appreciate about the future
but — and I'm absolutely not saying this in a critical
sense, it's an enquiring sense — you obviously had
considerable scepticism about how quickly lawyers could
sort this out.
A Mm.
SIR WYN WILLIAMS: So you become the relevant minister in
2022, admittedly the HSS is well down the road, but the
Overturned Conviction Scheme wasn't well down the road
29
through that process. It's something I got wrong. I'm
sorry that's the case.
SIR WYN WILLIAMS: Well, I wasn't, actually, as I hope
I made clear, necessarily saying you were wrong but
I was exploring the reasons why, in the end, this
scheme, all schemes, have become -- these are my words
and they may not turn out to be my final words — but
apparently a battle between lawyers, in certain cases.
A. Thats definitely the case and something we should not
do ~ not let happen again.
SIR WYN WILLIAMS: All right.
MR BEER: Can we then tum to the topic, topic 2. It was
paragraphs 19 and 20 of this witness statement and this
is after you become the Minister. You say:
“I continued to be briefed on issues throughout my
time as a Minister. I had regular meetings with the
lead departmental officials — David Bickerton (Director
General), Carl Creswell (Director) and Rob Brightwell
(Deputy Director) -- and in those meetings I would often
make requests for more information on particular topics
and raise and discuss ideas for change.”
Then in 20, you say:
“It was also important to me that I should receive
unfiltered information from stakeholders, and right from
the start I asked my private office to arrange calls
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and the GLO scheme had hardly begun. All right? So why
not then say, "Right, we'll have a completely different
attitude in the Post Office and the Department. We
won't arm our defence with lawyers, we'll have
reasonable whoever, who will just look at these claims
and make fair assessments"?
Yes, and if I had my time again, that's exactly what
I would've done -- one of the mistakes I made. It was
very early on in my time as Minister that the GLO scheme
‘came down the track. It was only after two or three
months after, I think, and met with various different
people, including people like Kevan Jones, Lord
Arbuthnot and others, who were -- all seemed to be quite
happy with the way the scheme was established.
Looking back now, I don't think I should have been
happy with that. There were scheme reviewers, Sir Ross
Cranston was brought in as a scheme reviewer for the
GLO. I think what I should have insisted on at that
point in time was for someone like Sir Ross to play
a greater role right at the start, rather than be the
back stop for a dispute. And I probably hoped, which is
probably a vain hope, that that process could happen
more quickly. And — but it's too far down the line.
So I hold my hands up, you know, and I say sorry to
people whose claims have not been settled quickly enough
30
with Nick Read, Alan Bates and Lord Arbuthnot.”
So you're there describing getting information
through the usual channels, ie through departmental
officials, but also going directly to both the Post
Office and to relevant stakeholders, yes?
Yes, that's right.
In your witness statement, it's paragraph 55, which is
on page 14. Just by way of background, in 54 you say:
"... the Government and the Post Office have
approached compensation with the best of intentions, but
there have obviously been a number of problems,
especially in relation to the pace at which
subpostmasters have received compensation (or not)."
Then you set out some reasons, and you say:
"There were, as I understand it, a number of reasons
for this during my time as Minister ..."
Then the first of those is:
"Slow and flawed disclosure by the Post Office ..."
Can you help us: what information were you provided
with as to the Post Office providing "slow and flawed
disclosure" in connection with the compensation schemes?
It wasn't information I was given by officials; it was
just usually case — when I'd spoken to victims or the
representative of victims, or evidence we'd hear at the
Select Committee inquiry, or things I would read in the
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various media reports so that would tend to be where
I revealed that it was taking longer than it should
So this is disclosure by the Post Office in and for the
purpose of a compensation and redress scheme?
Yes, absolutely. I'd speak to obviously the claimants’
lawyers and they would say to me that's certainly part
of the problem. I think that was a problem particularly
early on when the Post Office, to be fair, was getting
up to speed with a lot of these cases. As we introduced
things like the fixed-sum awards, which are one of the
things that have made a big difference in terms of
making sure the flow of compensation increased, and
there has been, I think, around a fourfold increase in
the amount of compensation paid over the last 12 months.
I think now it stands at £438 million, it was just over
100 million this time last year.
So many things have worked that we tried to do
but — so that ~ one of the — where the areas that
helped in was the Post Office, by using that ~ by using
that approach, it meant the Post Office had fewer cases
to have to disclose evidence to because the fixed-sum
awards don't require disclosure of evidence. So there
is a twofold benefit in using that approach as one way
to get compensation to people.
Other than the introduction of fixed-sum awards, did you
33
in trying to make sure those schemes were fit for
purpose. And, indeed, the establishment of the Horizon
Compensation Advisory Board, with Lord Arbuthnot and
Kevan Jones, and I was very keen to make sure there was
cross-party representation on that. But also there were
people who had been fierce critics of the Government on
that Board including Sir Professor Richard Moorhead —
sorry, Professor Richard Moorhead -- to make sure that,
they could have some oversight of how those schemes were
operating and establish where things were going wrong,
and be able to advise us on what we needed to do to try
and help.
You also cite, as a second reason -- this is something
you have mentioned earlier this morning -- the fact that
large claims were being held up by demands for detailing
information on trivial issues, such as mileage and
travel. Who was providing you with that information?
It would tend to be the claimants. I think this was
something that Jo Hamilton, for example, has often
mentioned to me when I met her. There was information
required that seemed pretty trivial and not material to
what compensation might be offered that would seem to
be -- seemed to be ~ have to perform part of the claim
before it was submitted.
In relation to that, did you communicate any concerns
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do anything in response to the information that you were
given that the Post Office was providing slow and flawed
disclosure?
Well, certainly, it was a topic of conversation we had
when I had regular meetings with Nick Read and others,
that we urged them to increase the pace of compensation,
we were always reassured that was going to be the case.
Again, on an individual case level, if things were
brought to me, I would attempt to have those cases —
understand why those cases were taking so long and urge
the relevant participants to accelerate the -- whatever
information gathering was needed and provision was
needed
We also set an SLA, a service level agreement, kind
of expectation on things like the GLO, that offers were
made to individuals within 40 days of offers being — of
claims being submitted. But, of course, that's down the
track from when claims could ~ because ~ could be
submitted because they would require the disclosure of
evidence to make the claim.
So there were some attempts to accelerate things but
we also brought in schemes reviewers, again, Sir Ross
Cranston, being on the GLO scheme, Antony Higginbotham
for the -- on the Overtumed Conviction Schemes, which
we were very keen to make sure they could play some part
34
about delays in large claims being essentially stalled
by demands for trivial details to ~
Yes.
~ anyone at Post Office.
Yes. Sorry, yes, it was certainly a conversation we had
in our regular meetings with the Compensation Advisory
Board, how we'd do this a different way. It was very
much the case that I felt there should be some sense
checking, rather than simply just going ~ getting —
sense checking in terms of what might be an appropriate
level of compensation for those kind of things, and
there would be -- and that there should be a way to give
a — an assessment of the -- of somebody's loss without
having to go into a detailed assessment of that loss.
There should be ~ and this is something that was
piloted, that there should be a general -- there should
be less of an expectation, less requirement for there to
be a submission of individual loss at financial level or
in terms of people's health or mental health, that we
should be able to work that out on the basis of some
kind of tariff. That was certainly a scheme that was
piloted within the Department that I understood helped
to some degree.
You also cite, thirdly:
*... the requirement that each claim had to be
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supported by medical evidence of trauma and physical
impacts and forensic accountancy evidence for financial
loss, when these experts had limited capacity ..."
Who was providing you with that information?
Again, that was a conversation I had with the civil
servants, Carl Creswell, Rob Brightwell, who were clear
that there were some issues around just -- there was
a queue for getting the forensic accountancy or the
assessment of somebody's impacts on their health, or
their mental health, and those kind of things can take
time, even when people are working on those cases but
there was a queue of cases to be heard by those, as
people who are experts in that field.
If we could move -- and I think we did this on
a pilot basis, which I understood was successful, this
was probably towards the end of my tenure as Minister ~
to have, I say, a general kind of -- a lower requirement
for assessment of individual need and more of a kind of
general figure that could be put on that kind of loss,
that could provide a basis of compensation rather than
a more detailed assessment.
You've mentioned a couple of times in your answers that
you asked for the issue that was being raised in front
of you to be sense checked, or words to that effect.
What did you mean by that? I sometimes find that when
37
There were proposals for upfront offers in a fixed sum.
Where did that idea originate from?
It originated from me. I floated the idea at
a Departmental meeting with the Secretary of State and
the Permanent Secretary, and David Bickerton and others
were at that meeting. And it was a frustration for
myself and the Secretary of State, indeed, who was
always very supportive of all my efforts to accelerate
compensation, that things weren't moving quickly enough
To be honest, again, I wish I'd recommended it
earlier because it was very well received by all the
people at that meeting, that we should look at
a different way of doing this, but the original idea
came from an idea, you know, a principle, an approach we
took at the Lloyds/HBoS Compensation Scheme, where we
suffered exactly the same problems even when the scheme
was redone with Sir David Foskett as the -- as running
the Foskett panel, still the compensation claims took
a long time to assess those losses and to agree what the
compensation levels should be.
So what we alighted upon was using this fixed sum
award approach, which was very successful and allows
people to walk away from the process much more quickly
and get compensation more quickly and move on with their
lives because, as we know, and it's terrible to hear
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people use that phrase it can carry a number of
meanings, some of which obscure what is, in fact,
happening?
Well, I think I used that in terms of Alan Bates’ case.
If you just look at the case, somebody who has been
campaigning on behalf of thousands of people for
20 years, and then you make an offer of compensation at
the level it was initially made, you'd think somebody
who has been working for 18/20 years on a case, the
amount of time it was required for somebody to work on
that full time — and I'm sure he was working more than
full time in his campaign ~ you can probably add it up
pretty quickly that that claim should be significantly
higher than the claim that was initially issued.
Similarly, with things like Jo Hamilton
Just stopping there, you mean sense check in ~
Yeah.
~ apply some common sense?
Yes, that's exactly what I mean
Okay. You were moving on Jo Hamilton?
Yeah, well, similarly, you know, asking Jo to evidence
her mileage between her home and workplace where she had
to clean to keep, you know ~ to make sure she could,
you know, pay for her things she needed to pay for and
subsist, was just, to me, ludicrous.
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about Mrs Riddell, and my thoughts are with her and her
husband and others, how people do -- have, you know,
passed away without ever seeing compensation. It's
simply wrong.
And it’s a way we can accelerate the compensation to
make sure those people at least can move on with their
lives to some extent after all the terrible things that
have happened to them.
Can we look, please, at BEISO000808. This is
a letter ~- I think we've only got this as an undated or
finally dated draft -- but it's dated August 2023.
You'll see that it's from the Secretary of State, who
was then Kemi Badenoch, if we just go to the top, thank
you, to the Chancellor, then Jeremy Hunt. "Accelerating
Post Office ... Compensation” is the title and
Ms Badenoch's letter reads:
"Kevin Hollinrake and I are both determined that
postmasters affected by the Post Office Horizon scandal
should get proper compensation -- and they should get it
as rapidly as possible.
“Three different compensation arrangements are at
different stages of maturity ..."
Then she summarises, including some figures, the
HSS, the Overturned Conviction Scheme and the GLO
scheme.
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Ms Badenoch continues:
“The scandal ruined many postmasters' lives. The
longer compensation goes unpaid, the more criticism we
shall face — including from the Williams Inquiry. If
we were to fail to compensate all the GLO members in
time we would face severe criticism from all sides.
"Kevin and I have therefore been looking at ways in
which we could rapidly speed up the processes. We
already make interim payments of £163k to almost all
postmasters whose convictions are overturned, and we
undertake only limited scrutiny of GLO claims for
certain heads of loss under £10k pants and HSS ones
under £8k. We are looking to extend these measures
substantially in relation to the GLO, which has started
to receive claims.
"Some of the options we are considering would
actually save more on the cost of lawyers or other
advisors than they would cost in extra compensation.
Others do have additional costs ~ but in my view this
would be well worthwhile in the light of the
non-financial benefits of accelerating the schemes. In
particular, I would like us to be able to offer a £100k
fixed payment to every claimant who applies to the GLO
scheme. I recognise that announcing this would create
significant pressure to offer the same for HSS
41
he addresses the request, the ask:
“In relation to the specific proposal for fixed-sum
awards on the GLO scheme, while successful delivery is
paramount, we must also have regard to our
responsibility for the public finances and to ensuring
that the treatment of claimants on each Horizon
compensation scheme is fair to that of their peers.
"As you note, making fixed-sum awards on the GLO
would incur significant repercussive risk and cost,
including to the [HSS]. Given the extent of this risk
and its high likelihood of crystallisation, I would
encourage you to explore the full breadth of other
options to advance the ultimate objective of timely and
successful delivery of full and fair compensation.”
Then the letter continues about some other things.
That's essentially a rejection of the proposal; is
that right?
Yes, that's right
It doesn't say so, in as many terms. It says, "Please
explore other options”.
Yes, which, you know, we ~- clearly, we were.
What was your reaction to the rejection of the proposal
made by you and Ms Badenoch?
Well, disappointment but I wasn't surprised because it
is quite — was quite --I think we'd --I think the
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claimants, which we should consider separately, but
I believe this the right route far for the GLO scheme.
Such radical action would offer great advantages in
terms of the speed of the process. The DBT Accounting
Officer has expressed some concerns about the value for
money given the repercussive risk and raised the
potential need for a direction for this idea.”
That's a reference to a ministerial direction, yes?
Yes.
“I would welcome your views on the best approach, being
mindful of value for money considerations, and whether
you agree that we should pursue this.”
The letter was copied to you.
So this was a joint suggestion between you and Kemi
Badenoch; is that right?
That's right.
Do you agree with everything that she has written?
Yes.
Can we look, please, at BEIS0000705. We can see from
this -- if we go down to the bottom, please, it's over
the page, the end of the letter -- Mr Hunt, the then
Chancellor, replied. Go back to the top, we can see in
his paragraph 1 in his reply to the Secretary of State,
Ms Badenoch, that her letter must have been dated
9 August. Then if we scroll past paragraphs 2, 3 and 4,
42
Secretary of State had described the proposal as
radical, actually, in a previous letter, and it is quite
a radical thing to do, and a Permanent Secretary would
never sign this off on value for money grounds because
that’s what Permanent Secretaries are there to do, to
protect public money.
Personally, I felt it was still the right thing to
do and we continued to press for it because ~ I think
Jeremy Hunt has always been massively, massively
supportive of everything I tried to do in terms of
providing compensation to postmasters, as has the
Secretary of State and others, and the Prime Minister
indeed, Rishi Sunak. But I don't think any of them had
had the experiences of previous compensation schemes
that we had experienced, the ones I referred to earlier,
particularly Lloyds and RBS, so I felt it was something
that we would, in the end, have to do.
Thank you. Can we move to BEIS0000722. Can we look,
please, at the bottom of page 2 and on to the top of
page 3. We can see an email from Carl Creswell, to,
amongst others, your email address. It's "Minister
HOLLINRAKE", the rest of it has been redacted on data
protection grounds. Is that essentially your private
office?
Yes, that's right
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It wouldn't be to you personally?
No.
This is essentially a record of the outfall from the
decision we have just looked at. We can see it's in
late September, 22 September. If we go forward to
point (3), so if we just scroll down, please. On (3),
that's a reference to a point earlier in the email
chain, which I'm not going to turn up, but CST, which
I think means Chief Secretary to the Treasury, I think;
is that right?
That's right.
The Chief Secretary to the Treasury, that would have
been, I think, John Glen, at that time; is that right?
That's right.
That was before Laura Trott took over in November:
"... the [Chief Secretary to the Treasury] has
approved in principle a higher scrutiny threshold for
Group Litigation Order claimants. He has tasked his
officials with agreeing a sensible level with us, rather
than picking a figure say as £100k of £50k. Our current
scrutiny policy is rather [selective] and just covers up
to £10k shortfalls, so moving to a higher and less
restrictive threshold as soon as possible would be
useful and enable us to process more claims more
quickly.”
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externally.
The email continues:
“This leaves the question of our proposed £100k,
which the Chancellor is resisting on the basis of
concems about precedent for other compensation schemes,
as well as potential repercussions. As we explained
ahead of the recent [Secretary of State] meeting, we
floated the idea of a £75k upfront payment with
[Treasury] officials, but were again rebuffed as
a matter of [Treasury] principle. Our understanding is
that the [Chief Secretary to the Treasury] is
sympathetic to our proposals from a political
perspective but feels unable to go further because of
advice from [Treasury] officials about the impact on
other compensation schemes, (eg Infected Blood) and the
strong views of the Chancellor.
“I would be grateful for Ministers’ views on
handling, please.”
So that's a direct request to you; is that right?
Yes.
“In addition to reaching agreement at official level to
an amended scrutiny threshold (even at £40k would enable
us to process a significant number of GLO cases more
rapidly), minister Hollinrake/[Secretary of State],
could consider writing to [Treasury] ministers to
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Can you explain to us what the “higher scrutiny
threshold” means?
It would mean when you did receive a claim, whatever
that scrutiny threshold was, if it was below that,
threshold, then there would be a pretty light touch
process in agreeing the claim. So if it's £10,000, or
you expect to say it's less than £10,000, just pay it.
‘And what the officials were keen to do and I was keen to
do was raise that threshold so, if you'd got a claim of
up to, say, £100,000 that light-touch process would be
applied to that particular claim.
So you wouldn't get into this lawyer-to-lawyer
process of arguing about semantics, I would say, in many
cases about the level of the claim in certain areas.
You'd just pay it.
So by raising the level, you would bring more claims
within the no or lesser scrutiny approach?
That's right, yes, I think it's fair to say probably
this is one of the alternatives to a fixed-sum award.
The difficulty with this in replacing a fixed-sum award,
is that clearly you can't reveal this scrutiny threshold
to the claimants because everybody would just put
a claim in, if it was lower than that, up to £100,000
level, if that’s where you set the threshold. So it's
something you use internally, rather than disclose
46
represent the case [to them] and ask them again to
reconsider. I would prefer not to hold up progressing
the scrutiny threshold because we are processing cases
every week and it may take a while for that political
conversation to reach a conclusion.”
I'm reading between the lines here -- can you help
with whether I'm correct in my reading between the
lines -- that there was a difference of view between the
Chief Secretary of the Treasury and the Chancellor and
you were being asked as a minister to approach the Chief
Secretary to the Treasury, ie at many ministerial level,
rather than going back to the Chancellor who had
expressed his view more than once.
I might be wrong but I don't think the Chancellor and
the CST did differ actually. I think the CST -- Chief
Secretary of the Treasury ~ was happy to look at
a higher level of scrutiny but still had the same
reservations about the fixed-sum award, the upfront
offer, as he calls it here, as the Chancellor did on
value for money grounds. And I know this has been
a topic of conversation, and you've queried it, I think,
Sir Wyn in terms of public money: there is a requirement
within the work we do and within the Civil Service to
protect public money and to look after public money, and
there's ~ it may seem callous in this regard, and I can
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understand why people might see it like that, but you've
got responsibility to the individuals their families, of
course, to properly compensate them. You've also got
to -- so be fair to them.
You've also got to be fair to other postmasters so
everybody gets treated equally but you've got to be fair
to taxpayers as well, so I do understand the grounds
whereby ministers and officials would push back against
the fixed-sum award because it does mean extra levels of
compensation, it does mean more money paid out.
So I don't think anybody pushed back on the higher
scrutiny level, although they did ask us to decide upon
the — or argue for what the right level, but the
fixed-sum award was more difficult to agree, it is quite
radical.
My experience was that civil servants, certainly
Carl Creswell and Rob Brightwell, were very supportive
of that, as was David Bickerton and the Secretary of
State, indeed, but when it gets to Permanent Secretary
level, both in the Treasury and in the DBT, the
Department for Business and Trade, at that point in
time, somebody has to sign it off on value for money
grounds, they would not do that, it would have to be
ministerial direction, which I was very happy to sign,
if somebody had asked me to do that. But I can
49
for it. But, in the meantime, I think as Carl says in
this email, he says that we'll carry on with things
like -- things we could do, in the meantime, things like
the scrutiny threshold, which would help, while I was
still continuing to make the case for fixed-sum awards,
as we'd got agreement to do in the overturned
convictions.
What this is really talking about is expanding
fixed-sum awards into the GLO and the HSS, as eventually
we did
Q. Could we look, please, just before the break at
POL00448411.
A. Before we get to that, actually, just the reference
there to the Infected Blood, one thing -- and this is
obviously not a matter for this Inquiry, Sir Wyn ~ but,
to me, the Infected Blood Scandal should have fixed-sum
awards, and that's not a feature of those — of that
compensation schemes right now ~- scheme right now.
SIR WYN WILLIAMS: I think I've got my hands full without
that!
‘THE WITNESS: I understand that.
MR BEER: Thank you. This is a letter with which the
Inquiry is familiar. It's from some anonymous Post
Office whistleblowers. I think you've seen this as
a result of disclosure to you in the Inquiry. Did you
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understand why it's controversial
Could you have been the appropriate person to have
signed a ministerial direction?
I don't think without the support of the Secretary of
State, realistically, or indeed the Chancellor, that
would have been possible.
Do you think the Treasury regarded the Post Office
scandal as the priority that you evidently did?
Yes, I do, although I probably had greater experience of
it than some perhaps other people working in the
Treasury. So I think anybody who has had the direct
experience ~- my predecessor ministers or civil servants
dealing in these cases, or many of the backbench Members
of Parliament, or many of the campaigners, obviously,
here and further afield knew how serious it was; I don't
think until the TV series was aired that many ~ that
there was ~ that was a view widely held everywhere in
Government, and everywhere in the public consciousness.
What was your response to the Treasury's resistance to
the proposals that were being made to it?
Well, keep making the case, as we did. One-to-one
conversations with various ministers in Treasury. You
know, I perfectly understood the response because of the
reasons I set out earlier about public money but I still
think it was the right thing to do, so we kept arguing
50
see this at the time?
Not at the time. This was about a week after the
election was called, so that kind of correspondence
would not be shared with me. It may not have been
shared with me in the normal course of events because
I think this letter is unsigned, actually. So —
Itisn't signed. It's signed off by the "POL
Whistleblowers". We can look at that at the foot of
page 2
Yes, signed off unnamed people, which I've got to say,
in my experience as a Member of Parliament, I think
people who are not prepared to put their name to
a letter, I think you're bound to think twice about
completely trusting the contents of something that's not
signed by an individual.
Could you think the opposite: that the strength of views
that are expressed are to be accorded particular weight
because the people who are writing the whistleblowing
letter think that retribution will be taken against them
if they are identified?
I think it's something you should read. I don't think
you shouldn't read it, but I think it's ~ if somebody
makes allegations that they're not prepared to stand up
to the individual -- I understand why somebody might not
want to, particularly if they hold a position that might
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be affected by the claims they make.
So I say I'm not saying you shouldn't read it or ask
questions on the basis of it but I think to trust it
completely on the basis it's not something you can then
go and interrogate both sides -- clearly you can ask
questions of the people who were -- allegations were
made against but it's -- obviously, you can't then go
and ask questions of the people that have made the
allegations.
Q. Thank you. It's just one passage in paragraph 4 on
page 1, the paragraph beginning "Furthermore". It says:
"... key people are not being appropriately managed
by [that's Nick Read or Mr Read]. You are no doubt
aware that Ben Foat has been given significant time off
work (he has hardly been seen this year) and for the
last few months he has been on permitted fully paid
leave, to allow him to prepare for his half day at the
Inquiry on Monday, 3 June. Not only this, but he has
also had a forensic lawyer assigned to him for over
12 months, to assist with the questioning at the
Inquiry, costing the public (we are told) [about]
£700,000 (we are all wondering why on earth he has to
practice so hard to tell the truth).”
Then it continues. Were you aware of this
suggestion, that one of the witnesses to the Inquiry had
53
day, so --
So you couldn't have caused it to be investigated or
explored?
A. No.
MR BEER: Thank you.
Sir, might that be an appropriate moment for the
morning break?
SIR WYN WILLIAMS: Yes.
MR BEER: Can we break until 11.05, please?
(10.49 am)
(A short break)
(11.05 am)
MR BEER: Thank you, sir.
Mr Hollinrake, can we just continue on the issue of
compensation a little longer and go back to paragraph 55
of your witness statement, which is on page 14. Thank
you.
You mention in (b) and (c) essentially evidential
thresholds for claiming and then payment of
contribution, yes?
A. That's right.
Q. Are you aware that UKGI was involved in setting the
minimum evidential thresholds?
A. No, I wasn't aware of that.
Q__ Who did you think set the minimum evidential thresholds?
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had a lawyer supplied to them which had cost about
£700,000?
I wasn't aware of that figure. I mean, it doesn’t
surprise me that they had legal advice. I had legal
advice to give evidence today to understand the process
and what was expected of me. I was very surprised that
anybody needed time off to be able to prepare for this
Inquiry. I've not had any time off to prepare for it.
But I think you are saying that, because of the timing
of this letter, of 20 May, it was within the purdah
period and, therefore, it wouldn't have got through to
you?
Yes, I never saw this letter at the time. I only saw it
when it was given to me as part of the bundle.
So it wasn't something — because on the one hand,
you're campaigning quite hard for fair provision of full
and fair compensation to subpostmasters and, on the
other, on the face of it, a relatively high sum of money
is being expended for preparation to give a half day's
evidence at the Inquiry. But this didn't essentially
arrive in your inbox?
I don't know if it's true but it seems an absolutely
ludicrous amount of money if that's the case.
But it didn't get through to you?
No, I never saw this letter until I saw it the other
54
Well, I guess I assumed they were set by DBT, or whoever
established the terms of compensation that were formed
on the basis of how their compensation processes would
work. So I expected it would be the Department in
consultation with legal representatives.
Would you agree that medical records are necessary for
those claims which allege some personal injury, whether
physical or psychiatric, so that the severity of the
injury can be accurately assessed?
I think that was definitely the principles of the
scheme. I think what we tried to do later on is reduce
the need for evidence around that. So you might say,
well, somebody in these circumstances, we would expect
the compensation for somebody in that circumstance,
whatever happened to them, to be at this level, rather
than the need for specific assessment of that ~ the
impact on that individual. That's what we were trying
to get to, to reduce the need for this evidential
requirement.
But to form a basis of somebody's claim, I think
that -- I understand why that was part of the original
scheme. Because every situation is different, therefore
its difficult to assess everybody's loss or impact on
somebody on the basis of a tariff, but what we looked at
doing later on, as I said earlier in my evidence, is
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maybe there's a way to do that without the need
specifically for that to be evidenced. If a claimant's
lawyer could say, "Well, this is the impact, we believe
based upon other experience we've had with other
claimants, this should be the level of compensation for
the impact they've had on their lives", and then
hopefully that could be then agreed without needing for
a detailed assessment, which should accelerate the
process of compensation.
Presumably, you'd be aware that, in some cases,
obtaining medical evidence can benefit claimants by
achieving a higher award or, for example, where the
expert recommends that treatment is necessary, then the
cost of that treatment can be part of the claim?
Yes, and nobody would ever want to stand in the way of
what - any assessment that would lead to fair
compensation of an individual's claim. It wasn't saying
it would be a cap, it was simply saying is there a way
to expedite this on the basis that you could have a sum
that might reflect on the impact of that individual that
could be agreed between -- would be the claimant's
side ~ the claimant's representatives, and the
representatives on the other side of the scheme, be it
DBT or Post Office.
As to (d), “the involvement of lawyers on all sides", is
87
the panel of KCs and other experts were there to try and
take an inquisitorial approach to assessment of the
compensation and pay it that way. It was, as I say,
an attempt to take away some of that lawyer-to-lawyer
friction but there may be concerns then raised that did
people get the right advice right at the start.
Then, finally on this, are you aware that, for cases
outside the parameters of the funding agreement between
DBT and Post Office, the Post Office is required to wait
for settlement offers to be ratified by the Department
who then have, on occasions, to liaise with the
Treasury?
I wasn't aware specifically of that process, no
Can we tum, please, to the issue of the relationship of
Postmaster Non-Executive Directors to the Board, and
with Government. In a witness statement provided to the
Inquiry ~ there's no need to display it, the reference
is WITN11170100, at pages 119 to 110 ~ Saf Ismail, one
of the Postmaster NEDs, said that he "had conversations
with individuals at DBT", namely Carl Creswell and the
Minister, you, to raise concerns that the business of
the Post Office was in a “very precarious position” but
that he felt “ignored”.
Firstly, do you remember Mr Elliot (sic) coming to
you?
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it your view that postmasters should have the assistance
of a lawyer for complex claims?
Oh, yes.
‘Are you aware that the Department has rejected
a suggestion that early legal advice, ie pre-offer, for
postmasters should be funded by Post Office?
I think the different schemes operate in different ways.
HSS operated in a different way. I think the legal
advice came down the line, rather than upfront. So
I think the idea behind the HSS scheme, as I understand
it, was to try and make it take away some of that
lawyer-to-lawyer friction and to try to make these.
claims -- try and expedite the claims to make them be
able to settle more quickly. I understand why it was
done like that, but that may well have meant that people
didn't get the right advice early on, which is one of
the reasons we wanted to push for fixed-sum awards on
the HSS scheme because there was a concern that things
like consequential loss weren't properly assessed in the
original scheme.
‘Are you aware that, in the majority of cases in the HSS,
they do not involve lawyers or forensic accountants’
evidence?
I think I understood that to be the case yes. It was
supposed to be assessed in a non-adversarial process, so
58
I remember we had a meeting, an online meeting with Saf
Ismail and Elliot Jacobs, I think, to discuss where the
Post Office was and their role within it, in terms of
being non-executive roles, and the potential change of
chair. And, of course, I can't think specifically —
can't remember specifically them saying that, you
know, things -- I don't remember them saying everything
was fine, nor can I ever remember them saying that
things were disastrous and unfixable, and certainly my
feeling was, in that conversation that we had with them
online in that meeting, is that they were both keen on
the new chair we were recommending to take over at the
Post Office, Nigel Railton.
Can we look, please, at BEIS0001020. You will see this
is an e-mail from and to your private office email
address, yes?
Yes.
This is, as we've seen in the past, a means sometimes
employed of recording a meeting: an email to yourself,
essentially.
That's right.
In this case, it was from Jamie Lucas again to himself,
essentially a minute of the meeting; is this the meeting
you were referring to?
That is right.
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I's 28 March this year. You will see it records, in
a sort of semi-verbatim fashion, what was said with you
being referred to as "Kevin", Mr Jacobs as “Elliot” and
Mr Ismail as "Saf.
You'll see there's some quite general information
passed and, essentially, sort of pleasantries right at
the beginning, where I think you're presumably warming
each other up at the beginning of the meeting there.
Then if we look at the second paragraph, you say:
“... we are on the same page on central costs."
Mr Elliot says:
“The minimum wage ... is becoming a problem.”
Bottom of the page, you say:
“Agree with what you've said, the top and the bottom
of it.”
This is essentially about not Horizon issues at the
moment here; speaking about, essentially, the future of
the Post Office.
Then over the page. They say that:
“It’s a lack of a roadmap [that's a problem]. We
live in [I think that's supposed to be a ‘never-never
land’] between sustainable business and social purpose.”
You ask: "Who's your stand out?"
Mr Jacobs replies: "Nigel Railton."
Mr Ismail agrees. Then it continues
61
I think good. As I say, it wasn't a day-to-day working
relationship but I hope they felt that I was willing to
listen to what they had to say, and the thing, the
responses I gave them were what I truly felt and, as it
says in this exchange, I did agree with a lot of the
things they were talking about, particularly the need to
reduce central costs, so that more of the revenue that
flowed into the Post Office centre then flowed out to
the postmasters who were actually doing the day-to-day
business at the sharp end.
Do you understand how Mr Ismail feels able to say that
he felt ignored after his conversation with you?
I was surprised that's the case, you know, but if that’s
how he feels, that’s how he feels
Did you take any action as a result of the things they
said to you in the course of the meeting?
I think the principal thing we were talking about here,
which is what we certainly agreed on, was the need to
cut costs so centre, which is something I was very keen
to do, that was something I'd talked to Nick Read about
and other members of the Post Office Board. I got
frustrated, I think I said in my witness statement, that
that didn't happen more quickly. But that was certainly
a conversation I had with Nigel Railton when we first
‘met about the potential for him to take over as chair.
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What was the purpose of your engagement with the
Postmaster NEDs in this way?
I guess to find out what was going on at the sharp end
and what they really felt about the business, and I was
keen to have their confidence that we were truly
interested in making sure that the Post Office had
a viable future, not just as a network but also at
an individual postmaster level. So I always liked to
talk to the people who were at the sharp end, and
I think both Saf and Elliot both operated as well as
non-execs, so they are postmasters as well as non-execs.
That's the reason they're on the Board.
So I was very keen to hear from their perspective.
but also for them to feel that they were being heard.
Was this part of a regular series of meetings with them
or was this essentially a one-off?
I think it was a one-off, although I had spoken to them
separate ~ in separate situations, when I attended
a board meeting, and I think when we were at various
conferences, National Federation of SubPostmasters
conferences as well. So it was never something I was
afraid to do, talking to the people who were the
operators of the network themselves.
In general, what was your relationship like with the two
Postmaster NEDs?
62
And I understand, you know -- and Nigel was always
very keen to do the same. He felt the same, and I think
he has spoken subsequently or recently about his plans
to reduce the cost at the centre, which definitely need
doing.
So I don't think there's anything in here
fundamentally, if we're talking about central costs or
the shape and size of the network, which both are
matters for consideration and action, or anything that
I didn't agree with or wasn't willing to act upon. So
I'm surprised he felt ignored. I'd be very happy to
have a conversation about why he felt that.
Thank you. That can come down
Turing, then, to the issue of cutting central
costs. Can you firstly explain in summary terms what
you mean by cutting central costs?
Well, it's ~ I had a business background, and when you
hit trouble in a business, as the network has -- and
lots of those troubles have come as a result of customer
behaviour, as well as other matters, in terms of how
difficult it is as a postmaster to make a living. So,
you know, we use high street shops less than we did
before because people have different ways of shopping.
I understand that. And so ~ and the Post Office and
lots of the services we used to get from the Post
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Office, such as our driving licence or passport, many of
us do online now, which has hit postmaster income
significantly.
So what you do when you're in a situation where your
branches are less profitable, the first thing you should
look to do, in my experience, is cut costs at the centre
because they are not the most important - the most
important people in your network are the people serving
the customers day to day because they're generating the
revenue. So what you'd expect to happen, therefore, is,
the size at the centre, particularly the executive and
the management team, you look at how many people you
have in that Executive Management Team and look to cut
it. And, typically, what I did in my own business when
you hit trouble in the past, you would have cut that by
at least 40 per cent, if not more.
And that's some of the conversations we had with the
Chief Exec and their team and the Finance Director, or
the Acting Finance Director, the acting CFO. You know,
how many people were at different salary levels within
the organisation, and what was going to be the direction
of travel in terms of reducing the costs of those people
at the centre. There were other costs as well, and the
plans to reduce costs of directly managed branches, for
example, which are a significant cost, and to the ~ to
65
It's quite the list.
Yes.
Amongst those matters that you mention is a reluctance
to reduce central costs to allow a consequential
increase of revenue to postmasters’ remuneration. The
way that's written, I take two things from it, can you
tell me whether I'm correct to do so: firstly, that you
drew a link between the reduction of central costs and
the increase of revenue to postmasters?
Well, inevitably there is.
Was that the purpose of the reduction, in your mind, of
central costs?
Yes, of course.
Then the second thing is that there was a reluctance to
do so
Yes.
-- by the Post Office?
Absolutely.
Who within the Post Office did you detect a reluctance
in to reduce central costs?
Well, the Chief Executive. I mean, the Chief Executive
carries the can for everything and it's not easy to be
a Chief Executive and it's not easy to be a Chief
Executive of an organisation that had hit so much
trouble. So I sympathise about the difficulties of
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Post Office Limited, and that was something we discussed
but, certainly, focusing on the people, the management
team at the centre and the Executive Team, I think 143
people earn £100,000 or more, and you expect there to be
a direction of travel in terms of reducing the numbers
of people who earn that kind of money.
Can we tum, please, to page 8, paragraph 30 of your
witness statement. Under the heading "Post Office Board
and culture”, within paragraph 30, you say this:
*... there are also signs that the Post Office
remains too inward looking and dysfunctional."
Then examples of being too inward looking and
dysfunctional you then give. You say:
"Good examples are the failures to disclose
information to the Inquiry, [2] the slow pace of
disclosure for compensation cases, [3] the reluctance to
reduce central costs to allow a consequential increase
of revenue to postmasters ... [4] the Henry Staunton
saga, [5] the failure to deal with longstanding issues
with senior executives, such as Alisdair Cameron, (6]
the Remuneration Committee's decision and processes
around the sign off of bonuses for complying with the
Inquiry’s disclosure requests, {7] the persistent and
aggressive lobbying by the CEO to significantly increase
his remuneration.”
66
running this organisation, but that — I don't
sympathise with doing things that were clearly needed to
be done.
And had Nick Read come back to me and said,
0,
you're wrong, Minister, Kevin" -- whatever you want to
call me -- "we need to keep the people for this, that
and the other reason”, then I would have listened to the
argument, of course, but I never heard a compelling
reason why that should not be the case. There was, as
I understood it, an acceptance that there should be
an area where we would look to save costs, that could
mean then more money flowed into the postmasters
themselves.
But then nothing happen about it, despite our urging
at several -- at every juncture, at every meeting. And
you could easily say, "Well, you should have done more"
and I would hold my hands up and say I should have done
more to insist upon this, but that was never properly
forthcoming and that, to me, is a failure of leadership.
Can I look at those two things that I've taken from the
sentence, and that you've confirmed, then -- the first
of them is the link between a reduction in central costs
and increased remuneration for subpostmasters, and that
as an aim -- by looking at POL00447841. You'll see this
is a letter from you to the then Chairman, Mr Staunton,
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of 29 June 2023. It's a five-and-a-half-page letter
including its annex, and its heading sets out its
purpose, namely to set out the strategic priorities for
2023 to 2024.
Could you just explain why you write letters of this
kind and what their purpose is?
Obviously, we are the shareholder for the organisation
and, therefore, it's up to us to set out the priorities
that then the Chair and the Chief Exec should then focus
upon.
Page 2, please. You say:
“... Lwould like you to focus on the following
priorities, and align the reward package to the
shareholder priorities ..."
So “align the review package to the shareholder
priorities"; what does that mean?
I would guess that's a case of the ~ the - any bonuses
that would be due to senior executives should reflect
the priorities that are set by the shareholder.
Okay:
“1, Effective financial management and performance,
including management of legal costs to ensure medium
term viability.
“For the [financial year 23/24] the Post Office
should
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remuneration. In the letter, it doesn't set out, as
a strategic objective, the need to increase postmaster
remuneration, or that the Post Office should work
towards that. Was that a strategic priority?
Yes, it definitely was. It wasn't a case I was trying
to do this to reduce the contribution by the taxpayer —
and it was a case of, from my focus, it was very much —
all the conversations I had with post masters, be it
through the conferences I attended or by other means,
was very much an understanding that life was difficult
as a postmaster. Many were working at or below minimum
wage, and the Post Office itself would not be viable if
its network would not be viable. So that's the most
important part in terms of viability of the network, in
my view.
If we just look through, just if we scan through the
four strategic priorities, there's a mention at the foot
of that page there, in the last bullet point under
number 2 of postmasters. But that's in the context of
rolling out to them the Strategic Platform Modernisation
Programme. So far as I can see, that's the only mention
of postmasters in the strategic priorities, if we go
over the page and look at priorities 3 and 4. Are you
saying that it was to be taken as read that postmaster
viability and, as part of that, remuneration increase
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Then as the fourth bullet point:
"Maintain stringent cost control, and maintain
a clear focus on value for money and efficient delivery
across the cost base, including ..."
Then there are five sub-bullet points, the last of
which is:
"Other measures aimed at reducing central costs
wherever possible."
Is this the record, essentially, of you telling the
Post Office to reduce central costs?
Yeah, I mean that's one of the records. The other
records containing within the meetings that are minuted
between myself and Nick Read.
But this is a particularly formal way of doing it ~
Yes.
~ by setting out the shareholder strategic priorities;
is that right?
Yes.
This says that the direction to reduce central costs
has, as its aim, the medium-term viability of the Post
Office, yes?
Yes.
In the heading at the top.
That's what it says, yes.
Rather than with a view to increasing postmaster
70
was a strategic objective?
Well, I don't think anybody who had an interaction with
me in terms of the management team or leadership team
would have any doubt that it was my intention, and
a requirement of their work, to make sure that we reduce
costs to make sure that ~ and the beneficiaries of that
should have been the postmasters. It may not
specifically say this in here and maybe it should have
done, but that was certainly the case, that's what we
were intending to do.
Can I look at the next part of the equation then, in
that sentence that we read, which was that there was
a reluctance within the Post Office to reduce central
cost, by looking at BEISO000805. I think this is
essentially a presentation or a series of slides for
a presentation for a meeting that was held on 5 December
2023, which I think you attended?
Mm.
This is part of the Post Office presentation to you, or
to the meeting at which you were present. It's,
I think, annotated up the slide pack if we look, for
example, at page 3, presumably by somebody at the
Department because this was disclosed to us by the
Department.
Overall, can you just describe the purpose of the
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meeting; can you remember?
Well, obviously, central costs is mentioned there, and
one of the ~ I think the next slide then talks about
the number of people on high salaries. So I'm not
saying the only purpose of the meeting was to look at
central costs but, as far as I was concerned, that was
one of the most important areas for discussion at the
meeting.
Can we tum to page 7, please:
“Further scope for self-help is possible but this
either involves trade-offs in the near term or it
delivers benefits outside the [three-year plan]."
Then this the Post Office speaking, essentially:
"We have cost saving targets for [the financial year
23/24]
I think that's a reference back to the letter we
just looked at:
*.. and we will have further targets for [24/25}."
Then:
“However cash constraints limit what we can deliver
in the near term.
“if [the Department] was to [do something] (and
noting subsidy has been flat for five years) we would
[have to do something] we would have more funds to
support cost saving activity
73
need to get from Treasury to fund those changes, and
I'll make the case for you to make those changes". So
there should have been nothing that would stop Nick Read
or others making the business case to me and, if it made
sense, I would have taken that to Treasury to get the
money, if that made financial sense to do so.
So what you were being told on this occasion evidence of
or an example of the reluctance to reduce central costs
that you've described?
Well, it was one of the barriers that might be put in
the way. The response I always get to that is "Fine,
okay, we'll come back with a business plan to do that",
I never got that business plan back. So there was never
a clear argument made to me to say, "Okay, you put X
amount of money in here, we can deliver that, we can
bring that money back to you in savings", or in terms of
how that may work over a period of time. And so that
was never the case that that was — that ~ it was never
the case that that case was made.
I've heard this a lot from a business perspective,
that you need people at the centre to do all the work at
the outside and even though the outside is getting
smaller and clearly, in many ways the Branch Network is
getting smaller because some of those branches are not
physical branches any more, they're drop and collects
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"We know our costs can and should be reduced and we
have a track record of taking costs out across our
business over the last ten years. But to have any
material lasting impact we need access to funding.
"With limited capacity, tight cash and uncertain
future funding, working up detailed cost saving plans is
speculative and high risk. Plans developed today can
only be implemented today.”
Was this Post Office saying to you that cash
constraints limited how far the Post Office could cut
its central costs, further than it was already doing
without Government support?
Yes, that's right. That's what they're saying.
Do you agree that Government constraints, in fact,
significantly limited how far Post Office was able to go
in cutting central costs?
No, I don't. And the conversation I think has been
minuted elsewhere that my -- whenever we discussed this,
there are things like directly managed branches, for
example, redundancies at the centre, all these things
cost money. In the short-term there is a short-term
impact when you make these decisions, I completely
understand that.
My clear message to Nick Read and others was, "You
make the business case for that investment that we would
74
and other things, and yet the centre remains the same
size. To me, that's wrong. That's the wrong emphasis.
The first thing you should look to do is reduce costs at
the centre.
it's not uncommon that the management team at the
centre don't want to do that because there are lots of
people they work with on a daily basis. So it's
a difficult thing to make redundancies. I've been
through it. Itis heartbreaking. You are letting
people go you've worked with for a long time but that
doesn't mean that's not the right decision to make,
and -- but the difficulty here was it just did not move
forward at the pace it should have done.
You tell us in your witness statement that the solution
is good leadership, nothing can replace that. It's
paragraph 48.
Yes, I said that.
Would you accept that, as the Government minister for
this 18-month period, you had a role in the leadership
of the Post Office?
Yeah, of course. You could easily make the argument
Hailed, I could have pushed harder. I will hold my
hands up to that effect. The thing is, you can't do it
for them, the Chief Exec is there for a reason, paid
a lot of money to do that job, the Chair the same, and
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the other in the management team. You can see how many
people in the organisation — there are 43 people,
I think, in the organisation paid more than £150,000
a year, so you'd expect those people to be competent at
delivering on priorities set by the shareholder.
You say this of Mr Staunton, if we tum it up, please,
it's page 9 in your witness statement, at 34, which is
at the bottom:
“Whilst I did not have regular contact with Henry
Staunton, as Nick Read was my principle [sic] point of
contact at [Post Office], my own view of Mr Staunton was
that he was incapable of chairing this organisation
I first started to doubt his judgement only a few days
into my ministerial role when he strongly advocated a
very large percentage increase in the CEO's
remuneration. I was very aware from my meetings with
senior officials at UKGI ~ Tom Cooper and then Laura
Gratton -- that they did not rate him very highly and
felt he was a Chair from a previous generation."
Given that you had doubts about Mr Staunton as soon
as you took office and heard from others about his
inadequacies, why did it take a considerable period of
time after then to essentially move against him and
ensure his removal?
I don't believe you should go round sacking people on
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Mr Staunton very highly, so far as you understood?
Well, I just don't think they felt he chaired the Board
very well. I think, if you look at the report that was
done separately, evidenced by Grant Thornton, it talks
about some of the processes, meeting discipline, lack of
structured management information, all of those things
a chair is responsible for. So I guess that was
a reflection of some of those failures at board level,
and that's very much the responsibility of the chair.
In paragraph 36 of your witness statement, you say
you're aware of Mr Staunton's allegations, in which he
claimed that a senior departmental official had told him
to go slow on compensation for subpostmasters and also
about the reasons he was given for his departure and you
say, "So far as I'm concemed this was nonsense”.
Can you explain why you think that what Mr Staunton
has alleged was nonsense?
Well, I just don't imagine who he had a conversation
with on that basis. And, if you look at Mr Staunton's
evidence to the Select Committee, after he was let go,
he actually says that there was nothing wrong with the
HSS scheme. I think that's, again, evidenced within my
witness statement, that he said it was — that bit of it
was going fine. Now, I think anybody who has been
through this process as part of the HSS would not say
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a whim. I always try to work with people in my business
life, and also in this life, in trying to give people
the opportunity to get the job right. Now, that was.
an early reflection in terms of the remuneration point,
I wasn't ~ I was ~ it wasn't handled directly by me;
it was my Secretary of State, Grant Shapps, who handled
the remuneration situation.
But, certainly, a chair coming on and arguing for,
I think -- I've never seen the letter but I think it was
a doubling of Mr Read's -- Nick Read's salary, I think
we all were pretty shocked by that within the
Department. So, at that point in time, red flags
appeared and I think it wasn't the only time he made
that case.
But, you know, I say, he wasn't my principal point
of contact. As I went through this, and certainly,
latterly — it was only latterly that we heard that
Mr Staunton’s allegations -- I think proven
allegations -- of misogyny and racism and bullying,
these kind of things that he was — that he was alleged
to have done, you know, over time it became the case
that I think it was quite clear his position was
untenable and that was a position that was held by UKGI
and the civil servants responsible.
Why did the senior officials at UKGI not rate
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“Everything was fine with the HSS schemes". We know
there were problems with that.
In fact, he refers to that in one of his other
emails, this claimant who only received £16,000. That's
‘one of the concerns he raised.
So I just do not think that Mr Staunton’s evidence
holds water on so many different levels. I think that
what he -- what I think he says in the Select Committee,
the problem was with the overturning of the convictions,
which we did. We overtumed the convictions of probably
700 people but that was something we were in the process
of doing at that point in time, something that never
happened in the history of Parliament,
So I just didn't think that any of his allegations
were ever evidenced or ever made sense.
Thank you. Can I turn to Mr Read. You tell us in your
witness statement that the Post Office was your number 1
priority as Minister, that you spent at least
25 per cent of your overall time, and at many periods
a much higher percentage, focused on the Post Office,
and that Mr Read was your principal point of contact at
the Post Office
You tell us in paragraph 44 if we move on, please:
“As time went on I formed the view that Nick Read
was unable to lead the organisation as it needed to be
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led."
You say:
“I repeatedly asked for basic information about
management headcount ... and a plan to reduce ... senior
management headcount and cost ... It was like drawing
teeth."
What information are you referring to: basic
information?
Well, you saw, I think a bit earlier on the -- well,
it's in evidence in the pack, if it wasn't shown on the
screen ~- the numbers of people earning more than
£100,000. You'd expect, quite simply, the situation
today — and this is what I set out at various meetings
we had, how did you think those numbers ~ what the
direction of travel with those numbers in a year's time,
in three years’ time, you'd expect that direction of
travel to be significant in terms of reduction of cost.
It's quite simple: you'd expect a Chief Exec to
deliver that from one Board meeting to the next, so
within a month, and that never happened.
You tell us in paragraph 46 that you worked
constructively with Mr Read, you would meet and talk.
You thought it might give him a decent chance to see
through the reform of Post Office's culture:
“But my view was that the guy was being paid lots
81
no unifying purpose, a lack of succession planning, and
we talked before about the processes of the meeting
discipline and the people agenda.
So it was quite clear that the organisation was not
being run as well as it should. As I said before, it
was a difficult organisation to run, hugely in the
public spotlight because of all the — because of all
what's happened to it. So I'm not saying this job was
easy but I think there were some fundamental failings
and shortcomings amongst the leadership that meant it
hasn't moved forward at the pace it should have done.
Paragraph 45, which is above the one highlighted, you
say:
“Nick Read's pay as CEO was always a running theme."
I'm not going to explore that with you but later in
the paragraph, at the end, you say:
“It was generally thought that Nick Read was always
on flight watch, even before this.”
First of all, can you explain so that I understand
what you mean by he was always on “flight watch”.
Yeah, I think Henry Staunton had referred to this,
that -- and so that my officials at times ~ that he may
leave if he wasn't given more pay. So not just that,
that's not the only thing that Nick might consider as
a reason to leave. You know, he was massively under
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whilst not doing a very good job. On the other hand
subpostmasters ... were struggling to break even at
best.”
What, in your view, were the key issues with
Mr Read's leadership at the Post Office?
Well, I was always being told that -- things within the
Post Office nick Read was having problems doing, and
motivating the team. I think I was told by Lorna at
UKGI that the team needed motivating, we needed to bring
somebody else in to motivate the team, the leadership
team. Well, that's the job of the CEO, quite clearly:
reducing central costs; the disclosure of information to.
the Inquiry, and to make sure that information was
disclosed to cases. I think there was a -- at one point
a server was discovered, or two servers were discovered
that carried lots of information that hadn't been
disclosed to the Inquiry.
There were constantly a number of different issues
that were being — that had been raised with me or had
been raised in the media, that gave rise to concern that
the organisation wasn't being led well.
I think, again, this is set out by the Grant
Thornton report in terms of the limited effectiveness of
the Board, as it was stated in their report on 24 June
a lack of clarity, low levels of trust within the Board,
82
pressure and I think anybody running that organisation
would have been. So I understand this was not an easy
sig.
But I think it principally meant he'd leave if we
weren't careful. My response always to that was "Well,
you know, if that's the case, that's the case, and we'll
find somebody else to lead the organisation if he
decides to leave"
You tell us later on your witness statement that:
"My own view was that we should not be moved by the
threats to leave. If he wanted to leave, he should
leave."
Is that right?
That's right.
Can we look, please, at POL00448706. This is a letter
from you of 21 April 2023, about Mr Read's remuneration,
to Mr Staunton, the then Chair of the Post Office. You
say in the second paragraph:
"The Government continues to be grateful for Nick
Read's work in leading [Post Office] since his
appointment as Chief Executive Officer in September
2019, and I recognise the significant commitment and
effort he is putting in to tackle the multiple
challenges that the company is facing."
If you just scan the next two paragraphs, then the
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large paragraph at the foot of the page. So in this you
refer to a miscommunication between Post Office and
Government, in relation to a backdated pay increase for
Mr Read.
You say that you were content to approve it and that
you recognised the significant commitment and effort
he's putting in to tackle multiple challenges.
Can you help us, why did you approve the backdated
pay increase, if Mr Read wasn't, as you say now, doing
a very good job?
Well, this is fairly early on, don't forget. I think
I was moved from the (unclear) Government changes that
I think came into effect in February of that year, so my
responsibility for this at that point in time was
greater. I think the previous Secretary of State held
a lot of the responsibility with the Post Office prior
to that. The new Secretary of State, Kemi Badenoch, had
been very happy to leave me more to it since then.
‘As general principle, I'l work with anybody until
I'm ready to not work with that person. So it's not the
case of at this point in time we were trying to been
about Nick Read's departure. It was the fact that if he
was ready to go, he should go. But we weren't saying at
this point in time, that it was something we were
actively trying to do in trying to get rid of Nick Read.
85
Office's compensation schemes, had an exchange with the
Department for Business and Trade. He started it off
with Carl Creswell and Rob Brightwell. They remained
copied in throughout the exchange but the responses came
from Beth White. If I can just summarise what he says
in his emails, his argument was that the £600,000 was
effectively a floor, in the sense that everyone in the
Overtumed Conviction Schemes would be entitled to it
and, therefore, it should be paid to everyone
straightaway.
His point was that those who were able to show that
they were entitled to more could treat it as an interim
payment and, for everybody else, it would just be a full
and final payment but paid out straightaway?
His argument was also that paying it out to everyone
straightaway in that fashion would get compensation
flowing quickly because everyone is entitled to it,
everyone might as well have it, those who still have
more to claim thereafter can do so, in the time that
that takes; do you see his point?
Ido.
Well, the response that he received was as follows ~
I think we will have time to bring it up, so I'll ask
for it to be brought up. It's BEISO000738. If we could
start on page 2 -- if we could zip down to page 2, thank
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So that being the case, we were trying to work with
him on the basis of a constructive relationship and Nick
Read, at this point, hadn't had an increase in pay, as
I think it says in the letter, since 2019. And there
was some confusion about when this pay rise is made, and
in the context of some much larger pay rises that Nick
Read and the Chair was pushing for. It seemed
a reasonable thing to pay this relatively modest
increase in his pay at this point in time on the basis
he hadn't had a pay rise for four years.
MR BEER: Mr Hollinrake, thank you very much. Those are the
questions that I ask.
THE WITNESS: Thank you.
MR BEER: Thank you very much for answering them. There
will be some questions from the Core Participant
representatives taking us up until about 12.30.
I think we start with Ms Page. We've got questions
from Mr Stein as well, and one from Ms Watt on behalf of
the NFSP.
Questioned by MS PAGE
MS PAGE: Mr Hollinrake, hello.
I want to ask some questions about the £600,000
offer, which was made to those whose prosecutions were
held to be an affront to the public conscience
In January this year, Mr Recaldin from the Post
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you. This is Beth White and, as I've said, it's copied
to Carl Creswell and Rob Brightwell:
"Simon,
"You asked yesterday whether the aim was to get
money as quickly to claimants, or to get F&F [evidently
full and final shorthand] to claimants. Our focus is on
achieving the latter. This proposal ie his proposal]
doesn't encourage any pace or movement to full and final
settlements does it? Ministers and politicians as shown
in the Select Committee are keen to take steps to
encourage victims getting their full and final
settlement as quickly as possible.”
If we go up, he tries one more time, and then on
page 1, Ms White comes back to him again. He says:
"So we hold back funds that we could pay to
pressurise sorry ‘encourage’ F&F?"
Then her response above that. If I could pick it up
from the second sentence:
"You asked yesterday whether you should focus on
maximising payments or maximising settlements yesterday.
We were very clear that we would like you to focus on
ensuring that claimants are able to settle their claims
as quickly as possible, as this is what ministers and
other politicians are keen to achieve ...”
Neither Mr Creswell nor Mr Brightwell stepped in to
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contradict that. Was the Department for Business and
Trade right to say that ministers wanted to effect full
and final settlements ahead of getting payments out of
the door?
Sorry, would you just ask that question again?
Well, these responses are saying very plainly, "We don't
want you to maximise getting payments out of the door,
we want you to maximise getting full and final
settlements. That's what we're aiming for".
No, we wanted both. Will you go back to the original
point that Beth made, in that first sentence?
Yes, page 2.
Yes, that's right. You asked whether the aim was to get
money out as quickly to claimants or to get full and
final settlements to claimants. She says the focus is
the latter; I say the focus is on both, because the way
the fixed-sum award works, as you will, I'm sure, know
is that some people, if they've gone through a full and
final settlement would have got less than £600,000
Some would get more. So the point is, it shortens the
queue for the others.
If you take half the people out of the queue —
because one of the problems we heard is getting people
heard that — their claim heard or getting the
assessments made, forensic accountants, experts on
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"So I then had to issue instructions internally to
say that 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.”
He's wrong and, if he'd come to me and expressed those
views, I'd have explained to him why he was wrong ~ I'd
have listened to him. We had a very similar
conversation with the Horizon Compensation Advisory
Board and Lord Arbuthnot made this argument too: he said
“Why can't we pay to everybody and then we let the
people who want to claim more”. And you can make that
argument and James did. But I say, I point to it, if
you do that, you will not shorten the queue for people
who think they're claims are worth more than 600,000.
So I've pointed out before how we've seen this,
massive uplift in compensation over the last year, which
has to be a good thing, a fourfold increase to now over
£438 million, I think itis. A lot of that is through
the fixed-sum awards.
I think of the latest scheme, of the GLO scheme, of
the 306 claims submitted so far, 96 per cent have
received offers, 295; 228 have agreed offers, I think
66 per cent of claims, through the fixed-sum awards.
Again, in terms of the new Horizon Convictions Redress
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mental health, physical health, all those things, but if
you have fewer people having to go through that process,
they can get to the claim point more quickly because
people have come out of the process. It was never
trying to say to somebody, "Your claim might be worth
1 million, we're going to give you 600,000 to get you
out of this". It was a choice people could have and
they could make the assessment based upon their personal
circumstances. It was never trying to shortchange
people
Let's have look at how it panned out as far as.
Mr Recaldin was concerned. In the Inquiry, on Monday,
he said this:
"Lwas extremely uncomfortable with that, and
I think I'm making my point, articulating 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. There's an offer there. I want to pay the
offer amount [ie the 600,000] then I don't want to feel
restricted about not paying that out because I'm any
going to pay out ifit's a full and final settlement.
But they made it clear, absolutely crystal clear, 'No
Simon, the objective is there, black and white, full and
final settlement’
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Scheme: 36 claims have been submitted; 36 offers have
been made and paid
So we're seeing much more rapid compensation through
this mechanism. That does not stop people going for the
full assessment and, if you do if a complete a full
claim, which you can do more quickly now because you can
access the reports now for the forensic accountants and
the other advisers you need, assuming you submitted that
claim, then you get £450,000, as an interim payment.
So-
Why not 600?
Why not 600 — well, it was actually £450,000 as
recommended by Sir Gary Hickinbottom, as the payment we
should make. I can't remember why we said not £600,000
at that time. I guess it's because the claim might not
stack up at 600,000.
Is it not because it's putting pressure on people to
accept the full sum of £600,000?
That was never the intention.
It might not have been the intention; can you not see
that's the effect?
Well, if you -- I'm very happy to hear from you or
anybody else in this room, or anybody else outside this
room, about ways to accelerate compensation to
individuals. We felt this was the best way. I'm very
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happy to have a conversation with you at a later stage
why you think — how we think we might do this in
a better way, and the Advisory Board would do that too,
but we accepted virtually every recommendation made by
the Advisory Board.
Our intention was always to try to expedite claims
full and final settlement, or full assessment claim, or
a fixed-sum award, whichever people would prefer.
Q._ This was the message that your Department sent to the
Post Office:
"You asked yesterday whether the aim was to get
money as quickly to claimants or to get F&F settlements
to claimants. Our focus is on achieving the latter."
A. That's not true, and I never had a conversation with
Beth about that. If she'd have asked me, I'd have
explained it to her. But definitely myself and Carl
Creswell and Rob Brightwell, and the Horizon
Compensation Advisory Board, were all completely on the
same page as this, as this is the right way to do it.
Q_ One more issue, if I may, Mr Hollinrake. It's about
Herbert Smith Freehills. Now, in January this year,
Post Office told you that HSF were to be phased out. In
March this year, in another meeting, I can give the
reference because this is not one that has come up
before -- we don't need to look at it - BEISO000754,
93,
some very good people in Herbert Smith Freehills, I'm
not criticising everybody who works in that organisation
and I'm not saying they weren't trying to do the right
thing but perception is reality. I think there's
a certain part of — as has been said earlier within
this Inquiry and by the Chair, that we are where we find
ourselves, and what's the best way from getting here to
there?
So, yes, I mean just tearing out a big lump of the
existing compensation scheme and the processes and the
legal advice of that scheme maybe isn't the quickest way
to get compensation out the door, so it does take
longer. Should it have happened in the first place?
Absolutely no, it shouldn't.
MS PAGE: Thank you. Those are my questions.
Questioned by MR STEIN
MR STEIN: Mr Hollinrake, my name is Sam Stein. I represent
a large group of subpostmasters, also people that worked
in Post Office branches and we represent people that
have been through the Court of Appeal and who have had
their convictions overturned, and people that have had
their convictions overtumed via the legislation.
Now you've mentioned and discussed with the Chair,
Sir Wyn, the issue of lawyers being involved and how far
and to what extent that assists.
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you were told, again, that the Post Office were looking
at alternative providers.
Back in July 2020, in the email that you wrote as.
chair of the APPG, which we've already looked at, you
said on page 2:
“I'm also very concerned at the involvement of
Herbert Smith Freehills, who I understand are advising
on the design and implementation of the Historic
Shortfall Scheme. The mere fact that HSF acted on
behalf of the Post Office in the legal action with the
responsibility to minimise losses should prohibit them
from taking any role in a compensation scheme."
Of course, you were also aware and you said in that
email of their involvement in the compensation scheme
for small businesses after the banking scandals and the
question marks over their role in that case, as well.
it was an obvious problem, wasn't it, having Herbert
Smith Freehills involved in the compensation schemes?
Yes.
Yet here they were, four years on, and you were still
having warm words about them being phased out,
alternative providers. Do you regret not doing more to
make sure that they were properly exorcised from all the
compensation schemes?
