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The Post Office Horizon IT Inquiry
Thursday, 7 November 2024
(10.00 am)
MS HODGE: Can you see and hear us?
SIR WYN WILLIAMS: Yes, but only faintly.
MS HODGE: Is that any better, sir?
‘SIR WYN WILLIAMS: It is to a degree. Itis a bit faint
but, anyway, I can hear you
MS HODGE: Would you like us to see if we can improve the
sound?
‘SIR WYN WILLIAMS: The trouble is it may interfere with your
questioning if you're worrying about whether I can hear
you or not, that's all. Let's start and see how we get
on and if I'm struggling Ill et you know.
MS HODGE: Thank you, sir. Our first witness today is Lora
Gratton.
SIR WYN WILLIAMS: It's fine now, by the way. You suddenly
came through much more clearly
LORNA RACHEL GRATTON (affirmed)
Questioned by MS HODGE
MS HODGE: Please give your full name.
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Lorna Rachel Gratton.
You should have in front of you a copy of a witness
statement dated 13 September this year. Do you have
that before you?
Ido, yes.
Enterprise and Growth Unit.
Thank you, you left the Civil Service in January 2013 to
join Boston Consulting Group, later returning in July
2016 to serve as Private Secretary to the Prime
Minister; is that correct?
Yes.
You subsequently worked in the Department for Culture,
Media and Sport, where you were appointed the Director
for the Digital and Tech Policy Directorate in May 2020;
is that right?
Yes.
In October 2021, you joined UKGI as a director —
(The witness nodded)
-- and were appointed as the Shareholder Representative
Non-Executive Director to the Board of Sheffield
Forgemasters; is that correct?
Yes.
Since May 2023, you've served as the UKGI Director with
responsibility for the Post Office ~ is that right —
Yes, itis.
-- and have sat on the Board of the Post Office as the
Shareholder Representative Non-Executive Director?
Yes.
In your role as UKGI Director, you currently have
responsibility for leadership of the Shareholder Team;
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That statement runs to 113 pages. Could I ask you,
please, to turn to page 99.
Yes.
Do you see your signature there at the end of your
statement?
Ido, yes.
Is the content of the statement true to the best of your
knowledge and belief?
Yes.
Thank you, Ms Gratton. As you know, my name is Ms Hodge
and I ask questions on behalf of the Inquiry. I shall
begin by asking you some brief questions about your
career background, if I may.
Upon graduating from university in 2005 you began
a career in teaching; is that correct?
Yes, I did the Teach First programme, yes.
You later joined the Civil Service in January 2010 and
were assigned to work in the Treasury; is that right?
Yes.
In your statement you say you worked in the Enterprise
and Growth Unit and as Private Secretary to the
Chancellor; did you perform both of those roles
simultaneously?
No, I was in the Enterprise and Growth Unit first, then
I worked for the Chancellor and then I went back to the
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is that right?
Yes.
In your statement, you describe the responsibilities of
that team as being to oversee the Post Office's
corporate governance and strategy and to monitor its
stewardship of financial resources; is that correct?
Yes, this is.
I'd like to begin, please, by asking you some questions
about the relationship between the Government and the
Post Office. In your statement, you describe the
Memorandum of Understanding that exists between UKGI and
what is now the Department for Business and Trade and
you explain that the MOU, which was signed in December
2019, draws a distinction between what we know as the
policy function and the shareholder function as it
applies to arm’s-length bodies, such as the Post Office;
is that correct?
Itis, yes.
You point out that the MOU formally assigns the policy
function to the Department and not to UKGI; is that
right?
That is, yes
Although matters of policy are decided by the
Department, you acknowledge that they are communicated
to UKGI, which is obliged to take them into account when
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performing its shareholder representative function; is
that correct?
Yes, absolutely. So the Department sets the objectives
for Post Office, and UKGI helps ensure that the Post
Office is delivering on those objectives.
How would you characterise the Department's current
policy objectives for the Post Office?
So the policy framework for Post Office as it stands is
expressed in terms of the number of branches that the
Post Office has to have and the coverage of the UK
population that have to be within a certain distance of
a number of branches, and then the services that Post
Office is subsidised by the Government to provide, which
are currently mails, banking and payment services, and
then some other Government services as well.
Does it remain the Government's ambition that the Post
Office should strive to achieve financial
self-sufficiency?
Yes, as set out in the Chair's letter. So the
Department writes an annual letter to the Board of the
Post Office and “financial sustainability" --I think,
is the phrase used in the letter --is set out in that.
Sustainability is slightly different from
self-sufficiency.
What do you understand "financial sustainability" to
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bits of the branches. A sort of slightly more rigorous
view of it would be that the Post Office would need to
be cash generative on an overall basis
At the moment, that is not the case. Itis, as
I say, a live discussion with Government at the
moment -- between Post Office and the Government —- as,
to whether or not that is achievable through changes to
the Post Office
By changes to the Post Office, do you mean changes to
the size of the Post Office Network?
Not necessarily to the size of the network. Largely due
to ~ largely changes to the Post Office's Head Office
cost base
You describe in your statement the various levers which
are available to the Government to influence the
governance and management of the Post Office. Some of
these are coercive powers, such as the power to dismiss
the Chair of the Post Office Board; is that correct?
Indeed.
Others you characterise as soft powers or influence --
(The witness nodded)
-- over the direction of the company, such as maybe
exercised through meetings between ministers and the
senior leaders of the Post Office; is that correct?
Yes.
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mean?
It's a really good question and a topic that is of live
discussion within Government. Post Office is currently
loss-making and has been since it was separated from
Royal Mail. The losses are at the moment worsening, so
I think, as a starting position, we would like to
stabilise the financial position of the company and then
take a view from there. But ministers have not yet
given a steer on that.
So financial sustainability reflecting not
an expectation of self-sufficiency, at least in the
short-term?
Not necessarily, no.
Do you consider that financial self-sufficiency, would
that be a realistic objective for the Post Office, given
the social function which it is required to perform by
the Department?
So I think you can separate out the two parts. You
could have a financially self-sufficient commercial
network, and then there are uneconomic branches which
the Government subsidises through the network subsidy.
You could take one view that that would be a sort of
mode of self-sufficiency where the Post Office is
funding the bits that are commercial and Government is
paying for the service that it delivered in the other
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In your statement, you suggest it's always been open to
ministers to exercise power and influence over the Post,
Office, and you cite the example of Baroness
Neville-Rolfe writing to the incoming Chair in September
2015, requesting that he prioritise getting to the
bottom of concerns about Horizon; is that right?
Yes, that is, yeah.
Ifall the necessary levers were available to ministers
to influence Post Office Management, what do you think
went wrong from a governance perspective in relation to
Horizon?
I wasn't involved at the time so my reflections are
based purely on sort of evidence that's been given to
this Inquiry. My understanding is that there was a lack
of transparency from the Post Office to the Government,
and within the Post Office to the Board, so that there
wasn't a widely shared understanding of what had gone
wrong and, where people did know that, that information
was not adequately shared with ministers or, indeed, in
‘some cases, my understanding is with the Board.
You say in your statement that a certain amount of
caution needs to be shown regarding the exercise of
those powers, hard and soft, by ministers; is that
right?
Yes, itis.
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Why is that?
Post Office, as other arm’s-length bodies, has a Board
that has fiduciary responsibilities to the company. We
try, as Government, to attract sort of qualified
individuals to be on that Board, and they are typically
people who have got a range of experiences and a range
of backgrounds. And the Board, I think, needs to feel
empowered to exercise oversight and exercise its
responsibilities in holding the company to account.
I think if there's too much interference from
Government, then the Board doesn't feel empowered to do
that and I think we would find it difficult to retain
people who have got the right skillset to join that.
Board. You know, it's a significant time commitment to
people.
That said, I think there is a lot of space for
ministers, as the shareholder of Post Office, to provide
their views to the Board and think, as with any
100 per cent single shareholder-owned company, the Board
should be willing to take a steer because the success of
the company should be closely aligned with what the
shareholder considers to be success.
We'll return to that particular point shortly but, in
your statement you say, as a matter of principle, the
shareholder should not involve itself in the operational
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I like to have a high level ~ like other Board members,
I like to have a high level understanding of what is
happening at an operational level because that is the
performance of the company. I don't involve myself in
operational matters, generally speaking, beyond those
that come to the whole Board.
In her evidence to the Inquiry, Amanda Burton, one of
your colleagues in the Post Office Board, stated that
you personally requested to be involved in overseeing
an investigation into a whistleblowing complaint made
against the CEO; is that correct?
Yes, itis.
Why was that?
Because I think that it's of interest to the
shareholder. The CEO is the most senior employee of the
company, he is a Board director. I think it is
appropriate that — and an appointee appointed by the
shareholder. The behaviour and conduct of the CEO
I think is a pertinent issue to the shareholder because
it impacts the culture of the organisation.
You say in your statement that a risk-averse culture has
developed in the Post Office, which you attribute,
I think at least in part, to the intense scrutiny of
this Inquiry and to the media; is that right?
Yes, itis.
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running of the business. That's a matter which should
be left to the Post Office's Board, and you've explained
the concern about the Board not feeling empowered.
Do you consider that the distinction between the
Government's policy objectives for the Post Office and
operational matters is one which is capable of being
maintained in practice?
Yes, I think it is capable of being maintained in
practice, although I think circumstances sometimes
require more intervention from the shareholder's point
of view and sometimes less intervention. And I think
that it is appropriate for the shareholder to provide
views where they feel very strongly on a matter of great
significance.
So for example, on culture, I personally think that
is a topic that is rightly for the shareholder because
itis integral to the running of the company. The
operational matters, actually, I think are more for the
Executive than for the Board. You know, the CEO is
accountable for the operations of the company and the
CEO is accountable to the Board.
In your role as Shareholder Non-Executive Director, how
do you determine whether and to what extent you should
involve yourself in operational matters concerning the
Post Office?
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Has the intervention by the shareholder and by its
representative Non-Executive Director been
a contributing factor, do you think, in the development
of that particular culture?
I think it's a good question. The shareholder provides
a very significant degree of scrutiny to Post Office,
particularly relating to funding requests, which I think
are rightly a matter for the shareholder. If the
shareholder has been asked for funds, then I think it is
completely legitimate that the Post Office has to
provide a business case, and scrutiny to that.
I actually don't think the shareholder intervenes
significantly outside of the processes that are set out
in the governance documents. So think, on the IT
programme, there's probably something in the idea that
there is a high level of scrutiny from the shareholder
and that has made people very conscious of the decisions
they're making ~ I think rightly so, when they're
spending public money. But I don't think the
shareholder has contributed more widely than that.
In terms of striking a balance between, on the one hand,
exercising effective oversight of the Post Office and,
on the other, affording its Board and management team
sufficient autonomy to make decisions, do you think that
you in your role as Shareholder Non-Executive Director
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are currently striking the right balance?
So I think part of the context for this question and
discussion is the ongoing and very frequent requests for
funding that have come from Post Office over the course
of the last two to three years into Government. As
I just described, I think it is entirely right and
proper that Government provides scrutiny to the spending
of what is ultimately taxpayers’ money.
I don't think —I think the Post Office gets a lot
of scrutiny from the Government in terms of its funding
plans and spending of taxpayers money. I think that,
outside of that, the shareholder and my -- sorry,
they're slightly distinct. The shareholder's
interventions are set out in the governance documents
and they are in line with the Government's governance
documents. I am a Non-Executive Director of the
company: I provide scrutiny, as any other Non-Executive
Director does, and not beyond that.
In your statement you acknowledge the frustration
expressed by some Board members about the level of
intervention by the Shareholder Non-Executive Director
in Board meetings. Have those sentiments prompted you
to reflect upon whether you are striking the right
balance currently in that role?
‘So my understanding is that those concerns were raised
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those principles need to be tailored. I'm happy to take
you to it, if that helps give it context.
Yeah, I'lljust find it, if that's all right.
It's page 15 of your statement, WITN11310100.
Yes, so I am very happy to expand on that. So I think
there are considerations for companies that are owned by
government that are a bit different to companies that
are privately held or listed companies, for example the
approach to settlement agreements with staff. So in the
public sector, arm's-length bodies do not have the
ability to make settlement agreements with staff, so
that is essentially reaching an agreement where you are
paying a member of staff to leave, and that is
a principle set out by Treasury, to ensure that public
funds are well used and to incentivise good management,
rather than exiting people out of the business without
having followed a process.
That is not typically done. Sorry, in commercial
organisations they typically have a freedom to reach
an agreement and pay someone to go. That is not a thing
that can happen in the public sector.
So that being one example of that tailoring?
Yeah.
Can you provide any specific examples in relation to
your interactions with the Post Office, where you think
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prior to my time joining the Board and that there are
not concerns, or I have not had concems reflected tome
or, as I understand it, to UKGI about my interventions
in meetings. That said, I can understand where the
question comes from, not least because the shareholder
representative is a proxy for the views of the
shareholder, and where the views of the shareholder are
pertinent to a decision that is being made, I think it
is helpful to have those reflected into the Board.
I think there's sometimes a little bit of confusion
between the extent to which the shareholder
representative is sort of making a decision themselves
or giving their own views, rather than being a conduit
for the -- or a sort of good proxy for the views of the
minister and I think that the views of the minister and
the shareholder are often a thing that is helpful for
the Board to hear, for them to understand how a proposal
they've got is likely to be received by the Department.
‘Speaking more generally about this governance issue, you
say at paragraph 31 of your statement that it's your
view that the principles that apply to purely commercial
companies need to be tailored to take account of the
policy considerations that underline publicly owned
assets. Can you please explain, insofar as you haven't
done so already, in precisely what way you considered
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those principles need tailoring?
I also think the remuneration would be another example
of that, I think. So remuneration in the public sector
is a matter of public record and ministers feel strongly
that those who serve in public corporations and for the
Government should have a sense of social purpose around
what they do as well, and remuneration rates are not as
high in the public sector in many instances as they are
in commercial organisations.
Do you consider that the issues relating to remuneration
have been a significant problem during your tenure as
Shareholder Non-Executive Director?
At Post Office, yes; when I was a NED at Sheffield
Forgemasters, no.
Why is that?
I think the issues relating to the Post Office CEO's —
the request for pay increases, are sort of well
documented and have attracted a lot of attention
Thank you. If I could move on, please, to ask some
brief questions about the mechanisms that exist in UKGI
for recording and reporting on risks relating to the
Post Office.
Could we please bring up the statement again at
page 15, paragraph 33, please. Thank you. This in
relation to UKGI's internal risk reporting. You say:
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“[This] provides a mechanism to identify, escalate
and manage risks faced by UKGI in exercising its
mandate. These risks predominantly relate to UKGI's
ability to provide sound advice to client departments
and for UKGI's Shareholder [Non-Executive Directors] and
Shareholder Teams to perform their roles effectively
These are not the same [you point out] as the risks
being faced by the Assets directly.”
Do you know why it is that risks faced by the
Government's assets, such as the Post Office, are not
captured in UKGI's internal risk registers?
Because they're captured elsewhere through different
processes. So Post Office -- the CEO of Post Office is,
in Government speak, an accountable person and the
accountable person reports their risk into the Principal
Accounting Officer, which is to say the Post Office
reports its risk into the shareholder, as in the
Department, and the Department's Board and Principal
Accounting Officer is ultimately responsible there.
And in UKGI the UKGI Board is responsible for UKGI's
risks and our operational risks, which are primarily
around things like resourcing, are we getting traction
with the Department, that kind of thing.
Given the supervisory nature of the role that UKGI
performs in relation to assets, such as the Post Office,
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-- by reporting issues of concerns identified as
a result of your daily interactions with the Post
Office; is that correct?
Yes, itis.
How do you judge whether an issue of operational
performance requires to be reported to the Department?
I think that's a really good question and ultimately
it's a matter of judgement and there are lots of things
that feed into one making a judgement call. There are
some things I - you know, the Department has got risk
appetite statements, right? There are some things that
it is very clear to me -- the Department has told me
that they are very concemed about, in terms of sort of
financial performance, budgets, that sort of things.
And then there will be other things that are of
particular concern to the Department for historical
reasons, or for other operational reasons.
For example, and I'm sure we may come on to this,
the discrepancies ~ the survey that was done by the
Inquiry, the YouGov survey, with the responses from
postmasters about how frequently they were experiencing
discrepancies. That is a great concern to the
Department. It's also of great concern to the Post
Office Board. You know, I raised it outside of the sort
of normal risk reporting process and talked to the
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do you think that risks relating to those assets ought
to be captured within UKGI's internal risk registers?
No, because I think that they are adequately dealt with,
and managed elsewhere. Now, we provide a lens into the
Department on Post Office's risks, and, you know, the
risk reporting, there is a formal element to it, and
then I, as a Board member, will also have a view,
because I sit on the Post Office ARC Committee, and
I will provide a sort of additional layer into the
Department, if I think there is anything that's not been
captured or I think there's anything that needs to have
their particular attention drawn to it
But that is the mechanism for doing it, rather than
through the UKGI Board because UKGI Board ultimately
don't have any levers over Post Office, right? The
levers sit with the shareholder, who is the Department.
You've mentioned the CEO's role as an accountable
person. Does it follow that from UKG''s perspective,
primary responsible for risk reporting in relation to
the Post Office rests with the CEO?
Yes.
But you've gone on to say, and you say in your
statement, that you and your team complement that risk
reporting —
Yes.
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Department about what they wanted to do about it.
Some of your risk reporting to the Department is
conducted formally in the presence of the Post Office
Executive, such as in the context of the quarterly
shareholder meetings; is that correct?
That's not our risk reporting: that is Post Office's
risk reporting to the Department.
But which you would complement in the context of those
meetings?
Probably not. I would probably talk to them outside of
the meetings.
I think, therefore, it follows that the bulk of your
risk reporting takes place in private meetings and
communications with the Department Director, Carl
Creswell -
Yes.
~ and the Director General, David Bickerton; is that
correct?
Indeed, yes.
Is there sufficient transparency, do you think, in the
reporting of risk by UKGI to the Department, insofar as
it concems the Post Office?
Yes. Absolutely. So we do a ~ currently our process
is we do a monthly note in addition to the -- so Post
Office do the quarterly shareholder meetings with the
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Department, my team do a monthly note, where we provide
any updates or any additional issues ~ that goes to
David Bickerton and to the Permanent Secretary and to
ministers -- and then I have conversations on top of
that, with David and with Carl.
I there's something particularly pertinent outside
of those meetings, I will send them -- you know, send
them an email -- yeah
Forgive me, you've answered the question with reference
to how those interactions are recorded —
Right.
-- and that's fair, I didn't clarify. But do you think
those interactions are sufficiently transparent to the
Post Office, and should they be?
In the vast majority of cases, I am not saying anything
to the Department that I wouldn't say to the Post
Office. That is not true in every case and nor should
it be true in every case because I am there to represent
the shareholder with a particular, you know, view of
what the shareholder is going to be interested in.
Do you think that those private channels of
communication with the Department risk undermining the
Post Office Board and the Senior Executive Team in their
governance and management of the Post Office?
No, I don't. Having said that I don't say anything,
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Carl Creswell almost every day about the Department's
risk appetite. This was about sort of formalising that
through risk appetite statements.
Is there or has there been a misalignment, in your view,
between the risk appetite of the company and the
Department?
No.
According to your statement, the review also recommended
that sources of risk assurance available to the Post
Office should be shared with the Department; is that
correct?
I don't recall that but, if that is true, then that is
true,
If we could just take a quick look, please, at page 19
of Ms Gratton’s statement. It's at paragraph 42.
Right, yeah.
So it's just that final sentence. Do you know what
reference is being made there, in terms of sources of
risk assurance within the Post Office?
I actually don't -- I can't recall what those sources.
would be. My best guess would be that it would be
internal audit type reports but I'm afraid I can't
provide any more information.
Do you know whether those are routinely shared with the
Department?
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though occasionally I do say things I wouldn't say to
Post Office, I almost always share my views very openly
with other Board colleagues. So perhaps not with the
management team but always with the other Board
colleagues.
You refer in your statement to a recent review of the
Department's risk reporting analysis by the Government
Internal Audit Agency. You say that the review made
a recommendation concerning the alignment of risk
appetite as between the Post Office and the Department;
is that correct?
Yes.
Can you please explain the basis on which that
recommendation was made?
The Government intemal Audit Agency are -- so the
findings of their report was that the relationship
works, effectively, and they did not have concerns at
a high level about the ~- us performing shareholder role
on behalf of the Department. They made a number of
recommendations that are quite administrative in nature,
around taking more notes of meetings, you know,
producing a document that says who does what, rather
than everybody just knowing who does what, and it was
the same thing on the risk appetite.
So I have a good understanding because I talked to
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They are not routinely shared with the Department, no.
The Department could ask to see them if they wished to.
Thank you. I'd like to move on then, please, to another
topic, this time concerning the composition of the Post
Office Board.
Yes.
The statement can come down, thank you, although it will
‘come back up shortly.
You discuss in your statement the contribution which
Mr Elliot Jacobs and Mr Saf Ismail have made as
Postmaster Non-Executive Directors of the Post Office
Board. I wonder if we could please just take a look at
page 39, paragraph 84, where you describe that
contribution which they've made. You say this:
“In my opinion, Mr Jacobs and Mr Ismail have added
a huge amount of value to the Board. They have changed
the nature of discussions at Board level and ensure that,
the actual experiences of post masters are heard. In my
experience they have been listened to, particularly when
discussing issues relating to how policies and practice
contained in Board papers will affect postmasters on the
ground."
If we could go over the page, please, you have given
an example there to ways in which they've made a valid
contribution. You say, at the end of paragraph 84:
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“Their perspective on this and other important
issues -- particularly those that affect {the Post
Office's] cost base, and therefore ultimately have
a significant affect on postmaster livelihoods -- has
been invaluable."
You go on in the following paragraph to discuss some
of the problems which have arisen from the appointment
of postmasters to the Post Office Board. You say there:
“There have plainly been some issues in the way in
which the Postmaster [Non-Executive Directors] have been
inducted and integrated onto the Board. There were also
occasions when [they] did not fully distinguish between
their role as Directors (with the fiduciary duties that
this entails) and their position as both active
postmasters and representatives of the wider postmaster
community.”
Can you please explain a little more clearly what
you mean by their failure fully to distinguish fully
between their role as Directors and their position as
postmasters and representatives of that community?
So as I say at the beginning of that section, I think
Elliot and Saf have added huge amounts of value to the
Post Office Board and they have genuinely changed —
I wasn't on Board before. My understanding is they
completely changed the dynamic in the Board room by
25
BEISO000753.
Thank you, the subject of the email is "Nick Read
Readout 29 February’. Is this is an example of the
quarterly shareholder meetings which we discussed
earlier?
No, it's not. It's a monthly meeting that the Minister
had with Nick Read and some other Post Office Executives
that myself and Carl would regularly attend.
Thank you. We see there list of attendees is: the Post
Office CEO; and you're there on behalf of UKGI; and as
you say, Mr Creswell is the Director of the Department.
This meeting comes shortly after the dismissal of the
Post Office Chair, Henry Staunton; is that correct?
Itis, yes.
We'll retum to that topic a little later, but that
provides relevant background to the discussion in this
meeting; is that right?
Yes.
Shortly after the meeting starts, we see you make the
following comment, so your first contribution is there
saying:
“Need as much support as you can get from Ben
Tidswell to try and get the Board functioning properly.
We need to try and find a way through the Project
Pineapple memo."
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bringing their perspective and lived experience as
postmasters to the discussion.
I touched earlier on Post Office's financial
position, which is not a healthy one. And the budget
discussions annually are very tricky in Post Office,
because the company is not able to pay postmasters as
much remuneration as it would like to because there are
insufficient funds available. And there are many
reasons for that, and, you know, potentially, had things
been done differently in the past, in terms of cost
saving measures, there may be more funds available now
but the situation now is what it is.
And I think occasionally, well certainly this year
in the budget discussions, I think Mr Ismail and
Mr Jacobs found the position really difficult to accept,
and I understand why they found it difficult to accept.
Itis, broadly speaking, not an acceptable position.
But as a director of the company, you need to ensure the
‘company continues to be a going concern and has
a balanced budget and I think they found that
interaction very difficult.
I'd like to ask you some questions about a meeting which
you attended with Minister Hollinrake on the 29 February
2024.
We have a readout of that meeting, please, at
26
The Project Pineapple memo was a reference to
concerns raised by both Postmaster Non-Executive
Directors about the prevailing culture within the Post
Office, which they perceived to be hostile to.
postmasters; is that correct?
I think that is part of it. That memo had been sent on,
I understand inadvertently, to the Group Executive
members by the CEO. So it had also had quotes of it
published in The Times. So the issue isn't just the
memo, they expressed legitimate concems. I think the
issue is that memo had been sent on to the people who
they referred to in the note, they had received that
note, and the note in part had been made public.
It had a really damaging impact on the relationship
between the Postmaster Non-Execs and the Executives in
the company. So, aside from the sort of completely
valid concerns that they are raising, it had caused
a huge amount of friction in the relationship between of
the Postmaster Non-Execs and the Executive Team.
What did you mean exactly when you said we need to try
to find a way through the memo?
There was, I think, a disagreement about who needed to
apologise to who between the Postmaster Non-Execs and
some of the Executive Team. It was a sort of very
unpleasant personal situation in which I think quite
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a few people felt quite upset about what had happened
and not just Saf and Elliot.
So are you saying there that your concems as
articulated there related to the manner, rather than the
substance, of the complaints
Yes,
-- that had been raised?
Yeah,
We can see a little further down a further discussion
about the role of the Postmaster Non-Executive
Directors. Nick Read, the CEO, says
“This goes back to whether the postmaster directors
are playing the role of a director, or of a trade union
rep. I don't know where that is going to go. They are
extremely exposed as a result of Project Pineapple. Not
sure how to patch this up. Ina slight stand off.”
You say:
“They are not in a good place and aren't operating
in a way appropriate for the business.”
One of the specific issues raised in the Project
Pineapple memo concerned the retention of employees
whose actions in relation to Horizon had been the
subject of criticism; is that fair?
Yes, it is.
Do you recall that being one of the issues raised?
29
that relates to aggressive behaviour reported to you as.
directed at Post Office staff?
Yes, and just to be really clear: this is a point in
time, right. This isn't my general view about Saf and
Elliot at all. They were under huge amounts of stress.
They'd had journalists outside their houses and were
getting an awful lot of criticism. And nobody is their
best when they are under stress and, at this particular
time, the relationship was quite tense and I think there
were a number of people who weren't behaving in a way
where, I think in hindsight, they wished they had.
But it is about this time. That is not my general
view, I have an awful lot of time for Elliot and Saf.
I think they've made a huge contribution
A little later in the meeting there's some discussion
about postmaster representation in the business. Please
can we turn to the second page of this readout, where we
can see that discussion, please, halfway down. So we
see a comment from the Minister which reads:
“In terms of other messaging, the mutualisation has
died down a bit.”
The CEO then comments:
“met on Monday. VOTP etc.”
Do you know what that's referring to?
Voice of the Postmaster.
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Yes, I think so, Yeah.
Did you share the postmasters’ concerns about the extent
of cultural change which had been achieved within the
Post Office by January 2024?
Yes, absolutely.
If you were sympathetic with the concerns raised by
Mr Jacobs and Mr Ismail, why did you not say so in this
meeting?
The discussion that is taking place in this meeting is
particularly around the relationship that they're having
with the Executive Team at the moment. So I mentioned
a couple of minutes ago about the budget discussions
that were really tense. There had been a meeting the
prior week, I think, where Saf and Elliot had met some
of the Finance Team and I understand the meeting had —
the Executives in that meeting had found the meeting
slightly distressing because of the approach that they
took in the meeting, and I don't think it is the role of
Non-Executive Directors to be aggressive and upsetting
to staff members.
So that is what this is about, rather than the
concems that they expressed in the memo. So it's about
behaviour rather than the memo itself.
So when you say that they “aren't operating in a way
appropriate for the business", it's your evidence that
30
“Their main point was about future of Post Office and
representation of postmasters. We are going to see some
governance work done by Grant Thornton in a few weeks’
time."
You say, or you're recorded as saying:
“I don't think postmaster oversight of the Board is
worth it. I think there's good mileage for more
postmaster input in the retail part of the business.”
Can you please explain your comments there?
So this looks like a verbatim note of the meeting. It
isn't: there is a lot of paraphrasing in this note and
I can't imagine I would have used the phrase “worth it"
because it's not the sort of thing I would have said.
However, I standing by the comments. So this is
referring to the NFSP’s proposal to have a sort of
parallel board, basically an oversight board of
postmasters -- made up of postmasters and other
stakeholders. I don't think that is the right way to
get postmaster engagement in Post Office.
An oversight board, by definition, on decision
makers, and I think you need postmasters involved in the
decision making, not just at Board level, which they
currently are but actually all the way down the business
at an operational level too, because the Board, by
definition, isn't operational
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So I think there should be, you know, some sort of
franchise-type council looking at the business side of
it, with products and services and marketing material,
and then I think there should also be postmaster
engagement and interaction in other areas that are
rightly areas of concem for postmasters. So they'd be
that in kind of decisions around discrepancies and
investigations, or whether or not, you know, the back
office systems are working correctly.
So I think you need it at all levels, not sort of
parked over there as a separate oversight Board.
I think if you want ~ if the idea of that is that the
Board is not working properly, you should get
a different Board, not create another one that's going
to have some more bureaucracy and process to it.
You referred to a proposal to establish a council within
the Post Office to provide input on operational matters?
Yes.
What practical steps have been taken to implement that
proposal, do you know?
So, the new management team are actually, like, taking
these ideas really seriously. So they've been holding
a series over the summer with Voice of the Postmaster,
NFSP and other representatives, and they've obviously
been attended, I've been to a couple of those sessions.
33
a kind of target operating model for UKGI of, like,
stuff we should be doing. So it's, broadly speaking,
making sure that the company has got good corporate
governance oversight. It sets out sort of activities,
basically, to be performed, that there are objectives
for the company, business plans in place, that the
corporate capability within the company is effective,
that the leadership within the company is effective,
that there's good relationships with the Department, and
then the sort of contribution of the Shareholder NED.
So it sort of sets out how we should be doing our
jobs.
Is it right that these -- I think you say these
principles provide guidance about the performance of
your role -—-
Yeah.
-- as UKGI NED on the Post Office Board. On the one
hand, they acknowledge that your duties are the same as
those of all the other directors on the Post Office
Board, and include the duty to promote the success of
the company; is that correct?
Yes, itis, yes.
On the other hand, they expect you, in your role as UKGI
NED, to act as an interlocutor between the shareholder
and the company, with a view to delivering the
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My understanding is that the proposals that are coming
out of that, whilst not finalised, are being taken
forward and will be implemented.
t'm sure we'll come on to the discrepancies and the
like light, but they are also working with
representatives from Voice of the Postmaster and NFSP to
look at the integrity of the current system, and to do
a review of the current system with a third party
provider, and those groups and other postmasters will be
involved, both in the terms of reference and sitting
alongside the people doing the work, to provide a view
and reassurance and input into that work. So it is
something that is very much live at the moment, and
change is being made.
Do you think those steps will be sufficient to make the
‘company more postmaster centric?
I think it's a place to start, and I think you've got to
start, see where you get to, iterate, and make it
better.
I'd like to move on to ask you some questions about your
role as the Non-Executive Director of the Post Office
Board. In your statement, you refer to UKGI's portfolio
operating at principles. Can you explain what these
are, please?
Yes, certainly. So it is a sort of, if you will, like
34
Department's policy objectives; is that fair?
Yes.
You say in your statement that this dual function does
not, in practice, present problems for you; is that
right?
That's my view, yes.
You suggest it's because it's in the Post Office's best
interests to comply with the shareholder's policy
objectives; is that fair?
That is why the Post Office exists, yes.
You say, in effect, if the Post Office fails to comply,
it will not receive the Government subsidy on which it
is currently reliant to remain as a going concern?
So there is a funding agreement that sets out that it
must meet the policy, which is not with UKGI, it's with
the Department -- that sets out they must meet the
policy objectives in order to receive the subsidy, yes
What if Post Office, as a commercial company, took the
view that its financial interests were best served by
foregoing the Government subsidy and relieving itself of
the social function, or the obligation it has to perform
social function; would there not then be a direct
conflict between the dual role you're performing?
can see that, in that situation, there would be. That
is not the situation in which we find ourselves. So I'm
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not saying there could never be a conflict. I am saying
that I have not experienced a conflict and that, at
UKGI, we've got a lot of training and support of how to
approach those conflicts, should they arise. But I have
not personally ~ you know, the situation you've
described is not one that is obtained.
We did discuss earlier on a situation in which the Post
Office might focus upon its commercial function and
a network that's capable of being financially
sustainable, and that's one in which you then saw the
Government subsidy as being tied specifically to those
aspects of the network which are not financially
self-sufficient. So do you not anticipate in the Post
Office's future that there could well be a direct
conflict in the dual role that you're performing?
No, I don’t because the policy framework is -- so
I think the Government announced on Monday, I think,
that they're doing a Green Paper, which will look at the
policy framework for Post Office and that the will be
the subject for a call for evidence, I would imagine,
and the Post Office will contribute to that,
And there will be a dialogue with Post Office
between the Post Office and the Government, about where
that will end up. It is not something that I anticipate
there being a conflict over, though, if there is, it
37
relates to the conduct of the Post Office's lawyers; is
that right?
Yes.
You describe being concerned about what you say was
a conventional legalistic approach that was adopted by
the Post Office's lawyers to the negotiation of
settlements with claimants; is that right?
Yes, and to be clear, that is Post Office's external
lawyers, rather than the people in Post Office.
What caused you to have those concerns?
So, at the Remediation Committee -- until quite
recently, Post Office's external lawyers attended the
Committee and they would give updates on various cases,
and some of those updates would involve -- they would
recount, to my mind -- sorry - having ~ disputing
relatively small amounts of money
‘And I just don't think that's the right way that
they should be approaching it. Both from a sort of
administrative point of view, I don't think Herbert
Smith spending time disputing a small amount of money is
a good use of taxpayers’ money but, much more.
importantly, that is a bad experience for claimants and,
in the scheme of things, it's just not a big deal, and
I think they should have been taking a less kind of
commercial approach to it, and much more of a sort of
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MS HODGE: Thank you.
Sir, that brings me to the end of that particular
topic, I wonder if now will be a convenient time to take
our first morning break?
SIR WYN WILLIAMS: By all means, yes. What time shall we
resume?
MS HODGE: Shall we resume at 11.05?
SIR WYN WILLIAMS: Yes, that's fine.
(10.53 am)
(A short break)
(11.05 am)
MS HODGE: Good moming, sir.
SIR WYN WILLIAMS: Good morning again.
MS HODGE: I'd like to move on to another topic, please,
concerning the Post Office's redress and compensation
schemes. Is it right that you and your team were not
directly involved in the administration of those schemes.
but, in your capacity as Non-Executive Director, you sit
on the Post Office's Remediation Committee which
oversees the administration of Post Office's redress and
compensation schemes?
A. Yes, that's exactly right.
Q._One of the concerns which you raise in your statement
about the administration of the Horizon Shortfall Scheme
38
benefit of the doubt, yes, within the parameters set out
within the scheme, but I just didn't think arguing over
small amounts of money is the right approach to take to
people who have suffered terrible harms at the hands of
the Post Office.
SIR WYN WILLIAMS: Can I just ask you, before we go any
further, was this attitude an attitude which was
prevailing in the administration of HSS or of OC, or
both?
A. [recall it being related to HSS —
SIR WYN WILLIAMS: Right.
A. —rather than OC.
SIR WYN WILLIAMS: Yes.
MS HODGE: When did that issue of focusing on, as you say,
‘small matters of detail first become apparent to you?
A. Ithas been apparent to me since I have been on the
Committee, and other Committee members felt similarly to
me that, you know, we should just be getting on with it,
not having an argument over £1,500, or whatever the
amount is.
@._ So think you said in your statement you shared your
concems with the Remediation Committee, and what you
appear to say is they agreed with you in relation to
those concerns; is that correct?
A. Yes, and shared them directly with the lawyers, because
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the lawyers are at the Committee. So this isn't a thing
that we were sort of talking about behind the lawyers’
backs, so to say: this is a thing I said directly to the
lawyers involved.
Do you feel that that message was getting across?
I am not convinced that the message was getting across.
I would like to -- well, why do you think that is,
firstly?
I think that some of the lawyers felt quite -- I think
they -- and this is speculation, right? I don't know
how they felt. My impression was they'd been very
involved in the development of the scheme and there was
a litle bit of a "This I just how commercial
negotiation is done, you don't understand” sort of
approach to it, whereas my point of view was, "This is
the Post Office, it is different. Your commercial
approach is not an appropriate one”,
Ordinarily, lawyers act on their instructions and, if
their instructions are to achieve a settlement and not
necessarily at the lowest figure that that settlement
might be achieved, then one would expect them to give
effect to that. Was the issue in relation to the
instructions that were being given or in the willingness
of the lawyers to give effect to them?
I don't know, to be honest. It was an issue that came
41
Well, that is a separate issue, in the sense that you
say in your statement that, in parallel with the
development of policy in relation to that, the Post
Office was separately developing a set of agreed
principles by which it planned to take forward
settlement of claims made under the Overturned
Convictions Scheme; do you recall that?
Yes, do you mean the Lord Dyson principles of ~ Early
Neutral Evaluation principles?
I think if I refer you to your statement, that may be
the easiest way?
Yeah, sorry, yeah.
If we could tum up, please, page 90.
You say when you started in your role, the Post
Office was piloting its remediation principles in the
assessment of pecuniary claims — this was under the
Overturned Convictions Scheme — and had shared a first
tranche of draft principles with claimant
representatives, and that your team had supported the
Department in its review of the draft principles and the
Post Office's proposed future ways of working.
You explain that:
“Under this new approach [the Post Office's] case
assessors would review claims received from claimants
and prepare offers consistent with the case principles
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up more than once at the Committee. I don't know
whether or not — my sense is that the approach
gradually changed but it was not the experience I was
expecting to have, which is: the Committee tells you to
do something, you go and do the thing.
Was the Committee supported by the Post Office Executive
Team in giving effect to that direction?
I think so. Certainly, Mr Recaldin at the Committee was
of a similar view. Actually, I don't know what happened
in terms of the sort of actual written instructions that
are then given to the lawyer.
You have answered a question just now from the Chair
about the Overturned Convictions Scheme and you've
explained your concems about the lawyers related
primarily to the Horizon Shortfall Scheme.
Yes.
But I would like to discuss with you some of the changes
that were made, during your tenure, to the Overturned
Convictions Scheme. You explain in your statement that
concems about the speed with which claims were being
resolved led the Post Office to adopt a different
approach based on agreed principles, rather than the
negotiated settlement approach that had been adopted
hereto; is that correct?
‘Are you referring to the 600,000 fixed payment?
42
agreed within the claimant representatives. The aim
[being] to reach settlement faster than had been
possible under the previous ‘negotiated’ approach, where
case principles had not been agreed [in advance] with
the claimant representatives."
So that was an initiative being taken, on the one
hand, by the Post Office; is that fair?
This started before my time on the Board. I joined the
Board in May and the adoption of the principles was
already kind of well in train by the time I started,
but -- so I don't know where it originated from, but,
yes, it was the process that was in train
In parallel with the development of that approach, a new
policy was developed by the Department for Business and
Trade to make a final settlement of £600,000 to
applicants under the scheme; is that correct?
Yes.
What did you understand to be the reasons for the
adoption of that new policy?
So the work on this was largely done by the Department.
There was some input from my team, not really from me
personally, but from people working to me. So I wasn't
close to it. My understanding is that it was meant to
provide a route for people who didn't want to go through
a process with Post Office. You know, people have
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suffered greatly at the hands of the Post Office, and
Ihave a lot of sympathy for claimants not wanting to
deal directly with the Post Office and go through a long
protracted process with them, because claims are taking
a very long time to process.
This was meant to be a much quicker way of resolving
those with less interaction, and enabled people to get
redress quicker, if that is what they felt was
appropriate for them. Now, if people still wanted to go
through the process, because they had a much higher
value claim, then that was still available but this was
meant to be a sort of alternative route to people to
give them access to quicker redress, if they thought
they had a lower claim or just wanted to get it done
quickly.
Was the decision to introduce the new settlement offer
driven by a desire to reduce the amount of money being
spent on legal fees associated with the settlement of
these claims?
No, so it wasn't driven by the desire to reduce the
amount of legal fees: it was done as an intention to be
a genuinely good thing for claimants to give people
an alternative. I think there is an effect where there
is a lower administration cost of the claim but that was
not the principal motivation behind it. It was meant to
45
informed by the need to ensure that public funds were
used responsibly?
Yes, but I think that that is the case with all spending
by all government-owned bodies. There is an obligation
on the Accounting Officer to ensure that the funds are
used responsibly.
Do you think it would be fair to say that the
introduction of this fixed-sum offer shifted the
goalposts for the Post Office, in terms of how it was
expected to approach the settlement of claims?
I mean, on one level, it's a very different approach,
yes, but I think that itis legitimate to have two
different routes to do this and to reiterate the
approach as you learn from what has happened in the
past. And my understanding is that the claims were
taking much, much longer to process than had initially
been anticipated and that the ratio of administrative
costs to amount of compensation paid out was not what
people had anticipated either, and that the experience
of postmasters was just not good enough.
And so this was meant to be a way to address some of
those concerns, primarily the experience of postmasters.
I think it's perfectly legitimate to have two different
ways of doing it.
Is there any merit, do you think, in the suggestion that
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be a thing that would be good for claimants
But it was anticipated, I think you say, that early
acceptance of a fixed-sum offer would bring savings, in
terms of avoiding the expense of disclosure and legal
advice associated with a more protracted settlement
process?
Yes, absolutely.
Did the anticipated reduction in legal spend, do you
know, affect the amount at which the offer was fixed?
I think that — this Inquiry heard at length from Sarah
Munby earlier in the week about the value for money
assessment for offers, and the like. I think there was
an amount sort of assumed to be for legal fees that was
included in the amount, with a view to making the value
for money case.
Were you aware of a sentiment within the Post Office
that it had, thus far, been working within a framework
which had been agreed with the Government, and which was
informed by a concern to ensure that public funds were
used responsibly?
Sorry, could you say that question again?
Were you aware of a sentiment within the Post Office,
and particularly with those responsible for remediation,
that they'd hitherto been working within a framework
which had been agreed with Government and which had been
46
the Post Office had, prior to the introduction of this
offer, been constrained in its ability to make generous
and decisive offers by the governance framework which it
agreed with the Government?
I think that there is almost always, with spending of
public funds, evidence required. I think that is
a legitimate thing when you're spending what is
ultimately taxpayers’ money. I don't think ~ the
anticipation wasn't that the process should stop Post
Office making generous and decisive offers to people.
Whether included in generous -- you know, was it quick
enough? No, absolutely not, and this was meant to be
a way to help make it quicker.
Thank you. II'd like to address a new topic, please,
which concems the governance of the programme to
replace Horizon, that's the programme we know is the New
Branch IT Programme. Now, you attended a meeting of the
Post Office Board in March 2023, shortly before you took
up your appointment as Non-Executive Director; is that
correct?
Yes.
At that meeting, you were attending as an observer; is
that right?
Yes.
One of the issues raised at the meeting related to cost
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increases in the programme; is that correct?
I believe so, yes.
Please could we look at the minutes of that meeting,
which bear the reference POLO0448789.
Thank you. So minutes of the Board meeting of
9 March 2023. If we could scroll down, please, to
page 4, we can see there agenda item number 3, relating
to the "Revised NBIT Forecast”. I'd like to look,
please, at the third paragraph, which reads as follows:
That would be Mr Mladenov; is that correct?
Yes, Zdravko, I don't know his surname.
Zdravko Mladenov:
[He] spoke to the Revised NBIT Forecast ... and
financials update, detailing the main drivers of the
costs increase."
Then it says "AC", that would be Alisdair Cameron;
is that right?
(No audible answer)
“... noted that the level of assurance being requested
from end to end was such that, if agreed to, the project
team would not be able to build at the same pace as.
currently, and a conversation on this needed to be had
with the shareholder.”
It then said:
49
I don't think I'd had briefings from the team in Post
Office yet, at this point. I didn't know much about it
at all, at this point.
From the briefings that you received, do you know what,
if any, oversight the Post Office Board and Shareholder
Team had had in relation to the procurement, the early
procurement, of the new system?
I know that there had been a proposal that had gone
through the Investment Committee, as was BEIS. I don't
know beyond that, I'm afraid.
You later attended a meeting with the Post Office
Minister in April, the following month, in which the
programme was discussed again. We have a readout of
that meeting at BEIS0000653, please. Thank you. This
the CEO's monthly meeting with the Minister on 18 April
2023. The principal issue raised by the CEO at this.
meeting concerned the decision of the Permanent
Secretary to withhold funding; is that correct, do you
recall?
Yeah, did you say this is April?
I think its 18 April.
Yes, I do recall, yeah.
Can you please explain the background to the decision to
withhold funding from the Post Office?
Yes, so Post Office is funded under -- well, it's now
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"ZP emphasised the need to have the right assurance
strategy which should focus on aspects of the project
that were particularly risky. ZM noted that a paper on
the NBIT assurance programme was due to come to the
28 March Board. ZP advised that it would be useful for
the Board to understand testing. ZM replied, detailing
the system testing and business acceptance testing.”
Was this the first occasion on which concerns about
the future viability and funding of the NBIT programme
were raised with you, or in your presence?
In my presence, yes. I had -- this was, I think, the
first Board meeting I attended, so I don't know whether
it had been discussed previously.
Had you received any prior briefing from your
predecessor, Tom Cooper, or from the Shareholder Team
about problems or concerns in relation to the NBIT
programme?
I cannot recall precisely. I very much imagine
Mr Cooper -- Mr Cooper held concerns. I imagine he
would have expressed those to me.
What was your perception at this stage in March 2023
about the seriousness of the issues being faced by the
programme?
I didn't have a good understanding of the programme. As
I say, this is the first meeting I had attended and
50
funded for many things. At the time, it was funded
under the subsidy control regime for the uneconomic part
of the network -- so they call that the network
subsidy ~ and also for investment funding. The
investment funding is dispersed from the Department
twice a year. I think it's 150 million quid each time,
I think, and the network funding is dispersed, I think,
quarterly.
The dispersal requires the approval of the Permanent
Secretary, and so, typically, my team writes the
submission that says, "Permanent Secretary, are you
happy to disperse the funds?", and gives them additional
context.
This was immediately after BEIS had been split up
into the Business Department and Energy Department and
Science Department, and so it was now a new Permanent
Secretary dealing with Post Office, so Post Office went
to the business department. It was now no longer Sarah
Munby who was Permanent Secretary and is now Gareth
Davies who is the Permanent Secretary. So this was the
first submission that had gone to Gareth Davies to say,
“Are you happy to release the network subsidy?"
The subsidy, as I mentioned previously, is the —
the sort of conditions for it are set out in a funding
agreement with Post Office, and it says a bunch of
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things that they have to do in order to release the
funding, the most sort of high profile of which are
maintain the Branch Network numbers, so the policy
obligations. There are also a number of other
conditions in the latter, such as have a three-year
business plan, have your budget approved, sort of thing,
Post Office didn't have a three-year business plan.
in place. In part, because their settlement from the
2021 spending review, which I think Sarah Munby talked
about, was lower than they had hoped, and they had found
it very difficult to put together a three-year plan.
Because the conditions for funding were technically
not met, the Permanent Secretary decided to withhold
funding.
You said that it was part of the role of your team to
put up the submission to the Permanent Secretary on the
funding issue; did that contain advice to the Permanent
Secretary to withhold funding?
No, it didn't
If we could look, please, at what the CEO had to say in
relation to the reasons why Post Office was experiencing
issues in relation to its funding. He said this, that
the main issues are, firstly, in relation to the Horizon
replacement, Post Office had underestimated the cost of
this; he referred also to Inquiry costs; and to
53
assurance for the funding request, in relation to the
Horizon replacement, and not just quality assurance
which is what you had seen thus far.
What quality assurance had been provided to UKGI at
this stage concerning the programme to replace Horizon?
I'm afraid I can't recall.
Thank you. If that could come down, please.
You attend a further meeting of the Post Office
Board on 5 July 2023. This is the meeting at which
whistleblowing allegations concerning the management of
the NBIT programme are raised by the CEO and in which
it's acknowledged that there is a need for a better
governance of the programme; is that fair?
That is fair, yes
I wonder if we could look, please, at the minutes of
that meeting. They are POLO0448509. Thank you. If we
could scroll down, please, and on to the second page.
So the agenda item is "Speak-Up", reference to the Post
Office's whistleblowing policy, and concerns which had
been raised under that policy relating to NBIT. You
received in that meeting a detailed update from the CEO
relating to the concerns and complaints raised by the
whistleblower.
By this stage in early July, what was your
perception as to the seriousness of the issues facing
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compensation.
In the paragraph that follows you're recording as
saying that:
*... UKGI and [Department] officials are working
together to provide the reassurance to the [Permanent
Secretary] about cost controls.”
Is that a reference to cost controls specifically in
relation to the NBIT programme or more generally?
The permanent — so just to provide a little bit of
context, the Permanent Secretary was completely new to
Post Office, and I think was surprised at the degree of,
welll call it out of cycle funding, so funding that was
being asked for by Post Office, outside the usual
process. The usual process is spending reviews done
every one, two, three years, or whatever, by Treasury.
Post Office was making a significant number of
requests for funding out side of that process. That is
very unusual, in a Government context ~ itis very
unusual, in a Government context. The Permanent
Secretary, I think, was very surprised by that and it
had led him to take the view that Post Office did not
have adequate control on its cost base.
Thank you. If we could go over the page, please. So at
the top there, still on the issue of funding, you're
recorded as saying that UKGI needed cost and time
54
the programme?
My recollection is that I, ike many of the other Board
members, thought the programme had extremely serious
problems with it. I think the updated cost estimate was
sort of multiples of the previous cost estimate, and the
team were very, very clearly concerned about their
ability to deliver to the timeline that had been set
out. So, yes, I think it's fair to say I and others
were extremely concerned.
Thank you. If we could just look, please, at the bottom
of page 2. So we see there, in the final paragraph,
a recognition that there was a need to establish better
governance across the programme, and a proposal by the
Chair which is said to have been discussed with another
member of the Board concerning the establishment of
anew committee, a Board committee, which would include
within its ambit responsibility for overseeing the NBIT
programme.
Is it right that you say that was your proposal or
a proposal that originated in UKGI?
So my predecessor on the Board had been — my
understanding is, had advocated for that, the
introduction of that committee. He'd not got any
traction, my understanding is, with the company on
introducing that committee. At this point, the
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committee was introduced, yes.
Do you think there's merit in the suggestion that the
Board's approach to that issue was rather reactive, that
is to say no action was taken to address the governance
issues in relation to the programme until this
particular complaint was raised?
I do think that's fair, although, from the complaint and
the subsequent pieces of assurance that have been done
on the programme, the governance issues are -- you know,
the oversight of the Board is not the only governance
issue. In the programme, my understanding is there were
issues right the way down the programme, in terms of
governance, so setting up an Investment Committee,
whilst a helpful step, was definitely not going to be
a panacea.
But it was something which you say that UKGI was
campaigning for ~
Yes.
-- so far as you were aware, at least prior to --
Yes.
-- your appointment.
Yes.
You're recorded in the minutes of the meeting as saying
that you considered it was sensible to pause on NBIT
with no regret activity continuing. Can you explain
57
meeting ~
Yes.
-- about the complaint?
Yes.
So that's, please, UKGI00049035.
Just before we come to that email, I asked you
earlier in your evidence whether you thought it was fair
to characterise the response to issues in the programme
as reactive, and you said you didn't think that was
an unfair characterisation in the circumstances. Were
you concerned that the very serious issues with the
programme that were identified in that complaint had not
reached the Board via normal reporting channels?
Yes. So, on one hand, it is a positive thing, I think,
that whoever the whistleblower was in this circumstance
came forward and felt able to use the Post Office's
processes to make a complaint, and that complaint was
taken seriously. On the other hand, the fact it has to
come through a whistleblowing complaint, rather than
being picked up through the normal course of business
with people being able to sort of speak to each other
and address concems openly, does not reflect well
From what you understood about the complaint, why do you
think it was that it ended up reaching the Board in that
way?
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what you mean by that, please?
When they were doing the programme, there was sort of
a view that there was some activity that would have to
carry on if the programme was to be able to deliver to
its timeline, but there was some other activity that
could be delayed/picked up at a later date. It was with
a view to giving the programme some space to reconsider
what it was it actually needed to do, whilst not
impacting significantly on the timeline for delivery.
What did you understand to be the dividing line between
those activities which were necessary to continue and
those which could be parked?
That is a question for the Executive Team, rather than
for me.
You wrote an email to the colleagues in the Department
the same day, informing them about this particular
complaint; is that correct?
I think it was after the complaint. I think the ~- the
email is relating to the complaint, isn't it?
Forgive me?
I think the email is relating to the complaint, isn’t
it?
Raising an email —
Yeah, raising, yeah
~ off the back of what you had learned in the Board
58
I don't know, I'm afraid.
If we could look, please, at your email, so this is to
Mr Bickerton and Mr Creswell in the Department. You say
you're writing to make them aware of a short notice
Board meeting that was held earlier that morning,
following an extensive complaint made under the
whistleblowing process. I think you said earlier in
your evidence this would be a good example of you
exercising your judgement to draw to the attention of
the Department what is, on the face of it,
an operational matter but one which you think is
sufficiently serious to draw to their attention —
Yes.
~ on this occasion because it related to a programme
which affected the future viability of the network?
Annumber of reasons. There's obviously a long and very
difficult history with Horizon, replacing it is
a priority for Post Office and for Government. This
called into question the programme to be able to do
that. There was also a very significant funding request
in from the Post Office to continue with the programme.
I think it's quite difficult to fund a programme fully,
that -- you know, to fully fund the request when you've
been told there's an awful lot of problems with the
programme. So I think it's pertinent on two levels.
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Q. You recalled that the complaint is quite wide-ranging
but primarily related to the NBIT programme, alleging
incompetent management of the programme, poor governance
and misleading information being given to the Board.
You point out it also made a wide range of conduct and
behaviour allegations against senior members of staff.
You go on to say that the CEO of the Post Office has
outlined a number of changes that he's proposing to make
to the NBIT program, the first of which is the
commissioning of a review by KPMG and Accenture.
Just pausing there, were you aware of any concerns
about the role of Accenture?
A. It’s a very good question, I was not as aware as I would
have liked to have been, in hindsight, about the role of
Accenture. So Accenture were involved in the programme;
they were providing contractors into the programme. My
understanding at the point at which this is commissioned
is that those contractors were quite junior people and,
you know, there are some people but it's not a big deal.
My subsequent understanding is that Accenture were
much more involved in the programme than I had
previously understood. So I think there's a good
question about whether or not a review done by Accenture
is appropriate, given that they are also contributing
staff to the programme, like how independent they could
61
Q._ So you say, in addition to that external review and
assessment of the programme, the CEO is proposing to
hire a new Transformation Director to oversee the
programme and, of course, you refer to the introduction
of the new Board committee, a request that you say, "We,
UKGI, made of the company’,
Finally
“A pause (reduction to minimal progressino regrets
on the activity) on the programme whilst this is
underway."
You say this:
“To note there are a number of other similar
whistleblowing allegations relating to the programme.
I think the changes Nick is proposing to make are
sensible (and long overdue).”
Bearing in mind that you were obviously first aware
of issues in relation to the programme in early March,
albeit you said at that stage your understanding of
them, I think, was quite limited, you were not yet in
post as Non-Executive Director, why do you say there
that you considered those particular changes to be long
overdue?
A. So this is particularly on the hiring of anew
Transformation Director. So when I started on the Board
or when I was first being an observer on the Board, Post
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really be.
At this stage, I think it's fair to say you see the
appointment of Accenture as a positive thing in
providing assurance?
Yes.
What you're saying now is perhaps that assurance wasn't
as concrete as you initially appreciated because of
their prior and ongoing involvement?
So Accenture, I am sure, would say, and say in their
report, that it's a different bit of the business but
I think that it is good practice to have a genuinely
independent third-party doing insurance.
You've explained just now in your evidence that your
understanding of the scope of their role then was not as
detailed as it is now. Hows it that you've come to
have a more fuller understanding of the extent of their
involvement?
can't recall. It must have been through discussion
with somebody who was in the company who, you know, told
me. I can't remember.
Do you consider there was a failure of reporting to you
in relation to Accenture and the role they were being
asked to perform?
I think the role of Accenture was probably underplayed
when it was described to the Board.
62
Office was running the programme to replace Horizon and
introduce new branch technology as two separate parts,
So they were treating the build of the new operating
system for postmasters as distinct from the rollout of
that technology into branches.
And, to my mind, it was quite a strange thing to do
to treat them as different things, and the NBIT
programme, my understanding is, it was quite isolated
from the rest of the business, and it wasn't being kind
of well integrated and treating this as an opportunity
to sort of transform the business, make it easier to put
products on to the system, and, you know, set the Post
Office up for future success. It was being treated as
a sort of IT project.
My understanding is that the hiring of the
Transformation Director would sort of bring that
together. So, yes, I do think it was the thing that -
I am surprised it was run like that in the first place.
Now, in relation to that new Board committee, which
became the Investment Committee, it held its inaugural
meeting in or around late October of 2023; is that
correct?
I don't recall. If that is what you say. I'm slightly
surprised it's not until October but that may be the
case.
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Q. Well, there's a reference in the Post Office Board
minutes to its inaugural meeting, which appears to date
it to October but we can look into that. You say, in
relation to the work of that committee, you're conscious
and acknowledge frustrations being expressed by members
of the committee about the level of assurance that the
shareholder or you, as shareholder representative, are
seeking on behalf of the shareholder in relation to that
particular programme; is that correct?
Sort of. Itis not me seeking the assurance. It is the
shareholder seeking the assurance. I am relaying what
the shareholder is going to require, which is a bit
different, right? I'm not inventing the level of
assurance that they need themselves. This is what the
shareholder is going to require because of the level of
public funds that are being spent.
Is it purely level of public funds or is there wider
concems about the role of this new platform in
replacing Horizon?
So I don't think there is concerns about the role of the
new platform. You know, the idea was is that the new
branch technology, like, should equip postmasters with
the tools to offer customers and communities the best
service. I don't think anyone disputed that at all
Government funded projects, when they reach a certain
65
Firstly, everybody in Post Office is acutely aware of
the history of Horizon and is determined to undertake
all the assurance necessary to ~ in order to ensure
that the system is robust, right? The people developing
it are absolutely adamant that it needs to work, and not
suffer from the bugs and defects that have previously
been present in Horizon. So I think everybody is sort
of on board with that.
In terms of the sort of wider assurance ~ sorry
I've forgotten the question that you asked me that led
me to think I had two things to say.
Well, broadly speaking, the question was whether you had
concems, bearing in mind what was said about the
onerousness of the assurance being sought as to the Post
Office's attitude to this particular programme and
whether it was repeating the mistakes of the past?
So I don't think that they were ~ so I don't think they
were concerned or expressing concems about assurance to.
make sure the system worked. I think everybody wanted
assurance to make sure that the system worked. I think
they were expressing concerns about what they saw to be
additional Government processes, so for example,
enrolling on to the Government Major Projects Programme
thing, and the interventions of a thing called the
Infrastructure Products Authority, which is a bit of
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level of funding required, or are particularly
contentious or novel, have to go through a thing called
the Government's Major Projects Process and that is true
across the whole public sector. And the scale of this
programme meant that it was going to have to go through
that process.
And so that it's not just a sort of "Are you
spending the money well’; its "Is the programme going
to do what it says it’s going to do? Is it going to
work as well?"
Is it going to deliver -
Yeah, on the objective, yeah.
~on the objective.
We saw in that Board meeting in March, where issues
were first raised in your presence about concerns in
relation to the programme, that the level of assurance
being sought was said to be something that was placing
a particularly onerous financial burden on the Post
Office.
Mm-hm.
Do you have concerns about whether or not the mistakes
that were made in the past, in relation to Horizon have
been or are being repeated in relation to the Post
Office handling of this particular programme?
So I think there's sort of two answers to that.
66
Cabinet Office that kind of gets involved when there are
big projects.
I think they saw that aspect of it as intrusive into
Post Office's plans. My personal view is that that has
been shown to have added quite a lot of value, because
not only is it the right thing to do where taxpayers
money is being spent but it has been demonstrated to add
quite a lot of money as the new management team are
rethinking the approach to the NBIT replacement and are
not sure that the plan that is under discussion here is
going to be taken forward in its current form.
Forgive me, can you repeat that? You're not sure that
the plan --
So I think the current CEO ~ Acting CEO of Post Office
has sent a message to all Post Office staff to say that
they are reviewing the current approach to NBIT, that
the objective of providing postmasters with tools to
offer customers and communities the best service remains
the same but they are reassessing the way in which they
are going to deliver that objective.
In your statement, you make some concluding remarks
about the programme. I can bring those up for you if
that would assist, but you say this: that providing
a replacement for Horizon that is effective and
reliable, and which meets the Government's requirements
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for the level of public funding that it requires,
I think you say, remains a highly challenging task.
Yes.
Can you just explain what you mean by the Government's
requirements for the level of public funding that it
requires?
So Post Office, as I sort of mentioned earlier, is not
cash generative, right? It loses money every year and
is a going concern because the Government provides
annual support. Post Office does not have its own funds
available to pay for the replacement of the in-branch
technology. It is going to be wholly funded by the
taxpayer. That funding is at a level at which it is
well past the Department's delegated authority. It is
going to Treasury for approval. And Treasury take
a view on the amount of money that they spend on
programmes, and that is related to how much money the
programme requires to deliver, but there are, in all
cases, cheaper, more expensive ways of meeting
objectives.
What do you consider the relationship to be between
ensuring that the replacement for Horizon is reliable,
and that the funding requirements of the Government are
met?
So absolutely nobody is making a trade-off about cost
69
please. The first relating to the dismissal of
Mr Staunton, former Chair of Post Office. That's
a topic which has been covered at some length already in
this Inquiry but one in which you had some direct
personal involvement and, therefore, I'd like to briefly
touch upon it with you now.
I think it's fair to say that you had a number of
concems about the conduct of the former Chair of the
Post Office, those related first to his attitude to
whistleblowing complaints that were made against other
staff at the Post Office, and you cite the example of
the whistleblowing complaint concerning NBIT, which we
discussed a short time ago, and whether that was taken
sufficiently seriously at the time by the Chair.
Secondly, you describe having concerns about
whistleblowing complaint which included allegations of
the use of racist and misogynistic language by the chair
himself; is that correct?
Yes, that's correct.
Sorry, I'm conscious you're nodding but it's purely for
the transcript. Thank you.
Yes.
You say in your statement that you had personally
experienced dismissive conduct from the Chair; is that
correct?
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and reliability on the system. To be completely clear,
there are lots of decisions about whether you employ
Post Office staff in-house to do it, whether you have
contractors who are on day rates to do it. Sort of
there is probably a bit of a trade-off between speed and
time as well: delivering something faster often costs
more money than delivering something at a slower pace.
So nobody is questioning the fact you need
a completely reliable system for the Post Office's IT.
That is not what the cost is about at all.
Ms HODGE: Thank you.
Sir, that brings me to the end of that particular
topic. What I would propose is another short break of
ten minutes. I anticipate I will be finished with
Ms Gratton shortly after that, and then there will be
some questions from Core Participants to follow.
SIR WYN WILLIAMS: All right. So resuming at 12.10?
MS HODGE: I think that would be fine, sir. Thank you.
(11.56 am)
(A short break)
(12.10 pm)
MS HODGE: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: I can. Thank you.
MS HODGE: Thank you
I have two further fairly brief topics to cover,
70
A. Yes, that's correct.
Q. That complaint, of course, was subject of an independent
investigation, which concluded after the Chair's
dismissal.
I think the third area of concern related to the
procedure for the appointment of a new Senior
Independent Director - is that right —
A. Yes
Q. particularly around irregularities in the procedure
that was undertaken in relation to that appointment?
A. Yes.
Q._ What I want to ask you is whether your concerns about
that appointment process were ones of form or of
substance, or indeed of both?
‘A. My concems were ~ sorry, by "substance" do you mean by
the appointment of Andrew Darfoor as the Senior
Independent Director?
Q. Forgive me, I should have explained. Perhaps not in
relation to him personally, but is it right that you had
earlier expressed a preference for a female Board member
to be appointed and one, in particular, with Whitehall
experience; is that correct?
A. So there's two things there. My preference as
a Non-Exec Director was that the Board should be more
representative of the community that the Post Office
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serves. So it currently has two female Board members,
of which I am one. So as a NED of the Post Office, yes,
I thought we should have a more diverse Board. But the
second part of that, of having a Non-Executive Director,
in this case, the SID, who had public sector experience,
was a view from the shareholder which I shared, rather
than just my personal view.
‘And which you communicated to the Board?
Yes, and to Mr Staunton.
Sorry. So my question was then: was your concern about
the approach that Mr Staunton had taken to the
appointment of Mr Darfoor one purely of form, that is to
say the procedure that was adopted, or one of substance?
It was about the procedure. I think there could have
been a sort of open discussion about the substance of
it. As it was, there wasn't.
You say in your statement that you considered that the
Chair's behaviour had, by late December/early January,
become increasingly erratic and conceming to you?
I think what I say in my statement is that it was
described like that by members of the Executive Team,
I think.
We can have a look but I think you say that was
a concem that was shared?
Yes, sorry, yes. It wasn't just my view, I think, is
73
operation of Horizon and the recovery of shortfalls?
(The witness nodded)
The Inquiry has heard evidence that this is a matter
that has been discussed at Board level -
(The witness nodded)
-- most recently on 24 September this year; is that
correct?
Actually, most recently, Tuesday of this week, where
there was an additional Board but, yes, it was also
discussed in September.
Can you give us an indication, in relation to the most
recent discussion, what the Board's doing about this
issue: what action has been taken to address it, please?
Yes, absolutely. I think I've touched on some of it in
previous things I've said. So with relation
particularly to the discrepancies point, and postmasters
continuing to experience discrepancies, the Post Office
Exec are in the process of appointing an independent
review, a third-party review, of Horizon and its
robustness. And they're in discussions with Voice of
the Postmaster and NFSP about the terms of reference for
that and how those groups are going to be involved in
the process.
So it's not going to be sort of a sign off the terms
of reference, get the product at the end, it’s going to
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the -- yeah.
Itwas a concem that was shared by your colleagues on
the Board as well; is that correct?
Yes.
The existing Senior Independent Director and Ms Burton?
Yes, it was, yes.
Those concerns culminated in a meeting between
Mr Tidswell, the SID, and Mr Creswell; is that correct?
Itwas a phone call, but yes.
Forgive me, a discussion ~
Yes, yeah
~ about his concems, and in a submission jointly
authored by you and Mr Creswell to the Secretary of
State, in which you recommended that she exercise her
powers to dismiss the Chair; is that right?
Yes, that he was removed from the Board. Yes.
Beyond that short summary, is there anything further you
wish to say on the topic of the Chair's dismissal?
No, I think that is an accurate reflection of what
happened.
Thank you. The final topic then, please, concems the
recent survey commissioned by the Inquiry and undertaken
by YouGov of current serving postmasters, and the high
levels of dissatisfaction expressed in that survey by
the postmasters on a variety of issues, including the
74
be involvement throughout, with a view to providing —
they are then planning on publishing it, so making it
sort of fully available to whoever wants to see it
They're also planning as part of that, inviting
postmasters -- and I think they might have already done
it~ into the Chesterfield operation centre, which is
run by Mel Park, who has also given evidence, so they
can be completely transparent on what the various stages
of, like, operational process management is for where
there are discrepancies, so that they are transparent on
that,
They also plan on publishing quite a lot more
evidence -- sorry, evidence is the wrong word —
information about Horizon. They've got a lot of it in
terms of uptime and bugs, and whatever, they plan on
making more of that available as well. The Board is
very supportive of that.
I also mentioned earlier the plan to get postmasters
more involved in the various bits of the business. That
is still more of a work in progress as to where it's
actually going to sort of finally land, but it is
a piece of work that is getting taken forward with a lot
of vigour.
Is this particular issue, namely ongoing concerns by
postmasters about the reliability of Horizon, one which
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you've escalated to the Department as part of your risk
reporting in relation to Post Office?
‘A. Yes, absolutely. They are concerned -- I am concerned.
The Board generally and the Executive Team are
concemed.
MS HODGE: Thank you, I've no further questions
THE WITNESS: Thank you.
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Before we ask Core Participants to ask
their questions, can I just take that latter point
alittle further? What I mean by that is the query
about the reliability of Horizon
You are probably aware, Ms Gratton, that I've heard
evidence in recent weeks about what might be thought to
be a degree of conflict between Fujitsu and the Post
Office in relation to the reliability of the current
version of Horizon and, allied to that, to what extent,
if at all, reliance should be placed upon it in
recovering what appear to be -- and I use the words
“appear to be" very advisedly, as you guessed ~
shortfalls and/or taking action against postmasters,
either to recover shortfalls or to report them to the
police.
Where has the Board got in relation to that, if
I can have an update from you, this time wearing your
77
that the Chairman has met with Fujitsu with a view to
discussing the extension of the Horizon contract
post-March '25. My understanding is that there is some
nuance in Fujitsu's position, whereby they do not want
the data to be used for criminal convictions, but they
are not questioning the integrity of the data within the
system, is my understanding from Post Office's IT
people.
SIR WYN WILLIAMS: Right. So that we don't confuse what you
might have been told perfectly in good faith with the
formality, so to speak, has the Post Office Board
discussed this in the last few weeks?
A. Notin the last few weeks. It has been discussed at
Board meetings through oral updates from the as-was
Acting CEO over the summer, and that is the position
that he outlined to the Board
SIR WYN WILLIAMS: Okay, right, fine. Thank you.
Right, over to the Core Participants.
MR JACOBS: Hello, I'm waiting for my microphone to come on.
SIR WYN WILLIAMS: You're stil very indistinct Mr Jacobs.
MR JACOBS: Ah, that's better thank you very much. I should
have known that I have to press a button. Sorry about
that.
Questioned by MR JACOBS
MR JACOBS: Ms Gratton, I'l start again. I represent
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Post Office Director hat, as opposed to what you might
be telling the Department.
A. So in terms of where the Post Office has got to with
Fujitsu on the system reliability issue?
SIR WYN WILLIAMS: Well, all of those issues, if you can
bring me up to date on them.
A So-
SIR WYN WILLIAMS: Let's start with what I understand to be
the position and then you tell me if there’s any
alteration, that, as of today, so to speak, or the last
time I heard evidence, the Post Office was not seeking
to recover apparent shortfalls from postmasters; is that
still the position?
A. That there is no civil recovery and my understanding is
that there is no passing of information to the police on
the basis of shortfalls, so no.
SIR WYN WILLIAMS: Right. So that answers the second part
of the question relating to prosecutions.
So far as the reliability of Horizon, as debated
between Post Office and Fujitsu, we'll hear from
Mr Patterson on Monday, but from your perspective, is
there simply an impasse in the sense that there was the
exchange of letters in the summer, and nothing further
has happened, or has something further happened?
A. I'm not sure if anything further has happened. I know
78
a large number of subpostmasters and assistants, who
were affected by the Horizon scandal
I want to ask you about the hard powers of
ministerial intervention that you detail in your
statement. So can we just turn to paragraph 27 of your
statement, and that's WITN11310100, and it's page 12 of
103.
Looking at that whole paragraph, you say:
“There are several ways in which the Secretary of
State and ministers at DBT can and do intervene in [Post
Office's] governance and management. Most directly, the
Secretary of State has the power under the Articles of
Association to dismiss the Chair of the [Post Office]
Board and [the Post Office] Directors (including the
Executive Directors) ..."
Then you cite the relevant part of the Articles of
Association. Now, that is what I think witnesses have
called the nuclear option, and that was in place during
the course of the events that the Inquiry is
considering; is that right?
I actually don't know the answer that, sorry.
No, you weren't there at the time, of course.
No.
Take it from me then, there's been evidence to say that
was right.
prop
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Moving on to what you also say, if we could look at
the seventh or the eighth line down, where it says, "The
revised Articles of Association also allow the Secretary
of State to give directions to POL"; can you see that
there?
Yeah,
which require POL to 'take all steps within its
power to do what those directions require to be done’.”
That is Article 7(F) of the revised Articles of
Association.
Now, I'm going to ask you a question that you may or
may not be able to answer because I know that you have
with UKGI since 2021
(The witness nodded)
But were involved with the Post Office since, I think,
May 2022?
So I've been involved with the Post Office probably
since February '23, when my predecessor was ~ it was
announced my predecessor was stepping down. So I had
a handover period.
Yes, and the revised Articles were amended on
14 December 2022?
(The witness nodded)
So a few months before you came to Post Office?
Yes.
81
a difference, it appears, between the nuclear option,
which is sacking and dismissing the Board, and
reappointing another Board and intervening directly and
taking control, and the power to issue a direction to
the Board or to an individual to say this is what Post
Office has to do because the Government is concemed
that mistakes of the past are about to be repeated. Do
you see that the second option is a more practical way
of getting a result quickly, rather than a nuclear way
of dismissing everybody?
Yes, I can see why you might think that. In practice,
my instinct would be that if you are on a Board where
you find yourself being directed, you may think that
you're not aligned with the shareholder.
Do you think, in light of the issues that this Inquiry
is looking at, and the scandal and the terrible effect
that it has had on the lives of so many people, that
this direction is a useful way by which the shareholder
can short-circuit matters, if it thinks that history is.
about to repeat itself?
It could be, yes.
At about 10.25 this morning, you were asked about
reporting operational matters up to the DBT, and you
said there were some things that the Department is very
concemed about, and you spoke about financial
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But did you know when you joined, were you told what the
provenance of these Articles is: was this inserted as
a result of the scandal, as a result of the Fraser
judgments, or the decision of the Court of Appeal in
Hamilton & Others?
I'm afraid I don't know.
You don't know. Okay. Well, I'll move on. You say in
your statement that, to your knowledge, this power, this
power to give directions, hasn't been exercised
We can take that down now from the screen. Thank
you.
Do you know under what circumstances the power would
be exercised or could be exercised?
On one level, that is a decision for ministers and they
could choose to exercise it when they wish: they are the
shareholder. In practice, I think they probably take
the view that directing organisations and people to do
things isn't conducive to a productive working
relationship. So I would imagine, in practice, they
would, as you have sort of called it, see that as
a nuclear option and, if you are in a position as
a Secretary of State where you find yourself directing
a Board, you may want to consider whether or not you
have the right people on that Board.
What I really wanted to ask you is: there's
82
performance and budgets, and you gave an example of the
YouGov survey.
(The witness nodded)
Is that the sort of thing that could be the subject of
a direction, if not properly resolved?
So in theory, yes. But I sort of come back to the idea
that the Board is appointed by the shareholder. As the
shareholder, you would aspire to appoint people who have
a shared understanding of the organisation's objectives
as the shareholder -- the shared understanding with the
shareholder of the organisation's objectives. So
I would hope that you would ~ that we wouldn't find
ourselves there because there is a sufficient dialogue
and sort of common understanding between the shareholder
and the Board
So I think what you're saying is that the direction
would be given reluctantly and as a matter of last
resort?
Yes, that, I think ~ I think that is how the power is
intended to be used.
Is there any guidance around the use of this power to
give a direction or is it entirely a matter of
discretion?
Ihave not seen any guidance. It is the sort of thing
that, were a Secretary of State minded to do so, they
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would expect to receive advice on prior to doing so from
their officials.
Do you think there should be guidance, so that the
position can be clear as to the use of this power?
Potentially, although I would imagine that the specifics
of the situation would be quite relevant to whether or
not it was used
You've been referred today in your evidence to some
concems that Mr Jacobs and Mr Ismail raised about
retention of employees, whose actions had been subject
to criticism,
(The witness nodded)
That is a point for many of our clients, if not all of
them. Another point of concern, which you've also been
referred to, is the YouGov survey, where 92 per cent of
the 1,000 subpostmasters who responded said that they'd
experienced issues with Horizon in the last 12 months.
98 per cent of those who reported shortfalls said that
the most common resolution was to use branch money or
resolve it themselves. These are serious matters,
aren't they?
I absolutely agree, yes.
Do you think that if they continued, escalated, weren't
resolved, that the direction could be used to prompt
Post Office in the right direction?
85
So my team and I write a lot of advice that goes to
ministers. In practice, all of the instances of that
that I have experienced seen in this -- since being in
this role have been done effectively jointly with the
Department, so that advice has gone through Carl
Creswell and David Bickerton. Where there is
a difference of views between somebody in the Department
and someone in UKGI, that has been noted in the
submission but I have never found myself in a position
where I have had such a violent disagreement with the
Department that I have felt the need to put up advice
aside from their process.
Do you consider that it is part of your function in
making such submissions to request for a direction if
you think that is necessary or appropriate?
I think, in theory, it could be, but, again, it's not
a situation in which I have found myself. Also, the
specific relation to my role, I am not there to direct
the Board, right? So when I am in a Board meeting, I am
a Non-Executive Director. I am not a decision maker on
behalf of the shareholder. So I am reflecting the
shareholder's view and then the Board is taking
a decision, and then, if the shareholder approval is
required the decision of the Board goes to the
shareholder for approval.
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So I wouldn't want to speculate because I think that
they are both matters that the Board is taking very
seriously.
‘SIR WYN WILLIAMS: Does it come to this, Ms Gratton: that if
A
it ever got to the point where the Minister thought it
appropriate to tell the Board what to do, the reality is
that he would have lost faith in the Board and/or the
Board would have thought he was wrong so they'd resign
en masse?
Yes, I completely share your view.
MR JACOBS: Thank you that's helpful
a
A.
Finally from me, I want to refer you to what you say
at paragraph 23 of your statement. There is no need to
tum it up, I can read it out.
"The MOU contains provision for the Shareholder Team
to make submissions directly to the DBT Permanent
Secretary, Minister or Secretary of State.”
You go on to say at paragraph 40
“Ultimately, should my team or I become aware of
an issue that we do not consider the Department has been
fully sighted on or has not fully considered, it may be
appropriate to provide a submission directly to the
departmental Minister or Permanent Secretary.”
Have you or anyone in your team made any such
submission?
86
But you do feed back concerns, don't you?
Yes.
MR JACOBS: Thank you. I don't have any further questions
for you. Thank you.
SIR WYN WILLIAMS: Thank you, Mr Jacobs.
Questioned by MS PATRICK
MS PATRICK: Good moming, Ms Gratton.
You'll be glad to hear we've only got two topics
we'd like to cover and both of them relate to your
witness statement.
The first relates to your general reflections at the
end of your statement on the efforts made to engage with
subpostmasters who might be eligible for compensation.
Mm-hm.
I'm not going to ask for it to come on screen but if you
want to have it in front of you, it's page 93. You deal
in the statement with the approach being taken to new
putative applicants to the HSS, the letters being sent
and how they highlight the fixed offer available. I'm
not going to read directly but I just want to highlight
a paragraph couple of paragraphs.
If you look at 202 in front of you, you start by
looking at the Overturned Compensation Scheme (sic) and
you set out how initially there were three letters being
sent, highlighting the right to appeal, the right to
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compensation, criminal cases review and so on. Then you
say:
“The work has largely been superseded by the
implementation of the exoneration policy.”
You finalise it by saying:
"The Post Office has also been in contact with
Citizens Advice to provide support and information for
potential applicants and has encouraged the few
applicants who do not have legal representatives to seek
legal advice to expedite their claims.”
Now, that's the Overtumed Convictions Scheme.
Yes.
You go on to the HSS, and say:
“On the HSS, much of the work to identify potential
claimants had been done before my appointment as NED,
including writing to former and current postmasters who
met the eligibility criteria and publishing information
on the website.”
You refer to the huge increases we've heard about
following the drama. You say that:
“The Post Office is planning to write again to
potential applicants, setting out details of the £75,000
offer, the appeals process and the end date.”
Then you go on to say that you've been asked about
how the communication with applicants is going. You say
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being made -- sorry, not at the point of application:
That is a decision for the Department, that the
Department has taken.
Indeed, we did cover that. The Inquiry has heard that
and that's why I've raised it.
What I wanted to ask you was, has that issue of
legal advice and funding for legal advice —
I apologise, I'm being reminded that I may have said
“Overtumed Compensation Scheme”, of course we're
talking about the difference with the Overturned
Conviction Scheme. I misspoke
But returning to that question, has that issue about
legal advice and encouraging legal advice or the
question of funding legal advice earlier in the process
for HSS applicants been discussed at the Remediation
Committee?
Yes, it has, extensively.
Are you able to help the Inquiry on what has been said?
So the Remediation Committee, of which I am part, thinks
that claimants should be offered legal advice at the
point of application. I think it's quite hard to decide
whether or not you should take a fixed-sum offer without
having some support in that process. That view from the
committee has been made clear to the Department. The
Department has taken a different view.
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you're aware that there have been concems about the
offer letters and that previously a complaint had been
made to the SRA.
You say that the wording in the letter has changed,
and you're not aware of major issues arising around Post
Office's communications with claimants. I won't read
out all of that because you say you're not in the thick
of it, as it were —
Yes.
— around how the timings, and so on, of compensation is
dealt with. But since you've raised the letters, can
you help the Inquiry with whether or not access to legal
advice is addressed expressly in the current letters
being sent to HSS applicants?
lam afraid I don't know.
You don't know.
We've heard a lot today about differences in
approach to legal advice. Do you know, at high level,
whether would-be applicants to the HSS are encouraged to
seek legal advice, in the same way that individuals in
the Overturned Compensation Scheme would be?
So I actually don't know whether this came up with
Mr Creswell yesterday but legal fees -- legal advice is
reimbursed ~- the cost of which is reimbursed in the HSS
only on receipt of the offer, not prior to the offer
90
Thank you. Now, moving to the second topic. I want to
deal briefly with transparency, which is a topic that’s
been addressed a lot this morning in the questions by
Ms Hodge.
Are you aware about the announcement in the King's
Speech this year that the Government intends to bring in
a law with a duty of candour for all public servants and
those acting with public functions, colloquially known
to most people as the Hillsborough Law, recognising the
campaign by those families involved in the Hillsborough
scandal and the recommendations of Bishop Jones; is that
something you're aware of?
Yes, it was disclosed to me as part of the bundle.
We know in his speech to his party conference on
24 September, just about six weeks ago, the Prime
Minister said a bit more about that law, and I hope you
don't mind, I'm going to quote what was said because we
don't know very much about Government thinking. He
said:
“For many people in this city, the speech they may
remember was the one here two years ago because that's
when I promised, on this stage, that if I ever had the
privilege to serve our country as Prime Minister, one of
my first acts would be to bring in a Hillsborough Law,
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1 97, a law that people should never have needed to fight
2 so hard to get but that will be delivered by this
3 Government. It's also a law for the subpostmasters in
4 the Horizon scandal ..."
5 He goes on:
6 ".. the victims of Infected Blood, Windrush,
7 Grenfell Tower, and the countless injustices over the
8 years suffered by working people at the hands of those
9 that were supposed to serve them. Truth and justice
10 concealed behind the closed ranks of the state.”
ca He goes on to say a little bit more about what it
12 will do:
13 “This is the meaning of Clause 1, because today,
14 can confirm that the duty of candour will apply to
15 public authorities and public servants. The Bill will
16 include criminal sanctions and that the Hillsborough Law
7 will be introduced to Parliament before the next
18 anniversary in April. It's work that shows how
19 a Government of service must act in everything it does.”
20 He ends a couple of paragraphs later on:
a “it doesn't mean that everyone will agree but it
22 does mean we understand that every decision we take, we
23 take together."
24 Now, I just want to ask you, because of your role
25 and your connection with the Post Office as a Director
93
1 because the company is not able to pay postmasters the
2 remuneration they would like to because, simply, there
3 aren't the funds for it and you said they found that
4 position difficult to accept.
5 So I wanted to put it to you, from your perspective,
6 it's great to hear from those Postmaster NEDs on the
7 Board but the truth is, actually, they of themselves as
8 Postmaster NEDs can't change the remuneration to
9 postmasters, they can't increase it simply by virtue of
10 being on the Post Office Board. That's the case, isn't
ca it?
42 A. Well, I don't think any Board Director is able to sort
13 of magically generate funds for the Post Office to have,
14 so to the extent that is true of all of us, itis also
15 true of the Postmaster Non-Executive Directors.
16 However, I don't think that is to say at all that they
17 are not a vital part of the company because I think they
18 are, and I think their contribution — anyone who -- you
19 know, we all bring our own kind of lived experiences to
20 the Board: I been a perspective from the shareholder,
a they bring a perspective from postmasters. It is very
22 difficult for the Board to adequately understand that
23 without their presence on the Board. So I think they
24 are integral to the Board.
25 @Q. So good to hear from them, as I said?
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on the Board, and your role with UKGI, have you been
involved so far in any conversation within Government as
to how this new duty of candour might apply to
arm’s-length bodies or public corporations?
No, I haven't
MS PATRICK: Thank you
SIR WYN WILLIAMS: Is that it, Ms Hodge?
MS HODGE: There are, I think, a few questions from Ms Watt.
‘SIR WYN WILLIAMS: Right.
Questioned by MS WATT
MS WATT: Good afternoon, Ms Gratton. Yes, I'm over here.
I think I just have to get Mr Jacobs to move. Thank you
very much
I ask questions on behalf of the NFSP. I have
couple of topics to follow up on from your evidence this
morning as given to Counsel to the Inquiry.
Earlier in answering questions from Counsel to the
Inquiry about the reference in your witness statement
regarding the Postmaster NEDs on occasions failing to
distinguish between their roles as Post Office Board
members and postmasters themselves — you remember that
part - you gave an example of how difficult the
Postmaster NEDs had found it when the Board was dealing
with its financial positions, such as the budget
discussions, and you said those discussions were tricky
94
I think they have as much say over the company as any
other Board Director does.
If we think about the readout that you were taken to,
the BEIS document -- I'm not going to go back to it, you
were already taken to it ~ and the comment of the Post
Office CEO, Mr Read, making the comment about the
Postmaster NED role as to whether they're directors or
trade union reps - it kind of goes back to what I've
just asked you about -- and you said you didn't know
where that was going to go.
That's the nub of the issue really, isn't it? UKGI,
Government, Post Office, they have the Postmaster
NEDs ~ that's an illustration of opening up and
apparently engaging with postmasters, but the fact is,
because of their two roles, the Postmaster NEDs and
inevitably constrained, at least some of the time?
The Postmaster NEDs are definitionally not independent
Non-Executive Directors; I am not an independent
Non-Executive Director. I -- that means that in some
situations they will find themselves conflicted in
decision making. The number of situations in which that
is true is very limited. I happen to think - I think
we have a difference of opinion on this.
happen to think that postmasters are a vital part
of the Post Office Board and it's not appropriate to put
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them on a sort of separate Board over there where the
decision making isn't. I think they should be integral
to the decision making in the Post Office, which they
are, in virtue of being two of the ten people around the
Board table.
It's really about if they're listened to, isn't it,
because the YouGov POL commissioned by the Inquiry,
EXPG0000007, page 39 — I'm not going to it — but it
says that 60 per cent of the postmaster respondents
think that the Post Office Board doesn't listen to the
Postmaster NEDs and, on the evidence of the Postmaster
NEDs themselves, they think they're not listened to. So
really, your view and the view of postmasters and those
NEDs are actually quite different, aren't they?
So I think there has been a particular issue around the
amount that the Postmaster Non-Executive Directors have
been able to discuss the work that they do on Post
Office's Board with their postmaster colleagues.
I understand that they had had some advice from ~
I think, actually from the Post Office Legal team, that
they weren't allowed to discuss what went on in Board
meetings.
That is going to change going forward. Post Office
Board meeting minutes are going to be published.
I think there will be more latitude going forward for
97
Just one more topic. I think it's fair to say, you can
correct me if I'm wrong, that you and UKGI -- so when
I say "you", not you personally, as you've often said,
in your role as the Shareholder NED representing UKGI —
consider that the role of the Shareholder NED is the one
that, actually, helps to give the oversight of the Post
Office Board. Is that how you see that role: as well as
being on the Board, the role of the UKGI shareholder,
that the NED has some oversight of what is happening?
I don't think that's a term that I've used, no. I think
that I am there as one of ten-ish Board members. As
a non-executive I am there to help the company
understand the views of the shareholder and to provide
the shareholder with insight from the company. I don't
think I have a particular oversight role, as distinct
from any other Board member.
Thank you. In your earlier answer to Counsel to the
Inquiry, you effectively dismissed the need for
an oversight committee of the type proposed by the NFSP.
I just want to ask you some things about that.
That proposal arises out of the failures in culture
that led to the Horizon scandal, also the culture and
governance not having changed sufficiently since Lord
Justice Fraser's judgment, and now we have the Grant
Thornton report which shows an almost total failure to
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Postmaster Non-Exec Directors to discuss what happens in
Board meetings, and I think that that will show the
influence that they have on the organisation. But being
a Non-Executive Director is different to being
an Executive of the company. They do not run the Post
Office. They are there as a Board member to provide
accountability for the CEO. Itis the Chief Executive's
job to run the Post Office.
Whatever the rights and wrongs of all of that, there are
many tools of engagement with the postmasters, including
‘engagement with representative bodies such as the NFSP,
which has 6,500 postmaster members. I mean, it's not
the be-all and end-all, not one thing ~ you mentioned
something over to the side. There's actually lots of
ways in which Post Office and the Board can engage with
postmasters, as well as having the two Postmaster NEDs?
I couldn't agree more with you and I think there should
be engagement with postmasters at all levels of the
business, at ~ as I've mentioned earlier, at
a commercial level, treating people as, you know,
genuine franchise partners; at an oversight in terms of
how the postmasters are treated with relation to issues
that have been concerned in the past; and at
a decision-making level at the Board. I think it should
be throughout the organisation, yes.
98
get to the grips with the issues he outlined?
So the oversight committee is not proposed by the
NFSP as the be-all and end-all, postmaster engagement
would continue with them, but as something there to help
the restoration of public trust, actual oversight of the
Board which has, in fact, failed to change itself and
the Post Office. That's what oversight is for, and with
a range of representative bodies, condition consumer
champions, specialist members as needed, and Post Office
and Government representation, that could never actually
be a bad thing, could it?
I think we just have a difference of opinion on this
matter. I think that, if the current structures aren't
working, you should fix the current structures. I don't
necessarily think more is better, in terms of Boards and
committees.
17 MSWATT: Thank you.
18 MSHODGE: Sir, I think that concludes the evidence of
19
Ms Gratton
20 SIRWYN WILLIAMS: Well, I'm very grateful to you,
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Ms Gratton, for making a long and detailed witness
statement, and for answering everyone's questions here
this morning and into this afternoon. Thank you very
much.
25 THE WITNESS: Thank you.
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SIR WYN WILLIAMS: So we'll adjourn for lunch, I take it,
Ms Hodge?