Yes, absolutely. I mean, you know, I'm sure there are
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You've had experience yourself, am I right in
thinking, with a constituent of yours, who came to you
to discuss their issues - someone that has been
affected by the Post Office scandal ~ and that they
were discussing with you an NDA, non-disclosure
agreement, and the potential effect of their signing of
the Official Secrets Act; is that right?
I don't remember that particular case. I did have
a constituent in Norton, near Helmsley, who passed away,
but I'd never met that individual before, that was the
case, who'd been — was part of the 555. I may be wrong
but I don't honestly think I did.
I think David Davies brought up the point in
Parliament about the Official Secrets Act and the
implications that had in terms of the ability for people
to speak out,
I'm grateful. That's of assistance
Subpostmasters signed the Official Secrets Act on
taking up post. As far as I know, they still do so.
Til stand corrected if 'm wrong. One of the issues
that we have come across is that they therefore think
that that may inhibit them actually engaging with the
Post Office, even on such matters as compensation
schemes. So that's something that has been raised. We
can't go into Parliamentary discussions but that's
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something you're aware of that has been raised
Yes, I'm aware of that.
We have experience as well that, since the legislation
cleared those people who had not had their cases taken
before the Court of Appeal before -- because there's
a certain issue regarding people that have gone to the
Court of Appeal in the past ~ but those people in the
past whose convictions have been cleared. We've had
people contacting my instructing solicitors Howe+Co
saying, "We've got this letter about my conviction, is
it real? Is this the Post Office trying to do something
else?"
In other words, the sheer level of mistrust that is
engendered by scandals such as the Post Office also
means that people need support from lawyers; do you
agree?
Oh, yes. It wasn't a personal criticism of you,
Mr Stein, in terms of my earlier remarks on lawyers.
Thank you very much. I'l put that one on my website!
The other issue, of course, and perhaps slightly
more seriously, is that people that have been through
these scandals, the Post Office scandal, you mentioned
the Blood Inquiry and what happened there, people are
damaged, severely damaged. People are damaged in their
physical health; people are damaged in their day-to-day
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All of that work has to be done on behalf of a large
number of people. One or two people lawyers can cope
with on a pro bono basis but you cannot represent people
when you're talking about tens and numbers of people
that gets up into the larger numbers. There is simply
not the capacity for lawyers to do so. So what has to
happen is that those lawyers make, as part of their
campaign, the attempt to try to get Government to engage
on compensation issues.
Let me tell you about the next stage. The next
stage is when there is a bare acceptance that there
might be a need to have lawyers on behalf of claimants,
there's then a wrangle about how much they should be
paid and about the hours they should spend on such
matters. So the next stage is then fighting about how
much it is that someone can have.
On the other side, what happens is that the
Government, represented by lawyers, and indeed the Post
Office, represented by many different firms of lawyers,
is able to fund the payment for their hourly rates as
they go forward.
So you can see there is an initial inequality that
I'm afraid relates to the claimants’ side; do you agree
with that?
Yeah, I do, yeah.
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ability to cope; people's lives are blighted by lack of
sleep, mental health problems, and the like, by the fact
that they are forced into poverty, by the fact they are
forced into trying to cater for the day to day.
Now, you're someone with a long track record of
supporting small businesses and you know that small
businesses depend upon everybody working together to run
that business within a family. Yes?
That's right.
So again, the difficulty for those people left in these
dreadful situations is that they do need support from
lawyers that are prepared to engage at early stages with
either Government or what's happened within a scandal in
order to provide access way to compensation, yes?
Quite right, yes.
Let's go one step further. The route through which
compensation is often argued tends to go this way before
inquiries: what happens is, first of all, there is
a need to try and see if the Inquiry will seize upon the
question of compensation. All of that work is often
done pro bono by lawyers, such as Howe+Co, myself and
others, to try to, in fact, get the Government ~ if the
Government is at the root of the scandal or at least
part of it, as it is here ~ to engage even on the very
basis of compensation.
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Now, you say in your statement this: your appointment —
this is paragraph 8, sir - was:
manna from Heaven to me because it meant
I could actually help to fix something important.”
You go on to say this:
“There wasn't a day, night or weekend that went by
when I wasn't doing something on the Post Office redress
schemes and transformation.”
So you understand how much hard work is involved in
trying to get things moving in relation to these matters
and you understand that that type of work, that day and
night work on behalf of people trying to get things done
and fixed is very difficult when, essentially, it is not
funded at all; do you accept that?
Totally.
Now, you've mentioned the question of working with
schemes that don't perhaps, on the Government's side,
necessarily have the full engagement of an entire legal
team, legions of lawyers working on their behalf. Could
you consider this: in scandals such as the Post Office,
whereby the Government is part of the problem, the
Government owning the Post Office, the single
shareholder, unless the Government approaches the
question of compensation with a spirit of generosity,
there is always going to be a need to have lawyers on
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both sides, probably, fighting it out —
Yes.
-- because, without a genuine spirit of generosity in
relation to the prospect of payment to those claimants,
then essentially there will always be a fight and the
claimants will have to be represented?
Yes.
Now, Sir Wyn is left with the task -- which I know he
welcomes and looks forward to ~- which is the drafting
of his report. The drafting of this report will take
place once all the lawyers stop talking, sometime
through this year and into next year.
Now, one of the matters that he has to wrestle with
are questions of recommendations. We've had by now two
other reports that touch upon how do recommendations get
implemented. The Grenfell reports and the Blood Inquiry
report have both recommended that a committee of
Parliament, probably a select committee, continues to
oversee recommendations made by inquiries. I'm not
asking you your opinion about that, what I am asking is
this: do you accept that there is a need for a body,
probably such a select committee, to look at the
question of how compensation is dealt with, where
scandals such as this take place, to learn lessons from
what has happened in the past, from past inquiries, to
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in the middle who is not incentivised for this process
to take longer because you and I would probably
recognise that, if you work for a large legal company,
you've got an amount of hours to bill on a monthly
basis, maybe some of those processes take longer than
they might.
So if somebody in the middle can say, "No, I'm not
worried about this small element of this claim or that
particular legal point you're raising, I'm taking a view
on this", exactly in the way you phrase it, so that it
is generous and seen to be generous to the claimants,
who are involved in the scheme; I don't think you can do
this just by lawyers arguing on either side. That's my
point.
Yes. What I'm terming the "spirit of generosity" really
must come about because it is in situations, such as the
Post Office scandal, whereby, at the heart of it, there
is a recognition that harm has been caused. That's the
starting point for this Inquiry. So when we're talking
about the spirit of generosity, itis in fact the
balance, it's the repair or an attempt to repair the
harm that has been caused by one actor, in this case the
Government and its single shareholder status in relation
to the Post Office.
So it's about acceptance of "This is what we've
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consider how better the frameworks for compensation can
be set up and managed in the future?
A. Yes, I totally agree with that and we tried to kind of
replicate that in a ~ perhaps a less formal way with
the Horizon Compensation Advisory Board. I wasn't
criticising the lawyers, the actual lawyers on either
side of the process, actually, and we never would have
been here if it hadn't been for lawyers, this would
never would have come to light.
And I fully understand that this is all done, as you
say, on a pro bono basis and, as I say in my statement,
this came to light because of Paul Marshall, and it was
supported by Flora and lots of other people who did
a fantastic job on a pro bono basis to bring this to
light. So, in many ways, you're the heroes of the hour,
in terms of making sure this came to light. I'm not
trying to be nice to you because you're asking me
difficult questions.
But my point is not really that you shouldn't have.
lawyers on either side; in fact, you should have
somebody in the middle. That's really my point. And
I think this is what the National Audit Office have
said. I don't think a select committee can ever play
that role. It might do some oversight or an advisory
board can do some oversight but it needs somebody right
102
done, we're sorry about it being done. We're not only
sorry but we're actually going to pay up and we're going
make sure we pay up as open handed as possible, bearing
in mind public finances"
That essentially is what should be embraced; do you
agree?
A. That's exactly what should happen.
MR STEIN: Thank you, Mr Hollinrake
THE WITNESS: Thank you.
SIR WYN WILLIAMS: Ms Watt.
Questioned by MS WATT
MS WATT: Thank you, sir. Good afternoon Mr Hollinrake, I'm
over here.
A. Good afternoon, hello
Q. We have this difficulty every time I ask a question.
I'm going to ask a question on behalf of the NFSP
and I'm going to call up a document and I'l give the
number for that but you might recall that on 8 January
this year, just after the ITV drama Mr Bates vs The Post
Office, the NFSP Chief Executive Calum Greenhow wrote to
you and that letter is WITNO0370106. I'd just like to
call that up.
if we scroll to page 2, it's about halfway down the
page, the paragraph that begins:
"Postmasters are justly and rightly highlighting
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their concems over the robustness of Horizon today,
with the NFSP repeatedly calling for the system to be
externally audited to ensure that nearly five years
after Justice Fraser's Horizon Issues ruling that the
system is robust. Everyone, whether postmaster,
assistant, or Crown Office employee of the Post Office,
still use Horizon today and collectively we have to have
confidence that the system works as it should and does
not have bugs, defects or errors that secretly affect
branch office accounts. Government as the solicitor
shareholder should be ensuring on behalf of the general
public that this is the case."
We can take that document down.
The Inquiry has also heard -- I'm not calling this
up but I think you've referred to it, in any event —
about the results of the YouGov survey for the Inquiry.
That's EXPGO0000007.
That indicated that 49 per cent of respondents using
Horizon at present were at net dissatisfied with Horizon
compared to 25 per cent who were net satisfied. In
addition, 57 per cent of respondents had experienced
unexplained discrepancies within the last 12 months.
In addition to that, the Inquiry has heard evidence
about the delays to the New Branch IT System, NBIT.
It's years behind now and millions over budget, and it's
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And it's my understanding that Post Office take
a completely different approach to this, instead of
an adversarial approach to some money missing, it's
inquisitorial approach which is "Okay, you know, let's
certainly give the postmaster the benefit of the doubt",
which you would expect to happen in this kind of
network. So I understand that to be the case.
It wasn't the case that anybody came to me in my
tenure as Post Office Minister to say, "This person has
been taken to court” ~ in fact the Post Office no
longer take forward private prosecutions ~- "but he's
been taken to court on the basis of evidence from
Horizon or something that is" - so I never heard those
concerns, either from the NFSP or from others in terms
of this was a live problem ongoing about these issues
about discrepancies being then taken forward in terms of
something along the lines of what happened with Horizon
previously.
Although that point is being put in that letter, you
would accept?
Yeah, and I have no problem at all in an audit of the
system and, clearly, I'm not the decision-making
minister now, but that would seem sensible to me because
the first time I'd seen the YouGov survey, in terms of
the pack that I read over the last few days, but on that
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possible, it sounds like, that the Post Office may have
to look even beyond NBIT. But, certainly, it's unlikely
that Post Office is going to move away from Horizon any
time soon.
So what I wanted to ask you was: would you agree
that an external audit of the Horizon system is
necessary, in other words something that's completely
independent, to report back to everyone with
an interest, involving and including postmasters?
A. That sounds very sensible to me.
Q. To your knowledge and following on from that letter of
8 January this year, and appreciating that your
knowledge may extend only to 4 July this year, in light
of this letter, has there been any proposal that you
know of within Post Office for the current system to be
externally audited?
A. I don't think that’s something that we ever directly
discussed, although we did discuss some of the concerns
about ongoing discrepancies. Postmasters are dealing
with cash every day. There will be discrepancies, or
there are bound to be some discrepancies. I think the
problems with Horizon were not just IT problems. They
were also the approach of the Post Office in terms of
their willingness to prosecute and their willingness to
think the worst of postmasters.
106
basis of lack of trust amongst the network for that
system, I think that would seem eminently sensible
Q. Okay just to tie that off: can I take it from what
you've said, in your time, up to when you concluded your
role, that the Government, as the sole shareholder,
hadn't asked the Post Office to conduct such an audit?
A. don't remember us doing that, no. But we did ask
questions about the approach that Post Office is now
taking where there were discrepancies.
MS WATT: Thank you.
SIR WYN WILLIAMS: Can I detain you for five minutes?
I think that's it, Mr Hollinrake.
A. Yes, certainly
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: It may be that I will need to form
a judgment about the pros and cons of the fixed offers
that operate, all right? I'm not sure if I will need to
do that but, just in case I do, since you were obviously
very influential in their introduction, I'd like to get
your view as to what are the pros and cons.
A. Yeah, of course.
SIR WYN WILLIAMS: All right? I think I can identify as two
pros, speeding up the payment of compensation ~ yes —
A. Yeah.
SIR WYN WILLIAMS: — and, in all probability, significant
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savings in legal and expert costs. Yes?
A. Yes, that's true.
SIR WYN WILLIAMS: Can you identify other pros for me,
before we get to the cons?
A. Well, like I said earlier, some people who would have
got less than the fixed-sum award will now get —
SIR WYN WILLIAMS: Well, that might be thought to be a con.
So let's come back to that in a moment.
A. No, well - okay.
SIR WYN WILLIAMS: Can we try and do it in that way? So
we've got speed of payment and, as I say, I can imagine
that, if you got an actuary or an accountant on it, they
might be able to justify value for money in terms of
saving and legal costs, and all the rest of it So
those are what I see, at least, as the two major
benefits of the scheme.
A. Okay.
SIR WYN WILLIAMS: Okay?
The cons actually relate to the recipient because
it's not a con for Wyn Williams if my true claim is
worth £5,000 but I get £75,000. It's a windfall, yes?
A. Yes.
SIR WYN WILLIAMS: But it's a con also, isn't it, for the
public at large if that happens.
A. I mean, the public at large pay more, you mean, in terms
109
make an offer in a case of £500,000, then, except in
those very rare cases where you withdraw it completely,
it's always available to be taken. Right?
In this scheme, if you don't accept the 75,000 or
the 600,000 at a particular moment in time, that sum is
lost forever and you're on risk of getting less. Is
that fair to describe as a downside?
A. Well, that would depend on the rules of the scheme. I'm
not saying --
SIR WYN WILLIAMS: Sure. So that's my last question to you.
‘A. No, I don't say for a minute that, if somebody decides
to go down a full assessment route and then is only
offered, let's say, £60,000 rather than £75,000, would
you give them the 75 anyway? I think you can argue that
case.
SIR WYN WILLIAMS: Well, I think I was being a bit more
generous to the Post Office or the Government. I'm
simply going to suggest that why is it you've got to
make a once-and-for-all choice at a moment in time, as
opposed to being able to say, "Well, look I've now gone
down the full route but I realise that I'm on risk and
so I want to draw back and take the 75,000"; what's
wrong with that?
A. No, I don't think potentially there is anything wrong
with that and that could be a feature of a future
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of the taxpayer, yes.
SIR WYN WILLIAMS: And there's a point about the faimess as
between claimants.
A. Oh, you could definitely argue that, that some people
would feel, you know, that person is getting more than
they should or the same as me, that person is only due
£5,000 and I've got £75,000, and I was due that and
they've got the same as me. You could argue that.
SIR WYN WILLIAMS: Sure. Then the other part of that
thinking process is that people who are, shall we say,
claiming £85,000 or £90,000, might well feel pressured
into taking £75,000 because they know that, if they
don't accept the £75,000 at a point in time, it's lost
forever, as the current scheme currently operates.
A. You could argue that.
SIR WYN WILLIAMS: Well, I think I would argue it, if I was
a lawyer.
A. Well, 'd argue differently. 1 would say there was, of
course, a case for that, so people might decide to take
a view. And can I say, nobody is saying those people
shouldn't that have legal advice or other advice before
they decide to take that.
SIR WYN WILLIAMS: I appreciate that but the point I'm going
to come to is this: that in normal litigation, okay —
set aside costs consequences ~ if you, the Government,
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scheme, and we had that discussion ourselves internally.
I was going to say it was never the case -- I don't care
how much this compensation scheme costs, of course we've
got to have an eye on public money, but what is fair is
fair. So if it costs -- it's now - the envelope,
I think, is 1.8 billion. I don't care if it costs 2 or
3 billion, I said this to James Arbuthnot and the
officials. It was never a case of trying to save money;
it was always a case of trying to expedite and
accelerate the amount of compensation that goes to
individuals. We would never try to shortchange anybody,
and the scheme should never do that.
SIR WYN WILLIAMS: Well, armed with your views, I'll ask
Mr Creswell and your successor minister in due course
what they think of that
All right. Jolly good, thank you
A. Thank you
SIR WYN WILLIAMS: Thanks very much, Mr Hollinrake, for your
assistance to this Inquiry.
THE WITNESS: My pleasure, thank you.
MRBEER: Thank you, sir. Can we break until 12 ~ 1.30,
please?
SIR WYN WILLIAMS: I've heard of truncated lunch times, but
even by your standards, Mr Beer, that was pushing it
abit! Yes.
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MR BEER: 1.30, yes.
(12.30 pm)
(The Short Adjournment)
(1.30 pm)
SIR WYN WILLIAMS: Mr Blake.
MR BLAKE: Thank you, sir. This afternoon we're going to
hear from Mr Creswell
CARL PHILIP CRESWELL (affirmed)
Questioned by MR BLAKE
MR BLAKE: Thank you very much. Can you give your full,
name please?
A. Carl Philip Creswell.
Q._ Mr Creswell you should have in front of you a bundle
containing two witness statements that you have
produced. Can I ask you to turn to the first witness
statement. That should be dated 2 October 2024; is that
correct?
A. itis.
Q. Can I please ask you to turn to the final substantive
page, that's page 71. Can you confirm that is your
signature?
A. Itis indeed.
Q._ Can you confirm that that statement is true to the best
of your knowledge and belief?
A. Ian confirm that.
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Q._ You are currently the Director of Post Office Policy and
Business Engagement, and you've been in that role since
April 2019?
A. That's right.
Q. Thank you very much. Mr Creswell, I'm going to start by
asking you just some general background about your
Department and your role within it?
In your statement, you touch upon changes that took
place just before you arrived, I think in 2018, to the
Department's role vis 4 vis the UKGI. Can you assist us
with that briefly?
A. Ofcourse. So you're right, in 2018 there was a step to
move some more Parliament-facing functions out of UKGI
into the core department. So that started with dealing
with correspondence and Parliamentary questions, and
that sort of Parliament-facing activity. In about March
2019, I was asked by Alex Chisholm, who was then the
Permanent Secretary, to move into a newly created
director role within the core department, and the
intention of that was to create a strong Policy Team to
sit alongside the UKGI team that was being run by Tom
Cooper.
And that was a broader function than just dealing
with Parliamentary Questions and so on; it was much more
about what are the Government's policy responsibilities
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Thank you very much. That has a unique reference number
of WITN11730100 and will be published on the Inquiry's
website.
You then also produced a second witness statement.
You should have that in front of you, dated 22 October
2024.
Ido.
Can I ask you, please, to turn to the final page of that
statement, that's page 20. Can you confirm that that is
your signature?
Itis.
Can you confirm that that statement is true to the best
of your knowledge and belief?
Itis.
Thank you very much. That witness statement has
a unique reference number of WITN11730200 and will
likewise be published on the Inquiry's website.
By way of background, you are a civil servant and
have been since 1998; is that correct?
Correct.
You have a background in a variety of roles, including
Director of Better Regulation, and you were also
involved in, for example, the establishment of the.
Competition and Markets Authority?
Correct.
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vis & vis the Post Office, and also issues of funding,
and so on.
And UKG''s role narrowed at that point to be more
focused on the commercials around the business and
appointments issues and remuneration, and so on.
I think you've said in your witness statement it's
effectively setting apart the policy direction from the
corporate governance and financial advice roles?
That's correct, and there were various motivations for
why that happened, which I could expand on if you're
interested?
If you could briefly, yes.
Okay. So at the point at which I joined -- and I talked
to both Alex Chisholm and then Kelly Tolhurst ~ it was
on the back of Mr Justice Fraser -- and now allow Lord
Justice Fraser -- judgments, there were quite serious
concems at ministerial and Perm Sec level about whether
we were providing adequate support to ministers on Post
Office related issues. I think there was a bit of
a loss of faith from Kelly Tolhurst in the support she
was getting from UKGI, so my role was to carve out space
for a new team, and I was given licence to bring in more
capacity, in order for me to create that stronger team
that would act as a bit of a counterpoint and balance
with UKGI.
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Is it easy to separate out those two distinct roles?
Ihave found it to be so but, over that first year,
towards December '19 we had to do some work through
setting out, ultimately in a framework document, the
relative responsibilities of the different parties, so
the Department, then BEIS, and the Post Office and UKGI.
There is an interaction between some of our
responsibilities but I think the delineation is fairly
clear. So I know you will be hearing from Lorna
Gratton. She and I worked very closely together but we
don't overlap in our areas of responsibility: she is
clear that I am the one who is responsible for
supporting business cases that go to Treasury about the
money that the company needs; I am clear that she
supports the recruitment of chairs and CEOs and others
to the company.
In terms of briefing a minister, do you take sole
responsibility for that or do you both brief ministers?
It depends upon the occasion and the topic. So I do see
Gareth Thomas, my current Minister, more frequently than
Lorna, but Lorna does also come and join meetings on
occasion with the minister, dependent on the topic.
Later this week, the Secretary of State, Sir Jonathan
Reynolds is seeing Nigel Railton for a catch-up
conversation, and we will have both someone from the
17
didn't work, I would have a much less strong grip about
the issues that were bothering the Post Office Board,
for example.
So I say that by way of an example about what
I think works well. I suppose, in theory, if the
relationship between the two teams or myself and Lorna
didn't operate effectively, then that would be
a challenge but I think that would probably be inherent
in any structure, since I don't think it would be
sensible for me to sit on the Post Office Board. That
is Lorna's role as the shareholder representative.
Thank you. In terms of the time that you spend on Post
Office matters, you've said in your witness statement
that you spend, I think, 80 per cent of your time on
those matters and you have a few other matters outside
of that role?
That is correct as of now. In the past, though, over
that five-year period I had a much wider set of
responsibilities, including during the Covid period of,
you know, 2020 to 2021, working with the retail,
hospitality and wedding sectors, and other
responsibilities that I had. But over a period of time,
particularly as our role in redress has grown, with DBT
running two of the compensation schemes, I've narrowed
my brief to focus primarily on the Post Office, and in
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Policy Team and someone from the UKGI team there because
there are interests on both sides of our fence that need
to be represented.
Over time, in my tenure over those five years,
Ihave taken on a much bigger role in relation to
redress, than I had in the early parts of my tenure,
where UKGI did a lot of the work on, for example, the
Horizon Shortfall Scheme, and so my conversations with
the minister about redress don't tend to now have Lorna
or UKGI present in the room.
Thank you.
We'll go into details in due course today about
various schemes and various developments but, just
looking at that separation broadly and looking at the
evidence that you've heard throughout this Inquiry, do
you think that current division is right; do you think
it should change in some way?
I think it works well actually, thank you. I think we
have got a good relationship and clear delineation of
responsibilities and, obviously, I am not running the
Post Office and I am not attending the Post Office Board
and I'm, therefore, quite dependent upon UKGI's expert
analysis on commercial issues, but also on the flow of
information from the Post Office through Lorna and her
team to me and to my team because, if that relationship
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the coming months, actually, I expect to lose my
business engagement responsibility and focus inclusively
on Post Office issues.
You have explained that you have 70 staff within your
team. Is that because you're particularly busy dealing
with redress matters and will that stay the case or
will, in due course, that team wind down to some extent?
So if you take a sort of very long-term view, I would
expect that team to reduce in size quite significantly,
yes. But there is a lot of work stil to do on redress,
as no doubt we will go on to discuss.
And when I joined in April 2019, I had two members
of staff, so we're actually above 70 staff now, as
a result of recent recruitments but since, probably, the
end of last year, I've doubled the size of my team to
respond to the need to legislate to overturn 900
convictions, to work with people affected by the Capture
system, to set up and then run the Horizon Convictions
Redress scheme as well as then the GLO scheme.
Thank you. I'm going to take you through the early
months of your time at the Department and focus on the
Group Litigation. Can we bring up on screen
UKGI00009785, please. This is an email chain from May
2019, so your first month, really, in the role. If we
scroll over the page, please. If we could scroll down
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slightly. A note here is being drafted for the
Minister, that’s Kelly Tolhurst at that stage. You are
sent an email by Tom Aldred, who is part of the UKGI
team?
That's right.
We see here I think it's a combination of his draft and
also your changes to the draft in a slightly lighter
text.
Yes.
I'ljust read to you a few passages from there. He
says as follows:
“As discussed, Tom has shared a draft note to go to
Kelly, which I've pasted below. What do you think?
Jess has confirmed that she is happy to pass to Kelly as
an email rather than a [submission].”
The draft is as follows:
“I gather you mentioned a couple of things to the
team after the meeting with [the Post Office] yesterday.
One being what happened at the Board in relation to the
legal advice. The other that you're concerned about the
company's approach to forecasting the potential size of
liability.”
Under the heading of "Litigation", it says:
“On the legal front, I think we've reached
a sensible position with [the Post Office] changing its
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Cameron and Tim Parker had been much more optimistic
about the likely outcome for the trial and I think she
felt — she was a relatively new minister and I think
she felt on her watch something awful had happened and
she hadn't known that it was coming.
She felt that the company was failing to give her
information that she needed to fulfil her
responsibilities as the minister. She was also very
angry with Tom Cooper, which is part of the backdrop to
this email and my advice back to him. And so she had
lost confidence, I think, in the whole arrangement and
set-up.
So, within that, I think you're right, she was
unhappy about the approach being taken by the Post
Office and the sort of "We are being sued”, rather than
“justice for postmasters" approach that you could see
evidenced, and I could see that myself from talking to
the Post Office in my early days talking to people like
Mr Cameron. And I think that left her feeling a bit
vulnerable but also trying to but also trying to work
out what happened next.
If we seroll up, please, we can see your response. You
say, at the bottom of page 1 into page 2:
“Thanks for sharing this with us. I've set out my
thoughts below, in the spirit of tying to help you land
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legal advisers and seeking a more conciliatory approach.
Like you, I have been concemed about their approach.
I wasn't happy with the meeting the company that with
you and Alex last October. That was followed up by
a very critical ruling from the judge a few months later
following which I spoke to Tim and Paula to say that
felt there needed to be a major change of approach.
Our interaction to the Legal Team at [the Post Office]
wasn't limited to the litigation -- in general we found
[their] chief counsel wasn't easy to deal with and I had
passed feedback to the management and Tim on various
occasions.
"Things [had come] to a head after the Common Issues
Judgment when it became totally clear ~ I think to
everyone on the Board — that there needed to be
a change to personnel. This led to Jane MacLeod —
Chief Counsel -- leaving the company.”
In terms of the atmospherics when you first joined
the team, what was the feeling towards the Post Office's
approach to the litigation?
So Kelly Tolhurst was very frustrated on a number of
fronts, to be honest, when I first met her. She was
very frustrated about what had happened. I think she
felt embarrassed, as I think she probably said in her
‘own evidence, about the outcome because I think Al
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your messages well!
“The tone feels a bit defensive to me, so I've
suggested some changes below. Kelly seemed to partly be
sparking because she thought that she was hearing
something different yesterday (decision by consensus)
‘compared with what she heard during the recent phone
call (coup).
Can you assist us with what is meant there?
Of course, yes, I also worked with Kelly on other areas
of responsibility, such as on the retail sector, so by
this point I'd already established what I thought was
quite a good relationship with her. Tom Cooper was
holding the role that Lorna Gratton is now holding
obviously in UKGI --
Sorry, please if I can pause you there. If itis
possible to speak slightly slower, that would be very
helpful?
Of course.
So what was happening here was I was trying to help
Tom navigate through a tense situation with Kelly
Tolhurst, where I'd been discussing with her for
a period of time, and so too had the Permanent
Secretary, what changes were needed to respond to the
Minister's concer about the Post Office. And this
whole email chain occurred in a situation where Tom
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Aldred, who worked for Tom Cooper, and I had met Kelly,
and Kelly had aired various concerns.
Tom Cooper then returned, I think, from leave or
absence of some kind and wanted to go to Kelly, and have
a conversation with her, because he had heard secondhand
that Kelly was a bit frustrated. My judgment was that
what the Minister wanted was for us to move beyond some
of the previous conversations that we had dealt with
without Tom Cooper there, and that it would actual
undermine our ability to get more confidence back in to
Tom Cooper if Tom wrote this sort of email that picked
up things that actually Kelly had reached a conclusion
on, and that it was better to sort of leave some of
those issues as they were and then move forward.
Would you like me to say a little bit more about the
"coup" question?
Yes.
So I think this was a question of slightly different
language between the two of them. Tom Cooper had said
in a previous meeting to Kelly, "Look, it's great the
Post Office has decided to change its Legal Team
following on from the judgment", and in order to I think
make it clear that he had played a significant role in
that, at the Post Office Board, remembering that this
was at a time when Kelly felt that the Government
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et cetera.
What was the feeling towards the leadership of the
company at that stage?
Well, I think Kelly was quite frustrated with both Tim
Parker and Alisdair Cameron. I think she found their
approach quite patronising and quite bullish, and
I think she felt - and I must admit I had some sympathy
for this — that they were slightly in denial about the
magnitude of the judgment, and they still hoped at this
point -- remembering it was May 2019 -- that the Post
Office would be successful - I can’t remember whether
the recusal attempt had been rejected by that point or
not, it had started before I joined but concluded
shortly thereafter. But the appeal requests were still
in play and I think she felt that the leadership was
still somewhat in denial. Yeah.
Thank you. If we turn, please, to page 1, and the final
email in that chain that I'll read to you.
It's the response from Tom Aldred and he says:
“For my own part, although she didn't say explicitly
that she had concems with the leadership, I thought it
came across pretty strongly in her remarks and in her
questions about how we appoint the Board, and her desire
to attend. While I'm tempted to hope it blows over, on
balance I'm more attracted to addressing it head on. If
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representative had not been sufficiently pressing the
Post Office for a number of months, he described it as
a coup, by which I think he meant this was a victory for
‘common sense in terms of getting the Post Office to
shift its approach.
She took that, I think, to be a sign that things
were still not right in the Post Office Board and that
there was a problem, and I think there was still
a slight disagreement of language of talking across each
other, which was slightly typical of their relationship
at that point.
I think you address that here. You say:
“1 explained that you had meant “coup” in the sense
of a victory for common sense, but she still seemed
concemed. So my advice would be to emphasise that we
have got to a better place, give the details of what
happened and explain that you're going to be keeping
a close eye on them going forward.
\ also think it would be best to leave out the
reference to the leadership of the company. Strictly
speaking she didn't raise it with us in those terms last
night -- what she said was that she remains nervous
about the Post Office approach. I also think Kelly is
unlikely to want to discuss it at this stage. I feel
that we have made some good progress this week",
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she really doesn't have confidence in the leadership
this has the ability to make everything else a lot more
difficult and we need to understand what's driving her
concern.”
So did the Minister at that stage have concerns
about the leadership of the Post Office?
‘She did have some concerns and she did suggest that she
would like to join the Post Office Board and actually
sit on the Board, which is slightly unusual in corporate
governance terms. I felt that Tom Cooper approaching
her and saying "Let's have a conversation about the
leadership", given that she had quite a level of concern
about the support that she got from him, I felt wouldn't
be that helpful because I felt that Tom would probably
go in and say how great, you know -- that the least were
fine and that we didn't need to change the leadership.
So my judgement was the best thing to do to support
the Minister at this point was to try to dissuade Tom
from going in heavily on this issue, given that
I actually felt that she had become more comfortable
over the period up to May 2019, with where we had got to
but still wanted us to do further work on things like
information sharing from the Post Office.
We'll get onto couple of emails that say exactly that.
If we could turn to UKGI00009832. We see on page 2,
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over to page 3, an update from Ben Foat, General Counsel
at the Post Office, providing an update regarding the
permission to appeal decision of the Common Issues
Judgment, and also in relation to costs.
If we can see over the page, thank you very much, it
says:
"We were in court today before the Managing Judge
... t0 seek permission to appeal the Common Issues
Judgment and determine how the costs of the Common
Issues trial should be treated.”
If we scroll downs on "Permission to Appeal”, he
says:
“As expected, the judge didn't agree there was
a real possibility of Post Office successfully appealing
his Common Issues Judgment and did not give us
permission to appeal ..."
If we scroll down, he addresses costs. He says:
“The judge exercised his discretion and awarded the
claimant their costs of the Common Issues trial, rather
than reserving the question until later in the
litigation when the full impacts of the Judgment would
be determined."
If we scroll up, please, to the bottom of page 1, we
see an email from you to Tom Cooper. You say:
"Thanks very much for sharing this all so promptly.
129
a classic thing you would do when you have been found
guilty. So we were all of that view and, to be fair,
I think Tom Cooper was in that space, as well, I think
the company was probably still hoping that it would, you
know, that people would see right and that the judgment
would be overturned in some ways. Ha! And my reading
of the judgment was ~- and I wasn't - and I'm not,
a legal expert but that the costs order was
an indication that the Post Office was very unlikely to
be successful in that course of action in trying to get
the judgment appealed.
So for me this was a flashing warning light on the
dashboard saying, you know, there's no way that their
optimism is going to work out.
You say there!
“Even though the new lawyers seemed to be saying
that [the Post Office] has a case, it feels to me like
this is going to run and run (and perhaps not end well,
given what the judge has already said)."
If we scroll up we can see the response from
Mr Cooper. He says:
“The judgment itself isn't a surprise. If the Court
of Appeal tums it down that would count as a real
setback ~ probably the biggest so far by some margin.”
Were there real concerns at this stage about how the
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"I suspect that this latest development will
strengthen Ministers’ concerns about {the Post Office's}
approach to the litigation, so I'm trying to get around
the scale of the implications.
"My reading of it is that the decision not to let
them appeal and require going to the Court of Appeal is
completely straightforward and anything different would
have been a surprise ... But the costs order is the
worrying bit because it will increase the liability for
[the Post Office] beyond any damages. Presumably that's
only for this first case but it might set a worrying
precedent for the future."
You say:
"Do you think there's an argument that it should
change our assessment of whether it's desirable for [the
Post Office] to consider settling at this stage?"
Just pausing there, what was the position within
your Department about settling at that stage, and what
was your own personal opinion?
Yes, so within the Department, Alex Chisholm and I were
both clear that a settlement would be needed, and that
was the right course of action. My own personal
experience of working in another department, the
Department for Education, was that a settlement, when
there was a legal dispute against a public body, is
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litigation was being run or continued to be run?
There were a lot of concerns about how it had been run
up until this point. I think prior to my arrival in
post, Sir Alex Chisholm had taken some advice or he'd
read ~ he'd read some of the advice about the strategy
that was being taken by the company in seeking to
appeal. I think there was a concern about the recusal,
you know, attempt but that was, again, prior to my time.
I think people were -- were dubious that the appeal
would succeed, but felt that it was a judgement for the
Post Office Board about whether to request that appeal.
My view was, "Look, this looks like you're going to
lose and you might as well accept that sooner rather
than later and then get on to settling", because part of
my responsibility is to support the current company with
all the current postmasters, as well as dealing with the
historical liabilities and, to my mind, you needed to
get quickly through that sort of settlement in order to
help the company move forward
I think Tom Cooper also would think that settlement
would be a good idea but it was his team in UKGI that
had been providing advice about the litigation, prior to
my arrival, and even sort of from now onwards a lot of
the submissions were written by UKGI but with input from
me.
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Q. Moving on shortly in time, can we please turn to
BEIS0000830. We're now on 4 June 2019. There's
a read-out from the industry meeting from the Post
Office, if we turn to page 3 please. Under the heading
“Litigation, it says’
[Secretary of State] (backed up by Kelly) {the
Minister] has serious concerns about the direction of
travel of the litigation and [the Post Office's}
handling of it. Referenced the first judgment and
particularly the recusal application as evidence of poor
judgement of the Board.”
Were the concems as broad as the Board itself,
rather than those two individuals who you have already
mentioned?
A. I wasn't present in this meeting, so I didn't actually
hear that conversation. But from -- and I didn't
actually meet the Secretary of State at that point to
discuss it - Greg Clark -- but I was talking to Kelly
and I think she was concerned about the Board more
widely, and I think that's why she wanted herself to
join the Board.
Q._ It continues:
“The Secretary of State gave a clearly steer that he
wanted the Department to be on the side of the
postmasters (he said it felt like there were shades of
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Q. Thank you. So where we see the internal attendees,
that's in addition to the Minister?
A. Correct, so where it says, for example, in the section
below "In response to your letter of 29 May’, it wasn't
my letter; it was Kelly Tolhurst's.
Q. Thank you. If we tum over, please, to page 2, it sets
out the Post Office's approach to ongoing litigation and
it suggested, as follows:
"Please express your dissatisfaction with the
current status of the litigation and invite the Post
Office to present details of their strategy."
The second bullet point:
"Please provide the below steers to the Post Office,
reflecting the options agreed by the [Secretary of
State]. [The Department's] preference is for {the Post
Office] to pursue early settlement of the case.
“[The Post Office] should carry out a project on how
to structure and operate a settlement including a fund
which would subsequently assess claims and award
compensation according to pre-agreed criteria.”
A. Mm.
Q. Is this where we see the beginnings of what became the
redress schemes or is this simply focused on the
settlement of the litigation vis @ vis the litigants?
A. So it was a major step towards the settlement in
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Windrush regarding the potential for a number of
injustices to come out) and wants a strategy on how we
can take this forward. He wants to resolve that is
quickly given the damage it's doing to the reputation of
the Post Office.
"Kelly reiterated her concerns about the
effectiveness of the Board, and about the information
shared with her. She pointed to the fact that [Post
Office] hadn't done any detailed work on the potential
liabilities from the case as a concern.”
If we scroll down we can see "Action the Secretary
of State has asked for’:
"He has asked for a BEIS strategy to ensure the
litigation is settled quickly and put [the Department]
on the side of the postmasters; resolve the CEO pay
issue so we can recruit the best candidate; and consider
how we deal with the ongoing management of [the Post
Office], given the concerns ministers have on Board
performance."
Can we please turn to UKGI00010212, please. There
is there a meeting with Tim Parker and Alisdair Cameron
on 24 June 2019. That's a meeting with you; is that
right?
I was present at the meeting but it was actually for
Kelly Tolhurst to meet those individuals.
134
December '19 with the GLO group. Within this comment is
the hint at the sort of redress schemes that we have now
set up and I must admit I had forgotten, until I saw
this paper, that that idea had been floated at the time.
I think the Post Office's lawyers had been looking at
various options. My memory is that the idea of a fund
that would award out compensation was rejected,
following conversations with the claimants in the GLO
group, on the grounds that, actually, what was needed
was early settlement and money to go to the GLO
claimants quickly, to be distributed by Freeths or
whoever through a formula, rather than the start of
a claim-based system, which is more like we have now.
There's a missing piece of the jigsaw between the
document you've just shown me and the previous one,
which was the actual BEIS advice, which was requested by
the Secretary of State that responded to some of Kelly
Tolhurst's and the Secretary of State's concerns,
including a long list of options, the most radical of
which would have been to have replaced the leadership.
But the Secretary of State decided not to do that.
Thank you. So one option up in the air at that stage
was to replace the leadership. This is a rung or two
down from that, is it?
In timing terms, yes, that's correct. I think I heard
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Kelly Tolhurst talk about this when she gave evidence
here before as well. I think the view was taken with
the Secretary of State that a new CEO was needed, both
a permanent and a new CEO, ie probably not Al Cameron,
and that, in that context ~ and that obviously led to
the appointment of Nick Read later that year —
replacing the Chair at that point probably wouldn't be
a good idea because you would create more instability at
a critical time when the company needed to move on
Thank you. If we could turn to BEIS0001130. There's
another meeting with Tim Parker in October, 31 October
2019. You attended that meeting, you're listed there as
an attendee; is that correct?
I'm definitely listed there and I'm sure I did attend,
yes. Yes, this was for Alex Chisholm —
Thank you,
with Tim and Tom and me.
If we scroll down, there are issues listed there:
“Litigation: judgment in the Horizon trial is
expected in early November, following the discovery that
[the Post Office] had failed to disclose information
(Known Error Logs) that may provide a fuller account of
bugs in the Horizon system. Whilst this appears to be
Fujitsu's responsibility Justice Fraser is likely to be
highly critical of [the Post Office]. A decision on
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UKGI00047866. We're now in April 2020, so we're now
a year into your role in the Department. I'd like to
start on page 3, please, it's an email from Minister
Scully's private email to you and others:
"Please find attached a letter from Tim Parker to
the Minister regarding the Post Office's financial
exposure resulting from the number of cases potentially
being referred from the CCRC to the appeal courts.”
If we scroll up, we can see a response from you to
the Permanent Secretary and others. You say:
"You should see the attached letter, which provides
more detail on the additional past prosecutions the Post
Office has identified. The letter includes an eye
watering maximum liability that they [may] be exposed
to.
“Minister Scully is meeting [the Post Office's]
leadership for the quarterly shareholder meeting
tomorrow afternoon and we are briefing him to express
disappointment and put pressure on [the Post Office] to
ask for more information ahead of our putting advice to
ministers.”
Is the picture getting somewhat worse by this stage?
Yes, and I think Sarah Munby touched on some of this in
her evidence yesterday. I think we knew after the Lord
Justice Fraser judgment that the Post Office had acted
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{the Post Office's] application to appeal the Common
Issues trial is expected on 12 November.”
If we go over the page, please, there are issues to
be raised with Tim Parker. The first of those is
culture:
"POL's culture needs to change and as the
shareholder we expect the Chair and Board to be leading
this.
“The leadership's decision on the litigation (such
as the failed, expensive recusal attempt) and the
proposal to pay bonuses in full appeared tone deaf and
complacent.”
By this stage, it seems very strong criticisms of
the way that the Post Office is being run; is that fair?
Yes, the bonuses incident over the summer, which, you
know, again sits between some of the earlier documents
and this one, caused great frustration for Alex Chisholm
and others in the Department because it was a classic
‘example of the company failing to acknowledge that they
had harmed so many postmasters through, you know, the
horrific scandal, and were stil trying to pay
themselves large bonuses. And it took Alex quite a lot
of effort to persuade them not to pay those bonuses in
full
Thank you. One final document on the litigation, that’s
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awfully. We didn't really realise probably as much as
probably we should have done, until, you know, the
Hamilton judgment, quite how badly the company had
behaved. And even prior to that judgment, the advice we
were getting was that they might not lose on both limbs,
you know, of the case, and so the sort of ~ there was
still some uncertainty about what the outcome would be.
And then we have a letter from Tim Parker saying
that the liability that they would be bringing to
Government that needed to be funded was of an order of
magnitude of around 700 million, in a world in which
their revenue is about 800 to 850 million. So it was,
you know, it was eye watering because of the sheer scale
of it. But, no, you're absolutely right. And the
disappointment from ministers probably reflected that
sense of, "Oh goodness, it's even worse". And this sort
of direction of travel continued over a period of time
as more stones were lifted up and more problems of past
behaviour were discovered, with the help, to be honest,
of Nick Read as the new CEO, helping turn over some of
those stones.
If we tun, please, to page 1, we have another email
from you. If we scroll down, please. You say as
follows, you say:
“The Minister expressed his disappointment as you
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can imagine and emphasised how important it is for the
Post Office to share information with us.”
Was there a concern about a lack of transparency
from the Post Office?
I think the Minister was concerned that the company
could perhaps have shared more information about this in
advance, probably because the outcome that was being
pointed at was so negative. I think he felt they should
have said in advance that this was the likely outcome.
I am not sure how completely fair that was because the
Post Office was saying it is possible that we might not
be successful, although, as I said earlier, they did not
say, "We're likely to lose on both limbs and, you know,
be found guilty of malicious prosecution", or whatever.
So I think I could have just said yes.
Just looking at of the picture, then, as it presented
itself to you within or by a year into the role, it
appears that there were real concems about the
leadership of the company, including as wide as the
Board; is that right?
Actually, by this point, the concems from ministers
weren't quite the same. So, yes, Minister Scully that
the Post Office hadn't shared more information about the
likely liability in relation to this court judgment but
Nick Read had joined at the end, about November, from
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externals in to come and give a view to enable Nick to
put in place changes, including heightened engagement
with postmasters, that would help respond to some of the
cultural challenges that were there.
So I suppose what I'm trying to say is that it
wasn't a sense of resignation about, “Oh, the culture is
awlul, i's never going to change", it was high on the
agenda for issues to be addressed
Would you say that there were serious issues with the
company to be overcome by that stage -
Oh, yes.
-- or to be addressed?
Oh, yes. No, I mean, throughout most of my time working
with the Post Office there have been quite serious
issues.
In those circumstances, the question might be asked, why
was it felt appropriate for the Post Office to be
charged with some of the redress and compensation
schemes?
Yes, of course. It's a very good question. The only
redress scheme in play at this point was the Horizon
Shortfall Scheme, then called the Historical Shortfall
Scheme. That was, as you probably well know, set out
delineated, drawn in the settlement deed for the GLO
order in December ‘19. And up until - well, I had not
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memory, 2019, and there had been some tumover in the
Board as well, and Kelly Tolhurst had moved on and Paul
Scully was now meeting regularly with Nick Read.
So that earlier level of heightened concem from.
Kelly Tolhurst had been sort of passed by, and I think
the Minister was less ~ this Minister was less of the
view that the whole Board needed to be replaced. And of
course, the settlement had been reached in December '19,
albeit that it then tured out in 2020 to have been much
smaller from the postmasters’ perspective than we had
frankly realised.
Irrespective of that, was the general feeling that this
was a company that had handled the litigation badly?
Yes.
Itwas a company of which your Department had concerns
about the culture within the company as well. We saw
that reference in that meeting with Tim Parker. Were
those cultural concerns present as at April 2020?
They were, although what I would say was that when Alex
Chisholm sat down with Nick Read for introductory
conversations, that was the central topic of
conversation between them. So Alex was effectively
saying to Nick, "One of your biggest challenges is to
grip the culture", and they talked about different ways
of assessing what the culture was like, getting some
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had any concems expressed to me at that point about the
Post Office running that scheme. Indeed, the settlement
deed said, "This is a scheme that should be run by the
Post Office”, and it even drew out the stages that
should happen for the dispute resolution appeals
process.
So maybe the question of ownership, as the NAO goes
‘on more recently to describe, should have come up at
that point but it didn't at that point and, indeed,
I suppose we regarded it as a relatively small scale
consequence of the December '19 settlement. We were
clearly wrong on that.
Who do you consider to be responsible for that
underestimation as to how significant a scheme it might,
have to be?
I suspect there were stages throughout the different
players involved. So I think —I suspect that the GLO
group and Freeths didn't realise quite how many others
there were out there because, otherwise, they would have
probably joined the 555 in recommending that there
should be this consequential shortfall scheme. But the
Post Office should have had a better sense or should
have analysed more firmly, you know, the indicative
numbers of a couple of hundred people who might be
involved in the scheme. UKGI, as I say, were working
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closely with the company on HSS for quite a lot of that
time, 2020, 2021, and we too in the Department probably
should have found a better way to analyse it.
I think the initial estimate was 200 applications; is
that correct?
I think that's right.
There were, you say in your statement, 12 times that
that applied to the Horizon Shortfall Scheme before
November 2020 and, obviously, much more since then as
well.
That's right and probably a lot more to come as the Post
Office is now writing out to a much wider cohort than
the 4,000 plus that are already in the scheme.
Who made that original 200-applicant estimate?
I think it came from the Post Office and Herbert Smith,
based upon the conversations with Freeths and the GLO
group. I don't know for sure whether Freeths gave that
number or whether it was just a Post Office estimate.
When I had to give some advice to Alex Chisholm about
what was happening in the mediation, he asked me to
spell out, as Accounting Officers do, what other sort of
consequences would come about as a result of agreeing to
the mediated settlement, and one of the issues that
highlighted there was what I was being told about the
need to run a Horizon Shortfall Scheme, and we took that
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Board for many years prior to that. Did they give you
any estimates about the numbers of likely applicants?
Well, that was the UKGI team to which I was referring
‘So Tom Cooper was the shareholder representative and had
been for about a year, I think. And it was either he or
his team that provided the figures. I think it was his
team that then wrote the advice to ministers that said
“This is what the settlement is, and this is the number
that we've been given of the 200 potential claimants to
the HSS"
So the numbers came to you from UKGI, but you think
that's likely to have originated from the Post Office
itself?
Yes, I don't see how UKGI could have made an estimate
without information from the company.
We know that Herbert Smith Freehills were involved in
that original process in building up the scheme. You've
probably heard some criticisms of that. What is your
personal view about their involvement?
You mean, rather than my view about the scheme that they
designed?
Yes.
So I have heard quite a lot of criticism of HSF, from
the perspective of people saying HSF were guilty and
culpable for the way in which the Post Office ran its
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number from what we were given by the Post Office, at
a time of fast-paced mediation, I would say.
Were your Department doing any work in trying to
estimate those numbers?
No. No, as I say, at that point I still had
a relatively small team and was taking a lot of advice
from UKGI. I have reflected a little bit on this
because it's obviously quite a big point of criticism
about our failure to understand how big the HSS was and
I think that's that would probably be fair.
In my heart of hearts, I think I probably didn't
particularly think it mattered how big the scheme was in
relation to settling in December '19 because I did not
think it was material to whether the Permanent Secretary
should accept what was on the table from the GLO group,
and I regarded it as our best estimate at that point to
answer the question from the Accounting Officer, and
that then the scheme would run and, whereas with the 555
group you have a defined cohort, there must always be
a risk when you run an open scheme that more people
apply than you realised.
Is that a failing? Well, if people deserve the
redress and they apply, no, as long as you can respond
to them quickly enough, which is a separate question
We know that UKGI had a Non-Executive Director on the
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litigation. I have found that harder to accept because
I know that they were brought in to play a role for the
Post Office around April time, after the judgment had
actually come out. So I think it is important to be
clear when their role started. I think there has been
quite a lot of criticism about their sort of high-end
City law firm, slightly assertive approach, that
sometimes rings true to me, from having seen how some of
those schemes are rolled out. And I have had quite
a bit of personal sympathy for the view that Kevin
Hollinrake expressed earlier about how the Post Office
needs to change its law firm, you know, supporting it in
a number of those schemes, for the reason that we had
feedback in Parliament and elsewhere about how Herbert
Smith were handling some of the dispute resolution
meetings with claimants.
I remember Alistair Carmichael in a Westminster Hall
debate talked about a meeting that he had heard about
where a victim had met with Herbert Smith and Herbert
Smith had not been particularly friendly with them, and
I know the Post Office took steps to put Post Office
staff into those meetings because they felt that that
would respond.
So that's not to say ~ you know, as Kevin
Hollindrake said earlier, there are good people in
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Herbert Smith who have worked very hard on the schemes
but I think they are both, from a reputational
perspective, not well liked by the postmaster community
and, from a costs perspective, they have, I think,
extracted quite a lot of money from the Post Office, who
haven't managed them as effectively as Sarah Munby and
I would have liked from a costs perspective.
Lorna Gratton's evidence, written evidence ~ we'll be
hearing her oral evidence tomorrow -- is to the effect
that the Post Office's external lawyers have taken
a legalistic approach, and she's also referred to
a cultural clash with the approach of commercial
litigators; do you have a view on that?
I mean, some of that is what I suppose I was hinting at.
When we were working with the company on the OC scheme,
which we were more involved in from the Department than
we were in those early days of the HSS, the initial
approach that was taken, which was very, I suppose you
would say, mediation based, seemed to be being really
slow. And I've apologised to Jo Hamilton for how long
it took for her claim to work its way through those
early stages and it seemed to me that it was quite
confrontational and it didn't feel to me that it would
deliver the outcomes that the ministers wanted.
And the steps that the company then took to bring in
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“Minister asked for a quick update on the Criminal
Cases Review Commission. Declan said Magistrate cases
are going to Crown Court of Appeal. Decision is
expected shortly. The Post Office will immediately
engage with six cases if they are overtumed and will
try to head off malicious prosecution. Declan said the
Post Office will look at how well they can mediate those
six cases as a test case of how to handle the other
cases. Tom Cooper said he agreed with the sentiment but
there's a lot to discuss in the approach around managing
these cases, which will be discussed at the Board
meeting later. Tom said that it's not just a Board
issue as it involves approvals and funding. [The Post
Office] have been given interim payments of up to
£10,000 on the schemes. Increasing amount of noise in
the system, eg calls and emails.
“Tom Cooper said that the Post Office want to
unblock de minimis payments on the HSS scheme.”
Just pausing there, because we'll get to another
email that talks about the de minimis payments, can you
just briefly explain what the de minimis payments were?
This is quite similar to the conversation that was being
had with Kevin Hollinrake earlier around the scrutiny
threshold for the GLO, and so the approach that was
being taken was to say that, if the claims were quite
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more of the remediation scheme, which a drive led more
by some of the people that Nick Read brought in, rather
than by Herbert Smith - you know, as you probably heard
from Mr Recaldin a group of people came in -- that
seemed to me to be an improvement on the kind of
approach that would be more classically the commercial
litigation approach that you've mentioned from Lorna
Gratton's evidence.
Thank you. I'd like to address your Department's.
approach to the initial Historic Shortfall Scheme.
Could we turn to UKGI00012774, and this is a meeting of
22 October 2020 with Minister Scully.
I'd like to start on page 4, please. Sorry, if we
have a look at page 1 because you can see there it's
a read out of Minister Scully's call with Nick Read. If
we scroll down, we can see you're listed as a Government
attendee.
Yes.
If we could keep on scrolling down, there are various
matters that are raised, not all relating to the Horizon
system but all relating to the litigation. if we go
over, please, to page 4 I'm just going to read to you
three bullet points from there.
Thank you very much. Weil start on that second
bullet point
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small, they should be paid with minimal levels of
scrutiny. That would enable the company to have more
resource to focus on the more complex claims and ensure
that money could go out the door quickly to those people
that were bringing the claims.
The point, I suppose, that Tom is making is that you
can't just deal with one part of the elephant, you need
to be clear about the overall liability for the scheme
and the overall approach, rather than just saying, yes,
it's fine we'll deal with that. You have to, in
Government approval terms, outline the overall shape,
when you're trying to get approval for it.
So is it fair to summarise that as the Post Office
wanted those small payments to happen quickly and your
Department or UKGI, Government as a whole, wanted to
look at the overarching scheme first, and establish the
entire thing before speeding up those small payments?
Yes, I think that's fair to say, yes.
“The other issue is wrongful trading for the directors,
as if the Post Office start making payments under the
scheme but don't have the funding to complete it, then
that could put directors in a tricky situation.”
We've heard quite a lot about wrongful trading, we
heard about it from Simon Recaldin the other day. Is it
a real difficulty with the Post Office because, as
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you've said, the numbers were always going to hugely
outweigh, in fact, the amount of money that the Post
Office can make?
So at the beginning, actually, the view was that the
Post Office could afford the potential scale of
liability in relation to the HSS. So our role as
a Department was more as it had been for the December
"19 settlement, to approve it from the perspective of,
you know, the overall Principal Accounting Officer
working with Treasury because it was a novel contentious
and repercussive type payment. But, as time went on and
as the cost well exceeded what the Post Office could
afford, then it became a broader and harder question for
Government, as Sarah Munby talked about in some depth
yesterday, because we then would need to go through the
approval mechanisms which I recognise can sometimes take
a long time, within Government.
It may be an issue that we return to at the end of your
evidence. We have heard quite a lot of evidence
throughout this phase of CEOs, chairs coming in to the
company, being told that they need to make the company
financially viable, and then constantly having to go to
the Post Office with a begging bow! -- to the
Government --
The Government.
That said, if you take the long view over number of
years, and this for the start of it, it became very
clear that the company could not afford what it needed
to do in order to get redress to the people who had been
victims of their activity. So it -- this may on
reflection have been slightly more debatable but
actually it was pretty clear quite quickly that they
couldn't afford all of this and, as I said at the
beginning, I'm not sure that an alternative governance
innocence arrangement would have removed that wrongful
trading risk in any sort of clear way.
You would have just taken it up to the departmental
level where the Department would then say, "We have now
got this liability on the core departments, because it's
an executive agency and Treasury you need to fund it
because otherwise we will have insufficient funds"
Thank you. It continues:
“Minister said if can get the information on the
de minimis case as soon as possible so he can look at
that.
“Carl said that BEIS will work with the Post Office
and UKGI to facilitate as quickly as possible, but that
control considerations and financial considerations with
BEIS finance and His Majesty's Treasury need to be
worked through. As the Post Office are now looking at
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—with a begging bow for money. Do you think that the
setup of the relationship between Government and Post
Office inevitably creates that kind of a situation
that's being discussed here?
It's hard to think of an alternative that would avoid
this situation. If you were to create an agency that
was a real arm's-length body, an executive agency, and
make that the Post Office, you would have quite
a different setup and then the liabilities would be ones
for the core department. But what you would lose,
I think, is that slightly more independent commercial
flexibility where, you know, you would have the Post
Office being run as a big retailer.
The wrongful trading risk is one that has been
mentioned to us quite a lot over the five years during
which I have worked with the company. The finance
people in my department tend to take the view that it is
overplayed by the Post Office leadership, as a way to
get quite large commitments from the Government to
underwrite whatever they want to do. And so I think, on
the Government side, it's fair to say, as you heard from
Kevin Hollinrake earlier, quite often we have felt that
the Post Office has opportunities within how it runs the
company to make some savings that would allow them to
absorb some of the costs.
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funds in the region of £100m to £200m, that is very
different to the original advice that went to Ministers
and the Perm Sec previously. Declan said that virtually
all 2,000 have gone thorough the eligibility test.
Declan said that funding element is vital to progressing
to the next stage."
Can you assist us with the control considerations
and financial considerations?
Of course. Well, as I was mentioning earlier, this
question of whether something is novel, contentious or
repercussive, is quite important when it comes to
deciding whether a public corporation like the Post
Office can proceed with something that the Board would
like to do. So there is the accountable officer, in
this case it was Nick Read, and then there is the
Principal Accounting Officer, Alex Chisholm, I believe,
at that point. I don't think the Permanent Secretary
could just decide to approve this and let those payments
happen, because Treasury needs to be consulted because
it is a novel contentious or repercussive proposal. So
that's partly what I mean by the control considerations.
The financial considerations is about where is of
the money going to come from and I think Sarah Munby
talked at some length yesterday about how, if I remember
correctly, this took about four months end to end, and
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there are steps that we have to go through both within
the Department and then with Treasury to convince them
that all of this can be funded, and this was the first
of a series of redress schemes where we found ourselves
having to go to Treasury to ask for approvals, and
I think it's fair to say that the confidence in the Post
Office early on was quite low from the Treasury side,
and over a period of time it has become easier and
better.
But I remember one of the business cases, I think it
was for this one, we had 29 questions back, even prior
to the actual approval meeting, where we went and had
proper scrutiny from Treasury.
So there were some sort of forests to pick our way
through before we could get the approval
Q._ So rightly or wrongly, would it be fair to say that, at
this stage, the Post Office wanted things to go faster
than, in fact, the Government could implement?
A. Yes.
Q. Thank you. If we please turn to UKGI00013196.
SIR WYN WILLIAMS: Before Mr Blake takes you to that,
document, just so I've got this clear in my head, the
settlement is December 2019, and I think I must be right
in inferring that the idea of a scheme for people other
than the group litigants themselves must have come from
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MR BLAKE:
This is your Department's Historic Shortfall Scheme
Steering Committee minutes of 27 January 2021
You are the Chair or were the Chair of that
committee; are you still the Chair of that committee?
‘A. Well, I am the Chair now. I was actually standing in
for Mike Jorgen(?), who is mentioned later on because he
was originally the senior responsible owner for the HSS,
but I then actually took on that role. So I became, you
know, the Chair. I was covering this role for this
meeting but shortly, thereafter, I became the permanent
Chair and I've chaired the meeting ever since
Q. Thank you. If we scroll down and over the page, please,
there's a section on de minimis payments. It says
there, "TC", Mr Cooper, I think?
A. Mm-hm:
Q. *... presented the de minimis paper. He noted that the
Post Office wanted to make these payments in November
but the Department for Business did not provide its
approval due to issues around funding and precedent
setting elements. Both of these aspects have now
progressed.”
I think we dealt with some of those this morning but
can you just briefly assist us with what those issues of
funding and precedent setting elements were?
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Thank you if we bring up on screen UKGI00013196.
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the group litigants?
A. Yes, absolutely. I think
SIR WYN WILLIAMS: So it follows, does it not, that Post
Office agreed to that without, in truth, having any idea
how many people might be involved?
A. Yes, I think that's right
SIR WYN WILLIAMS: Right. Having done that, the scheme
starts and still nobody has any idea how many are going
to apply?
A. Over a period of time, obviously, it was adjusted, but
I think that's right ~
‘SIR WYN WILLIAMS: Sure, but the scheme starts in May 2020
from memory.
A. Mm-hm.
SIR WYN WILLIAMS: Still nobody knows what's going to
happen. There's a slow start and then a rush, and
nobody has got the money to pay for it.
A. That's right.
SIR WYN WILLIAMS: That's it ina nutshell, isn't it?
A. Yes, the original estimate at that May point was
33 million, which could have been afforded by the Post
Office, and then when the rush came it became clear it
couldn't be afforded.
SIR WYN WILLIAMS: Yeah, okay.
Carry on, Mr Blake.
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A. I can't remember the specific details about how we
resolved them but I think the question was what will it
take us as a Department, as raised with Minister Scully,
to say, "Yes, the Post Office can go ahead with the
de minimis payments because it would be a quick way to
get money to the claimants and close down those claims".
The precedent setting question is what I meant around
the novel, contentious and repercussive, ie if you
agree ~- as I said about one part of the elephant, if
you agree to that is particular intervention, does it
mean that you have also taken decisions about the rest
of the scheme at the same point? And I think that we
and our Finance Team and Treasury just wanted confidence
about what we were signing up to, in effect.
Q. Itsays:
“For fully quantified claims, the issues were in
relation to the interests and legal costs. The Post
Office wanted to pay compound interest and contribute to
legal costs. Both set precedents. UKGI challenged
‘compound versus simple interest and the advice from
Herbert Smith Freehills is very clear. On legal costs
the Post Office is providing £400 for de minimis
claimants towards legal fees and £1,200 for claimants
with bigger claims. UKGI has also seen other advice
from Herbert Smith, UKGI is recommending that fully
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quantified de minimis claims be paid as soon as funding
is confirmed. The payments will also need to be signed
off by the BEIS Permanent Secretary and BEIS ministers.”
If we scroll down, we can see the approach towards
partially quantified claims, if we scroll down please’
“Turning to partially quantified claims, Mr Cooper
noted that the Post Office were taking a more generous
approach and gave an example. He noted that officials
are less comfortable with this; however, it is unlikely
that we will get more information from the Post Office,
given that these claims as per the de minimis principle
are not being investigated."
Does this show, again, at this stage, the Department
is more cautious than the Post Office with respect to
payments and quick payments?
Yes, I can't remember whether officials means UKGI or
BEIS. It could be either or both. But I think you're
right. I think itis. I think this is probably the
Department scrutinising what the company is proposing
and raising some questions about that
If we could turn to UKGI00043650. We're now on 9 March
2021, another Steering Committee meeting. If we scroll
down to the bottom, please, there's a section on "HSS.