MS HODGE: Sir, yes. Shall we resume at 2.00?
SIR WYN WILLIAMS: Yes, by all means. Fine.
(12.53 pm)
(The Short Adjournment)
(2.00 pm)
SIR WYN WILLIAMS: Are you ready, Ms Price?
MS PRICE: Yes, sir, forgive me. I don't think you heard or
the connection wasn't there. Good afternoon.
SIR WYN WILLIAMS: Good afternoon. I think before you call
the next witness, I wish to make a short statement and
issue an invitation. Is the witness in the room?
MS PRICE: No, sir. He's not.
SIR WYN WILLIAMS: So the statement I wish to make is as
follows.
Throughout Phases 2 to 7 of this Inquiry those
following it will know that most of the questioning of
the witnesses has been done by Mr Beer and his team of
counsel. However, you will also know that it's often
been the case that counsel for Core Participants ask
supplementary or additional questions of the witnesses
as we have been going along.
What might be less well known is the process by
which that came about and, without going into too much
101
The invitation I make is simply this: if there is
any Core Participant who feels that they are being
deprived of the opportunity of putting a question to
Sir Alex because of some kind of suggestion by Counsel
to the Inquiry that the question should not be asked,
now is your opportunity to raise it with me so that
can have the last word on the subject.
So if anybody does wish to make any application to
me, will they please do it now.
Any takers, Ms Price?
MS PRICE: It doesn't appear so, sir.
SIR WYN WILLIAMS: Fine. Then let's have Sir Alex into the
room, please.
MS PRICE: Thank you.
SIR ALEXANDER JAMES CHISHOLM KCB (sworn)
Questioned by MS PRICE
MS PRICE: Can you give us your full name, please, Sir Alex?
A. Alexander James Chisholm.
@._ As you know, my name is Emma Price and t'l be asking
you questions on behaif of the Inquiry.
Thank you for coming to the Inquiry today to assist
it in its work and for providing a detailed witness
statement in advance of today. You should have a hard
copy of that witness statement in front of you. Do you
have that?
103
1 detail, essentially what happens is that counsel for the
2 Core Participants submit lists of questions that they
3 wish witnesses to be asked about, and then Counsel to
4 the Inquiry decides whether they will ask the question
5 themselves or whether they will leave it to counsel for
6 the Core Participants to ask the particular question
7 That system has worked extremely well, and I should
8 say here and now that I am very grateful to all counsel
9 involved in this process who have made it work so well.
10 Very occasionally, as I understand it, counsel for
"1 a Core Participant may wish to ask a question which
12 Counsel to the Inquiry thinks ought not to be asked. In
13 those circumstances, Counsel to the Inquiry does not
14 have the last word. That would rest with me, if any
15 application is made to me to ask the particular question
16 ora line of questioning.
7 To date, I have never been asked to exercise my
18 power to determine whether or not a question should be
19 asked, and that's pretty remarkable, given that we're,
20 what is it, almost three years into this process.
21 Anyway, intelligence has reached me that there may
22 be a problem -- and I stress may be a problem — to be
23 resolved in relation to questioning of Sir Alex and so
24 I wanted to raise that immediately before he begins his
25 evidence.
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1 A. Yes, Ido
2 Q. Itis dated 14 October 2024. If you could tum to
3 page 68 of that, please.
4 A. Yeah.
5 Q@ Doyou have a copy of with a visible signature?
6 A. Ido.
7 Q. Isthat your signature?
8 A. itis.
9 Q Iunderstand there is one minor correction you'd like to
10 make to the statement?
"1 Yes, thank you very much.
12 Q. Would you like to tell us what that is?
13 A. Itis a point of detail. Paragraph 23, and I'm talking
>
14 there about the funding given to Post Office Limited by
15 the Department in my time and, in the fourth sentence
16 there, we talk about the subsidy over three years and
17 then the investment, and it says:
18 *... the investment was 168 million in 2018/2019
19 with the remainder of the £210m funding earmarked for
20 the next two years."
21 And it should be “the next year", just one year, not
22 two.
23 Q. Are there any further corrections to be made?
24 A. No.
25 Q. With that correction made, are the contents of the
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statement true to the best of your knowledge and belief?
Yes.
For the purposes of the transcript the reference for Sir
Alex's statement is WITNO0180100.
Sir Alex, your witness statement is now in evidence
and it will be published on the Inquiry's website in due
course. I will not therefore be asking you about every
aspect of your statement; just certain matters within
it
I'd like to start, please, with your background and
the roles that you have held which are of relevance to
matters being looked at by the Inquiry.
After you graduated from Oxford with a degree in
history and completed a master's in business
administration, you began your career as a civil servant
in 1990; is that right?
Yes.
You worked in various roles at the Department of Trade
and Industry and the Office of Fair Trading until 1996?
Mm-hm.
You then worked in the private sector for around
a decade before returning to public service in 2006,
when you were appointed as Commissioner at the
Commission for Communications Regulation in Ireland.
Yes.
105
of BEIS, please. As Permanent Secretary, you were the
senior civil servant with lead responsibility for the
management and oversight of the Department and its
resources?
Correct.
You were the Principal Accounting Officer, the Senior
Advisor to Ministers and a Public Representative of the
Department; is that right?
Yes.
You also chaired the Department's Executive Committee
and the represented the Department before the Public
Accounts Committee?
Yes.
You set out the many and varied matters which were
occupying the Department in 2016, and the years which
followed, at paragraphs 11 and 12 of your statement?
Yes.
You also explain in your statement that the Department
at that time sponsored over 40 arm's-length bodies or
partner organisations, as they were known, within BEIS;
is that right?
Yeah,
You deal at paragraph 15 of your statement with your
particular responsibilities as the Department's
Principal Accounting Officer. Could we have that on
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In 2013, you were appointed as Chief Executive of the
newly-formed Competition and Markets Authority and held
that position until 2016?
Yes.
You then served for a short period in the Department of
Energy and Climate Change as Permanent Secretary?
Yes.
Then, following the merger of the DECC with the
Department for Business, Innovation and Science (sic),
to create the Department for Business, Energy and
Industrial Strategy, you became Permanent Secretary of
BEIS on the 5 September 2016?
Yes.
You remained in that role at BEIS until 13 April 2020?
Yes.
You were then appointed as Chief Operating Officer for
the Civil Service —
Yes.
~ and, in parallel, Permanent Secretary for the Cabinet
Office, roles you held until April this year; is that,
right?
Correct.
You are now Chairman of EDF Energy?
Yes.
Coming to your responsibilities as Permanent Secretary
106
screen, please. It's page 4 of WITN00180100. Here you
explain that, as Principal Accounting Officer, you were’
"... accountable to Parliament for Departmental
expenditure. This covered funds directly spent by the
Department, for example the funds required to employ the
approximately 4,000 staff who worked at BEIS. It also
covered the funds spent by over 40 arm’s-length bodies
and capital programmes."
Then you give an example for 2018 to 2019 of the
expenditure of the core department and agencies being
£136 billion.
You describe Post Office as one of those
arm's-length bodies or partner organisations in the
paragraph below. Was that how the Post Office was
categorised, notwithstanding its status as a public
corporation?
Yes, I think technically, under the scheme of accounts,
the Office for National Statistics would classify it as.
a public non-financial corporation, or often referred to
as a public corporation, and that put it at even further
arm's length than the arm's-length bodies. For
practical purposes, we treated them as one of our
partner organisations. It is the case, though, that
when I talk about 40,000 people working within the
Department and its agencies, that doesn't include all
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the people who worked in the Post Office, which was
a separate business and, of course, tens of thousands of
further people were working there.
Q. Okay. Just on that figure, I think it was 4,000 in
paragraph 15 that you gave. Is that supposed to be
40,000?
A. No, 4,000 in the core department, and a further 40,000
working for us in the arm's-length bodies, but that
didn't include several tens of thousands more who would
have worked in sub post offices.
Q._Isee. To deal with your accountability for Post
Office's funded expenditure, you deal with this at
paragraph 45, which is page 12, please. You say:
“Whilst I was not involved in the detail of UKGI's
oversight of [Post Office Limited], as Principal
Accounting Officer I was accountable to Parliament in
respect of [Post Office Limited's] funded expenditure,
as defined above, and for ensuring that arrangements
were in place for effective shareholder oversight.”
So to be clear, first of all, about the parameters
of this, you say at paragraph 23 of your statement that,
at the time you were Permanent Secretary, Post Office
Limited was mainly self-funded through paid-for services
but, in addition, it benefited from top-up funding from
His Majesty's Treasury. Your accountability as
109
oversight is working effectively. You're there to
provide advice and support to the Accounting Officers.
You can see, you know, many times in those meetings,
one-to-one meetings, and so on, you're saying, you know,
what are the issues and how can we help you with those?
Also there is, I have to say, a supervisory aspect
to it, so you are also making sure they are doing things
correctly and, in my time -- I don't know if you're
going to come to this -- but at one point we found
evidence that they were using funds that we had given
the Post Office for the purpose of maintaining the
network and investing in transformation, they appeared
to have been used for a piece of litigation and we said
that that was incorrect.
MS PRICE: Yes, we will come on to that.
A. Yes, but it's an example of the exercise of the
Principal Accounting Officer function.
Q. The Inquiry has heard evidence from Sir Martin Donnelly
that, at least in some stage of his tenure from 2010 to
July 2016, as Permanent Secretary of the Department for
Business, Innovation and Science, for most of the
partner organisations over which BIS had oversight,
their accounts were consolidated into the main BIS
accounts. This did not apply, he said, to Royal Mail
and to the Post Office, given their status as a public
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Principal Accounting Officer for the Department to
Parliament for Post Office Limited's expenditure, was
that limited to expenditure funded by the Department?
I think the scheme ~- the way it works is that, as
Principal Accounting Officer, you then give delegated
accounting responsibility to either people working in
your own department or usually the heads of the
arm’s-length bodies. And in this case the Accountable
Officer -- it's not called Accounting Officer for,
again, a very technical reason, apologies for that —
the Accountable Officer was the Chief Executive of the
Post Office, and you could see in -- when I made, for
‘example, the appointment of the new Accountable Officer,
first Al Cameron and then Nick Read, they get a formal
letter for me, a formal delegation. That would have
been done for Paula Vennells who was appointed before my
time as Accountable Officer.
And says basically, "I'm the Principal Accounting
Officer, I'm now holding you responsible for running
this organisation, the public money within it, upholding
the standards of Managing Public Money and all the other
things". It's all set out in a formal letter of
delegation. So that's the first part of it
\ think, in addition, as part of that you don't say,
“Right, well, that's it". You remain concemed that
110
corporation.
Can you help, please, with whether the accounts for
any partner organisations were being consolidated into
the main BEIS accounts when you were Permanent
Secretary?
Mm, I'll have to think about that. I think it’s very
likely they would have been, for some of the executive
agencies, but I'm not absolutely sure of that. And they
might have been for -- yes, so for example the Nuclear
Decommissioning Authority, I think accounts must have
been consolidated because I remember we had to make
provision for change in the interest rate, yes.
So probably quite number of them would have been
consolidated, I think that is right, yes. Ifitis
important to the Inquiry I could check the detail of
that but it's all there in the public accounts.
In relation to the Post Office, its accounts weren't
consolidated -
No.
~ into the main accounts. What was the reason for
that?
It was treated as a company, run as a business, very
much at arm's length. It had its own statute, it had
its own Board -- fully fiduciary Board. Its accounts
were published/produced to the requirements of -- you
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know, like any other company. They were externally
audited, not done by the Government's auditors. All of
that was done on a completely separate basis, and
I think it's also the case that the -- unlike other
parts of the Department where we would be employing
civil servants, here obviously it's much like
a business, like a franchising business with lots and
lots of employees, quite a big business, I think about
£1 billion in turnover at that time and, you know, it's
accounts would have been more comparable to those of
another retailer than to something of a Government
department.
Was there any difference in your Principal Accounting
Officer responsibilities as they related to the Post
Office, when compared to other partner organisations, in
particular partner organisations which were not
classified as a public non-financial corporation?
Yes, I think that those which were closer and more alike
to us, we would probably -- if we were consolidating the
accounts, we would have had more control and
involvement, and also more day-to-day responsibilty.
So, again, as a public corporation, run like a business,
it was very much at the outer edge of that arm’s-length
responsibility and, in the delegated authority that we
gave them, it was clear that they needed to exercise
113
had oversight responsibility for ensuring the proper use
by the Post Office of public funds for their designated
purposes, as opposed to being more intricately involved
in their accounting practices?
Yes. I mean, in effect, the responsibility I had as
Principal Accounting Officer was then passed on to the
Chief Executive of the Post Office, who was the
Accountable Officer.
The example that you've referred to, of your
correspondence with Paula Vennells, in respect of use of
public funds for the litigation, could you have on
screen, please, POL00024073. This is a letter you wrote
to Paula Vennells on 3 January 2018, which raises your
concem about a recent funding request which had been
made of the Department. Starting at the second
paragraph down, you say:
“As you will be aware, the Minister wrote to Tim
Parker on 20 December 2017 to set out the basis for
providing transformation funding to the Post Office and
her expectations on how this was to be used. The
Minister emphasised the need for funding to be used
prudently and efficiently in accordance with the
objectives of the three-year strategic plan whilst
recognising the need for some flexibility for
a commercial business engaged in investment projects.
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their own control, internal financial controls, proper
audit, proper processes, proper supervision, as you'd
expect in any other company or business.
To what extent did you get involve in overseeing Post
Office's accounting practices?
Accounting practices, I would say not at all. I think
the only exception I can think to that was we had
a funding agreement, it was called, and actually, I just
drew attention to you the funding we gave both the
network, a subsidy to make sure that there were
approximately 11,500 Post Office outlets, and also we
funded some investment they were making to improve their
efficiencies and transformation. So those are the two
pieces of direct BEIS funding that came from the
Treasury through us to the Post Office. And we were
very meticulous in making sure they were spending those
in the right way.
They had to account for how they were doing it, and
that’s how we detected that they had used a small part
of it incorrectly for litigation, which they then had to
repay to us, and were then put on a kind of extra
attention of monitoring and reporting every quarter
thereafter that they had not repeated that error.
We will come to the correspondence on that very shortly.
Broadly speaking, it is the case instead that you
414
“In your recent funding request, you indicated that
you intended to use BEIS funds for non-transformation
related spend specifically in relation to the ongoing
Horizon litigation. I understand that this is now no
longer the case and UKGI have communicated to your team
the requirement for BEIS funding only to be used against
those projects which are related to transformation and
approved investment activities."
You go on to explain that:
“As Principal Accounting Officer, [you were]
personally responsible for ensuring the Department has
a high standard of governance and exercises effective
controls over the management of resources, including
those through its partner organisations. So that I may
have ongoing assurance that BEIS funds entrusted to Post
Office are being used as the Minister intended, please
can you confirm this on a quarterly basis in arrears.
UKGI will provide you with further details on the exact
wording and format ..."
So it was your view that the use of departmental
funds for the Horizon litigation was not a proper use
for designated purposes; is that right?
Yes.
You go so far as to describe it in your statement as
a "categorical mistake in budgeting and reporting”
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Paula Vennells responded to you by way of a letter dated
8 January 2019. Could you have that on screen, please.
It's POLO0024074. She addresses the litigation funding
issue, starting the fourth paragraph down, and says:
"We operate a single portfolio of large change
projects, which form the basis of our reporting to the
Board. As you know, our change funding comes from
a combination of Post Office trading profit and
Government transformation funds. The GLO work draws on
shared (scarce) resources from the change budget; we
have been transparent about these costs. I will ensure
we make it clear that the source of funds for GLO work
is Post Office, not Government. When this was brought
to our attention in December we removed the £2.4m from
this quarterly request. We will not include GLO spend
in future funding requests and will confirm this
quarterly, agreeing the wording with UKGI as requested.”
She goes on:
“Furthermore, to ensure that the distinction is
absolute and consistent, I have asked Al Cameron, CFOO,
to arrange for £2.3m to be retumed to BEIS: the GLO was
listed in our earlier reporting and we received funding
from you of £2.3m for [Quarter 2)."
Did you personally review the quarterly funding
requests from the Post Office?
417
I hadn't noticed at the time that there was a difference
between that. Now, you've mentioned it, I see
2.4 million is different from 2.3 million so it may be
that they did it for two quarters but, anyway, you know,
when I saw that, I thought, "Good, they've paid the
money back and they've accepted they made a mistake and
they won't do it again”.
Was the 2.3 million returned by the Post Office to the
Department as promised?
I'm sure it was, yes.
Were you reassured by Ms Vennells's response to your
challenge?
Yes, in the sense that they didn't argue that they'd
made a mistake. They said, "We've made a mistake, we
made it good. We've paid the money back and we will,
you know, continue to account to you in a special way to
make sure it doesn't happen again" so I thought that
that was satisfactory. It wasn't good that it happened
in the first place but at least they had accepted their
error and made amends.
That document can come down now. Thank you:
In terms of your wider responsibility beyond being
accountable for Post Office's expenditure of public
funds, you were responsible for ensuring that
arrangements were in place for effective shareholder
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No.
Was that something you delegated to those who worked to
you?
Yes, the oversight of that was done by UKGI and I think
it's extremely likely that they drew my attention to it.
It's possible I spotted it myself but more likely they
said, "We've been going through the returns from the
Post Office, and they appear to have been using some of
our money [inverted commas, BEIS money], not for the
reasons given, which was specifically for network
maintenance and transformation, but for litigation. We
think that's wrong, do you agree?” And I saw it and
I said, "Yes, I absolutely agree and we should change
that and we should require them not only to give us the
money back but also to make sure it never happens
again", which I think is the effect of the commitment
that's entered into by the Chief Executive in that
letter.
So you were told, were you, by UKGI, about the previous
earlier reporting and the payment out that had been
made, in addition to the recent report? Because there
are two things referred to here: was it that you were
hearing about the previous reporting for the first time
in this letter from Paula Vennells, or had that already
been reported to you?
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oversight of Post Office; is that right?
Yes.
Was it in the context of that responsibility that you
began work in 2018 on a new Shareholder Relationship
Framework Document to clarify the respective roles and
responsibilities of BEIS and UKGI as they pertained to
Post Office?
Yes.
We'll come back in due course to the reasons why you
considered that necessary but, just in terms of
involvement on shareholder issues, you say you were
actively involved on core shareholder issues throughout
your tenure; is that right?
Yes.
You give examples in your statement of issuing guidance
letters to the Chair of the Post Office, appointing the
new CEO, following Paula Vennells' departure, and
involvement in Post Office strategy, setting and
discussions?
Yes.
In terms of the Government's interest in, and
relationship with, Post Office, you say at paragraph 18
of your statement that, whilst BEIS had no legal
responsibility for the Post Office, under its Articles
of Association, it had political responsibility for the
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company which you say it took seriously; is that right?
Yes.
Ministers took a broad view of its responsibilities for
the Post Office, given its social function?
Yes.
You describe the Department's oversight of the Post
Office as supervisory and advisory, with the Department
being heavily reliant on the reporting which came to it
from the Post Office?
Yes.
On the question of the extent to which the Department
was able to intervene in Post Office matters, could we
have on screen, please, paragraph 36 of Sir Alex's
statement it’s page 10. Having set out the role of
ministers in broad terms in the paragraphs above this,
you say:
“It was ... never my understanding that BEIS was
under a legal requirement which prevented ministers from
becoming involved in [Post Office Limited's] operations.
[Post Office Limited's] operational independence was
a practice and not an immutable right. My own view is
that [Post Office Limited] came to use its operational
independence in a self-protective way. Ministers and
BEIS officials were provided with carefully worded
summaries without the benefit of sight of many of the
421
sooner and more decisively in [Post Office Limited]'s
operations.”
So from your -- forgive me ~
Could we just show paragraph 31 as well?
Of course. If we can go back to that, please. That's
page 9.
I just wanted to show how the concept of operational
independence was not only a kind of a convention or
a practice, as I said there in the middle of that
paragraph, but actually was the way in which a public
corporation was meant to be treated, and that was
defined in the Public Bodies Handbook, and I quote there
the 2016 edition. So it says that is what a public
corporation is. It's:
“... controlled by Central Government ... and it has
substantial day-to-day operating independence so that it
should be seen as institutional units separate from its
parent Department.”
So that's exactly how, you know, it's often been
mentioned about this concept of operating independence,
but that's, you know, the bedrock and you'll see in
other documents, such as the framework document, that's
fully recognised. The paragraph that you've just drawn
my attention on, which follow on from that, were saying
that that was fine, if you like, when things were going
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key documents. The result was that, over time, the
reality of the situation as it concemed the Horizon IT
system and [subpostmasters] was obscured by [Post Office
Limited]. [Post Office Limited] came to use its
operational independence, and legal arguments about
privilege and confidentiality, as a defence to certain
decisions and to restrict the flow of information to
ministers.”
You go on to explain that
"POL's right to continue functioning at this level
of operational independence was always contingent upon
it fulfiling its responsibilities; both financial and
social. POL forfeited its claim to operational
independence when it failed in its public duties, and
ministers were entitled to intervene accordingly.”
Then at paragraph 38 you refer to the difficulty
that:
*... by obscuring the reality of the situation ...
ministers and officials had a very limited picture of
what had been happening within {the Post Office], at
least until the judgment of Mr Justice Fraser was handed
down in the Common Issues trial in March 2019. Had more
fulsome and honest information been provided to the
Department by [Post Office Limited] over the course of
these events, I believe ministers would have intervened
122
well, but that neither ministers nor myself, or the
Department as a whole felt that that meant that we
should be insulated from what was happening within the
organisation, or that it meant it could do what it
liked, so to speak.
In some of its operations, clearly it significantly
failed and that meant that ministers and myself became
increasingly involved and I think we had every right to
do and is there was no legal bar to do so.
Is it right that the reason for that greater involvement
at the stage that it happened was because the picture
the litigation revealed about the Post Office gave you
increasing concern?
Yes.
What was that concern?
I think even before we saw the judgment, the Common
Issues Judgment, in March 2019 from Justice Fraser,
which I think in the phrase used by the then Secretary
of State Greg Clark was a "seminal moment, that
revealed a great deal about the way in which the Post
Office operated, its dealings with subpostmasters, and
showed them to be, in effect, oppressive in many ways.
So that was an incredible eye-opener for us. It was
also very clear that the judge was very dissatisfied by
the conduct of the litigation by the Post Office, by the
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way in which the Post Office personnel had appeared as
witnesses before the High Court and, you know, all of
that was kind of very considerable and new information.
I think, even before that time, in the months of
preparing for it, we had been trying to get more
information about what they saw to be the legal risks,
and their contingency plans, and the potential
implications of this, and we found that was very
difficult to do so, and we had a lot of hard-fought
negotiations over an information sharing protocol, and
50 on, to try to be able to find out what was happening.
And then there was, I think, a kind of carefully
controlled flow of information to the Department, which
I think, if we'd seen more, we would have seen -- as I'd
said later on in the statement, we would have seen they
actually had no chance at all of success in the
litigation, and they should have exited from it even
earlier than they did.
The other reason you gave in your statement for greater
involvement was that the Department would need to be
directly involved in bringing settlement. Can you just
explain, please, why it was that the Department needed
to be directly involved in bringing settlement?
Yes, so think that — I mean, first of all, the
magnitude of the amount of sums, but also the
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In terms of your expectations of those working in
a public corporation, is it right that you would expect
them to act in a manner consistent with the Nolan.
Principles?
Yes, indeed. And indeed, in the letter of delegation,
which again I've referred to — to the Accountable
Person, it's very clear and it lists all the things that
they are required to do by reference to Managing Public
Money and includes, for example, treating your business
partners with respect, and things like that, acting
always with integrity, you know, such matters. So
I think there should be no doubt about Post Office
Limited as part of the public realm and its public
responsibilities.
You made your expectation of this clear, it seems, in
a meeting you had with Nick Read on 30 September 2019.
Mm-hm.
Could we have on screen, please, UKGI00018641. We can
see from the middle of page 1 that this is an email
readout of your meeting, sent on 2 October. Going to
page 3, please, under "BEIS expectations and immediate
priorities”
“Alex set out his expectations of Nick as CEO of
POL, [including] the Nolan Principles and guidance on
Managing Public Money. Recognising Nick's lack of
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implications of that, accepting wrongful practice,
effectively, and trying to make good, would absolutely
be a shareholder matter?
I think, technically, the approval level which the
Post Office, under their delegated authority, was
£50 million, and we anticipate it going beyond that, and
indeed it was more than that. There's was also
a concept under Managing Public Money, which was the
main reference point for good accounting practice in
Government, that anything which is not all contentious
or repercussive requires Treasury consent expressively,
which we had to obtain for that.
So for all of those reasons it was rightly, both by
Post Office Limited and ourselves, seen as being
a matter which the Department would need to be involved
in the decision making. But there was also -- and
again, this comes up in later correspondence -- I was
very clear in my advice to the Secretary of State but
also that the Department need to be able to be a neutral
party in relation to the litigation so we could respond
and deal with the fallout and consequences of
remediation.
We shouldn't be a party to the litigation, we needed
to be above that in order to respond as necessary
according to the outcome of the litigation.
126
experience in this area, Alex stressed that he should
lean on BEIS for this if ever unsure, especially for
anything that is ‘novel, contentious or repercussive’.”
You were here setting this out in terms for Nick
Read but, more widely during your tenure as Permanent
Secretary, was it made clear to the Post Office senior
executive and the Board, by the Department, that the
organisation was expected to operate in accordance with
the Nolan principles for standards in public life?
I can't remember any specific reference to it in
documents. So -- and I haven't seen any in the ones
that the Inquiry have shared to me. I think that when
Paula Vennells would have been appointed Accountable
Officer by my predecessor, the letter appointment which
I'm sure is pretty standardised when you become
an Accounting Officer, would have said the same things
that my letters when I appointed Nick Read and indeed
Alisdair Cameron when he was Interim Chief Executive
before, so it would have been set out their public
responsibilities there.
I think I was making a particular point of it here
with Nick Read because, unlike both his predecessors,
who had been a number of years in the organisation —
which was a public corporation -- Nick had been working
in the private sector beforehand, and I was sort of,
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I suppose, trying to lead him through it and say, “It's
a bit different now, you're now in the public, you know,
these are the things that you need to pay particular
attention to.”
Q._ Do you think there is a case for there being more
extensive and wider guidance to the Post Office on the
nature of those responsibilities?
A. It’s possibly the case. I mean, I think that, given all
the things we know now about the shameful, disgraceful
actions that the Post Office were engaged in, anything
that the Inquiry can recommend which would reinforce
upon them the high standards required of them and their
public duty, I'm sure it would be welcome.
Q._Did Nick Read line on the Department, as you had invited
him to do, if he was ever unsure.
A. Yes. In my time ~ and he was appointed in September
2019, and I finished, as we heard in April ‘20, so in
that six and a half months, I had a number of
interactions with Nick Read. I found him to be -- to
bring a fresh perspective. I found him to be very
welcoming of advice and input. He seemed not to be over
identified with the Post Office's past, which was very
necessary. After they had been resisting the need for
settlement for a long period of time and bringing number
of illjudged recusal and appeal attempts, he
129
It's UKG100008026.
SIR WYN WILLIAMS: While that's being done, can I just ask,
Sir Alex, was that the first time you were given
a formal briefing on Horizon, or is this just an example
that we're going to look at?
A. Thank you, Sir Wyn. I think May was the first time
Iwas given a briefing, and the timing of that was
probably because that was after a case management
meeting had taken place in relation to the conduct of
the so-called Common Issues litigation. So before that
time, it wasn't known what, you know, how the whole case
would be managed. At that point, I think they had
a concept of how it would be managed, the timing and the
processes, the issues, I think the ~ and I said,
"That's interesting. This is going to be a big deal.
I need to know lots about it. I want a full briefing"
This was the initial briefing. I said, “That's good but
Ineed more”.
And then there was that process of slight
negotiation between UKGI's lawyers and Post Office
Limited's lawyers about how much information we could be
given and under what terms, the so-called information
sharing protocol but, ultimately, that led up to a very
detailed briefing which we ended up getting in October,
“we" being the Minister responsibility, Kelly Tolhurst
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immediately saw, as, indeed, did their new General
Counsel, that that had been a mistaken path and they
should not only try and bring about a financial
settlement but also so set the Post Office itself on
a path of cultural renewal, which we thought was very
necessary.
He introduced, with my encouragement, but I think of
his own initiative as well, a rapid review of their
culture. They brought in some external people to try to
advise on that, to try to ~ and also to get advice on
how they could repair the relations with the
subpostmasters. So in all of that, in my experience,
Nick Read behaved like a responsible Chief Executive,
quickly trying to understand the expectations of the
so-called parent department but also the needs of
stakeholders in trying to run the organisation and put
it on to a better footing
Q. That document can come down now. Thank you.
I'd like to ask you, please, about some specific
examples of matters which you consider the Department
should have been made aware of, but was not. You were
briefed on the Horizon litigation in May 2018; is that
right?
A. Yes.
Q_ Can we have that May 2018 briefing on screen, please.
130
and myself, from the Post Office Legal team.
SIR WYN WILLIAMS: Thanks. Sorry, Ms Price.
Ms PRICE: Not at all, sir.
It's right to note that this is a draft of the
briefing, so we have the date at the top "XX May 2018",
and although we do not appear to have the final draft,
you say that the content in the most recent May drafts
are familiar to you; is that right?
A. Yes
@._ You think that you were, in fact, given this briefing in
May?
A. expect so, yeah.
Q._Looking, please, to paragraph 27. Here we have this:
“In terms of mitigating against legal and
operational risks, [Post Office Limited] has summarised
its past and ongoing measures in paragraphs 21 and 22
above. In addition to these, UKGI is aware from past
discussions with [Post Office Limited] that [Post Office
Limited] did the following:
“[First] appointed Deloitte in 2013 to look at the
Horizon system to establish its veracity. Whilst this
was a limited study due to the passage of time, at that
time [Post Office Limited] informed us that no issues
were found.
[secondly] at Baroness Neville-Rolfe’s request,
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when she was the responsible BIS Minister, the then
incoming [Post Office Limited] Chair Tim Parker
commissioned a new QC to investigate the matter when he
joined [Post Office Limited] in October 2015. The
initial findings satisfied the Chair that [Post Office
Limited] had taken the appropriate action at each stage.
With the announcement of the Group Litigation in
November 2015, the Chair decided, following legal
advice, not to conclude the investigation on the grounds
that it could have impacted the Court's consideration of
the claims
“[Finally] POL has also investigated individual
cases and at the time informed us that no systemic
issues were found.”
Is it right that you did not receive a copy of the
2013 Deloitte report or the report of Jonathan Swift KC?
Yes, itis. And indeed, it's interesting looking at
that paragraph, it doesn't refer to any reports. And
indeed, it's almost been written ~ I'm sure it was
written by Post Office Limited's lawyers at the time ~
sort of so as not to attract interest, "Nothing to see
here". It doesn't refer to who -- the name of the QC we
now know to be Swift, Jonathan Swift, and it refers to.
initial findings and appropriate action being taken. It
doesn't say, "There's a report”
133
considerable weaknesses and failings on the Post
Office's part. I get no sense of that from that
description.
Is it right that you also had no knowledge of the
existence of either of the Clarke Advices?
Absolutely not. So you're referring there to advice
which, again, the Inquiry has shown to me from before
the time that I joined the Department, as indeed both
these documents I've joined in 2016. So these earlier
points, which point to -- and I was, you know,
absolutely amazed and shocked to read those, written by
a criminal barrister, or solicitor, I think, saying that
the Post Office had knowingly continued to provide and
employ an expert witness, even though the expert witness
had chosen not to reveal evidence, to share with the
court evidence which undermined their own evidence, so
effectively tainted evidence, which I think is a major
failing under the criminal law. And, furthermore, that
the Department — that Post Office had not fulfilled its
obligations to keep a proper record of information
relevant to those criminal investigations, and indeed
had been involved, in some cases, in destroying that
information.
So I can hardly think of more serious information
to, you know, to have been ~- to come to anyone's
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It's actually a 66-page report with about eight
recommendations in, but you wouldn't know it from that
summary, and I didn't know it. I never saw that report
until the Inquiry showed it to me.
Before the Inquiry showed you those documents, was your
knowledge of them limited to what you were told in this
briefing?
Yes. We got similar phrases in the October briefing.
In particular, looking at the statement in relation to
the Swift investigation, the initial findings satisfied
the Chair that Post Office Limited had taken the
appropriate action at each stage. What is your
assessment of this statement, having now read the Swift
Report?
I think that's a very poor and inaccurate summary
because the full report, which is before the Inquiry,
shows a lot of loose ends, a lot of limitations, but
also has eight recommendations for further work.
Further work not only on legal issues but also technical
issues with the operation of the Horizon system and
accounting issues for the reconciliation of funds.
So in no sense is that saying everything fine here,
which is the impression given they're. It is
actually ~ there are a lot of issues here which require
ongoing attention and do point to some undoubted
134
attention. But that was absolutely hidden from the
Department. We had no idea. If we had, we would have
been absolutely shocked because it would have shown that
obviously none of the criminal investigations were safe.
Going back, please, in this document to page 2,
paragraph 7. You were given some information about
Second Sight's investigation here:
“An independent firm of forensic accountants, Second
Sight, were commissioned to examine the system for
evidence of flaws which coup cause accounting
discrepancies. Second Sight's initial report in June
2013 found no evidence of systemic flaws in Horizon.
A final report in 2015 did find that, in some cases
[Post Office Limited] could have provided more training
and support to some subpostmasters, though Post Office
disputes many of Second Sight's findings.”
Again, I put that in the character of "Nothing to see
here", and actually, I have now read those reports, and
they - again, that summary doesn't perhaps do full
justice to them. I'm sure it was well intended but it
says, you know, this phrase was used “found no evidence
of systemic flaws in Horizon". Actually Second Sight
did have certain limitations to their own access and
they said there that and they said were some
discrepancies and they'd like to do further work and
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that work was curtailed. So I don't think it provides
a very reassuring report, at least not as reassuring as
that summary would apply.
You were, though, told of the existence of two Second
Sight Reports here
Correct, yes.
Did you ask to see either of them at that point?
I didn't at that time and that's for a very simple
reason that the operation of the Horizon system was the
second issue before the High Court, the overall case,
Civil litigation, was split into four pieces. We only
got to two in the end but the second one was looking at
Horizon, and I knew that that was going to be a matter
that was going to be subject to very, very close
attention in the High Court, with expert witnesses on
both sides.
So that was going to be a much fuller answer to the
question that — than Second Sight's work had provided
and, also, if the Post Office were in dispute with the
findings of it, that didn't seem to have been like the
final matter on it, whereas I was confident the High
Court would get to the bottom of it.
That document can come down now. Thank you.
Is it right that, following this briefing, later in
May 2018, you asked to be briefed on the litigation by
137
relation to the litigation?
That was the beginning of concer.
That briefing came in October 2018; is that right?
Yes. Originally in September but then it got
rescheduled to October.
Although you describe the briefing as extensive, you say
you considered the section setting out the background to
the litigation to be relatively short; is that your
view?
Yes.
Could we have the briefing on screen, please. It's
POL00111214. Actually, if we stay on the first page, we
can see this is the briefing paper for the meeting on
17 October 2018, with Kelly Tolhurst and you. So this
briefing came to both of you; is that right?
Yes. Also "Strictly Confidential and Subject to Legal
Privilege", as it says.
Going to page 3, please. At paragraph 1.2 under the
“Executive Summary":
"What is the case about?
“The case represents the culmination of a series of
campaigns by disaffected postmasters and others
(including a number of MPs on both sides) who believe
that Post Office wrongly attributed branch losses to
those postmasters and that as a result, they suffered
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Post Office's General Counsel?
Yes.
Why did you make that request?
Ihave been getting indirect summaries of this kind, and
I wanted to have the chance, both for myself and for the
Minister, to ask some questions directly and also to
have a fuller account. The Post Office was very quick
always to claim kind of questions about legal privilege,
and so on, so, you know, you'd get these very heavily
edited pieces of information and, indeed, elsewhere in
the file of papers you've given to me, there's
an example of UKGI lawyers again arguing with Post
Office Limited lawyers, where they were trying to draft
a first section of advice, and great chunks of it had
been taken out by Post Office lawyers, including things
like the impact on Post Office Limited had been taken
out of the brief.
So there's a lot of rationing of information and
I was becoming -- I was already impatient with that and
became more so, of course, in the months that followed
and I wanted to have the chance to get as full
a briefing as we possibly could and to have a meeting on
it with the elusive Post Office Legal team.
So were you, by this point in May 2018, already
concemed about information flow to the Department in
138
financial and reputational harm. A theme of these
campaigns is that flaws in Horizon (the in-branch point
of sale system) were the cause of these losses.”
Going over the page again please, 1.8, the number of
claimants is identified here as 561. Then going to
page 6, please, the section on "Background to the
Litigation’. This is the section that you describe in
your statement as being relatively short. At 2.2,
there's this:
“In 2012 a small group of (mostly former)
postmasters, under the banner of the ‘Justice for
Subpostmasters Alliance’ and with the support from some
MPs led by the then MP (now Lord) James Arbuthnot,
claimed Post Office's Horizon IT system had caused
losses (shortfalls in physical cash against cash
holdings recorded on Horizon) which they had had to make
good. In some cases they had been prosecuted for these
losses (usually for false accounting, theft or both)
while, in other cases, they claim that it led to their
contracts with Post Office being terminated, causing
them financial loss and other personal harm, including
bankruptcy, divorce and emotional distress, including
suicide.”
So you were told here that subpostmasters had
alleged that the IT system had caused losses which they
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had to make good --
Mm-hm.
-- and this had led to some people being prosecuted for
the offences listed there --
Mm-hm.
--and the other consequences that are set out.
Yes, and, in fact, that's, I think from memory, the only
half sentence in the whole briefing, which goes on for
dozens if not hundreds of pages, which actually, in some
way, pays attention to the human impact of what had
happened. It does say even there, wrapped in a claim,
rather than the reality, but everything else in the
litigation, when you ~ in the briefing, when you look
at the contingency plans it talks, for example, of
installing CCTV in postmaster offices; it doesn't really
think about the impact on the people involved.
Did the nature of the allegations being described here
not cause you some alarm by their very nature?
Yes, but that wasn't new that these were the
allegations, as I said, they'd been around -- well,
I was briefed as soon as I joined the Department on the
fact that there was this litigation, that litigation had
been joined in March 2016, six months before I joined
the Department. So the litigation was underway. We
understood that the heart of the litigation was people
441
subpostmasters or the subpostmasters themselves to
understand their position?
don't remember giving that advice. I think that all
the postal ministers at various times did meet with
representatives of the subpostmasters, and so that was,
you know, absolutely a part of their job. They also
would have met with -- there were a number of
Westminster Hall debates and other things. Whenever
they appeared in the Commons or, indeed, in the Lords,
there were also debates about it.
So quite a lot of interaction on this issue and, if
I may say also, that in my experience of elected
ministers, that they always understand the role that
post offices play. It's the nature of their, you know,
constituencies that they understand the local role of
the post office is to support. They were involved and
they would hear these stories and so both Greg Clark and
Kelly Tolhurst, who I worked with for three years were
very understanding and sympathetic of these issues and
keen to make sure that they would be resolved
satisfactorily,
But that isn't something you recall discussing with
Kelly Tolhurst after this briefing or in relation to the
issues raised by the litigation?
She would already have had contact with the
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saying that Horizon gave false results and, therefore,
they'd been falsely prosecuted.
Did you understand, when you read this briefing, that it
was the Post Office which had been doing the
prosecuting?
Yes.
Had you been aware of that from the time you took up
your post as Permanent Secretary?
Yes, and I said, "What's happened now? Have the
prosecutions stopped?" And the answer was yes, the
prosecutions stopped in 2015, over a year before
I started, so that wasn'ta live issue. The question
was how had they been done in the past and had they been
done justly or not? And that was the issue that would
be looked at by the High Court.
Iwas also briefed, again it's included in other
documents, that the Criminal Cases Review Body were
examining whether or not — I think around 30 or so
cases had been referred to it at that time. So I was
welfare of that. So both the Criminal Cases Review Body
and the High Court were the main areas where these
actions were being looked at, at that time.
Did you consider, when you read the briefing, advising
the responsible minister, Kelly Tolhurst, to consider
meeting any of the MPs who were supporting the
142
subpostmasters and with the various MPs who had, you
know, who took up their cause. So it wasn't
a consequence of this. I think what we did discuss was
what were the chances of success were. And, in the same
briefing, you can see there's a lot of statements there
that -- from the legal advisers, saying that they had,
you know, they had the stronger part of the case and
that, on the issues which were the most significant they
were particularly confident that they would do well
They also, I think, described the issues very much
in terms of very precise kind of, you know, legalistic
issues about the interpretation of the contractual
obligations and about the burden of proof and
prosecutions, and things. So they were called Common
Issues because they were seen as kind of, you know,
legal issues which needed to be resolved in the court.
Both Kelly Tolhurst and myself, our instincts were
that this was not going to go as well as the Post Office
expected and that's why, and it's recorded in another
document, I'm asking even at that time "Shouldn't you be
settling?" And we'd had experience in other pieces of
litigation elsewhere in the Department where
a settlement had been necessary and had brought it to
an end. And we were concerned that this had been going
on for a long time, and that the Post Office was digging
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themselves in more and more and should be open to trying
to, you know, to mediate a solution.
At paragraph 2.3, below, there is reference again to
Second Sight?
Mm-hm.
Second Sight issued a report in July 2013, which
concluded there was no evidence of system-wide systemic
problems with the Horizon system software but identified
some areas where Post Office could have done more to
support individual postmasters.
It was Kelly Tolhurst's evidence to the Inquiry that
she understood from this briefing that there may have
been occasional bugs or errors in the system affecting
individual subpostmasters, but there was no serious
problem with the Horizon system. Was that also your
understanding?
The Post Office had maintained for years that there were
no problems with Horizon, and they used these stock
phrases, as very similar to the phrase given in the
briefing you put up earlier about May, referring to
Second Sight and sort of praying their report in aid to
say there was no evidence ever of system-wide problems
with Horizon software and it says there, you know, "Done
more to support individual postmasters". I think in the
previous one it was "more support and training", so
145
carelessness, or error?
Yes, I think that the, you know, intricacies of this
about the nature of contract law and where the duty
lies, and that was something that was brought out in
that briefing. I think again, the tone of that
paragraph is, you know, is lacking, I think, the, you
know, alleged “unfairness, in inverted commas, and the
sense in which the postmasters' case is kind of, you
know, drifting along, whereas the Post Office is kind of
resolute and unaltered
‘And I think there is — probably speaks to the whole
frame of mind the Post Office had about their position
that they were right and everybody else was wrong,
whereas, you know, it turned out it was -- the opposite
was the case,
The arguments in the litigation about this were in fact
addressed in this briefing document later on.
Right.
If we can go to page 37, please. This the contingency
planning for high impact areas in the scope of Common
Issues, so that its areas which were defined as having
a significant adverse impact on the business, if the
implied terms of the contract were to go against the
Post Office. Did you read the contingency planning
section of the briefing?
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there was a sense in which it was a training issue,
rather than a fault in the system, and that's what the
Post Office maintained throughout, until it was shown
not to be the case.
But specifically on Kelly Tolhurst’s understanding,
which she had after reading this briefing that there may
have been occasional bugs or errors in the system
affecting individual subpostmasters. Did you also
understand that?
I don't remember that point arising, but might have.
At paragraph 2.11 of the briefing, please, there is
this:
“In recent years, the focus of the complaints by
postmasters had expanded from issues with the Horizon IT
system, to the alleged ‘unfairness’ of the contract
between Post Office and postmasters. Despite
significant lobbying by the JFSA of Parliament and
through the media, Post Office's position has not
altered, and considers that these disputes are now best
resolved through the courts.”
Did you understand at the time that the complaint
from subpostmasters about the fairness of the contract
was that they were being asked to make good apparent
shortfalls, even where the Post Office could not prove
the loss was due to the subpostmaster's own negligence,
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Possibly. There's obviously a lot of detail here and it
was a one-hour meeting. But
The issue is set out in the left column
Yes.
In relation to shortfalls, the implied term which the
claimant subpostmasters were arguing for was set out
"Post Office would cooperate in trying to:
"Identify the possible or likely causes of any
shortfalls without any input from the subpostmasters,
andlor
“Work out whether or not there was any shortfall by
carrying out a formal investigation
"Prove as a result of the investigation that the
shortfall was properly attributed to the subpostmaster
under the contract.”
Going over the page, we see the effect of what was
being sought by the subpostmasters, by that implied
term. Post Office would not -- the "Impact" there:
“Losing this point would make it very difficult for
Post Office to recover losses without significant effort
and detailed investigation into every loss in every
branch.
“It also has the effect of shifting the burden of
proof on to Post Office to show the root cause of the
loss. In many case this will be impossible to
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1 discharge."
2 Does that cause you any concern at all, looking at
3 that?
4 A. I think ~I mean, that seems to be an accurate
5 description of the issues that were before the court.
6 I think the hearings began the month after that, and
7 obviously they looked at that very closely.
8 It's interesting that the impact on the Post Office
9 that section had previously been removed from the
10 briefing by the Post Office lawyers and given to me, so
ca they obviously saw it as a sensitive issue that they
12 were a bit slow in wanting to share but at this point
13 they did so. I think that I understood the legal point
14 there about the burden of proof. I didn't know what the
15 actuality of it was, but not being a expert on contract
16 law, and indeed experts on contract law were
7 subsequently consulted and themselves found themselves
18 to have got it wrong in the view of the High Court, and
19 the appeal court.
20 So obviously some real deep legal issues there.
a I think the -- I did understand that it made a huge
22 difference to the sense of who had the responsibility
23 for it, and, you know, therefore, why the subpostmasters
24 felt so strongly about it, and indeed, I recall that the
25 settlement, which came over a year later -- December
149
1 a number of external reports together with legal advice
2 on those reports were vital to the history of these
3 issues. In my view, ministers and I should have been
4 briefed on the contents of the Deloitte reports and the
5 Second Sight reports. We should. Have been provided
6 with copies of the Clarke Advices, Linklaters advice,
7 and the Swift Review. We should have been provided with
8 the history on the existence of bugs, errors or defects
9 with Horizon and the steps taken to investigate them —
10 which were extensive -- and their conclusions. Those
ca matters were highly material to achieving justice for
12 the [subpostmasters] and in properly understanding that
13 [the Post Office's] prospects of success in this
14 litigation were in fact always poor.
15 “Furthermore, we should have made aware that there
16 were important remedial steps recommended by Jonathan
17 ‘Swift QC that had not been actioned, indeed had not even
18 been shared with the Board."
19 In terms of reflections on your own actions, at this
20 stage, do you think you could have been more probing
a about the litigation, given what we have just looked at
22 in the briefing on what you were told?
23. A. I don't think we could have asked for documents, the
24 existence of which we didn't know.
25 Q. What about the Second Sight Reports?
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2019 -- as well as often talked about as a financial
settlement, has actually got some very important terms
to address this very issue, and has got a whole, you
know, schedule devoted to changing the way the Post
Office actually sets about establishing loss and those
commitments were entered into formally through that
settlement process.
So that was obviously a key issue for the
subpostmasters, which indeed they got resolution on.
The default position here was that it was for the
postmasters to prove that an apparent also was not
caused by their own negligence, carelessness or error.
Yes.
Did that feel wrong to you at all, at the time?
It did seem surprising but, again, this wasn't happening
in my time. The postmaster prosecutions had ended
a year before I started. So this was a historic issue
that was going to be looked at by the High Court who
would rule on it definitively.
That document can come down now. Thank you.
Could we have on screen, please, paragraph 129 of
Sir Alex's statement, that's page 34. Here you give
your reflections on this briefing, and you say that:
"The document was not sufficient for me to
understand the issues properly. I now know that
150
The Second Sight Reports, they were mentioned and we
could have looked at those. I've explained already that
they were -- the way they were described were things
which had provided a degree of reassurance, but also
that the Post Office wasn't, you know, fully in
agreement with them, and they were describing the
operation of the Horizon system, which was basing looked
at by the High Court. So I didn't think that was
particularly important. I was more concerned here with
the Deloitte report, because that does talk about bugs
and remote access, and all of that. So that obviously
seems to be speaking to a difference between what the
Post Office had been saying in a number of public
statements and the actuality.
That also was looked at particularly in the Swift
Review. Again, lots of information there about bugs and
errors and defects, and weak points in the Post Office
proceedings and a whole load of recommendations for
further action, and I have said already most shockingly
the Clarke Advices, which I only saw when the Inquiry,
you know, showed them to me in the summer — this
‘summer, '24 -- which show that, you know, those criminal
prosecutions were basically unsound.
And I think that is really a shocking thing,
absolutely shocking. And there's no hint of those, you
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know, the first I saw was in 2024
So people in the Post Office must have known that,
that advice was given to the Post Office. People in the
Post Office must have been aware about destruction of
documents and tainted evidence, but no hint of that was
given to the Department. If we had seen that, I think
we would have taken, you know, a much more significant
actions, and indeed, as I point out there, you know,
we'd have seen that they were going to lose for sure in
the civil litigation which they ended up losing but we
wasted another year and a lot of money and lot of
distress in the meantime and, even more importantly, all
those criminal investigations were left to stand for a
long, you know, considerable further period. I think it
didi
complete its work until, I think, 2020, and I think the
overturning of those by the appeal court was two more
years and finally legislation was passed, in 23
So it's a very long passage of time but, you know,
we could have cut short all of that, if there'd been.
the criminal cases review Board didn't
a fuller furnishing of the reality of the information,
rather than this careful kind of economising of the
actuality.
MS PRICE: Sir, I wonder if that might be a convenient
moment for the afternoon break?
153
when I asked to see the documents, there was a delay,
there was this negotiation over the information sharing
protocol, when it finally agreed after a lot of
negotiation, I then said it wasn't acceptable because
I said with this information I couldn't talk to anybody
else about it, you know. And I said I might need to,
you know, I obviously had responsibilities to Parliament
and across Government and I talked to the Treasury, to
Cabinet Office, et cetera. So that had to be changed as
well.
So there was just a kind of wariness. I also began
to see these stock phrases kept appearing in the
briefing and I began to think they were, you know,
designed not to kind of really invite one in and to show
the full reality. So that was an impression that
I already began to feel in 2018, and you can see that in
other correspondence over getting access to the full
briefing. I think it's definitely been reinforced now
by the experience of the Inquiry showing me documents
which the Post Office had, which they had chosen not to
reveal to the Department, such as the Swift Report, the
Clarke Advice, and other things which we were looking at
a moment ago.
Q._Looking back, do you think there is anything more you
could have done to investigate the true position in
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SIR WYN WILLIAMS: I think it would, Ms Price, yes. So what
shall we resume?
MS PRICE: If we could come back at 3.30, that would help us
this afternoon.
SIR WYN WILLIAMS: All right, fine.
MS PRICE: Thank you, sir.
(3.18 pm)
(A short break)
(3.30 pm)
MS PRICE: Good afternoon, sir.
SIR WYN WILLIAMS: Good afternoon.
MS PRICE: Sir Alex, if we could go, please, to page 31 of
the statement. That's paragraph 115. If we could have
that on screen, please, you say here:
"My impression all through 2018 was that [Post
Office Limited's] position in respect of providing BEIS
officials and ministers with information regarding the
litigation was on a ‘need to know basis’ and indeed that
there was an institutionalised wariness about what the
deposit should be told.”
Is this is an impression you formed at the time or
is this something you developed later with the benefit
of later knowledge?
A. I would say both. I think at the time I was already
conscious about the rationing of information, because
154
terms of what the Post Office knew?
A. I think that we became increasingly assertive as we
became more concemed. I think that, you know, there's
certainly a debate to be ~ was had in the late spring
of 2019 as to whether we should make wholesale changes
in the Post Office Board, because that was after the
‘Common Issues Judgment and after they'd made their
misguided recusal attempt. So not in 2018, but in 2019,
we did look at even more interventions. We did make
quite a few interventions at that time. We obviously
did change the Chief Executive; the General Counsel was
also changed; their legal advisers were changed. There
was quite a lot of change happened there.
Could we have brought along -- bought about change
more quickly? I felt there was an opportunity to settle
early, and there's a lot of my evidence of my pressing
for that. The Post Office themselves were sure that
they were right and they needed, as it happened, to
lose; as it turned out, to lose three times and change
their leadership before they came to see that they were
wrong.
Q._ You desoribe in your statement Post Office not coming
across as wanting Government involvement. What do you
think lay behind this?
A. I think, you know, every -- we are described as a parent
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Department. Every child probably wants some greater
degree of independence and, you know, I can see from
documents ~ again, you've shown to me meetings with the
Chair, the Chair is often saying, you know, "Could you
lower the level of oversight? Could you have less
intrusive inquiries? Why do we have to provide this
information?"
So they were trying to kind of -- were treating that
as a burden, rather than as both a necessary form of
accountability and as a source of guidance and advice.
So I think that probably did rather speak to the Post
Office culture at the time ~ I don't know how it is
today — but that they did tend to be kind of a little
bit self-absorbed and defensive, and seeing the outside
world as a bit threatening and, unfortunately, we were
part of the outside world from their perspective and
I think that was why they tended to ration the supply of
information to us, and to be a ittle bit resentful,
rather than welcoming about our oversight.
Was this not a red flag to you, indicating a need to
look more closely at the functioning of the relationship
between the business and the shareholder?
Yes, and that's why in 2018 --it started in January
2018, we had a first draft of the new Framework
Agreement, and one of the changes in that was to try to
187
know, identity information and pensions and tax credits
and what have you", and that's really why those
so-called services of general and economic interest —
it's a bit of jargon, but that’s what they're called —
that's what the Postal Services were providing and
that's why we had them.
And so I think the kind of interest in business and
making a profit and all of that was okay, but wasn't
sufficient, and they needed -- and -- you know, the ~
the public responsibility was there.
Moving, please, to the role played by UKGI, you describe
UKGI as being responsible for oversight of Post Office
Limited, in respect of both governance and policy when
you were appointed Permanent Secretary?
Correct.
By early 2018, you say you were considering the new
Shareholder Relationship Framework Document, which we've
touched on already. What made you think this was
necessary, over and above the concerns about information
sharing; was there anything structural that made you
think it was necessary?
Yes, there was. And I think — and let me try and set
that up, as help for the Inquiry. So UKGI, its
predecessor body Shareholder Executive, had a high level
of professional expertise, a lot of people with
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institutionalise the expected roles and the flow of
information that's part of that. It took a long time to
actually get that agreed with the Post Office, but that
was with exactly that purpose in mind.
Do you think this was an indicator that the Post Office
did not appreciate the significance of the public aspect
to Post Office?
Yes, I think that's true. I think it's, you know,
correct to say that they weren't a typical public body
because they were a retail business and a lot of their
thoughts and minds necessarily were on what it takes to
run a business, you know, logistically and in terms of
staff and product offers and customers and all of that,
and it's a complex enough business to run. So I think
it's right that they were thinking about those things.
I think sometimes that they underthought or didn't fully
understand that all this was still being done within the
public realm, that they had a public duty and that,
fundamentally, the reason there was a Post Office is.
because post offices provide a vital social, as well as
economic purpose and, you know, oftentimes, as you can
see in my letters and meetings with them, I'm saying,
“Don't forget about the social purpose, that what it's
there for, these are people who depend on the Post
Office for access to benefits and passports and, you
158
background in managing corporate transactions, they had
people who were kind of experts, if you like, in
governance, people who compared doing these different
roles across different parts of the public realm.
So that is a positive and useful part of it.
However, they actually didn't have as much experience of
working with ministers and some of the finer judgements
about, you know, political preference and requirements,
I think, was a bit harder for UKGI staff to pick up on.
When, in the -- the regime I inherited, everything
was done through UKGI. I think I found increasingly
that, given our concerns about the Department, given the
high level and justifiably high level of ministerial
interest, given this was becoming more and more
a political issue that we needed to have some direct
departmental input to that, so we established in 2018
a Post Office Policy Unit within the Department, which
worked in parallel with UKGI.
I should say UKGI in no way resisted this. They
themselves felt it was good to have a strong policy
partner and that UKGI would provide the kind of
shareholder expertise. So we moved from, if you like,
a one-engine to a two-engine operation from that point
onwards. That's what we have today as well; it's
persisted
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The final version was agreed in mid-December 2019, you
say in your statement; is that right?
Yes.
Can you help with why it took so long to reach agreement
on it?
I guess it probably wasn't seen as the absolute top
priority, because people were acting on -- you know, on
the basis that we had a kind of these different
responsibilities, and the way the final signed agreement
was, if you like, the codification of that.
Also the drafts were in circulation, so everyone
knew the roles that people were expecting to be played
within it, I don't know whether there was also kind of
low level negotiations or friction between the teams.
don't know, I wasn't part of that. Every so often
I would say, "Where are we with the framework
agreement?” And they'd say "Oh, it's coming along, we
are almost there". And, in the end, you know, we were
there and we hadn't had one before. So that was
a necessary and important improvement in governing
relations between - it's really a try Apartheid
arrangement between UKGI, BEIS, and Post Office Limited.
When you took up your post as Permanent Secretary did
you consider the avenues for reporting to ministers on
Post Office issues to have been effective?
161
different judgements on certain matters, notably the
bonuses issue [and we'll come on to that]. I think they
also struggled at times to reconcile the tension between
identifying with [Post Office Limited] and standing at
one remove to challenge [Post Office Limited.”
Pausing there, is this is an impression you formed
at the time you were Permanent Secretary and, if so, at
what point into your tenure?
Yes, I mean, I think, on the whole, we received very
good advice and service from UKGI. And, you know,
I stand by what I say there about their integrity and
professionalism. I think that because they were on the
Board of Post Office Limited, and as a member of the
Board I think they identified with the Board, I think
they felt they were directors and had responsibilities
there. That probably sometimes gave them almost too
much information and awareness of the interests of Post
Office Limited, and they were required by their role to
also sometimes stand back from that and say, "Okay,
well, that's all very well, but, you know, are you stuck
in a kind of a particular mindset or groupthink here
about particular pieces of litigation? Have you really
looked at it from the other perspective? You know, is
there a possibility, for example, that, contrary to the
Post Office's long maintained position that they were
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I think when I first started, I could see that I think
there were six different parts of our 40-odd public
arm’s-length bodies, partner organisations — I think
six of those were managed on the Department's behalf by
UKGI, and they had a lot of expertise, they did a very
good job across that overall
I think the Post Office, if you like, moved from
being seen as something where the business skills
available to UKGI and their experience and kind of
corporate finance matters and, you know, investment
returns, and all of that, that became, relatively
speaking, less important than these much wider
ramifications about was the Post Office actually
fulfilling its fundamental purpose; was the Post Office
actually run by competent and honest people? And they
were much more fundamental type questions, which
necessarily ministers will want to be advised upon
directly.
Could we have on screen please paragraph 248 of Sir
Alex's statement, that's page 65. You say:
"UKGI plays an important and valuable role across
Government. UKGI officials dealing with [Post Office
Limited] were under considerable pressure throughout my
tenure. I never had reason to doubt their integrity,
work rate or professional skill. At times we reached
162
actually wrong about Horizon, and that the -- and if
that was the case, that there had been miscarriages of
justice there?"
So there was a kind of myopia which I think was
there within Post Office Limited at that time and
I think it would have been very difficult for UKGI in
their succession of shareholder representatives on the
Board to challenge that. But I think that was part of
what they needed to try and do, difficult as it is, and
also, as I go on to say there, you know, as the kind of
supervising body, they needed also to be able to
sometimes test the version of things they were given.
And there's an awful lot of stock phrases and you can
see where whole chunks of text are lifted from one
document to another, supplied by Post Office Limited to
UKGI and then given to the Department on that basis
And very understandable they should do that, and
also to try to, if you like, smooth things along and
suggest things are going quite well. But I think the
unintentional effect of that, as I go on to say there,
is it probably preserved the status quo for a bit longer
than would have been the case otherwise. And postponed
the crisis. And a crisis was necessary and happened in
2019 and, actually, that brought, you know, complete
change to the leadership of the Post Office, the
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beginning of compensation, recovery and cultural
renewal.
Was this something which those at UKGI struggled with
across the board or were there particular individuals
who struggled with it more?
UKGI is an organisation of about 100 people and they
work closely —
I mean, forgive me, those working on Post Office?
Post Office, yes, I think there's about four work in
Post Office. But if you look at other papers given to
the Inquiry you can see that there's a lot of discussion
within UKGI, support from the Chief Executive, deputy
Chief Executive. You can see board meetings, Post
Office is constantly being looked at as an item. So
it's not only the individuals working there, it's also
the wider organisation trying to give support as part of
that.
I thought that they were extremely competent, the
people who worked on the Post Office account, so to.
speak. I think at times, at the margins, they found it
quite difficult to judge the political issues, and you
said you want to come on to the bonuses one, that's
an example of it.
And I think, at times, that ability to try and be
a member of the Board, but also to be sort of a little
165
accountability of ALBs could be approved across the
spectrum. It starts with openness and pattern
recognition. If concerns are raised there should be
formal and publicly accessible means of reporting and
tracking those concerns. That mechanism could be
overseen by an independent committee that has mandatory
reporting responsibilities to the Board, as well as the
authority to write to the Secretary of State annually
with any concerns. There could also be obligations to
report periodically to Parliament. As a basic
principle, where an ALB has failed in the trust that the
public places in it, this calls for more frequent and
more intrusive government scrutiny.”
In your view, should those accountability mechanisms
enhance existing structures, or should this be in
addition to them, or replace them?
I think in a perfect world you wouldn't need to have
this because it obviously adds an extra layer, and every
additional layer creates scope for friction, cost and,
you know, risk with that,
However, in the particular circumstances here, where
the Post Office Board has failed in its oversight
responsibilities, which clearly lie with the Post Office
Board, and the management executive being part of that,
their internal legal teams, over many years, you know,
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other compared to the other members of the Board and
bring a genuine challenge, I think again, that could
have been even stronger at some points. But,
undoubtedly, a difficult role to perform and I don't
envy them all.
But you identify this as potentially a contributory
factor to there being a delay?
Yes, particularly in the way that the briefings - those
phrases, and you've shown them up beforehand again,
stock phrases, you know, kind of the way in which the
Post Office Legal team gave material to UKGI, which they
didn't themselves challenge. They relied on this is
representations but they could have said, "Hang on, so
is there a report? You know, can we see a report here?"
They didn't do that, so they might have perhaps been
more pressing on our behalf but that is with the benefit
of hindsight and knowing what I know now, which I didn't
know at the time.
You make some proposals for accountability mechanisms in
your statement —
Mm-hm.
~ at paragraph 255.
Mm-hm,
Can we go to that, please. It's page 66. You say:
“To my mind there are other ways by which
166
have failed provide, you know, effective service, then
that has caused obviously a terrific breakdown of trust,
not only with the subpostmasters but the wider public.
So, in effect, I'm saying here that special measures
are required, because of the failings the organisation
has gone through.
Now, that was my judgment based on my knowledge of
working with the organisation which I left my role in
relation to it in 2020. So I don't know what's happened
since, and it may be now that the Board works much
better and the Executive has rebuilt the trust with the
subpostmasters, and other people can speak to that;
you've got other evidence, I'm sure, on it. But that
was why I was thinking about some kind of external
oversight committee as a potential tool for doing that,
but I ~ it's not a straightforward matter because then
you have run the risk of undermining the Board and its
‘own responsibilities and you've got sort of guards, for
guards, for guards, and that itself, you know, can
create, can obscure the underlying reality.
Tuming, please, to consideration given to settlement of
the litigation, you've touched on this already. Can we
have on screen please paragraph 131 of the statement.
You refer here to the Articles of Association requiring
approval for any spend over 50 million -- we have
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already referred to that -- the requirements of Managing
Public Money. You say:
“It seemed possible that ongoing investment would be
needed if there was to be wholesale change required to
the subpostmaster contractual relationship with Post
Office and/or the Horizon system."
That lay behind your invitation for a representative
of HMT to attend the 17 October meeting because you saw
itas:
“The main opportunity before the trial starts to get
all of the key stakeholders together to agree a common
approach, including discussing the impact on [Post
Office Limited's] financial position, the issue of
settlement, and Post Office's approach more generally to
mitigate against the risks posed."
Mm-hm.
What was your view after that meeting of 17th October --
was it 18 October -- that October meeting, on the
adequacy of the consideration which had been given by
the Post Office to settlement?
I think their view -- and it's actually set out in the
papers both in the briefing and in the write-up from it,
was that settlement couldn't be achieved because they
were complex sort of legal contractual issues which
didn't lend themselves to a kind of a settlement type of
169
leadership to recognise the importance of settlement,
and you also referred to disappointment that it required
change of almost the entire Legal Team to get away from
the groupthink. Why do you think there was such
resistance to proper consideration of settlement to that
point?
I think it was the continuation - it's
an interpretation, so I can't say for sure but, in my
mind, it's a continuation of this quite embedded view
that the Post Office is right that the Horizon system is
correct in all possible respects, and the kind of ~ the
errors are -- user errors within the — you know, the
postmaster community. And you see that from all of that
documents, the kind of sense of "We're right and other
people are wrong".
‘And I think it was a kind of, you know, the Common
Issues Judgment in March 2019 was a sort of substantial
blow to that point of view but, actually, required fault
unfortunately, you know, both blows, both in the
judgment from the appeal court on recusal and in the
appeal itself, substantive appeal. And, furthermore, in
the second issues, which was the Horizon Issues. So
those four. They lost four times in a row and, at that
point, finally they were prepared to accept that they
were wrong.
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solution. They also, you know, were quick to point out
that, you know, by no means all subpostmasters were
party to the litigation. So there would be — you know,
it wouldn't bring finality or a complete resolution:
On the whole, I think they were mainly saying it's
too difficult, we can't do it now’. I was saying,
"You're in a hole, you're still digging”, you know. So
that was the area of debate.
You say in your statement that you also raised concerns
about settlement in early 2019,
Mm-hm.
What were your concerns and how did you seek to address
them at that stage?
I sort of kept on at the Post Office about settlement
and you could see lots of other internal documents they
have is, "There he goes, again", kind of, "Alex Chisholm
is trying to get us to settle. At the end of it, when
they brought in new management, they said -- I can see
a note from Ben Foat to Nick Read saying, you know,
“Actually, we should have settled this a long time ago,
that was a big mistake and then, you know, we'd all have
been a much better’. So that clearly was right but it
did take them two years to recognise it.
You describe your disappointment at paragraph 199 of
your statement, that it took that length of time for the
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And even that, as I've said, was partly because they
had a new Chief Executive, new legal advisers, not just
new General Counsel, new solicitors, new external
counsels. They had to change the whole lot of them.
And I suspect, I don't know, again, that a lot of the
internal advice was very much left to the Legal Team,
and the Legal team had been providing that advice for
a long period of time, and were unable to allow for the
possibility that they had been misguided in that advice
for a long period of time.
Coming please to the recusal application, could we have
on screen, please, paragraph 152 of Sir Alex's
statement, that's page 40. Here you say this:
"BEIS was unsupportive of the recusal attempt,
deeming it unlikely to succeed, and too likely to
aggravate the situation and prolong the litigation
process, which we saw as the only means by then
available of resolving the dispute definitively and to
achieving a just [solution]. Greg Clark, Kelly Tolhurst
and I all expressed ourselves in our own way but clearly
all had real reservations about the recusal.”
At 153, you add that you thought it was the right
move strategically and presentationally, as well as on
the substance.
At paragraph 156, over the page, you say:
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“It was also clear that the Department (and UKG!)
took the view that the decision was for [Post Office
Limited] as the defendant in the litigation and accepted
that it should not do a volte face on its longstanding
and well-based position that BEIS was not a party to,
nor controlling the litigation."
You go on to deal with the discussions with
Mr Cooper. Towards the bottom of that paragraph, you
say:
“I therefore said to Mr Cooper that the Department
should maintain its clearly distinct and detached
position so that it is free and credible for dealing
with the consequences as they unfold. Ministers may
want to show appropriate concer about the criticism and
may express a desire for [Post Office Limited] to act
appropriately but should not comment substantively in
ongoing litigation in which the department has a clear
interest but no direct involvement.”
Mm-hm,
You go on to deal with Mr Watson's reply, asking whether
you were:
“.. agreed that we should not try to engineer
a position whereby if the Board decided to proceed with
recusal the Minister is given a chance to object.”
You agreed that:
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“The decision did not however inhibit Mr Cooper from
conveying the Department's views and BEIS expected him
to do so. I expected that Mr Cooper would participate
in the discussion and, in doing so, relay the
Department's objections as indicate in Stephen Clarke's
(UKGI) email ... dated 19 March.
“[Your] understanding by listening to the evidence
given by Tom Cooper to the Inquiry was that he did not
participate in any discussion with the Board regarding
the recusal application as he had interpreted our
correspondence as a clear instruction to ‘stay out of
this thing’
What do you say to that, to Mr Cooper's
interpretation of your correspondence?
Yes, so I think it's absolutely the case, first of all,
that we didn’t think that ministers should take
a decision which should probably be taken by the Post
Office Limited Board. We were the, you know, the
Department responsible for correct corporate governance,
and everything else the responsibility clearly was with
the Post Office Board, so we shouldn't sort of secretly
take their decision for them or take it on and there
were all kinds of negative consequences from that. So
that's the first part.
Secondly, I'm pretty sure I didn't know ~ and as
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we should not so engineer a position -- that
would make the Department into a directing force in the
litigation, which is neither correct nor prudent.”
Mm-hm.
Do I understand your written evidence correctly in being
that, although the Department did not want to direct the
Post Office’s decision on the recusal application, you
understood that the Department's view on the application
would be communicated to the Post Office Board?
Yes. And indeed, I, you know, wrote a -- I think the
news came through of that recusal about 7.00 on a Monday
evening and by 11.00 that evening I'd written a memo to
‘Tom Cooper setting out my views in some depth and also
given a version of that to the Secretary of State and
Kelly Tolhurst. And the decision was the next morning,
that’s why I was still working late into the evening.
It was all written up at the time you can see from these
documents.
Going to paragraph 163, please. You say:
“Iam aware now that Tom Cooper was advised to
recuse himself from the meeting. I do not recall being
aware of this discussion at the time and I was not asked
then for my view as to whether Mr Cooper should absent
himself from the decision."
You say:
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I said there I'm not aware that I knew that he was
advised to recuse himself from the meeting. I have seen
some of the legal chain thereafter, you know, on that
now, which I didn't see at the time, wasn't copied to
me. It seems to have been based partly in a sense, you
know, that if a Government official was part of
a recusal, it might show lack of deference to the
judiciary, which I think is an argument, you know, it's
probably a bit of a stretch, maybe, a super cautious
interpretation
I think maybe, you know, notwithstanding that,
people said, okay, well, don't be a part of the decision
but you should certainly be part of the discussion. And
Ihave seen, again, that email chain from UKGI lawyers
and BEIS lawyers saying, "Yeah, you can make
representations, you can make people aware of the
Department's views, but, you know, don't take the
decision itself".
'm a bit unclear, even now from the evidence, what
part he did play in the discussion. I have seen the
email from Tom back to the Department reporting on the
discussion. So he was clearly in it, but it's not
a verbatim he said, we said type thing. It's just "This
is the decision we had”. It did say that in the
discussion they had gone through very carefully the kind
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of legal advice, the downsides, the issues, et cetera
So there clearly was a full discussion on it. But
I don't know what Tom himself said as part of that
discussion.
You attribute the fact that the Department's view was
not at least expressly communicated to the Board to
a failure of communication or interpretation between
BEIS and UKGI, at that next paragraph.
Given the apparent strength of the Department's view
that the application was unwise, why did you not
yourself approach the Board to provide the Department's
views?
Well, I never attended the Post Office Board, I wasn't
a member of it. We had a shareholder representative,
that was our means for conveying the views of the
Department, so I'd no reason not to have confidence in
that representative, very professional capable person to
be able to do that so -- and I didn't think there was
any real doubt about our view because I'd written
a two-page memo and given it to him the evening before
It was Kelly Tolhurst's evidence to the Inquiry that she
had understood that you were going to speak to the Board
or, if not that, it was left with you. Are you aware of
that evidence?
Yes, she's probably referring to the fact that I was
177
ourselves take the Post Office's decision for them:
Did she speak to you about the Department taking
a harder line, that is shutting down the recusal
application altogether?
She accepted the advice, and there's a readout from her
office confirming this in the documents you have, that
we shouldn't take the decision for them, and we
shouldn't put in place a second stage, whereby they
decide something and then we decide it for them, or
undecide it. We thought that was both legally incorrect
but also unwise because it would mean that, thereafter,
it would effectively become our litigation, which we
didn't wish it to be. It was the Post Office that was
defending their own track record and we wanted Post
Office to take responsibility for that and deal with the
consequences, both financial and organisational, that
would come from the outcome of that judgment.
We wanted, as you've read before, to be, you know,
outside of the fray, to be standing above it, to be able
to respond as necessary, and not to become a part of the
litigation ourselves.
Did Ms Tolhurst express any view on the need for the
Post Office Limited Board to be spoken to before the
application proceeded; did she give an instruction to
anyone to that effect?
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looking at the issue and wrote that memo to her, and to
Greg Clark, with my views. But those same views were
‘communicated in writing to Tom Cooper as our
representative.
Kelly Tolhurst had serious concems about the recusal
application; would you agree? Do you recall that from
the time?
Yes, she was concerned about it. We all were concerned
about it. We all thought it was going to make a bad
thing worse and it was going to, you know, as I've said
in the advice, that it was going to confirm in the mind
not just of the judge but the wider public that the Post
Office was in denial here and that everybody else was
wrong, rather than itself failing.
So we were very concemed about that and, also, that
the same judge would then be sitting for three more
hearings in this kind of further enraged state. So, you
know, it wasn't going to be tactically good but also
reputationally poor. She was definitely part of that.
Equally, both Kelly Tolhurst and Greg Clark accepted the
view, both from myself but also departmental lawyers,
that you could disapprove of something and convey your
concems and say, you know, "Have you thought through
all the downsides? Have you thought through this, have
you thought through that?" But that we should not
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No, I think she had a conversation herself with the
Chair on Sunday, I think. At that stage, the Chair was
‘expecting there not to be a recusal attempt. I think
the legal advice from two different QCs at that time and
from a former President of the Supreme Court arrived on
the Monday, or at least was shared and distribute on the
Monday. Everyone rushes around reading this advice and
updating their thinking. That's when I wrote my memo
saying it's going to have alll these disadvantageous
effects but it's not wrong in itself, and we shouldn't
make the decision for them. And they took the decision
on the Tuesday morning,
Ministers were advised on Monday and accepted that
they shouldn't undo the decision or try and take it
themselves. So that's the sequence that we had, and
it's clear that ministers accepted that advice, which is
why they acted as they did.
Would you accept that, whatever the reason for Mr Cooper
interpreting an instruction to recuse himself, that
seems to have led to a failure to make the views of the
shareholder or the Minister known, clearly, to the Post
Office?
It seems to be the case. Again, the record is not very
complete about the fullness of that discussion.
I wasn't a party to it myself and I know the Inquiry has
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already heard from the people who were part of that
discussion so they could speak to it better than I could
myself. I have seen ~- received the email from Tom
Cooper after the discussion, which does, you know, point
to some of the downsides being fully discussed and the
independent advice they were given, et cetera.
So there obviously was proper discussion about it
and properly advised. They obviously reached the — you
know, a different conclusion to the one that we had
reached, but that was their error.
Was there any sense in which a political interest was in
operation here, in reserving responsibility for conduct
of this litigation squarely with the Post Office?
A political interest in the sense that, you know, Greg
Clark, as Secretary of State, you know, rightly saw
himself as kind of like representing the public
interest. He didn't side particularly with the Post
Office. Indeed, probably his sympathies were more
naturally with the subpostmasters. So we way waited to
see what the outcome would be from the High Court and
wanted to be there ready to respond as fully and
effectively as possible. So I would say, you know, kind
of “interested but neutral” is the stance of we took.
After the recusal application had been unsuccessful, was
the Department more willing to be interventionist in
181
bring a fresh perspective and, so to speak, a clean pair
of hands.
So that, I think, was, you know, one of the takings
that we had or takeaways that we had from the whole
experience. We became more suspicious and less trusting
of the Post Office, sadly, and more intent on bringing
about change there, firstly with the Chief Executive and
then with the General Counsel and then with all their
external advisers, and more insistent that they should
bring about a settlement, which indeed they did, and
that that settlement should be as definitive and
comprehensive as possible and should address cultural
change within the Post Office and a renewal of their
relations with subpostmasters, which had obviously, you
know, grown into a considerable deficit.
If you had known the full picture from the Post Office,
that is you'd been sighted on all the information you
say now you should have been, would you have advised the
Minister to sack the entire Board, to adopt the
expression from your statement, the option being
considered in June 2019?
We looked at that. I think it's possible. I know that
ministers, particularly Kelly Tolhurst, sort of felt so
frustrated and disappointed with the outcome that, you
know, a sense of kind of like could we hold these
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their approach?
Yes, and indeed, you know, at that time, Kelly Tolhurst,
for one, was very, you know, concerned. She'd begun to
lose confidence and I'm afraid she'd begun to lose
confidence in UKGI's representative at that time.
I think she used the language around "going native" or
something like that. You know, identifying too close to
the Post Office. She felt the Post Office themselves
had become, you know, economical with the sharing of
information and, you know, she said that - you know,
she said that she thought that the Chair should consider
his own position. At the time the Chief Executive had
just stepped down, if you remember, and they were just
in the process of trying to appoint an Interim Chief
Executive, Al Cameron.
We then had a meeting, not only with her but with
the Secretary of State and other officials in the
Department at which we considered a range of potential
interventions, I think up to 11 and, effectively, we
took the first eight of those. We didn't at that time
choose to change the Chair. We did --it probably
reinforced in her mind and mine that, rather than.
cementing the Interim Chief Executive, who had been the
CFOO since January 2015, it would be better to look
outside the organisation to find somebody who would
182
people, you know, accountable was, you know, absolutely
‘one of the things that she was -- questions that she was
asking. I think when we looked at it a bit more and
thought about it some more, we thought, well, hang on,
who are these people, in the sense that you had
an Interim Chief Executive, and then later a new one had
come from outside. Most of the Board members had been
appointed in the last two years, and indeed, I think,
that Board renewal process continued over the next year.
So if we had chosen to change the whole Board, we'd
have got rid of, so to speak, some of the people we just
hired to bring in to bring about change, and also we
wouldn't really have had a body to then oversee that
change, which is what you ~- would obviously have been
necessary.
So I think the kind of - we changed quite a lot in
the Chief Executive and the General Counsel, and we
tightened up the oversight that was applied to them and
put in place a new framework agreement, and strongly
encouraged them to settle in the way that they did. So
I think all of those actions came from it. It's
possible that, if they had known then, ministers, that
there was a very big report, the Swift Report, which had
been withheld from the scrutiny of the Board, I think
they would have tum a very dim view of that, as would
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I. That might have tipped in favour of changing the
Chair at that time.
It's hard to say, because we didn't know, and I know
that subsequently, when that became known, the later
Secretary of State and later Permanent Secretary decided
to write kind of a letter of sanction, or censure. But
if it had happened at that time when, you know, people
were feeling so disappointed by the recusal attempt and
by the Common Issues Judgment and felt that the Post
Office was still in a kind of denialism, that might have
caused them take that change at that time.
I also think that, if the Clarke Advices that
I referred to before had become known to the Department,
that would have pointed to just egregious failings
within the Post Office because this is people being
unfairly prosecuted. I can't think of a worse thing to
do.
So, again, I think that would have absolutely made
us bring more extreme changes than occurred.
Just two short points, finally, one on the issue of
bonuses. You gave a fairly strong steer to Tom Cooper
in alletter dated 29 July 2019 —
Mm-hm.
-- in respect of bonuses. I can put the document up on
screen ifit would help you
185
criticised by the judge, and that was a contemporary
matter, even if the matters being looked at by the judge
in terms of the historic treatments were from a previous
era
So I thought that was poor judgement from Post
Office Limited, from its RemCo ~ from its Remuneration
Committee, which had independent NEDs on ~ and actually
on this occasion by UKGI itself.
So I spoke to Tom about it, and he only somewhat
agreed with me. I then had a call from the Chair
saying, “Oh, you know, everyone should be paid their
bonuses in full and, if not, they're all going to resign
and, you know, and it's a sort of semi-contractual
matter and there's reasonable expectations", and all
this type of stuff which I just didn't accept was
appropriate. And that’s why I insisted that they make
these reductions, why formally they get this letter.
‘As a matter of fact, under the then Framework
Agreement, we didn't have control over remuneration
That was a Post Office; devolved matter. If you look at
the changes to the Articles of Association made in early
2020, that's one of the things that was added to it, to
say that they would have to get our consent to
compensation, including bonuses.
So that was, if you like, a kind of a new thing that
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Thank you.
It's BEISO000085. The first paragraph goes straight in
to commenting on an email informing you of Post Office's
intention to extend performance bonuses to the Executive
and wider leadership group.
You go on to set out your reasoning for opposing
that with express reference to the Common Issues
Judgment, if we can just scroll down, please. Over the
page, please. Reference to the Common Issues Judgment,
at the top there. Then the third paragraph down, you
say:
“Taking the picture as a whole, the Department's
view is that Executive bonuses should only be paid at
a much reduced amount compared to the proposed maximum
until tangible improvements have been made.”
Was your instruction or steer ~ the word
“instruction” is used as the title to your letter, but
it appears it may have been a steer -- was it followed?
Yes, it was, but it was resisted initially. First of
all, they came seeking support for the 100 per cent
level, and I was disappointed in that from UKGI because
I thought it showed a want of understanding about what
had actually occurred, and that doing so would kind of
not involve any recognition on Post Office Limited's
part that even their conduct of the litigation was
186
was added because we felt that's not satisfactory that
they should be able to do it. Anyway, nevertheless, it
does show that they were very, very clear about our
views, and about the reasoning and that's why it set it
all through and I said "It's not just me, it's the
Minister as well", and they did reduce their bonuses for
that reason, very reluctantly and, incidentally, people
didn't resign.
That document can come down now.
Just, finally, I won't put it on the screen unless
you need to see it but you will have seen in the
documents sent to you more recently a reference to
a meeting at which there was a discussion about the
merits of a more limited review into what had happened
at the Post Office versus an Inquiry.
Mm-hm.
It seems to suggest that your view and your advice was
a more limited view was appropriate.
Mm-hm.
Is that right and, if so, why?
Yes, so my view at that time, which is also the view of
ministers, was that we'd had at that stage a lot of
findings from the High Court, because we had not just
the Common Issues Judgment but the Horizon trial
judgment as well, so between them hundreds of pages of
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findings. We actually felt at that time — not
correctly, as it turns out, but at that time we felt we
had a good picture of what had been going on and the
focus needed to be on the Post Office to make recompense
and not just financial recompense, because that is not
adequate itself, but to reform itself, see through the
organisational renewal programme, which was initiated in
August, and deliver on the three-year plan, deliver on
all the promises made to the subpostmasters as part of
the settlement, in terms of the changes to the treatment
of them.
The whole process of reform, and our concern was
that, obviously, we needed to have an independent review
right from the beginning. That was clear that would be
necessary for public confidence and necessary for
lessons to be leamed. But we were concemed that
a full legal Inquiry would take some time, and this was
a concem that we had in January 2020, and it would cost
a great deal of money, and that it would pre-occupy the
Post Office, and take most of their time in thinking
about what had happened in the past, which was
necessary, but at the expense of what they were doing
now, and the actions taken in the future.
So those were the considerations, and what I've said
to you now is exactly what I would have said in those
189
revealing, and had, if you like, opened what had been,
to some extent, a black box about the way in which the
Post Office had been proceeding. I think subsequently,
thanks to this Inquiry, which obviously became
ultimately a Statutory Inquiry, there's been much fuller
disclosure in some of the documents that we've seen
now ~ not just the Swift Report, but I mentioned
already those Clarke Advices internally -- we wouldn't
have otherwise seen.
So I'm grateful we got this full disclosure because
it's brought us to a much fuller picture. At that time
we didn't know that such bad things had been happening
within the Post Office.
Ise. You say ~ and I don't need, I think, to take
you to it unless you would like to see it, but it's at
paragraph 241, at page 63 of your witness statement.
You say, among other words but this is a direct
quotation, and it's after Mr Parker complaining that he
felt that the Government was too interventionist. But
then you say this:
"My reflection is that if we had known what was
happening within the Post Office, we would have been
much more interventionist.”
Now, I would like to concentrate on what you
actually knew at the time, not with the benefit of
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meetings to ministers, who, at the time were of the same
view. In fact, I can see a decision from the then
Secretary of State had changed and it Alok Sharma by
then and he said he thought it should be done in four
months and for a budget of £1 million.
MS PRICE: Sir, those are all the questions that I have.
There are, I think, a handful of questions from several
CPs.
Ms Watt — no? I think it may just be Mr Henry,
unless there are any other questions which I'm missing
Just Mr Henry, sir.
Questioned by MR HENRY
MRHENRY: Thank you very much.
Sir Alex, the question of what you would have done
differently sometimes invites a self-serving
justification caveated with the benefit of hindsight and
you've just been asked about why you thought a limited
review was appropriate and asked to reflect on why you
came to that conclusion.
As part of your explanation, you said that, by that
time, you felt you had a good picture of what had been
going on inside the Post Office. When did you acquire
that good picture?
I just mentioned that we had the two judgments from the
High Court because I thought they had been very
190
hindsight but what your Department then appreciated, or
ought to have known. What was, as it were, obvious at
the time and so, therefore, what you ought to have done
not based on hindsight, but based on what your
Department then knew. If refer to shorthand "you",
Sir Alex, I'm looking at the totality of the framework.
Yes.
First of all, can you help us: you stated that there was
an element of denialism that the Post Office was
demonstrating. That denialism was surely clear at the
very latest by the time of the Common Issues Judgment,
was it not?
They had expected to do much better in that litigation
than turned out to be the case, and the judge was very
critical, as you know, and I've already spoken about.
I think their instinct was that that was a mistake with
the judge, rather than a mistake with them, and that's
why they brought the recusal attempt and, as we've
discussed already, we thought that was misguided and it
tured out to be. They also appealed it. The appeal
was on slightly more legal grounds, more technical
grounds but, nevertheless, that too failed.
So I think, by this time, which is October 2019, you
had good evidence that the old Post Office was mistaken.
At this time, we had a new Chief Executive who was
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appointed the month before that, and he was putting in
place considerable reforms and, with encouragement from
us, was on the point of tying to settle the ongoing
litigation to the satisfaction of the subpostmasters.
Well, let's try and detach it from the merits, as it
were. So you're saying that it was perhaps clearer by
October, not by, let's say, 15 March 2019, but let's
just concentrate for a moment on the costs, and I'm not
going to ask you to be precise to every pound, shilling
or to every penny. But your Department was facilitating
this defence, wasn't it, financially?
No, it wasn't.
It wasn't at all?
No. We already heard some evidence that mistakenly,
they'd used 2.4 million of departmental money on
litigation and that had to be repaid.
I know that got repaid but, overall, when one looks at
the way the Post Office was expending money, did it not
concer you about the legal expenses that it was
expending on this, particularly given the remarks made
by Mr Justice Fraser, as was, about the cost of the
litigation and the manner in which the trial was being
litigated?
It was with their own resources but I was concemed,
which is why I had been pressing for settlement for
193
us more information and put in place the framework of
oversight that applied to them:
‘And to the question should we have ordered them or
directed them to make a settlement? I think at that
time it's not clear we had the legal authority to do so.
You're probably aware of the Articles of Association of
2002 included a power of direction that had been removed
in 2013, was reinstated in 2020 during my time.
But that wasn't in place at that time, so we
wouldn't actually have been able to do that. We could
have tried in some other means to try and get them to
see that they needed to settle. We tried pretty hard on
that, at every meeting I had with them, pretty well.
They had, you know, respectable legal reasons for
saying that they needed to pursue the litigation. They
were convinced that they were right but also that
questions of precise the definitions about the duties
responsible under contract law were things which perhaps
did need to be adjudicated in a High Court, rather than
by means of a settlement.
‘As soon as they had had the Common Issues Judgment,
I felt that's when they should have been moving into
settlement. That's when they were in a period of
denialism, as I've called it, with the recusal and
appeal attempt, and that used up, you know, more time,
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a year at that time.
Q. Right. Now, on that subject about pressing for
settlement, do you, on reflection, feel that you ought
to have been more prescriptive and directive about that,
based upon a number of factors? I want to come to them
first of all, POL's longstanding refusal to share
information. It did not welcome scrutiny or
accountability, did it?
A. I didn't get that impression, no.
Q. You didn't get that impression, but you have spoken
about it being resentful about sharing information, and
also the information protocols we have seen --
‘A. Apologies, we're confusing -- I'm confusing myself or
you with my double negatives. Yes, my impression at the
time was that they did not welcome scrutiny.
Q. Ido apologise. Thank you.
So that must have been a red flag of which you were
aware at the time.
A. Yeah, they didn't refuse to give us information but
I became aware over time of this pattern of, as I tried
to describe, stock phrases and rationing of information,
a wariness -- an “institutional wariness" is the
expression I used there ~ and that was indeed
aconcem. That's why we became more and more involved,
and that's why we tightened up and required them to give
194
more money, unnecessarily, and delayed justice by
a further five or six months.
SIR WYN WILLIAMS: Can I just test that with you, Sir Alex.
A Yes.
SIR WYN WILLIAMS: Just in as neutral a way as possible. By
reference to the timetable in 2019, so at the Common
Issues Judgment, March, I believe ~
A. Yes
SIR WYN WILLIAMS: — am I not right in thinking that the
Horizon Issues trial was due to begin within weeks of
that?
A. Yes.
SIR WYN WILLIAMS: And in fact did take place within a few
months of the Common Issues Judgment?
A. Yes.
SIR WYN WILLIAM
litigation of this kind, where everybody has, I think,
acknowledged that there was more to any settlement than
So it's not impossible I know but, in
simply a financial amount —
A. Yes, and that was the point that —
SIR WYN WILLIAMS: -- where was the actual window of
‘opportunity for a settlement prior to Horizon Issues.
trial beginning?
A. Yeah, it's a very good question, Sir Wyn, and I don't
think there is a precise answer where there was
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a perfect moment. And, indeed, I think, you know, it's
more a waxing and waning. There are various points
where there were -- so-called windows of opportunity for
settlement opened up. I felt there could have been one
potentially immediately after the Common Issues
Judgment.
The Post Office for themselves decided that they
wanted to bring a recusal attempt and an appeal, which
I think was launched in May. So then we got the
judgment from the appeal -- they got the judgment for
the appeal in November, I think. So the whole of
Issue 1, the Common Issues Judgment, was before the
appeal court until that time. As you rightly say -
SIR WYN WILLIAMS: That -
A. As you rightly say, meanwhile the Horizon Issues
hearings were under way. The questions which everybody
wanted to get to the bottom of was, you know, was this
system as good as they said it was; were there problems,
were there errors? There was a lot of technical
evidence there, a lot of asking ~- Fujitsu, were
obviously on the stand, who largely built the system in
the first place and maintained it.