Finance Docs and Issuance of Settlement Offers". "JS",
that's, I think Joshua Scott from UKGI?
161
around branch definitions is a separate one.
Yes.
That is more about how the Post Office Board feels
comfortable about its overall financial position, and
the question here was whether there was
an interrelationship between the two, ie do we need to
have both resolved the funding commitment letter and
given the company clarity about what it can count as
a post office, where ministers had given more
flexibility to the company, before it could proceed?
Okay. The funding commitment letter issue goes back
again to the wrongful trading issue, doesn't it, because
without that commitment, there could be a suggestion
that the Post Office is acting improperly because it
doesn't have the funds?
That's right. Exactly.
If we scroll down the page, please, and over to page 3,
under "Any other business” towards the bottom. I'm just
going to read some of this for you. It says:
“CC [I think that's you] noted that Nick Read had
written to Minister Scully over the Department's role in
the delivery of a scheme for criminal cases.”
So we're now moving on from the HSS scheme to the
Overtumed Convictions Scheme:
“[You] set out your view that the Department and
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Correct.
introduced the item. On the issuance of settlement
offers he updated that the Post Office have around 100
ready to be issued but were waiting on the issuance of
the funding commitment letter before proceeding any
further. TC [I think that’s Mr Cooper] also noted that
the funding commitment letter was among a suite of wider
funding documentation that were all interrelated. CC
I think that’s you?
Mm-hm.
*... and Mr Cooper expressed concer about the risk of
other outstanding issues, such as the changes to branch
definitions causing delay, but noted that it was
a decision for the Post Office Management and Board
regarding progress on settlement offers should other
funding documentation be delayed."
So at this stage the Post Office is ready to go with
100 settlement offers but they are waiting for a funding
commitment letter?
Yes, and the funding commitment letter is a standard
piece of documentation that normally the Finance
Director from my Department would send to the Post
Office before it can make a commitment, especially when
we've had to go to Treasury for approval. The point
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UKGI do not have the capacity nor capability and would
struggle to build this sufficiently. Furthermore, the
Post Office holds the relevant information and there
would be difficulties in a third party managing the
scheme without direct access to the information. There
was also a point that it would be more appropriate for
the Post Office to continue to have ownership from
a moral perspective over resolving their past issues.
NB..."
That's Nigel Boardman, I think?
Yes, he was the Chair of the Audit and Risk Committee in
the Department
.. built upon these points and added a concern that
accepting Nick Read's proposal could create a precedent
to other partner organisations.”
11?
Tom Taylor, the Finance Director.
Thank you.
[He] also added that direct involvement in the
schemes would remove the ‘fire break’ for ministers
which can be important protection.”
So, at this stage, there are number of different
reasons why the Department considers that it shouldn't
be running that scheme. If I could summarise what I see
there and you can please assist me if I am wrong, it is
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for reasons of capacity and capability, for reasons that
the Post Office should have ownership from a moral
perspective and also for reasons of a firebreak to
distance ministers from the scheme.
Well, there is a fourth, and a comment I have on the
third. The fourth is that the Post Office holds the
relevant information and, as we know, access to that
information, disclosure, has proven problematic
throughout, and so that was of an important fourth
factor.
I think on the firebreak, the point that the Finance
Director was making was around potential legal action
against the Department. So I don't think it was
plausible deniability, or something like that.
Ministers always felt politically accountable for
whatever the Post Office did anyway, whether it was, you
know, done by them or done in-house but I think the
Finance Director would be more concerned about
potentially bringing a legal liability into the core of
the Department
I think - I mean, you say that is the Department's.
view. This was a conversation with a number of
representatives at the point when that letter had come
in from Nick Read and the mood in the meeting was this
was the Post Office tying to shift the problem on to the
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and I was also under quite a bit of financial headcount
and admin budget pressure within the Department. So
some of these points around capacity and capability were
things that I felt quite strongly. It's a very
different environment now but, at that point, it was
difficult for me to see how I would have been able to
get hold of the skills and capacity to do this.
That said, between this email, this note, and then
my advice to Sarah Munby, I felt that the balance had
shifted, given how HSS was going to, towards a different
approach, which, ultimately, Kwasi Kwarteng decided not
to pursue.
In terms of the position of the Post Office, we see
there it seems to be at that stage the Post Office's
view that this should be a scheme that was run by
Government.
Yes, and Nick Read had articulated that in a letter to
Paul Scully saying, "Well, the HSS is one thing’, to
summarise it slightly crudely, "It doesn't look like
an HSS-style scheme is what is wanted by the OC victims,
and, actually, it will be much better for the Post
Office if it could be dealt with by the Government,
allowing us to focus on the future of the company’
By that stage, had Nick Read expressed any concern to
you or any concern that you are aware of about Post
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deposit and get it off their books. I hope you might
then move on later to the advice that I gave Sarah Munby
and then the submission that we put up to ministers on
this point because my view on this shifted after this
meeting.
Perhaps if you could explain that briefly and then we'll
‘come back to the various reasons.
Of course. So in Sarah Munby's submissions of her
written statement she quotes quite extensively from
an email I wrote to her, where I said that I felt that,
given how slowly the HSS was moving, the model of the
Post Office delivering OC was not right and that we
should consider setting up a new Directorate in parallel
with my own, with a new director, overseeing the OC
redress scheme.
Sarah replied to that and I think she touched on
that in her evidence yesterday and said that she would
like me to do a proper note, which I then did and she
rightly yesterday said she approved it without changing
it to ministers, outlining the pros and cons and that
eventual advice went to Kwasi Kwarteng and was a mixture
of pros and cons on a delicate question about whether we
should set up a new team or not.
From my own perspective, I had previously had some
experience of a compensation scheme in the Department,
166
Office running the HSS scheme, and whether Government
should instead be running that scheme?
No, I don't remember that. Obviously, Nick and I spoke
every fortnight at least, and he and I did discuss
difficulties with the scheme ~- with the HSS scheme,
but -- and this has come up quite a bit in the different
evidence hearings, you know, should the Post Office have
said in the compensation hearings what it really thought
about this issue? And I think quite a lot of the tone
of my conversations with the company were about this is
the situation in which we find ourselves so let's focus
‘on what we need to do to make it work.
And I think that, you know, without trying to
provide excuses for the company, I think that was
probably the view, "We have taken a decision with
ministers about how these things should run, we're
trying to make them work". So Nick wasn't saying to me,
“Oh, please can you just take on the HSS?", because it
was in mid-flight and changing things in mid-flight can
be disruptive. This was at the point before OC had
launched, where he was saying, before we get into this,
we need to have a conversation about who should run it.
We spoke earlier, looking at the litigation, and issues
with the competence of the Post Office, the culture
within the Post Office, you've expressed here issues —
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a number of issues but you're being asked by the Post
Office to manage this other scheme. Was this a moment
to revisit the question of the Historic Shortfall Scheme
and, at that point, to have made a different decision?
I suppose there would have been moments throughout,
before this time and afterwards, when we could have
said, "Stop doing that work, please take it on into the
Department", but I think the argument I articulated
earlier about changing horses in midstream, this was at
a point when people had applied to the HSS, they were
there being assessed for eligibility, there was Declan
Salter and his team working on them, they pointed away
from trying to take it on. And, furthermore, we hadn't
had complaints that I can recall saying the Post Office
shouldn't be running the HSS.
As I said earlier on, the settlement deed said the
Post Office should run the HSS. That is what was
happening. I think if you take the long view, concerns
about how the Post Office, whether the Post Office was
appropriate from the postmasters' perspective for
running those schemes have grown over time, and
I wasn't — I mean, I don't think that was the argument
that Nick was particularly making about why the
Government should take it on. I don't think he was
particularly saying the post masters don't want us to run
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seek approval within BEIS and then HMT for interim
payments for these individuals. My team will work with
UKGI on the business case for this and we plan to submit
an ‘in principle’ submission to you in the next few dis.
I may need to ask you to prompt Charles Roxburgh ...”
That is His Majesty's Treasury?
Yes, second Permanent Secretary at the time.
Thank you,
“... ifit looks like we're going to run in Treasury
issues on the proposed interim payments but that should
wait until after we've agreed the business case here.
"We then need to do further work with UKGI and POL
on how we administer the rest of the compensation and
Mike and would welcome your thoughts. 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.”
So by this time, had your personal opinion shifted
as to who should operate that?
Yes, this was the email that I was referring to that
described my shift in position and that partly came
about through conversations with Mike Jorgen, to be
fair, who was then my line manager. As Director General
he'd had some experience from afar around the cold
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the OC scheme. I think it was a range of other reasons
that he was articulating but, obviously, with the
benefit of hindsight, it's probably fair to say that
there were points when we could have said the Department
should have taken it on.
One final point, though, is that I wasn't convinced
at this point in this meeting that we would necessarily
do a better job, given that we didn't have a team of
Case Assessors or the admin budget to actually do it.
Thank you, if we could turn to BEIS0000988, I think this
is the email from you to Sarah Munby, on 26 May 2021
I can just read those first two substantive paragraphs,
if we scroll down. You say:
"Compensation for criminally convicted postmasters:
the Post Office will now have received the awaited
merits opinion from their lawyers. We understand it
provides an assessment of the strength of potential
‘malicious prosecution’ claims from those whose
convictions were overturned at the Court of Appeal and
concludes that all postmasters are likely to have
a strong basis for a claim. This means we're looking
towards the upper end of the financial cost band. It
might also make things easier because the Post Office
shouldn't be tempted to resist any legal claim from this
group of postmasters. Our plan for the short term is to
170
health(?) claims that the Department had dealt with
before for other compensation schemes, and he mounted
the argument that, actually, the Civil Service have
quite a lot of people who can do operational delivery
who could have been brought to in help run this sort of
scheme.
To the best of understanding, why was it ultimately
rejected by Kwasi Kwarteng?
So there were a couple of steps after this. First of
all, we talked to Paul Scully and to Lord Callanan, who
was then representing the Department in the House of
Lords on Post Office matters, and also to special
advisers on the back of some advice, a formal submission
that went to ministers, and that's the one to which
I referred earlier, that argued about the pros and cons.
Views were split across those different people
I think Paul Scully favoured taking it on in-house; Lord
Callanan expressed a view that it would be better to
leave it with the Post Office. We purposefully
presented it as a set of options, rather than
recommendations to ministers because we felt they needed
to weigh it up and reach a political judgement about it
I attended the meeting that happened with Kwasi
Kwarteng. I believe Sarah Munby was there as well and
Paul Scully and Lord Callanan and special advisers and
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Mike Jergen and others, and we talked through it with
the then Secretary of State, and he weighed it up, and
discussed it with people and ultimately concluded that
it would be better to rely on oversight of the scheme
from the Department, ensure that there was sufficient
governance over the scheme, but ask the company to run
it themselves.
MR BLAKE: Thank you.
Sir, that might be an appropriate moment to take our
mid-afternoon break, I think 3.00.
SIR WYN WILLIAMS: 3.00.
(2.47 pm)
(A short break)
(3.00 pm)
MR BLAKE: Mr Creswell, 'm going to move on to a number of
specific issues that have been highlighted in relation
to the HSS scheme. The first is access to lawyers. One
issue that we've heard, especially from Mr Recaldin, is
the inability for lawyers to give early advice in
relation to the HSS and also to commission early
reports, such as forensic accountancy reports, and
matters such as that, because funding isn't available at
that pre-offer stage.
Do you see that as an issue with the Horizon
Shortfall Scheme?
173
vulnerable victims to fill in the form, and so on.
Whether lawyers are the answer to that or not I think is
a question on which others would probably be better
placed to reach a view.
I would say that on those schemes where we have
a lot of legal representation involved, the number of
claims that come forward is much lower. So if you look
at the OC scheme, it has taken a very long time to get
to the point that we are now, where over half of the
claims have been submitted. I'm not saying that is
purely the fault of the lawyers by any means, but it is
striking that the HSS scheme was designed in a way to
try to encourage early submission of claims to the
scheme, and then, having met them, the independent panel
would say that they've worked hard to draw out the
issues for which the claimants should get extra
compensation, beyond what they have stated in the form.
Q__ So when you say come forward, in terms of the Overturned
Convietion Scheme, for example, you mean you have
applicants who fully intend to apply but the building of
the case at that initial stage with the lawyer takes
time that doesn't -- isn't in the HSS scheme?
A. Yes, yes.
Q. We've seen a lot of references to trying to keep the HSS
scheme and the GLO scheme consistent with each other.
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I think it’s the fact of the design, that's correct.
Legal advice is not available upfront. It is available
alater stage. The origin of that, and this was
something that was discussed at the compensation
hearings, and Sir Wyn's interim report, I believe, was
that the desire right at its inception was to try to
avoid a very lawyer-heavy scheme. So my understanding
is that the discussions around the settlement deed set
out a requirement that the Post Office should run
a scheme that was not full of lawyers, and I think that
is indeed how the HSS has run.
I think that the Advisory Board, with whom I work
closely, have expressed some concems about how far HSS
has gone in delivering faimess. I think a lot of the
claimant lawyers, many of whom met the Advisory Board
and myself last week, would say more fairness would have
been achieved if those claimants had had legal
representation. So I do recognise those criticisms.
I think it's a very different model to the other
schemes that we are running and I know Sir Wyn,
I believe, commented that he thought the HSS in theory
was capable of delivering fair outcomes. I think some
of the criticisms of the scheme have been about the late
provision of the consequential loss guidance, the
‘overcomplicated nature of the form, how hard it is for
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That appears to be an inconsistency between the two.
Why is there that specific inconsistency in respect of
the Horizon Shortfall Scheme?
Yes, a very good question. We worked with the Advisory
Board to try and ensure alignment around the principles
for the GLO scheme cohort because both HSS and GLO have
non-convicted claimants and we need to ensure
consistency of principle across the piece, but what we
also did was worked with Freeths whom, you know, we
paid, in effect, to help us design the scheme and we
worked with the JFSA to help us design the GLO scheme,
and one of the points that we heard through those
conversations was about a lesson to be learned from the
HSS, which had been running for a while at that point
and the requests were to ensure that legal advice was
available upfront because it was felt that would better
help the GLO claimants to formulate their advice.
And obviously a lot of the people in the - it's not
quite 556, it's the 492 people within the scope of the
GLO scheme -- had an existing relationship with Freeths
or another legal firm who could help them formulate
those claims.
Thank you. The topic of delegated authority,
Mr Recaldin also gave evidence in relation to the levels
at which that is set. In 60 per cent of cases he said
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he had to seek further authority and, in his view, the
level at which authority is required is set at too low
a level. Do you have a view on that?
I think over time we have seen more delegation towards
the Post Office across a range of different aspects of
the schemes. So for example, on OC, I hardly ever see
a non-pecuniary claim and offer now. It's dealt with by
the Post Office within a very clear set of principles
that have been signed off. We tend to see more
pecuniary claims because those principles are a bit
fresher and tend to be a bit more novel in their nature.
Sticking, though, in respect of the Horizon Shortfall
Scheme in particular --
Yes, I think it's probably true that the collective view
in Government has been to give Simon and his team
a certain amount of discretion but not completely
unfettered
Do you consider that changing that level of authority
might speed up the Horizon Shortfall Scheme?
I'm not sure that that is really critical. I've spoken
to Dr Hudgell quite a bit about how the HSS scheme is
working and, over a period of time, I've tried to
develop a relationship with some of the claimants’
lawyers to try to find out what is going on from their
perspective, so I'm not just dependent on information
477
and get legal advice would mean that aim would not be
achieved for a very long period of time.
So back to my point around how many claims have come
through for the OC, I think we're talking about 61 out
of the 111 plus probably PNC cases have come forward.
On the HSS scheme, we're talking about over 4,000
cases at the moment. The wider population who could
access the HSS is about 24,000 people. That doesn't
mean they will all reply but I think, if you look at it
from the perspective of capacity in the market, I think
it would be difficult to see how the legal community
could support those, you know, that volume of claim.
One of the documents that I took Mr Recaldin to ~- I can
bring it up on to screen if you want but I don't think
it's necessary — is a meeting at which he raised
a concer, or he notified you and others that — he
said, "Claimant lawyers may ask how can I advise my
client" -- this is in respect of the £600,000 payment —
Okay,
-- is good enough, given no disclosure?”
I don't know if you saw that document. I think it's
forwarded to you. You were present as well. The
concer there being, without disclosure at that stage,
how can somebody know if the figure is sufficient. That
presumably also applies to the 75,000, so you don't have
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from Mr Recaldin
The number of cases in the dispute resolution
process is quite small, so when Simon talks about more
delegation, he’s talking about his ability to mediate
a settlement in a handful of cases. So I can't remember
the exact number but it's something like five or six
claims have been settled through mediation this year.
What has made a much more material difference in terms
of full redress has been the 75k intervention.
Thank you. That's the next topic, the £75,000 offers
and top-ups.
Do you understand legal advice to be available to
those given the £75,000 offer or top-up?
No, it's not.
No.
Only -- no, it's not at that stage.
Do you consider that that is helpful or unhelpful?
I think this is a matter on which there was consensus in
the House of Commons when my ministers announced some of
the interventions. So both my current set of ministers
and my previous minister, Kevin Hollinrake, were of the
view that what was needed was an intervention that would
get us to full and final settlement for those people
that chose to accept it as quickly as possible. And
I think they took the view that having every claimant go
178
a lawyer, you don't have disclosure at that stage. Do
you think that important rights of individuals to know
the underlying information are being taken away by that
process?
I think that the 75k, if you look at it through the lens
of the HSS, is quite a large sum of money, though it
might not sound it. But compared to the average offer
that comes from the independent panel, that is quite
a big uplift for many people. When I've discussed it
with some claimants’ lawyers more privately, they have
said that they feel that for many people who have
suffered a shortfall and the distress and inconvenience
that comes with that, 75k is an overpayment, based upon
what they, you know, would be sort of expected to
receive through a full sort of legal assessment.
The more complex claims, where 75k might not be
sufficient, based upon HSS and other precedent, is where
there are other consequential losses or a termination,
or other sort of factors, and those are the claims that
I think are more likely to lose out, I suppose, in
accepting the 75k.
Of course, the lawyers, with respect to the people
in the room, are always keen to have more clients, and
0 this is partly the conversation I have had with
claimants’ lawyers who have said every person who
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applies for the £75,000 should get access to paid legal
advice. But the inherent design of the HSS, as I said
earlier, was to try to avoid that.
I don't know if you heard the discussion with
Mr Hollinrake about the position that people are put in,
in respect of the 600,000, or equally for the 75,000,
and the risk that is involved in that decision if they
can't later down of the line say, "Actually, I've
changed my mind". What's your view on that?
I did hear that and I heard Sir Wyn's comments on it, as
well. I think I would say that Kevin Hollinrake touched
on the Accounting Officer considerations in relation to
the 600,000, or indeed the 75,000. We didn't need
a direction in the end, although the Secretary of State,
or Minister Hollinrake as was, would have sought to give
one, and the reason for that was we got ourselves
comfortable with the fact that this was an efficient way
to deliver the outcome that ministers wanted to see. So
that is what VFM means for me. It's about the most
efficient way to deliver the outcome set by ministers.
Now, prior to late 2023, there was probably more
emphasis on full and fair and a bit less on prompt. And
then towards the end of the year the political pressure
on us became higher to deliver things more promptly,
even if that meant you were foregoing some faimess in
181
bringing closure to those individuals and giving more
demonstrable progress. It wasn't, from my point of
view, get as much money out of the door as quickly as
you can by giving people even higher interim payments,
and, actually, I think Mr Recaldin was incorrect in
couple of points in his evidence but one of them was
around this 600,000 being possible to be offered as
an interim payment. It was expressly not -- the
Government policy was not 600,000 as an interim payment
to every member of the OC, it's a fixed-sum offer.
You said that Mr Recaldin was wrong in a number of
places.
Mm.
Just while we're on that topic, if there's anything else
you think should be drawn to the Chair's attention —-
Yeah, there are a couple of issues. One of which is he
implied that it was only recently that the Department
became comfortable with approving interim payments of
a large size, which was why he was saying we should have
done the £600,000. It is not true that we have only
recently got comfortable with approving large interim
payments, we have approved six figure interim payment
sums from 2022 and 2023 onwards. So I think that was
incorrect.
He also talked about the HSS appeals announcement
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terms of consistency between different claimants, this
point being that some people would gain more than others
if they all level up to 75,000 or 600,000. But in
Accounting Officer terms, it was justifiable to achieve
that, that sort of intervention without a direction,
because it was about delivering ministers’ aims.
Is part of that, then, intentionally carrying a degree
of risk to incentivise the acceptance of those offers?
Yes, I'm afraid that is the conversation we had had with
ministers which is why I would sort of agree a bit more
with what Beth White had written in that email, which
has been discussed, I know, because I think from the
politicians perspective, they were publishing regularly
data showing how much money had been paid out to lots of
claimants, and, you know, every member of the OC 111 has
had at least £200,000 in terms of interim payments. But
when you, as a politician, give a big number, people
quite understand people come back and say, "Yes, but
these people haven't had their full and final redress.
You've given them loads of interim payments but it's
just a big number that doesn't mean anything to the poor
people who haven't got to the end of the process”, and
obviously, you know, that's very unfortunate
So the political desire was actually to try to
target more full and final settlements because that was
182
being made in March, it was not. It was made in
September. Because ~ I think that's important because
it makes it sound as if we've been sitting on our hands
since March but we are currently consulting and I can
‘say more about what we're doing there if you would find
that useful
Then, finally, his comments about Emily Snow, who is
an excellent member of my team, were completely
incorrect about when we consulted the Post Office. We
consulted Simon Recaldin's team in June 2023. We got
the data from the Post Office in order to build the
business case for the 600,000 intervention. Emily then
wrote on 5 September to the team in the Post Office
saying, "Would you please consider the operational
delivery implications?” She outlined her plan for HSF,
Herbert Smith, to write to law firms on the day when we
announced it. Eleanor Brooks, also in my team, spoke on
12 September to Simon.
Our Comms Team talked to the Post Office Comms Team.
I raised it with Simon myself. He wrote to us, thanking
us for sharing the analysis for the 600k and then we
discussed it at the quarterly shareholder meeting. I'm
sorry that was a litle bit at length but I felt that
the account that was given the other day was
disingenuous because we had been involving the Post
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1 Office, including up to the level of Nick Read for
2 a while. I think the issue, though, which I think is
3 worth being aware of is that Simon and team did not
4 agree with the £600,000 policy. They felt it was
5 cutting across and undermining the principles-based
6 system that they had been working on developing with the
7 claimant lawyers for a very long period of time.
8 ‘And we were caught, from my point of view, between
9 the Minister's desire to have a fixed-sum offer that
10 would enable swifter full and final settlement, even if
ca it meant overpaying at the individual level, and the
12 Post Office's desire to stick with the claim that was
13 principle-based that would take a lot longer.
14 SIR WYN WILLIAMS: Before we go any further, when I read the
15 transcript of today, in respect of the last five minutes
16 I may get the impression that you have told me that
7 there is a shift in ministerial objective from the three
18 words “full, fair and prompt” to at least an emphasis on
19 “prompt". Right? If so, I've not heard any minister or
20 other politician articulate that publicly, and I don't
a want to be unfair either to you or them but if itis the
22 case that one of the driving forces behind the fixed
23 offer is to elevate "prompt", above what is full and
24 fair, I'd like to know it in plain language, please.
25 A. And sir, responding to that, that is precisely what I am
185
1 counterfactual of what would have happen if we had not
2 introduced the fixed sums
3. SIRWYNWILLIAMS: I agree. I understand that there are
4 a multiplicity of pros and cons. I understand that,
5 which is why I was trying to tease them out of the
6 minister.
7 MRBLAKE: In terms of the counterfactual, is that
8 principally of one of length of time awaiting payment.
9 A. Yes, I think I would have been sitting here today with
10 a lot lower number on both the OC and HSS schemes for
ca completion. My experience on the HCRS, which is the
12 Horizon Convictions Redress Scheme, that we set up on
13 the back of the legislation that we designed to overturn
14 so many convictions, has been quite a high rate of
15 people accepting the 600,000. So, obviously, I'm
16 a civil servant who advises ministers, and they
17 ultimately decide, and what we have decided in this
18 space has been to meet what ministers have asked us to
19 do, which is to try to ensure people can get to the end
20 of the process as quickly as possible.
a I think we probably fall short on some of that. As
22 I've been discussing with Jo Hamilton earlier today,
23 there are still part of what we are doing that aren't
24 going quickly enough.
25 @Q. Moving on to the topic of employees and assistants,
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saying. I was given the steer by Secretary of State
Badenoch and others that we needed -- and some of this,
evidence is included in my bundle -- to prioritise
speed, even if it meant overpayment.
SIR WYN WILLIAMS: Well, and underpayment because the way
the fixed offer operates, once you don't accept it, it's
lost forever, isn't it? So there's an overpayment
possibility, certainly, but there's also an underpayment
possibility.
A. There is, although the 600k, I would say, is supported
by legal advice.
SIR WYN WILLIAMS: I am not saying that anybody is going to
do it deliberately; I'm talking about the effect of it.
A Yes.
SIR WYN WILLIAMS: I can put myself in a position of
a claimant who may claim £1 million, who is prepared to
take the risk on not accepting 600. It's much more
difficult if your claim is 700 or 750, isn't it?
A. itis.
SIR WYN WILLIAMS: Yes.
‘A. May lalso add to my comments based upon your earlier
question?
SIR WYN WILLIAMS: Yes.
A. I think for me, in looking at your pros and cons that
you mentioned earlier, it's worth thinking about the
186
you'll recall that is something that was addressed by
Mr Recaldin. They're not eligible under the Horizon
Shortfall Scheme because they don't have a contract with
the Post Office. Are you aware of discussions to expand
the eligibility criteria?
A. lam aware of exactly that question and we have been
discussing it with Simon's team and we are preparing
advice for our Minister, Gareth Thomas, but we have not
yet submitted it to him, but it is a live question. My
new ministerial team has been quite focused on gaps
between existing schemes and so, in our early time
working together, they have been asking us questions
about people who might fall between the cracks.
Q._ Where do you see those principal gaps?
‘A. I mean, I think that's quite a good example. We have
also been asked questions around caution cases and
prosecuted but not convicted claimants. There is also
a question about family members which the previous
Government was firmly set against including, certainly
Kevin Hollinrake was clear on that in the House of
Commons.
So we ~ and I suppose I should also say Capture,
I've worked closely with number of the post masters
affected. I know that's outside the terms of reference
of this Inquiry but we have also been trying to look at
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the harms that have fallen, it appears, on, you know,
a large group of people there.
Q._ Whatis the direction of travel, as far as you see it,
in respect of those cases: all of those, the various
gaps that you've identified?
A. Well, I think our starting point as policy officials is
to respond to the question of are there gaps? What are
the gaps? Then we tend to say, well, what are the
options and what do ministers want to do? And that is
a cross-Government conversation that needs to happen.
So I'm not, at this point, able to say where I think it
will end up, but I think it is quite important,
particularly to Gareth Thomas, my new minister, to make
sure we are clear about who falls into which scheme.
This I also a point that the NAO brings out in its
report earlier this year, where they say you need to be
really clear about the eligibility of your compensation
schemes, you know, the boundaries. And sometimes you
draw a boundary that leaves some people outside and
sometimes you need to expand the boundaries to bring
people inside. And those are judgements for politicians
to make.
SIR WYN WILLIAMS: In terms of process, I'm just taking
an example, an extension to family members or
an extension to managers and employees, there will
189
A. No.
Q._ The appeals mechanism, that’s something you have already
touched on. You've explained at paragraph 33 and
paragraph 60 of your statement -- a route to appeal
that's being established. I'd just like to ask you
about a number of documents where the matter has been
discussed previously. It's BEIS0001092.
This a discussion of 5 October 2023, at the monthly
monitoring meeting. If we scroll over the page, please,
to page 2. Atnumber 4, we can see there you expressing
some concerns with the potential for an appeals
mechanism. It says:
“The group discussed the Advisory Board's
recommendation to introduce an independent appeals
process on the HSS. Carl noted that there was a risk
that, as envisaged, the appeals process would
effectively be a rerunning of the HSS and would be very
challenging on value for money grounds.”
‘Am [ right to say that, at that point in time, you
were concerned about the potential cost of an appeals
mechanism?
A. It’s not - well, I suppose cost is a dimension but, in
this case, it's the efficiency dimensions of value for
money that were on my mind, ie quite a large amount of
money has been spent or had been spent at that point on
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either have to be yet another scheme or it was HSS,
because they couldn't sensibly fit in to Overturned
Convictions or Exoneration and Convictions, and they
weren't part of the GLO.
I think you are probably right. We could decide,
I suppose, to say a postmaster who is in any of the
schemes could include family member losses within their
claim
‘SIR WYN WILLIAMS: So sort of what's the correct word or
phrase? They could ~- I can't think of it, but they
could bring ~ the postmaster could bring a claim on
behalf of a range of people?
Yes, and some of the GLO applicants have indeed included
family losses within their claim but, because of the
ways in which the rules were drawn, based upon
an agreement from ministers, those aspects of the claim
are not compensatable, if that's a word.
SIR WYN WILLIAMS: Yes, the slang I was thinking of is that
A.
you could "piggyback" certain people onto existing
claims?
That's right and obviously family members would be quite
a big expansion.
‘SIR WYN WILLIAMS: Sure, yes.
MR BLAKE: Do you have sums in mind that you envisage such
expansion would involve?
190
running the HSS. The Advisory Board earlier than this
date ~ I think June '23 ~ had first suggested that it
might be needed and, at that point, I felt that what was
being proposed was basically rerunning the whole thing
again for claimants who had gone to the independent
appeal, and on average I think at that point had
received about £39,000 each. So I was a bit concerned
about that. But we worked on this with the Advisory
Board over a number of months and the Post Office gave
us some ideas as well.
At that point, I think I probably hadn't realised
quite how many criticisms there were of the way in which
the Post Office had run the HSS and it became clear to
me eventually that the criticisms were so large that the
Advisory Board were right, that we wouldn't get closure
on the HSS unless we gave individuals the opportunity to
bring an appeal with legal support.
If we could please turn to BEIS0001098. There's then
another monthly monitoring meeting on the 1 February
2024, so quite a bit of time has passed by this meeting
If we could please turn to page 3. We see there again
the appeals mechanism is discussed. It says:
"Co [that's Catherine Connolly] explained that
there had been 70 requests to open HSS cases. These
will be assessed however it was noted that there is
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limited availability of the panel.
“The monthly monitoring meeting were told that the
Department has started to receive correspondence
regarding potential appeals too. The Department's
position is to explain that cases are settled. This
aligns with what the Post Office are informing potential
appellants.
“The Post Office stated that the Department need to
be aware that not everyone had full guidelines
(including legal) when originally claiming. There are
currently no timescales with regard to appeals.”
You advised that:
“The Department were minded to see how the £75,000
initiative washed through, how many cases this resolved
before further consideration of the appeals process.
“SR.”
I think that's Mr Recaldin,
Yes.
... fesponded by reminding [you] that this went
directly against the Post Office's and the AB's
recommendation ...”
What's the AB?
That's the Advisory Board.
*.. the [Advisory Board's] recommendation currently
with the Minister who had mentioned his consideration in
193
Indeed, I think Minister Hollinrake found it quite
challenging to get the then CST comfortable with the
idea of launching an appeals mechanism. He wrote in
March '24 to the CST and continued to chase in the
run-up to the election. But we weren't able to persuade
Treasury at that point to agree, and it then went on
pause and we picked it up again with new ministers after
the election and they quite quickly agreed that we
should press ahead with this intervention.
In respect of the criteria to be applied, do you know
what the criteria will be?
So we have been consulting ~- started consulting various
people on this. I wrote to Calum — who I know is in
the room -- from the NFSP, and also to Sir Alan Bates
last week, and we attended a meeting with the Advisory
Board, where we aired with them various proposals. Some
of the aspects that we covered included the fact that
the bar should be quite low, that we would like to model
it~ this is our proposal -- on the HCRS scheme,
ie people will have access to legal advice, based upon
a legal tariff, and that then we in the Department will
get some external legal support but will recruit a team
of case assessors to assess those claims for appeal,
that those case assessors would not see the panel's
decision on the case, but that they would have access to
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the House of Commons. It also did not consider that
an appeals process would address a number of other
issues which had been and will be raised at the Inquiry.
"{You] recognised [his] points and pointed out the
additional concern about the potential costs of
establishing such an appeals process."
We spoke about value for money before but actually
here it's directly on the issue of costs.
Yes, that's right. We had advised Mr Hollinrake in
December that it would be sensible to look at running
an appeals mechanism. We ended up in this early period
prioritising the 75k and this is obviously January of
this year when there were lots of other interventions
happening, such as the GLO fixed sum. I don't know that
I would agree that it was — that not introducing it was
running counter to the recommendation. Certainly Lord
Beamish -- Kevan Jones ~ and others continued to press
for us to do this. The Minister had not ruled it out;
he did say he would do it
My concern about costs was partly influenced by our
conversations with the Treasury at official level about
this proposal because, from their point of view, we
would be effectively double dipping, coming back to
Treasury, asking for another version of the scheme that
had been quite expensive up until that point.
194
all of the documentation that was put together through
RFls, requests for information, and other such
interventions.
We discovered with the Advisory Board whether those
cases that have been through the HSS Dispute Resolution
Procedure, that is the appeal mechanism set out through
the original December '19 settlement deed, whether they
should also be eligible to apply. Our emerging
conclusion is the closed DRP cases should not be in
scope because those individuals had had access to legal
advice and had reached mediated settlements and other
such steps, but that anyone whose case is still being
considered by DRP could have the option to transfer in
to the HSS appeals mechanism, that we would use the
existing HSS principles, and that we would again have
access to an independent panel but we would not put it
upfront.
I think one of our views is that having the
independent panel upfront in the HSS appeals process,
ie pre-offer, has been one of the contributory factors
to the slow progress of that scheme, and that's not any
criticism of the panel but it's a recognition of the
capacity constraint that is caused by having the panel
review every offer, and we would then again have a tier
of an independent reviewer, a /a Sir Ross Cranston,
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though probably not him, on hand if anyone is unhappy
with the independent pane''s view.
‘Am I right to understand, therefore, that there won't be
a strict criteria for eligibility. I mean, to give
an example, the GLO test for the independent reviewer is
whether there's been a manifest error, procedural
irregularity or substantive error of principle. Those
kinds of narrow criteria, legalistic criteria, will
those kinds of things apply or is it just an appeal,
effectively as of right, to this panel?
So I was interpreting what you said to be about the
exhibit for someone to bring an appeal to the Department
scheme.
Yes.
Our emerging view is that the bar for that should be
very low, so the eligibility should be very wide. You
point around the independent review is a slightly
separate one because it's not about eligibility for the
scheme; it's about the grounds on which you can appeal
the independent panel's view on your claim, and this is
what is happening in the GLO, where Sir Ross Cranston is
that final point of arbitration.
So that's the second layer but, in fact, in terms of the
first layer, having somebody in the Department review
your claim afresh, there won't be any strict criteria
197
discussed with the advisory board and are continuing to
discuss with people as we go through the consultation.
As I say, what we're trying to do is learn the lesson of
before you launch the scheme, talk to people about any
concems about the scheme.
Is it a possibility that those who have signed away
their rights to appeal may in fact, in due course,
receive a right to appeal?
Would it be a problem if we were to allow them into the
scheme?
Is there a consideration being given to those who have
signed up for the 75,000, waived their right to an
appeal, being actually, in fact, allowed in that appeal
mechanism because they weren't aware of the
circumstances on which you could possibly appeal?
I think we need to reach a view with ministers about
what they would like to do. As I say, the proposition
that we tested with the advisory board last week was
based upon the existing policy, which has been to say:
“Here is a £75,000 offer that you can accept, and that
would be the final resolution of your claim, or you
could continue through the existing Dispute Resolution
Procedure, or the new appeal mechanism that the
Department is going to introduce in the first part of
next year."
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that's applied?
Well, we will have to explain who can apply, but our
intention is to make that quite broad and open, rather
than limited, as we found was a criticism for the HSS
early in its tenure. I would say I see it as three
stages, probably. So we would have a Case Assessor in
the Department with external legal support looking at
the claim. If someone is unhappy as per the GLO, they
can go to an independent panel. Question yet undecided,
undetermined whether to have two bites of the chery
with the independent panel, and then ultimately an
independent reviewer.
That might sound convoluted and bureaucratic, but
actually those are protections in place for the
claimants to ensure that they have an opportunity to
challenge an offer.
We have heard, in terms of the fixed-sum offer, so the
£75,000, that in accepting that you are giving away
certain rights, and one of those would potentially
include the right to appeal; is that correct?
That is certainly the kind of policy.
Can you see a difficulty with that policy in
circumstances where the actual arrangements for that
appeal mechanism aren't even published?
I can see your point, and it is something that we
198
Finally, in terms of the Horizon Shortfall Scheme, end
date. Do you have in mind a date on which all that work
will be completed?
Yes. So again, on the back of the compensation hearings
and some of Sir Wyn's comments, we consulted the
advisory board. I think this was one of the
recommendations in the interim report, that an end date
was set. The advisory board's board view was that it
was too early to determine what that date would be,
given that the Inquiry was continuing. And the Post
Office tends to find that whenever there is publicity
about activities, whether it is the ITV documentary and
drama or the Inquiry hearings, that more people come
forward with claims from within that wider cohort.
Ministers in the new administration have also
encouraged the Post Office to write out to a large
number of claimants who haven't yet come forward, as
I said, beyond the 40,500-odd that are in the scheme.
So currently, ministers have not yet set a date,
although I have discussed with the Secretary of State
and Minister Thomas that it is our ability of drawing to
a close, at some point, that window for HSS claimants to
apply.
When do you anticipate that will be?
When do I anticipate the end date will be?
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Q Yes.
Or when do I anticipate ~
Q._ On the knowledge you presently have, assuming that the
ITV drama was the peak, in terms of publicity, when do
you anticipate the scheme will end?
A. Well, I am not sure whether it is the peak of publicity.
We have waves of publicity, of course. I think i's
a judgment for ministers. I think —
Q._ As somebody with experience of the scheme for a number
of years now, when do you personally think it will end?
A. Well, I think the question for ministers to decide is
between the summer, or September next year. I think the
judgement is partly how much time do we need to allow
people to give them fair access to redress?
SIR WYN WILLIAMS: Just so there is no public confusion
about what we mean by "closing the scheme”, when
I recommended that the scheme could be closed, I meant
that it would no longer be possible to apply for
compensation, not that everybody had been paid.
‘A. And that is what I'm talking about, as well
SIR WYN WILLIAMS: Yes. So we're talking about a date after
which nobody would be eligible to apply for
compensation?
A. Exactly.
SIR WYN WILLIAMS: Right. Fine.
201
>
principles between the Post Office and the claimants’
legal representatives. It is the Inquiry’s
understanding that there was consultation, but there
wasn't formal agreement. Is that something that you
understand, or do you have a different view?
‘A. suppose your understanding must be based upon what the
claimants’ lawyers have said to you. I remember that
consultation did happen between the Post Office and
various claimant lawyers, and feedback was given, and
the principles were amended in light of that.
I know Dr Hudgell did say to me that there may be
elements of the principles that they would choose to
challenge on a case-by-case basis, so perhaps your
description is more accurate than what I've said in my
statement on that point.
However, I do think our experience has been that
getting those principles in place is immensely helpful.
Even if you go slower -- more slowly at first, you can
then go more quickly afterwards because the areas for
dispute narrow.
Q_ Thank you
My other topic under that heading was the £600,000
Government offer, but I think you've addressed that in
addressing Mr Recaldin’s objections when it was first
announced, and you've explained your position on that.
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MR BLAKE: Thank you.
Moving now to the overturned convictions redress.
I'd like to ask you a number of topics that, again, have
arisen throughout other people's evidence. The first is
delegation levels again. Can you assist us briefly with
how the delegation levels apply under that process in
respect of the Post Office, leading to ask permission to
settle claims?
Of course. So the OC has been on a journey, from those
early cases that were mediated settlements, to the very
helpful Lord Dyson ENE principles for non-pecuniary.
Once those were up and running, we then gave delegation
to the Post Office to work within those principles. And
as I say, we only need to see a non-pecuniary offer if
it brings a new head of loss, for example, that would be
precedent setting.
The pecuniary principles, again, took a very long
time to get agreed; but since they have been agreed,
they have been have applied to more cases. And although
we do still see pecuniary offers come to the Department,
we have given more freedom to the Post Office to make
those offers.
Can I just touch on one clarification in respect of your
statement. At paragraph 29 of your second statement,
you've said that there was agreement of the pecuniary
202
Yes, I think that's right. I would say that the 450,000
intervention that Minister Hollinrake — Kevin
Hollinrake touched on earlier is also quite helpful,
from Sir Gary Hickinbottom's recommendations. And he
has played a very active role in case management, as he
described at the Select Committee yesterday, which
I think has really been welcomed by the claimant
lawyers.
At the meeting last week when we met the advisory
board and the lawyers, there was quite a bit of positive
feedback about how the OC scheme was running now, and in
particular, the role that Sir Gary Hickinbottom is
playing in helping bang heads together, and so on.
If we could move on to the Group Litigation, the GLO
scheme. Can we start on BE1S0000722, please.
Vlltake this quite quickly because this was an
email exchange that we saw with Mr Hollinrake this
morning. It relates to the Chief Secretary of the
Treasury's approval of the various thresholds and the
Chancellor appearing to resist the upfront offer. What
is your view on how receptive the Treasury were to the
proposals you were making in this regard? It's page 3
We can have a look at those passages that Mr Beer took
Mr Hollinrake to earlier today. Thank you.
Mm. Well, we got to the right place in the end, which
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was that Ministers were able to announce the
intervention that the Secretary of State and Kevin
Hollinrake wanted, but it together a lot longer than
I think it probably should have done. I know that Kevin
Hollinrake challenged what I'd said here about the
strong views of the Chancellor. That information was
based upon what the Treasury officials had told me: ie
the Chief Secretary was sympathetic to the case from
a political perspective, but the Chancellor was taking
a bit of a broader precedent view -- which, you know, to
be fair to Treasury officials, is part of their job, to
say: what is the repercussion of this decision on other
schemes?
And there was quite a bit of resistance, as you saw
through that letter that was, you know, sent back, which
in summary said something like: "Good idea but go away
and come back with a different number.”
And after January of this year, it then became
possible to get political agreement on that
intervention, which I think was the right outcome.
Thank you. So the original thinking was 100,000, and
then it went -- and was agreed at 75,000?
Correct.
Thank you.
The latest figures in terms of the GLO is that there
205
reports in the medical reports come through.
This is — I mean, this is one of the points of
contention around the scheme: that we are awaiting 186
claims, and the conversation we had at the advisory
board last week was about are we delivering full and
fair redress? The answer was, from everyone there:
“Generally we are achieving fair and full outcomes.”
‘And that wording was included in the minutes that we
published earlier this week of the advisory board
conversation. The problem is the speed. And the Select
Committee discussed some examples yesterday that I
thought were requiring of more work on our parts around
the way in which Addleshaw Goddard, who act for us on
this scheme, ask for more detail from the claimants’
side.
The claimants’ solicitors raised a few issues with
us last week. One of them was around Addleshaw
Goddard's approach to asking lots of questions. The
other was around how long it has taken to get forensic
accountancy reports to the quality needed, and it has
been quite a long lag there.
The other issue that was raised, which I think is
quite important, is around the sort to mental health
challenges of some of the claimants who are needing to
participate in this scheme. Whether that's that it's
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are 306 claims received, 221 claims paid; is that
correct?
Yes, and there are interim numbers, as well, around how
many offers have been made, and so on.
Are those figures slightly deceptive in terms of
progress, because the most complex ones have yet to be
settled and may take some time yet?
So it is definitely the case that the more complex
claims are either ones that we've just started on, or
are to come. So I'm not expecting many more 75ks
between now and -- you still get the occasional one, but
they mainly settled early on. Of the 228 offers that
have been accepted, 151 accepted the 75k. So that gives
you an indication of the fact that we have dealt with
some offers above that level, but it's sort of broadly,
I think, two-thirds one-third, if my maths is correct.
‘Two-thirds 75k; one-third, I suppose you might say
complex, above 75k.
I don't have any reason to believe, based upon
discussions with my team and my analysts, that cases
we've seen above 75k are any more or less complex than
the other claims that are coming. I don't think Freeths
or other legal representatives have held back more
complex claims, particularly. I think they've been
processing them as soon as those forensic accountant
206
quite intimidating having to fill in the forms, which is
something that Jo and I have discussed, or whether
people are holding out for the Inquiry to complete,
which is something that Mr Moloney has mentioned in the
compensation hearings before, and advisory board
mentioned as well.
Chris Hodges, the Chair of the Advisory Board, said
that he felt it was important to say the schemes are
there, the money is there, there's 1.8 billion there.
So anyone listening should, you know, feel ready to come
forward — was his sort of view. But I can understand
that, from what the claimant lawyers said, some of the
claimants want more time, and don't want to be pressed
by a deadiine for the GLO scheme for when they need to
complete their claim.
‘One of the issues that has been raised by Sir Alan
Bates, for example, is setting a deadline for the GLO to
be resolved.
Yes.
What's your view on that?
I mean, Sir Alan has been really helpful for us over
a number of years, and was involved in the design of the
scheme for us, but I know he’s unhappy with how aspects
of it are running at the moment.
I think the view from my ministers -- and I think
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the Prime Minister said this in a letter to Sir Alan
earlier this week — that if claims come to us by
Christmas, then we should be able to get offers out in
the early part of next year. So it is - you know, 40
working days is our target for getting out those initial
offers in 90 per cent of the cases. We have met that
for a number of months, and I would expect we would be
able to honour that commitment for those claims that
come to us by the end of the calendar year. Which, you
know, means that we should be able to get offers out to
those GLO claimants by the end, you know, by the end of
March in those situations.
Now that doesn't mean that those claimants should
feel forced to accept those offers, and I think, however
good a job we and Addleshaw Goddard do to give generous
and right offers, there will stil be some claimants who
wish to challenge those offers, which is why I think
Government ministers have been reluctant to say no one
-- you know, everyone will get their money and no one
can claim any later than the end of March. It's a bit
like the point we have discussed in the Inquiry before
about the August deadline was an arbitrary one that
would have forced some people either to apply either
earlier than they were ready, or they would end up
missing the boat.
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A. Yes.
SIR WYN WILLIAMS: So there are still a very substantial
number of people who have not yet made a claim?
A. Yes, and to be precise about the number as it sits now,
492 is stil the claimant cohort.
SIR WYN WILLIAMS: Yes.
A. 306 full claims have been received.
SIR WYN WILLIAMS: So it's 306 now.
A. And that leaves 186 that were not received.
SIR WYN WILLIAMS: Right.
A. Now Freeths, as an example, tell me that they think they
will be able to get their claims in by Christmas, and
they own quite a big proportion of that remaining 186,
and many of those claims are, I think, complete in part,
at least.
SIR WYN WILLIAMS: Fine, thanks.
Sorry, Mr Blake
MR BLAKE: So the Post Office Horizon System Offences Act
2024, under section 4, the Secretary of State has a duty
to take all reasonable steps to identify those whose
convictions have been quashed.
Briefly, can you assist us with how you are
establishing those individuals?
A. Yes. So this is a responsibility that's being
discharged by the Ministry of Justice. We have two
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So I think I definitely agree with the sentiment of
you should get on with it and get the claims out, you
know, get the offers out quickly, but I think the
mechanism of saying you must ~ claimants must apply and
you must give them an offer by the end of March might
actually end up with vulnerable claimants either being
forced to apply before they were ready, if you see what
I mean.
Q._ Thank you very much.
In light of the time, because we have to get to
questions from Core Participants, I'm going to address
the next topic quite quickly. That's the Horizon
Compensation Review Scheme.
A. Redress.
SIR WYN WILLIAMS: Sorry, Mr Blake.
Just so I'm clear, the statistics about the number
of people who to made claims in the GLO to the 30 August
2024 is paragraph 41 of your second statement. It may
need a little bit of updating, but that's by the by, for
the moment. What it shows is that as of 30 August 2024
there were 492 eligible applicants, but only 264
completed claims received.
A. Atthat point, yes.
SIR WYN WILLIAMS: At that point. Obviously there will be
a bit of updating,
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routes in. We have, when the scheme was launched in
July, we opened a portal on gov.uk where anyone can
self-assess and declare that they think they fall within
the scope of the Act, and therefore should be able to
achieve redress. And part of the reason for that is
because of the passage of time, and some concern that it
might be difficult for us to track down every last one
of the cohorts.
We have also had data from the Post Office and from
the CPS which has been shared with the Ministry of
Justice. That cohort is 949 people in total for England
and Wales, which is the jurisdiction that the Ministry
of Justice oversees. The judicial authorities in
Scotland and Northem Ireland have number of 130 between
them, in addition to this cohort.
The MoJ has assessed 732 of that 949, and this,
data — these data are available publicly on gov.uk,
And I can give you more information if you would find
that useful
Q. That's fine, thank you
Section 5 of that Act includes cautions. Now there
has been some confusion in the Inquiry as to which
compensation scheme is going to compensate people who
have received cautions. In your view, which is the
appropriate compensation scheme -- or redress scheme,
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sorry?
So cautions could be in scope of OC if the work that was
being undertaken was voluntary. So if, for an example
a partner was helping — you know, I'll say their
partner - with the records for the accounts and then
ended up being cautioned because of alleged
falsification of accounts, that individual could be in
scope of the OC, but most are actually picked up by the
HSS scheme and the GLO scheme, where there are cases of
people with cautions in scope.
Those whose cautions are overturned by this new
legislation, where would you say they should be applying
to?
Well, I would expect anyone in that situation to be in
scope of the HCRS, this new scheme. But I think
I should probably check that with my team. The OC
cohort tends to be a bit more bound, because it
generally is people whose cases were overturned by the
courts as opposed to this legislation. But I can share
further information with you, if you would find that.
useful.
Thank you,
There's a category that isn't covered by the new
legislation: that’s those who were convicted and
appealed unsuccessfully to the Court of Appeal because
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paragraph 114. Do you see any current issues insofar as
that is concemed, and specifically with reference to
any differences between how those matters are treated
between the Horizon Shortfall Scheme and GLO.
participants?
So I think that the Inquiry's intervention was very
helpful in getting us to get a direction in relation to
Moors(?), which helped us tackle that particular issue
for the GLO group of claimants who were affected. So
I think that has moved things on significantly.
I think there are clear principles in place in
relation to bankruptcy, although some cases I know from
Dr Hudgell were a bit contentious at the point of
discussion with the panel, but I think there are
principles now in place for how to deal with bankruptcy
claims, but I'm probably not close enough to the detail
for that.
We did have a concern which has been expressed
publicly, I know, by one victim who is within the scope
of the HCRS scheme, because early in the running of the
HCRS scheme, there was a question about the approach
that the Official Receiver would take in relation to
bankruptcies and the claim on the estate. But that has
actually now been resolved, and we are now able to make
payments to those individuals who were falling foul of
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they didn't satisfy the Horizon system essential
prosecution criteria. What is the plan for those
individuals?
There were a couple of different categories, actually,
that were excluded when Parliament reviewed the
legislation. There were DWP cases, as well, which is
something the advisory board has been discussing
actively. The Court of Appeal, as you say, and also
other offences like capture related offences, all of
which are outside the cope of the legislation.
The advisory board has been discussing the DWP cases
and liaising with DWP about them. There's no active
plan relating to Court of Appeal cases that I am aware
of, although, as I say, this is more a matter for Mou to
reach a view on.
This was quite contentious when the legislation went
through Parliament, and there was quite a strong voice
from the judiciary that those cases that had been
determined by the highest court, effectively, in the
Court of Appeal should not be overturned, whereas those
judgments reached by a lower court could be. And that
was a decision made by the Executive and Parliament.
‘Two very brief topics before I hand over to others. The
first is bankruptcy issues. You've addressed those in
detail in your first witness statement from
214
that uncertainty with the Official Receiver.
Thank you.
Final topic is current priorities and current
matters at the Post Office. I don't need to take you to
it, There was some document in your pack that relate to
concerns at the Post Office about the increasing number
of losses at the Post Office and how to address that
matter. I don't know if you've seen the various
correspondence with Fujitsu in this Inquiry regarding
future prosecutions. What do you see as the plan, going
forward, to address issues with discrepancies, going
forward?
So in my mind those are slightly distinct issues,
although I recognise there is an interrelationship
between them. I think, under Nigel Railton’s
leadership, the company is taking quite an active
approach to trying to bring postmasters with them on the
discrepancies and losses issue. So I know they have
taking steps to bring the NFSP and I think the Voice of
the Postmaster into the Chesterfield office to come and
see the back office that deals win the discrepancies,
and various steps were taken, such as the dispute
button, which I think was used a bit less than the Post
Office had expected. And there were various training
interventions and so on that were pursued.
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‘And Kevin Hollinrake mentioned earlier the
conversations we had had with the company about that.
What I believe is going to happen is that the Post
Office is going to bring in someone external to have
a look at the current Horizon system. When I saw the
YouGov survey that the Inquiry published, I spoke to
Loma Gratton, ahead of a Post Office Board meeting, and
said, "This is even worse than what I thought, from what
I've heard from the company."
She raised at the board meeting, I understand, the
need to get some independent assurance for us and for
the company, and I understand that any Nigel was of that
view himself anyway, and so there are plans in place to
bring in someone to provide a bit more confidence to
everyone involved about how the system is operating at
the moment.
I think the issue with Fujitsu is probably something
you should discuss with Paul Patterson. There was a bit
of a dispute between him and Nick Read around this
issue, I know, I think earlier in the summer, where
I think — I suspect that the Post Office feels, when
the police approaches it requesting data, that it needs
to release the data to the police. But they need some
checks and balances around that, but I'm not closely
enough involved to be able to tell you what the Post
217
reasonably long length. You haven't mentioned Mr Cooper
in either of them but you did mention him when you were
being asked questions by Mr Blake earlier today.
The impression given was that Kelly Tolhurst, the
minister, was not particularly happy with Mr Cooper's
performance, or would it be right to say judgement
calls; is that fair?
At that early point in the tenure, that is the case.
She became more comfortable with him over a period of
time, but what I was describing was a particularly
sticky patch early in my tenure in the sort of April/May
period, which was the fallout from the judgment.
Yes, the fallout from the judgment. How well did you
know Mr Cooper?
I worked as closely with him as I now work with
Lorna Gratton. The reason I spoke more about - well,
the reason I didn't really mention Tom Cooper was my
statements are of a moment in time, principally about
now, where I worked with Lorna and have done for about
18 months, I think.
So you have worked closely with him?
Mm.
I mean, he was, was he not, displaying a very pro Post
Office line, wasn't he?
I don't think that is the conclusion that one would
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MR BLAKE: Thank you very much.
Sir, there are just some questions from Mr Henry and
Mr Jacobs, and from Mr Moloney as well.
SIR WYN WILLIAMS: Before they do, can I just be clear about
the questions that I asked you about the greater
emphasis on speed of delivery, right? Your answer is
clear, but what I didn't follow up with you and should
have, is whether that steer, that I'll call it a gloss
on the earlier steer, is a steer which was given to you
by the previous government or by this government, or by
both.
A. Yes, the answer is by both.
SIR WYN WILLIAMS: By both. Right. That's fine. I just
wanted to know. Fine.
Right. Who is going to first?
MRHENRY: I'l go first if I may, sir.
SIR WYN WILLIAMS: Can you swap places with Ms Page so I can
see you, Mr Henry?
MRHENRY: Sorry, sir. I was taking cover.
SIR WYN WILLIAMS: Even late in the day, I like to see the
questioner.
Questioned by MR HENRY
MRHENRY: Thank you
Hello, Mr Creswell. You've made two statements at
218
reach, having heard evidence from members of the Post
Office who have spent quite a lot of time in this chair
complaining about an overly-interventionist approach
taken by Mr Cooper.
Q._ Well, that might have been philosophically the fact that
he was supposed to be a Non-Executive Director who
thought that actually maybe he wanted to have an
executive role, but he was aggressively taking the side
of POL in the litigation and also on the recusal issue,
wasn't he?
A. Well, I wasn't around at the point of the recusal. I
believe he recused himself from the discussion about the
recusal. I found him not someone who wanted to be an
executive in the company, but someone who felt that the
‘company wasn't conducting itself as well as it should
throughout the organisation. And he did put quite a lot
of pressure on the executives in the company, and they
didn't like that, but that was what we wanted him to do.
Q. Can I just ask you, do you know Josh Scott?
Ido.
Q. You do. Because in November 2019, Mr Cooper
>
commissioned Mr Scott to do research on subpostmasters
and their background stories, and that which they had
mentioned to the press about the tragedies that had
befallen them.
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Okay, I don't recall that, but I understand what you're 1 factual material.
saying. 2 Q@ Nocriticism of him at all
Later on ~ and no need to take you to the document, but 3 A. Okay.
so the reference is clear for the Inquiry in due course, 4 Q No. But that surely would set alarm bells, would it
it's POLO0337435 -- there is a note of a consultation 5 not?
with Mr Altman Queen's Counsel at which a Mr Vamos, whom 6 A. Itcertainly should do, and I don't recall seeing that,
you will have known from Peters & Peters, was present, 7 you know, at the time. The strategy of attacking
where the following is stated: 8 postmasters is not a winning one.
“Board desperate to decide whether to take potshots 9 MRHENRY: No. Thank you very much.
at Misra." 10 SIRWYN WILLIAMS: Who is next?
Then, further down in the document, and it is at "1 Questioned by MR JACOBS
page 3 out of 4 of the document, there is a reference 12 MRJACOBS: Hello, Mr Creswell. I represent a large number
to: 13 of subpostmasters who were affected by the scandal
“Tom Cooper and Tim Parker need to say ’Misra has 14 I want to ask you about delays in the GLO scheme.
been saying X in the press’. What our actual review of 15 You said at the beginning of your evidence that
her case is X." 16 you've taken much more control in relation to redress,
But presumably it meant "Y”. 7 and that's come across as your evidence progressed
Then Mr Altman says that he knew Misra well. 18 Many of our clients were members of the GLO, and they
If you'd been aware of that, you would have 19 have expressed to us concems that their claims are
exercised caution, would you not? 20 taking inordinately long to finalise. I think, from
1 21 what you've said, there are over 80 claims outstanding;
That's dirty pool, isn't it? 22 is that right?
That certainly sounds like a strange approach to be 23 A. In terms of claims that have not yet had offers?
taking. I think, in defence of Mr Scott, I imagine he 24 @. Yes. Or those that have had offers that haven't been
was doing what he had been asked to do, in terms of 25 accepted?
221 222
It must be something like that. I don't immediately 1 April 2023. Then there was a 38-week period where the
have the numbers to hand, but it would be something like 2 Post Office provided disclosure, at the end of which
that, probably. 3 So the scheme wasn't really in operation until
I'l quote you, and correct me if I'm wrong. You said 4 January 2024; is that right?
306 claims received, 221 claims paid? 5 A. That sounds slightly later than I have in mind,
Well 295 offers have been made. 6 actually, about when the GLO started running, because in
Okay. 7 January '24, that was when we launched the 75k fixed
To the 306 8 sum. And you'll remember from the earlier
Okay. 9 correspondence that we were discussing -- this was
So there is obviously a gap between the 295 offers and 10 during Kevin Hollinrake's evidence ~ we were discussing
the 228 that have accepted, but there is always a lag, "1 the scrutiny threshold in it must have been about the
because we may have issued an offer at the end of 12 September of 2022. So the scheme must have been -- you
October, and the claimant has not yet replied and would 13 know, at that point, do you remember I was saying in my
do so soon. I think the most relevant fact, which may 14 correspondence that we were handling cases every week?
support your argument, is there were about 39 or 40 15 So it must be earlier than the time you are saying to
claims that were formally challenged. 16 me.
But about 80 outstanding; is that right? 17 Q. Well, the point I make is that it only got really got
Do you mean of the 295 offers that have been made? 18 going after the disclosure exercise had been concluded,
Those that haven't accepted and are still involved in 19 because that was the point at which it was possible to
the scheme. 20 instruct accountants to deal with the disclosure and
Yeah, I make it 74, but ~ 21 assess the losses?
Very well. Well, we're nearly there, aren't we. 22 A. Imean, there were steps along the way such, as the 19.5
Yeah. 23 interim payments, 19.5 million interim payments that we
So the delays. You will know that the GLO was announced 24 got out early on. But in terms of the part of the
in June 2022. The scheme was published in March to 25 process in which you are most interested, that had to be
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later on, and disclosure did take a while.
I'm talking about the ability to instruct a forensic
accountant.
I understand.
You're aware, no doubt, that the scheme is beset with
delays at the moment because the current problem —
I think i's been alluded to ~ is that there are only
a limited pool of forensic accountants, so there's a bit
of a bottleneck because they're all dealing with
a number of claims. The Inquiry has heard very sad news
on a number of occasions, including today, that Core
Participants have died before receiving full
compensation. Do you agree it's imperative that the
Department does everything possible to address
continuing delays in this scheme?
Ido agree with that. Ido. And it's very regrettable
that people have died without full compensation;
I completely agree with you.
At paragraph 81 of your statement you say that the
Department has made further interim payments to GLO
postmasters suffering hardship.
We have.
You cite the risk of bankruptcy or the loss of a home as
examples where payments have been made. At
paragraph 151, you say that interim payments for medical
225
a sort of indirect funding. I don't know, if a family
member comes along and says, "I need funding to pay for
this bill", whether that particular bill would be
covered through the payment to the postmaster or whether
what we would do would be to provide a hardship payment
against a head of loss from that main postmaster, and
then it was up to the postmaster or former postmaster to
decide how to spend that money, if you see what I mean.
We have clients who are here today, and I won't name
them, but I am told that people here today have received
such payments in respect of family members with medical
conditions, and others have had pre-existing medical
conditions that have deteriorated, and they have
received payments in relation to that. But don't you
think that the availability of payments for
subpostmasters, former subpostmasters or assistants, or
family members who are struggling, for whatever reason,
is something that should be published? It's not
something that people should have to go to their lawyers
and write letters to make requests for. That should be
information that's freely available?
That's quite an interesting point, actually. I mean, my
team and I try hard to ensure that post masters who need
money whilst they are still in the system can access
that money, and obviously we've had waves of interim
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expenses are automatically approved upon receipt of
a medical report that supports the need for treatment.
Would such payments cover medical expenses where
a subpostmaster, for example, needed medical treatment
within a short time frame, but wanted to do so privately
because they didn't want to wait or be in a queue?
As far as I'm aware, they could well do. We discussed
this with the advisory board last week around cognitive
behavioural therapy, where some claimants are still in
the system and have not had full redress, and need money
to access that sort of support. And my team confirmed
in that conversation that that was the sort of thing
that we could provide funding for. I have personally
signed off hardship payments for people who are
struggling with their gas bills.
Well, exactly. What if a close family member was
struggling or needed medical care? A spouse or a child,
for example?