So there was, I think, you know -- you are right to.
say, to point out very gently there possibly a public
interest in allowing those proceedings to bring their
197
his judgment in the Common Issues Judgment in March
SIR WYN WILLIAMS: So I just wanted to kind of test ~ and
thank you for your assistance — what actually happened
in 2019, in terms of how likely it was that a settlement
could have been achieved much more quickly, let's put it
in that way, than it actually was. So thank you for
that.
I'm sorry to take over, Mr Henry.
MR HENRY: No, thank you very much, sir. I'm very grateful.
So-
SIR WYN WILLIAMS: Finally, from me, this question of
direction, which Ms Gratton and I had a discussion about
this moming. The trouble is that it takes two people
to settle, doesn't it?
A. Yes.
SIR WYN WILLIAMS: So even if you'd said to the Post Office,
“We direct you to enter into settlement negotiations’,
it may or may not have happened, is the reality?
A. I think, again, that's a very fair comment, Sir Wyn.
‘And, you know, again, when we look at the terms of the
settlement it's not just — it’s by no means, you know,
only financial. Indeed, it's very interesting. And
indeed in the — you know, I was looking at the press
release issued afterwards as well, when I think Alan
Bates, you know, includes a quote saying that he'd -
199
1 natural course. I remained the whole way through of the
2 view that the Post Office was losing, and the longer
3 that they persisted, the worse it was going to be for
4 them, for the postmasters, for their -- you know, their
5 customers, their future reputation, and I think that was
6
7
8
borne out by the turn of events.
So, ultimately, they did actually settle. I think
after they'd had the embargoed judgment on Horizon
9 Issues, the settlement came in December, and they'd
10 had ~- the embargoed judgment had been given to their
"1 counsel and also to the subpostmasters bringing the
12 claim. So both parties, when they settled, new by that
13 stage that the JFSA, the claimants, had won not once but
14 four times: both the first two hearings and in the
15 recusal and in the Appeal Court, and it was settled in
16 most terms.
17 SIRWYN WILLIAMS: I'm sure you've got that right but, even
18 on that, if I may say so, the mediation process which
19 led to the settlement, had been started in the sense of
20 being discussed between the lawyers and the setup before
21 you had the embargoed judgment. I just want to make
22 sure I have ~
23 A. Yes, and that's right, and perhaps I could just draw
24 your attention to the fact that it was actually
25 a recommended mediation from Justice Fraser, as part of
198
1 you know, the thing that he talks about is actually not
2 the financial settlement. He says, "Look, you know, at
3 last the Post Office have recognised that they need to
4 kind of overhaul themselves and treat subpostmasters in
5 a different way"
6 And there's a whole schedule to finding all the
7 different things the Post Office needs to do to
8 implement that plan, as well, of course, as the
9 financial value of the settlement itself and the promise
10 of the Horizon Shortfall Scheme, all of which is set out
"1 as part of the settlement. So it was quite
12 ‘comprehensive, but I think what you're hinting at is
13 that it might not have been possible to actually achieve
14 that much before the time of settlement was actually
15 achieved.
16 SIRWYN WILLIAMS: That's all I'm saying because I'm
17 conscious -- and this is quite deliberate on my part, so
18 let nobody be under any misapprehension about this ~ we
19 are only hearing the Post Office side of the litigation.
20 A. Yes.
21 SIRWYN WILLIAMS: We haven't heard evidence, you know, from
22 Freeths or any of the claimants or anything like that,
23 about how they were viewing all of this. So I've just
24 got to be a bit careful, if I can put it in that way.
25 A. Okay.
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MR HENRY: Sir, very quickly -
SIR WYN WILLIAMS: Have you got anything else?
MR HENRY: Yes, thank you very much.
So you accept that there was a window of opportunity
before Horizon issues, but you were observing the trial.
A. We just heard from Sir Wyn there may not have been, but
we were certainly saying the whole away along, "Take
every opportunity you can to try to settle”.
Q. Exactly. You were obviously observing the trial, you
had a ringside seat, and it was your impression that it
was not going well —
A. So the —
Q. ~is that right?
A. Somewhat, yes. So ~I mean the hearings were going on
I think from November 2018, and certainly I would get
reports from them saying Justice Fraser seems very
unimpressed by the Post Office witnesses. So things
like that. I wasn't, you know, obviously attending the
trial or reading all the transcripts at the time, but
when the — and he was very certainly critical, I think,
in the nature of his questions. You could see that he
was unsatisfied.
I think, nevertheless, when the actual judgment came
on 15 March, it was, I think, quite a shock for a lot of
people because it was so critical in so many different
201
a Framework Agreement all in place, that looks like
quite a solid piece of governance, and we obviously
improved that in my time in the Department.
However, no structural solution can fully deal with
the realties of the situation which depend on the
quality of the people you have in there, and their
dealings with each other. So I think -
Q._ So, in other words, the last sentence of that paragraph:
“The Board had the prime responsibility for the sum
conduct of the Post Office and manifestly failed to
discharge this."
So that's bad actors, as it were, concealing
information from you?
‘A. The Board themselves do not appear to have had all the
information they should have had. I mean, we've heard
already about the Swift Report not being given to them.
Q. Absolutely. But can I just ~ and this was coming to
the very last thing from me -- Swift was originally
Baroness Neville-Rolfe's idea. Do you not think that
your Department ought not to have lost track of that
because this was originally an idea coming from the
Minister that there should be a QC-led review to assist
Mr Parker on his succession as Chairman?
SIR WYN WILLIAMS: Sorry, Mr Henry, is that quite right? It
was Baroness Neville-Rolfe's idea to have a review. It
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ways of the Post Office. It hadn't simply tried to
answer the questions about where the responsibility lay
from a contractual interpretation point of view, the
sort of technical issues before the Common Issues part
of the litigation, but had actually made a lot of really
critical remarks about the Post Office and their
witnesses themselves, and that went a lot further. And
also, the Post Office lost on practically every count,
which, again, is comparatively unusual.
Q. So, last question. Your page 65 of your statement, Sir
Alex, paragraph 249. You said this:
“I do not consider that there is something
inherently defective in the governance structure of the
Post Office.”
Doesn't that sit ill with what you have said earlier
about not knowing what was going on inside the Post
Office?
A. Well, yes and no. So I think it's an interesting
question. I think at the - what I would say is that
the set-up of having a public corporation with Articles
of Association, with a Memorandum of Understanding, with
a specialist body providing oversight ~ at that time
UKGI — with additional reinforcement from the Post
Office Policy Team and the Department, with defined
residual powers given to the Secretary of State, with
202
was -- I think I'm right in saying -- Mr Parker's idea
to instruct a silk to assist him.
MRHENRY: I'm so sorry, sir. It arises ~ I will provide
Counsel to the Inquiry with the —
SIR WYN WILLIAM
me right with ~
MRHENRY: Yes, definitely. That was my understanding of
her intention at the time, and we will find the document
and supply it
What I'm trying to suggest is that there are
a series of oversight failures by the Department, and
that you had found yourself, as it were, in a classic
‘frog boiling’ analogy and that, over a period of time,
Yes, if 'm wrong about that, you can put
you gave too much latitude. You were thereby
compromised and then, ultimately, this resulted in
a disaster; what do you say to that?
A. I don't recognise those phrases or that description, no.
SIR WYN WILLIAM
I think you've had two last questions now, so that's
quite enough.
MRHENRY: Thank you, sir.
SIR WYN WILLIAMS: Is that it, Ms Price?
MS PRICE: Itis, sir.
SIR WYN WILLIAMS: Well, thank you very much, Sir Alex, for
making a detailed witness statement and for giving
204
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(51) Pages 201 - 204
The Post Office Horizon IT Inquiry
evidence during the course of this afternoon. I'm very
grateful to you.
THE WITNESS: Thank you
SIR WYN WILLIAMS: So, tomorrow moming at 10.00?
MS PRICE: Yes, sir.
‘SIR WYN WILLIAMS: Fine, thank you very much.
MS PRICE: Thank you.
(4.42 pm)
(The hearing adjourned until 10.00 am the following day)
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INDEX
LORNA RACHEL GRATTON (affirmed) .......0. 1
Questioned by MS HODGE
Questioned by SIR WYN WILLIAMS 7
Questioned by MR JACOBS ......... 79
Questioned by MS PATRICK... 88
Questioned by MS WATT ces 94
SIR ALEXANDER JAMES CHISHOLM KCB (swont)3
Questioned by MS PRICE .. 103
Questioned by MR HENRY .........0..00000 190
206
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1 2 24 September [2] 8
MRHENRY: [7] 1 billion[1] 113/9 I2 October [4] 127/20 I 79/6 92/15 8 January [1] 117/2
190/13 199/9 201/1 I4 million [4] 190/5 I 2.00 [2] 101/3 1017 [241 [1] 191/16 84 [2] 24/13 24/25
201/3 204/3 204/7 I4,000 [1] 85/16 2.14 [4] 146/11 248 [1] 162/19 —
204/21 1,500 [4] 40/19 2.2 [4] 1408 249 [1] 202/11 9
MR JACOBS: [5] I1.2 [4] 139/18 2.3 [4] 145/3 255 [1] 166/22 9 March [1] 49/6
79/19 79/21 79/25 I4.8 [1] 140/4 2.3 million [2] 119/3 I27 [2] 80/5 132/13 99 14) 43/13
86/11 88/3 10 [1] 121/14 119/8 28 March [1] 50/5 I 99 per cent [1] 85/15
MS HODGE: [18] 1/3/10.00 [3] 1/2 205/4 I2.3m [2] 117/21 29 February [2] 93 [1] 88/16
4/5 1/8 1/14 1/20 38/2I 205/9 117/23 26/28 27/3 97 [1] 93/1
38/8 38/13 38/15 I10.25 [1] 83/22 2.4 million [2] 119/3 I29 July [1] 185/22 _I98 per cent [1] 85/18
40/14 70/11 70/18 I 10.53 [1] 38/10 193/15 3 99 [1] 2/2
70/22 70/24 77/6 94/8I100 [2] 165/6 186/20 I2.4m [1] 117/14 3 Januaw ti) 115/13
400/18 101/3 100 per [1] 9/19 I20 December [1] sen ey 115/13 IA
MS PATRICK: [2] [103 [1] 80/7 115/18 330 [2] 154/3 154/9 ability [5] 15/11 17/4
88/7 94/6 14 [2] 107/16 182/19 I2002 [1] 195/7 30 [1] 142/18 48/2 56/7 165/24
MS PRICE: [16] 11,500 [4] 114/11 2005 [1] 2/14 30 September [1 able [19] 26/6 49/22
101/9 101/14 103/11 I41.00 [1] 174/12 2006 [1] 105/22 127/16 rt] 58/4 59/16 59/21
103/14 103/17 111/15/11.05 [2] 38/8 38/12 I2010 [2] 2/17 111/19 I34 19) 44/00 1239/4 60/19 81/12 91/18
132/3 153/24 154/3 I11.56 [1] 70/19 2012 [1] 140/10 154/12 95/1 95/12 97/17
154/6 154/10 154/12 /113 pages [1] 2/1 I2013 [7] 3/2106/1 I 32 ra Ye iog 121/12 125/11 126/19
190/6 204/23 205/5 I415[1] 154/13 132/20 133/16 136/12I 34 a 450/22 164/11 177/18 179/19}
205/7 12[3] 80/6 107/16 I 145/6 195/8 oa eed 188/2 195/10
MS WATT: [2] 94/11] 109/13 2015 [6] 8/5 133/4 I37 ay 147/19 about [209]
100/17 12 months [1] 85/17 I 133/8 136/13 142/11 I35 ay 122/16 above [6] 109/18
SIR WYN WILLIAMS:I12.10 [2] 70/17 70/21 I 182/24 39 [2] 24/13 97/8 121/15 126/24 132/17
[56] 1/41/6110 = I42.53 [4] 101/5 2016 [8] 3/4106/3 IS HAE SIS STI _I 159/19 179/19
1/16 38/6 38/9 38/14 I129 [4] 150/21 106/12 107/15 111/20I4 absent [1] 174/23
40/6 40/1140/13 [43 April [4] 106/14 I 123/13 135/9 141/23 I4 900131 108/6 109/4 I absolute [2] 117/20
70/17 70/23 77/9 78/5I13 September [1] I2017 [1] 115/18 viremia 10816 109/4 16116
78/8 78/17 79/9 79/17] 1/23 2018 [18] 108/9 4.42 [1] 205/8 absolutely [23] 5/3
79/20 86/4 88/5 94/7 I13.6 billion [1] 115/13 120/4 130/22 I 49 [4] 86/18 107/19 20/23 30/5 46/7 48/12
94/9 100/20 101/1 108/11 130/25 132/5 137/25 I 4098/7 172/13 67/5 69/25 75/14 77/3
101/4 101/8 101/11 I434 [1] 168/23 138/24 139/3 139/14 I 49,900 [3] 108/24 85/22 112/8 118/13
101/15 103/12 131/2 I14 December [1] 154/15 155/16 156/8 I 49/6 109/7 126/2 135/6 135/11
132/2 154/1 154/5 I 81/22 157/23 157/24 159/16 I 4g.odd [4] 162/2 136/1 136/3 143/6
154/11 196/3 196/5 I14 October [1] 104/2I 160/16 201/15 42 [1] 23/15 152/25 175/15 184/1
196/9 196/13 196/16 I15 [4] 15/4 16/24 I2018/2019 [1] 104/18 45 14) 109/13 185/18 203/17
196/21 197/14 198/17I 107/23 109/5 2019 [21] 4/14 on absorbed [1] 157/14
199/2 199/11 199/16 ]15 March [1] 201/24 I 104/18 108/9 117/2 I5 AC [1] 49/17
200/16 200/21 201/2 /15 March 2019 [1] I 122/22 124/17 127/16I5 july [1] 55/9 _—_—~(I Accenture [10] 61/10
203/24 204/5 204/18 I 193/7 129/17 150/1 156/5_ I5 September [1] 61/12 61/15 61/15
204/22 204/24 205/4 I450 million [1] 52/6 I 156/8 161/1 164/24 I 196/12 61/20 61/23 62/3 62/9
205/6 152 [1] 172/12 170/10 171/17 183/21I50 million [2] 126/6 I ©2/22 62/24
THE WITNESS: [3] I153 [1] 172/22 185/22 192/23 193/7 I 168/25 accept [7] 26/15
77/7 100/25 205/3 156 [1] 172/25 196/6 199/4 561 [1] 140/5 26/16 95/4 171/24
OO (I163 [4] 174/19. 202 [1] 88/22 ——__—_—___I 180/18 187/15 201/4
168 million [1] 2020 [7] 3/9 106/14 I6 acceptable [2] 26/17
‘20 [1] 129/17 104/18 153/16 168/9 187/22 I6,500 [1] 98/12 155/4
23 [1] 81/18 17 October [2] 189/18 195/8 60 per cent [1] 97/9 Iacceptance [2] 46/3
‘24 [1] 152/22 139/14 169/8 2021 [3] 3/1253/9 I 600,000 [2] 42/25 I 50/7
"25 [1] 79/3 17th October [1] 81/13 44/15 accepted [7] 119/6
frog [1] 204/13 169/17 2022 [2] 81/16 81/22 I63 [1] 191/16 119/19 173/3 178/20
‘Justice [1] 140/11 I48 [4] 120/22 2023 [7] 3/18 48/18 Ig5 [2] 162/20 202/10 I 179/5 180/13 180/16
‘need [1] 154/18 18 April [2] 51/15 —_I 49/6 50/21 51/16 55/9/66 [1] 166/24 accepting [1] 126/1
‘negotiated’ [1] 44/3 I 51/21 64/21 68 [4] 104/3 access [6] 45/13
‘novel [1] 128/3 18 October [1] 2024 [5] 1/1 26/24 = I>— 90/12 136/23 152/11
‘s [1] 123/1 169/18 30/4 104/2 153/1 155/17 158/25
‘stay [1] 175/11 19 [1] 23/14 21 [1] 132/16 7 November 2024 [1] Iaccessible [1] 167/4
‘take [1] 81/7 19 March [1] 175/6 I210m [1] 104/19 1 accordance [2]
‘unfairness’ [1] 199 [1] 170/24 22 [1] 132/16 7.00 [1] 174/11 115/22 128/8
146/15 1990 [1] 105/16 23 [4] 86/13 104/13 I75,000 [1] 89/22 according [2] 23/8
1996 [1] 105/19 109/21 153/18 126/25
(53) MR HENRY: - according
INQ00001203
1NQ00001203
A actions [8] 29/22 195/19 afternoon [10] 70/22 I 103/4 103/12 103/17
accordingly [1] I 85/10 129/10 142/22 Iadministration [6] I 94/11 100/23 101/10 I 105/5 127/23 128/1
129/15 151/19 153/8 184/21 I 38/18 38/21 38/25 I 101/11 153/25 154/4 I 131/3 154/12 170/16
account [7] 4/25 9/9 I 189/23 40/8 45/24 105/15 I 154/10 154/11 205/1 I 190/14 192/6 196/3
14/22 114/18 119/16 Iactive [1] 25/14 administrative [3] I afterwards [1] 202/11 204/24
4138/7 165/19 actively [1] 120/12 I 22/20 39/19.47/17 I 199/24 Alex's [5] 105/4
accountability [8] activities [3] 35/4 I adopt [2] 42/21 again [35] 16/23 121/13 150/22 162/20
98/7 109/11 109/25 I 38/11 116/8 183/19 38/14 46/2151/13 I 172/12
157/10 166/19 1671 Iactivity [4] 57/25 Iadopted [3] 39/5 79/25 87/16 89/21 I ALEXANDER [3]
167/14 194/8 58/3 58/5 63/9 42/23 73/13 110/10 113/22 118/16I 103/15 103/18 206/14
accountable [16) [actors [1] 203/12 adoption [2] 44/9 I 119/7 119/17 126/17 Ialigned [2] 9/21
10/20 10/21 17/14 \acts [1] 92/24 44/19 127/6 135/7 136/17 I 83/14
17/15 18/17 108/3 {actual [5] 24/18 advance [2] 44/4 136/19 138/12 140/4 alignment [1] 22/9
409/16 11078 110/11 I 42/10. 1005 196/21 I 103/23 142/16 145/3 147/5 I alike [1] 113/18
410/43 110/17 115/8 I 201/23 adverse [1] 147/22 I 150/15 152/16 157/3 I Alisdair [2] 49/17
119/23 127/6 128/13 Iactuality [3] 149/15 advice [45] 17/4 46/5I 166/2 166/9 170/16 _ I 128/18
4184/1 152/14 153/23 53/17 85/1 87/1 87/5 I 172/5 176/14 180/23 Iall [98] 1/12 8/8 15/3
accountants [1] actually [50] 10/18 I 87/11 89/7 89/10 185/18 199/19 199/20) 31/5 32/23 33/10
12/12 23/20 32/23 I 90/13 90/18 90/20 I 202/9 35/19 38/6 47/3 47/4
33/21 42/9 58/8 75/8 I 90/23 91/7 91/7 91/13) against [9] 11/11 51/3 65/24 67/3 68/15)
76/21 80/21 90/22 91/13 91/14 91/20 61/6 71/10 77/21 69/18 70/10 70/17
95/7 97/14 97/20 97/19 111/2 126/18 I 116/6 132/14 140/15 I 77/18 78/5 81/7 85/13,
accounting [25]
17/16 17/19 47/5
107/6 107/25 108/2
40916 14671 1107/5 I 98/14 99/6 100/10 _I 129/21 130/10 133/9 I 147/23 169/15 87/2 90/7 92/7 95/14
tore 110/9 tole I 114/8 123/10 125/16 I 135/6 138/14 143/3 Iagencies [3] 108/10 I 95/16 95/19 98/9
tae 1117 131g I 134/1 134/24 136/18 I 1541/1 151/6 153/3_I 108/25 112/8 98/13 98/13 98/18
Tals 1414/6 11614. I 136/22 139/12 141/9 I 155/22 157/10 163/10I Agency [2] 22/8 100/3 100/3 101/4
1156 11e/10 12/9 I 190/2 150/5 158/3_ I 172/6 172/7 17219 I 22/15 4102/8 108/25 109/20
428/16 134/21 136/10] 160/6 162/13 162/15 I 17/1 178/11 179/5 Iagenda [2] 49/7 110/21 110/22 112/16
iors 164/1 164/24 169/21 I 180/4 180/7 180/16 I 55/18 4113/2 114/6 125/2
accounts [13] 107/12 170/20 171/18 186/23] 181/6 188/17 aggravate [1] 172/16 I 125/16 125/24 126/10}
TOBY 11/25 114/24) 187/7 189/1 191/25 IAdvices [5] 135/5 _ Iaggressive [2] 30/19I 126/13 127/7 129/8
top 119i talto I 195/10 198/7 198/24 I 151/6 152/20 185/12 I 31/1 130/12 132/3 143/3
Harte 149/17 112/20) 199/3 199/6 20011 I 191/8 ago [6] 30/12 71/13 I 149/2 150/14 152/11
HID4 119/10 113/20] 200/13 200/14 202/5 ladvise [1] 130/10 I 92/15 92/21 155/23 I 153/12 13/20 154/5,
accurate [2] 74/19 Iaeutely [1] 67/1 advised [7] 50/5 170/20 154/15 158/13 158/17,
tag/8 adamant [1] 67/5 I 162/17 174/20 176/2 Iagree [7] 85/22 93/21] 159/8 162/11 163/20
achievable [1] 7/7 {44 [2] 68/7 172122 I 180/13 181/8 183/18 I 98/17 118/12 118/13 I 166/5 169/11 170/2
achieve [3] 5/17 added [5] 24/15 Jadvisedly [1] 77/20 I 169/11 1781/6 170/21 171/11 171/13
IG SOOM 25/22 68/5 187/22 advisers [4] 144/6 Iagreed [15] 40/23 I 172/20 172/21 174/17
188/1 156/12 172/2 183/9 I 42/22 43/4 44/1 44/4 I 175/15 175/23 178/8
achieved [5] 30/3 46/18 46/25 48/4 178/9 178/24 180/9
41/21 169/23 199/5 I@ddition [7] 20/24 adh
200/15 63/1 109/24 110/24 I Adi 49/21 155/3 158/3_ I 183/8 183/17 184/21
achieving [2] 151/11 I 11821 132/17 167/16 advisory [1] 1217 I 164/1 173/22 173/26 I 186/20 187/12 187/14
172/19 additional [8] 18/9 _Iadvocated [1] 56/22 I 187/10 188/5 189/9 190/6
acknowledge [4] 21/2 52/12 67/22 75/9\ affect [4] 24/21 25/2 Iagreeing [1] 117/17 I 192/8 193/13 194/6
424 15/19 5/18 65/5) 101/22 167/19 202/23] 25/4 46/9 agreement [13] 200/6 200/10 200/16
acknowledged [2] I@ddress [8] 47/21 affected [2] 60/15 I 15/12 15/20 36/14 I 200/23 201/19 203/1
sor? 196/18 48/14 57/4 59/22 80/2 52/25 114/8 1526 I 203/14
acquire [1] 190/22 I 75/13 150/3 170/12 affecting [2] 145/13 I 157/25 161/4 161/9 allegations [6] 55/10
across [11] 41/5 41/6) 183/12 146/8 161/17 184/19 187/19I 61/6 63/13 71/16
56/13 66/4 155/8 [addressed [3] 90/13 affirmed [2] 1/18 I 203/1 141/17 141/20
186/23 160/4 162/6 I 92/3 147/17 206/2 agreements [2] 15/9 Ialleged [3] 140/25
462/21 165/4 167/11 [addresses [1] 117/3 Iaffording [1] 12/23 I 15/11 146/15 147/7
act [5] 35/24 4118 [adds [1] 167/18 afraid [7] 23/22 51/10IAh [1] 79/21 alleging [1] 61/2
93/19 127/3 173/15 [Adequacy [1] 169/19 I 55/6 60/1 82/6 90/15 Iaid [1] 145/21 Alliance’ [1] 140/12
acted [1] 180/17 [adequate [2] 54/22 I 1821/4 aim [1] 44/1 allied [1] 77/17
acting [5] 68/14 189/6 after [21] 27/12 27/19] Al [3] 110/14 117/20 Iallow [2] 81/3 172/8
Tale 92/8 127/10 _ IAdequately [3] 8/19 I 52/14 58/18 70/15 I 182/15 allowed [1] 97/21
16177 18/3 95/22 72/3 105/13 129/23 IAlan [1] 199/24 allowing [1] 197/25
action 7] 57/4 75/13 [adiourn [1] 1014/1 I 131/8 143/23 146/6 alarm [1] 141/18 almost [9] 22/2 23/1
77/21 4133/6 133/24. adjourned [1] 205/9 I 149/6 155/3 16/6 I ALB [1] 167/11 48/5 99/25 102/20
134/12 152/19 Adjournment [1] 156/7 169/17 181/4 albeit [1] 63/18 133/19 161/18 163/16
actioned [1] 151/17 I 1016 181/24 191/18 197/5 IALBs [1] 167/1 17113
adjudicated [1] 198/8 Alex [15] 102/23 Alok [1] 190/3
(4) accordingly - Alok
INQ00001203
INQ00001203
A 174/20 196/9 205/9 I 200/18 200/22 appointing [2] 75/18 I 52/24 53/2 53/4 53/23
along [6] 101723 IAmanda [1] 11/7 anybody [2] 1039/8 I 120/16 54/4 55/11 55/16 57/9)
14779 156/14 161/17 [amazed [1] 135/11 I 155/5 appointment [12] _I 61/19 61/24 63/12
164/18 2047 ambit [1] 56/17 anyone [4] 65/24 _I 25/7 48/19 57/21 62/3I 63/14 65/7 65/16 66/1
alongside [1] 34/11 ambition [1] 5/16 86/24 95/18 179/25 I 72/6 72/10 72/13 66/7 66/23 67/5 68/1
already [22] 14/25 amended [1] 81/21 Ianyone's [1] 135/25 I 72/16 73/12 89/15 68/8 68/9 68/16 68/19
44/10 71/3 76/5 96/5 Iamends [1] 119/20 janything [13] 18/10 I 110/13 128/14 68/20 69/18 69/23
118/24 138/19 138/24/@mong [1] 191/17 18/11 21/15 21/25 appreciate [1] 158/6 I 70/2 70/4 75/18 75/22
143/25 152/2 152/19 Iamount [16] 8/21 74/17 78/25 126/10 Iappreciated [2] 62/7 I 76/2 76/10 76/10 77/3
24/16 28/18 39/20 I 128/3 129/10 155/24 I 192/1 77/4 77/13 79/6 80/9
tears leoignn 40/20 45/17 45/21 I 159/20 200/22 201/2 Iapproach [27] 15/9 I 82/15 82/21 83/7
19118 192/15 192/19 I 26/9.46/13 46/14 I anyway [4] 1/7 30/17 37/4 39/5 39/25) 83/12 85/20 86/2
193/14 203/16 47118 69/16 97/16 I 102/21 119/4 188/2 I 40/3 41/15 41/17 42/2I 90/19 91/18 92/5 94/8
also [92] 16/2 19/7 I 125/25 186/14 196/19] Apartheid [1] 161/21 I 42/22 42/23 43/23 I 95/17 95/18 95/24
19/23 23/8 25/11 28/gIamounts [4] 25/22 apologies [2] 110/10 I 44/3 44/13 47/10 96/17 96/24 97/4
33/4 34/5 5/4 5/4_I 31/5 39/16 40/3 194/13 47/11 47/14 57/3 68/9] 97/14 97/24 98/6 98/9
53/28 60/20 61/5 Ianalogy [1] 204/13 I apologise [3] 28/23 I 68/16 73/11 88/17 I 98/22 101/8 103/2
81/24 75/9 76/4 76/7 [analysis [1] 22/7 I 91/8 194/16 90/18 169/12 169/14 I 104/23 104/25 105/11
76/12 76/18 81/1 81/3/Andrew [1] 72/16 apparent [6] 40/15 I 17/11 182/1 106/23 111/5 111/7
85/14 87/17 89/6 93/3 anniversary [1] 40/16 78/12 146/23 Iapproaching [1] 4411/7 114/13 116/7
98/14 99/22 101/20 I 93/18 150/11 17/9 39/18 116/16 118/22 127/8
107/10 107/18 108/6 [announced [2] 37/17 Iapparently [1] 96/14 I appropriate [18] 129/3 132/8 134/24
tue 1117 13/4. I 81/19 appeal [15] 82/4 10/12 11/17 29/19 I 141/6 146/19 156/25
413/21 114/11 119/15/4NMOuncement [2] I 88/25 129/25 149/19 I 30/25 41/17 45/9 158/24 161/16 161/18
424/04 128/25 12677 I 92/5 13/7 153/17 171/20 171/21I 61/24 86/6 86/22 163/20 164/14 164/19
126/16 126/19 130/4 [annual [2] 5/20 69/10) 171/21 192/20 195/25) 87/15 96/25 133/6 166/25 167/3 168/5
430/10 130/15 133/12! annually [2] 26/5 197/8 197/10 197/11 I 133/24 134/12 173/14) 171/12 171/15 177/23,
434/18 134/19 138/4 I 1987/8 197/13 198/15 187/16 188/18 190/18I 184/5 190/6 190/7
137/19 138/6 139/16 (another [12] 16/2 appealed [1] 192/20 Iappropriately [2] 190/10 197/2 197/23
qaait6 143/6 143/10 I 24/3 33/14 38/15 appeals [1] 89/23 I 38/1 173/16 200/19 204/10
56/14 70/13 83/3 appear [7] 40/23 approval [6] 52/9 —_ area [3] 72/5 128/1
ree agbs eon 85/14 113/11 144/19 I 77/19 7/20 103/11 I 69/15 87/23 87/25 I 170/8
452/4 152/15 155/11 153/11 164/15 118/8 132/6 203/14 I 126/4 168/25 areas [6] 33/5 33/6
456/12 161/11 161/13) answer [8] 49/19 appeared [3] 111/12 Iapproved [3] 53/6 142/21 145/9 147/20
1463/3 163/19 164/10 80/21 81/12 99/17 125/1 143/9 116/8 167/1 147/21
1464/11 164/18 165/15 137/17 142/10 196/25I appearing [1] 155/12 Iapproximately [2] aren't [6] 29/18 30/24)
165/25 167/9 170/11 I 202/2 appears [3] 65/2 83/1) 108/6 114/11 85/21 95/3 97/14
170/9 171/2 173/1 answered [2] 21/9 186/18 April [8] 51/12 51/15 I 100/13
174/13 178/15 178/18) 42/12 appetite [6] 19/11 51/20 51/21 93/18 argue [1] 119/13
1478/21 179/11 184/12 answering [2] 94/17 I 22/10 22/24 23/2 23/3I 106/14 106/20 129/17I arguing [3] 40/2
485/12 188/21 192/20 100/22 23/5 April '20 [1] 129/17 I 138/12 148/6
494/12 195/16 198/11/answers [2] 66/25 applicants [9] 44/16 IArbuthnot [1] 140/13/argument [2] 40/19
202/8 78/17 88/18 89/8 89/9 89/22IARC [1] 18/8 176/8
anticipate [4] 37/13 I 89/25 90/14 90/19 are [174] 4/23 4/24 Iarguments [2] 122/5
alteration [1] 78/10
altered [1] 146/19 37/24 70/14 126/6 91/15 5/14 6/5 6/20 6/24 147/16
alternative [2] 45/12 anticipated [4] 46/2 Iapplication [13] 91/1I 7/15 7/17 8/12 9/5 __ I arise [1] 37/4
45/23 46/8 47/17 47/19 91/21 102/15 103/8 I 10/18 12/8 12/13 13/1Iarisen [1] 25/7
although [8] 4/23 anticipation [1] 48/9 I 172/11 174/7 174/8 I 13/14 13/15 13/23 _I arises [2] 99/21
10/9 24/7 57/7 85/5 any [51] 1/59/18 175/10 177/10 178/6 I 14/1 14/7 14/16 15/6 I 204/3
1432/6 139/6 174/6 13/17 15/24 18/15 179/4 179/24 181/24 I 15/6 15/7 15/8 15/12 Iarising [2] 90/5
altogether [1] 179/4 21/2 21/2 23/23 40/6 Iapplied [2] 184/18 15/15 16/7 16/8 16/17I 146/10
always [9] 8/1 22/2 47/25 50/14 51/5 195/2 17/7 17/10 17/21 arm's [14] 4/16 9/2
22/4 48/5 122/11 56/23 61/11 78/9 applies [1] 4/16 17/22 18/3 19/8 19/9 I 15/10 94/4 107/19
127/11 138/8 143/13 I 84/21 84/24 86/24 apply [5] 14/21 93/14I 19/11 19/13 19/15 108/7 108/13 108/21
151/14 88/3 94/2 95/12 96/1 I 94/3 111/24 137/3 21/10 21/13 22/15 108/21 109/8 110/8
am [29] 1/2 13/16 99/16 102/14 103/2 Iappoint [2] 84/8 22/20 23/24 24/1 112/23 113/23 162/3
15/5 24/15 21/18 37/1I 103/8 103/10 104/23 I 182/14 24/18 26/5 26/7 26/8 Iarm's-length [12]
38/10 38/12 41/6 62/9I 112/3 113/1 113/13 Iappointed [16] 3/8 I 28/17 29/3 29/13 4/16 9/2 15/10 94/4
64/18 65/11 70/19 114/3 128/10 128/11 I 3/14 11/17 72/21 84/7I 29/14 29/18 31/8 32/2I 107/19 108/7 108/13
73/2 77/3 87/18 87/19I 199/18 142/25 148/8 I 105/23 106/1 106/16 I 32/23 33/5 33/9 33/21) 108/21 109/8 110/8
87/19 87/20 87/21 148/9 148/11 149/2 I 110/16 128/13 128/17I 34/1 34/2 34/5 34/24 I 113/23 162/3
90/15 91/19 96/18 167/9 168/25 175/9 I 129/16 132/20 159/14) 35/5 35/18 37/12 41/1I around [17] 16/6
99/11 99/12 102/8 177/19 179/22 181/11] 184/8 193/1 41/19 42/11 42/25 17/22 22/21 30/10
186/24 190/10 196/18] appointee [1] 11/17 I 45/4 47/5 52/11 52/22I 33/7 64/21 72/9 84/21
(65) along - around
INQ00001203
INQ00001203
A
around... [9] 90/5
90/10 97/4 97/15
105/21 141/20 142/18)
180/7 182/6
arrange [1] 117/21
arrangement [1]
161/22
arrangements [2]
109/18 119/25
arrears [1] 116/17
arrived [1] 180/5
Article [1] 81/9
Article 7 [1] 81/9
Articles [11] 80/12
80/16 81/3 81/9 81/21
82/2 120/24 168/24
187/21 195/6 202/20
articulated [1] 29/4
as [344]
as-was [1] 79/14
aside [2] 28/16 87/12
ask [28] 2/1 2/11
16/19 24/2 26/22
34/20 40/6 72/12 77/9)
77/9 80/3 81/11 82/25)
88/15 91/6 93/24
94/14 99/20 101/21
102/4 102/6 102/11
102/15 130/19 131/2
137/7 138/6 193/9
asked [21] 12/9
54/13 59/6 62/23
67/10 83/22 89/24
96/9 102/3 102/12
102/17 102/19 103/5
117/20 137/25 146/23}
151/23 155/1 174/22
190/17 190/18
asking [8] 2/12 4/8
103/19 105/7 144/20
173/20 184/3 197/20
aspect [4] 68/3 105/8
111/6 158/6
aspects [2] 37/12
50/2
aspire [1] 84/8
assertive [1] 156/2
assessment [4]
43/16 46/12 63/2
134/13
assessors [1] 43/24
assets [5] 14/24 17/8
17/10 17/25 18/1
assigned [1] 2/18
assist [4] 68/23
103/21 203/22 204/2
assistance [1] 199/3
assistants [1] 80/1
associated [2] 45/18
46/5
Association [9]
80/13 80/17 81/3
81/10 120/25 168/24
187/21 195/6 202/21
assumed [1] 46/13
assurance [22] 23/9
23/19 49/20 50/1 50/4,
55/1 55/2 55/4 57/8
62/4 62/6 65/6 65/10
65/11 65/14 66/16
67/3 67/9 67/14 67/18
67/20 116/15
at [264]
attempt [7] 156/8
172/14 180/3 185/8
192/18 195/25 197/8
attempts [1] 129/25
attend [3] 27/8 55/8
169/8
attended [8] 26/23
33/25 39/12 48/17
50/12 50/25 51/11
177/13
attendees [1] 27/9
attending [2] 48/22
201/18
attention [15] 16/18
18/12 60/9 60/12
114/9 114/22 117/14
118/5 123/24 129/4
134/25 136/1 137/15
141/10 198/24
attitude [4] 40/7 40/7
67/15 71/9
attract [2] 9/4 133/21
attracted [1] 16/18
attribute [2] 11/22
177/15
attributed [2] 139/24
148/14
audible [1] 49/19
audit [4] 22/8 22/15
23/22 114/2
audited [1] 113/2
auditors [1] 113/2
August [1] 189/8
authored [1] 74/13
authorities [1] 93/15
authority [8] 67/25
69/14 106/2 112/10
113/24 126/5 167/8
195/5
autonomy [1] 12/24
available [12] 7/15
8/8 23/9 26/8 26/11
45/11 69/11 76/3
76/16 88/19 162/9
172/18
avenues [1] 161/24
averse [1] 11/21
avoiding [1] 46/4
aware [28] 46/16
46/22 57/19 60/4
61/11 61/13 63/16
67/1 77/13 86/19 90/1
90/5 92/5 92/12
115/17 130/21 132/17
142/7 151/15 153/4
174/20 174/22 176/1
176/16 177/23 194/18
194/20 195/6
awareness [1]
163/17
away [2] 171/3 201/7
awful [4] 31/7 31/13
60/24 164/13
B
back [19] 2/25 24/8
29/12 33/8 58/25 84/6
88/1 96/4 96/8 118/15
119/6 119/15 120/9
123/5 136/5 154/3
155/24 163/19 176/21
background [7] 2/13
27/16 51/23 105/10
139/7 140/6 160/1
backgrounds [1] 9/7
backs [1] 41/3
bad [5] 39/22 100/11
178/9 191/12 203/12
balance [3] 12/21
13/1 13/24
balanced [1] 26/20
banking [1] 5/14
bankruptcy [1]
140/22
banner [1] 140/11
bar [1] 124/9
Baroness [4] 8/3
132/25 203/19 203/25
barrister [1] 135/12
base [3] 7/13 25/3
54/22
based [8] 8/13 42/22
168/7 173/5 176/5
192/4 192/4 194/5
basic [1] 167/10
basically [4] 32/16
35/5 110/18 152/23
basing [1] 152/7
basis [9] 7/3 22/13
78/16 113/3 115/18
116/17 117/6 161/8
164/16
basis’ [1] 154/18
Bates [1] 199/25
be [252]
be-all [2] 98/13 100/3
bear [1] 49/4
bearing [2] 63/16
67/13
became [12] 64/20
106/11 124/7 138/20
156/2 156/3 162/11
183/5 185/4 191/4
194/20 194/24
because [79] 9/20
10/16 11/3 11/14
11/19 14/5 17/12 18/3)
18/8 18/14 21/18
22/25 26/6 26/7 30/17
32/13 32/24 36/7
37/16 40/25 45/4
45/10 53/8 53/12
60/14 62/7 65/15 68/5
69/9 81/12 83/6 84/13
86/1 90/7 92/17 92/21
93/13 93/24 95/1 95/2
95/17 96/15 97/7
103/4 112/11 118/21
124/11 128/22 131/8
134/16 136/3 144/15
152/10 154/25 155/4
156/6 158/10 158/20
161/7 163/12 167/18
168/5 168/16 169/8
169/23 172/1 177/19
179/11 185/3 185/15
186/21 188/1 188/23
189/5 190/25 191/10
200/16 201/25 203/21
become [8] 40/15
73/19 86/19 128/15
179/12 179/20 182/9
185/13
becoming [3] 121/19
138/19 160/14
bedrock [1] 123/21
been [185] 6/4 8/1
8/13 12/2 12/9 16/11
18/10 23/4 24/19 25/5)
25/9 25/10 26/10 28/6
28/11 28/13 29/7
29/22 30/3 30/13
33/19 33/22 33/25
33/25 39/24 40/16
40/16 41/11 42/23
44/2 44/4 46/17 46/18
46/24 46/25 46/25
47/17 48/2 50/13 51/8
52/14 55/4 55/20 56/7
56/14 56/21 57/8
60/24 61/14 62/18
66/23 67/7 68/5 68/7
71/3 73/15 75/4 75/13
79/10 79/13 80/24
81/17 82/9 85/8 85/10
85/14 86/20 87/4 87/8
89/3 89/6 89/15 89/24
90/1 90/2 91/15 91/18
91/24 92/3 94/1 95/20
97/15 97/17 98/23
101/19 101/21 101/23)
102/17 110/16 111/13)
112/7 112/9 112/11
112/13 113/10 115/14)
117/11 118/7 118/8
118/20 118/25 122/20)
122/23 123/19 125/5
128/13 128/19 128/23)
128/24 129/23 130/2
130/21 133/19 135/22)
135/25 136/3 137/20
138/4 138/15 138/16
140/17 141/20 141/23)
142/2 142/4 142/7
142/13 142/13 142/19)
144/23 144/24 145/13)
146/7 149/9 151/3
151/5 151/7 151/17
151/18 151/20 152/13)
153/4 153/20 155/18
161/25 164/2 164/6
164/22 166/3 166/15
169/19 170/22 172/7
172/9 176/5 181/24
182/23 183/17 183/18)
184/7 184/14 184/24
186/15 186/18 189/3
190/17 190/21 190/25)
191/1 191/3 191/5
191/12 191/22 193/25)
194/4 194/17 195/7
195/10 195/22 197/4
198/10 198/19 199/5
200/13 201/6
Beer [1] 101/19
before [41] 1/24
25/24 40/6 44/8 48/18
59/6 77/9 81/24 89/15)
93/17 101/11 102/24
105/22 107/11 110/16)
124/16 125/2 125/4
128/19 131/10 134/5
134/16 135/7 137/10
141/23 142/11 149/5
150/17 156/20 161/19)
169/10 177/20 179/18)
179/23 185/13 193/1
197/12 198/20 200/14)
201/5 202/4
beforehand [2]
128/25 166/9
began [7] 2/14
105/15 120/4 149/6
155/11 155/13 155/16)
begin [3] 2/12 4/8
196/10
beginning [5] 25/21
139/2 165/1 189/14
196/23
begins [1] 102/24
begun [2] 182/3
182/4
behalf [9] 2/11 22/19
27/10 65/8 87/21
94/14 103/20 162/4
166/16
behaved [1] 130/13
behaving [1] 31/10
behaviour [5] 11/18
30/23 31/1 61/6 73/18)
behind [5] 41/2 45/25I
93/10 156/24 169/7
being [87] 4/4 10/6
10/8 14/8 14/13 15/22)
(66) around... - being
INQ00001203
INQ00001203
B 4/11 4/14 7/6 7/23 64/19 65/1 66/14 67/8] 53/3 64/2 65/22 69/11] 144/13 148/23 149/14,
being... [81] 1718 10/4 12/21 14/11 72/20 72/24 73/1 73/3] 85/19 139/24 140/2 I 157/9
Be 29/25 34/2 22/10 23/5 25/12 73/8 74/3 74/16 75/4 I 148/22 bureaucracy [1]
34/14 37/9 37/11 25/19 28/15 28/18 75/9 76/16 77/4 77/24) branches [5] 5/9 33/15,
37/25 39/4 40/10 28/23 35/24 36/23 79/11 79/14 79/16 5/12 6/20 7/1 64/5 Burton [2] 11/7 74/5
41/23 42/20 44/2 44/6I 37/23 58/10 69/21 80/14 82/23 82/24 break [6] 38/5 38/11 Ibusiness [43] 4/12
45/17 49/20 50/22 70/5 74/7 77/15 78/20) 83/2 83/3 83/5 83/12 I 70/13 70/20 153/25 I 10/1 12/11 15/16
54/13 59/20 59/21 83/1 84/14 87/7 94/20) 84/7 84/15 86/2 86/6 I 154/8 29/19 30/25 31/16
61/4 62/22 63/25 64/9) 119/2 131/20 146/16 I 86/7 86/8 87/19 87/19I breakdown [1] 168/2I 32/8 32/23 33/2 35/6
64/13 65/5 65/16 152/12 157/22 161/14] 87/22 87/24 94/1 brief [4] 2/12 16/20 I 44/14 50/7 52/15
66/17 66/23 67/14 161/21 161/22 163/3 I 94/20 94/23 95/7 70/25 138/17 52/18 53/6 53/7 59/20)
68/7 83/13 87/3 88/17I.1/ 7/7 188/25 198/20 I 95/10 95/12 95/20 briefed [5] 130/22 62/10 64/9 64/11
88/18 88/24 90/14 Ibeyond [6] 11/5 95/22 95/23 95/24 137/25 141/21 142/16] 76/19 98/19 105/14
91/1 91/8 95/10 97/4 I 19/18 51/10 74/17 96/2 96/25 97/1 97/5 151/4 106/9 106/10 109/2
98/3 98/4 99/8 103/2 I 119/22 126/6 97/10 97/18 97/21 briefing [37] 50/14 I 111/21 112/22 113/7
105/12 108/10 112/3 [Bickerton [4] 20/17 I 97/24 98/2 98/6 98/15) 130/25 131/4 131/7 I 113/7 113/8 113/22
115/3 116/16 119/22 I 21/3 60/3 87/6 98/24 99/7 99/8 99/11] 131/16 131/17 131/24] 114/3 115/25 127/9
4121/8 126/14 129/5 IPig [7] 39/23 61/19 I 99/16 100/6 112/24 I 132/5 132/10 134/7_ I 147/22 157/22 158/10
4131/2 131/25 133/24 I 68/2 113/8 131/15 112/24 117/7 128/7 I 134/8 137/24 138/22 I 158/12 158/14 159/7
140/8 140/20 141/3. I 170/21 184/23 151/18 153/15 156/6 I 139/3 139/6 139/11 I 162/8
441/17 142/22 146/23] Bill [1] 93/15 163/13 163/14 163/14) 139/13 139/15 141/8 Ibut [189] 1/4 1/7 6/8
148/17 149/15 158/17 I Dillion [2] 108/11 164/8 165/4 165/13 I 141/13 142/3 142/23 I 9/23 12/19 18/13
159/12 162/8 165/14 I 113/9 165/25 166/1 167/7 I 143/23 144/5 145/12 I 18/22 20/8 21/12 22/4}
1466/7 167/24 174/5 I BIS [3] 111/22 167/22 167/24 168/10) 145/20 146/6 146/11 I 23/12 23/22 26/12
174/21 181/5 183/20 I 111/23 133/1 168/17 173/23 174/9 I 147/5 147/17 147/25 I 26/18 27/15 31/12
185/15 187/2 193/22 IBishop [1] 92/11 175/9 175/18 175/21 I 149/10 150/23 151/22I 32/23 34/5 37/4 38/19)
194/11 198/20 203/16 bit [24] 1/6 14/10 177/16 177/11 177/13 I 155/13 155/18 169/22) 39/21 40/2 42/3 42/17,
BEIS [28] 51/9 52/14 15/7 31/21 41/13 54/9I 177/22 179/23 183/19] briefings [3] 51/1 44/11 44/11 44/22
96/4 106/12 106/14 _ I 82/10 65/12 67/25 184/7 184/9 184/10 I 51/4 166/8 45/11 45/24 46/2 47/3
107/1 107/20 1089/6 I 70/5 92/16 93/11 184/24 203/9 203/14 Ibriefly [2] 71/5 92/2 I 47/12 57/16 58/5
112/4 114/14 1416/2 I 129/2 149/12 157/14 I Board's [2] 57/3 bring [20] 16/23 46/3 I 60/11 61/2 61/19
1416/6 116/15 117/21 I 197/15 157/18 159/4 I 75/12 64/16 68/22 78/6 92/6I 62/10 64/24 65/3 68/7
118/9 120/6 120/23 I 160/9 164/21 176/9 IBoards [1] 100/15 92/24 95/19 95/21 68/19 68/23 69/18
421/17 121/24 127/21I 178/19 184/3 200/24 Ibodies [15] 4/16 9/2 I 129/20 130/3 166/2 I 71/4 71/20 72/19 73/3}
1428/2 154/16 161/22 Ibits [3] 6/24 7/1 15/10 47/4 94/4 98/11) 170/4 183/1 183/10 I 73/23 74/9 75/9 76/21
172/14 173/5 1175/2. I 76/19 100/8 107/19 108/7 I 184/12 184/12 185/19I 78/21 79/5 81/15 82/1
176/15 177/8 black [1] 191/2 108/13 108/21 109/8 I 197/8 197/25 84/6 87/9 87/16 88/1
BEIS0000085 [1] Blood [1] 93/6 110/8 123/12 162/3 I bringing [6] 26/1 88/15 88/20 90/11
186/2 blow [1] 171/18 body [7] 142/17 125/21 125/23 129/24] 90/23 91/12 93/2
BEIS0000653 [1] blows [1] 171/19 142/20 158/9 159/24 I 183/6 198/11 93/21 95/7 96/14 97/8,
51/14 board [182] 3/15 164/11 184/13 202/22I brings [2] 38/3 70/12 I 98/3 100/4 109/8
BEIS0000753 [1] 3/21 5/20 7/18 8/16 Iboiling' [1] 204/13 I broad [2] 121/3 109/24 111/9 111/16
27M 8/20 9/2 9/5 9/7 9/11 Ibonuses [9] 163/2 121/15 112/8 112/16 118/6
belief [2] 2/8 105/1 9/14 9/18 9/19 10/2 I 165/22 185/21 185/24) broadly [4] 26/17 118/11 118/15 119/4
believe [4] 49/2 10/3 10/19 10/21 11/1] 186/4 186/13 187/12 I 35/2 67/12 114/25 119/19 120/10 123/10)
122/25 139/23 196/7 I 11/6 11/8 11/16 12/23] 187/24 188/6 brought [9] 117/13 I 123/21 124/1 125/25
below [2] 108/14 13/20 13/22 14/1 14/9Iborne [1] 198/6 130/9 144/23 147/4 I 126/16 126/18 128/5
145/3 14/17 17/18 17/20 Boston [1] 3/3 156/14 164/24 170/18] 130/4 130/7 130/15
Ben [2] 27/22 170/19 18/7 18/14 18/14 both [34] 2/22 25/14 I 191/11 192/18 130/21 131/17 131/23)
benefit [6] 40/1 19/24 21/23 22/3 22/4I 28/2 34/10 39/18 40/9I budget [8] 26/4 26/14) 134/2 134/17 134/19
121/25 154/22 166/16I 24/5 24/12 24/16 72/14 86/2 88/9 114/9} 26/20 30/12 53/6 136/1 136/20 137/12
190/16 191/25 24/17 24/21 25/8 122/12 126/13 128/22) 94/24 117/10 190/5 I 139/4 141/12 141/19
ben d [1] 109/24 25/11 25/23 25/24 135/8 137/16 138/5 I budgeting [1] 116/25I 143/22 145/8 145/14
benefits [1] 158/25 25/25 27/23 32/6 139/15 139/23 140/18) budgets [2] 19/14 146/5 146/10 148/2
best [9] 2/7 23/21 32/16 32/16 32/20 142/20 143/17 144/17I 84/1 149/12 149/15 150/15)
31/8 36/7 36/19 65/23I 92/22 32/24 33/11 154/24 157/9 159/13 Ibugs [7] 67/6 76/15 I 152/4 153/5 153/10
68/18 105/1 146/19 I 39/13 33/14 34/22 169/22 171/19 171/19) 145/13 146/7 151/8 I 153/19 156/8 157/13
better [12] 1/5 34/19 I 35/17 35/20 44/8 44/9) 178/20 178/21 179/10 152/10 152/16 158/3 159/4 159/8
S512 56/12 79/21 I 48/18 49/5 50/5 50/6 I 179/16 198/12 198/14I build [2] 49/22 64/3 I 163/20 164/8 164/19
100/18 130/17 168/11] 50/12 51/5 55/9 56/2 Ibottom [5] 8/6 56/10 Ibuilt [1] 197/21 165/10 165/25 166/3
470/22 181/2 182/24 I 59/15 56/16 56/21 I 137/22 173/8 197/17 Ibulk [1] 20/12 166/6 166/13 166/16
192/13 57/10 58/25 59/13 Ibought [1] 156/14 Ibunch [1] 52/25 168/3 168/13 168/16
between [40] 4/9 I 59/24 80/5 61/4 62/25 box [1] 191/2 bundle [1] 92/13 I 170/22 171/8 171/18
63/5 63/24 63/25 branch [9] 48/17 burden [5] 66/18 172/20 173/16 173/18)
(57) being... - but
INQ00001203
INQ00001203
B 111/3 111/5 112/2 I 116/25 champions [1] 100/9ICitizens [1] 89/7
but. [47] 17613 114/7 116/17 119/21 Icategorised [1] chance [4] 125/16 I city [1] 92/20
176/17 176/22 177/2 123/5 125/21 127/18 I 108/15 138/5 138/21 173/24 Icivil [9] 2/17 3/2
178/2 178/12 178/18 129/11 130/18 130/25I cause [6] 136/10 Chancellor [2] 2/22 I 78/14 105/15 106/17
131/2 135/24 137/23 I 140/3 141/18 144/2 2/25 107/2 113/6 137/11
178/21 178/25 179/11
180/10 181/10 181/23I 139/13 144/5 147/19 I 148/24 149/2 chances [1] 144/4 153/10
182/16 185/6 186/17 I 100/20 155/16 157/2 Icaused [7] 28/17 change [26] 30/3 claim [8] 45/11 45/14
186/19 188/11 188/24I 158/21 161/4 164/13 I 39/10 140/14 140/25 I 34/14 95/8 97/23 45/24 122/13 138/8
189/2 189/6 189/16 I 165/11 165/13 166/14) 150/12 168/2 185/11 I 100/6 106/6 112/12 I 140/19 141/11 198/12
189/22 191/7 191/15 I 166/24 168/12 168/19) causes [1] 148/8 117/5 117/7 117/10 I claimant [4] 43/18
191/17 191/19 192/1 I 168/20 168/22 170/18Icausing [1] 140/20 I 118/13 156/11 156/13) 44/1 44/5 148/6
192/4 192/22 193/7_ I 174/17 176/15 176/16Icaution [1] 8/22 156/14 156/19 164/25) claimants [12] 39/7
193/10 193/17 193/24I 185/24 186/8 188/9 [cautious [1] 176/9 169/4 171/3 172/4 39/22 43/24 45/2
194/10 194/19 195/9 I 190/2 192/8 196/3 caveated [1] 190/16 I 182/21 183/7 183/13 I 45/22 46/1 89/15 90/6
195/16 196/16 198/13] 200/24 201/8 203/4 ICCTV [1] 141/15 184/10 184/12 184/14) 91/20 140/5 198/13
203/17 204/5 cementing [1] 185/11 200/22
seelb oonriooemg. fean't [12] 23/20 I 182/23 changed [11] 24/16 Iclaimed [1] 140/14
ee 23/22 32/12 55/6 __Ieensure [1] 18516 I 25123 25/25 42/3 90/4Iclaims [10] 42/20
62/18 62/20 95/8 95/9I cent [5] 9/19 85/15 I 99/23 155/9 156/12 I 43/6 43/16 43/24 45/4
button [1] 79/22 128/10 170/6 171/8 I 85/18 97/9 186/20 156/12 184/16 190/3 I 45/19 47/10 47/15
Cc 185/16 Central [1] 123/15 Ichanges [13] 7/7 7/9 I 89/10 133/11
Cabinet [3] 68/1 candour [4] 92/7 centre [1] 76/6 7/9 7/12 42/17 61/8 I clarify [2] 21/12
106/19 155/9 92/25 93/14 94/3 centric [1] 34/16 63/14 63/21 156/5 120/5
call [7] 19/9 37/20 [cannot [1] 50/18 CEO [24] 10/19 10/21) 157/25 185/19 187/21I Clark [6] 124/19
52/3 54/12 74/9 capability [1] 35/7 I 11/1111/15 11/18 I 189/10 143/17 172/19 178/2
101/11 187/10 capable [4] 10/6 10/8I 17/13 18/20 27/10 _Ichanging [2] 150/4 I 178/20 181/15
called [15] 60/19 I 37/9 177/17 28/8 29/11 31/22 185/1 Clarke [6] 135/5
66/2 67/24 80/18 —-Ieapacity [1] 38/19 I 51/16 53/20 55/11 __Ichannels [2] 21/21 I 151/6 152/20 155/22
82/20 110/9 114/8 {capital [1] 108/8 55/21 61/7 63/2 68/14] 59/13 185/12 191/8
430/15 131/10 131/22Iaptured [4] 17/11 I 68/14 79/15 96/6 98/7I character [1] 136/17 IClarke's [1] 175/5
444/14 159/3 159/4 17/12 18/2 18/11 120/17 127/23 characterisation [1] Iclassic [1] 204/12
495/24 197/3 career [3] 2/13 2/15 ICEO's [3] 16/16 59/10
calls [1] 167/12 105/15 18/17 51/15 characterise [3] 5/6 y [1] 108/18
came [20] 1/17 41/25Icareful [2] 153/22 certain [7] 5/11 8/21 I 7/20 59/8 Clause [1] 93/13
59/16 81/24 90/22 200/24 65/25 105/8 122/6 cheaper [1] 69/19 Clause 1 [1] 93/13
101/25 114/14 121/8 [Carefully [3] 121/24 I 136/23 163/1 check [1] 112/15 —_Iclean [1] 183/1
421/22 122/4 139/3. I 125/12 176/25 certainly [8] 26/13 IChesterfield [1] 76/6 I clear [22] 19/12 31/3
439/15 149/25 156/20I carelessness [2] 34/25 42/8 156/4 __IChief [19] 98/7 106/1I 39/8 70/1 85/4 91/24
474/14 184/21 186/20) 147/1 150/12 176/13 201/7 201/15 I 106/16 110/11 115/7 I 109/20 113/25 117/12
490/19 198/9 201/23 ICarl [5] 20/14 21/5 I 201/20 118/17 128/18 130/13) 124/24 126/18 127/7
Cameron [5] 49/17 I 23/1 27/8 87/5 cetera [3] 155/9 156/11 165/12 165/13] 127/15 128/6 173/1
110/14 117/20 128/18] carry [1] 58/4 17/1 18116 4172/2 182/12 182/14 I 173/17 175/11 180/16
182/15 carrying [1] 148/12 ICFOO [2] 117/20 182/23 183/7 184/6 I 188/3 189/14 192/10
campaign [1] 92/10 ease [35] 7/4 12/11 I 182/24 184/17 192/25 195/5
campaigning [1] 21/17 21/18 43/23 _Ichain [2] 176/3 child [1] 157/1 clearer [1] 193/6
57/17 43/25 44/4 46/15 47/3) 176/14 CHISHOLM [4] clearly [12] 1/17
campaigns [2] 64/25 73/5 95/10 chair [25] 7/18 8/4 103/15 103/18 170/16] 25/17 56/6 124/6
139/22 140/2 101/21 108/23 110/8 I 27/13 42/12 56/14 I 206/14 167/23 170/22 172/20
can [96] 1/3 1/7 1/8. I 1139/4 114/25 116/5 I 71/2 74/8 71/14 71/17Ichoose [2] 82/15 I 173/11 175/20 176/22
1/11 6/18 14/4 14/24 I 129/5 1129/8 131/8 I 71/24 74/15 80/13 I 182/21 177/2 180/21
45/21 15/24 22/13 I 131/11 137/10 139/20) 120/16 133/2 133/5 chosen [3] 135/15 _Iclient [1] 17/4
24/7 25/17 27/22 29/9I 139/21 144/7 146/4 I 133/8 134/11 157/4 I 155/20 184/10 clients [1] 85/13
31/17 31/18 32/9 147/8 147/15 148/25 I 157/4 180/2 180/2 chunks [2] 138/14 I Climate [1] 106/6
34/23 36/24 40/6 49/7I 164/2 164/22 175/15 I 182/11 182/21 185/2 I 164/14 close [3] 44/23
51/23 87/25 65/3 180/23 192/14 187/10 circuit [1] 83/19 137/14 182/7
68/12 68/22 69/4 ~—«eases [14] 8/20 Chair's [4] 5/19 72/3 Icirculation [1] closed [1] 93/10
70/22 70/23 73/23 I 21/15 39/13 69/19 I 73/18 74/18 161/11 closely [4] 9/21
75/1176/8 77/10 I 89/1 133/13 135/22 Ichaired [1] 107/10 Icircumstance [1] I 149/7 157/21 165/7
77/25 78/5 80/5 80/10) 136/13 140/17 140/19I Chairman [3] 79/1 I 59/15 closer [1] 113/18
81/4 82/10 83/11 142/17 142/19 142/20I 106/23 203/23 circumstances [5] _ I codification [1]
83/19 85/4 86/14 153/15 challenge [5] 119/12 I 10/9 59/10 82/12 161/10
90/11 93/14 98/15 cash [4] 7/369/8 —_I 163/5 164/8 166/2 I 102/13 167/21 coercive [1] 7/17
99/1 103/7 103/17 140/15 140/15 166/12 cite [3] 8/3 71/11 colleagues [6] 11/8
categorical [1] challenging [1] 69/2 I 80/16 22/3 22/5 58/15 74/2
(68) but... - colleagues
INQ00001203
INQ00001203
Cc common [22] 84/14 Icompleted [1] concluded [2] 72/3 I 171/5
colleagues...[1] 85/19 122/22 124/16 I 105/14 145/7 considerations [3]
97/18 i 131/10 144/14 147/20I completely [9] 12/10 Iconcludes [1] 100/18) 14/23 15/6 189/24
colloquially [1] 92/8 156/7 169/11 171/16 I 25/25 28/16 54/10 concluding [1] 68/21 I considered [9] 14/25
column [1] 148/3 185/9 186/7 186/9 70/1 70/9 76/8 86/10 Iconclusion [2] 181/9I 57/24 63/21 73/17
combination [1] 188/24 192/11 195/21) 113/3 190/19 86/21 120/10 139/7
117/18 196/6 196/14 197/5 Icomplex [2] 158/14 Iconclusions [1] 182/18 183/21
come [31] 11/6 13/4 197/12 199/1 202/4 I 169/24 151/10 considering [2]
19/18 24/7 24/8 34/4 Commons [1] 143/9 Icomply [2] 36/8 concrete [1] 62/7 80/20 159/16
50/4 55/7 59/6 59/19 [Communicated [6] I 36/11 condition [1] 100/8 Iconsiders [2] 9/22
62/15 79/19 84/6 86/4 4/24 73/8 116/5 174/9I composition [1] 24/4Iconditions [3] 52/24 I 146/19
88/15 111/9 111/15 177/16 178/3 comprehensive [2] I 53/5 53/12 consistent [3] 43/25
114/24 119/21 120/9 communication [3] I 183/12 200/12 conducive [1] 82/18 I 117/20 127/3
1430/18 135/25 137/23 21/22 89/25 177/7 compromised [1] conduct [10] 11/18 I consolidated [5]
1450/20 154/3 163/2 communications [3] I 204/15 39/1 61/5 71/8 71/24 I 111/23 112/3 112/11
465/22 179/17 184/7 20/14 90/6 105/24 concealed [1] 93/10 I 124/25 131/9 181/12 I 112/14 112/18
jee/9 194/5 communities [2] concealing [1] 186/25 203/10 consolidating [1]
comes [4] 14/5 27/12 65/23 68/18 203/12 conducted [1] 20/3 I 113/19
M177 126/17 community [4] 25/16 Iconcentrate [2] conduit [1] 14/13 Iconstantly [1] 165/14!
coming [8] 34/1 25/20 72/25 171/13 I 191/24 193/8 conference [1] 92/14I constituencies [1]
103/21 106/25 156/22 companies [4] 14/22 Iconcept [4] 123/7 confidence [4] 143/15
461/17 172/11 203/17 15/6 15/7 15/8 123/20 126/8 131/13 I 177/16 182/4 182/5 Iconstrained [2] 48/2
203/21 company [37] 6/7 Iconcern [24] 10/3 I 189/15 96/16
commas [2] 118/9 7/22 9/3 9/9 9/19 9/21) 19/16 19/22 19/23 confident [2] 137/21 Iconsulted [1] 149/17
447/7 10/17 10/20 11/4 26/19 33/6 36/13 144/9 Consulting [1] 3/3
comment [6] 27/20 11/16 13/17 23/5 26/6I 46/19 69/9 72/5 73/10) Confidential [1] consumer [1] 100/8
31/19 96/5 96/6 26/18 26/19 28/16 73/24 74/2 85/14 139/16 contact [2] 89/6
173/16 199/19 34/16 35/3 35/6 35/7 I 115/14 124/13 124/15) confidentiality [1] 143/25
commenting [1] 35/8 35/21 35/25 139/2 149/2 173/14 I 122/6 contain [1] 53/17
1486/3. 36/18 56/24 62/19 189/12 189/18 193/19I confirm [4] 93/14 contained [1] 24/21
comments [3] 31/22 63/6 95/1 95/17 96/1 I 194/24 116/17 117/16 178/11I contains [1] 86/15
32/9 32/14 98/5 99/12 99/14 concerned [26] confirming [1] 179/6 Icontemporary [1]
commercial [12] 112/22 113/1 114/3 I 19/13 29/21 39/4 conflict [6] 36/23 187/1
6/19 6/24 14/21 15/18 121/1 51/17 56/6 56/9 59/11I 37/1 37/2 37/15 37/25I content [2] 2/7 132/7
16/9 36/18 37/8 39/25I comparable [1] 67/18 77/3 77/3 77/5 I 77/15 contentious [3] 66/2
41/13 41/16 98/20 113/10 83/6 83/25 98/23 conflicted [1] 96/20 I 126/10 128/3
115/25 comparatively [1] 110/25 122/2 138/25 Iconflicts [1] 37/4 contents [2] 104/25
Commission [1] 02/9 144/24 152/9 156/3 _Iconfuse [1] 79/9 151/4
105/24 compared [4] 113/15I 178/8 178/8 178/15 I confusing [2] 194/13) context [9] 13/2 15/2
commissioned [5] 160/3 166/1 186/14 I 182/3 189/16 193/24 I 194/13 20/4 20/8 52/13 54/10
61/17 74/22 97/7 compensation [12] Iconcerning [9] 10/24Iconfusion [1] 14/10 I 54/18 54/19 120/3
133/3 136/9 38/16 38/22 47/18 22/9 24/4 38/16 55/5 Iconnection [2] 93/25I contingency [4]
Commissioner [1] 54/1 88/13 88/23 89/1) 55/10 56/15 71/12 101/10 125/7 141/14 147/19
105/23 90/10 90/21 91/9 73/19 conscious [5] 12/17 I 147/24
commissioning [1] 165/1 187/24 concerns [56] 8/6 65/4 71/20 154/25 contingent [1]
61/10 competent [2] 13/25 14/2 14/2 19/1 I 200/17 122/11
commitment [2] 9/14 162/15 165/18 20/22 22/17 28/2 consent [2] 126/11 I continuation [2]
118/16 Competition [1] 28/10 28/17 29/3 30/2I 187/23 171/7 171/19
commitments [1] 106/2 30/6 30/22 38/24 consequence [1] continue [5] 58/11
1450/6 complaining [1] 39/10 40/22 40/24 144/3 60/21 100/4 119/16
committee [34] 18/8 191/18 42/14 42/20 47/22 consequences [5] 122/10
38/20 39/11 39/13 complaint [20] 11/10I 48/15 50/8 50/16 126/21 141/6 173/13 Icontinued [3] 85/23
40/17 40/17 40/22 57/6 57/7 58/17 58/18) 50/19 55/19 55/22 175/23 179/16 135/13 184/9
41/1 42/1 42/4 42/6 58/19 58/21 59/3 59/22 61/11 65/18 consider [15] 6/14 Icontinues [1] 26/19
42/8 51/9 56/16 56/16 59/12 59/17 59/17 65/20 66/15 66/21 10/4 16/10 62/21 continuing [2] 57/25
56/23 56/25 57/1 59/19 59/23 60/6 61/1I 67/13 67/18 67/21 69/21 82/23 86/20 75/17
57/13 63/5 64/19 71/12 71/16 72/2 90/2) 71/8 71/15 72/12 87/13 99/5 130/20 contract [9] 79/2
64/20 65/4 65/6 91/16 146/21 72/15 74/7 74/12 142/23 142/24 161/24I 146/15 146/22 147/3
91/19 91/24 99/19 complaints [4] 29/5 I 74/21 76/24 85/9 88/1) 182/11 202/12 147/23 148/15 149/15)
1400/2 107/10 107/12 55/22 71/10 146/13 I 90/1 159/19 160/12 Iconsiderable [6] 149/16 195/18
1467/6 168/15 187/7 complement [2] 167/3 167/5 167/9 125/3 135/1 153/14 I contractors [3] 61/16]
committees [1] 18/23 20/8 170/9 170/12 178/5 I 162/23 183/15 193/2 I 61/18 70/4
100/16 complete [4] 153/16 I 178/23 consideration [4] contracts [1] 140/20
164/24 170/4 180/24 Iconclude [1] 133/9 I 133/10 168/21 169/19] contractual [5]
(69) colleagues... - contractual
INQ00001203
INQ00001203
c 128/24 202/20 155/5 169/23 139/21 December/early [1]
—Icorporations [2] 16/5}council [2] 33/2 cultural [4] 30/3 73/18
contractual Ul 4 I 94/4 33/16 130/5 165/1 183/12 decide [3] 91/21
187/13 202/3 correct [44] 2/15 3/5 Icounsel [21] 94/16 Iculture [10] 3/7 179/9 179/9
3/16 4/6 4/17 5/2 7/18I 94/17 99/17 101/20 10/15 11/20 11/21 decided [6] 4/23
contrary [1] 163/24 I 7194 11/11 19/3 20/5 I 101/21 102/1 102/3 I 12/4 28/3 99/21 99/22I 53/13 133/8 173/23
contribute [1] 37/21
contributed [1] 12/20 20/18 22/11 23/11 102/5 102/8 102/10 I 130/9 157/12 185/5 197/7
contributing [2] 12/3 27/13 28/5 35/21 102/12 102/13 103/4 Icurrent [12] 5/6 34/7 I decides [1] 102/4
61/24 40/24 42/24 44/16 130/2 138/1 156/11 I 34/8 68/11 68/14 decision [35] 14/8
contribution [7] 24/9 48/20 49/1 49/11 172/3 183/8 184/17 I 68/16 74/23 77/16 14/12 32/20 32/22
24/14 24/25 27/20 51/18 58/17 64/22 198/11 204/4 89/16 90/13 100/13 I 45/16 51/17 51/23
31/14 35/10 95/18 65/9 71/18 71/19 counsels [1] 172/4 I 100/14 82/4 82/14 87/20
contributory [1] 71/25 72/1 72/22 74/3I count [1] 202/8 currently [10] 3/24 I 87/23 87/24 91/2
166/6 74/8 75/7 99/2 106/22) countless [1] 93/7 5/14 6/3 13/1 13/24 I 93/22 96/21 97/2 97/3
control [6] 52/2 107/5 137/6 158/9 country [1] 92/23 20/23 32/23 36/13 98/24 126/16 173/2
54/22 83/4 113/20 159/15 171/11 174/3 Icoup [1] 136/10 49/23 73/1 ATAIT 174/15 174/24
1414/1 187/19 175/19 couple [5] 30/12 curtailed [1] 137/1 175/1 175/17 175/22
controlled [2] 123/15 correction [2] 104/9 I 33/25 88/21 93/20 customers [4] 65/23 I 176/12 176/18 176/24
425/13 104/25 94/15 68/18 158/13 198/5 I 179/1 179/7 180/11
controlling [1] 173/6 corrections [1] course [16] 13/4 cut [1] 153/20 180/11 180/14 190/2
controls [4] 54/6 104/23 59/20 63/4 72/2 80/19) cycle [1] 54/12 decisions [5] 12/17
54/7 114/1 116/13 correctly [4] 33/9 80/22 91/9 105/7 >-D.UO~C™” 12/24 33/7 70/2 122/7I
convenient [2] 38/4 111/8 174/5 189/2 109/2 120/9 122/24 ——__________Idecisive [2] 48/3
453/24 correspondence [6] I 123/5 138/20 198/1 I daily (1] 19/2 48/10
convention [1] 123/8 114/24 115/10 126/17I 200/8 205/1 damaging [1] 28/14 I decisively [1] 123/1
conventional [1] 155/17 175/11 175/14I court [23] 82/4 125/2IDarfoor [2] 72/16 Decommissioning [1
39/5 cost [18] 7/13 25/3 I 135/16 137/10 137/15] 73/12 112/10
26/10 45/24 48/25 137/22 142/15 142/21) data [2] 79/5 79/6 deeming [1] 172/15
53/24 54/6 54/7 54/22! 144/16 149/5 149/18 Idate [6] 58/6 65/2 deep [1] 149/20
54/25 56/4 56/5 69/25] 149/19 150/18 152/8 I 78/6 89/23 102/17 default [1] 150/10
conversation [3]
49/23 94/2 180/1
conversations [1]
2114 70/10 90/24 167/19 I 153/17 171/20 180/5 I 132/5 defective [1] 202/13
convey [1] 178/22 189/18 193/21 181/20 188/23 190/25Idated [5] 1/23 104/2 Idefects [3] 67/6
conveying [2] 175/2 costs [6] 47/18 49/16I 195/19 197/13 198/15, 17/1 175/6 185/22 151/8 152/17
Wie 53/25 70/6 117/11 ICourt's [1] 133/10 IDavid [4] 20/17 21/3 Idefence [2] 122/6
Conviction [1] 91/11 193/8 courts [1] 146/20 21/5 87/6 493/11
convictions [6] 42/13 could [84] 2/16/19 Icover [3] 70/25 88/9 IDavies [2] 52/20 defendant [1] 173/3
42/19 43/7 43/17 79/5 6/22 16/19 16/23 91/4 52/21 defending [1] 179/14
89/11 23/14 24/2 24/12 coverage [1] 5/10 day [8] 23/1 58/16 defensive [1] 157/14
convinced [2] 41/6 24/23 37/1 37/14 covered [3] 71/3 70/4 113/21 113/21 I deference [1] 176/7
195/16 43/13 46/21 49/3 49/6] 108/4 108/7 123/16 123/16 205/9 I deficit [4] 183/15
Cooper [15] 50/15 53/20 54/23 55/7 CPs [1] 190/8 DBT [3] 80/10 83/23 I defined [4] 109/18
50/19 50/19 173/8 55/15 55/17 56/10 create [3] 33/14 86/16 123/12 147/21 202/24)
173/10 174/13 174/20I 58/6 58/12 60/2 61/25I 106/10 168/20 deal [16] 39/23 45/3 I definitely [4] 57/14
474/23 175/1 175/3 I 73/14 81/1 82/13 Icreates [1] 167/19 I 61/19 88/16 92/2 155/18 178/19 204/7
4175/8 17813 180/18 I 82/15 83/21 84/4 I credible [4] 173/12 I 107/23 109/11 109/12 definition [2] 32/20
4181/4 185/21 85/24 87/16 100/10 credits [1] 159/1 124/20 126/21 131/15I 32/25
Cooper's [1] 175/13 100/11 104/2 107/25 ICreswell [8] 20/15 I 173/7 173/20 179/15 I definitionally [1]
Ps 110/12 112/15 115/11I 23/1 27/11 60/3 74/8 I 189/19 203/4 96/17
cooperate [1] 148/7
copied [1] 176/4
copies [1] 151/6
copy [4] 1/22 103/24
117/2 121/12 123/4 I 74/13 87/6 90/23 dealing [4] 52/17 definitions [1]
124/4 126/20 127/18 I criminal [12] 79/5 94/23 162/22 173/12 I 195/17
130/11 131/21 133/10] 89/1 93/16 135/12 dealings [2] 124/21 I definitive [1] 183/11
104/5 133/15 136/14 138/22 139/11] 135/18 135/21 136/4 I 203/7 definitively [2]
core [11] 70/16 77/9 145/9 146/24 150/21 I 142/17 142/20 152/22Idealt [2] 18/3 90/11 I 150/19 172/18
79/18 101/21 102/2. I 151/20 151/23 152/2 I 153/13 153/15 debate [2] 156/4 degree [7] 1/6 12/6
1402/6 102/11 103/2. I 193/20 154/3 154/12 Icrisis [2] 164/23 170/8 54/11 77/15 105/13
108/10 109/7 120/12 I 194/13 155/25 156/14] 164/23 debated [1] 78/19 1452/4 157/2
corporate [6] 4/5 157/4 157/5 162/1 criteria [1] 89/17 debates [2] 143/8 delay [2] 155/1 166/7
35/3 35/7 160/1 162/19 166/2 166/13 Icritical [4] 192/15 143/10 delayed [2] 58/6
162/10 175/19 167/1 167/5 167/9 201/20 201/25 202/6 Idecade [1] 105/22 1496/1
170/15 172/11 178/22I criticised [1] 187/1 IDECC [1] 106/8 delayed/picked [1]
corporation [11] seine,
108/16 108/19 108/20! 181/2 181/2 183/25 criticism [4] 29/23 IDecember [8] 4/13 I 58/6
Tor ttaity 13 I 195/10 197/4 198/23 I 31/7 85/11 173/14 I 73/18 81/22 115/18 I delegated [5] 69/14
123/11 123/14 127/2 I 1989/5 201/21 culminated [1] 74/7 I 117/14 149/25 161/1 I 110/5 113/24 118/2
couldn't [3] 98/17 I culmination [1] 198/9 12615
(60) contractual... - delegated
INQ00001203
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delegation [3] 110/15}
110/23 127/5
deliberate [1] 200/17
deliver [7] 56/7 58/4
66/11 68/20 69/18
189/8 189/8
delivered [2] 6/25
93/2
delivering [4] 5/5
35/25 70/6 70/7
delivery [1] 58/9
Deloitte [4] 132/20
133/16 151/4 152/10
demonstrated [1]
demonstrating [1]
192/10
denial [1] 178/13
denialism [4] 185/10
192/9 192/10 195/24
department [128] 3/7
4/12 4/20 4/24 5/3
5/20 6/17 14/18 17/18
17/23 18/5 18/10
18/16 19/6 19/10
19/12 19/16 19/23
20/1 20/2 20/7 20/14
20/21 21/1 21/16
21/22 22/10 22/19
23/6 23/10 23/25 24/1
24/2 27/11 35/9 36/16
43/20 44/14 44/20
52/5 52/15 52/15
52/16 52/18 54/4
58/15 60/3 60/10 77/1
78/2 83/24 86/20 87/5)
87/7 87/11 91/2 91/3
91/24 91/25 104/15
105/18 106/5 106/9
106/10 107/3 107/8
107/11 107/15 107/18)
108/5 108/10 108/25
109/7 110/1 110/3
110/7 111/20 113/5
113/12 115/15 116/11
1149/9 121/7 121/11
122/24 123/18 124/2
125/13 125/20 125/22)
126/15 126/19 128/7
129/14 130/15 130/20)
135/8 135/19 136/2
138/25 141/21 141/24
144/22 153/6 155/21
157/1 160/12 160/17
164/16 173/1 173/10
173/17 174/2 174/6
175/19 176/21 177/16)
179/2 181/25 182/18
185/13 192/1 192/5
193/10 202/24 203/3
203/20 204/11
Department's [18]
5/6 17/18 22/7 23/1
36/1 69/14 107/10
107/24 121/6 162/4
174/8 175/2 175/5
176/17 177/5 177/9
177/11 186/12
departmental [6]
86/23 108/3 116/20
160/16 178/21 193/15)
departments [1] 17/4)
departure [1] 120/17
depend [2] 158/24
203/5
deposit [1] 154/20
deprived [1] 103/3
depth [1] 174/13
deputy [1] 165/12
describe [15] 4/3
4/10 7/14 24/13 39/4
71/15 108/12 116/24
121/6 139/6 140/7
156/22 159/11 170/24'
194/21
described [8] 13/6
37/6 62/25 73/21
141/17 144/10 152/3
156/25
lescribing [1] 152/6
description [3] 135/3
149/5 204/17
designated [2] 115/2
116/22
designed [1] 155/14
desire [3] 45/17
45/20 173/15
Despite [1] 146/16
destroying [1]
135/22
destruction [1] 153/4
detach [1] 193/5
detached [1] 173/11
detail [7] 40/15 80/4
102/1 104/13 109/14
112/15 148/1
detailed [7] 55/21
62/15 100/21 103/22
131/24 148/21 204/25)
detailing [2] 49/15
50/6
details [2] 89/22
116/18
detected [1] 114/19
determine [2] 10/23
102/18
determined [1] 67/2
developed [3] 11/22
44/14 154/22
developing [2] 43/4
714
development [4]
12/3 41/12 43/3 44/13)
devolved [1] 187/20
devoted [1] 150/4
dialogue [2] 37/22
84/13
did [75] 2/16 2/22
8/18 22/17 25/12
28/20 30/2 30/7 37/7
40/14 44/18 46/8
51/20 53/17 54/21
58/10 82/1 91/4
111/24 114/4 117/24
119/4 125/18 129/14
130/1 132/19 133/15
136/13 136/23 137/7
138/3 141/17 142/3
142/23 143/4 144/3
146/8 146/21 147/24
149/13 149/21 150/14:
150/15 156/9 156/9
156/11 157/11 157/13
158/6 161/23 162/5
170/12 170/23 174/6
175/1 175/8 176/20
176/24 177/10 179/2
179/22 179/24 180/17
182/21 183/10 184/20
188/6 190/22 193/18
194/7 194/8 194/15
195/19 196/13 198/7
didn't [40] 21/12 40/2
44/24 50/24 51/2 53/7
53/19 59/9 96/9 109/9
119/13 134/3 137/8
137/20 149/14 151/24:
152/8 153/15 153/15
158/16 160/6 166/12
166/15 166/17 169/25
175/16 175/25 176/4
177/18 179/13 181/17
182/20 185/3 187/15
187/19 188/8 191/12
194/9 194/10 194/19
died [1] 31/21
difference [9] 83/1
87/7 91/10 96/23
100/12 113/13 119/1
149/22 152/12
differences [1] 90/17
different [27] 5/23
15/7 17/12 33/14
41/16 42/21 47/11
47/13 47/23 62/10
64/7 65/13 91/25
97/14 98/4 119/3
129/2 160/3 160/4
161/8 162/2 163/1
180/4 181/9 200/5
200/7 201/25
differently [2] 26/10
190/15
difficult [17] 9/12
26/15 26/16 26/21
53/11 60/17 60/22
94/22 95/4 95/22
125/9 148/19 164/6
164/9 165/21 166/4
170/6
difficulty [1] 122/16
digging [2] 144/25
170/7
Digital [1] 3/9
dim [1] 184/25
direct [10] 36/22
37/14 71/4 87/18
174/6 191/17 199/17
directed [3] 31/2
83/13 195/4
directing [3] 82/17
82/22 174/2
direction [12] 7/22
42/7 83/4 83/18 84/5
84/16 84/22 85/24
85/25 87/14 195/7
199/12
directions [3] 81/4
81/8 82/9
directive [1] 194/4
directly [15] 17/8
80/11 83/3 86/16
86/22 88/20 108/4
125/21 125/23 138/6
162/18
3/15 3/18 3/22 3/24
10/22 11/16 12/2
12/25 13/16 13/18
13/21 16/12 20/14
20/17 26/18 27/11
29/13 34/21 38/19
48/19 63/3 63/20
63/24 64/16 72/7
78/1 87/20 93/25
Directorate [1] 3/9
directors [18] 17/5
24/11 25/10 25/13
25/19 28/3 29/11
29/12 30/19 35/19
80/14 80/15 95/15
96/7 96/18 97/16 98/1
163/15
disadvantageous [1]
180/9
disaffected [1]
139/22
disagreement [2]
28/22 87/10
disappointed [3]
183/24 185/8 186/21
disappointment [2]
170/24 171/2
disapprove [1]
178/22
disaster [1] 204/16
discharge [2] 149/1
203/11
disclosed [1] 92/13
disclosure [3] 46/4
114/14 160/15 173/18] 37/7 42/17 97/17
38/18 40/25 41/3 45/3I 176/13 176/20 176/22
director [38] 3/8 3/12I 24/17 26/5 26/14
30/12 75/20 94/25
94/25 120/19 132/18
72/17 72/24 73/4 74/5
95/12 96/2 96/19 98/4I 83/10
191/6 191/10
discrepancies [9]
19/19 19/22 33/7 34/4)
75/16 75/17 76/10
136/11 136/25
discretion [1] 84/23
discuss [8] 24/9 25/6
97/21 98/1 144/3
discussed [13] 27/4
50/13 51/13 56/14
71/13 75/4 75/10
79/12 79/13 91/15
181/5 192/19 198/20
discussing [4] 24/20
79/2 143/22 169/12
discussion [30] 6/3
7/5 13/3 26/2 27/16
29/9 30/9 31/15 31/18
62/18 68/10 73/15
74/10 75/12 165/11
174/22 175/4 175/9
176/25 177/2 177/4
180/24 181/2 181/4
181/7 188/13 199/12
discussions [10]
ismiss [3] 7/17
74/15 80/13
dismissal [4] 27/12
71/1 72/4 74/18
dismissed [1] 99/18
dismissing [2] 83/2
dismissive [1] 71/24
dispersed [2] 52/5
52/7
dispute [2] 137/19
172/18
isputed [1] 65/24
disputes [2] 136/16
146/19
disputing [2] 39/15
39/20
dissatisfaction [1]
dissatisfied [1]
124/24
istance [1] 5/11
inct [4] 13/13
64/4 99/15 173/11
distinction [3] 4/14
10/4 117/19
distinguish [3] 25/12
25/18 94/20
distress [2] 140/22
153/12
di:
(61) delegation - distress
INQ00001203
INQ00001203
D does [19] 5/16 13/18 I 150/20 179/3 182/13 Iedited [1] 138/10 I 90/19 184/20
Toaeaina 4) a0n7I 18/18 22/22 22/23 186/8 186/10 188/9 edition [1] 123/13 encouragement [2]
dened aoe. 36/3 59/22 69/10 86/4I downsides [3] 177/1 leffect [14] 36/11 130/7 193/2
diverse [1] 73/3 93/19 93/22 96/2 178/24 181/5 41/22 41/24 42/7 —_ encouraging [1]
102/13 103/8 141/11 Idozens [1] 141/9 45/23 83/16 115/5 91/13
dividing [1] S8/10 I 4 4o/2 152/10 181/4 {draft [6] 43/18 43/20 I 118/16 124/22 148/16Iend [16] 2/4 24/25
divorce [1] 140/22
do [135] 1/23 1/25 188/3 132/4 132/6 138/13 I 148/23 164/20 168/4 I 37/24 38/3 49/21
2/4 2/6 5/25 6/14 7/9 IAoesn't [13] 9/11 157/24 179/25 49/21 70/12 75/25
8/9 9/11 10/4 10/23 I 99/21 97/10 103/11 I drafts [2] 132/7 effective [9] 12/22 88/12 89/23 98/13
12/3 12/24 15/10 16/7I 108/25 119/17 133/18] 161/11 35/7 35/8 68/24 100/3 137/12 144/24
16/10 17/9 18/1 19/5 I 133/22 133/25 136/19Idrama [1] 89/20 109/19 116/12 119/25] 161/18 170/17
20/1 20/20 20/23 141/15 199/14 202/15I draw [3] 60/9 60/12 I 161/25 168/1 end-all [2] 98/13
20/24 20/25 21/1 doing [18] 18/13 198/23 effectively [10] 17/6 I 100/3
24/12 21/21 22/1 34/11 35/2 35/11 drawn [2] 18/12 22/17 87/4 99/18 ended [4] 59/24
23/17 23/24 29/25 37/18 47/24 58/2 123/23 111/14 126/2 135/17 I 131/24 150/16 153/10
31/24 33/20 34/7 62/12 75/12 85/1 draws [2] 4/14 117/9 I 179/12 181/22 182/19] ends [2] 93/20
34/15 37/13 41/5 41/7I 111/7 114/18 142/4 Idrew [2] 114/9 118/5 Ieffects [1] 180/10 134/17
160/3 168/15 175/4 I drifting [1] 147/9 efficiencies [1] Energy [4] 52/15
tee ae or ae 186/23 189/22 driven [2] 45/17 114/13 106/6 106/10 106/23
51/4. 51/18 51/22 53/1IFOn't [69] 11/4 12/12 I 45/20 efficiently [1] 115/22 Iengage [2] 88/12
12/19 13/9 18/15 drivers [1] 49/15 effort [1] 148/20 98/15
57/2 57/7 58/8 59/23 I 94/95 91/25 23/12 Idual [3] 36/3 36/23 efforts [1] 88/12 lengaged [2] 115/25
60/19 62/21 63/20
23/20 29/14 30/18 37/15 egregious [1] 185/14I 129/10
Ce ean 32/6 32/18 37/16 due [7] 7/11 50/4 eight [3] 134/1 engagement [6]
70/4 72/15 79/4 80/10I 99/17 39/19 41/10 105/6 120/9 132/22 I 134/18 182/20 32/19 33/5 98/10
81/8 82/12 82/17 83/6) 41/14 41/25 42/1 42/9I 146/25 196/10 eighth [1] 81/2 98/11 98/18 100/3
44/11 48/8.49/12 during [6] 16/11 __either [5] 47/19 77/22Iengaging [1] 96/14
coos eole Seie I 80/12 51/1 51/9 60/1 I 42/18 Bolts 128/ I 110/6 135/5 13777 Iengine [2] 160/23
64/23 65/20 65/24 195/8 205/1 elected [1] 143/12 160/23
oat eitege. 67/17 67/17 79/9 duties [4] 25/13 element [2] 18/6 engineer [2] 173/22
80/21 82/6 82/7 88/1 I 35/18 122/14 195/17 I 192/9 174/1
103/9 103/24 104/1 ; .