I think I would need to check the exact approach, but
I think obviously, as I mentioned earlier, the
principles around whether family members are included or
not is something where there is a line. I think the
impact of an individual seeing the harm that has fallen
on a family member as a result of the Horizon scandal
can be funded through compensation schemes. That's
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payments, but we have also approved quite a large number
of hardship payments, and the definition of hardship is
very loose. It's quite a low bar. So maybe that is
something that I should take away and discuss with my
team.
There is a trade-off between how much time is spent
by claimants, victims, lawyers and departmental lawyers
in handling small requests for funding, and then getting
to the end of the challenge cases and getting payments
out. Of course, small amounts of incremental requests
every week would probably be excessive, but the
principle of trying to ensure that people aren't
suffering whilst they're waiting for their claim to be
completed seems inarguable. So maybe we should amend
our guidance to reflect that.
That's helpful. It's also noted that you say the
definition of hardship is -- the words that you used are
"loose" and “low bar". So it's a wide discretion, isn't
it?
Correct.
Thank you.
My next question, then, is in relation to, at 3.55.
I think today in answers to questions from Mr Blake, you
spoke about the publicly available figures in relation
to overturned convictions and people who qualify under
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the Act. Can I just ask you to confirm that that
information is the Quashed Convictions Management
Information published by the Ministry of Justice?
That's correct, from 1 November, and it was included
latterly in the bundles.
Yes, I think what was included was October's numbers, so
I'm not going to take you to that, but there was one for
4 November that's been published in the last obviously
couple of days. You said in your evidence there's
a cohort of 949 in England and Wales.
Yes.
732 have been assessed?
Yes.
There's a cohort of 130 in Scotland and Northern
lreland?
Yes. 100 in Scotland and 30 in Northern Ireland.
Have they been assessed?
I believe that they are in the process of being assessed
and letters have started to issue. There was a press
notice from the Scottish Judicial Authorities as well,
which you might want to look at to see how far they've
got.
The figures that are published I think say that 441
individuals in England and Wales have been sent
a letter?
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from the evidence base. A point that I think hasn't
been expressed publicly very clearly is that 949 for
England and Wales includes the 111 overturned
convictions cohort. So the list that the Post Office
provided included those whose convictions have been
already overtumed.
I think i's 104 letters have been sent out to —
That's correct.
-- people to clarify whether they are —
You're looking at the same table as me.
Yes. We've heard, the Inquiry has heard -- finally,
from me -- the Inquiry has heard evidence from the Post
Office that searches are ongoing in relation to
subpostmasters who were in post during the relevant
period to see whether there may be further people whose
convictions have been quashed. What attempts is the
Department making to obtain responses from people who
don't respond, and to look for people who haven't been
identified yet but may be in scope?
Yes. So this is a question, really, that the Ministry
of Justice Is dealing with. I understand they've
employed external search -- are you okay?
Yes. Please continue.
I understand that the Department, the Ministry of
Justice, has recruited some external search experts who
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Correct.
pp
Do you know how many have replied? Because this isn't
recent; this is over the whole period, isn't it, that,
letters have been sent?
‘A. How many have applied is linked to how many people have
submitted claims, and that's 172 people. That's up from
104 the previous month. So every day we are getting
large numbers of people who have received those letters
applying.
Can I just take the opportunity to give a couple of
other bits of information around these stats that
I think are relevant, which is that the Mod, the
Ministry of Justice, is now getting to the point where
they don't have evidence for everyone. So they have
written out to lots of people, which are quite
straightforward. You might have heard this through the
discussions that my team holds with you on a regular
basis.
There are 116 people in addition to the 441 who have
been assessed and either have already been written to,
or will be written to, saying: "We think you might be in
scope, can you provide more evidence?”
So back to that point I made earlier to Mr Blake,
there are two ways in. We have a bit of a Venn diagram:
people that have come in of their own accord, and people
230
are searching for people. I have also passed on to them
the offer that I think you may have raised previously
about the NFSP saying that they could perhaps help, and
I've passed that on to the Ministry of Justice. They
are also following up where there are no responses to
the letters that have been sent.
Q. Okay. I have one further question to ask you
l understand that — of people that you've written to,
how many of them have registered?
A. I don't have that statistic here, I'm afraid.
Q. Are you able to answer this question: what is being done
to find those who have not registered?
A. Well, that was what I answered earlier.
MR JACOBS: Okay. That's very helpful. I don't have any
more questions for you.
MR BLAKE: Sir, there are no questions from Mr Moloney.
SIR WYN WILLIAMS: So I think that's it, then
Thank you very much, Mr Creswell, for both your
witness statements and for your oral evidence this
afternoon.
We will resume at 10.00 tomorrow morning.
(4.20 pm)
(The hearing adjourned until 10.00 am the followed day)
232
(58) Pages 229 - 232
INDEX
KEVIN HOLLINRAKE MP (sworn) ...
Questioned by MR BEER
Questioned by MS PAGE
Questioned by MR STEIN «20...
Questioned by MS WATT .....
Questioned by SIR WYN WILLIAMS ..........
CARL PHILIP CRESWELL (affirmed) ......
Questioned by MR BLAKE .....
Questioned by MR HENRY .......
Questioned by MR JACOBS
The Post Office Horizon IT Inquiry
86
95
104
108
113
113
218
222
INQ00001202
INQ00001202
6 November 2024
(59) Pages 233 - 233
INQ00001202
INQ00001202
‘never [1] 61/21 18-month [1] 76/19 221 [2] 206/1 223/5 ]41 [1] 210/18
WR BEER TIA 217 I'No [1] 90/23 18/20 [1] 38/9 228 [3] 91/23 206/12 I43 [4] 77/2
grease sie ‘rule [1] 11/10 186 [3] 207/3 2114/9 I 223/11 438 million [2] 33/15
51/22 55/5 55/9 58/13]7. =~ 4 21/13 23/24 [2] 69/24 73/15I 91/19
Belt Bernd 142/21 [-<——_I19 [3] 11/21 22/16/24 [3] 69/24 73/15 I4a [2] 4/4 80/23
113/1 1 February [1] 31/13 82/24 441 [2] 229/23
MR BLAKE: [11] I,'22/19 19.5 [2] 224/22 24 June [1] 134/22 I 230/19
11376 113/10 159/1 I*,millfon [2] 90/6 I 224/23 24,000[1] 179/8 —I45 [1] 83/12
17318 173/15 187/7 I ,'86/16 1991 [1] 1/9 24/25 [1] 73/18 450,000 [4] 18/14
Teed Soy Seing [220011] 16023 I4998 [1] 114/19 25 [3] 7/6 73/18 92/9 92/12 204/1
218/2 232/16 1.30 [3] 112/21 113/15 —I 105/20 46 [1] 81/21
MR HENRY: [4] 13/4 20S October [4] 1/7 [47 [1] 11/24
Sey or aag e1g/24I 1-8 billion [2] 112/6 I2 October [1] 113/16 I25 per cent [1] 80/19 I48 [1] 76/16
22219 208/9 2,000 [1] 156/4 26 March [1] 5/9 — I49 [4] 105/18
MR JACOBS: [2] 10,000 [3] 46/6 46/7 I2.47 [1] 173/12 26 May [1] 170/11 492 [3] 176/19
222/12 232/14 151/15 20 [6] 21/1 22/17 264 [1] 210/21 210/21 211/5
MR STEIN: [2] 96/17] 12.00 [9] 9/5 232/21 I 31/13 31/22 38/9/27 January [1] 15913
104/8 232/23 114/9 27 October [2] 5/3. I>
MS PAGE: [2] 86/21 [10-49 [1] 55/10 20 May [1] 54/10 I 6/17 5 December [1]
95/15 . 100 [3] 162/3 162/19 I20 years [2] 11/18 [28 March [1] 61/1 72/16
MS WATT: [2] 229/16 38/7 29 [2] 157/11 202/24 I5 February [1] 17/16
104/12 108/10 100 million [1] 33/16 I200 [4] 4/9 4/14 29 June [1] 69/1 5 July [2] 5/13 9/3
SIR WYN WILLIAMS,I 122:000 [6] 4/10 145/4 147/9 29 May [1] 135/4 5 October [1] 191/8
[e7] 1/33/11 3714 I 40/10.46/23 66/4 200,000 [1] 182/16 295 [4] 91/23 223/6 I5 September [1]
29/1 29/10 29/12 81/12 205/21 200-applicant [1] I 223/10 223/18 184/13
sONT o0os aig (100K [3] 41/22 45/20 I 145/14 3 (8,000 129 109124
31/11 51/19 55/8 47i3 2000 [2] 1101/14 IS 110/77
104/10 108/11 108/15I120™ [1] 156/1 2002 [1] 11/21 3 billion [1] 112/7 I50 [1] 2/19
108/22 18/5 1093 (104 [2] 230/7 231/7 I200m [1] 156/1 3 June [1] 53/18 — I50,000 [2] 18/9 18/16
jooyy tonto toons (10K [2] 41/12. 45/22 I2010 [1] 11/23 3.00 [3] 173/10 500,000 [1] 111/1
Tooea ror 10/9, I11-05 [2] 55/9 56/12 I2013 [2] 1/16 1/24 I 173/11 173/14 50k [1] 45/20
410/16 110/23 111/10] 140 [4] 59/18 2015 [1] 4/25 3.55 [1] 228/22 54 [1] 32/8
414/16 112/13 112/18) 114 [3] 179/5 182/15 I2018 [2] 115/9 30 [4] 18/17 66/7 55 [2] 32/7 55/15
112/23 1138 187/21 I 2318 15/12 66/9 229/16 550 [1] 12/13
1458/3 158/7 158/12 I114 [1] 215/1 2019 [14] 84/22 86/4 I30 August [1] 210/17I555 [4] 96/11 144/20
teers 1e8/10 sepin4I 116 [1] 230/19 115/3 115/17 120/12 I30 August 2024 [1] I 146/18 176/19
119 [1] 59/18 420/24 127/10 128/21) 210/20 57 per cent [1]
Terld teerta teereol 124] 4/2 4/4 112/21 I 1339/2 134/22 137/12 I306 [6] 91/22 206/1 I 105/21
Tere ets 186/20) ta5i7 4142/1 157/23 220/21 I 211/7 211/8 223/5 I 58 million [1] 12/5
12 months [3] 33/14 I2020 [12] 9/3 9/14 I 223/8 —_——_————
Aare ootiet sorasI 53/20 105/22 13/24 94/3 119/20 I34 October [1] 6
210/15 210/24 211/2 [12 November [1] I 139/1 142/9 142/18 I 137/11 6 November 2024 [1]
D116 21118 211/10 I 1382 145/2 145/9 150/12 I33 [1] 191/3 1M
211/16 218/5 218/14 I12, September [1] 158/12 33 million [1] 158/21 I60 [1] 191/4
218/18 218/21 222/10] 184/18 2021 [5] 119/20 34 [1] 77/7 60 per cent [1]
232/17 12.30 [2] 86/16 113/2I 145/2 159/3 161/22 I36 [3] 79/10 92/1 176/25
THE witness: [4] I130 [21 212/14 170/11 92/1 60,000 [1] 111/13
51/21 86/13 10/9 I 229/14 2022 [7] 5/35/24 —_I39 [1] 223/15 600 [3] 92/11 92/12
412/20 14 [2] 32/8 55/16 6/17 29/24 183/23 39,000 [1] 192/7 186/17
ta 44 October [1] 13/24 I 223/25 224/12 7 I 600,000 [21] 86/22
' 143 [4] 4/1142 I2023 [10] 40/11 69/1 I4 87/6 89/19 90/6 90/20
9 [8] 11713 1367 I 4/14 66/3 69/4 72/17 84/16 I4 July [1] 106/13 91/15 92/14 92/16
142/8 143/25 144/11 [1511] 21/2 181/21 183/23 184/10I4 June [1] 133/2 92/18 111/5 179/18
446/13 153/8 1967 I150,000 [1] 77/3 191/8 224/1 4 November [1] 2/14 I 181/6 181/13 182/3
23 [1] 192/2 151 [2] 206/13 2024 [16] 1/13/25 I4,000 [2] 145/13 183/7 183/9 183/20
24 [2] 1951/4 22477 I 225/28 5/9 5/13 5/24 6/2 6/18) 179/6 184/12 185/4 187/15
‘an [1] 12/3 16 [1] 2/19 17/16 69/4 113/16 I4.20 [1] 232/22 203/22
‘an affront [1] 12/3 I16,000 [1] 80/4 114/6 192/20 210/18 I40 [3] 65/16 209/4 I 600k [2] 184/21
‘encourage’ [1] 68/16 163K [1] 41/9 210/20 211/19 224/4 I 223/15 186/10
fire [1] 164/20 17 [1] 4/15 21 April [1] 84/16 [40 days [1] 34/16 [61 [1] 179/4
‘in [1] 171/4 17 pages [1] 4/1 22 October [2] 114/5 I40,500-odd [1] 66 per cent [1] 91/24
‘malicious [1] 170/18I172 [11 230/6 150/12 200/18 7
"Misra [1] 221/14 18 [2] 26/11 219/20 I22 September [1] 400 [1] 160/22
18 years [1] 18/10 I 45/5 40k [1] 47/22 7 May [1] 4/25
(60) MR BEER: - 7 May
INQ00001202
INQ00001202
7
7 October [1] 3/25
70 [3] 120/4 120/13
192/24
700 [2] 80/11 186/18
700 million [1]
140/11
700,000 [2] 53/22
54/2
74 [4] 113/20
732 [2] 212/16
229/12
74 [1] 223/21
75 [4] 111/14
75,000 [19] 109/21
110/7 110/12 110/13
111/4 111/13 111/22
178/10 178/13 179/25)
181/1 181/6 181/13
182/3 193/13 198/18
199/12 199/20 205/22)
750 [1] 186/18
75k [12] 47/8 178/9
180/5 180/13 180/16
180/21 194/12 206/13}
206/17 206/18 206/21
224/7
75ks [1] 206/10
8
8 January [2] 104/18
106/12
80 [3] 21/1 222/21
223/17
80 per cent [1]
119/14
800 [1] 140/12
81 [1] 225/19
85,000 [1] 110/11
850 million [1]
140/12
8k [1] 41/13
9
9 August [1] 42/25
9 March [1] 161/21
9.30 [1] 1/2
90 [1] 209/6
90,000 [1] 110/11
900 [1] 120/16
949 [4] 212/11
212/16 229/10 231/2
96 [1] 91/22
A
A2 [1] 4/2
AB [1] 193/22
AB's [1] 193/20
ability [7] 96/15 98/1
125/10 128/2 178/4
200/21 225/2
able [26] 14/1 25/12
35/11 36/20 41/22
54/7 58/14 63/11
74/15 87/11 88/22
99/20 109/13 111/20
167/6 189/11 195/5
205/1 209/3 209/8
209/10 211/12 212/4
215/24 217/25 232/11
about [249]
above [9] 10/12 21/3
83/12 88/17 120/13
185/23 206/15 206/18)
206/21
absence [2] 13/14
125/4
absolutely [11] 4/21
22/20 29/18 33/5
54/22 67/18 90/23
94/25 95/14 140/14
158/2
absorb [1] 154/25
abuse [1] 11/2
accelerate [7] 34/11
34/21 39/8 40/5 57/8
92/24 112/10
accelerating [2]
40/14 41/21
accept [14] 76/18
92/18 100/14 101/21
107/20 110/13 111/4
132/13 146/15 148/1
178/24 186/6 199/20
209/14
acceptance [4] 68/10I
99/11 103/25 182/8
accepted [6] 93/4
206/13 206/13 222/25
223/11 223/19
accepting [5] 164/14
180/21 186/17 187/15)
198/18
access [15] 74/4
92/7 98/14 164/5
165/7 173/17 179/8
181/1 195/20 195/25
196/10 196/16 201/14'
226/11 227/24
accord [1] 230/25
accorded [1] 52/17
according [2] 24/6
135/20
account [4] 4/18 16/1
137/22 184/24
accountable [2]
156/14 165/15
accountancy [4] 37/2
37/8 173/21 207/20
accountant [3]
109/12 206/25 225/3
accountants [4]
89/25 92/7 224/20
225/8
accountants’ [1]
58/22
Accounting [7] 42/4
145/21 146/17 153/9
156/16 181/12 182/4
accounts [3] 105/10
213/5 213/7
accurate [1] 203/14
accurately [1] 56/9
achieve [3] 88/24
182/4 212/5
achieved [2] 174/17
179/2
achieving [4] 57/12
88/7 93/13 207/7
acid [1] 1/19
acknowledge [1]
138/19
across [14] 8/7 16/23)
21/21 28/12 70/4 74/2
96/21 126/9 127/22
172/16 176/8 177/5
185/5 222/17
act [10] 64/10 96/7
96/14 96/18 116/24
207/13 211/18 212/4
212/21 229/1
acted [2] 94/9 139/25
acting [3] 65/19
65/19 163/14
action [9] 6/20 42/3
63/15 64/9 94/10
130/22 131/10 134/11
165/12
active [4] 26/11
204/5 214/12 216/16
actively [2] 85/25
214/8
activities [1] 200/12
activity [3] 73/25
115/16 155/5
actor [1] 103/22
actual [7] 4/13 102/6
125/9 136/16 157/12
198/23 221/15
actually [48] 7/2
19/11 31/3 41/17 44/2
48/15 51/13 52/6 63/9
79/21 92/12 96/22
100/4 102/7 104/2
109/19 118/18 120/1
120/13 125/12 128/8
128/20 133/15 133/17
134/24 136/9 141/21
148/4 153/4 155/7
159/6 159/9 167/21
170/9 172/3 181/8
182/24 183/5 194/7
198/14 199/13 210/6
213/8 214/4 215/24
220/7 224/6 227/22
actuary [1] 109/12
add [4] 4/14 22/18
38/12 186/21
added [2] 164/13
164/19
addition [7] 18/19
47/21 105/21 105/23
135/2 212/15 230/19
additional [3] 41/19
139/12 194/5
Addleshaw [3]
207/13 207/17 209/15
address [10] 17/17
44/21 60/16 126/12
150/9 194/2 210/11
216/7 216/11 225/14
addressed [6] 9/11
143/8 143/12 188/1
203/23 214/24
addresses [2] 43/1
129/17
addressing [2]
127/25 203/24
adds [1] 13/21
adequate [1] 116/18
adjourned [1] 232/23
Adjournment [1]
113/3
adjusted [1] 158/10
admin [2] 167/2
170/9
administer [2] 27/25
171/13
administering [1]
25/21
administration [3]
24/23 26/16 200/15
admit [2] 127/7 136/3)
admittedly [1] 29/24
adopted [1] 13/7
advance [3] 43/13
141/7 141/9
advantages [1] 42/3
adversarial [5] 13/7
16/12 24/10 58/25
107/3
advice [41] 47/14
54/4 54/5 58/5 58/9
58/16 59/6 95/11
110/21 110/21 116/8
121/20 123/10 126/15)
132/4 132/5 132/22
136/16 139/20 140/4
145/19 146/6 147/7
156/2 160/20 160/24
166/2 166/21 167/9
172/13 173/19 174/2
176/15 176/17 178/12)
179/1 181/2 186/11
188/8 195/20 196/11
advise [2] 35/11
179/17
advised [2] 193/12
194/9
advisers [4] 92/8
122/1 172/13 172/25
advises [1] 187/16
advising [1] 94/7
advisors [1] 41/18
advisory [32] 18/21
35/3 36/6 91/9 93/3
93/5 93/18 102/5
102/24 174/12 174/15)
176/4 191/13 192/1
192/8 192/15 193/23
193/24 195/15 196/4
199/1 199/18 200/6
200/8 204/9 207/4
207/9 208/5 208/7
214/7 214/11 226/8
advocated [1] 77/14
afar [1] 171/25
affair [1] 11/1
affect [1] 105/9
affected [9] 13/25
15/21 40/18 53/1 96/4)
120/17 188/24 215/9
222/13
affirmed [2] 113/8
233/14
afford [4] 153/5
153/13 155/3 155/8
afforded [2] 158/21
158/23
affront [2] 12/3 86/24
afield [1] 50/15
afraid [5] 3/6 62/22
99/23 182/9 232/10
afresh [1] 197/25
after [26] 4/23 6/1
25/19 30/10 30/11
31/14 40/7 48/24 52/2
63/12 77/23 79/20
94/15 104/19 105/4
121/18 122/13 139/24)
148/3 166/4 171/11
172/9 195/7 201/21
205/18 224/18
afternoon [6] 104/12
104/14 113/6 139/18
173/10 232/20
afterwards [2] 169/6
203/19
again [37] 2/24 16/5
17/3 23/20 25/1 26/17)
26/22 27/17 30/7
31/10 34/8 34/22 37/5)
39/10 47/9 48/1 60/22
79/22 82/22 88/14
89/5 91/25 94/1 98/10)
132/8 138/16 161/13
163/12 192/5 192/21
195/7 196/15 196/24
200/4 202/3 202/5
202/17
against [10] 13/18
49/8 52/19 53/7 77/23
130/25 165/13 188/19)
193/20 227/6
aged [1] 11/21
agency [3] 154/6
154/7 155/15,
agenda [2] 83/3
143/8
(61) 7 October - agenda
INQ00001202
INQ00001202
A 21/17 25/7 26/22 30/1I 188/17 188/22 188/25) 51/23 129/16 130/6 130/6
30/13 31/6 31/11 39/8) 189/15 194/1 195/14 Ianother [12] 1/4 131/23 132/7 132/9
39/11 40/7 41/5 41/6 I 196/8 200/15 204/3 I 10/13 93/23 130/23 I 132/11 138/1 139/8
41/9 53/22 57/25 71/8] 212/9 214/8 220/9 137/11 140/22 151/19] 151/3 170/19 191/4
aggressive [1] 66/24
aggressively [1]
oe [26] 39/19 74/20 75/21 78/11 228/1 228/16 232/1 161/22 176/21 190/1 I 192/6 192/17 195/23
Oo ua7 4914 I 79/6 83/7 83/7 83/19 I 23215 192/19 194/24 196/6 197/9 197/12
56/6 61/14 63/5 64/10I 90/1 93/18 94/23 alternative [4] 94/2 answer [11] 15/8 —_I 197/19 198/20 198/24
74/14 97/16 99/23 98/18 98/20 99/1 94/22 154/5 155/9 16/22 23/21 24/19 199/7 199/8 199/13
102/3 104/6 1906/5 I 100/14 101/11 102/10] alternatives [1] 25/19 146/17 175/2 I 199/13 199/15 199/23
429/13 16019 160/10 I 107/21 108/17 108/22] 46/19 207/6 218/7 218/13 I 213/25 214/8 214/13
108/25 109/14 111/19Ialthough [18] 3/1 I 232/11 214/20
182/10 185/4 187/3
194/15 195/6 210/1
225/13 225/16 225/18)
agreed [14] 12/14
112/16 129/25 131/2 I 26/22 28/12 49/12 Ianswered [1] 232/13 Iappealed [2] 131/11
132/16 150/20 150/21I 50/9 62/17 106/18 —_Ianswering [1] 86/14 I 213/25
155/8 156/4 157/3 I 107/19 127/20 141/12Ianswers [3] 22/2 I appealing [1] 129/14
87/7 57/21 63/18 162/8 170/20 172/10 I 142/19 181/14 186/10] 37/22 228/23 appeals [17] 144/5
91/23 135/14 135/20 I 179/9 182/3 189/4 I 200/20 202/19 214/14I anticipate [4] 200/24 I 183/25 191/2 191/11
1541/9 188/4 171/11. I 1960/1 200/2 211/20 I 215/12 216/14 200/25 20112 201/5 I 191/14 191/16 191/20
4195/8 202/18 202/18 I 214/9 222/2 225/9 IAltman [2] 221/6 _Iantithetical [1] 11/9 I 192/22 193/4 193/11
205/22 All-Party [2] 7/20 8/1 I 221/18 Antony [1] 34/23 193/15 194/2 194/6
allegations [7] 52/23 Ialways [22] 34/7 39/8Iany [51] 8/20 12/22 I 194/11 195/3 196/14
53/6 53/9 78/18 78/19I 44/9 62/8 64/1 75/11 I 14/21 14/23 14/24 I 196/19
79/11 80/14 78/1 82/6 83/14 83/17I 15/18 29/3 35/25 —_Iappeared [2] 78/13
allege [1] 56/7 83/20 84/5 93/6 44/13 54/8 57/16 138/11
ore taone aad alleged [3] 78/20 I 100/25 10/5 111/3 I 63/15 69/17 72/4 74/3I appearing [1] 204/20
203/4 205/19 79/17 213/6 112/9 146/19 153/1_ I 75/25 80/14 88/8 _— appears [4] 137/23
agrees [1] 61/25 _ [allow [7] 53/17 66/17] 165/15 180/23 223/11) 90/21 94/12 105/15 I 141/18 176/1 18911
ahead [6] 47/7 89/3 I 67/4 116/15 154/24 am [24] 1/2 13/3 13/5) 106/3 106/14 119/9 I appellants [1] 193/7
139/20 160/4 1985/9 I 199/9 201/13 29/3 55/10 55/12 96/1I 130/10 134/9 144/1 I APPG [6] 7/23 7/25
allowed [1] 199/13 I 101/20 117/12 117/14I 146/3 147/2 155/11 I 8/1 9/8 10/24 94/4
agreeing [3] 45/19
46/6 145/22
agreement [10] 27/8
amt} 68/24 70/20 allowing [1] 167/23 I 118/20 118/21 141/10) 158/4 158/8 162/5 applicant [1] 145/14
88/4 89/13 93/11 allows [1] 39/22 159/6 164/25 185/25 I 163/18 167/24 167/25I applicants [4] 147/2
1479/1 alluded [1] 225/7 186/12 188/6 191/19 I 170/24 175/11 185/14) 175/20 190/13 210/21
aimed [1] 70/7 almost [1] 41/9 197/3 201/6 214/13 I 185/19 190/6 196/21 I application [2]
aiming [1] 89/9 Alok [1] 14/5 227/10 232/23 197/25 199/4 206/19 I 133/10 138/1
aims [1] 182/6 along [4] 17/19 amend [1] 228/14 206/21 209/20 215/1 I applications [1]
air [1] 136/22 107/17 224/22 227/2 Iamended [2] 47/22 I 215/3 217/12 232/14 I 145/4
aired [3] 50/16 125/2 alongside [1] 115/21 I 203/10 anybody [18] 15/16 Iapplied [7] 46/11
already [16] 10/12 Iamong [1] 162/7 15/17 17/1 17/12 145/8 169/10 195/10
195/16
Al [2] 122/25 137/4
Alan [12] 1/14 1/21
21/5 27/15 28/7 28/8 Iamongst [5] 5/19 19/14 23/14 49/11 198/1 202/19 230/5
28/15 41/9 74/11 94/4) 44/21 67/3 83/10 50/11 54/7 72/2 79/24I applies [3] 41/23
124/11 131/19 133/13] 108/41 84/1 85/19 92/23 179/25 181/1
38 aad tena 145/13 191/2 230/20 Iamount [12] 24/21 92/23 107/8 112/11 I apply [15] 38/18
231/6 33/14 38/10 54/23 186/12 146/21 146/23 158/9
208/16 208/21 209/1
alarm [5] 3/6 22/10
22/21 25/19 222/4
albeit [1] 142/9
Aldred [3] 121/3
125/1 127/19
Alex [12] 115/17
116/14 122/4 130/20
also [82] 6/24 8/12 I 75/15 90/20 103/4 {anyone [8] 12/24 _I 175/20 196/8 197/9
13/3 14/8 17/7 20/23 I 112/10 151/15 153/2 I 16/23 36/4 196/12 I 198/2 200/23 201/18
23/16 27/2 31/23 32/4I 177/16 191/24 197/1 208/10 212/2 I 201/22 202/6 209/23
34/14 34/22 35/5 Iamounts [1] 228/10 I 213/14 210/4 210/7
35/13 36/24 43/4 49/3I analyse [1] 145/3 _ Ianything [9] 3/2 25/6 Iapplying [7] 24/1
49/5 53/19 62/7 62/14Ianalysed [1] 144/23 I 34/1 64/6 64/9 111/24] 24/4 24/4 24/15 25/13
66/10 78/2 79/13 —_Ianalysis [2] 118/23 I 130/7 182/21 183/14 I 213/12 230/9
1432/4 137/15 138/17 87/15 94/6 94/13 184/21 anyway [4] 29/5 appoint [1] 127/23
438/22 142/19 142/22 95/18 97/14 105/14 analysts [1] 206/20 I 111/14 165/16 217/13] appointed [3] 5/4 6/6
145/19 156/16 106/23 109/23 114/4 Iangry [1] 123/9 anywhere [1] 20/16 I 8/17
alighted [1] 39/21 114/22 116/1 117/21 Iannex [1] 69/2 apart [1] 116/7 appointment [4] 7/1
align [2] 69/13 69/15 118/23 121/7 123/8 Iannotated [1] 72/21 Iapologised [1] 84/21 100/1 137/6
iment [1] 176/5 I 123/20 123/20 124/9 Jannounce [1] 205/1 I 149/20 appointments [1]
aligns [1] 193/6 126/19 126/23 129/4 Iannounced [4] apologises [1] 3/3 116/5
Alisdair [3] 66/20 132/20 149/11 160/11] 178/19 184/17 203/25I apparent [3] 12/11 I appreciate [2] 29/17
4127/5 134/21 160/24 161/2 162/6 I 223/24 14/16 18/3 110/23
Alistair [1] 148/17 164/6 164/19 165/3 Iannouncement [3] apparently [1] 31/8 I appreciating [1]
all [69] 1/5 1/24 2/7 167/1 170/23 172/12 I 1/4 3/5 183/25 appeal [41] 11/24 106/12
2/8 7/20 8/1 12/15 173/20 176/9 176/24 Iannouncing [1] 18/19 26/24 95/20 approach [45] 13/7
13/10 15/25 18/12 179/25 183/25 184/17I 41/24 97/5 97/7 127/14 33/20 33/23 39/14
186/8 186/21 188/16 Ianonymous [1] 129/3 129/8 129/11 39/22 42/10 46/17
(62) aggressive - approach
INQ00001202
INQ00001202
A
approach... [38]
48/10 59/2 106/23
107/2 107/3 107/4
108/8 121/21 122/1
122/2 122/7 122/20
123/14 123/16 126/5
126/23 127/6 130/3
135/7 148/7 149/11
149/12 149/18 150/6
150/7 150/10 151/10
151/24 152/9 161/4
161/8 167/11 207/18
215/21 216/17 220/3
221/23 226/19
approached [1]
32/10
approaches [2]
100/23 217/22
approaching [1]
128/10
appropriate [8] 36/10}
50/2 55/6 143/17
164/6 169/20 173/9
212/25
appropriately [1]
53/12
approval [9] 152/11
152/12 153/16 157/12)
157/15 159/20 162/25)
1711/1 204/19
approvals [2] 151/13
157/5
approve [6] 85/5 85/8
91/3 91/4 153/8
156/18
approved [5] 45/17
166/19 183/22 226/1
228/1
approving [2] 183/18
183/21
April [8] 84/16 115/3
120/12 139/1 142/18
148/3 219/11 224/1
April/May [1] 219/11
arbitrary [1] 209/22
arbitration [1] 197/22
Arbuthnot [5] 30/13
32/1 35/3 91/10 112/7I
are [217] 1/5 2/16
4/18 4/21 10/10 10/22
11/17 14/25 16/10
16/10 16/16 16/19
17/9 17/19 19/12
20/10 23/1 23/3 23/25)
24/1 24/13 24/16
24/22 24/25 25/12
25/25 26/18 31/6
33/10 37/11 37/13
40/1 40/17 40/21
41/10 41/13 41/16
44/5 48/3 52/12 52/17
52/17 52/18 52/20
53/12 53/13 53/21
53/22 54/9 55/22 56/6
58/4 58/21 59/7 61/10
62/11 64/8 65/5 65/7
65/8 65/25 66/10
66/14 69/7 69/19 70/5
70/12 71/23 74/19
75/24 76/6 76/9 77/2
81/7 86/11 88/10
88/22 88/24 89/6
91/15 94/7 94/25 95/6
95/15 97/23 97/24
97/25 98/1 98/3 98/3
98/12 101/14 103/12
104/25 106/19 106/21
108/20 109/15 110/10)
114/18 115/1 115/25
118/2 121/2 123/15
137/18 138/3 139/18
145/13 148/9 148/25
149/2 150/19 150/20
151/3 151/5 155/25
157/1 158/8 159/4
159/5 161/9 161/12
162/19 164/22 167/25)
170/20 174/20 175/2
175/9 177/10 180/3
180/18 180/19 180/20)
180/23 181/5 183/16
184/4 187/3 187/23
187/23 188/4 188/7
189/7 189/7 189/8
189/14 189/21 190/5
190/17 193/5 193/6
193/10 198/14 198/18)
199/1 200/18 206/1
206/3 206/5 206/9
206/10 206/21 206/22
207/3 207/5 207/7
207/24 208/3 208/8
208/24 211/2 211/14
211/22 212/17 213/8
213/9 213/11 214/10
215/3 215/11 215/14
215/24 216/13 217/13
218/3 219/18 222/19
222/21 223/19 224/15
224/25 225/7 226/1
226/9 226/14 226/21
227/9 227/17 227/24
228/17 229/18 229/23
230/7 230/12 230/15
230/19 230/24 231/9
231/13 231/22 232/1
232/5 232/5 232/11
232/16
area [2] 9/23 68/11
areas [6] 33/18 46/14
73/7 117/11 124/9
203/19
aren't [5] 18/12
187/23 198/24 223/22)
228/12
argue [8] 29/7 49/13
110/4 110/8 110/15
110/16 110/18 111/14:
argued [2] 98/17
172/15
arguing [9] 16/13
19/18 19/25 24/25
29/3 46/13 50/25 78/8
103/13
argument [12] 68/8
75/14 76/21 87/6
87/15 91/10 91/13
130/14 169/8 169/22
172/3 223/15
arisen [1] 202/4
arising [1] 23/21
arm [2] 29/6 30/4
arm's [1] 154/7
arm's-length [1]
154/7
armed [2] 1/17
112/13
arming [1] 29/2
around [35] 33/13
37/7 56/12 66/22
116/4 130/3 140/11
148/3 151/10 151/23
159/20 160/7 162/3
163/1 165/12 167/3
171/25 174/8 176/5
179/3 183/7 188/16
197/17 206/3 207/3
207/12 207/17 207/19
207/23 217/19 217/24
220/11 226/8 226/21
230/11
arrange [1] 31/25
arrangement [2]
123/11 155/10
arrangements [2]
40/21 198/23
arrival [2] 132/3
132/23
arrive [2] 24/7 54/21
arrived [1] 115/9
articulate [1] 185/20
articulated [2]
167/17 169/8
articulating [2] 90/15
170/2
as [378]
aside [1] 110/25
ask [33] 23/21 43/1
48/1 49/12 53/2 53/5
53/8 61/23 86/12
86/22 87/23 89/5
104/15 104/16 106/5
108/7 112/13 113/15
113/19 114/8 139/20
157/5 1714/5 173/6
179/17 191/5 202/3
202/7 207/14 220/19
222/14 229/1 232/7
asked [24] 21/9
31/25 37/23 48/10
49/25 81/3 88/4 88/19
89/13 93/11 93/15
108/6 115/17 134/12
134/13 143/16 145/20)
151/1 169/1 187/18
188/16 218/6 219/3
221/25
asking [9] 11/12
38/21 101/20 101/20
102/17 115/6 188/12
194/24 207/18
aspects [5] 159/21
177/5 190/16 195/17
208/23
assertive [1] 148/7
assess [7] 15/4
39/19 56/23 135/19
195/23 212/3 224/21
assessed [10] 56/9
58/19 58/25 169/11
192/25 212/16 229/12)
229/17 229/18 230/20
assessing [1] 142/25
assessment [17]
24/8 36/13 36/14 37/9
37/18 37/21 56/16
57/8 57/16 59/2 90/8
92/5 93/7 111/12
130/15 170/17 180/15)
assessments [2]
30/6 89/25
Assessor [1] 198/6
assessors [3] 170/9
195/23 195/24
assigned [1] 53/19
assist [8] 53/20
115/10 124/8 156/7
159/24 164/25 202/5
211/22
assistance [3] 58/1
96/17 112/19
assistant [1] 105/6
assistants [3] 2/16
187/25 227/16
assisted [2] 1/21
1/23
assisting [1] 10/18
assists [1] 95/25
associated [1] 11/17
assumed [2] 12/4
56/1
assuming [2] 92/8
201/3
assumption [1]
assurance [1] 217/11
Astonishingly [1]
12/11
at [313]
atmospherics [1]
122/18
attached [4] 12/19
12/20 139/5 139/11
attacking [1] 222/7
attempt [7] 34/9 59/4
99/8 103/21 127/12
132/8 138/10
attempts [2] 34/21
231/16
attend [2] 127/24
137/14
attended [6] 62/18
71/9 72/17 137/12
172/23 195/15
attendee [2] 137/13
150/17
attendees [1] 135/1
attending [1] 118/21
attention [1] 183/15
attitude [1] 30/3
attracted [1] 127/25
audit [7] 23/18 25/3
102/22 106/6 107/21
108/6 164/11
audited [2] 105/3
106/16
augment [1] 13/15
August [5] 40/11
42/25 209/22 210/17
210/20
authoritarian [1]
11/17
authorities [2]
212/13 229/20
authority [5] 114/24
176/23 177/1 177/2
177/18
automatically [1]
226/1
availability [2] 193/1
227/15
available [9] 111/3
173/22 174/2 174/2
176/16 178/12 212/17)
227/21 228/24
average [2] 180/7
192/6
avoid [3] 154/5 174/7
181/3
awaited [1] 170/15
awaiting [2] 187/8
207/3
award [13] 27/3
39/22 46/19 46/20
48/18 49/9 49/14
57/12 89/17 93/8
109/6 135/19 136/7
awarded [1] 129/18
awards [12] 16/18
33/10 33/22 33/25
43/3 43/8 51/5 51/9
51/17 58/17 91/20
91/24
aware [28] 3/1 10/12
21/22 53/14 53/24
54/3 55/22 55/24
57/10 58/4 58/21 59/7,
59/13 77/16 79/11
(63) approach... - aware
INQ00001202
INQ00001202
A
aware... [13] 94/13
97/1 97/2 167/25
185/3 188/4 188/6
193/9 199/14 214/13
221/19 225/5 226/7
away [12] 39/23 40/3
58/11 59/4 96/9 106/3,
169/12 180/3 198/18
199/6 205/16 228/4
awful [2] 123/4 143/7
awfully [1] 140/1
awkwardly [1] 3/9
B
back [45] 9/12 18/1
23/10 23/12 25/19
27/16 27/20 28/14
28/23 30/15 30/21
42/22 48/12 49/8
49/11 55/15 68/4
73/16 75/12 75/13
75/16 88/14 88/15
89/10 94/3 106/8
109/8 111/22 116/15
123/10 125/10 157/11
163/11 166/7 172/13
179/3 182/18 187/13
194/23 200/4 205/15
205/17 206/23 216/21
230/23
backbench [2] 11/14
50/13
backbencher [7] 5/2
6/25 7/10 8/19 9/4
10/2 22/6
backbenches [3]
7/14 8/16 8/25
backdated [2] 85/3
85/8
backdrop [1] 123/9
backed [1] 133/6
background [7] 4/23
32/8 64/17 114/18
114/21 115/6 220/23
backwards [1] 27/17
Badenoch [8] 6/6
40/13 41/1 42/15,
42/24 43/23 85/17
186/2
Badenoch's [1]
40/16
badly [2] 140/3
142/13
balance [4] 103/21
116/24 127/25 167/9
balances [1] 217/24
band [1] 170/22
bang [1] 204/13
banking [5] 7/17 7/20]
8/2 10/24 94/15
bankruptcies [1]
215/23
bankruptcy [4]
214/24 215/12 215/15
225/23
banks [2] 7/18 8/6
bar [4] 195/18 197/15)
228/3 228/18
bare [1] 99/11
barriers [1] 75/10
barrister [1] 10/18
barristers [1] 8/9
base [2] 70/4 231/1
based [16] 57/4 90/8
136/13 145/16 149/19)
180/13 180/17 185/5
185/13 186/21 190/15)
195/20 199/19 203/6
205/7 206/19
basic [3] 24/13 81/3
basis [28] 11/8 21/15
21/15 21/18 36/20
37/15 37/20 47/4 53/3
53/4 56/3 56/20 56/24,
57/19 76/7 79/19 86/2
86/9 98/25 99/3
102/11 102/14 103/5
107/12 108/1 170/21
203/13 230/18
Bates [7] 11/25 12/15I
21/25 32/1 104/19
195/14 208/17
Bates' [4] 18/8 20/18
21/3 38/4
battle [1] 31/8
be [339]
Beamish [1] 194/17
bearing [1] 104/3
became [17] 1/7 8/15
11/15 14/14 78/21
122/14 135/22 153/13)
155/2 158/22 159/9
159/11 181/24 183/18)
192/13 205/18 219/9
because [126] 7/1
8/19 14/24 20/1 21/9
25/15 28/7 33/21
34/18 34/19 39/11
39/25 43/24 44/4 44/8
46/22 47/13 48/3 49/9
50/23 52/5 52/18 54/9
54/15 56/22 58/18
64/23 65/7 65/9 72/23
75/24 76/6 83/7 83/7
87/17 89/16 89/23
90/3 90/16 90/21 91/4
92/6 92/15 92/17
93/24 97/5 100/3
101/3 102/12 102/17
103/2 103/16 107/23
109/19 110/12 118/1
118/25 120/5 122/25
124/4 125/5 128/14
130/9 132/14 137/8
138/18 140/13 141/7
141/10 144/19 146/8
146/13 148/1 148/22
150/14 151/19 152/25,
153/10 153/15 155/14:
155/16 156/19 156/19)
159/7 160/5 163/12
163/14 166/4 168/18
170/23 172/21 173/22
176/6 176/16 177/10
182/6 182/12 182/25
184/2 184/2 184/25
186/5 188/3 190/2
190/14 194/22 196/10:
197/18 199/14 203/19)
204/16 206/6 210/10
212/6 213/6 213/17
213/25 215/20 220/21
223/12 224/6 224/19
225/6 225/9 226/6
230/2
become [5] 29/23
31/6 31/14 128/20
157/8
becomes [2] 23/16
24/12
becoming [1] 61/12
been [192] 2/25 7/12
9/4 10/17 10/18 10/21
11/4 11/23 12/1 12/8
12/16 15/21 17/6
20/19 22/22 23/23
25/24 26/6 26/8 26/25
27/1 27/6 27/15 28/2
28/7 28/8 28/9 28/9
28/15 28/19 30/15
30/25 32/11 33/13
35/6 38/5 38/9 41/7
42/24 44/9 44/22
45/13 48/20 50/2 50/6
52/4 53/14 53/15
53/16 72/7 73/23
74/17 75/3 76/8 79/24
82/16 82/19 82/20
84/2 85/18 85/21 92/1
92/2 92/20 95/5 95/20
96/3 96/11 96/24 97/1
97/8 97/21 102/8
102/8 103/18 103/22
106/14 107/10 107/12
114/19 115/2 122/2
123/1 124/21 126/1
127/12 130/8 131/1
132/2 132/22 136/4
136/5 136/20 142/1
142/5 142/8 142/9
143/14 147/5 147/9
148/5 148/20 151/14
153/7 154/14 155/4
155/6 158/21 167/6
169/5 172/5 173/16
174/17 174/23 175/10
176/14 177/9 177/15
178/7 178/9 182/12
182/14 184/3 184/25
185/6 187/9 187/14
187/18 187/22 188/6
188/10 188/12 188/16)
188/25 191/6 191/25
191/25 192/24 194/3
194/25 195/12 196/5
196/20 197/6 199/19
201/19 202/9 202/18
202/19 203/16 204/7
206/4 206/13 206/24
207/21 208/16 208/21
209/18 211/7 211/21
212/10 212/22 214/7
214/11 214/18 215/18
215/24 220/5 221/15
221/19 221/25 222/24
223/6 223/18 224/11
224/12 224/18 225/7
225/24 229/8 229/12
229/17 229/24 230/4
230/20 230/20 231/2
231/5 231/7 231/16
231/18 232/6
Beer [9] 1/3 2/10
3/12 3/18 3/20 29/1
112/24 204/23 233/4
befallen [1] 220/25
before [47] 1/3 2/11
10/2 18/21 22/18 29/1
35/24 45/15 51/11
51/13 64/23 83/2 83/5
83/18 91/16 93/25
96/10 97/5 97/5 98/17
109/4 110/21 115/9
127/13 129/7 137/2
145/8 152/17 157/15
157/21 162/5 162/24
163/10 168/20 168/21
169/6 172/2 185/14
193/15 194/7 199/4
208/5 209/21 210/7
214/23 218/5 225/12
begging [2] 153/23
154/1
beginning [6] 53/11
61/7 61/8 153/4 155/9
222/15
beginnings [1]
135/22
begins [1] 104/24
begun [1] 30/1
behalf [12] 2/7 2/8
38/6 86/18 94/10 99/1
99/12 100/12 100/19
104/16 105/11 190/12)
behaved [1] 140/4
behaviour [2] 64/20
140/19
behavioural [1]
226/9
behind [6] 20/24 23/5)
23/23 58/10 105/25
185/22
being [74] 5/9 7/8
7/13 12/23 21/5 26/5
28/18 34/16 34/17
34/23 35/15 36/1
37/23 42/10 48/10
50/20 53/12 54/19
60/4 61/3 62/14 66/12
75I7 81/25 82/6 82/19
82/21 83/5 86/1 94/21
95/24 104/14 107/16
107/19 111/16 111/20)
115/21 121/14 121/19
123/14 123/15 132/1
132/6 138/14 139/8
141/7 145/24 149/19
151/22 151/25 153/21
154/4 154/13 161/12
169/1 169/11 179/23
180/3 182/2 183/7
184/1 185/3 191/5
192/4 196/12 199/11
199/13 210/6 211/24
213/3 213/6 219/3
229/18 232/11
BEIS [10] 117/6
134/13 136/16 155/21
155/24 161/3 161/3
161/17 171/1 174/17
BEIS0000705 [1]
42/19
BEIS0000722 [2]
44/18 204/15
BEIS0000738 [1]
87/24
BEIS0000754 [1]
93/25
BEIS0000805 [1]
72/14
BEIS0000808 [1]
40/9
BEIS0000830 [1]
133/2
BEIS0000988 [1]
170/10
BEIS0001020 [1]
60/14
BEIS0001023 [1]
17/14
BEIS0001092 [1]
191/7
BEIS0001098 [1]
192/18
BEIS0001130 [1]
137/10
belief [3] 4/20 113/24
114/13
believe [13] 16/16
17/1 42/2 57/3 77/25
156/16 172/24 174/5
174/21 206/19 217/3
220/12 229/18
bells [1] 222/4
below [7] 46/4 71/11
121/13 123/25 124/3
(64) aware... - below
INQ00001202
INQ00001202
B
below... [2] 135/4
135/13
Ben [2] 53/14 129/1
beneficiaries [1]
72/6
benefit [6] 21/16
24/11 33/23 57/11
107/5 170/3
benefits [3] 41/21
73/12 109/16
beset [1] 225/5
best [13] 4/19 32/10
42/10 82/3 92/25 95/7
113/23 114/12 126/19}
128/17 134/16 146/16)
172/7
Beth [5] 87/5 88/1
89/11 93/15 182/11
better [16] 16/4
27/10 93/3 102/1
114/22 125/13 126/16)
144/22 145/3 157/9
167/21 170/8 172/18
173/4 175/3 176/16
between [46] 5/24
8/12 11/1 11/5 12/12
15/20 28/5 31/8 38/22)
42/14 48/6 48/7 48/8
57/21 59/8 61/22 67/8,
68/22 70/13 85/2
110/3 117/7 119/6
125/19 136/14 138/16)
142/22 154/2 163/6
167/8 176/1 182/1
185/8 188/11 188/13
201/12 203/1 203/8
206/11 212/14 215/3
215/4 216/15 217/19
223/10 228/6
beyond [5] 106/2
125/7 130/10 175/17
200/18
Bickerton [3] 31/17
39/5 49/18
big [13] 7/18 23/2
33/11 95/9 146/8
146/9 146/12 154/13
180/9 182/17 182/21
190/22 211/13
bigger [2] 118/5
160/24
biggest [3] 16/12
131/24 142/23
bill [3] 103/4 227/3
227/13
billion [3] 112/6
112/7 208/9
bills [1] 226/15
bit [39] 5/3 7/22
24/24 79/23 81/9
111/16 112/25 116/19}
116/24 123/19 124/2
125/6 125/15 130/9
146/7 148/10 167/1
168/6 177/10 177/11
177/21 181/22 182/10)
184/23 192/7 192/20
204/10 205/10 205/14,
209/20 210/19 210/25
213/17 215/13 216/23
217/14 217/18 225/8
230/24
bites [1] 198/10
bits [1] 230/11
black [1] 90/24
Blake [10] 113/5
113/9 157/21 158/25
210/15 211/17 219/3
228/23 230/23 233/16
blighted [1] 98/1
blinded [1] 1/18
Blood [5] 47/15
51/14 51/16 97/23
101/16
blows [1] 127/24
board [73] 18/21
21/21 27/24 35/3 35/7
36/7 59/15 62/12
62/19 63/21 66/8 79/2
79/8 81/19 82/24
82/25 91/10 93/3 93/5
93/18 102/5 102/25
118/21 119/2 119/10
121/19 122/15 125/24 I
126/7 127/23 128/8
128/9 132/11 133/11
133/12 133/19 133/21
134/7 134/18 138/7
141/20 142/2 142/7
147/1 151/11 151/12
156/13 162/15 163/3
174/12 174/15 176/5
192/1 192/9 192/15
193/23 195/16 196/4
199/1 199/18 200/6
200/8 204/10 207/5
207/9 208/5 208/7
214/7 214/11 217/7
217/10 221/9 226/8
board's [3] 191/13
193/24 200/8
Boardman [1] 164/10I
boat [1] 209/25
body [3] 101/21
130/25 154/7
Boldon [1] 1/8
bono [4] 98/21 99/3
102/11 102/14
bonuses [6] 66/22
69/17 138/11 138/15
138/22 138/23
books [1] 166/1
both [41] 1/20 5/17
5/17 15/21 24/24 25/8
29/5 32/4 40/17 49/20
53/5 60/11 62/10
62/10 64/8 89/10
89/16 101/1 101/17
116/14 117/18 117/25
118/2 127/4 130/21
137/3 140/5 141/13
149/2 157/1 159/21
160/19 161/17 163/7
176/6 178/20 187/10
218/12 218/13 218/14
232/18
bothering [1] 119/2
bottleneck [1] 225/9
bottom [10] 9/6
42/20 44/19 61/13
61/14 77/8 123/23
129/23 161/23 163/18
bound [4] 25/25
52/13 106/21 213/17
boundaries [2]
189/18 189/20
boundary [1] 189/19
bowl [2] 153/23
154/1
brackets [1] 4/8
branch [5] 75/23
105/10 105/24 162/13
163/1
branches [6] 65/5
65/24 74/19 75/24
75/25 95/19
breadth [1] 43/12
break [8] 51/11 55/7
55/9 55/11 82/2
112/21 173/10 173/13
break’ [1] 164/20
brief [5] 28/13 28/21
117/18 119/25 214/23
briefed [1] 31/15
briefing [2] 117/17
139/18
briefly [7] 115/11
116/12 151/21 159/24:
166/6 202/5 211/22
Brightwell [8] 17/18
31/18 37/6 49/17 87/3
88/2 88/25 93/17
bring [19] 46/16
75/16 82/9 87/23
102/14 116/22 120/22
149/25 159/1 179/14
189/20 190/11 190/11
192/17 197/12 216/17
216/19 217/4 217/14
bringing [4] 140/9
152/5 165/19 183/1
brings [2] 189/15
202/15
broad [2] 133/12
198/3
broader [3] 115/23
153/13 205/10
broadly [2] 118/14
206/15
Brooks [1] 184/17
brought [10] 4/18
8/10 30/17 34/9 34/22
87/24 96/13 148/2
150/2 172/5
Buckland [1] 14/6
budget [3] 105/25
167/2 170/9
bugs [2] 105/9
137/23
build [2] 164/2
184/11
building [2] 147/17
175/20
built [1] 164/13
bullet [8] 18/7 19/1
70/1 70/5 71/18
135/12 150/23 150/25)
bullish [4] 127/6
bullying [1] 78/19
bundle [3] 54/14
113/13 186/3
bundles [1] 229/5
bureaucratic [4] 15/6
19/16 24/12 198/13
business [42] 4/24
5/6 5/10 6/3 7/12 7/16)
7/20 8/2 9/20 9/20
9/23 10/24 14/4 14/5
49/21 59/21 61/22
62/4 63/10 64/17
64/18 65/14 74/3
74/25 75/4 75/12
75/13 75/20 78/1 87/2
89/1 98/8 115/2 116/4
117/13 120/2 157/10
159/19 163/18 171/3
171/11 184/12
businesses [6] 7/18
8/3 8/5 94/15 98/6
98/7
busy [1] 120/5
but [273]
button [1] 216/23
c
calculated [1] 18/8
calculation [1] 24/7
calendar [1] 209/9
call [7] 3/15 68/6
104/17 104/22 124/7
150/15 218/9
Callanan [3] 172/10
172/18 172/25
called [2] 52/3
143/22
calling [2] 105/2
105/14
callous [1] 48/25
calls [5] 13/9 31/25
48/19 151/16 219/7
Calum [2] 104/20
195/13
came [17] 8/7 28/12
30/10 39/14 58/9
85/13 87/4 96/2
102/12 102/16 107/8
127/22 145/15 147/11
150/4 158/22 171/22
Cameron [6] 66/20
123/1 123/19 127/5
134/21 137/4
campaign [2] 38/12
99/8
campaigners [1]
50/14
campaigning [2]
38/6 54/16
can [186] 3/20 4/22
6/10 7/10 7/10 7/14
8/24 8/25 9/6 9/12
17/14 18/22 19/23
21/7 22/9 22/11 22/14
22/18 23/21 24/17
24/19 24/25 25/22
28/24 29/4 29/8 31/12
32/19 37/10 38/1
38/12 40/5 40/6 40/9
42/19 42/19 42/22
44/18 44/18 44/20
45/4 46/1 48/6 48/25
49/25 52/8 53/4 53/5
55/9 55/14 56/9 57/11
57/14 59/14 60/8
60/14 64/13 64/15
66/7 67/6 67/22 68/20
71/21 72/11 72/25
73/1 73/9 73/20 74/1
74/7 75/15 75/15
76/15 77/1 79/16
80/16 83/19 84/15
85/8 87/5 87/19 90/3
91/12 92/6 92/6 92/20)
93/23 99/2 99/16
99/22 102/1 102/23
102/25 103/7 103/12
105/13 108/3 108/11
108/22 109/3 109/10
109/11 110/20 111/14)
112/21 113/10 113/15)
113/19 113/20 113/23)
113/25 114/8 114/9
114/12 115/10 120/22)
123/22 124/8 124/15
129/5 131/20 133/1
134/3 134/11 134/16
134/20 139/9 141/1
146/23 150/14 150/16)
151/7 151/20 153/3
153/16 155/18 155/19)
156/7 156/13 157/3
159/24 160/4 161/4
162/24 163/8 164/21
164/25 168/18 168/19)
169/14 170/12 172/4
179/13 179/17 179/24)
183/4 184/4 186/15
187/19 191/10 197/19)
198/2 198/9 198/22
(65) below... - can
INQ00001202
INQ00001202
Cc 107/7 107/8 108/18 I 70/10 70/19 72/13 130/15 138/6 143/7 I 57/14 57/17 87/19
can 1991 198/95 I 110/19 111/1 111/15 I 73/2 73/6 74/11 74/16) 148/12 89/24 90/3 90/5 91/12
can... [22] 198/25
199/26 202/5 202/23 I 112/2 1128 112/9 I 75/8 82/12 142/21 Ichanged [1] 181/9 I 92/6 92/9 92/15 93/7
203/18 204/15 204/23I 120/6 130/11 131/17 Icentre [12] 63/8 changes [9] 75/1 103/8 109/20 136/13
208/11 209/20 211/22) 134/10 135/16 140/6 I 63/19 64/4 65/6 65/11) 75/2 85/12 115/8 149/21 170/21 170/24)
2412/2 212/18 213/19 I 151/8 155/19 156/15 I 65/23 66/3 74/20 121/7 124/3 124/23 I 177/7 179/12 185/12
218/5 218/18 218/18 I 170/9 171/3 171/11 _ I 75/21 76/1 76/4 76/6 I 143/2 162/13 186/16 186/18 190/8
220/19 226/25 227/24) 175/21 184/12 185/22ICEO [8] 27/23 66/24 Ichanging [5] 121/25 I 190/11 190/14 190/16
229/14 230/10 230/22 I 191/23 195/23 195/24) 82/11 83/14 134/15 I 166/19 168/19 169/9 I 197/20 197/25 198/8
' 195/25 196/12 198/6 I 137/3 137/4 140/20 I 177/18 199/21 208/15 209/20)
can't [17] 20/9 28/20
203/13 203/13 204/5 [CEO's [1] 77/15 channels [3] 10/5 I 211/3 215/28 228/13
soe a OOE ® I 205/8 206/8 21918 ICEOs [2] 117/15 I 10/6 32/3 claimant [16] 21/16
Oe econ I 22116 153/20 charged [1] 143/18 I 24/11 26/4 41/23 60/4
So ate eam [eases [57] 11/23 certain [9] 26/16 31/8ICharles [1] 171/5 I 129/19 174/15 178/25
Rd 17/7 2118 2213 31/8_I 41/12 46/14 95/5 97/6Ichase [1] 195/44 __I 179/17 185/7 186/16
33/9 33/20 34/9 34/10} 177/16 190/19 198/19) check [5] 20/6 25/12 I 203/9 204/7 208/12
candidate [1] 134/16 I 37744 37/12 46/14 certainly [27] 5/21 I 38/16 213/16 226/19 I 211/5 223/13
cannot [1] 99/3
cap [1] 57/18 47/23 48/3 50/13 14/19 26/17 28/3 checked [1] 37/24 I claimant's [4] 16/13
copabilit [3] 164/1 57/10 58/21 59/7 28/20 29/16 33/6 34/4I checking [2] 36/9 57/2 57/21 57/22
Teer 1r/3 66/16 82/14 97/4 36/5 36/21 49/16 60/9) 36/10 claimants [53] 2/3
111/2 117/13 139/7 I 63/18 63/23 66/2 72/9Ichecks [1] 217/24 10/14 10/20 12/13
capable [1] 174/22 I 54/9 4581/2 151/5 I 78/8 78/16 106/2 Icherry [1] 198/10 I 12/15 26/2 35/18 42/1
capacity [12] 9/13
9/18 37/3 74/5 99/6 I 191/8 151/9 151/11 I 107/5 108/13 186/8 I Chesterfield [1] 43/6 45/18 46/22 57/5
116/23 164/1 165/1_ I 197/10 163/22 176/25] 188/19 194/16 198/21I 216/20 57/11 88/5 88/6 88/22!
467/3 167/7 17910 I 178/2 178/5 179/5 I 221/23 222/6 chief [21] 45/9 45/12 I 89/14 89/15 93/12
196/23 179/7 188/16 189/4 Icetera [1] 127/1 45/16 47/11 48/9 I 93/13 99/12 101/4
capture [3] 120/17 I 192/24 199/5 193/14 ICFO [1] 65/19 48/10 48/15 65/18 I 10/6 103/11 110/3
188/22 214/9 196/5 196/9 202/10 I chain [4] 45/8 120/23] 67/21 67/21 67/23 I 136/8 136/11 147/9
care [3] 112/2 11216 I 202/19 206/20 20916 I 124/26 127/18 67/23 69/9 76/24 148/16 160/6 160/23
296/17 213/9 213/18 214/6 Ichair [29] 9/89/19 I 81/18 84/21 104/20 I 160/23 174/17 175/16
cared [2] 6/24 7/9 I 214/11 214/13 214/18) 9/22 10/24 GOI 6O/12I 122/10 122/17 204/18] 176/7 176/17 182/1
career [1] 4/23 215/12 224/14 228/9 I 63/25 69/9 76/25 205/8 182/15 188/17 192/5
careful [2] 14/2 84/5 I0ash [4] 73/20 74/5 I 7/19 78/8 79/7 79/9 Ichild [1] 226/17 198/15 200/17 200/22
Carl [15] 17/19 31/18I 74/9 106/20 84/17 86/7 94/4 95/6 IChisholm [9] 115/17 I 207/24 208/13 209/11
37/6 44/20 49/17 51/1/cateh [1] 117/24 95/23 137/7 138/7 I 116/14 130/20 132/4 I 209/13 209/16 210/4
59/20 87/3 88/2 93/16] Categories [1] 214/4 I 159/4 159/4 159/5 I 137/15 138/17 142/20) 210/6 215/9 226/9
113/8 113/12 155/21 {Category [1] 213/23 I 159/6 159/10 159/12 I 145/19 156/16 228/7
191/15 233/14 cater [1] 98/4 164/11 208/7 220/2 I choice [5] 29/5 29/6 Iclaimants' [10] 27/8
Carmichael [1] Catherine [1] 192/23 IChair's [1] 183/15 I 29/8 90/7 111/19 33/5 99/23 177/23
148/17 caught [1] 185/8 I chaired [2] 79/2 choose [1] 203/12 I 180/10 180/25 203/1
Carol [1] 1/6 caused [5] 55/2 159/12 chose [1] 178/24 203/7 207/14 207/16
carried [2] 11/15 103/18 103/22 138/17I chairing [1] 77/12 IChris [1] 208/7 claimed [2] 21/2
82/16 196/23 Chairman [1] 68/25 IChristmas [2] 209/3 I 79/12
carries [1] 67/22 causing [1] 162/14 I chairs [2] 117/15 211/12 claiming [3] 55/19
carry [5] 14/13 38/1 caution [2] 188/16 I 153/20 Christopher [1] 21/2 I 110/11 193/10
51/2 135/17 158/25 I 221/20 challenge [5] 119/8 Icircumstance [1] _ Iclaims [78] 19/11
carrying [2] 22/5 cautioned [1] 213/6 I 198/16 203/13 209/17I 56/14 19/13 20/7 20/24
1482/7 cautions [5] 212/21 I 228/9 circumstances [6] 20/25 26/21 28/8 30/5
carve [4] 116/21 212/24 213/2 213/10 Ichallenged [3] 13/19 56/13 90/9 30/25 34/17 34/18
case [86] 3/8 8/9 213/11 160/19 205/5 223/16 I 143/16 198/23 199/15I 35/15 36/1 39/18
15/20 16/13 19/23 [Cautious [1] 161/14. Ichallenges [5] 84/24 Icite [3] 35/13 36/24 I 41/11 41/15 45/24
20/11 20/14 20/18 [CC [2] 162/8 163/20 I 85/7 142/23 143/4 I 225/23 46/16 53/1 56/7 58/2
21/20 25/22 27/5 31/2I C9 [1] 192/23 207/24 City [1] 148/7 58/13 58/13 88/22
31/9 32/23 34/7 34/8 (CCRC [3] 11/24 12/2 I challenging [2] civil [12] 15/18 16/24) 91/15 91/22 91/24
36/8 38/4 38/5 38/9 I 39/8 191/18 195/2 18/5 25/8 37/5 48/23 I 92/1 93/6 135/19
48/1 50/21 51/5 54/23I ceased [1] 1/24 chance [1] 81/23 49/16 50/12 78/24 I 151/25 152/3 152/5
58/24 60/22 63/13. [Cent [10] 65/16 80/19I Chancellor [12] 114/18 172/3 187/16 I 160/6 160/16 160/24
68/9 69/17 71/5 71/7 I 91/22 91/24 105/18 I 40/14 42/22 47/4 claim [57] 2/17 13/18) 161/1 161/5 161/6
7219 74/25 75/2 75/4 I 105/20 105/21 119/14] 47/16 48/9 48/12 18/14 18/18 19/19 I 161/11 170/18 172/1
75/18 75/19 75/19 I 176/25 209/6 48/14 48/19 50/5 19/25 20/1 21/1 21/3 I 175/7 175/10 175/13
78/14 78/21 84/6 84/6 Central [22] 61/10 204/20 205/6 205/9 I 21/20 34/20 35/23 176/22 177/10 178/7
85/21 86/1 94/16 96/8) ©3/7 64/7 64/14 64/16Ichange [11] 31/21 36/25 38/13 38/14 179/3 180/16 180/19
96/11 103/22 105/12 I 86/17 67/4 67/8 67/12I 60/4 118/17 122/7 46/3 46/6 46/9 46/11 I 190/20 195/23 200/14
67/20 68/22 70/7 122/16 125/21 128/16I 46/14 46/23 56/20 202/8 206/1 206/1
(66) can... - claims.
INQ00001202
INQ00001202
c
claims... [21] 206/9
206/22 206/24 207/4
209/2 209/8 210/2
210/17 210/22 211/7
211/12 211/14 215/16
222/19 222/21 222/23
223/5 223/5 223/16
225/10 230/6
clarification [2] 2/13
202/23
clarify [1] 231/9
clarity [2] 82/25
163/8
Clark [1] 133/18
clash [1] 149/12
classic [2] 131/1
138/18
classically [1] 150/6
clean [1] 38/23
clear [36] 11/1 31/4
37/6 70/3 74/24 75/14,
78/22 83/4 88/21
90/23 90/23 117/9
117/12 117/14 118/19}
122/14 125/23 130/21
148/5 152/8 155/3
155/7 155/11 157/22
158/22 160/21 177/8
188/20 189/14 189/17
192/13 210/16 215/11
218/5 218/8 221/4
cleared [2] 97/4 97/8
clearly [11] 14/7
43/21 46/21 53/5 68/2
75/23 82/11 107/22
133/23 144/12 231/2
client [1] 179/18
clients [3] 180/23
222/18 227/9
close [6] 1/22 126/18
160/6 200/22 215/16
226/16
closed [2] 196/9
201/17
closely [7] 117/10
145/1 174/13 188/23
217/24 219/15 219/21
closing [1] 201/16
closure [2] 183/1
192/15
Co [3] 9/8 97/9 98/21
Co-Chair [1] 9/8
coalition [1] 10/3
cognitive [1] 226/8
cohort [11] 145/12
146/19 176/6 200/14
211/5 212/11 212/15
213/17 229/10 229/14
231/4
cohorts [1] 212/8
cold [1] 171/25
collective [1] 177/14
collectively [2] 29/10
105/7
collects [1] 75/25
combination [1]
121/16
come [47] 6/13 9/1
16/22 22/9 22/16
64/13 64/19 68/4
75/12 90/4 91/6 93/24
96/21 102/9 103/16
109/8 110/24 117/21
122/13 134/2 143/1
144/8 145/11 145/22
148/4 156/23 157/25
165/23 166/7 168/6
175/7 175/18 179/3
179/5 182/18 200/13
200/17 202/20 205/17
206/10 207/1 208/10
209/2 209/9 216/20
222/17 230/25
comes [6] 23/3 88/14
156/11 180/8 180/13
227/2
comfortable [8]
128/20 161/9 163/4
181/17 183/18 183/21
195/2 219/9
coming [7] 59/24
78/8 120/1 123/5
153/20 194/23 206/22)
comment [4] 18/7
28/21 136/1 165/5
commented [1]
174/21
comments [7] 18/4
26/23 28/13 181/10
184/7 186/21 200/5
commercial [4]
118/23 149/12 150/6
154/11
commercials [1]
116/4
commission [2]
151/2 173/20
commissioned [1]
220/22
commitment [11]
84/22 85/6 162/5
162/7 162/20 162/21
162/24 163/7 163/11
163/13 209/8
commitments [1]
154/19
committed [1] 21/17
committee [21] 9/20
9/21 9/22 10/1 10/10
13/9 32/25 79/20 80/8)
88/10 101/17 101/18
101/22 102/23 159/3
159/5 159/5 161/22
164/11 204/6 207/11
Committee's [1]
66/21
common [13] 20/20
21/15 24/21 38/18
122/13 126/4 126/14
129/3 129/8 129/9
129/15 129/19 138/1
Commons [3] 178/19
188/21 194/1
Comms [2] 184/19
184/19
communicate [1]
35/25
Communities [1] 6/8
community [2] 149/3
179/11
companies [1] 23/2
company [46] 84/24
103/3 117/14 117/16
122/3 122/17 123/6
126/20 127/3 131/4
132/6 132/15 132/19
137/9 138/19 140/3
141/5 141/19 142/13
142/15 142/16 143/10
145/1 147/15 149/15
149/25 152/2 153/21
153/21 154/16 154/24:
155/3 161/19 163/8
163/10 167/23 168/10:
168/14 173/6 216/16
217/2 217/9 217/12
220/14 220/15 220/17
company's [1]
121/21
compared [3] 105/20
124/6 180/7
comparison [1]
18/22
compelling [1] 68/8
compensatable [1]
190/17
compensate [6]
17/12 24/5 24/14 41/5
49/3 212/23
compensated [2]
26/5 26/8
compensating [1]
23/6
compensation [132]
2/5 8/14 9/16 10/7
10/15 10/21 12/7
12/15 13/10 14/18
14/21 14/22 14/23
15/4 15/18 16/8 16/20
17/2 18/9 20/4 21/18
22/23 23/3 23/4 23/10
23/11 23/12 23/13
23/15 23/22 23/25
24/1 24/17 24/22
25/14 27/1 27/3 28/3
32/10 32/13 32/21
33/4 33/12 33/14
33/24 34/6 35/3 35/22
36/6 36/11 37/20 38/7
39/9 39/15 39/18
39/20 39/24 40/3 40/5
40/15 40/19 40/21
41/3 41/18 43/7 43/14
44/11 44/14 47/5
47/15 49/10 51/18
54/17 55/15 56/2 56/3
56/14 57/5 57/9 57/17
59/3 66/16 79/13 87/1
87/16 91/9 91/17 92/3
92/24 93/18 94/12
94/14 94/18 94/24
95/10 95/12 96/23
98/14 98/17 98/20
98/25 99/9 100/24
101/23 102/1 102/5
108/23 112/3 112/10
119/24 135/20 136/7
143/18 166/25 168/8
170/14 171/13 171/17)
172/2 174/4 175/17
189/17 200/4 201/19
201/23 208/5 210/13
212/23 212/25 225/13
225/17 226/25
competence [1]
168/24
competent [1] 77/4
Competition [1]
114/24
complacent [1]
138/12
complaining [1]
220/3
complaint [2] 24/20
25/23
complaints [1]
169/14
complete [5] 92/5
152/21 208/3 208/15
211/14
completed [3] 200/3
210/22 228/14
completely [15] 15/1
15/2 30/2 52/14 53/4
74/22 93/18 106/7
107/2 111/2 130/7
141/10 177/16 184/8
225/18
completion [1]
187/11
complex [11] 14/25
15/19 24/8 58/2 152/3)
180/16 206/6 206/8
206/18 206/21 206/24
complexity [1] 16/12
complicated [2]
14/24 18/12
complicated/getting
[1] 18/42
complying [1] 66/22
compound [2]
160/18 160/20
con [3] 109/7 109/20
109/23
concern [21] 21/12
29/2 58/18 82/20
124/24 128/4 128/12
132/7 134/10 141/3
142/4 162/12 164/13
167/24 167/25 179/16)
179/23 194/5 194/20
212/6 215/18
concerned [16] 13/3
19/14 19/14 73/6
79/15 90/12 94/6
121/20 122/2 126/15
133/19 141/5 165/18
191/20 192/7 215/2
concerns [33] 35/25
42/5 47/5 59/5 59/21
80/5 105/1 106/18
107/14 116/17 125/2
127/21 128/5 128/7
130/2 131/25 132/2
133/7 133/12 134/6
134/18 136/18 141/18)
141/21 142/15 142/18)
144/1 169/18 174/13
191/11 199/5 216/6
222/19
conciliatory [1]
122/1
concluded [4] 108/4
127/13 173/3 224/18
concludes [1] 170/20}
conclusion [5] 12/18
48/5 125/12 196/9
219/25
conditions [2]
227/12 227/13
conduct [1] 108/6
conducted [1] 11/19
conducting [1]
220/15
conferences [3]
62/20 62/21 71/9
confidence [10]
23/14 26/4 62/5 105/8
123/11 125/10 128/1
157/6 160/13 217/14
confirm [6] 113/20
113/23 113/25 114/9
114/12 229/1
confirmed [4] 68/21
121/14 161/2 226/11
confrontational [1]
149/23
confusion [4] 3/4
86/5 201/15 212/22
connection [1] 32/21
Connolly [1] 192/23
cons [9] 108/16
108/20 109/4 109/19
166/20 166/22 172/15)
186/24 187/4
conscience [1] 86/24
conscience’ [1] 12/3
consciousness [1]
(67) claims... - consciousness
INQ00001202
INQ00001202
c
consciousness... [1]
50/18
consensus [2] 124/5
178/18
consequence [4]
1/13 13/2 15/13
144/11
consequences [2]
110/25 145/22
consequential [6]
58/19 66/17 67/4
144/21 174/24 180/18)
Conservative [1] 5/2
consider [14] 42/1
47/25 83/24 100/20
102/1 130/16 134/16
144/13 166/13 171/15)
177/18 178/17 184/14}
194/1
considerable [2]
29/20 77/22
considerably [2]
1/23 18/11
consideration [8]
2/20 3/2 14/3 26/12
64/9 193/15 193/25
199/11
considerations [8]
42/11 155/23 155/23
156/7 156/8 156/21
156/22 181/12
considered [1]
196/13
considering [1]
considers [1] 164/23
consistency [2]
176/8 182/1
consistent [1]
175/25
constantly [2] 82/18
153/22
constituent [2] 96/2
96/9
constraint [1] 196/23
constraints [3] 73/20
74/10 74/14
constructive [1] 86/2
constructively [1]
consult [1] 18/20
consultation [5] 56/5
199/2 203/3 203/8
221/5
consulted [4] 156/19
184/9 184/10 200/5
consulting [3] 184/4
195/12 195/12
contact [5] 20/11
77/9 77/11 78/16
80/21
contacted [3] 10/17
10/23 22/1
contacting [2] 11/4
97/9
containing [2] 70/12
113/14
contend [1] 1/17
content [1] 85/5
contention [1] 207/3
contentious [6]
153/10 156/10 156/20)
160/8 214/16 215/13
contents [2] 4/19
52/14
contest [1] 27/1
context [4] 9/13
71/19 86/6 137/5
continue [5] 22/11
55/14 164/7 199/22
231/23
continued [9] 1/9
1/15 8/16 31/15 44/8
132/1 140/17 194/17
195/4
continues [10] 20/21
41/1 43/15 47/2 53/24
61/25 84/19 101/18
133/22 155/17
continuing [5] 13/14
51/5 199/14 200/10
225/15
contract [1] 188/3
contradict [1] 89/1
contribute [1] 160/18)
contribution [2]
55/20 71/6
contributory [1]
196/20
control [5] 70/2
155/23 156/7 156/21
222/16
controversial [1]
50/1
conversation [28]
34/4 36/5 37/5 48/5
48/21 60/10 63/12
63/24 64/12 74/17
79/18 91/9 93/1 93/14
117/25 125/5 128/11
133/16 142/22 151/22)
165/22 168/22 180/24'
182/9 189/10 207/4
207/10 226/12
conversations [15]
28/3 50/22 59/19
65/17 71/8 118/8
125/8 136/8 142/21
145/16 168/10 171/23)
176/13 194/21 217/2
convicted [9] 10/14
10/20 12/9 12/16
12/25 170/14 176/7
188/17 213/24
conviction [8] 27/15
27/20 29/25 34/24
40/24 87/8 97/10
175/19
convictions [25]
18/23 28/11 41/10
51/7 80/9 80/10 91/25
95/21 95/22 97/8
120/17 120/18 163/24:
170/19 187/12 187/14
190/3 190/3 202/2
211/21 228/25 229/2
231/4 231/5 231/16
convince [1] 157/2
convinced [1] 170/6
convoluted [1]
198/13
Cooper [27] 77/17
115/22 123/9 124/12
125/1 125/3 125/9
125/11 125/19 128/10
129/24 131/3 131/21
132/20 147/4 151/9
151/17 159/15 161/6
162/6 162/12 219/1
219/14 219/17 220/4
220/21 221/14
Cooper's [1] 219/5
cope [3] 98/1 99/2
214/10
copied [4] 14/4 42/13
87/4 88/1
copy [3] 3/24 12/18
12/20
core [11] 1/6 1/25 2/1
86/15 115/14 115/19
154/10 155/14 165/19)
210/11 225/11
corporate [2] 116/8
128/9
corporately [1] 27/24
corporation [1]
156/12
correct [30] 2/23
4/11 5/1 5/12 5/16 9/5
48/7 67/7 113/17
114/19 114/20 114/25
116/9 119/17 135/3
136/25 137/13 145/5
162/1 174/1 190/9
198/20 205/23 206/2
206/16 223/4 228/20
229/4 230/1 231/8
corrected [1] 96/20
correction [2] 4/1
4/18
correctly [1] 156/25
correspondence [6]
52/3 115/15 193/3
216/9 224/9 224/14
cost [20] 41/17 41/18
43/9 54/1 57/14 64/4
65/25 70/2 70/4 72/14
73/14 73/25 74/6
74/21 81/5 81/17
153/12 170/22 191/20
191/22
costing [1] 53/21
costs [54] 12/6 41/19
61/10 63/7 63/19 64/7
64/15 64/16 65/6
65/22 65/23 65/24
66/17 67/4 67/8 67/12
67/20 68/11 68/22
69/22 70/7 70/10
70/19 72/6 73/2 73/6
74/1 74/2 74/11 74/16
75/8 76/3 82/12 109/1
109/14 110/25 112/3
112/5 112/6 129/4
129/9 129/17 129/19
130/8 131/8 149/4
149/7 154/25 160/17
160/19 160/21 194/5
194/8 194/20
could [98] 7/2 20/12
26/25 27/4 29/20
30/22 34/18 34/18
34/25 35/9 37/14
37/19 37/20 38/23
41/8 47/25 50/2 51/3
51/11 52/16 57/3 57/7,
57/19 57/21 68/11
68/16 69/5 74/10
76/21 76/22 87/12
87/24 87/25 88/15
88/17 90/7 90/8 100/4
100/19 110/4 110/8
110/15 111/25 116/10)
116/12 120/25 123/16)
123/17 128/25 137/10)
141/6 141/15 147/14
150/11 150/19 152/4
152/22 153/5 153/12
155/3 156/18 157/15
157/18 158/21 161/17)
161/21 163/10 163/13)
164/14 164/24 166/6
167/22 169/6 170/4
170/10 172/5 176/21
179/7 179/12 190/5
190/7 190/10 190/11
190/11 190/19 192/18)
192/21 196/13 199/15)
199/22 201/17 204/14)
213/2 213/7 214/21
226/7 226/13 232/3
couldn't [4] 55/2
155/8 158/23 190/2
counsel [4] 122/10
122/17 129/1 221/6
count [2] 131/23
163/8
counter [1] 194/16
counterfactual [2]
187/1 187/7
counterpoint [1]
116/24
coup [4] 124/7
125/16 126/3 126/13
couple [10] 37/22
121/17 128/24 144/24)
172/9 183/6 183/16
214/4 229/9 230/10
course [37] 1/18 3/6
14/10 15/2 16/22
21/11 34/17 49/3 52/5)
60/5 63/16 67/13 68/8
76/21 94/13 97/20
108/21 110/19 112/3
112/14 115/12 118/12)
120/7 124/9 124/18
130/22 131/10 142/8
143/20 156/9 166/8
180/22 199/7 201/7
202/9 221/4 228/10
courses [1] 14/1
court [19] 11/23 24/6
95/20 97/5 97/7
107/10 107/12 129/7
130/6 131/22 141/24
151/3 170/19 213/25
214/8 214/13 214/19
214/20 214/21
courts [3] 24/14
139/8 213/19
cover [2] 218/20
226/3
covered [6] 16/3 17/3I
23/18 195/17 213/23
227/14
covering [1] 159/10
covers [1] 45/21
Covid [1] 119/19
CPS [1] 212/10
cracks [1] 188/13
Cranston [4] 30/17
34/23 196/25 197/21
create [6] 41/24
115/20 116/23 137/8
154/6 164/14
created [1] 115/18
creates [1] 154/3
Creswell [21] 17/19
31/18 37/6 44/20
49/17 59/20 87/3 88/2
88/25 93/17 112/14
113/7 113/8 113/12
113/13 115/5 173/15
218/25 222/12 232/18
233/14
criminal [3] 12/17
151/1 163/22
criminally [1] 170/14
criteria [9] 135/20
188/5 195/10 195/11
197/4 197/8 197/8
197/25 214/2
critical [6] 25/2 29/18
122/5 137/9 137/25
177/20
criticising [2] 95/2
102/6
criticism [10] 19/20
(68) consciousness... - criticism
INQ00001202
INQ00001202
c David [5] 31/17 39/5 deciding [1] 156/12 I 171/16 172/4 184/15 Idescription [1]
—____________I 39/17 49/18 96/13 n [22] 22/14 I 218/7 203/14
eons yl David Bickerton [1] I 27/14 28/7 28/15 Idemand [1] 14/2 _Ideserve [1] 146/22
147/93 148/6 196/22 I 49/18 28/19 45/4 66/21 Idemands [2] 35/15 Idesign [7] 94/8
1498/4 222/2 Davies [1] 96/13 76/11 107/22 124/5 36/2 171/16 174/1 176/10
criticisms [6] 138/13 day [23] 5/14 7/3 129/3 130/5 137/25 Idemocracy [1] 11/10I 176/11 181/2 208/22
147/18 174/18 174/23] 09/17 55/1 63/1 63/1 I 138/9 151/3 162/15 Idemonstrable [1] designed [3] 147/21
492/12 192/14 63/9 63/9 65/9 65/9 I 168/15 169/4 1814/7 I 183/2 175/12 187/13
critics [1] 35/6 97/25 97/25 98/4 98/4I 195/25 205/12 214/22I deniability [1] 165/14] desirable [1] 130/15
cross [3] 4/14 35/5 I 1006 100/11 106/20 Idecision-making [1] Idenial [3] 13/19 desire [5] 127/23
189/10 152/24 184/16 184/24) 2 127/8 127/16 174/6 182/24 185/9
cross-party [1] 35/5 I 218/21 23017 232/23 Idecisions [2] 74/22 department [74] 5/5 I 185/12
Crown [2] 105/6 day's [1] 54/19 160/11 6/24 16/14 17/19 30/3I desk [1] 28/13
151/3 days [7] 34/16 77/13 IDectan [5] 151/2 36/22 49/21 56/4 58/4I desperate [1] 21/9
crudely [1] 167/19 I 107/25 123/18 149/17/ 151/6 156/3 156/5 I 59/10 72/23 72/24 Idespite [1] 68/14
crystal [1] 90/23 209/5 229/9 169/11 73/22 78/12 87/2 89/1I despotic [1] 11/18
crystallisation [1] [DBT [11] 2/25 27/9 /dectare [1] 212/3 I 93/9 115/7 115/14 I detail [6] 20/24 21/8
43/11 27/9 27/19 42/4 49/20I deed [5] 143/24 115/19 117/6 120/21 I 139/12 207/14 214/25
CST [5] 45/8 4e/15 I 59/1 57/24 59/9 59/20I 14/3 169/16 174/8 I 130/18 130/20 130/23] 215/16
48/15 19512 195/4. I 119/23 196/7 130/24 133/24 134/14] detailed [5] 36/14
culpable [1] 147/25 de [10] 151/18 deepest [1] 2/8 138/18 139/2 142/15 I 37/21 57/8 74/6 134/9
cultural [3] 142/18 I 151/20 151/21 155/19I defects [1] 105/9 145/2 146/3 149/16 I detailing [1] 35/15
143/4 149/12 159/14 159/17 160/5 Idefence [2] 30/4 152/15 153/7 154/10 Idetails [6] 19/11 36/2
culture [10] 25/24 I 160/22 161/1 161/11 I 221/24 154/17 155/13 157/2 I 118/12 126/16 135/11
66/9 81/24 138/5 [de minimis [10] defensive [1] 124/2 I 159/19 160/3 161/13 I 160/1
138/6 142/16 142/24 I 191/18 151/20 151/21I deficiencies [1] 9/15 I 161/19 162/23 163/25] detain [1] 108/11
142/25 143/6 168/24 I 195/19 159/14 159/17I defined [1] 146/19 164/12 164/23 165/13I detect [1] 67/19
current [15] 2/15 160/5 160/22 161/1 I definitely [9] 31/9 165/20 166/25 167/2 I deteriorated [1]
161/11 56/10 64/4 71/5 93/16] 169/8 170/4 172/1 227/13
Seo Sane 1a0/45 deadline [3] 208/14 I 110/4 137/14 206/8 I 172/11 173/5 183/17 Idetermine [2] 129/9
132/16 135/10 178/20I 208/17 209/22 210/1 193/3 193/8 193/13 I 200/9
215/1 216/3 216/3 deaf [1] 138/11 definition [2] 228/2 I 195/21 197/12 197/24I determined [3] 40/17
217/5 225/6 deal [9] 16/18 24/6 I 228/17 198/7 199/24 202/20 I 129/22 214/19
currently [6] 110/14 66/19 122/10 134/17 Idefinitions [2] 225/14 225/20 231/17I determining [2] 24/1
1415/1 184/4 193/11 152/7 152/10 215/15 I 162/14 163/1 231/24 24/21
493/24 200/19 224/20 degree [2] 36/23 IDepartment's [8] _ I detriment [1] 15/1
customer [1] 64/19 dealing [10] 1/11 182/7 29/6 115/10 135/15 I develop [2] 25/22
customers [1] 65/9 28/2 50/13 106/19 delay [3] 90/16 90/17} 150/9 159/2 163/21 177/23
cut [6] 22/21 63/19 115/14 115/23 120/5 I 162/14 165/21 193/4 developed [1] 74/7
65/6 65/13 65/15 132/16 225/9 231/21 Idelayed [1] 162/17 Idepartmental [6] developing [1] 185/6
74/10 deals [1] 216/21 delays [6] 36/1 31/17 32/3 39/4 79/12) development [1]
cutting [4] 64/14 dealt [8] 14/22 105/24 222/14 223/24I 155/12 228/7 130/1
BANeTA/16 1965/5 I 101/23 125/8 159/23 I 225/6 225/15 departments [1] developments [1]
———____—_——_I 167/22 172/1 177/7 Idelegated [1] 176/23 I 155/14 118/13
D 206/14 delegation [5] 177/4 Ideparture [2] 79/14 Idevices [1] 13/17
daily[1] 76/7 debatable [1] 155/6 I 178/4 202/5 202/6 85/22 diagram [1] 230/24
damage [1] 134/4 [debate [1] 148/18 I 202/12 depend [2] 98/7 did [72] 5/25 8/8 8/10
damaged [4] 97/24 IDecember [11] 72/16Ideliberately [2] 16/25, 111/8 8/24 14/12 14/13
97/24 97/24 97/25 I 117/3 136/1 142/8 I 186/13 dependent [3] 14/15 16/24 19/10
damages [1] 130/10 143/25 144/11 146/13I delicate [1] 166/22 I 117/22 118/22 177/25I 23/9 25/6 26/22 27/24I
Darren [4] 9/3 9/11 153/7 157/23 194/10 Idelineated [1] 143/24Idepends [1] 117/19 I 33/25 35/25 37/14
9/14 9/19 196/7 delineation [2] 117/8 Ideposit [1] 166/1 37/25 39/2 46/3 48/15
dashboard [1] December ‘19 [1] 118/19 depth [1] 153/14 48/19 49/12 50/8
134/13 117/13 deliver [8] 23/13 Deputy [2] 17/23 50/21 51/10 51/25
data [8] 44/22 182/14Idecent [1] 81/23 73/20 75/15 81/19 I 31/19 55/25 59/5 63/5 63/15
184/11 212/9 212/17 Ideceptive [1] 206/5 I 149/24 181/18 181/20Idescribe [3] 72/25 I 64/22 65/14 67/19
249/47 217/22 217/23) decide [10] 28/10 I 181/24 1141/7 144/8 76/12 77/9 77/18
date [8] 192/2 200/2 49/12 110/19 110/22 Idelivered [1] 23/15 Idescribed [9] 12/2 I 77/22 78/25 80/10
200/2 200/7 200/9 156/18 187/17 190/5 Idelivering [6] 77/5 I 14/17 17/10 21/8 44/1I 81/14 85/8 91/13 96/8}
200/19 200/25 201/21) 201/11 221/9 227/8 I 166/12 174/14 174/22I 75/9 126/2 171/22 96/12 102/13 106/18
dated [7] 3/25 17/16 Idecided [4] 125/21 I 182/6 207/5 204/6 108/7 118/7 128/5
40/11 40/11 42/24 136/21 167/11 187/17I delivers [1] 73/12 describes [1] 3/4 128/7 128/7 129/15
113/16 114/5 decides [2] 84/8 delivery [8] 43/3 describing [3] 18/25 I 137/14 141/12 146/13
111/11 43/14 70/3 163/22 32/2 219/10 147/1 159/19 165/16
(69) criticism... - did
INQ00001202
INQ00001202
D 189/3 215/7 discussion [6] 73/7 I 131/1 136/21 144/13 I 54/22 60/7 64/6 68/1
did.. [14] 160/16 IAirectly [9] 19/4 22/2 I 11271 181/4 1991/8 I 145/21 149/13 154/1 I 72/2 74/17 7616 77/25}
168/4 17619 181/10 I 32/4 65/24 74/19 78/5I 215/14 220/12 154/20 155/4 156/14 I 79/2 79/18 85/11 89/6
185/3 194/1 194/19 I 106/17 193/20 194/8 Idiscussions [6] 2/25 I 163/6 164/1 166/18 I 90/20 93/25 96/8
203/8 203/11 215/18 Idirector [16] 31/17 I 96/25 174/8 188/4 167/7 168/12 170/8 I 96/12 100/17 102/23
d19/2 219/13 220/16 I 31/18 31/19 65/18 I 206/20 230/17 4170/9 171/12 172/4 I 103/12 106/17 108/7
225i 65/19 114/22 115/1 Idisgraceful [1] 11/2 I 173/24 174/18 177/3 I 110/13 111/4 111/11
didn't [38] 14/11 115/19 146/25 162/23Idisingenuous [1] _I 177/18 178/12 178/17I 111/24 112/2 112/6
16122 17/1 17/12 20/8I 184/17 165/12 165/18] 184/25 180/1 186/13 187/19 I 117/11 118/9 119/9
20/19 21/24 28/6 166/14 171/24 220/6 Idisplay [1] 59/17 _I 188/14 189/9 189/9 I 145/17 147/14 152/21
28/22 29/7 54/20 _ (Directorate [1] displaying [1] 219/23] 190/24 194/18 194/19] 156/17 165/13 168/3
54/24 58/16 63/23 I 166/13 dispute [10] 30/21 I 195/10 199/3 199/17 I 169/22 169/24 169/25]
84/10 80/14 90/16 IAitectors [3] 59/15 I 130/25 144/5 148/15 I 200/2 200/24 200/26 I 179/14 179/21 179/25
913 119/1 119/7 152/19 182/22 178/2 196/5 199/22 I 201/2 201/4 201/10 I 180/1 181/4 185/20
126/21 127/20 128/16) dirty [1] 221/22 203/20 216/22 217/19] 201/13 202/20 203/5 I 186/6 188/3 194/14
429/13 133/15 133/16I 418 [1] 171/4 disruptive [1] 168/20I 203/16 209/15 215/1 I 206/19 206/22 208/13
4140/1 144/9 14418 I4isagreement [1] _Idissatisfaction [1] I 216/10 218/5 220/18 I 216/4 216/8 219/25
146/11 149/23 170/8 I 126/9 135/9 220/19 220/20 220/21) 221/1 22/6 223/1
481/13 214/1 218/8 Idisappointment [4] Idissatisfied [1] 220/22 221/25 222/6 I 227/14 227/14 230/14
219/17 220/18 226/6 I 43/24 139/19 140/15 I 105/19 223/14 223/18 224/13) 231/18 232/10 232/14I
died [3] 1/7 225/12 I 140/25 dissuade [1] 128/18 I 225/13 225/16 225/16Idone [29] 13/12
225/17 disastrous [1] 60/9 Idistance [1] 165/4 I 226/5 226/7 227/5 I 16/10 25/7 27/9 30/8
differ [1] 48/15 discharged [1] distinct [2] 117/1 I 230/2 58/15 68/3 68/16
difference [3] 33/11 I 211/25 216/13 Docs [1] 161/24 68/17 72/9 76/13
48/8 178/8 discipline [2] 79/5 distress [1] 180/12 Idocument [11] 78/21 79/4 83/11
differences [1] 215/3I £2 distributed [1] 104/17 105/13 117/4 I 98/21 99/1 100/12
different [41] 10/5 {disclose [4] 33/21 I 136/11 136/15 138/25 157/22I 102/10 104/1 104/1
14/05 15/21 20/12 I 26/25 66/14 137/21 Idistribution [1] 9/12 I 179/21 216/5 22113 I 134/9 140/2 158/7
27/11 30/2 30/11 36/7I tisclosed [3] 72/23. Idivision [1] 118/16 I 221/11 221/12 165/17 165/17 183/20
39/13 40/21 40/22 I 82/14 82/17 do [182] 4/11 8/16 Idocument in [1] 205/4 219/19 232/11
56/22 58/7 58/7 gale (disclosure [20] 17/5 I 8/22 14/19 16/4 16/19] 216/5 door [5] 89/4 89/7
64/23 65/20 80/7 32/18 32/21 33/3 19/10 19/23 20/8 Idocumentary [1] 95/12 152/4 183/3
82/18 99/19 107/2 I 33/22. 34/3 34/19 21/17 22/18 23/19 I 200/12 double [1] 194/23
117/5 124/5 125/18 I 21/25 66/16 66/23 24/8 25/4 25/5 26/10 Idocumentation [4] [doubled [1] 120/15
4130/7 142/24 144/16 I 82/12 96/5 165/8 27/11 27/22 28/10 162/8 162/17 162/22 Idoubling [1] 78/10
1454/9 156/2 164/22 179/20 179/23 180/1 I 28/16 29/1 29/13 196/1 doubt [8] 21/16 24/11
1467/5 167/10 168/6 224/2 224/18 224/20 I 31/10 33/17 34/1 documents [5] 4/13 I 53/13 72/4 77/13
1469/4 172/16 174/19 225/1 35/11 36/7 40/2 41/19] 11/3 138/16 179/13 I 107/5 120/11 225/5
177/5 1821 203/5 Iiscovered [4] 82/15] 42/17 44/3 44/5 44/8 I 191/6 doubts [1] 77/20
205/17 214/4 82/15 140/19 196/4 I 44/10 44/17 46/8 46/9Idoes [14] 18/17 down [39] 3/12 7/22
discovery [1] 137/20 I 48/23 49/7 49/23 24/17 49/9 49/10 20/7 22/9 29/24 29/25)
dirtiest 4) i 18] discrepancies [9] I 49/25 50/7 50/9 50/25I 69/16 88/9 92/4 95/12I 30/10 30/23 34/17
49/14 56/23 64/21 105/22 106/19 106/20I 51/3 51/6 56/11 57/1 I 105/8 117/21 158/3 I 42/20 45/6 58/9 64/13}
71/10 76/8 83/6 106/21 107/16 108/9 I 58/22 59/24 62/22 160/10 161/13 225/14] 87/25 104/23 105/13
100/13 102/18 128/3 I 216/11 216/18 216/21] 63/11 63/20 64/2 65/2/doesn't [17] 16/15 111/12 111/21 120/7
167/6 179/11 186/18 Iiscretion [3] 129/18] 65/4 65/6 67/7 67/15 I 20/15 23/14 24/10 120/25 129/17 131/23)
22/7 177/16 228/18 71/6 72/10 73/22 43/19 54/3 71/1 76/11] 134/11 136/24 137/18
difficulties [3] 67/25 discuss [12] 31/21 I 73/24 74/14 75/6 88/8 128/1 163/12 140/23 142/20 150/16)
164/4 168/5 60/2 96/3 106/18 75/12 75/21 76/3 76/6I 163/15 167/19 175/22) 150/19 159/13 160/6
difficulty [6] 46/20 120/11 126/24 133/18] 76/23 76/25 80/6 179/8 182/21 209/13 I 161/4 161/5 161/23
76/12 98/10 104/15 I 151/10 168/4 199/2 I 85/25 87/19 87/20 doing [26] 7/49/25 I 163/17 170/13 181/8
152/25 198/22 217/18 228/4 87/21 90/16 91/14 10/1 10/10 20/5 39/13] 212/7 221/11
ion [4] 191/22 discussed [22] 25/25] 92/5 92/6 93/2 93/3 I 56/25 63/9 64/5 68/2 I down please [1]
dimensions [1] 66/1 74/18 95/23 93/19 94/22 95/3 70/14 74/11 80/12 161/5
191/23 106/18 121/12 151/11] 96/19 97/11 97/15 82/1 82/7 85/9 94/22 Idowns [1] 129/11
dipping [1] 194/23 154/4 173/3 174/4 98/11 99/6 99/23 100/7 108/7 134/4 downside [1] 111/7
direct [4] 47/19 50/11 180/9 182/12 184/22 I 99/25 100/14 101/15 I 146/3 169/7 184/5 DPP [1] 12/2
164/5 164/19 191/7 191/13 192/22 I 101/21 102/24 102/25) 187/23 218/1 221/25 IDr [3] 177/21 203/11
direction [16] 42/7 199/1 200/20 207/11 I 103/12 104/5 108/18 Idon't [82] 8/20 10/2 I 215/13
42/8 49/24 50/3 65/21] 208/2 209/21 26/7 I 108/18 109/10 112/12) 17/1 17/11 19/21 24/3] Dr Hudgell [3]
66/5 70/19 81/15 discussing [8] 96/5 I 114/7 117/3 117/17 I 24/3 26/9 28/14 29/3 I 177/21 203/11 215/13)
81/16 116/7 133/7 124/21 187/22 188/7 I 117/18 117/19 118/15) 29/13 30/15 33/22 draft [5] 40/11 121/6
140/17 181/14 1892/5 I 214/7 214/11 224/9 I 118/16 120/10 121/13] 44/13 48/14 49/11 1241/7 121/12 121/16
224/10 128/17 128/22 130/14) 50/4 50/15 52/21 drafted [2] 21/5
dimen:
(70) did... - drafted
INQ00001202
INQ00001202
D
drafted... [1] 121/1
drafting [2] 101/9
101/10
drama [3] 104/19
200/13 201/4
draw [4] 10/3 111/22
175/15 189/19
drawing [3] 11/5 81/5I
200/21
drawn [3] 143/24
183/15 190/15
dreadful [1] 98/11
drew [2] 67/8 144/4
drive [1] 150/1
driving [3] 65/1 128/3I
185/22
drop [1] 75/25
DRP [2] 196/9 196/13,
dubious [1] 132/9
due [9] 69/18 110/6
110/7 112/14 118/12
120/7 159/20 199/7
221/14
dug [1] 20/7
during [10] 1/16 1/18
6/17 7/6 32/16 119/19
124/6 154/15 224/10
231/14
duty [1] 211/19
DwpP [3] 214/6
214/11 214/12
dysfunctional [2]
66/11 66/13
Dyson [1] 202/11
E
each [7] 29/2 36/25
43/6 61/8 126/9
175/25 192/7
earlier [47] 16/7
17/15 22/19 26/23
26/23 35/14 39/11
44/15 45/7 50/24
56/25 81/9 95/5 97/18)
109/5 138/16 141/12
142/4 148/11 148/25
151/23 154/22 156/9
168/23 169/9 169/16
172/15 181/3 186/21
186/25 187/22 189/16)
192/1 204/3 204/24
207/9 209/2 209/24
217/1 217/20 218/10
219/3 224/8 224/15
226/20 230/23 232/13
early [32] 5/24 27/13
30/9 33/8 58/5 58/16
78/4 85/11 98/12
118/6 120/20 123/18
135/16 136/10 137/20)
149/17 149/22 157/7
173/19 173/20 175/13}
188/11 194/11 198/5
200/9 202/10 206/12
209/4 215/20 219/8
219/11 224/24
earn [2] 66/4 66/6
earning [2] 4/9 81/11
earth [1] 53/22
easier [2] 157/8
170/23
easily [2] 68/16 76/21
East [1] 1/8
easy [6] 67/22 67/23
83/9 84/2 117/1
122/10
Education [1] 130/24
effect [10] 37/24
76/23 85/13 89/2
92/21 96/6 149/9
160/14 176/10 186/13)
Effective [1] 69/21
effectively [10] 21/14
87/7 116/7 119/7
142/22 149/6 191/17
194/23 197/10 214/19)
effectiveness [2]
82/23 134/7
efficiency [1] 191/23
efficient [3] 70/3
181/17 181/20
effort [3] 84/23 85/6
138/23
efforts [1] 39/8
eg [2] 47/15 151/16
eg calls [1] 151/16
eight [1] 5/23
either [20] 16/15
18/21 27/25 28/9
73/11 98/13 102/6
102/20 103/13 107/14!
147/5 161/17 185/21
190/1 206/9 209/23
209/23 210/6 219/2
230/20
Eleanor [1] 184/17
elected [1] 4/24
election [5] 5/15 6/18)
52/3 195/5 195/8
element [2] 103/8
156/5
elements [4] 19/19
159/21 159/25 203/12)
elephant [2] 152/7
60/9
elevate [1] 185/23
eligibility [7] 156/4
169/11 188/5 189/17
197/4 197/16 197/18
eligible [4] 188/2
196/8 201/22 210/21
Elliot [5] 59/24 60/2
61/3 61/11 62/10
else [8] 82/10 84/7
87/13 92/23 92/23
97/12 128/2 183/14
elsewhere [2] 74/18
148/14
email [34] 9/2 12/19
12/21 14/11 17/15
17/17 20/12 44/20
44/21 45/7 47/2 51/2
60/15 60/19 94/3
94/14 120/23 121/3
121/15 123/10 124/25
125/11 127/18 129/24
139/3 139/4 140/22
151/20 166/10 167/8
170/11 171/21 182/11
204/17
emails [4] 80/4 87/6
128/24 151/16
embarrassed [1]
122/24
embraced [1] 104/5
emerged [1] 12/4
emerging [2] 196/8
197/15
Emily [2] 184/7
184/12
eminently [1] 108/2
emphasis [4] 76/2
181/22 185/18 218/7
emphasise [1]
126/15
emphasised [1]
141/1
employed [2] 60/19
231/22
employee [1] 105/6
employees [2]
187/25 189/25
enable [6] 13/10
45/24 47/22 143/1
152/2 185/10
encourage [4] 43/12
88/8 88/11 175/13
encouraged [1]
200/16
end [38] 4/8 31/5
37/16 42/21 44/17
62/3 62/9 63/10 83/16
120/15 131/18 141/25
148/6 153/18 156/25
156/25 170/22 181/14
181/23 182/22 187/19
189/12 200/1 200/7
200/25 201/5 201/10
204/25 209/9 209/11
209/11 209/20 209/24
210/5 210/6 223/12
224/2 228/9
ended [2] 194/11
213/6
ENE [1] 202/11
Energy [1] 9/20
engage [4] 98/12
98/24 99/8 151/5
engagement [6]
25/14 62/1 100/18
115/2 120/2 143/2
engaging [1] 96/22
engendered [1]
97/14
England [5] 1/9
212/11 229/10 229/24
231/3
enough [7] 30/25
39/9 146/24 179/20
187/24 215/16 217/25)
enquiring [1] 29/19
ensure [13] 69/22
77124 105/3 134/13
152/3 173/5 176/5
176/7 176/15 187/19
198/15 227/23 228/12)
ensuring [3] 43/5
88/22 105/11
Enterprise [1] 5/10
entire [3] 6/17 100/18}
152/17
entitled [3] 87/8
87/12 87/17
envelope [1] 112/5
environment [1]
167/5
envisage [1] 190/24
envisaged [1] 191/16
episode [1] 13/22
equally [2] 49/6
181/6
equation [1] 72/11
error [3] 137/22
197/6 197/7
errors [1] 105/9
especially [4] 23/1
32/12 162/24 173/18
essential [1] 214/1
essentially [26] 9/23
13/6 15/7 18/7 18/25
19/3 22/5 36/1 43/16
44/23 45/3 54/20
55/18 60/20 60/23
61/6 61/16 61/17
62/16 70/9 72/15
73/13 77/23 100/13
101/5 104/5
establish [2] 35/10
152/16
established [5] 20/19)
30/14 56/2 124/11
191/5
establishing [2]
194/6 211/23
establishment [2]
35/2 114/23
estate [1] 215/23
estimate [7] 145/4
145/14 145/18 146/4
146/16 147/14 158/20)
estimates [1] 147/2
et [1] 127/1
et cetera [1] 127/1
evaluate [1] 14/1
even [27] 8/20 18/9
27/10 37/11 39/16
47/22 75/22 82/2
83/18 96/23 98/24
106/2 112/24 131/16
132/23 140/4 140/16
144/4 157/11 181/25
183/4 185/10 186/4
198/24 203/18 217/8
218/21
event [1] 105/15
events [1] 52/5
eventual [1] 166/21
eventually [2] 51/9
192/14
ever [11] 16/5 27/23
40/3 57/15 60/8 80/15
80/15 102/23 106/17
159/12 177/6
every [18] 41/23 48/4
56/22 68/15 68/15
93/4 104/15 106/20
168/4 178/25 180/25
182/15 183/10 196/24)
212/7 224/14 228/11
230/7
everybody [8] 28/11
46/22 49/6 87/13
91/11 95/2 98/7
201/19
everybody's [4]
14/24 14/25 15/4
56/23
everyone [13] 87/7
87/9 87/15 87/17
87/18 105/5 106/8
122/15 193/9 207/6
209/19 217/15 230/14
everything [9] 11/10
20/10 42/17 44/10
60/7 67/22 80/1 128/2
225/14
everywhere [2] 50/17
50/18
evidence [55] 1/3
2/11 2/13 2/15 2/18
2/22 3/7 11/9 14/16
32/24 33/21 33/22
34/20 37/1 37/2 38/21
54/5 54/20 56/12
56/25 57/11 58/23
75/7 79/20 80/6 81/10)
105/23 107/12 118/15)
122/25 133/10 137/1
139/24 149/8 149/8
149/9 150/8 153/19
153/19 166/17 168/7
176/24 183/6 186/3
202/4 220/1 222/15
222/17 224/10 229/9
230/14 230/22 231/1
231/12 232/19
evidenced [5] 57/2
79/4 79/22 80/15
(71) drafted... - evidenced
INQ00001202
INQ00001202
E exorcised [1] 94/23 I 19/17 20/17 20/23 43/7 43/14 46/18 49/4Ifeels [8] 47/13 63/11
evidenced..[1]) expand [3] 116/10 I 22/6 42/5 48/13 52/17I 49/5 49/6 54/16 54/17I 63/14 63/14 124/2
123/17 188/4 189/20 91/6 140/25 144/41 57/16 111/7 112/4 131/17 163/3 217/21
evidential [4] 55/18 expanding [1] 51/8 I 148/11 162/12 167/24I 112/5 131/2 138/14 Ifees [1] 160/23
55/23 55/25 56/18 expansion [2] 190/22) 168/25 172/18 174/13) 141/10 146/10 152/13) fell [1] 6/19
evidently [2] 5018 I 190/25 215/18 222/19 231/2 I 152/18 154/21 157/6 IFelstead [1] 11/21
88/5 expect [15] 21/18 expressing [1] 157/16 170/3 171/24 Ifelt [49] 10/7 19/15
exact [2] 178/6 46/7 56/13 65/10 66/4I 191/10 174/22 181/22 185/18] 20/6 22/22 23/4 27/6
226/19 77/4 81/12 81/16 expressly [1] 183/8 I 185/24 201/14 205/11) 36/8 44/7 44/16 59/23
exactly [12] 9/25 81/18 107/6 120/1 extend [3] 2/8 41/13 I 207/6 207/7 219/7 62/4 63/2 63/4 63/12
22/8 30/7 38/19 39/16 120/9 138/7 209/7 106/13 fairly [3] 17/10 85/11 I 64/2 64/11 64/12
103/10 104/7 128/24 213/14 extended [1] 13/24 I 117/8 77/19 79/2 92/25
163/16 188/6 201/24 [expectation [2] extension [2] 189/24 Ifairness [4] 110/2 122/7 122/24 123/3
226/16 34/15 36/17 189/25 174/14 174/16 181/25] 123/4 123/6 125/25
example [26] 8/24 expected [8] 54/6 extensively [1] 166/9Ifaith [1] 116/20 127/7 127/15 128/10
20/25 35/19 57/12 56/4 129/13 137/20 Iextent [5] 6/15 40/7 /fall [3] 187/21 188/13} 128/13 128/14 128/20
65/25 72/22 74/20 138/2 151/4 180/14 I 43/10 95/25 120/7 212/3 132/10 133/25 141/8
75/8 114/23 118/7 216/24 external [7] 106/6 fallen [2] 189/1 143/17 148/22 154/22)
1419/3 119/4 135/3 expecting [1] 206/10 I 149/10 195/22 198/7 I 226/23 165/15 166/10 167/4
138/19 161/8 175/19 IexPedite [6] 16/16 I 217/4 231/22 231/25 Ifalling [1] 215/25 167/9 172/21 176/16
177/6 188/15 189/24 I 16/20 57/19 58/13 externally [4] 28/10 Ifallout [2] 219/12 184/23 185/4 192/3
93/6 112/9 47/1 105/3 106/16 I 219/13 208/8 220/14
i ea. expended [1] 54/19 Iexternals [1] 143/1 Ifalls [1] 189/14 fence [4] 118/2
226/18 expenses [3] 12/6 extra [3] 41/18 49/9 Ifalse [2] 11/8 11/9 I few [8] 53/16 77/13
examples [6] 11/20 I 226/1 226/3 175/16 falsification [1] 213/7] 107/25 119/15 121/10
21/22 66/12 66/14. [expensive [2] 138/10Iextracted [1] 149/5 I familiar [1] 51/23 122/5 171/4 207/16
207/11 225/24 194/25 extraordinary [1] I families [1] 49/2 fewer [2] 33/20 90/2
exceeded [1] 153/12 experience [14] 12/23 family [15] 1/22 2/9 Ifield [1] 37/13
49/16 50/9 50/12 extremely [1] 90/14 I 15/24 98/8 188/18 fierce [1] 35/6
excellent [1] 184/8 I 55114 57/4 65/6 96/1 \eye [4] 112/4 126/18 I 189/24 190/7 190/14 Ifight [1] 101/5
except [1] 111/1
excess [1] 18/11 97/3 130/23 166/25 I 139/13 140/13 190/21 226/16 226/21I fighting [2] 99/15
excessive [1] 228/11] 171/25 187/11 201/9 IE——______ 226/24 22711 227/11 I 10111
exchange [5] 17/15. I 209/16 PO) 2297/17 figure [6] 4/11 37/19
63/5 87/1 87/4 204/17) exPerienced [5] face [4] 1/1941/4 fantastic [1] 102/14 I 45/20 54/3 179/24
exclude [1] 16/25 I 19/16 15/17 26/7 41/6 54/18 far [17] 30/23 42/2 I 183/22
excluded [2] 10/22 I 44/18 105/21 faced [1] 25/16 71/21 7316 74/10 figures [6] 40/23
214/5 experiences [1] facilitate [1] 155/22 I 74/15 79/1 79/15 147/6 205/25 206/5
excuses [1] 168/14 I 44/14 facing [3] 84/24 90/11 91/22 95/24 I 228/24 229/23
Exec [4] 65/18 69/9 I@xPert [4] 57/13 115/13 115/16 96/19 131/24 174/13 Ifill [2] 175/1 208/1
76/24 81/18 4109/1 118/22 131/8 Ifact [28] 6/2 17/15 I 189/3 226/7 229/21 Ifinal [26] 31/7 87/14
execs [2] 62/11 experts [5] 37/3 23/9 23/11 35/14 38/2/fashion [2] 61/2 88/6 88/8 88/11 89/3
eari1 37/13 59/1 89/25 74/14 80/3 85/22 94/9I 87/16 89/8 89/15 89/19
executive [18] 59/15 I 231/25 98/2 98/3 98/22 fast [1] 146/2 90/18 90/22 90/25
60/4 65/11 65/13 66/3IEXPG00000007 [1] I 102/20 103/20 107/10Ifast-paced [1] 146/2 I 91/5 93/7 113/19
67/21 67/21 67/23. I 105/17 134/8 153/2 157/18 Ifaster [1] 157/17 114/8 127/17 138/25
67/24 84/21 104/20 I@xPlain [11] 7/10 174/1 181/17 195/17 Ifault [2] 9/17 175/11 I 170/6 178/23 182/19
146/25 154/7 155/15 I 49/1 64/15 69/5 79/16 197/23 199/7 199/13 Ifavoured [1] 172/17 I 182/25 185/10 197/22,
83/19 126/17 151/21 I 206/14 20/5 223/14 Ifear [1] 13/6 199/21 216/3
ona 22016 20/8 I 1ee/6 193/5 198/2 _Ifactor [1] 165/10 _Ifeature [2] 51/17 _I finalise [1] 222/20
executives [3] 66/20 explained [8] 47/6 Ifactors [2] 180/19 111/25 finally [5] 40/11 59/7
69/18 220/17 91/7 93/16 120/4 196/20 February [3] 17/16 I 184/7 200/1 231/11
exercise [2] 15/9 I 126/13 191/3 192/23 Ifactual [1] 222/1 85/13 192/19 finance [10] 65/18
224/18 203/25 fail [1] 41/5 Federation [1] 62/20 I 65/19 154/16 155/24
exercised [2] 129/18 I©%Planation [1] 12/17Ifailed [4] 25/4 76/22 Ifeedback [4] 122/11 I 160/13 161/24 162/22I
221/20 explicitly [1] 127/20 I 137/21 138/10 148/14 203/9 204/11 I 164/17 165/11 165/18
exhibit [1] 197/12 [explore [4] 24/19 falling [3] 123/6 feel [12] 25/25 26/4 I finances [2] 43/5
existed [2] 8/12 10/7 I 42/12 43/20 83/15 I 138/19 146/22 26/25 62/14 90/20 I 104/4
existing [8] 95/10 explored [1] 55/3 _Ifailings [1] 83/9 110/5 110/11 126/24 Ifinancial [15] 36/18
176/20 188/11 190/19I@XPloring [1] 31/5 failure [3] 66/19 149/23 180/11 208/10] 37/2 41/21 69/21
496/15 199/19 199/22\exPosed [1] 139/14 I 68/19 146/9 209/14 69/24 73/14 75/6
227/12 exposure [1] 139/7 Ifailures [4] 17/4 17/5 feeling [5] 60/10 116/8 139/6 155/23
Exoneration [1] express [2] 135/9 I 66/14 79/8 122/19 123/19 127/2 I 156/8 156/22 163/4
190/3 139/18 fair [38] 7/20 8/2 142/12 167/1 170/22
expressed [20] 14/9 I 10/24 14/9 30/6 33/8 Ifeelings [1] 11/14 I financially [2] 15/22
(72) evidenced... - financially
INQ00001202
1NQ00001202
F flashing [1] 131/12 Iformally [1] 223/16 I 113/13 114/5 121/24 Ifuture [12] 16/20
financially...) fat [1] 73/23 formed [3] 5/14 56/2 Ifronts [1] 122/22 27/12 29/14 29/17
153/22 flawed [6] 12/10 17/8I 80/24 frustrated [5] 63/22 I 61/17 62/7 74/6 102/2
find [14] 16/11 26/18 I 24/18 32/18 32/20 former [2] 227/7 122/21 122/23 125/6 I 111/25 130/12 167/23
37/25 62/3 84/7 95/6 I 34/2 227/16 127/4 216/10
1439/5 168/11 177/24 lexibility [2] 154/12 Iforms [1] 208/1 frustration [4] 19/17 ¢..U”~™
4184/5 200/11 212/18 I 163/10 formula [1] 136/12 I 20/17 39/6 138/17, IB
213/20 232/12 flight [4] 83/18 83/20 Iformulate [2] 176/17 IFSA [1] 18/20 gain [1] 182/2
fine [42] 10/9 60/8 I 168/19 168/19 176/21 Fujitsu [3] 12/1 216/9Igap [1] 223/10
75/11 79/24 80/1 floated [3] 39/3 47/8 Iforthcoming [1] 217/17 gaps [5] 188/10
128/16 152/10 201/25] 136/4 68/19 Fujitsu's [1] 137/24 I 188/14 189/5 189/7
211/46 212/20 218/14I floor [1] 87/7 fortnight [1] 168/4 _Ifulfil [1] 123/7 189/8
218/15 Flora [1] 102/13 forward [20] 22/5 full [51] 2/5 3/20 Gareth [3] 117/20
fire [4] 3/6 22/10 _ {flow [2] 33/12 118/23] 45/5 76/13 83/11 18/14 29/7 38/11 188/8 189/13
29/94 25/19 flowed [3] 63/8 63/8 I 99/21 101/9 107/11 I 38/12 43/12 43/14 I Gary [3] 92/13 204/4
firebreak [2] 1653 I 98/12 107/16 125/14 126/18I 51/19 54/16 87/13 I 204/12
4165/11 flowing [2] 17/2 132/19 134/3 175/7 I 88/6 88/8 88/11 89/2 Igas [1] 226/15
firm [3] 148/7 148/12 I 87/17 175/18 179/5 200/14 I 89/8 89/14 89/18 gather [1] 121/17
176/21 Foat [2] 53/14 129/1 I 200/17 208/11 216/11I 90/18 90/22 90/24 _ I gathering [1] 34/12
firmly [2] 144/23 [focus [17] 7/15 69/9 I 216/12 91/4 92/5 92/5 92/18 Igauge [1] 11/13
188/19 69/12 70/3 71/7 88/6 I forwarded [1] 179/22) 93/7 93/7 100/18 gave [13] 2/14 2/15
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1457/3 170/12 172/9 followed [2] 122/4 86/10 94/20 156/25 160/16 160/25 175/20I generally [3] 83/17
232/23 fourfold [2] 33/13 Ifunction [1] 115/23 I 207/7 213/18
oso poole mote following [10] 1/5 I 91/18 functions [1] 115/13 I generating [1] 65/9
203/24 214/24 214/25I 11/24 69/12 106/11 I fourth [4] 70/1 165/5 Ifund [5] 75/1 99/20 Igeneration [1] 77/19
218/16 218/17 122/6 125/22 136/8 I 165/6 165/9 135/18 136/6 155/15 I generosity [4]
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64/15 67/7 follows [6] 87/22 _ I framework [1] 117/4 I 23/17 83/9 103/20
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five [13] 3/9 4/6 18/7 I 140/24 158/3 102/1 23/7 64/7 103/11 111/17 161/7
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408/11 1184 119/18 I 52/8 71/17 85/1 142/11 100/14 140/10 157/3 Igenuine [1] 101/3
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fixed [34] 16/17 27/3 forces [1] 185/22 105/4 151/13 152/21 156/5 I 40/19 46/12 51/13
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51/9 51/16 58/17 37/8 53/19 58/22 freely [1] 227/21 226/13 227/1 227/2 I 89/14 89/20 90/3 90/6
89/17 91/20 91/24 89/25 92/7 173/21 Freeths [9] 12/12 228/8 92/9 93/11 93/12
93/8 100/13 108/16 206/25 207/19 225/2 I 136/11 144/18 145/16] funds [5] 73/24 88/15] 95/12 98/22 99/8
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fixed-sum [18] 16/17 111/6 186/7 117/20 50/15 73/10 73/18 130/3 131/10 132/14
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91/24 109/6 198/17 175/17 friendly [1] 148/20 232/7 175/8 175/16 178/23
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102/4 172/13 203/4 I front [5] 3/24 37/23 I 53/11 164/2 169/13 I 185/16 187/19 192/15
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I Dg/do shorts 205/19I 21514 215/9 222/14 I got [45] 3/9 4/5 8/9 I 45/18 95/18 120/22 I 148/18 148/19 148/20
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getting [30] 18/12
21/10 32/2 33/8 36/9 55/15 71/22 74/15 111/18 112/4 118/19 Iguess [5] 56/1 62/3 I 174/17 176/14 176/20,
37/8 75/22 75/24 76/10 77/25 79/13 126/16 128/13 128/21I 69/17 79/7 92/15 177/1 180/24 182/9
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209/85 216/7 2288 I 121/12 12514 128/15 I 212/17 guy [1] 81/25 193/25 194/3 194/9
2208/9 230/7 230/13 I 136/10 138/3 150/21 I governance [5] H I 194/18 194/26 196/10
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Foe ede ap le aa/ieI 20/2 22/18 26/3 26/7 I 153/17 153/24 153/25I 49/25 50/9 50/11 Inalfway [1] 104/23
28/14 28/23 28/24 154/2 154/19 154/21 I 53/19 53/25 54/1 54/1) Hall [1] 148/17
32/4 34/7 35/10 36/9 I 157/18 167/16 167/22] 54/4 54/4 54/8 57/4 I Hamilton [8] 20/25
45/8 48/12 62/3 65/21I 168/1 169/24 177/15 I 57/6 59/19 60/1 60/10) 22/1 35/19 38/15
53/14 54/14 77/20
79/14 83/23 116/22
128/12 128/19 131/19}
4134/4 134/18 1406/1. I 79/24 83/15 90/6 I 183/9 188/19 189/10 I 62/6 62/17 63/3 63/24I 38/20 140/3 149/20
44719 181/14 161/11 I 90/22 92/4 100/25 I 203/23 209/18 218/11] 64/17 65/17 67/24 I 187/22
104/2 104/2 104/16 I 218/11 68/4 71/8 72/2 76/19 Ihand [5] 54/15 82/1
163/8 163/9 166/11
167/10 170/8 178/13
179/20 182/20 184/24)
186/1 199/11 200/10
104/17 106/3 110/23 IGovernment's [3] 77/20 79/12 79/18 197/1 214/23 223/2
111/18 112/2 113/6 I 6/20 100/17 115/25 I 81/14 82/19 82/19 handed [5] 23/10
115/5 120/20 126/17 IGrant [3] 78/6 79/4 I 83/21 85/17 86/3 23/11 25/19 25/20
126/18 128/19 130/6 I 82/22 86/10 87/1 91/1 91/8 I 104/3
aor 203/9 218/10 131/14 131/18 132/12I grateful [3] 47/17 93/14 95/20 95/21 handful [1] 178/5
143/7 150/22 151/3 I 84/19 96/17 96/1 96/15 97/4 97/4 Ihandle [2] 27/16
gives [1] 206/13
giving [3] 183/1
183/4 198/18
153/1 156/23 158/8 IGratton [5] 77/18 97/8 101/14 105/21 151/18
158/15 163/19 167/10I 117/10 124/13 217/7 I 112/1 117/3 118/6 handled [5] 27/18
Glen [1] 45/13 171/9 173/15 177/24 I 219/16 119/18 119/22 120/12I 27/20 78/5 78/6
GLO [56] 18/15 27/7 186/12 187/24 199/24IGratton's [2] 149/8 I 122/10 122/13 122/23) 142/13
27/18 27/25 28/10 210/11 212/23 216/10) 150/8 123/1 123/4 123/10 I handling [5] 47/18
30/1 30/9 30/18 34/15I 216/11 217/3 217/4_ Igreat [5] 16/18 42/3 124/22 125/1 125/2 I 133/9 148/15 224/14
34/23 40/24 41/5 218/16 224/18 229/7 I 125/20 128/15 138/17! 125/5 125/8 125/12 I 228/8
41/11 41/14 41/23 Igone [7] 18/4 89/18 I greater [4] 30/20 125/19 125/23 126/1 Ihands [5] 30/24
42/2 43/3 43/8 47/23 97/6 111/20 156/4 50/9 85/15 218/6 126/13 127/7 127/12 I 51/19 68/17 76/23
51/9 91/21 120/19 174/14 192/5 Greenhow [1] 104/20] 127/13 127/21 128/12 184/3
136/1 136/8 136/10 I9°0d [26] 3/19 18/15 IGreg [1] 133/18 128/20 128/21 132/2 Ihappen [19] 8/22
143/24 144/17 145/16I 24/16 25/7 63/1 66/14/Grenfell [1] 101/16 132/4 132/22 136/3 I 16/5 28/6 30/22 31/10}
76/15 82/1 85/10 GRG [4] 7/19 136/4 136/5 137/21 I 63/23 65/10 68/14
146/15 151/24 175/25)
176/6 176/6 176/11
176/17 176/20 190/4
190/13 194/14 197/5
197/21 198/8 204/14
91/18 95/1 104/12 grievously [1] 13/20 I 138/20 139/25 140/3 I 99/7 104/7 107/6
104/14 112/16 118/19Igrip [2] 119/1 142/24 I 141/25 142/1 142/2 I 144/5 152/14 156/19
124/12 126/25 132/21I grounds [8] 44/4 142/5 142/8 142/10 I 158/16 187/1 189/10
137/8 143/20 148/25 I 44/23 48/20 49/7 142/13 142/15 143/25) 203/8 217/3
176/4 179/20 188/15 I 49/23 136/9 191/18 I 144/1 144/22 145/19 Ihappened [17] 40/8
(74) get... - happened
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happened...[16]_ 207/19 207/20 208/4 I 219/23 219/23 219/24IHelmsley [1] 96/9 148/6 187/14
56/15 80/13 81/20 208/16 208/21 211/19) 220/6 220/7 220/8 help [23] 7/2 7/10 high-end [1] 148/6
83/8 95/13 97/23 212/10 212/16 212/22! 220/10 220/12 220/16] 7/17 9/13 16/15 32/19I high-profile [1] 20/24
98/13 101/25 107/17 214/7 214/11 215/10 I 221/18 221/24 221/25] 35/12 48/6 51/4 73/10I higher [11] 7/7 38/14
116/10 121/19 122/23I 219/18 215/23 221/14/he'd [6] 20/23 84/4 I 85/8 100/4 123/25 45/17 45/22 46/1
4123/4 123/21 126/17 I 223/13 225/10 225/20] 91/6 132/4 132/5 124/19 132/19 140/19I 48/17 49/11 57/12