104/5 104/6 118/12 I 88/3 90/15 90/16 duty [8] 35/20 92/7 eligibility [1] 89/17 Ienhance [1] 167/15
4119/7 124/4 124/9 90/22 92/17 92/18 92/25 93/14 94/3 eligible [1] 88/13 enough [4] 47/20
1424/9 125/9 127/8 95/12 95/16 99/10 129/13 147/3 158/18 IElliot [6] 24/10 25/22 I 48/12 158/14 204/20
1429/5 129/15 132/6 I 99/14 100/14 101/9 Idynamic [1] 25/25 29/2 30/14 31/5 31/13/ enraged [1] 178/17
110/24 111/8 137/1 IDyson [1] 43/8 _lelse [6] 141/12 enrolling [1] 67/23
jaaio 151120 tse I 14303 146/10 191/23 I= I 147/13 18516 175/20 lensure [10] 5/4 15/14
14a/o 181/20 158/24 I asz7ii2 158/23 161/13, __I 478/13 20112 24/17 26/18 46/19
4164/9 164/17 166/15 I 191/15 166/4 168/9_ each [5] 52/6 59/21 /elsewhere [4] 17/12 I 47/1 47/5 67/3 117/11
17016 1714 17314. I 172/5 176/12 176/17 I 133/6 134/12 203/7 I 18/4 138/10 144/22 I 117/19
47418 174/21 175/3. I 177/3. 191/14 196/24 Jearlier [20] 26/3 27/5 /elusive [1] 138/23 ensuring [5] 69/22
175/13 177/18 178/6 I 204/17 37/7 46/11 59/7 60/5 Iemail [14] 21/8 27/2 I 109/18 115/1 116/11
485/17 188/2 192/13 Idone [31] 14/25 60/7 69/7 72/20 76/18) 58/15 58/19 58/21 I 119/24
194/3 194/16 195/58 I 15/18 19/19 26/10 I 91/14 94/17 98/19 I 58/23 59/6 6OI2 entails [1] 25/14
495/10 200/7 200/12 I 32/3 41/14 44/20 99/17 117/22 118/20 I 127/19 175/6 176/14 Ienter [1] 199/17
203/14 203/19 204/16) 45/14 45/21 54/14 I 125/18 135/9 145/20 I 176/21 181/3 186/3_Ientered [2] 118/17
document [17] 22/22] 57/8 61/23 76/5 87/4 I 202/15 embargoed [3] 198/8I 150/6
96/4 119/21 120/5 I 89/15 101/19 110/16 Iearly [10] 43/8 46/2 I 198/10 198/21 Enterprise [3] 2/20
423/22 130/18 136/5 113/2 113/3 118/4 51/6 55/24 63/17 embedded [1] 171/9 2/24 3/1
437/23 144/20 147/17] 131/2 142/13 142/14 I 73/18 156/16 159/16 IEmma [1] 103/19 _ entire [2] 171/3
145/9 145/23 155/25 I 170/10 187/21 emotional [1] 140/22} 183/19
teens tooo tooo. 158/17 160/11 190/4 Iearmarked [1] emphasised [2] 50/1 I entirely [2] 13/6
204/8 190/14 192/3 104/19 115/21 84/22
documented [1] done’ [1] 81/8 easier [1] 64/11 employ [3] 70/2 entitled [1] 122/15
16/18 Donnelly [1] 111/18 Ieasiest [1] 43/11 108/5 135/14 entrusted [1] 116/15
documents [20] double [1] 194/14 economic [2] 158/21 Iemployee [1] 11/15 envy [1] 166/5
42/14 13/14 13/16 [doubt [4] 40/1 127/12) 159/3 employees [3] 29/21 IEqually [1] 178/20
4122/1 123/22 128/11 I 162/24 177/19 economical [1] 182/9I 85/10 113/8 equip [1] 65/22
134/5 135/9 142/17 down [24] 24/7 29/9 Ieconomising [1] employing [1] 113/5 Iera [1] 187/4
151/23 153/5 155/1_ I 31/18 31/21 32/23 153/22 empowered [3] 9/8 [erratic [1] 73/19
1455/19 157/3 170/15 49/6 55/7 55/17 57/12IEDF [1] 106/23 9/11 10/3 error [5] 114/23
171/14 174/18 179/6 81/2 81/19 82/10 EDF Energy [1] en [1] 86/9 119/20 147/1 150/12
188/12 191/6 115/16 117/4 119/21 I 106/23 enabled [1] 45/7 181/10
122/22 130/18 137/23Iedge [1] 113/23 encouraged [3] 89/8 \errors [7] 145/13
(62) distressing - errors
INQ00001203
INQ00001203
E 100/18 102/25 105/5 I 17/2 60/9 42/14 62/13 72/18 168/5 185/14
errors... [6] 146/77 __ 111/10 111/18 135/15) exist [1] 16/20 152/2 fails [1] 36/11
1541/8 152/17 471/12 135/16 135/16 135/17I existence [4] 135/5 Iexplanation [1] failure [5] 25/18
471/12 197/19 136/10 136/12 136/21I 137/4 151/8 151/24 190/20 62/21 99/25 177/7
escalate [1] 17/1 145/7 145/11 145/22 Iexisting [2] 74/5 Iexposed [1] 29/15 I 180/20
escalated [2] 77/1 153/5 156/16 168/13 I 167/15 express [3] 173/15 I failures [2] 99/21
85/23 174/5 175/7 176/19 Iexists [2] 4/11 36/10 I 179/22 186/7 204/11
especially [1] 128/2 177/21 177/24 192/24] exited [1] 125/17 expressed [9] 5/9 faint [1] 1/6
essentially [2] 15/12 193/14 197/20 200/21Iexiting [1] 15/16 13/20 28/10 30/22 faintly [1] 1/4
1402/1 205/1 exoneration [1] 89/4 I 50/20 65/5 72/20 fair [16] 21/12 29/23
establish [3] 33/16 exact [1] 116/18 expand [1] 15/5 74/24 172/20 36/1 36/9 44/7 47/7
56/12 132/21 exactly [6] 28/20 expanded [1] 146/14 Iexpressing [2] 67/18 I 55/13 55/14 56/8 57/7
established [1] 38/23 123/19 158/4 Iexpect [6] 35/23 67/21 59/7 62/2 71/7 99/1
160/16 189/25 201/9 41/21 85/1 114/3 expression [2] 105/19 199/19
establishing [1] examine [1] 136/9 127/2 132/12 183/20 194/23 fairly [2] 70/25
1450/5 examining [1] 142/18Iexpectation [2] 6/11 Iexpressively [1] 185/21
establishment [1] example [25] 8/3 127/15 126/11 fairness [1] 146/22
56/15 10/15 15/8 15/22 16/2I expectations [6] expressly [2] 90/13 I faith [2] 79/10 86/7
estimate [2] 56/4 19/18 24/24 27/3 60/8) 115/20 127/1 127/21 I 177/6 fallout [1] 126/21
56/5 67/22 71/11 84/1 127/23 130/14 187/14Iextend [1] 186/4 false [2] 140/18
et [3] 15519 17711 I 94/22, 108/5 108/9 expected [7] 47/10 extension [1] 79/2 I 142/1
181/6 110/13 111/16 112/9 I 128/8 144/19 158/1 extensive [4] 60/6 I falsely [1] 142/2
et cetera [3] 155/9 115/9 127/9 131/4 175/2 175/3 192/13 129/6 139/6 151/10 I familiar [1] 132/8
477/1 1841/6 138/12 141/14 163/24I expecting [3] 42/4 I extensively [1] 91/17I families [1] 92/10
ete [1] 31/23 165/23 161/12 180/3 extent [9] 10/23 far [6] 46/17 55/3
Evaluation [1] 43/9 I@xamples [3] 15/24 expedite [1] 89/10 I 14/11 30/2 62/16 57/19 78/19 94/2
even [18] 108/20 I 120/15 130/20 expending [2] 193/18] 77/17 95/14 114/4 I 116/24
424/16 125/4 125/17 exception [1] 114/7 I 193/20 121/11 191/2 faster [2] 44/2 70/6
435/14 141/11 144/20 exchange [1] 78/23 Iexpenditure [7] external [8] 39/8 fault [2] 146/2 171/18)
146/24 151/17 153/12! Exec [3] 72/24 75/18 I 108/4 108/10 109/12 I 39/12 63/1 130/9 favour [1] 185/1
1456/9 166/3 172/1 98/1 109/17 110/2 110/3 151/1 168/14 172/3 I February [3] 26/23
176/19 186/25 187/2 IEXecs [3] 26/15 119/23 183/9 27/3 81/18
198/17 199/16 28/19 28/23 expense [2] 46/4 _ externally [1] 113/1 Ifeed [2] 19/9 88/1
evening [4] 174/12 executive [66] 3/15 I 189/22 extra [2] 114/21 feel [8] 9/7 9/11
1474/12 174/16 177/20 3/22 10/19 10/22 12/2I/expenses [1] 193/19 I 167/18 10/13 16/4 41/5
events [3] 80/19 12/25 13/16 13/17 expensive [1] 69/19 Iextreme [1] 185/19 I 150/14 155/16 194/3
422/25 198/6 13/21 16/12 17/5 20/4I experience [17] extremely [6] 29/15 Ifeeling [2] 10/3 185/8
ever [5] 86/5 92/22 21/23 24/11 25/10 24/19 26/1 39/22 42/3I 56/3 56/9 102/7 118/5/feels [1] 103/2
428/2 129/15 145/22 28/2 28/7 28/19 28/24) 47/19 47/22 72/22 165/18 fees [4] 45/18 45/21
every [20] 21/17 29/10 30/11 30/19 73/5 75/17 128/1 eye [1] 124/23 46/13 90/23
21/18 23/1 54/15 69/8 34/21 38/19 42/6 130/12 143/12 144/21I/ eye-opener [1] felt [22] 29/1 40/17
93/22 105/7 114/22 I 48/19 58/13 63/20__I 155/19 160/6 162/9 I 124/23 41/9 41/11 45/8 59/16I
424/8 148/21 148/21 73/4 73/21 77/4 80/15) 183/5 FO 87/11 124/2 149/24
156/25 157/1 161/15 I 87/20 95/15 96/18 experienced [4] 37/2I"__________I 156/15 160/20 163/15}
1467/18 193/9 193/10 96/19 97/16 98/4 98/5I 71/24 85/17 87/3 face [2] 60/10 173/4 I 182/8 183/23 185/9
195/13 201/8 202/8 99/12 106/1 107/10 Iexperiences [3] 9/6 Ifaced [4] 17/2 17/8 188/1 189/1 189/2
everybody [9] 22/23 I 110/11 112/7 115/7 I 24/18 95/19 1719 50/22 490/21 191/19 195/22
67/1 67/7 67/19 83/10 118/17 128/7 128/18 Iexperiencing [2] facilitating [1] 193/10) 197/4
147/13 178/13 196/17, 130/13 139/19 156/11I 19/21 53/21 facing [1] 55/25 female [2] 72/20 73/1
197/16 159/24 165/12 165/13Iexpert [4] 135/14 fact [15] 59/18 70/8 I few [9] 29/1 32/3
everyone [4] 93/21 167/24 168/11 172/2 I 135/14 137/15 149/15I 96/14 100/6 132/10 I 79/12 79/13 81/24
161/11 180/7 187/11 182/12 182/15 182/23I expertise [3] 159/25 I 141/7 141/22 147/16 I 89/8 94/8 156/10
everyone's [1] 183/7 184/6 184/17 I 160/22 162/5 151/14 177/5 177/25 I 196/13
400/22 186/4 186/13 192/25 Iexperts [2] 149/16 187/18 190/2 196/13 I fiduciary [3] 9/3
everything [5] 93/19 [Executive's [1] 98/7 I 160/2 198/24 25/13 112/24
134/22 141/12 160/10I Executives [3] 27/7 IEXPG0000007 [1] _Ifactor [2] 12/3 166/7 Ifight [1] 93/1
175/20 28/15 30/16 97/8 factors [1] 194/5 figure [2] 41/20
evidence [46] 8/13 exercise [9] 8/2 8/22 Iexplain [16] 4/13 failed [8] 100/6 109/4
14/7 30/25 37/20 48/6I 9/8 9/8 74/14 82/15 I 14/24 22/13 25/17 122/14 124/7 167/11 Ifile [1] 138/11
59/7 60/8 62/13 75/3 102/17 111/16 113/25) 32/9 34/23 42/19 167/22 168/1 192/22 I final [9] 23/17 44/15
76/7 76/13 76/13 exercised [4] 7/23 43/22 51/23 57/25 203/10 56/11 74/21 132/6
77/14 78/11 80/24 82/9 82/13 82/13 69/4 107/18 108/2 failing [3] 94/19 136/13 137/21 161/1
85/8 94/15 97/11 [exercises [1] 116/12 I 116/9 122/9 126/22 I 135/18 178/14 161/9
exercising [3] 12/22 \explained [5] 10/2 _Ifailings [3] 135/1 _I finalise [1] 89/5
(63) errors... - finalise
INQ00001203
INQ00001203
F flaws [4] 136/10 117/4 162/14 162/16 169/14
finalised [1] 34/2 Tt] 34/2 136/12 136/22 140/2 Iframe [1] 147/12 fundamentally [1] generate [1] 95/13
finality [1] 170/4 flexibility [1] 115/24 I framework [16] 5/8 I 158/19 generative [2] 7/3
finally [10] 63/7 flow [4] 122/7 125/13) 37/16 37/19 46/17 funded [10] 51/25 69/8
76/21 86/12 133/12 138/25 158/1 46/24 48/3 120/5 52/1 52/1 65/25 69/12) generous [3] 48/2
453/18 155/3 171/24 Foat [1] 170/19 123/22 157/24 159/17) 109/12 109/17 109/23) 48/10 48/11
1485/20 188/10 199/11 focus [4] 37/8 50/2 I 161/16 184/19 187/18) 110/3 114/12 gently [1] 197/24
finance [2] 30/15 146/13 189/4 192/6 195/1 203/1 funding [47] 6/24 genuine [2] 98/21
162/10 focusing [1] 40/14 I franchise [2] 33/2 12/7 13/4 13/10 36/14I 166/2
financial [28] 4/6 follow [4] 18/18 98/21 50/9 51/18 51/24 52/4) genuinely [3] 25/23
5/17 5/21 5/25 6/7 70/16 94/15 123/24 I franchise-type [1] 52/5 52/7 52/24 53/2 I 45/22 62/11
6/10 6/14 19/14 26/3 followed [4] 15/17 33/2 53/12 53/14 53/17 get [32] 1/12 27/22
36/19 66/18 83/25 107/16 138/20 186/18] franchising [1] 113/7I 53/18 53/22 54/12 27/23 32/19 33/13
94/24 108/19 113/17 following [12] 25/6 IFraser [6] 82/3 54/12 54/17 54/24 34/18 45/7 45/14
114/1 122/12 130/3 27/20 51/12 60/6 122/21 124/17 193/21) 55/1 60/20 66/1 69/1 I 75/25 76/18 93/2
1440/1 140/21 150/1 89/20 101/18 106/8 I 198/25 201/16 69/5 69/13 69/23 91/7I 94/12 100/1 110/14
169/13 179/16 189/5 120/17 132/19 133/8 IFraser's [1] 99/24 91/14 104/14 104/19 I 114/4 125/5 130/10
196/19 199/22 200/2 137/24 205/9 fray [1] 179/19 109/24 114/8 114/9 I 135/2 137/22 138/9
200/9 follows [4] 20/12 free [1] 173/12 114/14 115/14 115/19] 138/21 158/3 169/10
financially (4) 6/19 I 49/954/2 10116 — freedom [1] 15/19 I 115/21 416/1 116/6 I 170/17 1741/3 187/17
3719 37/12 193/11, (footing [1] 130/17 I Freeths [1] 200/22 I 117/3 117/7 117/16 I 187/23 194/9 194/10
inane force [1] 174/2 frequent [2] 13/3 I 117/22 117/24 195/11 197/17 201/15
frat ete 188 Forecast [2] 49/8 _I 167/12 funds [27] 12/9 15/15I gets [2] 13/9 68/1
oyIo4 ab/21 3e/2g I 49/14 frequently [1] 19/21 I 26/8 26/11 46/19 47/1) getting [14] 8/5 17/22)
82/22 83/13 84/12 (foregoing [1] 36/20 Ifresh [2] 129/20 47/5 48/6 52/12 65/16) 31/7 40/18 41/5 41/6
96/20 125/11 136/13 (forensic [1] 136/8 I 183/1 65/17 69/10 95/3 I 76/22 83/9 131/24
189/25 204/8 forfeited [1] 122/13 [friction [3] 28/18 I 95/13 108/4 108/5 I 138/4 155/17
finding (1) 2006 IFergemasters [2] I 161/14 167/19 108/7 111/10 115/2 Igive [22] 1/20 15/2
findings [8] 22/16 I 3/16 16/14 front [4] 1/22 88/16 I 115/11 116/2 116/15 I 39/13 41/21 41/24
1433/5 133/24 134/10 forget [1] 158/23 88/22 103/24 116/21 117/9 117/12 I 45/13 45/22 75/11
138/16 137/20 188/23)"0Fgive [8] 21/9 58/20Ifrustrated [1] 183/24I 119/24 134/21 81/4 82/9 84/22 99/6
4189/1 68/12 72/18 74/10 frustration [1] 13/19 Ifurnishing [1] 153/21) 103/17 108/9 110/5
fine [10] 1/16 38/9 101/9 123/3 165/8 _I frustrations [1] 65/5 Ifurther [25] 29/9 29/9) 118/14 120/15 150/22
70/18 79/17 101/4 Iforgotten [1] 67/10 IFujitsu [5] 77/15 78/4) 40/7 55/8 70/25 74/17I 165/16 179/24 194/19
form [5] 68/11 72/13 I 78/20 79/1 197/20 77/6 77/11 78/23 194/25
1a eee 134/22/73/12 11716 157/9 IFujitsu's [1] 79/4 I 78/24 78/25 88/3 given [49] 6/9 6/15
finer [1] 160/7 formal [7] 18/6 fulfilled [1] 135/19 104/23 108/20 109/3 I 8/13 17/24 24/23
finished [2] 70/14 110/14 110/15 110/22I fulfilling [2] 122/12 I 109/7 116/18 134/18 I 41/23 42/11 61/4
129/17 131/4 148/12 167/4 I 162/14 134/19 136/25 152/19] 61/24 76/7 84/17
firm [4] 136/8 formalising [1] 23/2 Ifull [13] 1/20 103/17 I 153/14 178/17 196/2 I 94/16 102/19 104/14
first [43] 1/14 2/16 formality [1] 79/11 131/16 134/16 136/19) 202/7 111/10 111/25 118/10)
2/24 27/20 38/5 40/15 formally [4] 4/19 20/3) 138/21 155/15 155/17I furthermore [4] 121/4 129/8 131/3
43/17 50/8 50/12 150/6 187/17 177/2 183/16 187/12 I 117/19 135/18 151/15) 131/7 131/22 132/10
50/25 52/21 61/9 format [1] 116/19 189/17 191/10 171/21 134/23 136/6 138/11
63/16 63/25 64/18 formed [3] 106/2 fuller [6] 62/16 future [9] 32/1 37/14 I 145/19 149/10 151/21
66/15 71/1 71/9 88/11 154/21 163/6 137/17 138/7 153/21 I 43/21 50/9 60/15 153/3 153/6 160/12
92/24 109/20 110/14 former [5] 71/2 71/8 I 191/5 191/11 64/13 117/16 189/23 I 160/12 160/14 164/12
110/23 118/23 119/19} 89/16 140/10 180/5 Ifullness [1] 180/24 I 198/5 164/16 165/10 168/21
125/24 131/3 131/6 forward [7] 34/3 43/5I fully [15] 25/12 25/18 G¢...C~™ 169/19 173/24 174/14)
132/20 138/14 139/12I 99/16 68/11 76/22 25/18 60/22 60/23 I 1755/8 177/9 177/20
153/1 157/24 162/1 I 97/23 97/25 76/3 86/21 86/21 Gareth [2] 52/19 181/6 193/20 198/10
1475/15 175/24 182/20I fought [1] 125/9 112/24 123/23 152/5 I 52/21 202/25 203/16
1486/2 186/19 192/8 found [21] 26/15 158/16 181/5 181/21 Igave [12] 84/1 94/22 I gives [1] 52/12
4194/6 197/22 198/14 26/16 26/20 30/16 203/4 109/5 113/25 114/9 ing [5] 14/13 42/7
firstly [4] 41/8 53/23 53/10 87/9 87/17 fulsome [4] 122/23 I 124/12 125/19 142/1 I 58/7 143/3 204/25
67/1 183/7 94/23 95/3 111/9 function [12] 4/15 163/16 166/11 185/21) glad [1] 88/8
five [1] 196/2 125/8 129/19 129/20 I 4/15 4/20 5/1 6/16 204/14 GLO [4] 117/9 117/12)
132/24 133/14 136/12I 36/3 36/21 36/22 37/8Igeneral [11] 20/17 117/15 117/21
fix [1] 100/14 136/21 149/17 160/11] 87/13 111/17 121/4 I 31/4 31/12 88/11 I go [32] 15/20 24/23
fixed [6] 42/25 46/3
165/20 204/12 functioning [3] 27/23I 130/1 138/1 156/11 I 25/6 29/14 40/6 42/5
fredeumtty 4718 22 sour [6] 137/11 165/9I 122/10 157/21 159/3 172/3 183/8 I 44/24 45/3 45/9 54/23
flag [2] 157/20 171/23 171/23 190/4 Ifunctions [1] 92/8 184/17 61/7 66/2 66/5 86/18
494/17 198/14 fund [2] 60/22 60/23 Igenerally [5] 11/5 89/13 89/24 96/4
fourth [2] 104/15 Ifundamental [2] 14/19 54/8 77/4 96/10 116/9 116/24
(64) finalised - go
INQ00001203
INQ00001203
G 197/9 197/10 198/17 I 133/7 140/10 186/5 Iharm [2] 140/1 46/10 75/3 77/13
ae I 200/24 201/2 groups [2] 34/9 140/21 78/11 89/19 90/17
Cn be ee governance [27] 4/5 I 75/22 harms [1] 40/4 91/4 101/9 111/18
1454/12 164/10 164/20) 7/16 8/10 12/14 13/14Igroupthink [2] has [85] 5/10 6/4 9/2 I 129/17 181/1 193/14
1466/24 173/7 173/20 13/15 14/19 21/24 163/21 171/4 9/3 11/21 12/1 12/9 200/21 201/6 203/15
1486/6 32/3 35/4 48/3 48/15 I grown [1] 183/15 12/10 12/17 12/20 hearing [3] 118/23
oalposts [1] 47/9 55/13 56/13 57/4 57/9IGrowth [3] 2/21 2/24 I 19/10 19/12 23/4 25/4) 200/19 205/9
goes [11] 21/2 29/12 57/10 57/13 61/3 3/1 26/19 31/20 35/3 hearings [5] 149/6
ont 87/24 93/5 93/11 80/11 99/23 116/12 I guards [3] 168/18 36/21 40/16 47/14 178/17 197/16 198/14}
96/8 117/18 141/8 159/13 160/3 175/19 I 168/19 168/19 59/18 61/7 68/4 68/7 I 201/14
170/16 186/2 202/13 203/2 guess [2] 23/21 68/15 71/3 73/1 75/3 Iheart [1] 141/25
governing [1] 161/20I 161/6 75/4 75/13 76/7 77/24) heavily [2] 121/8
oane v3) oye government [56] 4/9 Iguessed [1] 77/20 I 78/3 78/24 78/24 138/9
33/14 36/13 57/14 5/13 5/15 6/3 6/21 guidance [8] 35/14 I 78/25 79/1 79/11 held [7] 15/8 50/19
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94/11 95/25 101/10 I 199/12 206/2 188/14 189/21 199/3 I 128/18 129/15 129/16Ihereto [1] 42/24
101/11 11975 119/15 IGratton’s [1] 23/15 I 199/18 129/21 129/25 130/7 Iherself [1] 180/1
119/18 126/2 126/9 Igreat [7] 10/13 19/22 Ihappening [8] 11/3 I 133/3 170/16 175/8 I hidden [1] 136/1
434/17 140/17 141/1 I 19/23 95/6 124/20 I 99/9 122/20 124/3 I 175/10 176/1 176/20 Ihigh [27] 11/1 11/2
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35/3 37/3 56/23 76/14I 178/20 181/14 91/21 93/2 103/23 Ineads [1] 110/7 188/23 190/25 195/19
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importance [1] 171/1
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Innovation [2] 106/9
111/21
input [7] 32/8 33/17
34/12 44/21 129/21
148/9 160/16
inquiries [1] 157/6
Inquiry [48] 2/11 8/14)
11/7 11/24 19/20
46/10 53/25 71/4
74/22 75/3 80/19
83/15 90/12 91/4
91/18 94/16 94/18
97/7 99/18 101/17
102/4 102/12 102/13
103/5 103/20 103/21
105/12 111/18 112/15)
128/12 129/11 134/4
(67) I tried - Inquiry
INQ00001203
INQ00001203
1 173/18 181/11 181/14] inverted [2] 118/9 117/4 137/10 142/12 I 158/15 158/23 159/4
inquiry... [16] 134/5 181/17 197/25 147/7 142/14 143/11 146/1 I 160/24 161/17 161/21
134/16 135/7 145/11 interested [2] 21/20 Iinvestigate [3] 133/3 I 148/3 149/11 150/3 I 165/15 165/15 166/24)
1452/20 155/19 159/23) 181/23 151/9 155/25 150/8 150/17 160/15 I 168/16 169/21 170/5
465/11 175/8 177/21 interesting [5] investigated [1] 163/2 169/13 178/1 17117 171/9 175/15
180/25 188/15 189/17 131/15 133/17 149/8 I 133/12 185/20 197/12 176/8 176/22 176/23
191/4 191/5 204/4 199/22 202/18 investigation [8] Issue 1 [1] 197/12 180/9 180/10 180/16
Inquiry's [1] 105/6 interests [3] 36/8 11/10 72/3 133/9 issued [2] 145/6 183/22 184/21 185/3
inserted [1] 82/2 36/19 163/17 134/10 136/7 148/12 I 199/24 186/2 187/13 188/5
inside [2] 190/22 interfere [4] 1/10 148/13 148/21 issues [80] 16/10 188/5 191/11 191/15
202/16 interference [1] 9/10 Iinvestigations [4] 16/16 19/1 21/2 24/20I 191/18 195/5 196/16
insight [1] 99/14 Interim [4] 128/18 33/8 135/21 136/4 25/2 25/9 29/20 29/25] 196/24 197/1 199/21
insisted [1] 187/16 182/14 182/23 184/6 I 153/13 48/25 50/22 53/22 199/21 199/22 202/18)
insistent [1] 183/9 interlocutor [1] 35/24 investing [4] 111/12 I 53/23 55/25 57/5 57/9) item [3] 49/7 55/18
insofar [2] 14/24 internal [10] 16/25 Iinvestment [12] 51/9 I 57/12 59/8 59/11 165/14
20/21 17/11 18/2 22/8 22/15) 52/4 52/5 57/13 64/20) 63/17 66/14 74/25 iterate [1] 34/18
installing [1] 141/15 23/22 114/1 167/25 I 104/17 104/18 114/12] 78/5 83/15 85/17 90/5/its [58] 4/5 5/1 9/8
instances [2] 16/8 170/15 172/6 115/25 116/8 162/10 I 98/22 100/1 111/5 12/1 12/23 13/10 17/2)
87/2 internally [1] 191/8 I 169/3 120/11 120/12 122/22) 17/17 36/19 37/8
instead [1] 114/25 interpretation [6] invitation [3] 101/13 I 124/17 131/10 131/14) 43/15 43/20 48/2
instinct [2] 83/12 144/12 171/8 175/14 I 103/1 169/7 132/23 133/14 134/19] 53/22 54/22 56/17
192/16 176/10 177/7 202/3 _Iinvite [1] 155/14 134/20 134/21 134/24I 58/5 64/20 65/2 68/11
instincts [1] 144/17 interpreted [1] invited [1] 129/14 143/19 143/24 144/8 I 69/10 75/19 81/7
institutional [2] 175/10 ; invites [1] 190/15 144/10 144/12 144/15) 94/24 103/22 107/3
1423/17 194/22 interpreting [1] inviting [1] 76/4 144/16 146/14 147/21] 108/15 108/25 112/17
institutionalise [1] 180/19 involve [6] 9/25 149/5 149/20 150/25 I 112/23 112/24 112/24)
158/1 intervene [3] 80/10 I 10/24 11/4 39/14 151/3 156/7 161/25 116/14 120/24 121/3
institutionalised [1] (121/12 122/15 114/4 186/24 165/21 169/24 171/17I 121/4 121/22 122/4
154/19 intervened [1] involved [29] 8/12 171/22 171/22 177/1 I 122/12 122/13 122/14)
instruct [4] 204/2 122/25 11/9 32/21 34/10 185/9 186/7 186/9 123/17 124/6 124/21
instruction [5] intervenes [A] 12/12 I 38/18 41/4 41/12 188/24 192/11 195/21] 127/13 132/16 132/21
175/11 179/24 180/19] intervening [1] 83/3 I 61/15 61/21 68/1 196/7 196/10 196/14 I 135/19 147/21 153/16)
186/16 186/17 intervention [5] 75/22 76/19 81/15 196/22 197/5 197/12 I 159/23 162/14 167/22
instructions [4] 10/10 10/11 12/1 81/17 92/10 94/2 197/15 198/9 199/1 168/17 173/4 173/11
41/18 41/19 41/23 13/21 80/4 102/9 109/14 115/3 I 201/5 202/4 202/4 187/6 187/6
42h0 interventionist [3] _ I 120/12 121/19 124/8 Iissuing [1] 120/15 _ itself [15] 9/25 30/23
insufficient [1] 26/8 181/25 191/19 191/23] 125/21 125/23 126/15]it [555] 36/20 83/20 100/6
insulated [1] 124/3 interventions [6] 135/22 141/16 143/16) it's [128] 1/16 6/2 8/1I 130/4 168/19 171/21
insurance [1] 62/12 13/14 14/3 67/24 194/24 9/14 11/14 12/5 14/20] 176/18 178/14 180/10
integral [3] 10/17 156/9 156/10 182/19 involvement [11] 15/4 19/8 19/23 23/15) 187/8 189/6 189/6
95/24 97/2 into [35] 4/25 11/10 I 62/8 62/17 71/5 76/1 I 23/17 27/6 27/6 30/22I 200/9
integrated [2] 25/11 13/5 14/9 17/15 17/17I 113/21 120/11 120/18] 30/25 32/13 34/17
64/10 18/4 18/9 19/9 34/12 I 124/10 125/20 156/23) 35/2 36/7 36/7 36/15 JM
integrity [5] 34/7 52/15 60/19 61/16 173/18 39/23 47/11 47/23 Jacobs [10] 24/10
79/6 127/11 162/24 64/5 65/3 68/3 76/6 IIreland [1] 105/24 51/21 51/25 52/6 24/15 26/15 30/7
163/11 100/23 101/25 102/20) irregularities [1] 72/9] 55/12 56/8 60/22 79/20 79/24 85/9 88/5)
intelligence [1] 103/12 111/23 112/3 Iis [551] 60/25 61/13 61/19 94/12 206/8
102/21 112/20 118/17 137/11Iish [1] 99/11 62/2 62/10 64/24 66/7I JAMES [4] 103/15
intended [4] 84/20 148/21 150/6 163/8 I Ismail [5] 24/10 66/8 66/9 71/7 71/20 I 103/18 140/13 206/14
1416/2 116/16 136/20 174/2 174/16 183/15 I 24/15 26/14 30/7 85/9I 75/24 75/25 76/20 January [9] 2/17 3/2
intends [1] 92/6 188/14 195/22 199/17Iisn't [13] 28/9 31/4 I 80/6 87/16 88/16 30/4 73/18 115/13
intense [1] 11/23 intricacies [1] 147/2 I 32/11 32/25 41/1 91/21 93/3 93/18 95/6I 117/2 157/23 182/24
intent [1] 183/6 intricately [1] 115/3 I 58/19 58/21 82/18 96/25 97/6 98/12 99/1] 189/18
intention [3] 45/21 introduce [2] 45/16 I 95/10 96/11 97/2 97/6I 101/20 108/1 110/9 I January 2015 [1]
186/4 204/8 64/2 143/22 110/22 111/16 112/6 182/24
interaction [4] 26/21 introduced [3] 57/1 Iisolated [1] 64/8 112/16 113/4 113/6 Ijargon [1] 159/4
33/5 45/7 143/11 93/17 130/7 issue [41] 11/19 113/9 117/3 118/5 JFSA [2] 146/17
interactions [5] introducing [1] 56/25I 14/19 19/5 28/9 28/11) 118/6 121/14 123/14 I 198/13
15/25 19/2 21/10 introduction [4] 47/8 I 40/14 41/22 41/25 123/19 127/7 129/1 I job [3] 98/8 143/6
21/13 129/19 48/1 56/23 63/4 43/1 51/16 53/17 129/8 131/1 132/4 162/6
interest [12] 11/14 intrusive [3] 68/3 54/24 57/3 57/11 133/17 133/19 134/1 Ijobs [1] 35/12
112/12 120/21 133/21 157/6 167/13 75/13 76/24 78/4 83/4] 139/11 142/16 143/14]join [2] 3/3 9/13
1459/3 159/7 160/14 Iinvaluable [1] 25/5 I 86/20 91/6 91/12 144/19 149/8 153/19 Ijoined [10] 2/17 3/12
inventing [1] 65/13 I 96/11 97/15 101/13 I 155/18 158/8 158/14 I 44/8 82/1 133/4 135/8
(68) Inquiry... - joined
INQ00001203
INQ00001203
J
joining [1] 14/1
jointly [2] 74/12 87/4
Jonathan [3] 133/16
133/23 151/16
Jones [1] 92/11
journalists [1] 31/6
187/1 187/2 192/14
192/17
judged [1] 129/25
judgement [4] 19/8
19/9 60/9 187/5
judgements [2]
160/7 163/1
judgment [28] 99/24
156/7 168/7 171/17
171/20 179/17 185/9
186/8 186/9 188/24
188/25 192/11 195/21
196/7 196/14 197/6
198/8 198/10 198/21
199/1 199/1 201/23
judgments [2] 82/4
190/24
judiciary [1] 176/8
July [6] 3/3 55/9
55/24 111/20 145/6
185/22
June [2] 136/11
183/21
junior [1] 61/18
just [82] 13/6 15/3
22/23 23/14 23/17
24/12 28/9 29/2 31/3
32/22 39/17 39/23
40/2 40/6 40/18 41/13
42/12 45/14 47/20
54/9 55/2 56/10 59/6
61/11 62/13 66/7 69/4
73/7 73/25 77/10 80/5)
88/20 92/15 93/24
94/12 96/9 99/1 99/20)
100/12 104/21 105/8
109/4 114/8 120/10
123/4 123/7 123/23
125/21 131/2 131/4
151/21 155/11 172/2
172/19 176/23 178/12)
182/13 182/13 184/11
185/14 185/20 186/8
187/15 188/5 188/10
188/23 189/5 190/9
190/11 190/17 190/24
191/7 193/8 196/3
196/5 198/21 198/23
199/2 199/21 200/23
201/6 203/17
joined... [4] 135/9
141/21 141/23 141/23] 136/20 151/11 164/3
judge [9] 19/5 124/24].