172123 226/23 231/11 231/12) 171/25 143/3 172/5 176/10 I 80/20 181/24 183/4
231/25 he's [6] 18/4 85/7 I 176/11 176/17 176/21Ihighest [1] 214/19
happening [7] 25/13
hasn't [2] 83/11 91/6 107/11 178/4 I 232/3 ight [1] 9/15
$8 ae tot nonon 231/1 208/23 helped [3] 33/19 ighlighted [4] 10/25
have [408] head [7] 17/23 36/22 215/8 83/12 145/24 173/16
happens [4] 24/16 ‘ nar
pe ale © Beate haven't [9] 17/11 122/13 127/25 151/6 Ihelpful [10] 124/17 I highlighting [1]
happy [13] 28/2 149/6 182/19 182/22 I 157/22 202/15 227/6 I 128/14 178/17 202/11) 104/25
Der 30/14 30/16 I 200/17 219/1 222/24 IHead's [1] 21/2 203/17 204/3 208/21 I highly [3] 77/18 79/1
4/6 agi24 64/11 I 223/19. 231/18 headcount [3] 81/4 I 215/7 228/16 232/14 I 137/25
85/18 92/22 93/1 [having [20] 1/19 4/12] 81/5 167/1 helping [3] 140/20 Ihim [27] 8/11 9/18
121/14 129/3 21915. I 22/22 36/14 82/7 90/2I heading [6] 66/8 69/2I 204/13 213/4 28/6 53/17 53/19
hard [9] 3/24 59/23 I 94/17 94/21 1488 I 70/23 121/23 13/4 IHenry [7] 66/18 77/9 I 63/25 77/18 77/23
B46 100/9 14911 I 153/22 187/5 1586/4 I 203/22 83/21 218/3 218/19 I 79/12 81/23 86/2
154/8 174/25 175/15 I 158/7 175/14 178/25 Iheads [2] 41/12 218/23 233/18 88/14 91/7 91/8
207193 196/18 196/23 197/24] 204/13 her [44] 1/8 1/13 1/13I 123/10 128/13 139/18
harder [3] 76/22 208/1 20/1 health [15] 1/13 13/1 I 1/16 1/17 1/19 1/21 I 188/9 197/1 217/19
148/1 153/13 HBoS [5] 7/19 10/25 I 15/22 15/23 15/23 I 1/24 20/25 21/1 35/20I 219/2 219/9 219/15
hardly [3] 30/1 53/15 I 11/6 14/23 39/15 36/19 36/19 37/9 38/22 38/22 38/24 I 219/21 220/13 220/18)
q77e HCAB [1] 18/20 37/10 90/1 90/1 97/25] 40/1 40/1 42/24 88/17I 222/2
hardship [6] 225/21 IHCRS [5] 187/11 98/2 172/1 207/23 I 93/16 118/24 122/22 Ihimself [3] 60/22
226/14 227/5 2208/2 I 195/19 213/15 215/20Ihear [8] 17/20 32/24 I 122/24 123/4 123/6_ I 217/13 220/12
28/2 228/17 215/21 39/25 62/13 92/22 I 123/7 123/19 124/12 Ihinder [1] 15/18
harm [3] 103/18 he [123] 2/14 9/22 I 113/7 133/16 181/10 I 124/21 125/5 127/22 Ihindered [2] 14/20
103/22 226/23 9/25 10/25 20/23 21/2Iheard [39] 20/1 37/12) 127/22 127/23 128/3 I 16/24
harmed [1] 138/20 I 38/11 49/1 45/18 62/14 68/8 75/20 128/11 134/6 134/8 /hindering [2] 15/9
harms [1] 189/1 48/19 51/2 53/15 77/21 78/17 89/23 I 139/24 149/9 149/21 I 15/12
has [124] 7/12 10/18 I 99/16 53/18 53/22 I 89/24 89/24 105/14 I 16/8 166/10 166/17 /hindsight [1] 170/3
12/2 12/4 18/21 17/9 I 59/19 59/23 63/12 I 105/23 107/13 112/23] 184/15 221/16 hint [1] 136/2
18/3 20/23 25/24 26/5] 63/14 63/14 64/2 64/3) 118/15 124/6 125/5 _IHerbert [16] 12/13 _Ihinting [1] 149/14
26/8 33/13 35/19 38/5) 64/11 64/12 7/12 I 136/25 147/18 147/23) 13/4 93/21 94/7 94/17Ihis [44] 27/23 38/12
38/9 41/14 42/5 42/17I 27/14 77/19 78/13 I 148/18 150/3 152/23 I 95/1 145/15 147/16 I 42/23 42/23 45/18
44/9 44/11 44/22 78/15 78/20 78/20 152/24 153/19 154/21) 148/14 148/19 148/19I 48/13 53/17 63/12
45/16 45/18 48/20 79/2 79/11 79/14 173/18 176/12 181/4 I 149/1 150/3 160/21 I 64/3 66/25 77/13
49/22 50/11 53/14 79/18 79/20 79/21 181/10 185/19 198/17I 160/25 184/16 77/21 77/24 78/22
53/15 53/16 53/18 79/23 80/3 80/5 80/8 I 217/9 220/1 225/10 I here [37] 3/8 3/8 16/9] 79/14 80/3 80/14
53/22 58/4 64/3 64/18) 80/8 83/20 83/22 230/16 231/11 231/11] 21/8 21/10 22/4 25/5 I 84/20 86/9 87/6 87/6
65/2 70/20 73/23 83/23 83/25 84/7 231/12 48/6 48/19 50/15 87/11 87/15 87/20
TAIT 79/17 79/24 84/11 84/11 84/23 hearing [4] 117/9 61/17 63/17 64/6 72/8I 88/7 101/10 121/6
91/18 93/24 95/5 96/3) 89/22 85/23 86/10 124/4 149/9 232/23 I 75/15 76/12 94/20 129/15 129/18 132/21
96/24 97/1 99/1 99/6 I 87/2 87/5 87/22 88/13I hearings [6] 168/7 I 95/7 98/24 102/8 140/25 147/6 147/6
101/13 101/25 103/18I 88/14 90/13 91/7 168/8 174/5 200/4 104/13 121/1 121/6 I 155/24 169/12 171/6
403/22 105/14 105/23 91/10 101/8 101/13 200/13 208/5 124/19 126/12 137/2 I 177/1 177/15 178/4
106/14 107/9 114/1_ I 121/10 125/5 125/23 Iheart [2] 103/17 154/4 163/5 168/25 I 183/6 184/7 193/25
114/15 119/23 121/12I 126/2 126/3 127/19 I 146/11 171/11 187/9 194/8 I 194/4 208/11
121/14 125/21 128/2 I 129/11 129/17 129/17I heartbreaking [1] 199/20 205/5 227/9 I Historic [5] 10/22
131/17 131/19 133/7 I 131/21 133/23 133/25] 76/9 227/10 232/10 94/8 150/10 159/2
134/3 134/13 141/8 Ihearts [1] 146/11 heroes [1] 102/15 169/3
teas teartd yeas 145/20 147/5 148/18 IHeaven [2] 7/1 100/3 Iherself [1] 133/20 Ihistorical [2] 132/17
157/8 158/8 158/17 I 191/9 155/19 159/7 Iheavily [1] 128/19 I Hickinbottom [2] 143/22
160/24 165/8 168/6 I 159/17 161/8 162/3 heavy [1] 174/7 92/13 204/12 history [1] 80/13
474/11 174/14 17518 I 164/11 164/19 168/4 Iheightened [2] 142/4IHickinbottom's [1] _Ihit [4] 64/18 65/2
168/21 169/24 170/2 I 143/2 204/4 65/15 67/24
177/15 178/8 178/9 7
182/12 182/15 187/14] 1272/2 173/2 174/21 Iheld [11] 5/13 5/22 Ihide [2] 23/5 23/23 I hm [3] 158/14 159/16
1487/18 188/10 191/6 I 179/25 177/1 179/15 I 6/1 6/3 35/15 50/17 I Higginbotham [1] 162/11
191/25 192/20 193/3 I 179/16 179/16 183/16] 72/16 78/23 85/15 34/23 HMT [1] 171/41
196/20 199/19 202/9 I 183/19 183/25 184/20] 86/24 206/23 high [11] 20/24 21/8 IHodges [1] 208/7
194/19 194/19 195/3 Ihello [4] 86/21 21/25 43/11 54/18 hold [8] 30/24 48/2
(75) happened... - hold
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includes [3] 139/13 [individually [1] 15/5 I 2/7 2/21 13/22 17/6 I 91/1 12/1 229/15 229/16
212/21 231/3 individuals [17] 23/6 I 32/25 41/4 51/15 interpreting [1] irregularity [1] 197/7
including [22] 12/8 34/16 49/2 59/20 51/23 51/25 53/18 197/11 Irrespective [1]
13/2 28/1 30/12 35/7 92/25 112/11 133/13 I 53/21 53/25 54/8 interrelated [1] 162/8I 142/12
40/23 41/4 43/10 69/2 134/25 171/2 180/2 I 54/20 59/17 66/15 interrelationship [2] Iis [575]
69/22 70/4 106/9 183/1 192/16 196/10 I 82/13 82/17 90/12 163/6 216/14 is -- the [1] 228/17
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1485/1 188/19 193/10 Industrial [1] 9/21 105/16 105/23 112/19) intervention [10] isn't [16] 19/20 23/8
225/14 industry [1] 133/3 118/15 188/25 194/3 I 160/10 178/9 178/22 I 52/7 95/11 109/23
inclusively [1] 120/2 inequality [1] 99/22 I 200/10 200/13 208/3 I 182/5 184/12 195/9 I 131/22 158/19 173/22)
inevitably [3] 15/20 I 209/21 212/22 216/9 I 204/2 205/2 205/20 I 175/22 186/7 186/18
(78) imperative... - isn't
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230/3 140/16 143/7 143/20 I 102/14 170/8 205/11 I 80/14 83/23 84/25 151/23 154/22 178/21
issuance [3] 161/24 146/8 150/14 151/12 I 209/15 87/5 87/13 89/5 95/9 I 181/11 188/20 204/2
162/2 162/4 152/10 154/5 154/21 IJohn [1] 45/13 103/13 104/19 104/21I 205/2 205/4 217/1
issue [32] 6/24 7/8 155/14 157/6 167/4 Ijoin [3] 117/21 128/8 I 106/22 108/3 108/18 I 224/10 233/2
10/4 10/12 37/23 170/3 174/1 174/19 I 133/21 115/6 115/9 115/23 I key [3] 6/23 53/12
176/18 176/19 177/7 Ijoined [6] 116/13 118/13 121/10 130/17I 82/4
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220/9 229/19 206/15 207/25 209/20I 194/17 189/23 191/5 197/9 I kindly [2] 3/23 11/4
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issues [56] 7/21 10/4I 228/3 228/16 228/18 Ijourney [1] 202/9 I 218/14 220/19 229/1 I 130/24 221/18
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420/3 122/13 125/14 74/11 103/23 121/25 Ijudgements [1] 231/21 231/25 232/4 I 26/21 27/19 29/14
4129/3 1290/8 129/10 I 125/21 126/5 147/25 I 189/21 Justice Fraser [1] I 30/24 38/21 38/23
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4143/9 143/15 145/23 I 198/5 125/22 127/9 129/4 I Justice oversees [1] I 50/23 54/22 60/7
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462/13 164/8 168/23 I 131/22 133/12 141/17I 1314/5 131/7 131/11 Ijustifiable [1] 182/4 I 65/19 74/1 78/15
468/25 169/1 171/10 I 147/13 220/15 131/22 133/9 137/19 Ijustification [1] 78/21 80/1 83/25 84/6
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494/3 207/16 208/16 I 201/4 141/24 148/3 201/8 Ijustify [1] 109/13 98/6 101/8 106/15
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216/13 <______________ judgments [3] 11/25 I Jorgen [3] 159/7 117/9 119/20 128/15
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its 1143] 28 3/26 I 233/20 229/20 K 140/6 140/13 141/13
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Jane [1] 122/16 July 2020 [1] 9/14 I 88/10 88/24 180/23 I 159/10 165/7 165/17
Pe ae ao 39105 January [9] 86/25 I July 2024 [1] 5/24 I keep [5] 38/23 50/21 I 168/7 168/13 174/20
4013 4018 40/11 ArtI 92/21 104/18 106/12 Ijuncture [1] 68/15 I 68/6 150/19 175/24 I 176/9 179/12 179/21
159/3 194/12 205/18 I June [8] 53/18 69/1 Ikeeping [1] 126/17 I 179/24 180/2 180/14
42/20 44/21 45/4 46/6I
46/7 46/18 46/24 50/1I 2274/4 224/7 82/24 133/2 134/22 IKelly [28] 116/14 181/4 182/12 182/15
51/23 52/7 52/21 January 2024 [1] 184/10 192/2 223/25 I 116/20 121/2 121/13 I 182/23 185/24 188/24
52/22 53/4 83/7 53/101 2244 June 2022 [4] 223/25) 121/14 122/21 124/3 I 189/1 189/18 194/14
54/22 61/1 61/20 Jason [1] 3/19 junior [1] 8/21 124/9 124/20 125/1 I 195/10 195/13 203/11
64/17 67/1 67/22 Jean [1] 1/22 jurisdiction [1] 125/2 125/4 125/6 I 205/4 205/10 205/15
67/23 69/1 69/8 72/20 Jeremy [2] 40/14 I 212/12 125/12 125/20 125/25] 208/10 208/23 209/4
76/5 76/7 76/15 77/7 I “9 just [95] 2/12 7/22 I 126/23 127/4 133/6 I 209/10 209/11 209/19
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tno (A) 19 12318) aii 148/7 148/12 Iled [5] 81/1 82/21 I 167/17 205/18 209/1 I 22972
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166/21 fo7711 17218 fawyer [16] 16/13 I 101/8 123/19 227/20 229/19 230/4 Ilikelihood [1] 43/11
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ae 1801 95/11 100/18 103/3 I 34/14 36/11 36/18 __Ilikewise [1] 114/17
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lap) 19625. I 174/7 110/21 121/20 121/24) 46/16 46/24 47/21 I 141/13
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lag [2] 207/21 223/11 33/6 41/17 57/25 174/2 174/17 175/6 155/13 177/2 177/3 193/1 198/4 225/8
land [1] 123/25 58/22 95/24 97/15 I 176/15 176/21 178/12I 177/18 182/3 185/1 _Iline [8] 2/19 10/13
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language [3] 125/19 I 99/2 99/6 99/7 99/12 I 181/1 186/11 192/17 ILevelling [1] 6/8 I 181/8 219/24 226/22
4126/9 185/24 99/18 99/19 100/19 I 193/10 195/20 195/21 levels [9] 39/20 49/9 Ilines [5] 4/6 20/22
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99/1 103/3 109/24 I 103/13 131/16 136/5 Ilegalistic [4] 23/16 I 202/6 linked [1] 20/5
109/25 138/22 154/19I 149/10 170/16 173/17I 24/10 149/11 197/8 liabilities [3] 132/17 Ilist [4] 9/12 67/1
174/18 180/6 183/19 I 173/19 174/10 174/15Ilegions [1] 100/19 I 134/10 154/9 136/19 231/4
483/21 189/2 191/24 I 175/2 175/11 177/24 legislate [1] 120/16 liability [9] 121/22 Ilisted [4] 137/12
492/14 200/16 222/12I 179/17 180/10 180/22) legislation [9] 95/22 I 130/9 139/14 140/9 I 137/14 137/18 150/16
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larger [2] 86/6 99/5 I 208/12 227/19 228/7 I 214/10 214/16 liaise [1] 59/11 listening [1] 208/10
last [25] 4/15 19/1 I 228/7 length [7] 4/1 25/25 litigants [3] 135/24
33/14 33/16 53/16 layer [2] 197/23 154/7 156/24 184/23 Iliberal [1] 11/10 157/25 158/1
70/5 71/18 74/3 91/17] 197/24 187/8 219/1 licence [2] 65/1 litigation [29] 2/4
105/22 107/25 111/10I!ead [5] 13/9 31/17 lens [1] 180/5 116/22 12/1 12/16 45/18
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207/17 212/7 226/8 I 68/19 72/3 76/15 111/6 119/1 142/6 light [12] 8/10 41/20 I 133/5 133/8 134/14
229/8 76/19 82/5 82/10 142/6 161/9 181/22 I 46/5 46/10 102/9 135/7 135/10 135/24
lasting [1] 74/4 83/10 126/20 127/2 I 206/21 216/23 102/12 102/15 102/16] 137/19 138/9 138/25
late [5] 18/17 45/5 I 127/15 127/21 128/1 Ilesser [1] 46/17 106/13 131/12 203/10I 142/13 148/1 150/7
174/23 181/21 218/21) 128/6 128/12 128/16 Ilesson [2] 176/13 I 210/10 150/21 168/23 204/14
later [23] 14/14 16/3 I 136/20 136/23 139/17] 199/3, light-touch [4] 46/10 I 220/9
17/20 27/7 56/11 141/19 154/18 216/16Ilessons [1] 101/24 lighter [1] 121/7 _Ilitigators [1] 149/13
56/25 83/15 84/9 93/1Ileadership's [1] let [6] 31/10 79/20 like [61] 7/15 16/17 Ilittle [8] 7/22 24/19
117/23 122/5 129/20 I 138/9 91/11 99/10 130/5 I 18/8 20/16 20/24 26/4 55/15 125/15
432/14 137/6 151/12 [leading [4] 6/20 156/18 23/19 28/8 30/12 146/7 184/23 210/19
1459/7 166/2 174/3 84/20 138/7 202/7 let's [8] 21/21 90/11 I 30/19 33/10 34/15 live [3] 61/21 107/15
1481/8 209/20 221/3 Ilearn [4] 16/2 23/17 I 98/16 107/4 109/8 38/15 41/22 49/1 51/3) 188/9
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latest [3] 91/21 130/1Ilearned [1] 176/13 I letter [48] 2/21 2/23 I 62/24 69/12 74/19 lives [7] 14/25 15/1
205/25 least [13] 7/6 13/23 I 2/24 3/3 8/8 40/10 81/5 88/21 98/2 39/25 40/7 41/2 57/6
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89/16 93/13 98/23 109/15 128/15 I 42/24 43/15 44/2 109/5 122/2 123/18 living [1] 64/21
latterly [4] 27/2 78/17 168/4 182/16 185/18 I 51/22 52/6 52/13 125/15 128/8 128/22 ILloyds [10] 7/19
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leaves [3] 47/3 139/13 140/8 162/5 I 199/17 202/3 205/16 Iloads [1] 182/20
(80) known - loads
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logistical [i] 179 ILomaGratton [1] IMagistrate [1] 151/2 I 41/2 43/19 46/13 [May 2019 [1] 128/21
Logs [i] 13722 ‘I 21916 magnitude [2] 127/9 I 48/11 50/13 50/14 I maybe [8] 57/1 72/8
long [23] 17/7 19/24 [Lorna's [1] 119/11 I 140/11 50/16 65/1 65/12 I 95/11 103/5 14/7
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jeanne 17/8 179 I 3613. 36/14 36/18 I 70/2 174/15 179/3 180/9 I 20/23 22/1 24/9 24/17
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207/21 219/1 220/20 I 56/23 58/19 116/20 I 17/6 193/14 206/4 206/10 I 31/23 33/6 34/9 35/20
long.term [4] 12018 I 174/24 202/15 226/23Imajor [3] 109/15 I 211/14 222/18 230/2 I 38/25 30/3 49/25
longer [10] 33/2 41/3 I 227/6 122/7 135/25 230/5 230/5 232/9 I 51/16 52/4 52/5 54/4
Sete d5/73 10312 [losses [9] 25/17 I majority [3] 12/6 March [12] 5/9 61/1 I 54/6 54/14 67/7 68/4
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201/18 205/3 190/7 190/14 216/7_Imake [59] 1/4 4/2 8/2I 184/1 184/4 195/4 I 75/14 76/2 78/5 82/19
longstanding [1] I 216/18 224/21 8/21 20/20 30/6 31/20I 209/12 209/20 210/5 I 85/18 90/17 91/6
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52/8 60/14 61/9 65/6 I 132/23 138/22 145/1 I 76/21 82/13 90/8 Marshall [4] 8/8 136/15 137/17 144/1
65/12 65/13 68/11 145/11 146/6 147/23 I 91/12 92/14 94/23 10/17 11/4 102/12 145/20 148/8 149/22
68/20 71/16 71/23 148/6 149/5 151/10 I 99/7 104/3 111/1 massive [1] 91/17 149/23 150/5 164/25
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79/3 79/19 84/15 168/9 172/4 174/14 I 153/3 153/21 154/8 I 44/9 83/25 171/15 181/19 185/16)
90/11 93/25 101/22 I 1759/6 175/24 176/18 I 154/24 159/18 162/24) material [5] 35/21 186/24 192/14 203/11
106/2 111/20 125/20 I 185/13 187/10 205/3 I 168/12 168/17 170/23) 74/4 146/14 178/8 205/7 211/11 223/4
432/12 150/14 151/7 I 220/2 220/16 189/13 189/22 198/3 I 222/1 224/16 231/10 231/12
152/16 155/19 167/19I!Ots [10] 64/19 64/25 I 202/21 215/24 223/21Imaths [1] 206/16 mean [46] 10/13 17/1
1475/7 179/9 180/5 76/6 81/25 82/16 224/17 227/20 matter [6] 47/10 19/12 24/17 25/24
188/25 194/10 204/23I 102/13 182/14 194/13Imakes [2] 52/23 51/15 178/18 191/6 I 37/25 38/16 38/19
207/18 230/15 184/3 214/14 216/8 46/3 49/9 49/10 54/3
ge ay nares 4Ilow [7] 82/25 157/7 Imaking [17] 18/12 Imattered [1] 146/12 I 64/16 67/21 68/12
o3it7 Olt 177/2 195/18 197/16 I 22/14 28/13 33/12 Imatters [18] 2/12 _ I 69/16 70/11 76/11
looking [19] 22/15 I 228/3 228/18 43/8 50/21 62/6 75/4 I 14/8 64/9 64/20 67/3 I 83/20 94/25 95/9
3015 21/7 41/13 lower [5] 37/17 46/23) 90/15 102/16 107/22 I 96/23 99/15 100/10 I 109/25 109/25 143/13
86/11 66/12 6a/24__I 175/7 187/10 214/21 I 152/6 152/20 165/12 I 101/13 119/13 119/15] 147/20 149/14 156/21
72/14 94/1 118/14 [Lucas [2] 17/22 169/23 204/22 231/17I 119/15 120/6 150/20 I 160/11 165/21 169/22
118/14 136/5 141/16 I 60/22 malicious [3] 13/18 I 172/12 173/22 215/3 I 175/19 179/1 179/9
455/25 168/23 170/21 ludicrous [2] 38/25 I 141/14 151/6 216/4 182/21 188/15 197/4
186/24 198/7 231/10 I 54/23 Malton [3] 3/22 4/25 Imature [1] 14/2 201/16 207/2 208/21
looks [4] 101/9 lump [1] 95/9 9/7 maturity [1] 40/22 I 209/13 210/8 219/23
132/12 171/9 171/14 Itunch [1] 112/23 manage [1] 169/2 Imaximise [2] 89/7 I 223/18 224/22 227/8
loose [2] 228/3 M managed [5] 53/12 I 89/8 227/22
228/18 —___I 65/24 74/19 102/2 I maximising [2] 88/20/meanings [1] 38/2
MacLeod [1] 122/16 I 149/6 88/20 means [10] 45/9 46/2
tod On ee made [52] 2/18 3/23 Imanagement [16] I maximum [1] 139/14 I 60/18 71/9 97/15
17/8 18/11 20/19 25/5I 65/12 65/13 66/2 Imay [46] 3/15 4/25 I 161/16 170/21 175/11
139/24 172/10 172/17) d6/09 27/15 2819 I 69/21 69/22 72/3 76/5I 10/12 31/7 48/4 48/25I 181/19 209/10
end Arbuthnot 2) 28/19 28/21 30/8 31/4) 77/1 79/6 81/4 81/5 I 52/4 54/10 58/15 59/5Imeant [15] 7/2 33/20
32/1 91/10 33/11 34/16 38/8 122/11 134/17 162/15I 72/7 75/17 83/22 58/15 83/10 84/4
Lord Callanan [2] 43/23 50/20 53/7 53/8I 204/5 229/2 93/20 96/11 96/22 I 100/3 124/8 126/3
T7ON10 172/95 75/4 75/6 75/14 75/19 manager [1] 171/24 I 106/1 106/13 108/15 I 126/13 160/7 181/25
78/13 80/15 86/5 Imanagers [2] 2/16 I 120/23 127/10 128/21I 185/11 186/4 201/17
to eson El 86/23 89/11 89/25 I 189/25 135/4 137/22 139/14 I 221/17
Lords [1] 172/12 90/23 91/10 92/2 93/4) managing [3] 129/7 I 153/18 155/5 158/12 Imeantime [2] 51/1
a 101/19 126/25 145/14] 151/10 164/4 158/20 170/11 171/5 I 51/3
Lorna [13] 82/8 5
pd be 417/21 147/14 169/4 178/8 Imanifest [1] 197/6 179/17 185/16 186/16I measures [2] 41/13
184/1 184/1 206/4 — Imanna [2] 7/1 100/3 I 186/21 199/7 203/11 I 70/7
1148/9 118/24 11916 I d4q17 2114/3 214/22 Imany [47] 1/20 7/6 I 206/7 210/18 218/17 I mechanism [15]
(81) lobbying - mechanism
INQ00001202
INQ00001202
M 136/6 142/1 158/13 I 132/17 181/9 190/24 IMinistry [8] 211/25 I 227/24 227/25
mechanism... [15] mental [7] 13/2 15/23) 191/24 200/2 216/13 I 212/10 212/12 229/3 Imonitoring [3] 191/9
18/19 26/24 92/4 36/19 37/10 90/1 98/2) 224/5 230/13 231/20 231/24] 192/19 193/2
1491/2 191/12 191/21 207/23 minded [1] 193/13 232/4 month [4] 76/19
192/22 194/11 195/3 Imention [7] 7/22 mindful [1] 42/11 minute [2] 60/23 81/20 120/24 230/7
1496/6 196/14 198/24 55/18 67/3 71/17 minds [1] 28/5 111/11 monthly [4] 103/4
499/14 199/23 210/4 71/21 219/2 219/17 Iminimal [1] 152/1 minuted [2] 70/12 191/8 192/19 193/2
mechanisms [1] mentioned [21] 9/9 Iminimis [10] 151/18 I 74/18 months [16] 5/23
153/16 35/14 35/20 37/22 151/20 151/21 155/19) minutes [5] 3/9 13/24 26/11 30/11
media [3] 20/12 33/1 73/2 95/23 97/22 159/14 159/17 160/5 I 108/11 159/3 185/15 I 33/14 53/16 53/20
82/20 100/16 121/17 133/14] 160/22 161/1 161/11 I 207/8 105/22 120/1 120/21
mediate [2] 151/7 150/7 154/15 159/7 Iminimise [1] 94/11 Imiscommunication I 122/5 126/2 156/25
178/4 186/25 193/25 208/4 Iminimum [5] 27/4 [1] 85/2 192/9 209/7 219/20
mediated [3] 145/23 208/6 217/1 219/1 55/23 55/25 61/12 misogyny [1] 78/19 Imood [1] 165/24
196/11 202/10 220/24 226/20 71/11 Misra [3] 11/22 Moorhead [2] 35/7
mediation [4] 145/20 mentioning [1] 156/9I minister [73] 2/20 221/10 221/18 35/8
4146/2 149/19 17/7 IMere [1] 94/9 5/4 5/8 5/9 5/19 6/22 Imissing [3] 107/3 _IMoors [1] 215/8
medical [14] 37/1 merits [1] 170/16 8/17 8/21 8/23 11/15 I 136/14 209/25 moral [2] 164/8 165/2I
56/6 57/11 207/1 message [2] 74/24 I 14/5 14/14 17/17 18/2I mistakes [3] 17/8 more [130] 21/13
225/25 226/2 226/3 93/9 22/7 26/12 27/14 25/5 30/8 29/4 29/5 30/23 31/20
226/4 226/17 227/11 Imessages [A] 124/1 I 29/23 30/9 31/14 mistreated [3] 7/18 I 37/18 37/21 38/11
227/12 met [13] 8/11 17/11 I 31/16 32/16 37/16 8/4 23/1 39/23 39/24 41/3
medium [2] 69/22 30/11 35/20 63/25 44/12 44/21 47/24 mistreatment [1] 8/5 I 41/17 45/24 45/24
70/20 96/10 122/22 125/1 I 48/10 59/21 68/5 mistrust [1] 97/13 46/16 47/23 48/13
medium-term [1] 148/19 174/15 175/14I 76/18 80/18 107/9 mixture [1] 166/21 49/10 49/14 58/14
70/20 204/9 209/6 107/23 112/14 117/17IMm [9] 29/22 72/18 I 63/7 63/23 65/16 66/4,
meet [4] 81/22 mid [3] 168/19 117/20 117/22 118/9 I 135/21 158/14 159/16] 68/12 68/16 68/18
133/17 134/25 187/18 168/19 173/10 121/2 123/3 123/8 162/11 183/13 204/25I 73/24 75/25 77/3
meeting [60] 18/2 mid-afternoon [1] 125/7 128/5 128/18 I 219/22 81/11 83/23 85/18
28/5 39/4 39/6 39/12 173/10 133/7 135/2 139/3 Mm-hm [3] 158/14 87/12 87/19 88/13
47/7 60/1 60/1 60/11 mid-flight [2] 168/19 I 139/6 139/16 140/25 I 159/16 162/11 89/20 90/3 91/12
60/19 60/23 60/23 168/19 141/5 141/22 142/6 Imodel [3] 166/11 91/15 92/3 92/6 93/20)
61/8 62/19 63/16 middle [5] 25/11 142/6 150/12 150/15 I 174/19 195/18 94/22 97/21 109/25
68/15 72/16 72/20 29/15 102/21 103/1 151/1 155/18 160/3 IModernisation [1] 110/5 111/16 115/13
73/1 73/5 73/8 79/5 103/7 163/21 178/21 181/15) 71/20 115/24 116/3 116/22
81/19 83/2 93/23 midstream [1] 169/9 I 185/19 187/6 188/8 Imodest [1] 86/8 117/20 122/1 123/1
121/18 122/3 125/20 might [53] 3/11 14/17I 189/13 193/25 194/18IMoJ [3] 212/16 125/10 125/15 127/25)
1433/3 133/15 134/21 21/9 27/14 35/22 195/1 200/21 204/2 I 214/14 230/12 128/2 128/20 133/19
134/22 134/24 137/11 36/10 48/14 49/1 209/1 219/5 Moloney [3] 208/4 136/13 137/8 139/12
137/12 139/16 139/17 52/24 52/25 55/6 Minister's [2] 124/24 I 218/4 232/16 139/20 140/18 140/18)
1442/3 142/17 148/18 56/12 57/20 75/10 185/9 moment [13] 55/6 141/6 141/23 144/8
450/11 151/12 157/12! 81/23 83/24 87/18 ministerial [12] 5/22 I 61/17 109/8 111/5 144/23 145/9 145/11
159/11 159/12 161/22! 90/5 92/15 92/20 93/2) 6/15 6/19 25/8 42/8 I 111/19 169/2 173/9 I 146/20 149/16 150/1
165/24 166/5 170/7 99/12 102/24 103/6 I 48/11 49/24 50/3 179/7 208/24 210/20 I 150/1 150/6 152/2
172/23 179/15 184/22! 104/18 109/7 109/13 I 77/14 116/17 185/17 I 217/16 219/18 225/6 I 152/3 153/7 154/11
1491/9 192/19 192/20 110/11 110/19 130/11] 188/10 moments [1] 169/5 I 155/6 161/7 161/10
1493/2 195/15 204/9 132/13 140/5 141/11 Iministers [46] 19/12 IMonday [5] 2/14 2/14I 161/14 163/3 163/9
2417/7 217/10 143/16 144/14 144/24) 20/9 47/25 49/8 50/12I 2/19 53/18 90/12 164/6 165/18 174/16
meetings [11] 31/16 158/5 166/1 170/23 I 50/22 88/9 88/23 89/2Imoney [50] 42/6 177/4 177/9 177/11
31/19 34/5 36/6 62/15 173/9 177/19 180/7 I 116/18 117/18 134/18) 42/11 44/4 44/6 48/20) 178/3 178/8 180/10
70/12 77/16 81/13 180/16 188/13 192/3 I 139/21 140/15 141/21) 48/22 48/24 48/24 180/16 180/20 180/23)
117/21 148/16 148/22! 198/13 206/17 210/5 I 147/7 149/24 156/2 I 49/10 49/22 50/24 181/21 181/24 182/2
member [11] 3/21 212/7 220/5 229/21 161/3 163/9 164/20 I 54/18 54/23 66/6 182/10 182/25 183/1
4/24 7/13 52/11 230/16 230/21 165/4 165/15 166/3 I 68/12 70/3 74/21 75/6) 184/5 186/17 200/13
182/15 183/10 184/8 Mike [4] 159/7 166/20 168/16 172/14I 75/15 75/16 76/25 202/19 202/21 203/14
1490/7 226/16 226/24 171/14 171/23 173/1 I 172/21 178/19 178/20) 88/5 89/14 93/12 203/18 203/19 206/8
2207/2 mileage [4] 19/25 181/18 181/20 182/10) 107/3 109/13 112/4 I 206/10 206/21 206/23,
members [13] 2/7 20/2 35/16 38/22 187/16 187/18 189/9 I 112/8 117/14 136/10 I 207/12 207/14 208/13}
41/5 50/13 63/21 million [10] 12/5 190/16 195/7 199/16 I 149/5 152/4 153/2 212/18 213/17 214/14
120/12 188/18 189/24! 33/15 33/16 90/6 200/15 200/19 201/8 I 154/1 156/23 158/17 I 217/14 219/9 219/16
490/21 220/1 222/18 91/19 140/11 140/12 I 201/11 205/1 208/25 I 160/6 180/6 182/14 I 222/16 230/22 232/15
226/21 227/11 227/17 158/21 186/16 224/23] 209/18 183/3 191/18 191/24 I morning [6] 3/19
memory [4] 4/12 millions [1] 105/25 Iministers' [3] 47/17 I 191/25 194/7 208/9 I 35/14 55/7 159/23
mind [9] 67/11 104/4 I 130/2 182/6 209/19 226/10 227/8 I 204/18 232/21
(82) mechanism... - morning
INQ00001202
INQ00001202
M
most [13] 13/20 28/8
65/7 65/7 71/13 73/7
136/19 143/13 181/19
206/6 213/8 223/14
224/25
motivate [1] 82/10
motivating [2] 82/8
motivations [1]
116/9
mounted [1] 172/2
move [17] 37/14
39/24 40/6 44/18
76/12 77/23 80/23
106/3 115/13 115/18
125/7 125/14 132/19
137/9 166/2 173/15
204/14
moved [5] 83/11
84/10 85/12 142/2
215/10
movement [1] 88/8
moving [9] 38/20
39/9 45/22 100/10
133/1 163/23 166/11
187/25 202/2
MP [6] 2/12 3/17 9/7
11/14 22/6 233/2
Mr [125] 1/3 2/1 2/3
2/10 2/12 2/15 2/18
3/7 3/12 3/15 3/18
3/19 4/23 11/4 22/11
27/23 29/1 42/21
53/13 55/14 59/24
61/3 61/4 61/11 61/24
61/25 63/11 68/25
77/6 77/11 77/20
78/10 78/18 79/1
79/11 79/16 79/19
80/6 80/16 80/21
81/22 82/5 84/16
84/17 85/4 85/9 86/11
86/18 86/21 86/25
88/25 88/25 90/12
93/20 95/16 95/17
97/18 104/8 104/12
104/19 108/12 112/14}
112/18 112/24 113/5
113/7 113/9 113/13
115/5 116/15 123/19
131/21 150/4 157/21
158/25 159/15 161/6
162/6 162/12 173/15
173/18 176/24 178/1
179/13 181/5 183/5
183/11 188/2 193/17
194/9 203/24 204/17
204/23 204/24 208/4
210/15 211/17 218/3
218/4 218/4 218/19
218/23 218/25 219/1
219/3 219/5 219/14
220/4 220/21 220/22
221/6 221/6 221/18
221/24 222/11 222/12
228/23 230/23 232/16
232/18 233/4 233/8
233/16 233/18 233/20
Mr Altman [2] 221/6
221/18
Mr Bates [1] 104/19
Mr Beer [6] 1/3 2/10
3/12 29/1 112/24
204/23
Mr Blake [10] 113/5
113/9 157/21 158/25
210/15 211/17 219/3
228/23 230/23 233/16
Mr Brightwell [1]
88/25
Mr Cameron [1]
123/19
Mr Cooper [9]
131/21 159/15 161/6
162/6 162/12 219/1
219/14 220/4 220/21
Mr Cooper's [1]
219/5
Mr Creswell [9]
88/25 112/14 113/7
113/13 115/5 173/15
218/25 222/12 232/18
Mr Elliot [2] 59/24
61/11
Mr Henry [4] 218/3
218/19 218/23 233/18
Mr Hollinrake [17]
2/12 3/19 4/23 22/11
55/14 86/11 86/21
93/20 95/17 104/8
104/12 108/12 112/18)
181/5 194/9 204/17
204/24
Mr Hollinrake's [1]
3/7
Mr Hunt [1] 42/21
Mr Ismail [3] 61/4
61/25 63/11
Mr Jacobs [3] 61/3
61/24 218/4
Mr Justice Fraser [1]
116/15
Mr Kevin [1] 3/15
Mr Marshall [4] 11/4
Mr Moloney [3] 208/4I
218/4 232/16
Mr Read [7] 27/23
53/13 80/16 80/21
81/22 85/4 85/9
Mr Read's [3] 78/10
82/5 84/16
Mr Recaldin [13]
2/15 2/18 86/25 90/12
150/4 173/18 176/24
178/1 179/13 183/5
183/11 188/2 193/17
Mr Recaldin's [1]
203/24
Mr Riddell [1] 2/1
Mr Scott [2] 220/22
221/24
Mr Staunton [7]
68/25 77/6 77/11
77/20 79/1 79/16
84/17
Mr Staunton's [4]
78/18 79/11 79/19
80/6
Mr Stein [2] 86/18
97/18
Mrs [9] 1/6 1/7 1/16
1/21 1/25 2/3 2/9
11/22 40/1
Mrs Carol [1] 1/6
Mrs Riddell [6] 1/7
1/16 1/21 1/25 2/3
40/1
Mrs Riddell's [1] 2/9
Mrs Seema [1] 11/22
Ms [16] 1/22 2/1 6/6
40/16 41/1 42/24
43/23 86/17 86/18
86/20 88/14 104/10
104/11 218/18 233/6
233/10
Ms Badenoch [4] 6/6
41/1 42/24 43/23
Ms Badenoch's [1]
40/16
Ms Jean [1] 1/22
Ms Page [4] 86/17
86/20 218/18 233/6
Ms Smith [1] 2/1
Ms Watt [1] 86/18
Ms White [1] 88/14
much [53] 4/14 4/22
TIT 18/13 24/9 24/10
27/5 36/8 39/23 67/24
71/7 71/10 79/9 80/20
86/6 86/11 86/14 92/3
97/19 99/13 99/16
100/9 112/3 112/18
113/10 114/1 114/15
115/5 115/24 118/5
119/1 119/18 123/1
129/5 129/25 140/1
142/9 145/9 145/12
150/24 167/21 175/7
178/8 182/14 183/3
186/17 201/13 210/9
218/2 222/9 222/16
228/6 232/18
multiple [2] 84/23
85/7
multiplicity [4] 187/4
Munby [8] 139/23
149/6 153/14 156/23
166/2 167/9 170/11
172/24
Munby's [1] 166/8
must [16] 42/24 43/4
103/16 127/7 136/3
146/19 157/23 157/25
203/6 210/4 210/4
210/5 223/1 224/11
224/12 224/15
my [152] 2/8 3/8 3/19
6/17 6/19 6/22 6/25
7/1 7/6 7/12 8/19 9/17
10/23 16/3 17/3 26/22
26/23 27/14 28/12
30/7 30/9 30/24 31/6
31/7 31/15 31/25
32/16 37/16 39/8 40/1
41/19 48/7 49/16
50/12 51/19 52/11
56/25 60/9 63/22 65/6
65/14 68/17 71/7
71/15 72/4 74/18
74/24 76/22 77/10
77/11 77/14 77/16
78/1 78/6 78/15 79/22
81/25 83/22 84/5
84/10 85/13 90/15
95/15 95/17 97/9
97/10 97/18 97/19
102/11 102/19 102/21
103/13 107/1 107/8
109/20 111/10 112/20
116/21 117/20 118/4
118/6 118/8 118/25
119/25 120/1 120/15
123/10 123/18 123/24
4125/6 126/15 127/20
128/17 130/5 130/22
131/6 132/3 132/8
132/12 132/15 132/17
132/23 135/5 136/6
143/13 146/11 147/20
154/17 157/22 162/23
166/4 166/14 166/24
167/9 168/10 171/2
171/22 171/24 174/7
178/19 178/20 178/21
179/3 179/17 181/9
183/2 184/8 184/17
185/8 186/3 186/21
187/11 188/9 189/13
191/24 194/20 203/14)
203/22 206/16 206/20
206/20 208/25 213/16
216/13 219/11 219/17
224/13 226/11 227/22
228/4 228/22 230/17
myself [10] 20/9 39/7
70/13 93/16 98/21
119/6 123/17 174/16
184/20 186/15
N
name [6] 3/19 3/20
52/12 95/17 113/11
227/19
namely [2] 59/20
69/3
NAO [2] 144/7 189/15]
narrow [2] 197/8
203/20
narrowed [2] 116/3
119/24
National [4] 23/18
25/3 62/20 102/22
natural [1] 15/12
nature [6] 14/21 15/8
16/13 19/16 174/25
177/11
navigate [1] 124/20
NB [1] 164/9
NBIT [2] 105/24
106/2
NDA [1] 96/5
near [4] 20/16 73/11
73/21 96/9
nearly [2] 105/3
223/22
necessarily [4] 21/25
31/4 100/18 170/7
necessary [5] 19/12
56/6 57/13 106/7
179/15
NEDs [3] 59/19 62/2
62/25
need [69] 10/3 15/6
16/2 16/19 18/19
23/17 24/9 25/10
37/18 42/7 56/12
56/16 56/18 57/1
59/17 63/6 63/18 64/4,
68/6 71/2 74/4 75/1
75/21 92/8 93/25
97/15 98/11 98/19
99/12 100/25 101/21
108/15 108/17 118/2
120/16 128/3 128/16
145/25 152/7 153/15
153/21 155/15 155/24)
161/2 163/6 168/12
168/22 171/5 171/12
176/7 181/13 189/16
189/20 193/8 199/16
201/13 202/14 208/14
210/19 216/4 217/11
217/23 221/3 221/14
226/2 226/10 226/19
227/12 227/23
needed [28] 34/12
34/13 35/11 38/24
54/7 68/2 80/25 82/9
82/9 122/7 122/15
123/7 124/23 130/21
132/17 136/9 137/3
137/9 140/10 142/7
155/3 172/21 178/22
186/2 192/3 207/20
226/4 226/17
needing [2] 57/7
207/24
needs [8] 15/15
(83) most - needs
INQ00001202
INQ00001202
N
needs... [7] 102/25
117/14 138/6 148/12
156/19 189/10 217/22)
negative [1] 141/8
negotiated [1] 12/12
neither [2] 2/4 88/25
nervous [1] 126/22
net [2] 105/19 105/20
network [10] 62/7
62/23 64/8 64/18 65/8
71/13 71/14 75/23
107/7 108/1
never [30] 15/16
15/17 23/19 44/4
54/13 54/25 61/21
62/21 68/8 68/18
75/13 75/13 75/18
75/18 78/9 80/12
81/20 90/4 90/9 92/19
93/14 96/10 102/7
102/9 107/13 112/2
112/8 112/11 112/12
143/7
nevertheless [1]
16/10
new [24] 6/6 22/12
60/12 85/17 91/25
105/24 116/22 123/3
131/16 137/3 137/4
140/20 166/13 166/14)
166/23 188/10 189/13)
195/7 199/23 200/15
202/15 213/11 213/15
213/23
newly [1] 115/18
news [1] 225/10
newspapers [1]
21/20
next [20] 17/22 20/21
72/11 73/3 81/19
84/25 99/10 99/10
99/15 101/12 123/21
156/6 171/4 178/10
199/25 201/12 209/4
210/12 222/10 228/22
NFSP [8] 86/19
104/16 104/20 105/2
107/14 195/14 216/19}
232/3
nice [2] 7/13 102/17
niceties [1] 13/13
nick [42] 28/1 28/4
32/1 34/5 53/13 63/20)
68/4 70/13 74/24 75/3
77/10 78/10 80/24
82/7 83/14 83/17
83/24 84/19 85/22
85/25 86/2 86/6 137/6I
140/20 141/25 142/3
142/20 142/23 143/1
150/2 150/15 156/15
163/20 164/14 165/24)
167/17 167/24 168/3
168/17 169/23 185/1
217/19
Nigel [8] 60/13 61/24
63/24 64/1 117/24
164/10 216/15 217/12)
night [4] 7/3 100/6
100/12 126/22
no [51] 6/22 10/14
10/21 12/15 17/1 45/2)
46/17 53/13 54/25
55/4 55/24 59/13
59/17 68/4 74/17 83/1
89/10 95/14 103/7
107/10 107/21 108/7
109/9 111/11 111/24
120/11 131/13 140/14)
143/13 146/5 146/5
146/23 168/3 178/14
178/15 178/16 179/20)
191/1 193/11 201/15
201/18 209/18 209/19
214/12 221/3 222/2
222/4 222/9 225/5
232/5 232/16
nobody [6] 57/15
110/20 158/8 158/15
158/17 201/22
noise [1] 151/15
non [14] 18/23 41/21
58/25 59/15 60/4
62/11 62/11 96/5
146/25 176/7 177/7
202/11 202/14 220/6
non-convicted [1]
176/7
non-disclosure [1]
96/5
non-execs [2] 62/11
62/11
non-executive [2]
59/15 60/4
non-financial [1]
41/21
non-pecuniary [2]
18/23 202/11
none [1] 12/23
nonsense [2] 79/15
79/17
nor [3] 60/8 88/25
164/1
normal [2] 52/5
110/24
normally [1] 162/22
northeast [1] 1/9
Northern [3] 212/14
229/14 229/16
Norton [1] 96/9
not [202] 2/23 3/1
13/5 15/9 18/11 19/6
19/13 19/15 20/4
21/11 21/19 22/25
23/8 24/1 24/3 25/1
25/5 25/7 25/15 27/10
27/24 29/4 29/18 30/2
30/25 31/7 31/9 31/10
32/13 35/21 45/8 48/2
49/23 51/15 51/17
52/2 52/4 52/4 52/12
52/14 52/23 52/24
53/2 53/4 53/12 53/18
54/8 58/22 61/16 62/7
65/7 65/16 67/22
67/23 68/9 71/12
71/13 72/7 73/4 75/24
76/5 76/11 76/12 77/9
77/18 78/25 79/25
80/6 82/1 83/4 83/8
83/15 83/23 83/24
84/2 84/10 85/20
85/20 90/21 91/3
91/14 92/4 92/11
92/12 92/14 92/15
92/17 92/20 92/20
93/14 93/24 94/22
95/2 95/3 97/4 99/6
100/13 101/19 102/16:
102/19 103/1 103/7
104/1 105/9 105/14
106/22 107/22 108/17
109/20 111/9 118/20
118/21 126/1 126/7
127/13 129/15 130/5
131/7 131/18 136/21
137/4 138/23 140/5
141/10 141/11 141/12
143/25 146/13 148/20
148/24 149/3 150/20
151/12 155/3 155/9
158/3 159/19 161/12
164/1 166/12 166/23
167/11 174/2 174/10
175/2 175/10 176/18
177/16 177/20 177/25
178/14 178/16 179/1
180/7 180/16 183/8
183/9 183/20 184/1
185/3 185/19 186/12
186/17 187/1 188/2
188/8 188/17 189/11
190/17 191/22 193/9
194/1 194/15 194/18
195/24 196/9 196/16
196/21 197/1 197/18
200/19 201/6 201/19
206/10 211/3 211/9
214/20 215/16 217/24
219/5 219/23 220/13
221/20 222/5 222/8
222/23 223/13 226/10
226/22 227/18 229/7
232/12
note [10] 11/3 12/18
12/20 21/5 43/8 121/1
121/12 166/18 167/8
221/5
noted [9] 159/17
161/7 161/8 162/6
162/14 163/20 191/15)
192/25 228/16
nothing [4] 68/14
75/3 76/15 79/21
notice [1] 229/20
notified [1] 179/16
noting [1] 73/23
novel [5] 153/10
156/10 156/20 160/8
177/11
November [11] 1/1
2/14 45/15 137/20
138/2 141/25 145/9
159/18 220/21 229/4
229/8
November 2019 [1]
220/21
now [73] 12/4 12/11
13/17 13/21 16/20
18/3 19/22 22/11
30/15 33/15 51/18
51/18 65/2 78/3 79/24
85/9 91/3 91/18 92/6
92/7 93/21 95/23 98/5
100/1 100/16 101/8
101/13 101/14 105/25)
107/23 108/8 109/6
111/20 112/5 116/15
118/9 119/17 120/13
124/13 132/23 133/2
136/2 136/13 139/1
139/1 142/3 145/12
155/13 155/25 159/6
159/21 161/21 163/23)
167/5 170/15 175/9
1477/7 181/21 201/10
202/2 204/11 206/11
209/13 211/4 211/8
211/11 212/21 215/15
215/24 215/24 219/15
219/19 230/13
number [54] 6/22
20/24 32/11 32/15
38/1 47/23 71/19 73/4
80/17 82/18 99/2
104/18 114/1 114/16
122/21 126/2 134/1
139/7 145/18 146/1
147/8 148/13 155/1
164/22 165/22 169/1
173/15 175/6 178/2
178/6 182/17 182/21
183/11 187/10 188/23)
191/6 191/10 192/9
194/2 200/17 201/9
202/3 205/17 208/22
209/7 210/16 211/3
211/4 212/14 216/6
222/12 225/10 225/11
228/1
number 1 [1] 80/17
number 2 [1] 71/19
numbers [15] 66/5
81/11 81/14 81/15
99/4 99/5 144/24
146/4 147/2 147/11
153/1 206/3 223/2
229/6 230/8
nutshell [1] 158/19
fe)
objections [1] 203/24]
objective [5] 43/13
71/2 72/1 90/24
185/17
obscure [1] 38/2
obtain [1] 231/17
obtaining [1] 57/11
obvious [2] 12/24
94/17
obviously [29] 19/12
21/3 29/19 32/11 33/5)
50/14 51/15 53/7 69/7,
73/2 108/18 118/20
124/14 137/5 145/9
146/8 158/10 168/3
170/2 176/18 182/23
187/15 190/21 194/12)
210/24 223/10 226/20)
227/25 229/8
OC [17] 149/15
166/12 166/14 167/20)
168/20 170/1 175/8
177/6 179/4 182/15
183/10 187/10 202/9
204/11 213/2 213/8
213/16
occasion [3] 75/7
117/19 117/22
occasional [1]
206/11
occasions [4] 11/5
59/11 122/12 225/11
occurred [1] 124/25
October [14] 1/7 3/25)
5/3 5/24 6/17 13/24
113/16 114/5 122/4
137/11 137/11 150/12)
191/8 223/13
October's [1] 229/6
odd [1] 200/18
off [20] 9/7 22/21
44/4 49/22 52/7 52/10
53/14 54/7 54/8 62/16)
62/17 66/22 87/2
108/3 151/6 161/3
166/1 177/9 226/14
228/6
offences [4] 12/17
211/18 214/9 214/9
offend [1] 12/24
offer [33] 18/11
20/15 20/18 20/25
38/7 41/22 41/25 42/3,
48/19 58/5 86/23
90/19 90/20 111/1
173/23 177/7 178/13
180/7 183/10 185/9
(84) needs... - offer
INQ00001202
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fe) 8/9 10/5 11/6 11/7 21/14 21/14 21/15 157/16 159/4 161/16 I 180/18 180/19 184/24
12/22 12/24 16/2 20/1] 35/10 217/15 161/17 165/14 165/17I 185/20 194/2 194/13
offer... [13] 185/23 ‘
186/6 196/20 196/24 I 21/7 25/4 27/13 28/12I operation [1] 224/3 I 166/23 167/25 170/9 I 196/2 196/11 202/4
198/16 198/17 199/20I 29/4 30/8 33/10 33/18] operational [2] 172/4I 175/2 176/21 178/6 I 203/22 205/12 206/22
202/14 203/23 204/20 33/23 46/19 50/21 184/14 178/13 178/17 179/16] 206/23 207/19 207/22)
210/5 223/12 232/2 I 20/2151/14 53/10 operators [1] 62/23 I 180/18 180/19 181/6 I 214/9 230/11
offered [3] 35/22 53/25 54/15 58/16 opine [1] 22/25 181/13 181/15 182/3 I others [29] 9/3 11/24
114/13 183/7 59/18 62/16 62/17 opinion [4] 101/20 185/19 185/21 186/18] 17/20 30/13 34/5 39/5
offers [33] 26/20 70/11 73/3 73/7 75/10} 130/19 170/16 171/19) 189/24 190/1 190/3 I 40/2 41/19 44/12
28/9 34/15 34/16 39/1I 80/3 80/5 81/19 82/14 opinions [2] 14/10 I 190/9 191/25 197/7 I 44/21 74/24 75/4
59/10 91/23 91/23 83/12 86/18 88/13 14/13 197/9 199/21 199/23 I 77/21 89/21 98/22
92/1 108/16 161/24 I 89/23 93/20 93/24 opportunities [1] 200/13 201/2 201/12 I 107/14 117/15 138/18
96/20 97/19 98/16 154/23 203/5 206/9 206/21 I 139/4 139/10 144/18
162/3 162/16 162/19 ;
178/10 182/8 202/20 I 29/2 101/13 103/22 I opportunity [5] 13/25) 206/23 208/2 209/24 I 173/1 175/3 179/16
117/12 121/19 136/15] 78/3 192/16 198/15 I 212/25 218/11 218/11I 182/2 186/2 194/17
ene apes ce. 136/22 138/17 138/25] 230/10 219/6 222/24 223/15 I 214/23 227/12
209/10 209/14 209/16 142/23 145/23 152/7 Iopposed [2] 111/20 I 225/23 226/6 226/17 I otherwise [2] 144/19
209/17 210/3 222/23 154/14 157/10 157/11] 213/19 226/17 226/21 227/4 I 155/16
222/24 223/6 223/10 160/9 163/1 167/18 Iopposite [1] 52/16 227/7 227/16 227/16 Iour [49] 1/6 25/21
223/18 170/6 172/14 173/17 Iopposition [1] 6/1 230/21 30/4 36/6 43/4 45/20
office [303] 176/12 179/13 181/16] optimism [1] 131/14 Ioral [2] 149/9 232/19 I 47/3 47/10 47/12 65/1
Office's [17] 2/22 I 183/6 183/16 185/22 Ioptimistic [1] 123/1 order [12] 45/18 68/14 74/1 74/2 88/6
16/14 29/5 81/24 87/1 187/8 196/18 196/20 Ioption [2] 136/22 90/18 98/14 116/23 I 93/6 93/13 117/7
122/19 130/2 133/8 197/18 198/19 200/6 196/13 125/22 130/8 131/8 I 117/11 118/2 119/23
1435/7 136/5 138/1 202/23 206/11 206/16) options [8] 41/16 132/18 140/10 143/25I 122/8 125/10 130/15
1439/6 139/16 149/10 206/17 207/2 207/17 I 43/13 43/20 135/14 I 155/4 184/11 139/20 146/9 146/16
167/14 185/12 193/20) 208/16 209/18 209/19] 136/6 136/19 172/20 I organisation [16] 153/6 157/14 160/13
officer [8] 42/5 84/21 209/22 212/7 215/19 I 189/9 26/5 65/21 67/24 68/1I 170/25 173/9 184/3
146/17 153/9 156/14 219/25 222/8 229/7 Ior [176] 3/8 4/6 7/3 I 69/7 77/2 77/3 77/12 I 184/19 188/8 188/11
156/16 181/12 182/4 232/7 9/13 15/9 15/17 16/14) 80/25 82/21 83/4 83/6I 189/6 194/20 195/19
Officers [1] 145/21 one-third [2] 206/16 I 20/12 21/25 22/14 84/1 84/7 95/2 220/16] 196/8 196/18 197/15
official [8] 47/21 206/17 23/25 24/20 24/22 organisations [2] 8/4) 198/2 200/21 203/16
79/12 96/7 96/14 ones [5] 41/12 44/15 I 25/16 25/19 25/21 164/15 207/12 209/5 221/15
96/18 194/21 215/22 154/9 206/6 206/9 25/23 26/13 27/25 origin [1] 174/3 222/18 228/15
2316/1 ongoing [5] 106/19 I 28/9 30/10 32/13 original [14] 20/25 ourselves [7] 16/11
officials [18] 2/25 107/15 134/17 135/7 I 32/23 32/24 32/25 21/1 28/12 28/19 26/18 95/7 112/1
31/17 32/4 32/22 231/13 36/18 36/19 37/8 37/9I 39/13 56/21 58/20 157/4 168/11 181/16
45/19 46/8 47/9 47/14 online [3] 60/1 60/11 I 37/24 40/10 41/17 89/10 145/14 147/17 Iout [93] 1/11 3/9 4/14
49/8 77/17 78/25 65/2 46/6 46/17 49/13 50/5I 156/2 158/20 196/7 I 6/14 21/20 29/3 29/8
only [28] 23/8 25/6 I 50/12 50/13 50/14 205/21 29/21 31/7 32/14
83/22 112/8 161/8 an
161/16 189/6 205/7_ I 30/10 40/10 41/11 53/2 53/13 55/2 56/1 Ioriginally [4] 10/23 I 36/20 49/10 50/24
53/18 54/13 71/21 56/8 56/23 57/12 27/7 159/8 193/10 61/23 62/3 63/8 69/2
one tt} 73/11 73/5 74/8 77/13 78/13) 57/24 58/22 62/16 originate [1] 39/2 69/3 69/8 70/16 71/1
often [6] 15/1 31/19 78/17 80/4 83/24 64/3 64/7 64/9 64/10 Ioriginated [2] 39/3 I 71/20 74/2 81/13
35/19 98/17 98/20 104/1 106/13 110/6 I 65/1 65/18 66/4 71/3 I 147/12 82/22 87/14 87/15
154/22 111/12 130/11 143/20) 71/9 71/11 72/3 72/15I other [78] 16/19 89/3 89/7 89/14 89/22
178/16 183/17 183/20) 72/19 73/11 75/4 75/8) 17/11 33/25 41/17 90/4 90/7 90/11 90/18,
Oh [8] 58/3 97/17 I pozi14 210/21 224/17I 75/16 80/15 82/15 I 43/12 43/15 43/20 _I 90/21 90/22 91/4
110/4 140/16 143/6
143/11 143/13 168/18I 220/7 82/19 88/5 88/8 88/20) 47/5 47/15 49/5 50/10I 91/16 93/22 94/21
okay [22] 20/13 onto [2] 128/24 89/14 89/24 92/22 54/18 54/25 57/4 57/4I 95/9 95/12 96/16
38/20 69/20 75/12 190/19 92/23 93/7 93/7 93/12I 57/23 59/1 61/8 63/21I 101/1 115/13 116/21
75/14 107/4 1089/3 IOMwards [2] 132/23 I 98/13 98/23 99/2 64/20 65/23 68/7 70/7I 117/1 117/4 123/21
183/23 100/6 102/24 103/8 I 70/11 71/9 76/1 77/1 I 123/24 126/19 131/14
$e ie aytd wean open [5] 14/1 104/3 I 103/21 105/6 105/9 I 80/3 82/1 88/24 92/8 I 133/3 134/2 135/7
163/11 179/19 221/1 I 146/20 192/24 198/3 I 106/20 107/13 107/14) 97/13 97/20 99/17 135/17 136/7 142/9
222/3 223/7 223/9 Ipened [1] 212/2 109/12 110/6 110/11 I 101/15 102/13 106/7 I 143/23 144/4 144/19
operate [6] 21/18 110/21 111/4 111/17 I 109/3 110/9 110/21 I 145/12 145/21 148/4
nia) 292/14 58/7 108/17 119/7 112/6 117/18 118/10 I 119/15 119/21 121/20] 148/9 150/15 152/4
once [5] 48/13 135/18 171/20 119/6 120/6 125/3 124/9 126/10 145/21 I 163/25 174/9 175/15
101/11 111/19 186/6 IOPerated [3] 27/9 127/12 132/1 132/4 I 151/8 152/19 152/24 I 177/24 179/4 180/20
202/12 58/8 62/10 135/23 136/11 136/23) 157/24 160/24 162/13] 182/14 183/3 187/5
one [100] 1/6 4/1 operates [2] 110/14 I 141/14 141/17 143/12) 162/16 163/18 164/15) 189/15 194/4 194/18
186/6 144/22 145/18 147/5 I 169/2 170/1 172/2 196/6 200/16 208/3
5/23 6/22 7/12 7/16 I erating [6] 21/13 I 152/15 156/10 156/20) 174/19 175/25 180/17) 209/3 209/5 209/10
(85) offer... - out
INQ00001202
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fe) oversee [1] 101/19 I 129/23 140/22 150/14I 191/3 224/24
171 210/29 0210/3 Ioverseeing [1] page 12 [2] 4/2 4/4 I paragraph 36 [1] partially [2] 161/5
CeO aioe soar) 166/14 page 14 [2] 32/8 79/10 161/6
230/15 231/7 oversees [1] 212/13 I 55/16 paragraph 4 [1] Participant [2] 2/1
outcome [9] 12/23 oversight [4] 35/9 I page 17 [1] 4/15 53/10 86/15
122/25 123/2 140/7 102/24 102/25 173/4 I page 2 [13] 9/6 44/19I paragraph 41 [1] participants [6] 1/6
1441/7 141/9 181/18 Iovertly [1] 13/7 52/9 69/11 87/25 210/18 2/2 34/11 210/11
181/20 205/20 overturn [2] 120/16 I 87/25 89/12 94/5 paragraph 44 [2] 4/4 I 215/5 225/12
outcomes [3] 149/24 187/13 104/23 123/23 128/25) 80/23 participate [1]
174/22 207/7 overturned [26] 135/6 191/10 Paragraph 45 [1] 207/25
outfall [1] 45/3 18/23 27/15 27/20 Ipage 20[1] 114/9 I 83/12 particular [16] 7/20
outline [1] 152/11 I 28/11 29/25 34/24 Ipage 3 [10] 6/11 9/6 Iparagraph 46 [1] 8/6 8/7 21/19 31/20
outlined [1] 184/15 40/24 41/10 51/6 44/20 72/22 133/4 81/21 41/22 46/11 52/17
outlining [4] 166/20 80/10 87/8 95/21 139/3 163/17 192/21 Iparagraph 48 [1] 96/8 103/9 111/5
outnumbered [1] 95/22 131/6 151/5 204/22 221/12 76/16 160/10 177/13 204/12)
163/24 170/19 175/18] page 4 [2] 150/13 paragraph 55 [2] 215/8 227/3
190/2 202/2 213/11 150/22 32/7 55/15 particularly [19] 1/12
outrage [1] 13/16
outside [9] 59/8 213/18 214/20 228/25I page 50 [1] 2/19 Paragraph 6 [2] 6/11 I 7/18 33/7 44/16 52/25
231/3 231/6 page 6 [1] 22/16 63/6 65/11 70/14
Bos eee a0 4 [overturning [1] 80/9 Ipage 7 [1] 73/9 paragraph 60 [1] 119/23 120/5 133/10
189/19 214/10 own [14] 1/13 2/8 Ipage 71 [1] 113/20 I 191/4 146/12 148/20 169/23
outstanding [3] 13/17 65/1477/11 _ Ipage 8 [1] 66/7 paragraph 8 [1] 169/25 189/13 206/24
162/13 222121 223/17) 84/10 122/25 127/20 Ipage 9 [1] 77/7 100/2 219/5 219/10
outweigh [1] 153/2 130/19 130/22 166/14I pages [2] 4/1 59/18 I paragraph 81 [1] parties [1] 117/5
over [62] 1/14 2/10 I 166/24 211/13 230/25Ipages 119 [1] 59/18 I 225/19 partly [6] 124/3
4/9 11/20 17/22 20/24 /owner [1] 159/8 paid [21] 10/14 10/21Iparagraphs [8] 6/13 I 156/21 171/22 180/24
33/14 33/15 42/20 I Iownership [3] 144/7 I 12/5 33/14 49/10 6/14 19/18 22/16 194/20 201/13
45/15 53/19 60/12 I 164/7 1685/2 53/16 76/24 77/3 31/13 42/25 84/25 _ I partner [3] 164/15
61/19 63/25 71/23 jOWning [1] 100/22 _I 81/25 87/9 87/14 92/2) 170/12 213/4 213/5
74/3 75/17 78/21 PI 99/14 152/1 1611 Iparagraphs 19 [2] I parts [2] 118/6
91/17 91/18 94/16 I—_—s I 176/10 1841/1 182/14 I 22/16 31/13 207/12
104/13 105/1 105/25 IPace [6] 32/12 34/6 I 201/19 206/1 223/5_IParagraphs 6 [1] _I party [5] 6/6 7/20 8/1
407/25 117/2 19/4 I 06/15 76/13 83/11 I panel [13] 39/18 59/1/ 6/13 35/5 164/4
4119/4 149/17 119/22 I 888 175/14 180/8 193/1 Iparallel [1] 166/13 Ipass [1] 121/14
420/25 127/24 128/21IPaced [1] 146/2 196/16 196/19 196/22I parallels [3] 8/12 _ I passage [2] 53/10
129/1 12915 13516 PACK [4] 72/21 81/10 I 196/23 197/10 198/9 I 11/1 11/5 21216
4138/3 138/15 140/17 I 107/25 216/5 198/11 215/14 parameters [1] 59/8 Ipassages [3] 19/3
440/20 150/22 154/15I Package [2] 69/13 I panel's [3] 195/24 I paramount [1] 43/4 I 121/10 204/23
4155/1 157/8 158/10 I ©2/15 197/2 197/20 Parker [9] 123/1 passed [10] 19/7
159/13 163/17 163/21IPage [73] 2/194/2 I panned [1] 90/11 127/5 134/21 137/11 I 27/23 40/3 61/6 96/9
4164/8 169/21 17316 I 4/4 4/15 4/15 6/11 9/2Ipants [1] 41/12 138/4 139/5 140/8 I 122/11 142/5 192/20
4175/9 17/4 177/22 I 9169/6 11/20 17/21 I paper [2] 136/4 142/17 221/14 232/1 232/4
4179/6 191/9 192/9 17/22 18/1 22/16 32/8I 159/17 Parliament [14] 3/21 I passing [1] 18/5
42/21 44/19 44/20 I paragraph [29] 4/4 I 4/24 7/13 50/14 52/11I passport [1] 65/1
et aoe 21919 I 5919 53/11 55/16 6/11 6/16 13/5 32/7 I 80/13 96/14 101/18 I past [13] 26/18 28/4
overall [8] 7/6 72/25 I 81106113 61/19 I 4zi23.sa/10.53/11 I 115/13 115/16 148/14) 42/25 60/18 65/15
80/19 152/8 1529 I 05/7 69/1 69/11 71/18) 55/15 61/9 66/7 BE/9 I 214/5 214/17 214/22 I 97/7 97/8 101/25
152/11 153/9 163/4 I 21/23 72/22 73/9 77/7) 76/16 79/10 80/23 I Parliament-facing [2]I 101/25 119/17 139/12]
overarching [1] 85/1 86/17 86/20 81/21 83/12 83/16 115/13 115/16 140/18 164/8
152/16 87/25 87/25 88/14 I 84/18 85/1 100/2 Parliamentary [6] 5/5Ipasted [1] 121/13
overcome [1] 143/10 89/12 93/19 94/5 104/24 191/3 191/4 I 5/18 8/1 96/25 115/15I patch [1] 219/11
overcomplicated [4] 104/23 104/24 113/20] 202/24 210/18 215/1 I 115/24 patronising [1] 127/6I
174/25 113/20 114/8 114/9 I 225/19 225/25 part [37] 6/198/18 I Patterson [1] 217/18
lap (4) 117/11. I 120/28 123/23 123/23] paragraph 1 [1] 15/7 24/19 33/6 34/25) Paul [12] 8/8 10/17
overlap [1] 127/17 128/25 129/1 I 42/23 35/23 54/14 56/21 I 10/23 12/18 14/5
overly [2] 13/7 220/3 I 1299/5 129/23 133/4 Iparagraph 114 [4] I 57/1462/15 71/14 I 102/12 142/2 167/18
enh eos tons 135/6 138/3 1139/3 I 215/1 74/25 72/11 72119 I 172/10 172/17 172/25
overpaying [1] 140/22 150/13 150/14I paragraph 151 [1] I 79/25 95/5 96/11 217/18
eet 150/22 159/13 163/17I 225/25 98/24 99/7 100/21 I Paul Marshall [3] 8/8
overpayment [3] 163/17 191/9 191/10 I paragraph 29 [1] 110/9 121/3 123/9 I 10/17 102/12
180/13 186/4 1867 I 192/21 204/22 218/18) 202/24 127/20 132/14 152/7 IPaula [1] 122/6
overplayed [1] 221/12 233/6 paragraph 30 [2] 160/9 182/7 187/23 I pause [3] 22/10
154/18 page 1 [8] 18/1 53/11I 66/7 66/9 190/4 199/24 205/11 I 124/15 195/7
88/14 123/23 127/17 I paragraph 33 [1] 209/4 211/14 212/5 I pausing [2] 130/17
(86) out... - pausing
INQ00001202
INQ00001202
P 95/18 95/19 95/21 I 44/3 44/5 49/19 placed [1] 175/4 110/13 110/23 116/3
pausing. [i] 161/10 96/15 97/4 9716 97/7 I 115/18 124/22 137/4 Iplaces [2] 183/12 I 116/13 124/11 126/11
ay [31] 12/6 12/15 I 97/9 97/15 97/21 139/10 146/14 156/17I 218/18 127/10 127/12 128/18
eee l24 38/24 46/7 97/23 97/24 97/25 I 159/11 161/3 17/7 _Iplain [1] 185/24 132/3 133/17 135/12
46/15 5013 83/14 98/10 99/2 99/2 99/3 I permission [5] 129/3I plainly [1] 89/6 4137/7 141/21 143/21
83/23 85/3 85/9 86/3 I 99/4. 100/12 102/13 I 129/8 129/11 129/16 Iplan [10] 73/12 75/12) 14/1 144/9 144/9
gals see sera geo I 1095 110/4 110/10 I 202/7 75/13 81/4 170/25 I 146/5 146/8 146/16
B6/10 88/15 90/19 I 110/19 110/20 120/17I permitted [1] 53/16 I 171/3 184/15 214/2 I 150/25 152/6 156/17
90/22 91/11 104/2 I 123/18 131/5 132/9_I persistent [1] 66/23 I 214/13 216/10 158/20 160/12 162/25
104/3 109/25 134/15 I 144/24 146/20 146/22I person [7] 25/6 50/2 planning [1] 83/1 164/6 165/11 165/23
138/11 138/21 138/23I 147/24 148/25 150/2 I 85/20 107/9 110/5 plans [5] 64/3 65/24 I 166/4 167/5 168/20
158/17 160/18 227/2 I 1590/4 152/4 154/17 I 110/6 180/25 74/6 74/7 217/13 169/4 169/10 170/6
paying [2] 87/15 155/4 157/24 158/5 Ipersonal [8] 56/7 Platform [1] 71/20 170/7 175/9 176/14
90/21 169/10 172/4 172/16 I 90/8 97/17 130/19 plausible [1] 165/14 I 179/3 182/2 183/2
payment [19] 41/23 173/3 176/18 176/19 I 130/22 147/19 148/10) play [6] 30/19 34/25 I 185/8 189/6 189/11
47/8 55/19 87/13 178/23 179/8 180/9 I 171/19 102/23 127/15 143/21I 189/15 191/19 191/25
87/14 92/9 92/13 180/11 180/22 181/5 Ipersonally [6] 6/25 I 148/2 192/3 192/6 192/11
99/20 101/4 108/23 I 182/2 182/17 182/18 I 7/9 44/7 45/1 201/10 I played [2] 125/23 194/22 194/25 195/6
109/11 153/11 179/18I 182/19 182/22 183/4 I 226/13 204/5 197/17 197/22 198/25)
4183/8 183/9 183/22. I 187/15 187/19 188/13I personnel [1] 122/16 players [1] 144/17 I 200/22 203/15 209/21
4187/8 227/4 227/15 I 189/2 189/19 189/21 Ipersons [1] 1/25 playing [1] 204/13 I 210/23 210/24 215/13
payments [41] 2/17 I 190/12 190/19 195/13Iperspective [17] _I pleasantries [1] 61/6] 219/8 220/11 224/13
19 88/20 -89/3 ag/7 I 195/20 199/2 199/4 I 47/13 62/13 75/20 _ I please [69] 3/16 3/20) 224/17 224/19 227/22
91/2 181/14 181/18, I 200/13 201/14 208/3 I 142/10 147/24 149/3 I 4/2 4/22 6/10 8/25 I 230/13 230/23 231/1
151/20 181/21 152/14I 209/23 210/17 211/3 I 149/4 149/7 153/8 I 17/14 17/21 18/1 18/9I pointed [5] 91/16
152/17 182/20 186/18I 212/11 212/23 213/10I 164/8 165/3 166/24 I 18/22 22/15 25/22 I 134/8 141/8 169/12
159/14 159/18 160/5 213/18 225/17 226/14] 169/20 177/25 179/10) 40/9 42/19 42/20 194/4
4612 161/15 161/18 I 227/10 227/19 228/12I 182/13 205/9 43/19 44/19 45/6 —_I points [11] 3/15 18/7
17112 174/10 192/16 I 228/25 230/5 230/6 Ipersuade [2] 138/23 I 47/18 51/11 55/9 I 70/5 150/23 164/13
482/00 183/4 1@3/18 I 230/8 230/15 230/19 I 195/5 59/14 60/14 66/7 167/3 170/4 176/12
183/22 215/25 224/23I 230/25 230/25 231/9 IPeter [1] 11/25 69/11 73/9 77/6 80/23) 183/6 194/4 207/2
204/23 225/90 da8/o4I 231/15 231/17 231/18IPeters [2] 21/7 84/15 112/22 113/11 IPOL [3] 52/7 171/12
SosID5 206/3 2a6I14 I 2321 232/8 22117 113/19 114/8 120/23 I 220/9
227/11 227/14 227/15I People's [4] 15/1 phase [1] 153/20 120/25 123/22 124/15IPOL's [1] 138/6
2928/1 228/2 228/9 36/19 98/1 202/4 phased [2] 93/22 127/17 129/23 133/1 IPOL00337435 [1]
per [12] 65/16 80/19 I 94/21 133/4 134/20 134/20 I 221/5
peak [2] el 1823 91/22 91/24 105/18 I PHILIP [3] 113/8 135/6 135/9 135/13 IPOL00447841 [1]
ert TPO 202/14 I 105/20 105/21 119/14) 113/12 233/14 138/3 139/3 139/5 68/24
202/14 202/17 202/20I 161/11 176/25 198/8 I philosophically [1] I 140/22 140/23 150/13I POL00448411 [1]
202/25 209/6 220/5 150/22 157/20 159/13) 51/12
peers [1] 43/7 percentage [3] 7/7 Iphone [1] 124/6 161/5 161/23 163/17 IPOL00448706 [1]
eople [178] 4/9 4/11 77/15 80/20 phrase [3] 38/1 164/25 168/18 169/7 I 84/15
eine 10/4 20/11 22/1 IPerception [1] 95/4 I 103/10 190/10 184/14 185/24 191/9 I police [2] 217/22
23/1 23/3 23/5 24/5 IPerfectly [1] 50/23 I physical [6] 15/23 192/18 192/21 204/15) 217/23
24/14 25/8 25/16 perform [1] 35/23 37/1 56/8 75/25 90/1 I 231/23 policy [12] 45/21
25/25 26/21 26/25 performance [3] 97/25 pleased [1] 8/18 115/1 115/20 115/25
27/3 30/12 30/12 I 69/21 134/19 219/6 I pick [2] 88/17 157/14Ipleasure [1] 112/20 I 116/7 118/1 183/9
30/25 33/24 35/6 perhaps [12] 1/20 Ipicked [3] 125/11 _I plus [3] 18/10 145/13I 185/4 189/6 198/21
37/11 37/13 38/1 38/6) 3/11 13/1 50/10 97/20] 195/7 213/8 17915 198/22 199/19
100/17 102/4 131/18 Ipicking [1] 45/20 Ipm [5] 113/2 113/4 I political [7] 47/12
an aero soto 40/6 141/6 166/6 203/13 I picture [2] 139/22 173/12 173/14 232/22I 48/4 172/22 181/23
52/12 52/18 53/6 53/8 232/3 141/16 PNC [1] 179/5 182/24 205/9 205/19
53/12 58/15 59/6 62/9 period [22] 13/23 piece [3] 136/14 point [108] 19/1 politically [1] 165/15
62/22 64/23 65/8 65/8 54/11 75/17 76/19 162/22 176/8 26/20 28/16 30/19 politician [2] 182/17
65/12 65/20 65/22 77/22 119/18 119/19 Ipiggyback [1] 190/19] 45/6 45/7 49/21 70/1 I 185/20
66/2 66/4 66/6 68/6 119/22 124/22 128/21I pilot [1] 37/15 71/18 77/10 78/4 politicians [4] 88/9
73/4 75/21 76/7 76/10) 140/17 157/8 158/10 I piloted [2] 36/16 78/12 78/15 80/12 88/24 182/13 189/21
77/2 77/2 77/4 77/25 177/22 179/2 185/7 I 36/22 80/21 82/14 85/14 pool [2] 221/22 225/8
78/1 78/2 80/11 81/14] 194/11 219/9 219/12 I place [16] 15/3 20/2 I 85/21 85/24 86/3 86/9I poor [3] 9/17 133/10
83/3 89/18 89/22 224/1 230/3 231/15 I 20/3 26/24 95/13 87/11 87/20 89/11 182/21
89/23 90/2 90/4 90/7 IPeriods [2] 7/6 80/19) 101/11 101/24 115/9 I 89/20 90/3 90/15 population [1] 179/7
90/10 91/12 91/14 Perm [2] 116/17 126/16 143/2 198/14 I 91/13 96/13 102/19 I portal [1] 212/2
92/4 92/17 93/8 95/1 I 156/3 203/17 204/25 215/11] 102/21 103/9 103/14 I portfolio [2] 5/20
permanent [13] 39/5 I 215/15 217/13 103/19 107/19 110/2 I 8/19
(87) pausing... - portfolio
INQ00001202
INQ00001202
P 135/20 209/1 problem [16] 15/15 I 166/18
position [18] 2/15 _ pre-existing [1] principal [6] 63/17 16/12 33/7 33/7 61/12I properly [10] 14/1
2/20 5/8 5/13 6/3 227/12 78/15 80/21 153/9 61/20 80/9 94/17 23/5 23/15 25/15 26/7
52/25 59/22 78/22 pre-offer [1] 173/23 I 156/16 188/14 100/21 107/15 107/21] 26/8 49/3 58/19 68/18
78/23 121/25 130/17 IPrecarious [1] 59/22 I principally [3] 84/4 I 126/8 165/25 199/9 I 94/23
163/4 167/13 171/22 precedent [9] 47/5 187/8 219/18 207/10 225/6 proportion [1]
4181/5 186/15 193/5 I 130/12 159/20 159/25] principle [10] 39/14 I problematic [1] 211/13
203/25 160/7 164/14 180/17 I 45/17 47/10 77/10 165/8 proposal [12] 43/2
positions [1] 5/17 202/16 205/10 85/19 161/11 176/8 Iproblems [10] 17/9 I 43/16 43/22 44/1 88/7
ositive [2] 25/6 precedents [1] 185/13 197/7 228/12 I 32/11 39/16 80/2 82/7) 88/7 106/14 138/11
ee 410 160/19 principle’ [1] 171/4 I 89/23 98/2 106/22 I 156/20 164/14 194/22I
possibility [4] 129/14]Preceding [1] 6/14 [principle-based [1] I 106/22 140/18 195/19
186/8 186/9 199/6 precise [1] 211/4 185/13 procedural [1] 197/6 I proposals [5] 39/1
possible [21] 17/13 precisely [1] 185/25 Iprinciples [19] 24/6 IProcedure [2] 196/6 I 47/12 50/20 195/16
‘40/20 45/23 50/6 70/8 predecessor [1] 24/13 24/15 56/10 199/23 204/22
73/10 88/12 88/23 50/12 176/5 177/8 177/10 Iproceed [2] 156/13 Ipropose [1] 3/7
104/3 1068/1 124/16 IPrefer [2] 48/2 93/8 I 185/5 196/15 202/11 I 163/10 proposed [3] 47/3
141/11 195/19 155/22I Preference [1] 202/13 202/17 203/1 Iproceeding [1] 162/5I 171/10 192/4
478/24 183/7 187/20 I 135/15 203/10 203/12 203/17Iprocess [40] 15/6 I proposing [1] 161/19}
201/18 208/19 224/19] Pregnant [1] 11/22 I 215/11 215/15 226/21) 15/19 16/20 25/9 proposition [1]
225/14 preparation [1] 54/19Iprinciples-based [1] I 30/22 31/1 39/23 42/4] 199/17
possibly [1] 199/15 IPrepare [3] 53/17 I 185/5 45/24 46/6 46/10 _I pros [9] 108/16
54/7 54/8 prior [8] 85/16 132/3 I 46/13 47/23 54/5 57/9I 108/20 108/23 109/3
oe tinaster [21] prepared [4] 52/12 I 132/8 132/22 140/4 I 58/25 59/13 79/25 _I 166/20 166/22 172/15I
52/23 98/12 186/16 I 147/1 157/11 181/21 I 80/11 90/2 90/4 102/7) 186/24 187/4
ae ee a 6216) preparing [1] 188/7 Ipriorities [12] 69/3 I 103/1 110/10 144/6 Iprosecute [1] 106/24
70/25 71/2 71/11 present [9] 72/20 69/8 69/13 69/14 147/17 178/3 180/4 I prosecuted [2] 11/7
71/24 105/5 107/5 105/19 118/10 133/15) 69/16 69/19 70/16 182/22 187/20 189/23) 188/17
149/3 190/6 190/11 I 134/24 135/11 142/18) 71/17 71/22 71/23 191/15 191/16 193/15] prosecution [4]
179/22 221/7 77/5 216/3 194/2 194/6 196/19 13/18 141/14 151/6
pact 22716 I sesentation [3] prioritise [1] 186/3 I 202/6 224/25 229/18 I 214/2
postmasters [36] 72/15 72/16 72/19 prioritising [1] processes [9] 25/2 I prosecution’ [1]
2/16 17/12 40/18 presented [3] 141/16I 194/12 25/11 41/8 56/3 66/21I 170/18
41/10 44/11 49/5 58/1 159/17 172/20 priority [4] 6/22 50/8 I 79/5 83/2 95/10 103/5I prosecutions [7]
58/6 62/11 63/9 Be/1aI Presently [1] 201/3 I 71/4 80/18 processing [2] 48/3 I 11/19 12/3 12/10
67/9 68/12 71/8 71/19I Press [5] 44/8 194/17I private [9] 17/23 19/8) 206/25 86/23 107/11 139/12
71/22 72I7 104/25 195/9 220/24 229/19 I 20/21 21/6 31/25 produced [2] 113/15 I 216/10
106/9 106/19 106/25 IPress'[1] 221/15 I 44/23 60/15 107/11 I 114/4 prospect [1] 101/4
423/16 132/16 133/25) Pressed [1] 208/13 I 139/4 Professor [2] 35/7 Iprotect [2] 44/6
134/15 138/20 143/3 pressing [1] 126/1 Iprivately [2] 180/10 I 35/8 48/24
169/25 170/14 170/20I Pressure [7] 41/25 226/5 Professor Richard _I protection [2] 44/23
170/25 188/23 216/17, 84/1 92/17 139/19 pro [5] 98/21 99/3 [1] 35/7 164/21
22/8 225/21 227/23 167/2 181/23 220/17 I 102/11 102/14 219/23) profile [3] 20/24 21/8 I protections [1]
postmasters' [4] pressured [1] 110/11Ipro bono [1] 98/21 I 21/25 198/14
i2 67/5 142/10 pressurise [1] 88/16 I probability [1] profitable [1] 65/5 I proven [2] 78/18
169/20 presumably [6] 108/25 Programme [1] 165/8
57/10 61/7 72/22 probably [53] 22/21 I 71/21 provide [12] 13/25
potential [18] 42/7
‘47/6 60/4 63/25 91/2 130/10 179/25 221/17I 25/4 26/2 28/19 30/21Iprogress [6] 15/12 I 23/10 37/20 98/14
96/6 121/21 134/1 pretty [6] 35/21 38/13] 30/22 37/16 38/12 126/25 162/16 183/2 I 135/13 137/22 159/19
134/9 147/9 153/5 46/5 78/11 127/22 46/18 50/9 80/10 196/21 206/6 168/14 217/14 226/13)
465/12 170/17 191/11] 1595/7 101/1 101/18 101/22 I progressed [2] 227/5 230/22
191/20 193/4 193/6 [Prevent [1] 17/2 103/2 119/8 120/14 I 159/22 222/17 provided [9] 11/4
194/5 previous [13] 8/13 I 122/24 128/14 131/4 I progressing [2] 48/2 I 12/18 18/4 27/1 32/19
14/22 44/2 44/14 131/24 137/4 137/7 I 156/5 59/16 147/6 224/2
potentially [4] 111/24I
139/7 165/19 198/19
potshots [1] 221/9
poverty [1] 98/3
power [4] 8/20 8/21
77/19 85/15 125/8 I 140/1 140/2 140/15 prohibit [1] 94/11 I 231/5
125/20 136/15 178/21] 141/7 143/23 144/20 Iproject [1] 135/17 I providers [2] 94/2
188/18 218/11 230/7 I 145/2 145/11 146/10 Ipromoted [1] 5/8 I 94/22
previously [5] 107/18] 146/11 147/18 150/3 Iprompt [5] 171/5 _I provides [2] 139/11
40/3 11/2 156/3 166/24 191/7 I 161/18 168/15 170/3 I 181/22 185/18 185/19] 170/17
practice [1] 53/23 232/2 175/3 177/14 179/5 I 185/23 providing [11] 23/22
pre [5] 58/5 135/20 primarily [3] 9/11 181/21 187/21 190/5 Ipromptly [2] 129/25 I 23/25 32/20 34/2
1473/23 196/20 227/12 9/16 119/25 192/11 197/1 198/6 I 181/24 35/17 37/4 44/11
primary [1] 9/23 205/4 213/16 215/16 I proper [5] 13/10 116/18 129/2 132/22
pre-agreed [1] Prime [3] 5/4 44/12 I 217/17 223/3 228/11 I 13/21 40/19 157/13 I 160/22
(88) position - providing
INQ00001202
INQ00001202
Pp
provision [4] 22/13
34/12 54/16 174/24
psychiatric [1] 56/8
public [22] 12/3
13/22 21/11 21/12
43/5 44/6 48/22 48/24
48/24 50/18 50/24
53/21 83/7 86/24
104/4 105/12 109/24
109/25 112/4 130/25
156/12 201/15
publicised [1] 17/6
publicity [4] 200/11
201/4 201/6 201/7
publicly [5] 185/20
212/17 215/19 228/24
231/2
published [10] 114/2
114/17 198/24 207/9
217/6 223/25 227/18
229/3 229/8 229/23
publishing [1]
182/13
purdah [1] 54/10
purely [2] 24/15
175/11
purpose [11] 11/12
33/4 35/2 61/22 62/1
67/11 69/3 69/6 72/25
73/5 83/1
purposefully [1]
172/19
pursue [4] 13/17
42/12 135/16 167/12
pursued [1] 216/25
push [2] 49/8 58/17
pushed [3] 27/2
49/11 76/22
pushing [2] 86/7
112/24
put [21] 20/2 26/21
26/24 37/19 46/22
52/12 75/10 75/14
97/19 107/19 134/14
139/19 143/2 148/21
152/22 166/3 181/5
186/15 196/1 196/16
220/16
putting [7] 12/22
15/3 16/13 84/23 85/7
92/17 139/20
qualify [1] 228/25
quality [1] 207/20
quantified [4] 160/16
161/1 161/5 161/6
quarterly [2] 139/17
184/22
quashed [3] 211/21
229/2 231/16
Queen's [1] 221/6
queried [1] 48/21
question [43] 6/23
9/17 15/16 26/11 47/3
89/5 94/16 98/20
100/16 100/24 101/23)
104/15 104/16 111/10)
125/16 125/18 129/20)
143/16 143/20 144/7
146/17 146/24 153/13)
156/10 160/2 160/7
163/5 166/22 169/3
175/3 176/4 186/22
188/6 188/9 188/18
189/7 198/9 201/11
215/21 228/22 231/20
232/7 232/11
Questioned [16] 3/18I
86/20 95/16 104/11
108/14 113/9 218/23
222/11 233/4 233/6
233/8 233/10 233/12
233/16 233/18 233/20
questioner [1]
218/22
questioning [1]
53/20
questions [28] 11/13
23/21 53/3 53/6 53/8
86/12 86/15 86/17
86/22 95/15 101/14
102/18 108/8 115/15
115/24 127/23 157/11
161/20 188/12 188/16)
207/18 210/11 218/3
218/6 219/3 228/23
232/15 232/16
queue [6] 37/8 37/12
89/21 89/22 91/14
226/6
quick [3] 151/1 160/5
161/15
quickest [1] 95/11
quickly [38] 17/13
19/15 29/20 30/23
30/25 38/13 39/9
39/23 39/24 45/25
58/14 63/23 87/17
88/5 88/12 88/23
89/14 90/3 92/6 93/12
132/18 134/4 134/14
136/11 146/24 152/4
152/14 155/7 155/22
178/24 183/3 187/20
187/24 195/8 203/19
204/16 210/3 210/12
quite [90] 2/23 21/12
30/13 43/25 43/25
44/2 49/14 54/16 61/5
67/1 78/22 81/12
81/18 82/11 83/4
98/15 116/16 118/22
120/9 124/12 127/4
127/6 127/6 128/12
138/22 140/3 141/22
143/14 144/18 145/1
146/8 147/23 148/6
148/9 149/5 149/22
151/22 151/25 152/23
153/19 154/8 154/15
154/19 154/22 155/7
156/11 157/7 166/9
167/1 167/4 168/6
168/9 172/4 176/19
177/21 178/3 180/6
180/8 182/18 187/14
188/10 188/15 189/12
190/21 191/24 192/12
192/20 194/25 195/1
195/8 195/18 198/3
204/3 204/10 204/16
205/14 207/21 207/23
208/1 210/12 211/13
214/16 214/17 216/16
220/2 220/16 227/22
228/1 228/3 230/15
quote [2] 2/24 223/4
quotes [1] 166/9
R
racism [1] 78/19
radical [5] 42/3 44/2
44/3 49/15 136/19
Railton [4] 60/13
61/24 63/24 117/24
Railton's [1] 216/15
raise [7] 10/4 10/4
10/6 31/21 46/9 59/21
126/21
raised [19] 37/23
42/6 59/5 80/5 82/19
82/20 96/24 97/1
138/4 150/20 160/3
179/15 184/20 194/3
207/16 207/22 208/16
217/10 232/2
raising [3] 46/16
103/9 161/20
ran [41] 147/25
range [3] 170/1 177/5I
190/12
rapid [1] 92/3
rapidly [3] 40/20 41/8)
47/24
rare [1] 111/2
rate [3] 77/18 78/25
187/14
rates [1] 99/20
rather [25] 3/8 22/5
25/13 30/20 36/9
37/20 45/19 45/21
46/25 48/12 56/15
58/9 70/25 111/13
121/15 123/15 129/19)
132/13 133/13 136/12
147/20 150/2 152/9
172/20 198/3
ratified [1] 59/10
RBS [3] 7/19 14/23
44/16
reach [6] 48/5 172/22)
175/4 199/16 214/15
220/1
reached [5] 121/24
125/12 142/8 196/11
214/21
reaching [1] 47/21
react [1] 21/12
reaction [1] 43/22
read [57] 13/5 19/6
22/4 27/23 28/1 32/1
32/25 34/5 52/21
52/22 53/2 53/13
53/13 63/20 68/4
70/13 71/24 72/12
74/24 75/3 77/10
80/16 80/21 80/24
81/22 82/7 83/17 85/4
85/9 85/25 86/3 86/7
107/25 121/10 127/18)
132/5 132/5 133/3
137/6 140/20 141/25
142/3 142/20 150/2
150/15 150/15 150/22)
156/15 163/19 163/20)
165/24 167/17 167/24)
170/12 185/1 185/14
217/19
Read's [8] 78/10
78/10 82/5 83/14
84/16 84/20 85/22
164/14
reading [5] 10/25
48/6 48/7 130/5 131/6
reads [1] 40/16
ready [8] 18/9 85/20
85/23 162/4 162/18
208/10 209/24 210/7
real [7] 97/11 129/14
131/23 131/25 141/18)
152/25 154/7
realise [3] 111/21
140/1 144/18
realised [4] 8/11
142/11 146/21 192/11
realistically [1] 50/5
reality [1] 95/4
really [20] 19/18
21/19 51/8 62/4
102/19 102/21 103/15)
120/24 128/1 140/1
149/19 168/8 177/20
189/17 204/7 208/21
219/17 224/3 224/17
231/20
reason [15] 21/10
22/24 35/13 62/12
68/7 68/9 76/24 83/25
148/13 181/16 206/19)
212/5 219/16 219/17
227/117
reasonable [4] 13/25
30/5 86/8 211/20
reasonably [1] 219/1
reasons [15] 17/11
19/24 24/16 31/5
32/14 32/15 50/24
58/17 79/14 164/23
165/1 165/1 165/3
166/7 170/1
reassured [1] 34/7
rebuffed [1] 47/9
Recaldin [15] 2/14
2/15 2/18 86/25 90/12
150/4 152/24 173/18
176/24 178/1 179/13
183/5 183/11 188/2
193/17
Recaldin's [2] 184/10)
203/24
recall [5] 104/18
169/14 188/1 221/1
222/6
receipt [2] 18/14
226/1
receive [7] 13/12
31/23 41/15 46/3
180/15 193/3 199/8
received [18] 2/5
28/22 32/13 39/11
80/4 87/22 91/23
170/15 192/7 206/1
210/22 211/7 211/9
212/24 223/5 227/10
227/14 230/8
Receiver [2] 215/22
216/1
receiving [1] 225/12
recent [4] 47/7
120/14 124/6 230/3
recently [4] 64/3
144/8 183/17 183/21
receptive [1] 204/21
recipient [1] 109/19
reckoner [1] 18/9
recognise [6] 41/24
84/22 103/3 153/16
174/18 216/14
recognised [3] 26/9
85/6 194/4
recognition [2]
103/18 196/22
recommendation [5]
93/4 191/14 193/21
193/24 194/16
recommendations
[6] 101/14 101/15
101/19 172/21 200/7
204/4
recommended [4]
39/10 92/13 101/17
201/17
recommending [3]
60/12 144/20 160/25
recommends [1]
57/13
(89) provision - recommends
INQ00001202
INQ00001202
R
recompense [1]
13/20
reconsider [1] 48/2
record [4] 45/3 70/9
74/2 98/5
recording [1] 60/19
records [5] 56/6 61/1
70/11 70/12 213/5
recruit [2] 134/16
195/22
recruited [1] 231/25
recruitment [1]
117/15
recruitments [1]
120/14
recusal [7] 127/12
132/7 133/10 138/10
220/9 220/11 220/13
recused [1] 220/12
red [1] 78/12
redacted [1] 44/22
redone [1] 39/17
redress [33] 2/17
6/21 7/5 14/18 33/4
90/18 91/25 100/7
118/6 118/9 119/23
120/6 120/10 120/19
135/23 136/2 143/18
143/21 146/23 155/4
157/4 166/15 178/9
182/19 187/12 201/14}
202/2 207/6 210/14
212/5 212/25 222/16
226/10
reduce [17] 56/11
referring [4] 60/24
81/7 147/3 171/21
refers [2] 18/1 80/3
reflect [4] 25/16
57/20 69/18 228/15
reflected [2] 140/15
146/7
reflecting [1] 135/14
reflection [3] 78/4
79/8 155/6
reform [2] 6/21 81/24
regard [7] 3/1 3/4
10/10 43/4 48/25
193/11 204/22
regarded [3] 50/7
144/10 146/16
regarding [7] 97/6
129/2 134/1 139/6
162/16 193/4 216/9
regimes [1] 11/18
region [1] 156/1
registered [2] 232/9
232/12
regret [1] 94/22
regrettable [1]
225/16
regular [6] 31/16
34/5 36/6 62/15 77/9
230/17
regularly [2] 142/3
182/13
Regulation [1]
114/22
reiterated [1] 134/6
rejected [4] 58/4
127/12 136/7 172/8
rejection [2] 43/16
56/18 63/7 64/4 65/24, 43/22
66/17 67/4 67/20
70/10 70/19 71/6 72/5)
72/13 75/8 76/3 81/4
120/9
reduced [1] 74/1
reducing [4] 65/22
66/5 70/7 82/12
reduction [4] 67/8
67/11 68/22 81/17
redundancies [2]
74/20 76/8
refer [1] 85/2
reference [15] 2/19
42/8 45/7 51/13 59/17
73/16 93/24 114/1
114/16 126/20 142/17)
188/24 215/2 221/4
221/12
referenced [2] 21/3
133/9
references [1]
175/24
referred [10] 11/23
12/2 26/22 44/15 61/3)
83/21 105/15 139/8
149/11 172/15
relate [2] 109/19
216/5
related [2] 116/19
214/9
relates [2] 99/23
204/18
relating [4] 10/20
150/20 150/21 214/13)
relation [27] 32/12
35/25 41/14 43/2 85/3
100/10 101/4 103/23
118/5 121/19 129/4
141/24 146/13 153/6
160/17 173/16 173/20)
176/24 181/12 215/7
215/12 215/22 222/16
227/14 228/22 228/24
231/13
relationship [12]
59/14 62/24 63/2 86/2
118/19 118/25 119/6
124/12 126/10 154/2
176/20 177/23
relative [1] 117/5
relatively [5] 54/18
86/8 123/3 144/10
146/6
release [1] 217/23
relevant [9] 2/5 29/23)
32/5 34/11 164/3
165/7 223/14 230/12
231/14
reluctance [6] 66/16
67/3 67/14 67/19
72/13 75/8
reluctant [1] 209/18
rely [2] 20/10 173/4
remain [1] 2/1
remained [1] 87/3
remaining [3] 26/1
26/3 211/13
remains [3] 66/11
76/1 126/22
remarkable [1] 12/17
remarks [3] 16/7
97/18 127/22
remediation [1]
50/1
remember [21] 28/13.
59/24 60/1 60/6 60/7
60/8 73/1 92/14 96/8
108/7 127/11 148/17
156/24 157/10 160/1
161/16 168/3 178/5
203/7 224/8 224/13
remembering [2]
125/24 127/10
reminding [1] 193/19
remit [1] 6/19
removal [1] 77/24
remove [1] 164/20
removed [1] 155/10
remuneration [12]
66/21 66/25 67/5
68/23 71/1 71/3 71/25
77/16 78/4 78/7 84/16
116/5
repair [2] 103/21
103/21
reparation [1] 13/12
repeatedly [2] 81/3
105/2
repercussion [1]
205/12
repercussions [1]
47/6
repercussive [6]
42/6 43/9 153/11
156/11 156/20 160/8
replace [2] 76/15
136/23
replaced [2] 136/20
142/7
replacing [2] 46/20
137/7
replicate [1] 102/4
replied [4] 42/22
166/16 223/13 230/2
replies [1] 61/24
reply [2] 42/23 179/9
report [13] 2/4 23/19
79/3 82/23 82/24
101/10 101/10 101/17)
106/8 174/5 189/16
200/7 226/2
reports [9] 33/1 92/7
101/15 101/16 173/21
173/21 207/1 207/1
207/20
represent [5] 48/1
95/17 95/19 99/3
222/12
representation [3]
35/5 174/18 175/6
representative [4]
32/24 119/11 126/1
147/4
representatives [7]
56/5 57/22 57/23
86/16 165/23 203/2
206/23
represented [4]
99/18 99/19 101/6
118/3
representing [1]
172/11
reputation [1] 134/4
reputational [1]
149/2
request [3] 43/1
47/19 132/11
requested [1] 136/16
requesting [1]
217/22
requests [9] 31/20
66/23 127/14 176/15
192/24 196/2 227/20
228/8 228/10
require [3] 33/22
34/19 130/6
required [4] 35/21
38/10 59/9 177/2
requirement [8]
13/21 36/17 36/25
37/17 48/22 56/19
72/5 174/9
requiring [1] 207/12
rerunning [2] 191/17
192/4
research [1] 220/22
reservations [1]
48/18
reserving [1] 129/20
resignation [1] 143/6
resist [2] 170/24
204/20
resistance [2] 50/19
205/14
resisting [1] 47/4
resolution [6] 144/5
148/15 178/2 196/5
199/21 199/22
resolve [6] 7/17
14/17 19/13 21/19
134/3 134/15
resolved [6] 28/9
160/2 163/7 193/14
208/18 215/24
resolving [1] 164/8
resource [2] 152/3
171/18
respect [12] 161/14
176/2 177/12 179/18
180/22 181/6 185/15
189/4 195/10 202/7
202/23 227/11
respond [8] 18/17
120/16 124/23 143/3
146/23 148/23 189/7
231/18
responded [2]
136/17 193/19
respondents [2]
105/18 105/21
responding [1]
185/25
response [12] 34/1
50/19 50/23 75/11
84/5 87/22 88/17
123/22 127/19 131/20)
135/4 139/9
responses [5] 63/4
87/4 89/6 231/17
232/5
responsibilities [9]
5/20 6/15 115/25
117/5 117/8 118/20
119/19 119/22 123/8
responsibility [18]
5/22 9/23 25/21 26/14,
43/5 49/2 79/9 85/14
85/16 94/11 117/11
117/18 120/2 124/10
132/15 137/24 171/16)
211/24
responsible [8] 6/20
23/4 26/6 78/24 79/7
117/12 144/13 159/8
rest [4] 44/22 109/14
160/11 171/13
restricted [1] 90/21
restrictive [1] 45/23
result [11] 5/14 8/8
10/23 12/9 15/19
51/25 63/15 64/19
120/14 145/22 226/24)
resulting [1] 139/7
results [1] 105/16
resume [1] 232/21
retail [2] 119/20
124/10
retailer [1] 154/13
retain [1] 26/13
retribution [1] 52/19
return [1] 153/18
returned [1] 125/3
reveal [1] 46/21
revealed [1] 33/2
(0) recompense - revealed
INQ00001202
INQ00001202
R 198/19 199/7 rung [1] 136/23 satisfy [1] 214/1 73/5 74/9 74/13 83/8
revenue [6] 63/7 rings [1] 148/8 running [23] 1/23 save [3] 41/17 68/11 I 85/23 89/6 95/3 97/10}
65/10 66/18 67/5 67/9 rise [3] 82/20 86/5 39/17 68/1 83/14 84/1) 112/8 110/20 111/9 128/11
140/12 86/10 118/20 119/24 144/2 I saving [4] 73/14 131/13 131/16 140/8
review [7] 69/15 rises [1] 86/6 164/24 168/1 168/2 73/25 74/6 109/14 141/11 142/23 147/24)
151/2 196/24 197/17 Rishi [2] 5/4 44/13 169/15 169/21 174/20I savings [3] 75/16 152/9 167/18 168/17
497/24 210/13 221/15) "isk [16] 42/6 43/9 176/14 192/1 194/10 I 109/1 154/24 168/21 169/14 169/25)
reviewed [1] 214/5 43/10 74/7 111/6 194/16 202/12 204/11\saw [14] 14/21 22/6 I 175/10 183/19 184/14,
reviewer [4] 30/17 111/21 146/20 154/14] 208/24 215/20 224/6 I 22/23 54/13 54/13 186/1 186/12 210/4
196/25 197/5 198/12 155/11 162/12 164/11Iruns [1] 154/23 54/25 54/25 81/9 221/2 221/15 224/13
reviewers [2] 30/16 181/7 182/8 186/17 Irush [2] 158/16 136/3 142/16 179/21 I 224/15 230/21 232/3
34/22 191/15 225/23 158/22 204/17 205/14 217/5 Isays [31] 4/8 43/19
revisit [1] 169/3 road [2] 29/24 29/25 Ss say [151] 6/15 7/5 51/1 51/2 53/11 61/11
roadmap [1] 61/20 IS 10/8 11/12 13/6 13/8 I 63/5 70/19 70/24
Rob [7] 17/17 31/18 Isacking [1] 77/25 14/4 14/9 16/11 18/7 I 79/21 80/8 86/4 87/5
37/6 49/17 87/3 88/2 Isad [2] 1/4 225/10 I 18/15 19/17 20/13 I 88/14 89/15 121/11
revisiting [1] 26/19
reward [1] 69/13
Reynolds [1] 117/24
RFls [1] 196/2 93/17 Saf [4] 59/18 60/1 22/1 22/19 28/8 29/4 I 121/23 127/19 129/6
Richard [2] 35/7 35/8IObbery [1] 17 61/4 62/10 29/13 30/2 30/24 129/12 129/17 131/21
rid [4] 85/25 Robert [1] 14/6 saga [1] 66/19 31/14 31/22 32/8 133/5 135/3 159/14
Riddell [8] 1/7 1/7 Ifobust [1] 105/5 said [85] 2/18 8/17 I 32/14 33/6 37/17 160/15 163/19 191/12
1/16 1/21 1/25 2/1 2/3I"obustness [1] 105/1) 10/2 16/6 16/22 23/22] 43/19 45/20 46/7 192/22 221/18 227/2
40/1 role [33] 6/7 30/20 I 25/3 25/18 56/25 46/10 46/13 46/18 I scale [4] 130/4
60/3 76/19 77/14 59/19 61/2 61/14 52/10 53/2 56/12 57/3] 140/13 144/10 153/5
right [115] 3/14 5/7 94/12 94/16 102/24 I 63/16 63/22 68/4 59/3 61/9 61/13 61/19] scan [2] 71/16 84/25
5/11 5/17 6/5 7/24 108/5 115/2 115/7 76/17 79/23 83/5 88/1I 63/1 63/3 63/11 66/9 Iscandal [22] 8/7 8/13
9/10 9/25 10/15 10/16I 115/10 115/19 116/3 90/13 91/10 92/14 66/13 68/16 68/17 9/24 10/1 10/11 10/14,
Riddell's [1] 2/9
17/24 17/25 18/6 19/2 116/21 118/5 119/11 I 94/5 94/13 95/5 69/11 72/8 75/14 77/6I 10/20 10/25 11/2
19/9 19/22 22/8 26/9 I 119/16 119/23 120/24 102/23 108/4 109/5 I 78/15 79/10 79/15 144/10 40/18 41/2 50/8
124/13 125/23 139/2 I 112/7 116/6 119/13 I 79/25 81/2 83/13 51/16 96/4 97/22
29/11 30/1 30/2 30/20
31/41 31/24 32/6 43/2I 141/17 148/2 148/5 I 122/24 125/19 126/22I 83/16 84/18 85/5 85/9I 98/13 98/23 103/17
153/6 159/9 159/10 I 131/19 133/25 141/9 I 89/2 89/16 90/5 91/2 I 138/21 222/13 226/24
sella dal aame, — I 163/21 204/5 204/12 I 141/12 141/15 144/3 I 91/13 100/1 100/5 _ Iscandals [8] 7/17
45/10 45/11 45/13 220/8 147/7 148/25 151/2 I 102/11 102/11 103/7 I 8/13 11/6 94/15 97/14
45/14 46/18 47/19 roles [4] 60/4 114/21 I 151/6 151/9 151/12 I 107/9 109/11 110/10 I 97/22 100/20 101/24
49/13 50/25 51/18 116/8 117/1 151/17 153/1 155/1 110/18 110/20 111/11Iscepticism [1] 29/20
51/18 55/21 58/16 rolled [2] 1/11 148/9 I 155/8 155/18 155/21 I 111/13 111/20 112/2 Ischeme [181] 2/6
59/6 59/6 60/21 60/25 rolling [1] 71/20 156/3 156/5 160/9 119/4 122/6 123/23 I 2/17 9/16 10/23 13/10
61/6 70/17 74/13 room [8] 19/22 25/1 I 166/10 166/17 166/19] 125/15 126/12 127/20I 13/14 14/21 15/4
76/11 78/3 84/13 29/7 92/23 92/24 167/8 168/8 169/7 128/15 128/24 129/24] 21/18 22/23 23/9
84/14 89/2 89/13 118/10 180/23 195/14] 169/16 169/16 170/4 I 130/13 131/15 139/10} 23/11 23/12 24/23
90/16 93/19 95/3 96/1/root [1] 98/23 176/25 179/17 180/11] 140/23 140/24 141/13] 25/21 25/22 26/19
96/7 98/9 98/15 Ross [5] 30/16 30/19 I 180/25 181/2 183/11 I 142/19 143/5 143/9 I 27/8 27/16 27/18
102/25 108/17 108/22! 34/22 196/25 197/21 I 197/11 200/18 202/25) 144/25 145/7 146/2 I 27/20 27/25 28/12
round [1] 77/25 203/7 203/14 205/5 I 146/5 148/24 149/19 I 29/25 30/1 30/9 30/14
iene ‘ene tous route [5] 42/2 98/16 I 205/16 208/7 208/12 I 151/25 152/18 154/21) 30/16 30/17 31/6 33/4]
123/13 126/7 130/22 I 111/12 111/21 191/4 209/1 217/8 222/15 I 155/13 157/6 157/16 I 34/23 36/21 39/15
1341/5 134/23 140/14 Iroutes [1] 212/1 222/21 223/4 229/9 I 160/4 165/21 170/3_ I 39/16 40/24 40/25
141/20 1485/6 145/11 [Roxburgh [1] 171/5 Isalaries [1] 73/4 170/13 174/16 175/5 I 41/24 42/2 43/3 43/7
157/23 158/6 158/7_ Iruined [1] 41/2 salary [2] 65/20 175/15 175/18 181/8 I 51/18 56/11 56/22
458/11 158/18 161/18) "led [1] 194/18 78/10 181/11 182/18 184/5 I 57/23 58/10 58/18
163/16 166/12 174/6 Ifules [4] 25/13 25/14 ISalter [1] 169/12 186/10 188/22 189/8 I 58/20 79/22 91/21
485/19 190/5 190/21 I 111/8 190/15 Sam [1] 95/17 189/11 189/16 190/6 I 91/21 92/1 94/9 94/12
491/19 192/15 194/9 IFuling [2] 105/4 122/5}same [17] 18/15 191/19 194/19 198/5 I 94/14 95/10 95/11
4197/3 197/10 198/20 IfUn [28] 83/5 83/6 I 21/24 22/2 39/16 199/3 199/17 199/19 I 103/12 109/16 110/14
98/7 115/21 120/18 I 41/25 48/17 61/10 202/14 203/11 204/1 I 1114/4 111/8 112/1
204/1 204/25 205/20 I 131/18 131/18 132/1 64/2 64/2 76/1 76/25 I 205/12 206/17 208/8 I 112/3 112/12 118/8
209/16 211/10 2189/7 I 132/1 132/2 138/14 93/19 110/6 110/8 209/18 213/4 213/12 I 120/19 120/19 143/21
218/14 218/16 219/6 I 144/3 145/25 146/18 141/22 160/12 231/10] 214/8 214/14 219/6 I 143/22 143/23 144/2
146/20 154/13 167/15ISarah [10] 139/23 221/14 225/19 225/25] 144/3 144/14 144/21
199/8 199/12 201/25
dant Bt 168/16 168/22 169/17I 149/6 153/14 156/23 I 228/16 229/23 144/25 145/8 145/13
D112 104/25 157/16 I 169/25 171/9 172/5 I 166/2 166/8 166/16 I saying [48] 15/12 _ I 145/25 146/12 146/18
168/19 173/6 174/9 174/11 I 167/9 170/11 172/24 I 25/5 27/10 29/18 31/4I 146/20 147/17 147/20
192/13 195/5 sat [2] 25/11 142/20 I 53/2 54/9 57/17 57/18) 149/15 150/1 150/10
rights [3] 180/2 I un-up [1] 195/5 __Isatisfied [1] 105/20 I 60/6 60/7 60/8 71/24 I 151/18 152/8 152/16
(91) revenue - scheme
INQ00001202
INQ00001202
s
scheme... [91]
152/21 157/24 158/7
158/12 159/2 160/12
163/22 163/23 163/24)
164/5 164/24 165/4
166/15 166/25 167/15)
167/20 168/1 168/2
168/5 168/5 169/2
169/3 170/1 171/17
172/6 173/4 173/6
173/17 173/25 174/7
174/10 174/23 175/8
175/12 175/14 175/19}
175/22 175/25 175/25)
176/3 176/6 176/10
176/11 176/20 177/13}
177/19 177/21 179/6
187/12 188/3 189/14
190/1 194/24 195/19
196/21 197/13 197/19}
199/4 199/5 199/10
200/1 200/18 201/5
201/9 201/16 201/17
204/11 204/15 207/3
207/14 207/25 208/14
208/23 210/13 212/1
212/23 212/25 212/25
213/9 213/9 213/15,
215/4 215/20 215/21
222/14 223/20 223/25
224/3 224/12 225/5
225/15
schemes [54] 7/5
10/7 14/22 16/8 16/21
18/24 21/13 21/21
24/17 26/16 27/7 31/6
32/21 34/22 34/24
35/1 35/9 41/21 44/14
47/5 47/15 51/18 58/7
80/1 87/1 87/8 94/18
94/24 96/24 100/8
100/17 118/13 119/24
135/23 136/2 143/19
148/9 148/13 149/1
151/15 157/4 164/20
169/21 172/2 174/20
175/5 177/6 187/10
188/11 189/18 190/7
205/13 208/8 226/25
scope [11] 73/10
176/19 196/10 212/4
213/2 213/8 213/10
213/15 215/19 230/22
231/19
Scotland [3] 212/14
229/14 229/16
Scott [4] 161/25
220/19 220/22 221/24
Scottish [1] 229/20
screen [7] 6/13 9/1
22/16 81/11 120/22
159/1 179/14
scroll [22] 42/25 45/6)
104/23 120/25 120/25)
123/22 129/11 129/17)
129/23 131/20 134/11
137/18 139/9 140/23
150/16 159/13 161/4
161/5 161/22 163/17
170/13 191/9
scrolling [1] 150/19
scrutinising [1]
161/19
scrutiny [16] 41/11
45/17 45/21 46/1 46/4
46/17 46/21 47/22
48/3 48/17 49/12 51/4
151/23 152/2 157/13
224/11
Scully [11] 14/5
139/16 141/22 142/3
150/12 160/3 163/21
167/18 172/10 172/17
172/25
Scully's [2] 139/4
150/15
search [2] 231/22
231/25
searches [1] 231/13
searching [1] 232/1
Sec [2] 116/17 156/3
second [14] 3/5
25/18 35/13 61/9
67/14 84/18 88/18
114/4 135/12 150/24
1711/7 197/23 202/24
210/18
secondhand [1]
125/5
Secretaries [1] 44/5
secretary [60] 5/5
5/18 6/3 6/7 14/4 14/6
17/24 19/8 20/21 21/6)
28/16 28/18 39/4 39/5
39/7 40/12 42/23 44/1
44/3 44/12 45/9 45/12
45/16 47/7 47/11
47/24 48/9 48/11
48/16 49/18 49/19
50/4 78/6 85/15 85/17,
115/18 117/23 124/23)
133/6 133/17 133/23
134/11 135/14 136/17)
136/18 136/21 137/3
139/10 146/14 156/17)
161/3 1741/7 173/2
181/14 186/1 200/20
204/18 205/2 205/8
211/19
secretly [1] 105/9
Secrets [3] 96/7
96/14 96/18
section [5] 135/3
159/14 161/23 211/19)
212/21
section 4 [1] 211/19
Section 5 [1] 212/21
sector [1] 124/10
sectors [1] 119/21
see [74] 9/2 9/7 9/11
11/14 17/16 17/22
18/8 24/2 40/12 42/19
42/22 44/20 45/4 49/1
52/1 60/14 61/1 61/5
68/24 71/21 77/1
81/23 87/20 92/20
98/19 99/22 109/15
117/19 121/6 123/16
123/17 123/22 128/25
129/5 129/24 131/5
131/20 134/11 135/1
135/22 139/9 139/11
147/14 150/14 150/16
161/4 164/24 167/6
167/13 173/24 177/6
177/9 179/11 181/18
188/14 189/3 191/10
192/21 193/13 195/24:
198/5 198/22 198/25
202/14 202/20 210/7
215/1 216/10 216/21
218/19 218/21 227/8
229/21 231/15
seeing [5] 40/3 92/3
117/24 222/6 226/23
seek [3] 129/8 171/1
4177/1
seeking [2] 122/1
132/6
seem [5] 20/19 35/22
48/25 107/23 108/2
Seema [1] 11/22
seemed [11] 30/13
35/21 35/23 86/7
90/17 124/3 126/14
131/16 149/19 149/22
150/5
seems [5] 18/10
54/22 138/13 167/14
228/14
seen [15] 4/12 19/7
51/24 53/15 60/18
78/9 91/16 103/11
107/24 148/8 160/24
175/24 177/4 206/21
216/8
seize [1] 98/19
select [13] 9/19 9/21
10/10 13/9 32/25
79/20 80/8 88/10
101/18 101/22 102/23
204/6 207/10
selective [1] 45/21
self [2] 73/10 212/3
self-assess [1] 212/3
self-help [1] 73/10
semantics [1] 46/13
semi [1] 61/2
semi-verbatim [1]
61/2
send [1] 162/23
senior [8] 17/18
66/20 69/18 77/17
78/25 79/12 81/4
159/8
sense [23] 12/24
20/6 20/20 20/20
21/15 25/12 29/19
29/19 36/8 36/10
37/24 38/16 38/18
75/5 75/6 80/15 87/7
126/4 126/13 126/14
140/16 143/6 144/22
sensible [7] 45/19
106/10 107/23 108/2
119/10 121/25 194/10)
sensibly [1] 190/2
sent [7] 93/9 121/3
205/15 229/24 230/4
231/7 232/6
sentence [4] 68/21
72/12 88/18 89/11
sentiment [2] 151/9
210/1
sentiments [1] 22/6
separate [6] 62/18
62/18 117/1 146/24
163/1 197/18
separately [2] 42/1
79/4
separation [1]
118/14
September [8] 45/5
45/5 84/21 184/2
184/13 184/18 201/12)
224/12
series [4] 50/16
62/15 72/15 157/4
serious [8] 1/17 8/11
13/1 50/15 116/16
133/7 143/9 143/14
seriously [2] 12/9
97/21
servant [3] 17/18
114/18 187/16
servants [6] 18/5
21/12 37/6 49/16
50/12 78/24
served [1] 5/2
server [1] 82/15
servers [1] 82/15
service [6] 15/18
16/24 25/9 34/14
48/23 172/3
services [1] 64/25
serving [1] 65/8
set [40] 6/14 15/3
32/14 34/14 46/24
50/24 55/25 56/1 69/3
69/8 69/19 71/1 77/5
81/13 82/22 102/2
110/25 119/18 120/18)
123/12 123/24 130/11
136/3 143/23 160/19
163/25 166/23 172/20)
174/8 176/25 177/2
177/8 178/20 181/20
187/12 188/19 196/6
200/8 200/19 222/4
set-up [1] 123/12
setback [1] 131/24
sets [2] 69/2 135/6
setting [10] 55/22
70/16 116/7 117/4
159/21 159/25 160/7
166/13 202/16 208/17)
settle [3] 58/14 88/22
202/8
settled [6] 30/25
134/14 178/7 193/5
206/7 206/12
settlement [36]
12/12 13/19 59/10
88/12 89/19 90/19
90/22 91/5 93/7
130/21 130/24 132/18)
132/20 135/16 135/18)
135/24 135/25 136/10)
142/8 143/24 144/2
144/11 145/23 147/8
153/8 157/23 161/24
162/2 162/16 162/19
169/16 174/8 178/5
178/23 185/10 196/7
settlement’ [1] 90/25
settlements [9] 88/9
88/20 89/3 89/9 89/15)
93/12 182/25 196/11
202/10
settling [4] 130/16
130/18 132/14 146/13)
setup [2] 154/2 154/9I
seven [1] 5/2
several [1] 68/15
severe [1] 41/6
severely [1] 97/24
severity [1] 56/8
shades [1] 133/25
Shadow [1] 6/7
shall [2] 41/4 110/10
shameful [1] 13/22
shape [2] 64/8
152/11
Shapps [1] 78/6
share [2] 141/2
213/19
shared [7] 52/4 52/5
121/12 134/8 141/6
141/23 212/10
shareholder [15]
69/7 69/14 69/15
69/19 70/16 77/5
100/23 103/23 105/11
108/5 119/11 138/7
139/17 147/4 184/22
sharing [4] 123/24
128/23 129/25 184/21
Sharma [1] 14/5
(92) scheme... - Sharma
INQ00001202
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sharp [3] 62/3 62/9
63/10
she [58] 1/10 1/11
1/18 38/22 38/23
38/24 40/23 42/17
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117/11 117/14 121/14}
122/22 122/23 122/24)
123/2 123/3 123/4
123/5 123/6 123/7
123/8 123/10 123/13
124/4 124/4 124/6
126/6 126/14 126/21
126/22 126/22 127/5
127/7 127/15 127/20
127/21 128/1 128/7
128/7 128/7 128/12
128/13 128/20 133/19}
133/20 134/8 137/1
166/9 166/16 166/17
166/18 166/19 184/15)
217/10 219/9
she'd [1] 93/15
she's [1] 149/11
sheer [2] 97/13
140/13
shift [4] 126/5 165/25)
171/22 185/17
shifted [3] 166/4
167/10 171/19
shocked [1] 78/11
shopping [1] 64/23
shops [1] 64/22
shorn [1] 13/13
short [10] 2/12 5/22
55/11 74/21 74/21
113/3 170/25 173/13
187/21 226/5
short-term [1] 74/21
shortchange [2] 90/9)
112/11
shortchanged [1]
26/25
shortcomings [1]
83/10
shorten [1] 91/14
shortens [1] 89/20
shortfall [20] 2/17
10/22 94/9 118/8
143/22 143/22 144/21
145/8 145/25 150/10
159/2 169/3 173/25
176/3 177/12 177/19
180/12 188/3 200/1
215/4
shortfalls [1] 45/22
shorthand [1] 88/6
shortly [5] 7/25
127/14 133/1 151/4
159/11
should [143] 3/24
11/7 11/12 13/16
13/24 16/5 18/15
18/20 19/15 20/5
20/16 23/19 25/3
26/13 26/13 26/24
27/18 29/13 29/14
30/15 30/18 31/9
31/23 33/2 36/8 36/12
36/15 36/16 36/16
36/20 38/13 39/12
39/20 40/19 40/19
42/1 42/12 51/16
52/21 57/5 57/8 58/1
58/6 65/5 68/9 68/10
68/16 68/17 69/9
69/18 69/25 71/3 72/7
7218 74/1 75/3 76/3
76/13 77/25 83/5
83/11 84/10 84/11
85/23 87/9 88/19
92/14 94/11 95/13
99/13 99/14 102/20
104/5 104/7 105/8
105/11 110/6 112/12
113/13 113/16 114/5
118/17 129/10 130/14
135/17 139/11 140/2
141/8 144/3 144/5
144/8 144/21 144/22
144/22 145/3 146/15
4152/1 162/16 165/2
166/13 166/23 167/15
168/2 168/7 168/16
168/22 169/17 169/24
170/5 174/10 171/15
171/20 174/9 175/16
181/1 183/15 183/19
188/22 195/9 195/18
196/8 196/9 197/15
197/16 205/4 208/10
209/3 209/10 209/13
210/2 212/4 213/12
213/16 214/20 217/18
218/8 220/15 222/6
227/18 227/19 227/20
228/4 228/14
shouldn't [10] 27/6
27/11 52/22 53/2
95/14 102/19 110/21
164/23 169/15 170/24)
show [2] 87/11
161/13,
showing [2] 18/22
182/14
shown [3] 81/10 88/9
136/15
shows [1] 210/20
sic [2] 59/24 77/10
side [16] 12/22 29/2
57/22 57/23 99/17
99/23 100/17 102/7
102/20 103/13 133/24
134/15 154/21 157/7
207/15 220/8
sides [5] 41/6 53/5
57/25 101/1 118/2
sign [5] 44/4 49/22
49/24 66/22 126/6
signature [3] 4/16
113/21 114/10
signed [12] 9/7 50/3
52/7 52/7 52/10 52/15
96/18 161/2 177/9
199/6 199/12 226/14
significant [11] 41/25
43/9 47/23 53/14
65/25 81/17 84/22
85/6 108/25 125/23
144/14
significantly [6]
38/13 65/3 66/24
74/15 120/9 215/10
signing [2] 96/6
160/14
signs [1] 66/10
similar [2] 91/8
151/22
similarly [3] 11/1
38/15 38/21
Simon [10] 2/13 88/3
90/24 152/24 177/15
178/3 184/10 184/18
184/20 185/3
Simon's [1] 188/7
simple [2] 81/18
160/20
simply [7] 36/9 40/4
57/18 81/12 99/5
111/18 135/23
since [13] 84/20
85/18 86/4 97/3
108/18 114/19 115/2
119/9 120/14 145/9
159/12 184/4 202/18
single [2] 100/22
103/23
sir [45] 2/11 3/5 3/13
11/25 16/6 20/17
21/25 30/16 30/19
34/22 35/7 39/17
48/22 51/15 55/6
55/13 92/13 95/24
100/2 101/8 104/12
108/14 112/21 113/6
117/23 132/4 173/9
174/5 174/20 181/10
185/25 195/14 196/25
197/21 200/5 204/4
204/12 208/16 208/21
209/1 218/3 218/17
218/20 232/16 233/12
Sir Alan [3] 20/17
21/25 208/21
Sir David [1] 39/17
Sir Jonathan [1]
117/23
Sir Peter [1] 11/25
Sir Ross [4] 30/19
34/22 196/25 197/21
Sir Wyn [6] 16/6
48/22 51/15 95/24
101/8 174/20
Sir Wyn's [3] 174/5
181/10 200/5
sit [5] 3/8 3/11
115/21 119/10 128/9
sits [2] 138/16 211/4
sitting [2] 184/3
187/9
situation [12] 25/16
56/22 65/4 78/7 81/12
124/20 124/25 152/22)
154/3 154/6 168/11
213/14
situations [5] 25/14
62/18 98/11 103/16
209/12
six [4] 151/5 151/8
178/6 183/22
size [7] 64/8 65/11
76/2 120/9 120/15
121/21 183/19
skills [1] 167/7
skipping [1] 20/21
SLA [1] 34/14
slang [1] 190/18
sleep [1] 98/2
slide [2] 72/21 73/3
slides [1] 72/15
slight [1] 126/9
slightly [18] 18/2
27/11 97/20 121/1
121/7 124/16 125/18
126/10 127/8 128/9
148/7 154/11 155/6
167/19 197/17 206/5
216/13 224/5
slow [9] 7/22 32/18
32/20 34/2 66/15
79/13 149/20 158/16
196/21
slower [2] 124/16
203/18
slowly [2] 166/11
203/18
small [20] 5/10 7/12
7/16 7/18 8/3 8/5 14/5
19/19 94/15 98/6 98/6)
103/8 144/10 146/6
152/1 152/14 152/17
178/3 228/8 228/10
smaller [3] 75/23
75/24 142/10
Smith [18] 1/22 2/1
12/13 13/4 93/21 94/7)
94/18 95/1 145/15
147/16 148/15 148/19)
148/20 149/1 150/3
160/21 160/25 184/16)
Snow [1] 184/7
so [324]
social [2] 20/12
61/22
sole [2] 108/5 117/17
solicitor [1] 105/10
solicitors [3] 2/22
97/9 207/16
solution [1] 76/14
solved [1] 15/15
some [147] 2/13 7/17
8/4 8/21 9/15 9/25
10/18 11/7 11/20
13/16 16/17 17/4 17/5)
17/9 19/7 19/17 20/7
23/18 24/13 24/25
25/12 25/22 26/1 26/2
26/23 27/2 28/13
29/14 32/14 34/21
34/25 35/9 36/8 36/20)
36/23 37/7 38/2 38/18,
40/7 40/23 41/16 42/5
43/15 50/10 51/23
56/7 57/10 58/11 59/4,
61/5 65/17 75/24 79/5
79/8 83/9 86/5 86/6
86/15 86/22 89/18
89/20 95/1 102/24
102/25 103/5 106/18
106/21 107/3 109/5
110/4 115/6 115/13
117/3 117/7 118/17
120/7 124/3 125/4
125/7 125/13 126/25
127/7 128/7 131/6
131/24 132/4 132/5
136/17 138/16 139/23)
140/7 140/20 142/1
142/25 143/3 143/18
145/19 147/18 148/8
148/15 149/14 150/2
153/14 154/24 154/25)
156/24 157/14 159/23)
161/20 163/19 166/24)
167/3 171/25 172/13
174/13 174/22 177/23)
178/19 180/10 181/25)
182/2 186/2 187/21
189/19 190/13 191/11
192/10 195/16 195/22)
200/5 200/22 206/7
206/15 207/11 207/24,
208/12 209/16 209/23
212/6 212/22 215/12
216/5 217/11 217/23
218/3 226/9 231/25
somebody [25] 15/9
19/25 20/1 25/10 38/5)
38/8 38/10 49/22
49/25 52/22 52/24
56/13 56/14 56/24
72/22 82/10 84/7 90/5)
102/21 102/25 103/7
111/11 179/24 197/24)
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somebody's [3]
36/13 37/9 56/20
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someone... [14] 26/3 speak [6] 7/87/14 Istands [1] 33/15 I 218/10 structured [1] 79/6
tar 197119 19878 I 7/15. 33/5 96/16 start [19] 1/32/11 _ISteering [2] 159/3 Istruggle [1] 164/2
21714 217/14 220/13 I 124/16 4/22 16/9 22/15 30/20) 161/22 struggling [4] 82/2
S004 speaking [5] 19/4 I 31/25 59/6 86/17 Isteers [1] 135/13 _ I 226/15 226/17 227/17
something [61] 7/2 I 192061117 73/13 I 87/25 115/5 136/12 I stein [5] 86/18 95/16 Istyle [1] 167/20
or ee ts tig I 126/21 139/3 150/13 150/24 I 95/17 97/18 233/8 {sub [1] 70/5
23/7 23/17 27/11 special [2] 172/12 152/20 155/2 158/16 Istep [4] 27/17 98/16 Isub-bullet [1] 70/5
28/21 29/15 31/1 31/9) 172/25 204/15 115/12 135/25 subject [1] 10/13
35/13 35/19 36/15 ISPecific [5] 43/2 I started [11] 41/14 I stepped [1] 88/25 _I submission [8] 18/3
44/16 46/25 52/14 I 96/16 160/1 173/16 I 77/13 87/2 115/14 steps [10] 88/10 19/6 36/18 121/15
52/21 53/4 54/15 176/2 127/13 148/5 193/3 I 148/21 149/25 157/1 I 166/3 171/4 172/13
82/21 63/19 63/20 ISPeGifically [7] 10/22I 195/12 206/9 24/6 I 172/9 196/12 211/20 I 175/13
eG 73/22 73124 57/2 59/13 60/5 60/6 I 229/19 216/19 216/22 224/22I submissions [2]
80/11 Bolt2 aging I 72/8-215/2 starting [3] 26/21 _Istick [1] 185/12 132/24 166/8
96/24 97/1 97/11. [Speculative [1] 74/7 I 103/19 189/6 Sticking [1] 177/12 Isubmit [1] 171/3
10/4 100/7 106/7 __ISPeed [8] 33/9 41/8 Istarts [2] 158/8 sticky [1] 219/11 Isubmitted [9] 34/17
406/17 107/13 107/17) 42/4 109/11 177/19 I 158/12 still [34] 39/18 44/7 I 34/19 35/24 91/22
186/4 207/10 218/7 I state [38] 5/5 5/9 48/17 50/24 51/5 92/1 92/8 175/10
12314 12415 156/10 I Speeding [2] 108/23 I 5/10 5/18 6/3 6/7 11/7I 87/18 94/20 96/19 I 188/9 230/6
156/13 165/14 174/4
178/6 188/1 191/2 152/17 13/13 28/16 28/18 105/7 120/10 126/7 I subpostmaster [2]
198/25 203/4 205/16 ISPell [1] 145/21 39/4 39/7 40/12 42/23] 126/8 126/14 127/9 I 1/14 226/4
208/2 208/4 214/7_ [Spend [4] 99/14 44/1 44/12 47/7 47/24) 127/14 127/16 128/22I subpostmasters [15]
119/12 119/14 227/8 I 49/19 50/5 78/6 85/15I 131/4 138/21 140/7 I 6/21 12/7 32/13 54/17]
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sometime [1] 101/11 I 2286 135/15 136/17 136/21I 202/20 206/11 209/16I 220/22 222/13 227/16
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S0/18 148/8. 183/16 I 101/3 103/15 103/20 I 186/1 200/20 205/2 I 226/9 227/24 subpostmistress [2]
189/18 189/20 123/25 211/19 stones [2] 140/18 I 1/8 1/16
somewhat [2] 127/16ISPlt [1] 172/16 State's [1] 136/18 I 140/21 subpostmistresses
139/22 spoke [8] 122/6 stated [5] 26/17 stop [5] 30/21 75/3 I [4] 12/8
somewhere [1] 25/11) 188/3 168/23 184/17 I 82/24 175/17 193/8 I 92/4 101/11 169/7 I subsequently [2]
soon [7] 45/23 77/20 I 194/7 21716 219/16 I 221/8 stopping [1] 38/16 I 64/3 135/19
00/4 185119 1611. I 228/24 statement [38] 3/23 Istories [1] 220/23 Isubsidy [1] 73/23
206/25 223/14 spoken [4] 32/23 I 4/19 6/10 16/3 17/4 Istraightaway [3] _I subsist [1] 38/25
62/17 64/3 177/20 I 22/15 31/13 32/7 87/10 87/14 87/16 I substantial [1] 211/2
spotlight [1] 83/7 I 55/16 59/16 63/22 _Istraightforward [2] Isubstantially [1]
spouse [1] 226/17 I 66/8 76/14 77/7 79/10) 130/7 230/16 414
SR [1] 193/16 79/23 80/17 84/9 —_Istrange [1] 221/23 Isubstantive [3]
aoe ee stack [1] 92/16 100/1 102/11 113/16 Istrategic [8] 69/3 I 113/19 170/12 197/7
460/13 184/23 210/15I Staff [4] 120/4 120/13] 113/23 114/4 114/9 I 70/16 71/2 71/4 71/17Isucceed [1] 132/10
2447 213/1 218/20 I 120/13 148/22 114/12 114/15 115/8 I 71/20 71/22 72/1 — Isuccess [1] 16/18
sort [32] 29/21 61/2 [Stage [28] 93/1 99/10) 116/6 119/13 145/7 strategy [6] 9/21 successful [7] 37/15
61/6-118/16 120/8 I 99/11 99/15 121/2_ I 166/9 191/4 202/24 I 132/5 134/2 134/13 I 39/22 43/3 43/14
sooner [1] 132/13
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9/19 15/7 30/24 31/2
123/15 125/11 125/13) 126/24 127/3 128/5 I 202/24 203/15 210/18) 135/11 222/7 127/11 131/10 141/12
132/18 132/23 136/2 I 130/16 130/18 131/25] 214/25 225/19 street [1] 64/22 successfully [2] 8/11
4140/6 140/16 142/5 I 136/22 138/13 139/22/statements [4] strength [2] 52/16 I 129/14
445/21 148/6 185/11 I 143/10 156/6 157/17 I 113/14 218/25 219/18) 170/17 succession [1] 83/1
157/14 172/8 10/14 I 181/13 162/18 164/22] 232/19 strengthen [1] 130/2 Isuccessor [1] 112/14
480/18 180/19 182/5 I 167/14 167/24 173/23Istatistic [1] 232/10 I strict [3] 25/13 197/4 Isuch [30] 11/17
482/10 190/9 206/18 I 174/3 175/21 178/16 Istatistics [1] 210/16 I 197/25 11/19 13/14 35/16
207/23 208/11 219/14I 179/23 180/1 stats [1] 230/11 strictly [2] 24/5 42/3 65/1 66/20 96/23
226/11 226/12 227/1 IStages [7] 16/4 40/22I status [2] 103/23 126/20 97/14 98/21 99/14
sought [4] 8/10 8/13 I 98/12 144/4 144/16 I 135/10 striking [1] 175/12 I 100/20 101/22 101/24]
Tin BIS 149/22 198/6 statute [1] 24/21 _Istringent [1] 70/2 I 103/16 108/6 124/10
sound [4] 20/16 [Stakeholders [2] I Staunton [10] 66/18 Istrong [10] 14/10 I 138/9 162/13 173/21
BOT te4/3 198/13 I 31/24 32/5 68/25 77/6 77/10 14/13 22/5 47/16 173/22 190/24 194/6
stalled [1] 36/1 77/11 77120 79/1 115/20 119/1 138/13 I 194/14 196/2 196/12
sounds [4] 106/1
106/10 221/23 224/5
sources [1] 20/12
space [4] 25/7
stand [6] 3/8 11/11 I 79/16 83/21 84/17 —_I 170/21 205/6 214/17 I 216/22 224/22 226/3
52/23 57/15 61/23 IStaunton's [4] 78/18 Istronger [1] 116/23 I 227/11
96/20 79/11 79/19 80/6 —_Istrongly [3] 77/14 Isued [1] 123/15
standard [1] 162/21 Istay [1] 120/6 127/22 167/4 suffered [3] 13/1
(94) someone... - suffered
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s 33/12 34/25 35/1 35/4) 23/24 28/7 28/16 184/10 184/13 184/17I tested [1] 199/18
Suffered... [2] 39/16 35/8 38/11 38/23 40/6) 52/19 68/20 71/24 184/19 184/19 185/3 Itext [1] 121/8
180/12 62/6 72/5 72/6 82/13 I 75/5 97/4 107/10 188/7 188/10 195/22 Ithan [61] 25/13 30/20
89/17 94/23 94/25 107/12 107/16 111/3 I 206/20 213/16 226/11I 33/2 33/25 36/9 37/20)
Suffering [4] 26/6 I so2/46 104/3 108/17 I 118/5 123/14 132/4 I 227/23 28/5 230/17 I 38/11 38/14 41/18
26/8 225/21 228/13
sufficient [3] 173/5 I 110/9 114/10 137/14 I 132/6 137/2 149/10 teams [1] 119/6 45/20 46/7 46/23
179/24 186/17 141/10 145/17 155/9 I 149/18 151/25 155/12I tearing [1] 95/9 46/25 48/12 48/13
sufficiently [3] 22/25 I 158/12 177/20 189/14] 160/11 168/15 170/5 Itease [1] 187/5 50/10 56/16 58/9
126/1 16412 190/23 201/6 175/8 180/3 207/19 Iteeth [1] 81/6 64/22 70/25 74/11
suggest [3] 23/24 [Surely [1] 22/4 216/22 220/4 222/16 Itell [14] 7/25 20/13 I 77/3 81/11 89/19
111/18 128/7 surprise [3] 54/4 _I takes [3] 87/20 20/14 20/15 53/23 I 91/15 103/5 109/6
suggested [3] 124/3 I 1308 131/22 157/21 175/21 67/7 76/14 80/16 110/5 111/13 115/23
13518 192/2 surprised [5] 27/13 Itaking [22] 20/14 _I 80/23 81/21 84/9 117/20 118/6 121/15
suggestion [4] 42/14) 43/24 54/6 63/13 33/2 34/10 74/2 86/16I 99/10 211/11 217/25 I 123/15 129/20 132/14]
53755 56/5 163/13 I O4/11 94/12 96/19 103/9 telling [1] 70/9 133/13 136/12 142/10
suite [1] 162/7 survey [3] 105/16 I 108/9 110/12 146/6_ I temperature [1] 145/12 146/21 147/20
sum [33] 16/17 2713 I 107/24 217/6 4161/7 171/15 172/17 I 11/13 149/16 150/3 152/9
33/10 33/21 33/25 [SUSPect [4] 130/1 I 189/23 205/9 216/16 Itempted [2] 127/24 I 157/18 157/25 161/14]
30/1 39/21 43/2 4a/e I 144/16 144/17 217/21] 216/19 218/20 220/8 I 170/24 172/20 182/2 192/1
46/19 46/20 48/18 ISUStainable [1] 61/22] 221/24 222/20 ten [1] 74/3 198/4 203/14 205/3
49/9 49/14 51/5 51/9 [Swap [1] 218/18 talk [4] 62/9 81/22 Itend [9] 7/15 23/23 I 206/21 209/20 209/24
511654185719 _ ISwifter[1] 185/10 I 137/1 19/4 33/1 35/18 118/9 216/23 217/8 224/5
58/17 89/17 91/20 ISWorn [2] 3/17 233/2 Italked [12] 8/15 154/17 17719 177/11 I 224/15
91/24 92/18 93/8 /SY™Mpathetic [2] 63/20 83/2 116/13 I 189/8 thank [79] 2/11 3/13
109/6 111/5 180/6 I 47/12 205/8 142/24 148/18 153/14Itends [4] 23/24 98/17I 3/23 4/14 4/22 6/1
483/10 185/9 194/14. IS¥mpathise [2] 67/25) 156/24 172/10 173/1 I 200/11 213/17 8/24 9/22 10/8 10/9
198/17 224/8 68/2 183/25 184/19 tens [1] 99/4 17/14 22/9 28/24
summarise [4] 87/5 IS¥mpathy [3] 2/8 talking [19] 51/8 Itense [1] 124/20 40/13 44/18 51/22
152/13 164/24 167/19] 127/7 148/10 62/22 63/6 63/17 64/7Itenure [8] 27/14 53/10 55/5 55/13
summarises [1] system [21] 22/24 I 99/4 101/11 103/19 _ I 37/16 107/9 118/4 I 55/16 64/13 80/16
40123 105/2 105/5 105/8 I 123/17 123/18 126/9 I 118/6 198/5 219/8 I 86/11 86/13 86/14
summary [2] 64/15. I 105/24 106/6 106/15 I 133/18 17/4 179/4_ I 219/11 87/25 95/15 97/19
205/16 107/22 108/2 120/18 I 179/6 186/13 201/20 Iterm [8] 69/23 70/20 I 104/8 104/9 104/12
summer [3] 138/15. I 196/13 137/23 150/21) 201/21 225/2 73/11 73/21 74/21 I 108/10 112/16 112/17}
201/12 217/20 151/16 185/6 211/18 Italks [4] 73/3 79/4 I 74/21 120/8 170/25 I 112/20 112/21 113/6
sums [3] 183/23 214/1 217/5 217/15 I 151/20 178/3 termination [1] 113/10 114/1 114/15
187/2 190/24 226/10 227/24 target [2] 182/25 180/18 115/5 118/11 118/18
sunak (21 5/4443 IS 20988 terming [1] 103/15 I 119/12 120/20 127/17
supplied [1] 54/1 __Itargets [2] 73/14 __Iterms [64] 12/11 129/5 135/1 135/6
support [16] 50/4 tab [1] 4/2 73/18 15/22 15/22 15/24 136/22 137/10 137/16}
73/25 74/12 97/15 _ [table [3] 18/22 tariff [3] 36/21 56/24 I 16/7 16/9 23/5 26/1 I 138/25 150/9 150/24
98/11 116/18 116/20 I, 146/15 231/10 195/21 33/11 36/10 36/19 I 155/17 157/20 159/1
128/13 128/17 132/15I*ackle [3] 84/23 85/7 Itariffs [1] 18/23 38/4 42/4 43/19 44/10] 159/13 164/18 170/10
4179/12 192/17 195/22I 2198 task [1] 101/8 48/22 56/2 60/3 64/15) 171/8 173/8 176/23
4198/7 223/15 226/11 Itake [57] 14/8 15/5 tasked [1] 45/18 64/20 65/22 66/5 178/10 202/1 203/21
supported [3] 37/1 I 18/17 19/28 24/25 taxpayer [2] 71/6 I 71/14 72/3 75/16 76/4] 204/24 205/21 205/24
1da13 186; 25/15 37/10 48/4 4110/4 81/17 82/23 91/25 I 210/9 212/20 213/22
supporting [3] 98/6 I 98/11 59/2 59/4 60/12 taxpayers [1] 49/7 I 96/15 97/18 102/16 I 216/2 218/2 218/24
117/13 148/12 63/15 63/25 67/6 Taylor [1] 164/17 106/23 107/14 107/16I 222/9 228/21 232/18
77/22 88/10 89/22 I TC [2] 159/15 162/6 I 107/24 109/13 109/25I thanking [1] 184/20
Supportive [3] 39/8 I 95/12 101/10 101/24 Iteam [59] 2/7 65/12 I 117/17 119/12 122/18Ithanks [4] 112/18
supports 21 117115 I 10372 108/5 108/13 I 65/13 65/18 66/3 66/3] 12674 126/21 128/10 I 123/24 129125 211/16
suppc 407/1 107/11 108/3 I 72/3 72/3 76/5 77/1 I 136/25 152/11 167/13] that [1544]
capmose (14) 22122 I 110/19 110/22 111/22] eave e2/9 ea/t0 82/14] 175/18 178/8 182/1 I that I [3] 207/11
see Ot opie I 117/17 12018 120/20 I 100/19 115/20 115/21] 182/4 182/16 187/7_I 214/13 28/4
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155/1 160/3 168/18 I 118/1 118/25 118/25 I 198/17 200/1 201/4 I that's [166] 5/1 5/7
169/5 180/20 188/22
4190/6 191/22 2036 I 1997 169/13 169/18 I 120/5 120/7 120/9 _I 205/25 206/5 221/25 I 5/12 5/16 6/5 6/9 7/24]
206/17 169/24 173/9 185/13 I 120/15 121/4 121/18 I 222/23 224/24 8/17 8/22 9/5 9/10
supposed [3] 58/25 186/17 204/16 206/7 I 122/8 122/19 125/21 Iterrible [4] 8/5 13/11 I 10/16 15/4 15/5 17/3
61/21 220/6 211/20 215/22 216/4 I 132/21 146/6 147/3 I 39/25 40/7 17/25 18/6 18/25 19/2
sure (34) 8/3 11/16 I 22/3 221/9 2268/1 I 147/6 147/7 160/13 terribly [1] 23/1 19/3 19/9 20/23 21/11
18/11 24/16 28/20 I 228/4 229/7 230/10 I 166/23 169/12 170/8 Itest [4] 22/10 151/8 I 22/8 29/11 30/7 31/2
taken [31] 15/25 1741/2 177/15 184/8 I 156/4 197/5 32/6 33/6 34/17 38/19
(95) suffered... - that's
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47/19 51/17 52/14 208/15 209/19 211/12) 166/3 166/6 166/18 I 106/22 109/12 110/6 I 125/12 126/6 128/22
53/13 54/23 55/21 213/4 220/23 222/19 I 167/8171/1 171/12 I 110/12 110/12 110/22) 157/17 167/4 168/16
56/17 60/21 61/20 226/15 227/19 228/13) 171/24 172/11 173/2 I 112/15 125/14 127/8 I 168/19 170/23 181/24,
61/21 62/12.63/13._ I 230/25 175/14 181/23 182/7 I 127/9 138/19 139/14 I 197/9 215/10
63/13 63/14 65/17 Ithem [67] 13/12 14/2 I 184/7 184/12 184/21 I 140/5 140/9 141/8 _I think [382]
67/6 69/17 70/14 21/9 34/6 40/8 44/13 I 189/8 192/18 195/2 I 141/12 142/19 142/24I thinking [5] 96/2
70124 71/13 71/19 I 48/1 48/1 49/3 49/4 I 195/6 195/21 196/24 I 144/19 146/23 147/1 I 110/10 186/25 190/18
et 729 7316 I 82/1954! 56/15 I 198/11 202/12 203/19] 147/20 148/2 148/22 I 205/21
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82/11 83/24 84/6 84/6I 02/17 63/4 68/22 224/1 227/7 228/8 154/20 155/7 162/19 Ithirdly [1] 36/24
84/14 89/9 89/13, I 71/20 76/24 86/14 I 228/22 232/17 169/10 169/12 172/21I thirds [2] 206/16
92/21 93/14 96/17 91/3 91/4 94/11 94/21Itheory [2] 119/5 175/17 178/25 179/9 I 206/17
96/24 96/25 98/9 I 96/22. 111/14 125/19 I 174/21 180/10 180/11 180/14I Thirsk [3] 3/21 4/25
102/21 103/13 103/18) 126/18 130/6 138/23 Itherapy [1] 226/9 I 181/7 182/3 182/13. I 9/7
4104/7 105/17 106/7 I 142/22 146/24 148/20] there [250] 185/4 185/6 187/16 _ I this [419]
106/17 108/12 109/2 I 149/6 154/24 157/2_ Ithere's [36] 19/21 I 188/3 188/12 189/16 IThomas [4] 117/20
411/10 113/20 114/9 I 1960/2 165/17 168/17 I 21/5 23/7 23/17 26/3 I 190/2 190/3 190/10 I 188/8 189/13 200/21
4115/4 14619 121/2 I 169/12 175/14 176/21] 48/25 57/1 59/17 61/5I 190/10 195/8 195/25 IThornton [2] 79/4
12115 130/10 133/20 I 182/20 183/6 185/21 I 64/6 71/17 90/19 95/4) 196/7 198/8 198/15 I 82/23
4134/22 135/2 136/25 I 187/5 195/16 199/9 I 97/5 99/13 110/2 _I 199/14 199/17 202/18I thorough [1] 156/4
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1462/10 163/16 163/20 theme [1] 83/14 213/23 214/12 225/8 I 217/23 218/5 220/17 I 23/6 23/22 23/25 27/3
464/10 172/14 174/1 Ithemselves [7] 29/2 I 229/9 229/14 220/23 222/18 226/6 I 31/19 32/17 34/9
1478/10 182/23 184/2 29/6 62/23 68/13 thereafter [3] 87/19 I 226/7 227/13 227/24 I 34/10 35/1 35/9 36/11
1488/15 188/24 190/17 138/22 157/25 173/7 I 127/14 159/11 229/17 229/18 230/14! 37/10 37/11 37/12
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1494/9 196/21 197/23 I 11/20 14/4 17/23 65/10 69/8 87/9 96/21Ithey're [13] 24/3 24/4I 68/20 75/1 75/2 75/24,
1498/1 204/1 207/25 I 23/16 25/20 27/10 118/22 197/3 212/4 I 26/5 26/7 52/23 62/12I 77/4 79/6 79/8 81/14
210/12 210/19 211/24) 27/16 27/19 28/24 I these [36] 12/2 14/8 I 65/9 74/13 75/25 81/15 86/11 86/23
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221/22 222/17 226/25) 32/14 32/17 38/7 24/17 25/12 25/14 228/13 91/6 95/15 97/4 97/7
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229/4 229/8 230/6 42/21 42/25 43/15 41/13 50/13 56/13 89/18 110/8 175/15 I 103/5 107/13 109/15
5230/6 231/8 232/14 I 46/5 53/4 53/7 53/24 I 58/12 74/20 74/22 206/24 229/21 231/21] 110/20 111/2 117/1
232/17 55/19 57/6 57/7 57/13) 78/20 89/6 97/22 thing [27] 19/10 20/5 I 118/4 119/15 125/14
their [81] 11/23 13/17I 59/5 59/7 59/11 61/9 I 98/10 100/10 107/15 I 22/4 27/13 27/21 44/3) 126/21 133/13 134/25)
15/22 15/22 15/23 61/19 61/25 63/8 151/11 159/18 159/21I 44/7 50/25 51/14 63/3I 138/4 138/23 140/21
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82/24 88/11 88/22 73/19 77/17 77/23 21/14 21/14 21/15 —Ithings [65] 7/13 7/16 I 160/6 169/21 170/12
89/24 90/8 94/14 84/17 84/25 85/18 23/1 24/2 25/17 26/4 I 8/22 11/17 15/25 16/2I 170/18 172/16 174/17,
94/16 95/21 95/22 88/13 88/17 90/20 26/25 27/1 28/2 29/7 I 16/17 16/19 19/15 174/18 175/5 176/12
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97/25 99/7 99/20 99/15 101/5 107/16 I 35/9 40/19 41/18 21/22 21/24 25/4 25/7I 178/23 179/12 180/19
100/19 105/1 106/24 I 110/9 111/1 111/12 I 49/12 49/23 52/20 25/12 32/25 33/10 182/8 183/1 188/14
106/24 108/19 122/2 I 114/4 115/17 116/14 I 52/25 53/1 54/4 56/1 I 33/11 33/17 34/8 189/4 189/4 189/21
422/10 126/10 127/5 I 117/6 119/7 120/18 I 58/22 60/11 61/19 34/15 34/21 35/10 190/16 195/23 195/24)
1429/19 131/13 135/11I 120/19 125/3 125/14 I 62/4 62/11 62/14 63/2) 36/11 37/10 38/15 196/4 196/10 197/7
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211/23 213/11 213/24 time [108] 1/16 4/13 ITolhurst's [2] 135/5 I 228/6 truth [2] 53/23 158/4
D14/2 214/18 214/20 I 6/17 6/25 7/6 7/7 7/9 I 136/18 trade-offs [1] 73/11 Itry [27] 8/2 8/21 10/4
214/24 215/3 215/25 I 9/4 9/13 13/23 15/5 I Tom [30] 77/17 trading [5] 152/19 I 16/19 22/2 35/11
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1987 131/16 170/6 I 37/11 38/10 38/11 125/9 125/11 125/11 I tragedy [1] 13/11 112/11 128/18 151/6
171/17 177/12 180/6 I 98/12 39/19 41/6 125/19 127/19 128/10Itraining [1] 216/24 I 174/6 175/13 176/5
1485/2 197/1 45/13 49/22 52/1 52/2) 128/14 128/18 129/24Itranscript [2] 2/18 177/24 181/3 182/24
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thoughts fa) aon I 85/21 85124 86/9 I 14919 292/21 1441/3 90/9 95/3 97/11 98/4
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132/8 133/1 136/4 66/12 91/10 93/3 47/10 47/11 47/14 187/5 188/25 199/3
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topo awe ela 158/10 169/6 169/21 I 20/20 21/24 39/15 I 75/1 75/5 117/13 I 28/24 31/7 31/12 45/8
teroa Doan 1717 171/19 17518 I 39/18. 45/15 77/21 I 153/10 155/15 155/24I 59/14 66/7 73/9 77/6
thresholds [4] 55/19 175/22 177/4 177/22 I 115/8 126/6 138/22 I 156/19 157/2 157/5 I 80/16 113/15 113/19
55/23 55/25 204/19 I 179/2 185/7 187/8 145/25 148/21 149/21) 157/7 157/13 160/13 I 114/8 127/17 128/25
through [60] 10/5 188/11 191/19 192/20) 149/25 156/25 159/9 I 162/25 171/6 171/9 I 133/1 133/4 134/20
46/17 20/11 22/22 201/13 202/18 206/7 I 178/25 179/13 202/17) 194/21 194/24 195/6 I 135/6 137/10 140/20
22/22 24/14 25/8 25/9I 208/13 210/10 212/6 I 204/23 204/21 205/7 205/11 I 140/22 150/11 157/20}
31/1 32/3 3213 54/11 I 219/10 219/18 20/2 Itop [7] 40/13 42/22 I Treasury's [2] 50/19 I 161/21 170/10 192/18
54/24 71/9 71/16 222/7 224/15 226/5 I 44/19 61/14 70/23 I 204/19 192/21
716 76/9 786 228/6 178/11 178/13 treat [2] 23/4 87/12 Iturned [1] 142/9
79/25 81/24 89/18 ___Itimely [1] 43/13 top-up [1] 178/13 __Itreated [3] 49/6 Turning [2] 64/14
90/2 91/19 91/24 92/gItimes [6] 18/13 20/8 Itop-ups [1] 178/11 I 129/10 215/3 161/6
95/20 97/21 98/16 I 37/22 83/22 112/23 Itopic [16] 22/12 treatment [5] 43/6 turnover [1] 142/1
401/12 1173 118/24 I 145!7 28/24 31/12 31/12 I 57/13 57/14 26/2 I turns [1] 131/23
420/20 124/20 132/18) timescales [1] 34/4 48/21 117/19 226/4 TV [4] 50/16
136/12 138/20 149/21I 199/11 117/22 142/21 176/23Itreats [1] 22/25 twice [1] 52/13
483/15 185/25 157/1 Itiming [2] 54/9 178/10 183/14 187/25Itrial [5] 123/2 129/10 Itwo [34] 2/12 3/15
487/18 171/23 173/11 I 136/25 203/22 210/12 216/3 I 129/19 137/19 138/2 I 11/5 14/14 23/21
176/12 178/7 179/4 _Ititle [1] 40/15 topics [3] 31/20 tricky [1] 152/22 24/24 30/10 62/24
4180/5 180/15 193/14 {today [20] 2/6 6/2 I 202/3 214/23 tried [11] 7/16 8/22 I 67/6 68/20 82/15
t96/1 196/5 19616. I 17/20 54/5 74/7 74/8 Itopped [1] 27/4 14/17 14/19 15/18 I 84/25 99/2 101/14
4199/2 199/22 205/15 I 81/13 105/1 105/7 total [1] 212/11 25/4 33/17 44/10 108/22 109/15 113/14
207/1 214/17 226/28 I 118/12 129/7 185/15 Itotally [3] 100/15 I 56/11 102/3 17/22 I 117/1 119/6 119/24
9207/4 230/16 187/9 187/22 204/24 I 102/3 122/14 tries [1] 88/13 120/12 125/19 133/13
throughout [10] 219/3 225/11 227/9 Itouch [5] 46/5 46/10 Itrivial [3] 35/16 35/21] 136/23 163/6 170/12
Biieeria 19/15 I 227/10 228/23 101/15 115/8 202/23 I 36/2 176/1 198/10 206/16
143/13 144/16 153/20I together [8] 10/3 touched [5] 139/23 I Trott [1] 45/15 206/17 211/25 214/23
4165/9 169/5 02/4. I 11/24.98/7 117/10 _ I 166/16 181/11 191/3 Itrouble [3] 64/18 I 218/25 230/24
220/16 188/12 196/1 204/13 I 204/3 65/15 67/25 two-thirds [2] 206/16
thrown [1] 1/19 205/3 towards [13] 37/16 Itroubles [1] 64/19 I 206/17
tie [1] 10813 told [14] 20/10 53/21 I 71/4 117/3 122/19 Itrue [11] 4/196/9 I twofold [1] 33/23
75/7 79/12 82/6 82/8 I 127/2 135/25 160/23 I 54/22 93/14 109/2 _ tying [2] 123/25
(97) those... - tying
INQ00001202
1NQ00001202
T 203/22 211/19 216/15Iunsuccessfully [1] _Iups [1] 178/11 23/17 24/8 24/12
tying... [1] 165/25 228/25 213/25 urge [2] 13/9 34/10 I 24/12 24/16 27/5 28/2
type fra] 400/11 Under-Secretary [2] Iuntenable [1] 78/23 Iurged [1] 34/6 30/9 34/25 35/4 36/7
‘Sait 5/5 5/18 until [24] 1/10 1/15 Iurging [1] 68/14 39/8 39/11 39/22
typical [2] 22/4 underestimation [1] I 1/24 5/3 5/13 6/2 6/2 IURN [1] 3/25 49/17 49/24 54/6
B10 144/14 6/18 8/16 50/16 54/25Ius [61] 3/20 3/24 59/22 62/13 63/19
typically [1] 65/14 [Underlying [1] 180/3 I 55/9 85/19 86/16 TIM 7/25 9/13 32/19 I 64/2 64/11 71/7 71/10}
eee ey een’ _Iundermine [1] 112/21 129/20 132/3 I 35/11 41/22 45/19 I 77/15 77/16 77/18
U 125/10 136/3 140/2 143/25 I 45/24 46/1 47/23 79/1 79/3 79/9 82/1
UKGI [34] 55/22 ___IUndermining [1] 171/11 194/25 224/3 I 49/12 65/2 69/8 72/23I 85/10 85/18 86/11
77/47 78/23 78/25 I 185/5 232/23 76/14 80/16 80/23 I 86/14 88/21 89/6 91/8}
82/9 115/10 115/13 IUNderpayment [2] unusual [1] 128/9 81/21 84/9 85/8 86/16] 92/22 92/25 94/6 95/1
115/24 116/21 116/25I 186/5 186/8 up [96] 6/8 6/13 9/1 I 108/7 115/10 123/24 I 97/19 98/24 100/13
1417/6 118/1 118/7 understand [45] 21/7I 9/12 14/8 18/4 22/16 I 124/8 125/7 126/21 I 106/10 108/19 111/2
118/10 121/3 124/14 I 24/14 28/14 28/22 25/18 27/4 30/24 33/9] 128/22 129/15 141/2 I 112/18 113/10 114/1
432/21 132/24 144/25] 29/1 29/10 32/15 35/15 38/12 41/8 45/8] 154/15 156/7 159/24 I 114/15 115/5 117/10
1446/7 146/25 147/3 I 34/10 49/1 49/7 50/1 I 45/21 46/10 46/23 160/3 167/23 169/25 I 120/8 122/5 122/21
447/11 147/14 152/15] 91/21 52/24 54/5 48/2 52/23 61/8 68/17I 176/10 176/11 178/23) 122/23 123/8 124/16
455/22 160/19 160/24] 96/21 58/10 58/14 69/8 72/21 74/6 76/23] 181/24 184/20 184/21I 129/5 129/25 131/9
1460/25 161/16 161/25] 63/11 64/1 64/24 77/6 86/16 87/23 187/18 188/12 192/10] 138/13 143/20 149/1
1464/1 171/3. 171/12 I 74/23 83/19 84/2 94/7) 87/24 88/13 88/17 194/18 202/5 207/13 I 149/18 150/24 155/2
UKGI's [2] 116/3 100/9 100/11 102/10 I 92/16 93/24 96/13 207/17 208/21 208/23} 156/1 160/21 167/4
418/22 107/7 128/3 146/9 96/19 99/5 102/2 209/2 209/9 211/22 174IT 174/19 175/8
UKG100009785 [4] 170/16 178/12 182/18] 104/2 104/3 104/17 I 212/7 215/7 215/8 176/4 177/8 179/2
420/23 187/3 187/4 197/3 104/22 105/15 108/4 I 217/11 222/19 182/23 185/7 191/17
UKG100009832 [1] 203/5 208/11 217/10 I 108/23 117/24 120/18Iuse [7] 10/6 29/8 197/16 197/16 202/10)
128/25 217/12 221/1 225/4 I 120/22 122/4 123/12 I 38/1 46/25 64/22 202/17 204/5 210/9
UKG100010212 [1] 231/21 231/24 232/8 I 123/22 125/12 128/21) 105/7 196/14 211/2 214/23 215/6
134/20 understandably [1] I 129/23 131/20 132/3 Iused [6] 24/20 29/4 I 218/2 219/23 222/9
uKGi00012774 [4] I 13/1 133/6 136/3 136/22 I 38/4 64/25 216/23 I 223/22 225/10 225/16
450/11 understanding [8] 139/9 140/18 143/25 I 228/17 228/3 231/2 232/14
27/18 47/10 71/10 144/8 147/17 151/14 Iuseful [4] 45/24 232/18
ener 2] 107/14 172/7 174/7 152/17 155/12 159/1 I 184/6 212/19 213/21 IVFM [1] 181/19
UKG100030648 [1] 203/3 203/6 160/14 166/3 166/13 Iusing [5] 33/19 33/19) via [1] 95/22
9/1 understood [7] 21/6 I 166/23 168/6 172/22 I 33/23 39/21 105/18 I viability [4] 69/23
ukGi00043650 [1] I 36/22 37/15 50/23 173/2 17/19 178/13 Iusual [1] 32/3 70/20 71/14 71/25
164/24 58/24 68/10 79/1 179/14 182/3 185/1 Iusually [1] 32/23 _I viable [4] 62/7 71/12
UKG1I00047866 [1] [Undertake [1] 41/11 I 187/12 189/12 194/11) >I 71/13 153/22
439/1 undertaken [1] 213/3I 194/25 195/5 195/7_ I “_______________Ivictim [2] 148/19
ultimate [1] 43/13 [underwrite [1] 199/12 202/12 209/24Ivain [1] 30/22 215/19
ultimately [6] 117/4 I 154/20 210/6 213/6 213/8 — Ivalue [10] 42/5 42/11I victims [10] 10/19
467/11 172/7 173/3. Iwndetermined [1] I 218/8 227/7 230/6 I 44/4 48/20 49/22 70/3I 13/11 13/16 32/23
487/17 198/11 198/10 232/5 109/13 191/18 191/23] 32/24 88/11 155/5
unable [3] 2/16 47/13 unexplained [1] update [3] 129/1 194/7 167/20 175/1 228/7
80/25 105/22 129/2 151/1 Vamos [1] 221/6 I victory [2] 126/3
unblock [1] 151/18 unfair [1] 185/21 updated [1] 162/3 I variety [1] 114/21 126/14
uncertain [2] 13/17 unfettered [1] 177/17Iupdating [2] 210/19 Ivarious [23] 10/5 view [64] 20/20 21/24)
74/5 unfiltered [1] 31/24 I 210/25 20/11 30/11 33/1 23/25 24/20 25/23
uncertainty [2] 140/7IUnfixable [1] 60/9 upfront [9] 39/1 47/8 I 50/22 62/19 81/13 I 41/19 48/8 48/13
216/1 unfortunate [1] 48/18 58/9 174/2 116/9 118/13 118/13 I 50/17 58/1 70/25
unclear [1] 85/12 I 182/23 176/16 196/17 196/19I 122/11 125/2 136/6 I 71/15 77/11 80/24
uncomfortable [1] IUNhappy [4] 123/14 I 204/20 150/19 166/7 189/4 I 81/25 82/4 84/10
90/14 197/1 198/8 208/23 I uplift [2] 91/17 180/9 I 195/12 195/16 203/9 I 103/9 108/20 110/20
uncommon [1] 76/5 IWnhelpful [1] 178/17 Iupon [26] 15/24 204/19 216/8 216/22 I 120/8 131/2 132/12
undated [1] 40/10 [unifying [1] 83/1 39/21 49/12 57/4 216/24 137/2 142/7 143/1
undecided [1] 198/9 Unique [4] 15/2 15/2 I 64/10 68/18 69/10 __Ivast [2] 12/5 26/20 I 147/19 147/20 148/10
under [26] 2/52/17. I 114/1 114/16 90/8 98/7 98/19 Venn [1] 230/24 149/13 153/4 154/17
2/20 3/2 5/5 5/18 6/19IUNless [2] 100/23 I 101/15 115/8 117/19 Iverbatim [1] 61/2 I 155/1 163/25 165/22
12/11 23/18 26/12 192/16 118/22 145/16 164/13Iversion [1] 194/24 166/4 167/15 168/15
41/12 41/13 66/8 unlikely [4] 106/2 180/13 180/17 186/21Iversus [1] 160/20 169/18 172/18 175/4
71/18 83/25 121/23 I 126/24 131/9 161/9 I 190/15 195/20 199/19] very [113] 1/17 1/22 I 4177/1 17/3 17/14
4133/4 152/20 163/18 [Unnamed [1] 52/10 I 203/6 205/7 206/19 I 3/13 4/14 4/22 7/25 I 178/22 178/25 181/9
467/1 188/2 20216 [unpaid [1] 41/3 226/1 8/18 13/3 13/23 14/9 I 183/3 185/8 194/22
unsigned [1] 52/6 Iupper [1] 170/22 14/13 19/19 23/16 I 197/2 197/15 197/20
(98) tying... - view
INQ00001202
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Vv wasn't [46] 7/3 7/4 I 16/10 40/10 57/4 201/11 201/20 204/25] 160/16 161/7 162/4
View... [11] 199/16 20/6 29/25 31/3 32/22) 60/18 86/17 91/16 206/3 208/6 213/14 I 162/8 167/3 168/10
200/8 203/5 204/21 I 43/24 54/3 54/15 94/4 97/8 97/10 214/6 218/4 219/13 I 169/10 170/4 170/19
205/10 208/11 208/20] 99/24 57/17 59/13 101/14 103/25 109/11) 219/16 220/5 220/11 I 172/9 172/16 176/15
208/25 212/24 214/15 63/1 64/10 71/5 78/5 I 112/3 121/24 147/9 220/15 221/18 223/6 I 178/21 179/22 181/25
217/13 78/5 78/13 78/15 152/23 162/25 171/11) 223/22 223/22 224/17I 182/13 184/8 185/8
views [9] 42/10 47/16 81/10 82/21 83/23 173/18 175/24 184/3 I 226/7 226/16 229/20 I 190/15 191/20 191/24}
47/17 52/16 91/7 85/9 94/17 97/17 206/9 206/21 227/25 I 232/13 192/12 192/14 192/15)
112/13 172/16 196/18] 100/6 100/7 102/5 231/11 went [16] 7/4 12/6 193/2 193/13 194/13
205/6 107/8 122/3 122/9 __Iwebsite [3] 97/19 21/1 22/7 78/16 80/24! 199/9 202/10 202/12
village [1] 1/8 122/10 131/7 133/15 I 114/3 114/17 100/6 153/11 156/2 203/10 204/21 204/22
virtually [3] 7/14 93/4 135/4 143/6 168/17 Iwedding [1] 119/21 I 157/12 166/21 172/14) 205/1 207/12 209/24
156/3 169/22 170/6 183/2 IWednesday [1] 1/1 I 193/19 195/6 205/22 I 210/7 210/21 211/9
vis [6] 115/10 115/10 203/4 219/24 220/10 Iweeds [3] 18/13 20/9] 214/16 213/18 213/24 214/4
4116/1 116/1 135/24 I 220/11 220/15 224/3 I 21/10 were [227] 1/21 2/3 I 214/5 214/6 215/9
135/24 watch [3] 83/18 week [16] 48/4 52/2 I 4/9 4/24 5/3 5/8 8/3 I 215/13 215/25 216/22)
vis a vis [3] 115/10 83/20 123/4 117/23 126/25 174/16I 9/4 9/14 9/18 10/6 216/24 216/25 219/2
4116/1 135/24 water [1] 80/7 195/15 199/18 204/9 I 17/4 17/7 17/8 19/15 I 222/13 222/18 223/15)
vital [1] 156/5 watering [2] 139/14 I 207/5 207/9 207/17 I 20/3 20/4 21/10 21/13) 223/16 224/9 224/10
voice [3] 8/3 214/17 140/13 209/2 224/1 224/14 I 21/13 21/14 21/15 224/14 224/22 231/14
216/19 Watt [4] 86/18 104/10] 226/8 228/11 21/22 25/7 30/13 weren't [11] 21/25
volume [1] 179/12 104/11 233/10 weekend [2] 7/3 30/16 31/4 32/15 28/2 39/9 58/19 84/5
voluntary [1] 213/3 IWaves [2] 201/7 100/6 32/19 34/1 34/7 34/8 I 85/23 95/3 141/22
227/25 weeks [1] 18/17 34/10 34/15 34/21 190/4 195/5 199/14
vs Oo tty 104/19 way [49] 3/10 26/9 Iweeks'[1] 11/22 I 34/25 36/1 35/5 35/9 IWestminster [1]
vulnerable [3] 123/20] 28/17 30/14 32/8 weigh [1] 172/22 35/10 35/15 37/6 37/7) 148/17
q75/1 21016 33/23 36/7 36/12__Iweighed [1] 173/2 I 38/20 39/1 39/6 41/5 Iwhat [197] 3/3 8/22
ee] 39/13 40/5 57/1 57/15I weight [1] 52/17 I 43/21 46/8 47/9 48/10) 8/24 9/13 9/17 14/17
w 57/18 58/8 59/3 62/2 Iwelcome [2] 42/10 I 49/17 50/20 53/6 53/6I 14/20 18/25 19/6 19/7
wage [2] 61/12 71/12 67/6 70/14 75/11 171/14 53/24 56/1 56/2 56/17I 21/2 21/8 22/18 22/22
wait [3] 59/9 171/11 I 89/16 92/25 93/3 Iwelcomed [1] 204/7 I 59/1 60/9 60/11 60/12I 22/23 30/7 30/18
7226/6 93/19 95/7 95/11 Iwelcomes [1] 101/9 I 60/24 62/5 62/9 62/14] 32/19 35/11 35/22
waiting [4] 20/4 98/14 98/17 102/4 _Iwell [124] 1/25 3/11 I 62/19 62/22 63/4 63/6] 36/10 37/25 38/2
162/4 162/19 228/13 I 103/10 109/10 114/18) 6/14 7/12 9/15 16/19 I 63/9 63/17 65/20 —_—I 38/19 39/19 39/21
waived [4] 199/12. I 118/17 119/4 131/13 I 17/6 17/10 26/24 I 65/23.68/2 71/11 I 43/22 44/6 46/1 46/8
Wales [4] 212/12 _ I 138/14 145/3 147/26 I 29/13 29/17 29/24 I 72/10 72/20 75/7 —_I 49/13 50/19 51/8 54/6
299/10 229/24 231/3 I 149/21 154/18 155/11I 29/25 31/3 34/4 38/4 I 78/11 80/2 80/11 56/11 56/17 56/24
walk [1] 39/23 157/14 160/5 175/12 I 38/21 39/11 41/20 80/15 82/2 82/4 82/15] 57/16 61/2 61/14 62/1
want [26] 17/12 181/17 181/20 186/5 I 43/24 47/6 49/7 50/21I 82/18 82/19 83/9 85/5I 62/3 62/4 62/24 63/3
49/22 52/25 57/15 192/12 207/13 224/22I 56/1 56/13 57/3 58/15I 85/21 85/24 86/1 63/4 63/18 64/15 65/4
68/5 76/6 86/22 89/7 IWays [12] 15/21 62/10 62/11 62/21 86/23 87/11 87/12 65/10 65/14 65/21
89/8 90/16 90/19 16/16 41/7 58/7 64/23) 64/17 64/20 65/23 88/21 91/4 93/18 69/6 69/16 70/24 72/9
90/20 91/12 111/22 I 79/23 92/24 102/15 I 67/10 67/21 68/16 93/22 94/1 94/1 94/13] 73/20 74/13 75/7
426/24 151/17 154/20I 131/6 142/24 190/15 I 72/2 73/2 75/10 79/2 I 94/20 94/20 94/23 79/16 80/8 80/8 81/7
1469/25 179/14 185/21) 230/24 79/3 79/18 81/9 81/9 I 96/5 105/19 105/20 I 81/13 81/14 82/4
189/9 208/13 208/13 IWe [511] 82/6 82/11 82/21 83/5I 106/22 106/23 108/9 I 83/20 87/5 88/23 89/9
222/14 226/6 229/21 Iwe'd [5] 8/13 32/24 I 84/5 85/11 86/18 108/18 114/22 116/9 I 90/15 95/25 97/23
wanted [25] 58/17 36/7 43/25 51/6 87/18 87/22 89/6 116/16 116/18 119/2 I 98/18 99/6 99/17
84/11 89/2 89/10 we'll [12] 30/2 30/4 I 92/12 92/22 94/16 124/23 125/14 126/7 I 101/20 101/25 102/22)
106/5 125/4 125/7 51/2 75/12 84/6 97/3 109/5 109/7 127/8 127/14 128/15 I 103/15 103/25 104/5
428/22 133/20 133/24] 118/12 128/24 149/8 I 109/9 110/11 110/16 I 129/7 130/20 1314/2 I 104/7 106/5 107/17
449/24 152/14 152/15] 150/24 151/19 152/10I 110/18 111/8 111/16 I 131/25 132/2 132/9 I 108/3 108/20 109/15,
457/17 159/18 160/13] 16/6 111/20 112/13 118/18] 132/9 132/24 133/12 I 112/4 112/15 115/25
460/18 167/20 181/18] We're [29] 21/11 119/5 120/19 124/1 I 133/25 138/21 140/5 I 119/4 121/13 121/19
205/3 218/15 20/7 I 22/11 64/7 89/9 90/6 I 127/4 131/3 131/18 I 140/18 140/19 141/18I 122/19 122/23 123/21
500/13 220/18 226/5 I 92/3 103/19 104/1 I 132/13 132/16 137/2 I 142/17 142/19 143/4 I 124/6 124/8 124/11
wants [2] 134/2 104/1 104/2 104/2 I 142/2 142/16 143/23 I 143/9 144/11 144/16 I 124/19 124/23 125/7
134/3 113/6 120/13 133/2 I 143/25 145/10 146/22] 144/19 144/25 145/7 I 126/16 126/22 127/2
warm [4] 94/21 139/1 139/1 141/13 147/3 149/3 151/7 146/1 146/3 147/16 130/17 130/18 131/19}
warming [1] 61/7 161/21 163/23 168/16] 153/12 156/9 159/6 I 147/24 148/2 148/15 I 135/22 136/9 140/7
warning [1] 131/12 170/21 171/9 179/4 I 165/5 167/18 172/24 I 149/15 149/16 149/17I 142/19 142/25 143/5
was [642] 179/6 183/14 184/5 I 179/22 181/11 186/5 I 151/21 151/25 152/5 I 145/20 145/21 145/24!
washed [1] 193/14 199/3 201/21 223/22 I 189/6 189/8 191/22 I 153/1 154/6 157/14 I 146/1 146/15 147/8
we've [27] 11/3 14/16] 192/10 198/2 201/6 I 159/4 159/25 160/14 I 147/18 149/14 151/21
(99) view... - what
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what... [73] 153/12
154/10 155/3 156/21
159/24 160/2 160/7
160/14 161/19 163/8
164/24 167/20 168/8
168/12 169/17 175/17)
176/8 177/24 178/8
178/22 180/14 181/19}
182/11 184/5 185/23
185/25 187/1 187/17
187/18 187/23 189/3
189/7 189/8 189/9
192/3 193/6 195/11
197/11 197/21 199/3
199/17 200/9 201/16
201/20 203/6 203/14
204/20 205/5 205/7
205/12 208/12 210/7
210/20 214/2 216/10
217/3 217/8 217/8
217/25 218/8 219/10
220/18 221/1 221/15
221/25 222/21 226/16
227/5 227/8 229/6
231/16 232/11 232/13
what's [10] 83/8 95/7
98/13 111/22 128/3
158/15 181/9 190/9
193/22 208/20
whatever [10] 7/15
22/24 34/11 46/3
56/15 68/5 141/14
154/20 165/16 227/17
when [95] 1/10 5/13
7/4 7/13 8/3 8/7 11/15)
11/22 14/14 19/14
20/7 20/15 20/20 22/7
23/1 23/2 23/22 26/4
32/23 33/8 34/5 34/18
35/20 37/3 37/11
37/25 39/16 46/3
49/19 54/14 62/18
62/19 63/24 64/17
65/4 65/14 74/22
77/14 86/5 99/4 99/11
100/7 100/13 103/19
108/4 120/12 122/14
122/18 122/22 125/25)
129/21 130/24 131/1
137/1 137/9 142/19
145/19 146/20 148/5
149/15 152/12 156/11
158/22 162/24 165/23}
169/6 169/10 170/4
175/18 178/3 178/19
180/9 182/17 184/9
184/16 185/14 193/10)
194/13 200/24 200/25)
201/2 201/4 201/10
201/16 203/24 204/9
208/14 212/1 214/5
214/16 217/5 217/21
219/2 224/6 224/7
whenever [2] 74/18
200/11
where [62] 7/17 8/13
10/25 16/10 19/12
26/18 33/1 33/18
35/10 38/22 39/2
39/15 46/24 57/12
60/2 61/7 65/4 68/11
95/6 101/23 108/9
111/2 118/7 124/21
124/25 128/21 135/1
135/3 135/22 148/19
154/12 155/13 156/22)
157/4 157/12 163/9
166/10 168/21 175/5
175/9 180/16 180/17
188/14 189/11 189/16)
191/6 195/16 197/21
198/23 212/2 213/9
213/12 217/20 219/19
221/8 224/1 225/24
226/3 226/9 226/22
230/13 232/5
whereas [2] 146/18
214/20
whereby [3] 49/8
100/21 103/17
wherever [1] 70/8
whether [42] 11/14
26/12 42/11 48/7 56/7
67/7 88/4 88/19 89/13
93/11 105/5 116/17
127/11 130/15 132/11
145/17 145/18 146/14)
156/10 156/12 161/16)
163/5 165/16 166/22
168/1 169/19 175/2
196/4 196/7 197/6
198/10 200/12 201/6
207/25 208/2 218/9
221/9 226/21 227/3
227/4 231/9 231/15
which [154] 1/18
3/24 6/24 7/9 8/2 8/7
10/3 12/6 12/19 16/17)
16/18 17/6 19/19 20/1
22/12 26/19 27/9
27/17 28/10 30/21
32/7 32/12 33/10
34/24 37/15 38/2
39/22 41/8 41/14 42/1
43/21 45/8 45/8 47/4
49/24 51/4 51/22
52/10 54/1 55/16 56/7,
57/8 58/16 63/18
63/19 64/4 64/8 65/2
65/25 70/6 72/12
72/17 72/20 77/7
79/11 80/10 83/12
86/23 91/17 92/6 94/4
98/16 101/8 101/9
107/4 107/6 116/10
116/13 121/13 122/6
123/9 126/3 126/10
128/9 135/19 136/13
136/16 136/16 136/20
138/15 139/11 140/11
142/15 146/24 147/3
147/25 149/16 149/18
150/1 151/11 153/16
154/16 158/21 164/21
166/18 167/11 168/11
172/14 175/3 175/16
176/14 176/25 177/2
178/18 179/15 182/10:
182/11 183/16 183/19)
185/2 187/5 187/11
187/19 188/18 189/14.
190/15 192/12 194/3
197/19 199/15 199/19)
200/2 201/22 204/6
204/25 205/10 205/15
205/20 207/13 207/22
208/1 208/4 209/9
209/17 212/10 212/12
212/22 212/24 214/6
214/10 215/8 215/18
216/23 218/10 219/12
220/23 221/6 223/14
224/2 224/19 224/25
229/21 230/12 230/15
whichever [1] 93/8
while [11] 12/4 20/3
20/3 43/3 48/4 51/4
127/24 176/14 183/14:
185/2 225/1
whilst [7] 3/9 11/14
77/9 82/1 137/23
227/24 228/13
whim [1] 78/1
whistleblowers [2]
51/24 52/8
whistleblowing [1]
52/18
white [5] 87/5 88/1
88/14 90/24 182/11
who [132] 1/5 1/22
2/16 8/8 8/9 10/18
12/8 12/16 14/7 15/18
16/24 17/12 17/18
17/19 17/23 23/3 25/6
26/21 26/25 30/5
30/13 35/6 35/17 37/4
37/6 37/13 38/5 38/9
39/7 40/12 41/23
48/12 50/11 52/12
52/18 53/6 55/25
59/11 62/9 62/22 63/9
66/6 67/19 72/2 78/6
79/18 79/24 80/4
87/11 87/18 91/12
91/15 94/7 95/2 95/20
96/2 96/9 97/4 102/13
103/1 103/12 105/20
109/5 110/10 115/17
117/12 121/3 125/1
133/13 144/13 144/24
145/14 149/1 149/5
155/4 159/7 168/22
171/20 171/24 172/4
172/5 172/10 175/20
176/21 179/7 180/11
180/25 180/25 182/22)
184/7 186/16 186/16
187/16 188/13 189/14)
190/6 192/5 193/25
195/13 198/2 199/6
199/11 200/17 207/13)
207/24 209/16 210/17
211/3 212/23 213/24
215/9 215/19 215/25
218/16 220/2 220/6
220/13 220/14 222/10
222/13 226/14 227/9
227/17 227/23 228/25
230/8 230/19 231/14
231/17 231/18 231/25
232/12
who'd [1] 96/11
Who's [1] 61/23
whoever [3] 30/5
56/1 136/12
whole [6] 123/11
124/25 142/7 152/15
192/4 230/3
whom [4] 174/12
174/15 176/9 221/6
whose [12] 15/20
30/25 41/10 86/23
97/8 170/18 196/12
211/20 213/11 213/18
231/5 231/15
why [48] 7/10 8/17
18/17 20/14 20/15
21/1 21/2 21/7 24/16
25/3 28/5 28/14 28/22
29/12 30/1 31/5 34/10
49/1 50/1 52/24 53/22
56/21 58/14 64/12
68/9 69/5 77/22 78/25
79/16 85/8 91/7 91/11
92/11 92/12 92/14
93/2 111/18 116/10
133/20 143/16 164/23)
169/23 172/7 176/2
182/10 183/19 187/5
209/17
wide [4] 5/19 141/19
197/16 228/18
widely [2] 50/17
133/20
wider [5] 119/18
145/12 162/7 179/7
200/14
will [77] 3/6 6/13 9/1
9/2 12/24 13/10 13/15
13/25 14/7 22/16
23/15 25/15 30/5
52/19 60/14 61/1
73/18 76/22 86/15
87/23 89/10 89/17
91/3 91/14 98/19
101/5 101/6 101/10
106/20 108/15 108/17)
109/6 114/2 114/16
117/9 117/25 120/6
120/7 120/11 130/1
130/9 151/4 151/5
151/7 151/11 155/16
155/21 160/2 161/2
161/10 167/21 170/15)
171/2 179/9 189/12
189/25 192/25 194/3
195/11 195/20 195/21
195/22 197/8 198/2
200/3 200/24 200/25
201/5 201/10 209/16
209/19 210/24 211/12
221/7 223/24 230/21
232/21
Williams [4] 41/4
108/14 109/20 233/12)
willing [3] 20/13 63/2
64/10
willingness [2]
106/24 106/24
win [1] 216/21
wind [1] 120/7
windfall [1] 109/21
window [1] 200/22
Windrush [1] 134/41
winning [1] 222/8
wish [5] 4/11 21/7
27/24 39/10 209/17
withdraw [1] 111/2
within [52] 17/4
17/18 19/17 26/1
26/11 34/16 36/22
46/17 48/23 48/23
54/10 60/3 65/20 66/9
67/19 70/12 72/13
78/11 79/22 81/20
82/6 82/25 95/5 98/8
98/13 105/22 106/15
115/7 115/19 120/4
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136/1 141/17 142/16
153/17 154/23 157/1
167/2 168/25 171/1
171/17 176/19 177/8
190/7 190/14 200/14
202/13 212/3 215/19
226/5
without [18] 36/13
40/3 50/4 51/19 57/1
57/7 74/12 101/3
125/9 147/15 158/4
163/13 164/5 166/19
168/13 179/23 182/5
225/17
WITN00370106 [1]
104/21
WITN11170100 [1]
59/18
WITN11460100 [1]
(100) what... - WITN11460100
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228/17 230/21 232/8 44/25 46/18 47/20 I 103/9 111/6 115/12 Iyourself [2] 60/19
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498/22 131/14 13479 I 13/12 101/7 102/3 103/15 I 100/16 103/4 105/15
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105/8 118/18 119/5 I 39/16 53/15 61/1 210/23 211/1 2141/4 I 67/11 76/14 7/7
world [1] 140/11 69/24 73/12 73/14 I 2141/6 211/24 218/13 I 79/10 80/16 80/17
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(101) WITN11460100... - zip