165/21 178/12 178/16 Ustly [1] 142/14
122/21 124/16 124/17)
197/10 197/10 197/12)
justice [11] 93/9
99/24 122/21 124/17
193/21 196/1 198/25
201/16
Justice Fraser [2]
198/25 201/16
justifiably [1] 160/13
justification [1]
190/16
K
KCB [2] 103/15
206/14
keen [1] 143/20
keep [1] 135/20
Kelly [15] 131/25
143/23 144/17 145/11
146/5 172/19 174/15
177/21 178/5 178/20
182/2 183/23
kept [2] 155/12
170/14
key [3] 122/1 150/8
169/11
kind [54] 17/23 33/7
114/21 123/8 125/3
125/12 138/4 138/8
144/11 144/15 147/8
147/9 153/22 155/11
155/14 157/8 157/13
159/7 160/2 160/21
161/8 161/13 162/9
163/21 164/4 164/10
166/10 168/14 169/25)
170/16 171/11 171/14)
171/16 176/25 178/17)
181/16 181/22 183/25)
184/16 185/6 185/10
186/23 187/25 196/17)
199/2 200/4
kinds [4] 175/23
King's [1] 92/5
knew [6] 137/13
156/1 161/12 176/1
191/25 192/5
know [211]
knowing [3] 22/23
166/17 202/16
knowingly [1] 135/13
knowledge [7] 2/8
82/8 105/1 134/6
135/4 154/23 168/7
known [13] 79/22
92/8 101/24 107/20
131/11 153/2 180/21
183/16 184/22 185/4
185/13 191/21 192/2
KPMG [1] 64/10
KC [1] 133/16
L
176/7
lacking [4] 147/6
land [1] 76/21
language [2] 71/17
182/6
large [2] 80/1 117/5
largely [5] 7/11 7/12
44/20 89/3 197/21
last [14] 13/5 78/10
79/12 79/13 84/17
85/17 102/14 103/7
184/8 200/3 202/10
203/8 203/18 204/19
late [4] 64/21 73/18
156/4 174/16
later [17] 2/17 3/3
139/14 142/24 143/18I 27/15 31/15 51/11
58/6 93/20 125/15
184/6 185/4 185/5
latest [1] 192/11
latitude [2] 97/25
204/14
latter [2] 53/5 77/10
launched [1] 197/9
35/1 39/24 44/10 64/9I'@W [14] 92/7 92/9
92/16 92/24 92/25
68/1 95/19 96/8 103/4 92/25 93/1 93/3 93/16I!eNd [1] 169/25
135/18 147/3 149/16
149/16 195/18
lawyer [4] 42/11
lawyers [22] 39/1
39/6 39/9 39/12 40/25
41/1 41/4 41/9 41/18
41/24 42/14 131/20
131/21 133/20 138/12
138/13 138/15 149/10:
176/14 176/15 178/21
198/20
lawyers’ [1] 41/2
lay [3] 156/24 169/7
202/2
layer [3] 18/9 167/18
167/19
lead [2] 107/2 129/1
leaders [1] 7/24
leadership [6] 3/25
35/8 156/20 164/25
171/1 186/5
lean [1] 128/2
learn [1] 47/14
learned [2] 58/25
189/16
least [11] 6/11 11/23
14/5 57/19 96/16
111/19 119/19 122/21
137/2 177/6 180/6
leave [2] 15/13 102/5
led [11] 42/21 54/21
67/10 99/22 131/23
lack [3] 8/14 127/25
140/13 140/19 141/3
153/13 168/8 172/6
177/23
legal [52] 45/18
89/9 89/10 90/12
90/18 90/20 90/23
91/13 91/14 91/20
97/20 120/23 121/18
122/5 124/9 125/6
132/1 132/14 133/8
134/19 138/8 138/23
139/16 144/6 144/16
149/13 149/20 151/1
169/24 171/3 172/2
172/6 172/7 176/3
177/1 180/4 189/17
126/17 137/24 147/17
149/25 154/22 154/23I 192/21 193/19 195/5
195/14
legalistic [2] 39/5
144/11
legally [4] 179/10
legitimate [5] 12/10
28/10 47/12 47/23
48/7
length [17] 4/16 9/2
107/19 108/7 108/13
108/21 108/21 109/8
110/8 112/23 113/23
162/3 170/25
lens [1] 18/4
less [7] 10/11 39/24
45/7 101/24 157/5
162/12 183/5
lessons [1] 189/16
let [3] 1/13 159/22
200/18
let's [7] 1/12 78/8
103/12 193/5 193/7
193/7 199/5
letter [16] 5/19 5/20
5/22 90/4 110/15
110/22 115/12 117/1
118/18 118/24 127/5
128/14 185/6 185/22
186/17 187/17
letters [9] 78/23
88/18 88/24 90/2
90/11 90/13 120/16
128/17 158/22
level [33] 11/1 11/2
11/3 12/16 13/20
22/18 24/17 32/22
32/24 47/11 49/20
65/6 65/13 65/15,
65/17 66/1 66/16 69/1
69/5 69/13 75/4 82/14
180/20 198/19 203/22I 122/10 126/4 157/5
left [7] 3/2 10/2 148/3I 159/24 160/13 160/13
45/21 46/4 46/8 46/13} levers [4] 7/14 8/8
90/23 91/7 91/7 91/13}lies [1] 147/4
156/12 166/11 167/25] 34/25 35/1 38/15 41/7
legislation [1] 153/18] 138/16 160/2 160/22
15/10 46/10 71/3 94/4} liked [2] 61/14 124/5
90/18 98/20 98/24
161/14 186/21
levels [4] 33/10
60/25 74/24 98/18
18/15 18/16
lie [1] 167/23
life [1] 128/9
lifted [1] 164/14
light [2] 34/5 83/15
like [60] 1/8 4/8 6/6
44/1 14/4 11/2 17/22
24/3 26/7 26/22 32/10
33/21 34/5 34/20
42/17 46/12 48/14
49/8 56/2 61/25 64/18
65/22 71/5 73/21 76/9
88/9 95/2 104/9
104/12 105/10 113/1
113/6 113/7 113/22
123/25 127/10 130/13)
130/19 136/25 137/20)
161/10 162/7 164/18
181/16 182/7 183/25
187/25 191/1 191/15
191/24 200/22 201/18)
203/1
likely [7] 14/18 112/7
118/5 118/6 148/8
172/15 199/4
limitations [2] 134/17I
136/23
limited [44] 63/19
96/22 104/14 109/15
109/23 110/3 121/22
4122/4 12/4 122/19
122/24 123/1 126/14
127/13 132/15 132/18
132/19 132/22 132/23
133/2 133/4 133/6
134/6 134/11 136/14
138/13 138/16 159/13
161/22 162/23 163/4
163/5 163/13 163/18
164/5 164/15 173/3
173/15 175/18 179/23
187/6 188/14 188/18
190/17
Limited's [9] 109/17
110/2 121/19 121/20
131/21 133/20 154/16
169/13 186/24
line [6] 13/15 58/10
81/2 102/16 129/14
179/3
Linklaters [1] 151/6
list [1] 27/9
listed [3] 15/8 117/22
(69) joined... - listed
INQ00001203
INQ00001203
L
listed... [1] 141/4
listen [1] 97/10
listened [3] 24/19
97/6 97/12
listening [1] 175/7
lists [2] 102/2 127/7
ated [1] 193/23
litigation [53] 111/13
114/20 115/11 116/4
116/21 117/3 118/11
124/12 124/25 125/17)
126/20 126/23 126/25)
130/22 131/10 133/7
137/11 137/25 139/1
139/8 140/7 141/13
141/22 141/22 141/24)
141/25 143/24 144/22)
147/16 151/14 151/21
153/10 154/18 163/22)
168/22 170/3 172/16
173/3 173/6 173/17
174/3 179/12 179/21
181/13 186/25 192/13}
193/4 193/16 193/22
195/15 196/17 200/19}
202/5
little [12] 14/10 25/17
27/15 29/9 31/15
41/13 54/9 77/11
93/11 157/13 157/18
165/25
live [4] 6/2 7/5 34/13
142/12
lived [2] 26/1 95/19
livelihoods [1] 25/4
Liverpool [1] 92/25
lives [1] 83/17
load [1] 152/18
lobbying [1] 146/17
local [1] 143/15
logistically [1]
158/12
long [16] 45/3 45/5
60/16 63/15 63/21
100/21 129/24 144/25)
153/14 153/19 158/2
161/4 163/25 170/20
172/8 172/10
longer [5] 47/16
52/18 116/5 164/21
198/2
longstanding [2]
173/4 194/6
look [24] 23/14 24/12
34/7 37/18 49/3 49/8
53/20 55/15 56/10
60/2 65/3 73/23 81/1
88/22 131/5 132/20
141/13 156/9 157/21
165/10 182/24 187/20)
199/20 200/2
looked [14] 105/12
142/15 142/22 149/7
150/18 151/21 152/2
152/7 152/15 163/23
165/14 183/22 184/3
187/2
looking [14] 33/2
80/8 83/16 88/23
132/13 133/17 134/9
137/12 149/2 155/22
155/24 178/1 192/6
199/23
looks [3] 32/10
193/17 203/1
loose [1] 134/17
Lord [3] 43/8 99/23
140/13
Lord Dyson [1] 43/8
Lords [1] 143/9
Lorna [4] 1/14 1/18
1/21 206/2
lose [5] 153/9 156/19
156/19 182/4 182/4
loses [1] 69/8
losing [3] 148/19
153/10 198/2
loss [6] 6/4 140/21
146/25 148/21 148/25)
150/5
loss-making [1] 6/4
losses [7] 6/5 139/24
140/3 140/15 140/18
140/25 148/20
lost [4] 86/7 171/23
202/8 203/20
lot [44] 9/16 13/9
16/18 31/7 31/13
32/11 37/3 45/2 60/24
68/5 68/8 76/12 76/14
76/22 87/1 90/17 92/3
125/9 134/17 134/17
134/24 138/18 143/11
144/5 148/1 153/11
153/11 155/3 156/13
156/16 158/10 159/25)
162/5 164/13 165/11
172/4 172/5 184/16
188/22 197/19 197/20)
201/24 202/5 202/7
lots [8] 19/8 70/2
98/14 113/7 113/8
131/16 152/16 170/15)
low [1] 161/14
lower [4] 45/14 45/24
53/10 157/5
lowest [1] 41/20
lunch [1] 101/1
made [52] 11/10
12/17 14/8 22/8 22/14)
22/19 23/18 24/10
24/14 24/24 28/13
31/14 32/17 34/14
42/18 43/6 60/6 61/5
63/6 66/22 71/10
86/24 88/12 90/3 91/1
91/24 102/9 102/15
104/23 104/25 110/12
115/15 118/21 119/6
119/14 119/14 119/15
119/20 127/15 128/6
130/21 149/21 151/15
156/7 159/18 159/20
185/18 186/15 187/21
189/9 193/20 202/5
magically [1] 95/13
magnitude [1]
125/25
Mail [2] 6/5 111/24
mails [1] 5/14
main [9] 32/1 49/15
53/23 111/23 112/4
112/20 126/9 142/21
169/10
mainly [2] 109/23
170/5
maintain [2] 53/3
173/11
maintained [6] 10/7
10/8 145/17 146/3
163/25 197/22
maintaining [1]
111/11
maintenance [1]
118/11
Majesty's [1] 109/25
major [4] 66/3 67/23
90/5 135/17
majority [1] 21/15
make [47] 12/24
15/11 27/19 34/15
34/18 44/15 48/2
48/13 59/17 60/4 61/8
63/14 64/11 67/19
67/20 68/21 86/16
101/12 101/15 103/1
103/8 104/10 112/11
114/10 117/12 118/15
119/17 126/2 138/3
140/16 141/1 143/20
146/23 148/19 156/5
156/9 166/19 174/2
176/15 176/16 178/9
180/11 180/20 187/16
189/4 195/4 198/21
maker [1] 87/20
makers [1] 32/21
making [26] 6/4
12/18 14/12 19/9
32/22 35/3 46/14
48/10 54/16 69/25
76/2 76/16 87/14 96/6
96/21 97/2 97/3 98/24
100/21 111/7 114/12
114/16 126/16 128/21
159/8 204/25
manage [1] 17/2
managed [5] 18/4
38/1 131/12 131/13
162/4
management [17]
7/16 8/9 12/23 15/15
21/24 22/4 33/21
55/10 61/3 68/8 76/9
80/11 107/3 116/13
131/8 167/24 170/18
managing [6] 110/21
126/8 127/8 127/25
160/1 169/1
mandate [1] 17/3
mandatory [1] 167/6
manifestly [1] 203/10)
manner [3] 29/4
127/3 193/22
many [16] 16/8 26/8
52/1 56/2 83/17 85/13,
92/20 98/10 107/14
111/3 121/25 124/22
136/16 148/25 167/25)
201/25
March [16] 48/18
49/6 50/5 50/21 63/17
66/14 79/3 122/22
124/17 141/23 171/17)
175/6 193/7 196/7
199/1 201/24
March 2019 [1]
122/22
March 2023 [2] 48/18)
50/21
margins [1] 165/20
marketing [1] 33/3
Markets [1] 106/2
Martin [1] 111/18
masse [1] 86/9
master's [1] 105/14
material [3] 33/3
151/11 166/11
matter [21] 9/24 10/1
10/13 12/8 16/4 19/8
60/11 75/3 84/17
84/22 100/13 126/3
126/15 133/3 137/13
137/21 168/16 187/2
187/14 187/18 187/20;
matters [21] 4/23
10/6 10/18 10/24 11/5)
33/17 40/15 83/19
83/23 85/20 86/2
105/8 105/12 107/14
121/12 127/11 130/20)
151/11 162/10 163/1
187/2
maximum [1] 186/14
may [44] 1/10 2/13
3/9 3/18 19/18 26/11
43/10 44/9 64/24
81/11 81/12 81/16
82/23 83/13 86/21
91/8 92/20 102/11
102/21 102/22 116/14)
119/3 130/22 130/25
131/6 132/5 132/7
132/11 137/25 138/24}
143/12 145/12 145/20)
146/6 168/10 173/13
173/15 186/18 190/9
197/9 198/18 199/18
199/18 201/6
May 2048 [3] 130/22
130/25 132/5
maybe [3] 7/22 176/9
176/11
me [51] 14/2 19/12
19/12 21/9 38/3 40/16)
40/18 44/21 44/22
50/20 58/14 58/20
62/20 65/10 67/10
67/11 68/12 70/12
72/18 74/10 78/6 78/9
80/24 86/12 92/13
99/2 101/9 102/14
102/15 102/21 103/6
103/9 110/15 123/3
128/12 134/4 135/7
138/11 149/10 150/24)
152/21 155/19 157/3
159/22 165/8 176/5
187/10 188/5 199/11
203/18 204/6
mean [22] 6/1 7/9
25/18 28/20 43/8
47/11 58/1 69/4 72/15
77/11 93/21 93/22
98/12 115/5 125/24
129/8 149/4 163/9
165/8 179/11 201/14
203/15
meaning [1] 93/13
means [10] 38/6
96/19 101/4 167/4
170/2 172/17 177/15
195/11 195/20 199/21
meant [11] 44/23
45/6 45/12 45/25
47/21 48/12 66/5
123/11 124/2 124/4
124/7
meantime [1] 153/12
meanwhile [1]
197/15
measures [3] 26/11
132/16 168/4
mechanism [3] 17/1
18/13 167/5
mechanisms [3]
16/20 166/19 167/14
media [3] 3/8 11/24
146/18
mediate [1] 145/2
mediation [2] 198/18
198/25
meet [3] 36/15 36/16
143/4
meeting [55] 26/22
26/25 27/6 27/12
(70) listed... - meeting
INQ00001203
1NQ00001203
M 79/19 misleading [1] 61/4 I 14/19 22/21 23/23 I 88/5 90/23 94/12 96/6
ray mid [1] 161/1 misogynistic [1] 25/17 26/11 32/7 101/19 122/21 173/8
a od mid-December [1] _I 71/17 33/15 34/16 39/21 I 173/10 173/20 174/23
30/15 30/16 30/16 I 1611 missing [1] 190/10 I 39/25 42/1 46/5 54/8 I 175/1 175/3 175/13
30/18 31/18 32/10 [Middle [2] 123/9 I misspoke [1] 91/11 I 61/21 62/16 69/19 _I 180/18 190/9 190/11
49/17 49/22 49/25 I 127/19 mistake [7] 116/25 I 70/7 72/24 73/3 76/12I 190/12 191/18 193/21
49/3 49/5 50/12 50/25I Might [19] 37/8 41/21) 119/6 119/14 119/14 I 76/16 76/19 76/20 199/8 203/23 203/24
51/11 51/14 51/15 76/5 77/14 78/1 79/10) 170/21 192/16 192/17) 83/8 92/16 93/11 204/1 204/18 206/8
51/17 55/8 55/9 55/16I 99/11 88/13 94/3 mistaken [2] 130/2 I 97/25 98/17 99/1 206/18
101/24 112/9 146/10 I 192/24 100/15 109/9 113/10 IMr Beer [1] 101/19
eet Crea 80/5 153/24 155/6 166/15 Imistakenly [1] 113/18 113/20 113/21IMr Bickerton [1]
69/19 74/7 87/19 176/7 185/1 185/10 I 193/14 115/3 118/6 122/22 I 60/3
97/24 127/16 127/20 I 209/13 mistakes [3] 66/21 I 123/1 125/5 125/14 IMr Cooper [8] 50/19
131/9 138/22 139/13 IMileage [1] 32/7 67/16 83/7 126/7 128/5 129/5 50/19 173/8 173/10
142/25 148/2 169/8 in [9] 52/6 mitigate [1] 169/15 I 131/18 135/24 136/14) 174/23 175/1 175/3
1469/17 169/18 174/21] 104/18 119/3 119/3_ Imitigating [1] 132/14) 138/20 145/1 145/1_ I 180/18
176/2 182/16 188/13 I 119/8 126/6 168/25 IMladenov [2] 49/11 I 145/9 145/24 145/25 IMr Cooper's [1]
195/13 190/5 193/15 49/13 151/20 152/9 153/7 175/13
meetings [20] 7/23 mind [11] 39/15 Mm [17] 66/20 88/14 I 153/12 153/17 155/24) Mr Creswell [5]
43/22 aud 20/5 20/9 I ©3/16 64/6 67/13 105/20 112/6 127/17 I 156/3 156/9 156/15 I 27/11 60/3 74/8 74/13}
20/11 20/13 20/25 92/17 147/12 158/4 141/2 141/5 145/5 157/21 160/14 160/14! 90/23
21/7 22/21 27/4 79/14I 166/25 171/9 178/11 I 166/21 166/23 169/16) 162/16 165/5 166/16 IMr Darfoor [1] 73/12
97/22 98/2 111/3 182/22 170/11 173/19 174/4 I 167/12 167/13 169/14IMr Elliot [1] 24/10
111/4 157/3 158/22 Iminded [1] 84/25 185/23 188/16 188/19) 178/16 181/18 181/25IMr Henry [7] 190/9
1465/13 190/1 minds [1] 158/11 Mm-hm [16] 66/20 183/5 183/6 183/9 190/11 190/12 199/8
meets [1] 68/25 mindset [1] 163/21 I 88/14 105/20 127/17 I 184/3 184/4 185/19 I 203/24 204/18 206/18)
Mel [1] 76/7 mine [1] 182/22 141/2 141/5 145/5 188/12 188/14 188/18I Mr Ismail [4] 24/15
member [9] 15/13. I™ al [1] 63/8 166/21 166/23 169/16) 191/23 192/21 192/21I 26/14 30/7 85/9
18/7 56/15 72/20 98/6I Minister [25] 3/5 170/11 173/19 174/4 I 194/4 194/24 194/24 IMr Jacobs [7] 24/15
99/16 163/13 165/25 I 14/15 14/15 26/23 185/23 188/16 188/19) 195/1 195/25 196/1 I 26/15 30/7 79/20 85/9)
177/14 27/6 31/19 51/12 mode [1] 6/23 196/18 197/2 199/5 I 88/5 94/12
members [16] 11/1 51/15 86/5 86/17 model [1] 35/1 morning [13] 38/5 Mr Justice Fraser [2]
13/20 28/8 30/20 86/23 92/16 92/23 moment [10] 6/5 7/4 I 38/13 38/14 60/5 122/21 193/21
40/17 56/3 61/6 65/5 115/17 115/21 116/16] 7/6 30/11 34/13 83/22 88/7 92/3 94/16IMr Mladenov [1]
73/1 73/21 94/21 131/25 133/1 138/6 I 124/19 153/25 155/23) 100/23 174/15 180/12) 49/11
98/12 99/11 100/9 142/24 173/24 180/21I 193/8 197/1 199/13 205/4 Mr Parker [2] 191/18
166/1 184/7 183/19 188/6 203/22 IMonday [7] 31/23 _Imost [16] 11/15 53/2 I 203/23
memo [13] 27/25 ministerial [2] 80/4 I 37/17 78/21 174/11 I 75/6 75/8 75/11 80/11IMr Parker's [1] 204/1
28/1 28/6 28/10 28/11 160/13 180/6 180/7 180/13 I 85/19 92/9 101/18 Mr Patterson [1]
28/21 29/21 30/22 Ministers [38] 6/8 _Imoney [35] 12/19 I 111/21 132/7 144/8_ I 78/21
30/23 174/12 177/20 7/23 8/2 8/8 8/19 8/23) 13/8 13/11 39/16 152/19 184/7 189/20 IMr Read [1] 96/6
178/1 180/8 9/17 16/4 21/4 80/10 I 39/20 39/21 40/3 198/16 Mr Recaldin [1] 42/8
Memorandum [2] 82/14 87/2 107/7 45/17 46/11 46/15 mostly [1] 140/10 Mr Saf [1] 24/10
4/11 202/21 121/3 121/15 121/18 I 48/8 66/8 68/7 68/8 Imotivation [1] 45/25 IMr Staunton [3] 71/2
memory [1] 141/7 121/23 122/8 122/15 I 69/8 69/16 69/17 70/7IMOU [3] 4/13 4/19 73/9 73/11
mentioned [12] 122/19 122/25 124/1 I 85/19 110/20 110/21 I 86/15 Mr Tidswell [1] 74/8
18/17 30/11 52/23 124/7 143/4 143/13 I 118/9 118/9 118/15 Imove [7] 16/19 24/3 IMr Watson's [1]
69/7 76/18 98/13 151/3 154/17 160/7 I 119/6 119/15 126/8 I 34/20 38/15 82/7 173/20
98/19 119/2 123/20 161/24 162/17 173/13] 127/9 127/25 153/11 I 94/12 172/23 MS [33] 1/19 2/10
1452/1 190/24 191/7 175/16 180/13 180/16] 169/2 189/19 193/15 Imoved [2] 160/22 2/10 23/15 70/15 74/5
merger [1] 106/8 183/23 184/22 188/22I 193/18 196/1 162/7 77/13 79/25 86/4 88/6)
merit [2] 47/25 57/2 I 190/1 monitor [4] 4/5 moving [4] 81/1 92/1 I 88/7 92/4 94/7 94/8
merits [2] 188/14 minor [1] 104/9 monitoring [1] 159/11 195/22 94/10 94/11 100/19
1493/5 minutes [8] 30/12 114/22 MP [1] 140/13 100/21 101/2 101/8
message [3] 41/5 49/3 49/5 55/15 57/23I month [3] 51/12 MPs [4] 139/23 103/10 103/16 119/11
41/6 68/15 65/2 70/14 97/24 149/6 193/1 140/13 142/25 144/1 I 132/2 154/1 179/22
messaging [1] 31/20 Misalignment [1] Imonthly [4] 20/24 Imr [53] 24/10 24/10 I 190/9 199/12 204/22
met [7] 30/14 31/23 23/4 21/1 27/6 51/15 24/15 24/15 26/14 206/4 206/10 206/12
53/13 69/24 79/1 misapprehension [1] Imonths [9] 81/24 26/15 27/11 30/7 30/7I 206/16
89/17 143/7 200/18 85/17 125/4 129/18 I 42/8 49/11 50/19 Ms Burton [1] 74/5
meticulous [1] miscarriages [1] 138/20 141/23 190/5 I 50/19 60/3 60/3 71/2 IMs Gratton [10] 2/10
114/16 164/2 196/2 196/14 73/9 73/11 73/12 74/8] 70/15 77/13 79/25
microphone [1] misguided [3] 156/8 Imore [100] 1/17 7/1 I 74/8 74/13 78/21 86/4 88/7 94/11
172/9 192/19 10/10 10/18 12/20 79/20 79/24 85/9 85/9} 100/19 100/21 199/12
(71) meeting... - Ms Gratton
INQ00001203
INQ00001203
M 151/3 154/15 156/16 I 49/23 54/25 58/8 93/1INFSP's [1] 32/15 none [1] 136/4
Ms Gratton's [1] 156/16 158/22 162/23] 100/9 113/25 125/22 INick [15] 27/2 27/7 Inor [4] 21/17 124/1
23/15 166/25 168/7 168/7 I 126/23 144/16 156/18] 29/11 63/14 110/14 I 173/6 174/3
MS HODGE [6] 1/19 168/8 171/8 174/13 I 159/9 160/15 164/9 I 127/16 127/23 128/4 Inormal [3] 19/25
2/10 92/4 94/7 101/2 174/23 178/2 180/8 164/11 169/4 189/4 128/17 128/22 128/24I 59/13 59/20
5068/4 188/21 191/21 194/14] 189/13 195/12 195/15] 129/14 129/19 130/13] not [259]
Ms Price [7] 101/8 I 194/14 195/8 200/17 Ineeds [6] 8/22 9/7 I 170/19 notably [1] 163/1
103/10 103/16 132/2 I 203/3 204/7 18/11 67/5 130/15 I Nick's [1] 127/25 _I note [40] 20/24 21/1
154/1 204/22 206/16 IMyopia [1] 164/4 200/7 no [65] 2/24 6/13 28/12 28/13 28/13
Ms Tolhurst [1] myself [14] 11/4 27/8Inegative [1] 175/23 I 16/14 18/3 21/25 23/7) 32/10 32/11 63/12
179/22 87/9 87/17 118/6 _Inegatives [1] 194/14 I 24/1 27/6 37/16 45/20I 132/4 170/19
Ms Vennells's [1] 124/1 124/7 132/1 I negligence [2] 48/12 49/19 52/18 —_Inoted [3] 49/20 50/3
119/11 138/5 144/17 178/21 I 146/25 150/12 53/19 57/4 57/25 63/8I 87/8
Ms Watt [2] 94/8 180/25 181/3 194/13 Inegotiated [1] 42/23 I 74/19 77/6 78/14 notes [1] 22/21
190/9 N_ Iegotiation [5] 39/6 I 78/15 78/16 80/22 I nothing [3] 78/23
much [50] 1/17 9/10 I ————— 41/14 131/20 155/2 I 80/23 86/13 94/5 133/21 136/17
26/7 27/22 34/13 name [5] 1/20 2/10 I 155/4 99/10 101/14 104/24 Inotice [1] 60/4
39/21 39/25 45/6 103/17 103/19 133/22I negotiations [3] 109/7 112/19 116/4 Inoticed [1] 119/1
45/10 47/16 47/16 \namely [1] 76/24 125/10 161/14 199/17I 118/1 120/23 124/9 I notwithstanding [2]
50/18 51/2 61/21 National [1] 108/18 Ineither [2] 124/1 125/16 127/12 132/23I 108/15 176/11
69/17 79/21 8g/14_—(IMative [1] 182/6 174/3 133/13 134/22 135/2 Inovel [1] 66/2
natural [1] 198/1 network [15] 6/20 135/4 136/2 136/12 INovember [4] 1/1
ood tO oat naturally [1] 181/19 I 6/21 7/10 7/11 37/9 I 136/21 145/7 145/14 I 133/8 197/11 201/15
112/23 113/6 113/23 Iature [9] 17/24 37/12 52/3 52/3 52/7 I 145/18 145/22 152/25I November 2018 [1]
431/21 137/17 144/10 22/20 24/17 129/7 52/22 53/3 60/15 153/5 160/19 170/2 I 201/15
153/7 160/6 162/12 141/17 141/18 143/14) 141/42 114/10 118/10] 173/18 177/16 180/1 I now [63] 1/16 4/12
162/16 163/17 168/10) 147/3 201/21 neutral [4] 43/9 190/9 193/12 193/14 I 18/4 26/11 26/12 38/4
470/22 17216 186/14 INBIT [16] 49/8 49/14 I 126/19 181/23 196/5 I 194/9 199/9 199/21 I 42/12 45/9 48/17
490/13 191/5 191/11 I 90/4 50/9 50/16 54/8 Inever [10] 37/1 87/9 I 202/18 203/4 204/17 I 51/25 52/16 52/18
4191/23 192/13 199/5 I 95/11 55/20 56/17 I 93/1 100/10 102/17 Inobody [4] 31/7 52/19 62/6 62/13
499/9 200/14 201/3 I 57/24 61/2 61/9 64/7 I 118/15 121/17 134/3 I 69/25 70/8 200/18 _I 62/15 64/19 71/6
204/14 204/24 2085/6 I 88/9 68/16 71/12 162/24 177/13 nodded [8] 3/13 7/21 I 80/17 81/11 82/10
multiples [1] 56/5 necessarily [6] 6/13 Inevertheless [3] 75/2 75/5 81/14 81/23I 89/11 92/1 93/24
Munby [3] 46/11 7/11 41/20 100/15 I 188/2 192/22 201/23 I 84/3 85/12 99/24 102/8 103/6
52/19 53/9 158/11 162/17 Neville [4] 8/4 132/25Inodding [1] 71/20 I 103/9 105/5 106/23
must [8] 36/15 36/16 [Necessary [19] 8/8 I 203/19 203/25 Nolan [3] 127/3 110/19 116/4 119/2
62/18.93/19 112/10 I 58/11 67/3 87/15 I Neville-Rolfe [1] 8/4 I 127/24 128/9 119/21 129/2 129/2
4153/2 153/4 194/17 I 120/10 126/24 129/23I Neville-Rolfe's [3] __Inon [35] 3/15 3/22 I 129/9 130/18 133/23
130/6 144/23 157/9 I 132/25 203/19 203/25] 10/22 12/2 12/25 134/13 136/18 137/23
mumalisation i] 159/19 159/21 161/20Inew [44] 33/21 43/23] 13/16 13/17 13/21 140/13 142/9 146/19
my [97] 2/10 8/12 164/23 179/20 184/15] 44/13 44/19 45/16 16/12 17/5 24/11 150/20 150/25 155/18}
Bit 820 13/12 13/25I, 189/15 189/15 189/22] 48/14 48/16 51/7 25/10 28/2 28/15 166/17 168/7 168/10
44/1 14/3 21/1 22/2 INED [10] 16/13 35/10) 52/16 54/10 56/16 _I 28/19 28/23 29/10 170/6 174/20 176/4
23/21 24/15 24/18 I 90/17 35/24 73/2 63/3 63/5 63/23 64/2 I 30/19 34/21 38/19 176/19 183/18 188/9
25/24 31/4 31/12 34/1I 89/15 96/7 99/4 99/5 I 64/3 64/19 65/18 48/19 63/20 72/24 I 189/23 189/25 191/7
36/6 39/15 41/11 99/9 65/21 65/21 68/8 72/6I 73/4 87/20 95/15 191/24 194/2 204/19
41/15 42/2 44/8 44/21INEDs [12] 94/19 88/17 94/3 110/13 I 96/18 96/1997/16 _Inuance [4] 79/4
44/23 47/15 50/11 I 24/23 95/6 95/8 96/13) 120/4 120/17 125/3 I 98/1 98/4 99/12 nub [1] 96/11
52/10 56/2 56/21 96/15 96/17 97/11 130/1 133/3 141/19 I 108/19 113/17 116/2 Inuclear [5] 80/18
36/21 56/24 57/11 I 97/12 97/14 98/16 I 157/24 159/16 170/18INon-Exec [1] 98/1 _I 82/21 83/1 83/9 112/9
61/16 61/20 64/6 64/8 187/7 172/2 172/2 172/3 Non-Execs [3] 28/15 Inumber [23] 5/9 5/12
64/15 68/4 72/15 need [36] 7/2 14/22 I 172/3 172/3 184/6 I 28/19 28/23 22/19 31/10 49/7 53/4
72123 73/7 73/10 15/1 16/1 26/18 27/22I 184/19 187/25 192/25INon-Executive [22] I 54/16 60/16 61/8
73/00 73/28 7a14 I 22/24 28/20 32/21 I 198/12 3/15 3/22 10/22 12/2 I 63/12 71/7 80/1 96/21
79/3 7977 79/19 81/18I 22/10 47/1 50/1 55/12\newly [1] 106/2 12/25 13/17 13/21 I 112/13 128/23 129/18
81/19 83/12 86/19. I 00/12 65/14 70/8 newly-formed [4] 16/12 17/5 24/11 129/24 139/23 140/4
87/1 B7/18 89/15 86/13 87/11 99/18 I 4106/2 25/10 28/2 29/10 143/7 151/1 152/13
92/24 102/17 103/19 I 115/21 115/24 125/20I news [1] 174/11 30/19 34/21 38/19 I 194/5
104/15 110/16 111/8 I 126/15 126/19 129/3 Inext [7] 93/17 101/12I 48/19 63/20 95/15 Inumber 3 [1] 49/7
4118/5 121/17 121/21 I 129/23 131/16 131/18] 104/20 104/21 174/15] 96/18 96/19 97/16 I numbers [1] 53/3
155/6 157/20 167/17 I 177/8 184/9 non-financial [2]
ioany ioerte wea 179/22 188/11 191/14INFSP [7] 33/24 34/6 I 108/19 113/17 fe)
130/12 143/12 150/16 195/19 200/3 75/21 94/14 98/11 non-transformation I object [1] 173/24
needed [20] 28/22 I 99/19 100/3 [1] 116/2 objections [1] 175/5
(72) Ms Gratton’s - objections
INQ00001203
INQ00001203
° 90/2 90/25 90/25 160/23 161/19 163/5 I 82/21 83/1 83/8 originally [3] 139/4
ea I 91/22 164/14 165/22 181/9 I 183/20 203/18 203/21
oplective [5] 6/15 offered [1] 91/20 _I 182/3 183/3 184/2 _ or [134] 1/12 7/7 7/20I originated [2] 44/11
68/20 offers [5] 43/25 184/6 185/20 187/22 I 8/19 14/2 14/3 14/13 I 56/20
objectives [12] 5/3 46/12 48/3 48/10 193/17 197/4 14/14 15/8 18/11 other [59] 5/15 6/25
5/5 5/7 10/5 35/8 36/1I 158/13 onerous [1] 66/18 I 19/17 21/2 23/4 29/13] 9/2 11/1 12/23 13/17
36/9 36/17 69/20 84/9I Office [370] onerousness [1] 32/5 33/8 33/8 36/21 I 19/15 19/17 22/3 22/4I
B4/11 115/23 Office's [41] 4/4 7/12I 67/14 40/8 40/8 40/19 41/23) 25/1 27/7 31/20 32/17!
obligation [21 36/21 I 102 18/5 20/6 25/3 ones [2] 72/13 42/2 45/14 50/10 33/5 33/24 34/9 35/19
rer 26/3 36/7 37/14 38/16I 128/11 50/15 50/16 54/8 35/23 40/17 53/4 56/2
38/20 38/21 39/1 39/6] ongoing [10] 13/3 54/15 56/19 61/23 58/5 59/18 59/21
39/8 39/12 43/21 62/8 76/24 116/3 63/25 64/21 65/7 63/12 71/10 96/2
43/23 55/19 59/16 116/15 132/16 134/25) 65/17 66/1 66/2 66/21I 99/16 110/21 113/1
67/15 68/4 70/9 79/7 I 169/3 173/17 193/3 I 66/23 67/18 72/13 113/4 113/15 114/3
80/11 90/6 97/18 only [22] 1/457/10 I 72/14 73/13 77/21 123/22 125/19 140/19)
109/12 114/5 119/23 I 68/6 88/8 90/25 114/7I 77/22 78/10 78/24 140/21 141/6 142/16
129/22 135/2 138/1 I 116/6 118/14 123/8 I 81/2 81/11 82/4 82/13] 143/8 144/21 155/17
140/14 146/18 151/13) 130/3 134/19 137/11 I 82/23 83/5 84/22 85/6I 155/22 163/23 165/10}
obligations [4] 53/4
135/20 144/13 167/9
obliged [1] 4/25
obscure [1] 168/20
obscured [1] 122/3
obscuring [1] 122/18
observer [2] 48/22
63/25
observing [2] 201/5 163/25 169/14 174/7 I 141/7 152/20 165/15 I 85/19 86/7 86/17 166/1 166/1 166/25
201/9 179/1 186/3 168/3 172/17 182/16 I 86/19 86/21 86/23 168/12 168/13 170/15)
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tone er aeeae 109/13 paragraph 156 [1] 146/17 155/7 167/10 I 132/16 132/17 142/13
page 15 [2] 15/4 172/25 part [49] 11/23 13/2 I 189/21
toras teareo oe e8 16/24 paragraph 163 [1] I 28/6 28/13 32/8 52/2 Ipatch [1] 29/16
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92103 5035/9 189/12 198/18 150/25 151/12 181/8 I 100/5 105/22 107/7
principal [15] 17/15 [Processes [6] 12/13 Iproposal [9] 14/17 I 107/11 108/15 108/19
Teases sie I 17/1359/17 67/22 I 32/15 33/16 33/20 I 108/20 110/20 110/21
58/13 60/19 61/13
61/23 67/10 67/12
73/10 78/18 81/11
91/12 91/14 102/4
102/6 102/11 102/15
14/2 131114 51/8 56/13 56/19 I 111/25 112/16 113/17
Toone sor tree [Procurement [2} I 56/20 99721 113722 11512 115/11 I oat ee
tote 14417 113/13 U6 S17 proposals [2] 34/1 I 119/23 122/14 123/10] Janra4 sq 196/04
tae 160 produced [1] 112/25 I 166/19 423/12 123/13 126/8 I 499/14 s9D/10 200119
principle [3] 9/24 [Producing [1] 22/22 propose [1] 70/13 I 127/2 12716 127/13 I ectioned [14] 1/19
ea product [2] 75/25 Iproposed [4] 43/21 I 127/13 127/25 12819 I Questioned L'a] tits
principles [18] 14/21I 158/13 99/19 100/2 186/14 I 128/19 128/24 129/2 I 105/48 100/19 o06/4
sea enes aL, yoi14I Productive [1] 82/18 Iproposing [3] 61/8 I 129/13 152/13 15816 I ye pee soa/t0
todd aa/s ave azo [Products [3] 33/3 I 63/2 63/14 158/9 158/18 158/18 I Sees oce/46 SO6/18
sons dang agi I 64/12 67125 prosecuted [4] 159/10 160/4 162/2 I A Sing 6) 1/11
dae 44/4 44/0 127/4\ Professional [3] 140/17 141/3 142/2 I 167/12 168/3 169/2_I@uestioning [6]
toa 1098/0 159/25 162/25 177/17I 185/16 478/12 181/16 189/15] Joriae apoio
prior fo} 14/1 30/14. [Professionalism [1] prosecuting [1] 197/24 202/20 questions foo) 2/11
48/1 50/14 57/19 62/8) 163/12 14215 Publicly [2] 14/23 I 319 4/8 16/20 26/22
85/1 90/25 196/22 Profile [1] 53/2 prosecutions [6] 16714 34/20 70/16 77/6
ies [1] 127/22 profit [2] 117/8 159/8I 78/18 142/10 142/11 I published [4] 28/9
prio program [1] 61/9 I 144/14 150/46 152/23) 97/24 105/6 112/25 I 27/10 86/3 92/3 94/6
prioritise [1] 8/5 " 94/14 94/17 100/22
riority [2] 60/18 programme [57] 2/16Iprospects [1] 151/13Ipublished/produced 101/22 102/2 103/20
rreur 12/15 48/15 48/16 _I protective [4] 121/23] [1] 112/25 ige/6 138/8 142/16
rivate [6] 2/21 3/4 48/17 49/1 50/4 50/9 I protocol [3] 125/10 I publishing [3] 76/2 1484/2 190/6 190/7
Ons 21/21 105/21 50/17 50/23 50/24 131/23 155/3 76/12 89/17 1490/10 195/17 197/16
128/25 51/13 54/8 55/5 55/11Iprotocols [1] 194/12 I purely [5] 8/13 14/21 201/21 202/2 204/19
rivately [1] 15/8 55/13 56/1 56/3 56/13) protracted [2] 45/4 I 65/17 71/20 73/12 uick [4] 23/14 48/11
erivile 2 [41 92/23 I 56/18 57/5 57/9 57/11] 46/5 purpose [6] 16/6 (Var tors
P26 38/8 1439/17 57/12 58/2 58/4 58/7 Iprove [3] 146/24 111/11 158/4 158/21 quicker [4] 45/6 45/8
probably [23] 12/15 59/8 59/12 60/14 148/13 150/11 158/23 162/14 45/13 48/13
20/10 20/10 62/24 60/19 60/21 60/22 provenance [1] 82/2 Ipurposes [4] 105/3
60/25 61/2 61/3 61/15] provide [30] 5/13 108/22 115/3 116/22
70/5 77/13 81/17 83/9 130/14 156/15
82/16 112/13 113/19 61/16 61/21 61/25 9/17 10/12 12/11 pursue [1] 195/15 199/5 201/1
1341/8 147/11 157/1 63/2 63/4 63/9 63/13 I 13/17 15/24 17/4 18/4I put [19] 53/11 53/16 uid [1] 52/6
157/11 161/6 163/16 63/17 64/1 64/8 65/9 I 18/9 21/1 23/23 33/17) 64/11 87/11 95/5 q
quite [33] 22/20
164/21 175/17 176/9 28/25 29/1 31/9 39/11
177/25 181/18 182/21
41/9 60/22 61/1 61/18
quickly [6] 45/15
66/5 66/8 66/16 66/24] 34/11 35/14 44/24 96/25 108/20 114/21
67/15 67/23 68/22 54/5 54/9 86/22 89/7 I 130/16 136/17 145/20
69/18 189/7 98/6 99/13 111/2 179/8 184/19 185/24
195/6 programmes [2] 116/18 135/13 157/6 I 188/10 195/1 19/5 I 62/19 64/6 64/8 68/S
probing [1] 151/20 68/8 76/12 85/6 91/21
69/17 108/8 158/20 160/21 168/1 I 200/24 204/5
problem [4] 16/11 2 97/14 112/13 113/8
progress [2] 63/8 177/11 204/3 putative [1] 88/18
102/22 102/22 145/15I A ‘ 143/11 156/10 156/13
76/20 provided [8] 55/4 putting [2] 103/3
problems [9] 25/7 164/19 165/21 171/9
progress/no [1] 63/8 I 121/24 122/23 136/14] 193/1
36/4 50/16 56/4 60/24I Pros aon ee eae lave ISiy 184/16 200/11 200/17’
145/8 145/18 145/22 IProject [7] 5 201/24 203/2 203/24
28/1 29/15 29/20 152/4
(76) pretty... - quite
INQ00001203
INQ00001203
Q reading [3] 146/6 _Irecently [4] 39/12 reference [20] 21/9 [relation [44] 8/10
quite... [1] 204/20 180/7 201/19 75/6 75/8 188/12 23/18 28/1 34/10 49/4! 15/24 16/25 17/25
uo 1] 464/21 readout [7] 26/25 recognise [3] 170/23} 54/7 55/18 65/1 75/21] 18/19 29/22 40/23
ciotation Ti] 191/18 I 27/3 31/17 51/13 96/3] 171/1 204/17 75/25 94/18 105/3 I 41/22 43/3 50/16 51/6}
Note [3] 92/17 127/20 179/5 recognised [2] 126/9 127/8 128/10 I 53/21 53/22 53/23
Oona 199/25 reads [2] 31/19 49/9 I 123/23 200/3 145/3 186/7 186/9 54/8 55/1 57/5 62/22
uotes [1] 28/8 ready [2] 101/8 recognising [3] 92/9 I 188/12 196/6 63/17 64/19 65/4 65/8
quotes (1) eee I 181/21 115/24 127/25 referred [13] 28/12 I 66/16 66/22 66/23
R real [3] 149/20 recognition [3] 56/12) 33/16 53/25 85/8 72/10 72/19 75/11
RACHEL [3] 1/18 172/21 177/19 167/3 186/24 85/15 108/19 115/9 I 75/15 77/2 77/16
1/24 206/2 realistic [1] 6/15 _Irecollection [1] 56/2 I 118/22 127/6 142/19 I 77/24 87/18 98/22
racist [1] 71/17 reality [8] 86/6 122/2 Irecommend [1] 169/1 171/2 185/13 I 102/23 112/17 116/3
raise [3] 38/24 122/48 141/12 153/21I 129/11 referring [6] 31/24 I 126/20 131/9 134/9
102/24 103/6 155/15 168/20 199/18I recommendation [2] I 32/15 42/25 135/6 I 139/1 143/23 148/5
raised [21] 13/25 _ IFeally [21] 6/2 19/7 I 22/9 22/14 145/20 177/25 168/9
19/24 28/2 29/7 29/20] 26/15 28/14 30/13 recommendations __Irefers [1] 133/23 relations [3] 130/11
29/25 30/6 48/25 31/3 33/22 44/21 62/1) [5] 22/20 92/11 reflect [3] 13/23 161/21 183/14
50/10 51/16 55/11 82/25 96/11 97/6 134/2 134/18 152/18 I 59/22 190/18 relationship [13] 4/9
55/20 55/22 57/6 97/13 141/15 152/24 Irecommended [4] reflected [2] 14/2 22/16 28/14 28/18
66/15 85/9 90/11 91/5] 195/14 159/2 161/21 I 23/8 74/14 151/16 14/9 30/10 31/9 69/21
443/24 167/3 170/9 I 163/22 184/13 202/5 I 198/25 reflecting [2] 6/10 82/19 120/4 120/22
raises [1] 115/13 realm [3] 127/13 recompense [2] 87/21 157/21 159/17 169/5
raising [3] 28/17 158/18 160/4 189/4 189/5 reflection [3] 74/19 Irelationships [1]
58/23 58/24 realties [1] 203/5 reconcile [1] 163/3 I 191/21 194/3 35/9
ramifications [1] reappointing [1] 83/3Ireconciliation [1] reflections [4] 8/12 [relatively [4] 39/16
162/13 reason [10] pone 134/21 / 88/11 150/23 sete 139/8 140/8 162/11
112/20 124/10 125/19I reconsider [1] 58/7 Ireform [2] 189/6 relay [1] 175/4
range [5] oe 916 81/5) 13719 158/19 162/24 Irecord [4] 16/4 189/12 relaying [1] 65/11
ranging [1] 61/1 177/16 180/18 188/7 I 135/20 179/14 180/23I reforms [1] 193/2 release [3] 52/22
ranks [1] 93/10 reasonable [1] recorded [6] 21/10 refusal [1] 194/6 53/1 199/24
rapid [1] 130/8 187/14 32/5 54/25 57/23 refuse [1] 194/19 relevance [1] 105/11
rate [2] 112/12 reasoning [2] 186/6 I 140/16 144/19 regarding [4] 8/22 _Irelevant [4] 27/16
162/25 188/4 recording [2] 16/21 I 94/19 154/17 175/9 I 80/16 85/6 135/21
rates [2] 16/7 70/4 reasons [10] 19117 I 54/2 regime [2] 52/2 reliability [6] 70/1
rather [25] 14/13 19/17 26/9 44/18 recount [1] 39/15 I 160/10 76/25 77/12 77/16
15/16 18/13 22/22 53/21 60/16 118/10 recover [3] 77/22 registers [2] 17/11 78/4 78/19
29/4 30/21 30/23 39/9I 120/9 126/13 195/14 I 78/12 148/20 18/2 reliable [3] 68/25
40/12 42/22 57/3 reassessing [1] recovering [1] 77/19 Iregret [1] 57/25 69/22 70/9
58/13 59/19 73/6 83/9I 68/19 recovery [3] 75/1 regrets [1] 63/8 reliance [1] 77/18
141/12 146/2 153/22 Ifeassurance [3] 78/14 165/1 regularly [1] 27/8 __Ireliant [2] 36/13
457/9 157/11 157/19 I 34/12 54/5 152/4 recusal [20] 129/25 IRegulation [1] 121/8
178/14 182/22 192/17Ireassured [1] 119/11] 156/8 171/20 172/11 I 105/24 relied [1] 166/12
195/19 reassuring [2] 137/2 I 172/14 172/21 173/24) reimbursed [2] 90/24) relieving [1] 36/20
ratio [1] 47/17 137/2 174/7 174/11 175/10 I 90/24 reluctantly [2] 84/17
ration [1] 157/17 rebuilt [1] 168/11 176/7 178/5 179/3 reinforce [1] 129/11 I 188/7
rationing [3] 138/18 Recaldin [1] 42/8 180/3 181/24 185/8 Ireinforced [2] 155/18) remain [3] 5/16 36/13}
154/25 194/21 recall [15] 23/12 192/18 195/24 197/8 I 182/22 110/25
reach [4] 15/19 44/2 23/20 29/25 40/10 198/15 reinforcement [1] remainder [1] 104/19
65/25 161/4 43/7 50/18 51/19 recuse [3] 174/21 202/23 remained [2] 106/14
reached [5] 59/13 51/22 55/6 62/18 176/2 180/19 reinstated [1] 195/8 I 198/1
402/21 162/25 181/8 I 64/23 143/22 149/24 Ired [2] 157/20 194/17Ireiterate [1] 47/13 [remains [2] 68/18
181/10 174/21 178/6 redress [4] 38/16 relate [2] 17/3 88/9 I 69/2
reaching [2] 15/12 recalled [1] 61/1 38/21 45/8 45/13 related [12] 29/4 remarkable [1]
59/24 receipt [1] 90/25 reduce [3] 45/17 I 40/10.42/14 48/25 I 102/19
reactive [2] 57/3 59/9I receive [4] 36/12 45/20 188/6 60/14 61/2 69/17 71/9] remarks [3] 68/21
read [23] 27/2 27/7 I 36/17 85/1 133/15 reduced [1] 186/14 I 72/5 113/14 116/3 I 193/20 202/6
29/11 86/14 88/20 Ireceived [9] 14/18 reduction [2] 46/8 I 116/7 RemCo [1] 187/6
90/6 96/6 110/14 28/12 43/24 50/14 63/8 relates [3] 31/1 39/1 Iremedial [1] 151/16
127/16 128/5 128/17 I 51/4 55/21 117/22 Ireductions [1] 88/11 remediation [8]
428/22 129/14 129/19I 163/9 181/3 187/17 relating [14] 12/7 38/20 39/11 40/22
430/13 134/13 135/11/Fecent [9] 22/6 74/22 Irefer [11] 22/6 34/22 I 16/10 16/16 16/21 43/15 46/23 91/15
436/18 142/3 142/23 I 75/12 77/14 115/14 I 43/10 63/4 86/12 18/1 24/20 49/7 55/20I 91/19 126/22
447/24 170/19 179/18] 116/1 118/21 132/7 I 89/19 122/16 133/18 I 55/22 58/19 58/21 remember [8] 62/20
146/13 133/22 168/24 192/5 I 63/13 71/1 78/18 92/21 94/21 112/11
(77) quite... - remember
INQ00001203
1NQ00001203
R 151/2 151/4 151/5 —_Iresidual [1] 202/25 I 82/3 82/3 83/9 122/1 I 156/18 158/15 161/2
remember...[4] I 151/25 152/1 201/16 Iresign [3] 86/8 139/25 148/13 170/22 171/10 171/14
128/10 143/3 146/10 IfePresent [2] 21/18 I 187/12 188/8 resulted [1] 204/15 I 172/22 188/20 189/14}
182/13 79/25 resistance [1] 171/5 Iresults [1] 142/1 194/2 195/16 196/9
reminded [1] 91/8 IfePresentation [3] _Iresisted [2] 160/19 Iresume [4] 38/7 38/8I 197/23 198/17 198/23
remote [1] 152/11 I 31/16 32/2 100/10 I 186/19 101/3 154/2 201/13 203/24 204/1
remove [1] 163/5 representations [2] resisting [1] 129/23 Iresuming [1] 70/17 I 204/6
removed [4] 74/16 I 166/13 176/16 resolute [1] 147/10 Iretail [2] 32/8 158/10 I rightly [8] 10/16 12/8
417/14 149/9 195/7 representative [16] Iresolution [3] 85/19 Iretailer [1] 113/11 12/18 33/6 126/13
remuneration [9] 3/14 3/22 5/1 12/2 I 150/9 170/4 retain [1] 9/12 181/15 197/13 197/15
16/2 16/3 16/7 16/10 I 14/6 14/12 65/7 72/25Iresolve [1] 85/20 _Iretention [2] 29/21 rights [1] 98/9
26/7 95/2 95/8 187/6 I 98/11 100/8 107/7 _Iresolved [7] 42/21 I 85/10 rigorous [1] 7/1
187/19 169/7 177/14 177/17 I 84/5 85/24 102/23 _Irethinking [1] 68/9 _I ringside [1] 201/10
renewal [5] 130/5 I 178/4 182/5 143/20 144/16 146/20I return [2] 9/23 27/15 Irisk [28] 11/21 16/25
1465/2 183/13 184/9 representatives [10] Iresolving [2] 45/6 returned [2] 117/21 I 17/11 17/15 17/17
4189/7 25/15 25/20 33/24 I 172/18 119/8 18/2 18/6 18/19 18/23
rep [1] 29/14 34/6 43/19 44/1 44/5 Iresort [1] 84/18 returning [3] 3/3 19/10 19/25 20/2 20/6
repaid [2] 193/16 I 89/9 143/5 164/7 resources [5] 4/6 I 91/12 105/22 20/7 20/13 20/21
193/17 represented [1] 107/4 116/13 117/10 Ireturns [2] 118/7 21/22 22/7 22/9 22/24
repair [1] 130/11 107/11 193/24 162/11 23/2 23/3 23/5 23/9
repay [1] 114/21 representing [2] 99/4Iresourcing [1] 17/22 Ireveal [2] 135/15 23/19 77/1 167/20
repeat [2] 68/12 181/16 respect [6] 109/17 I 155/21 168/17
83/20 represents [1] 115/10 127/10 154/16Irevealed [2] 124/12 Irisks [12] 16/21 17/2
repeated [3] 66/23 I 139/21 159/13 185/24 124/20 17/3 17/7 17/9 17/21
83/7 114/23 reps [1] 96/8 respectable [1] revealing [1] 191/1 I 17/21 18/1 18/5 125/6I
repeating [1] 67/16 I"@Putation [1] 198/5 I 195/14 review [25] 22/6 22/8I 132/15 169/15
repercussive [1] reputational [1] respective [1] 120/5 I 23/8 34/8 43/20 43/24] risky [1] 50/3
126/11 140/1 respects [1] 171/11 I 53/9 61/10 61/23 63/1I robust [1] 67/4
repercussive' [1] I"@Putationally[1] respond [4] 126/20 I 75/19 75/19 89/1 robustness [1] 75/20
4128/3 178/19 126/24 179/20 181/21I 117/24 130/8 142/17 Irole [45] 3/24 10/22
replace [4] 48/16 Ifequest [11] 16/17 I responded [2] 85/16 I 142/20 11/7 152/16 I 12/26 13/24 17/24
55/5 64/1 167/16 55/1 60/20 60/23 63/5I 117/1 153/15 188/14 189/13] 18/17 22/18 25/13
replacement [6] 87/14 115/14 116/1 Irespondents [1] 97/9) 190/18 203/22 203/25) 25/19 29/10 29/13
53/24 55/2 68/9 68/24) 117/15 132/25 138/3 Iresponse [2] 59/8 [reviewing [1] 68/16 I 30/18 34/21 35/15
69/11 69/22 requested [3] 11/9 I 119/11 reviews [1] 54/14 35/23 36/23 37/15
replacing [2] 60/17 49/20 117/17 responses [1] 19/20 Irevised [5] 49/8 43/14 53/15 61/12
65/19 requesting [1] 8/5 _Iresponsibilities [18] I 49/14 81/3 81/9 81/21) 61/14 62/14 62/22
replied [1] 50/6 requests [5] 12/7 4/3 9/3 9/9 106/25 rid [1] 184/11 62/24 65/18 65/20
reply [4] 173/20 13/3 54/17 117/16 107/24 113/14 120/6 Iright [101] 2/18 3/10 I 87/4 87/18 93/24 94/1
report [26] 22/16 117/25 121/3 122/12 127/14 I 3/19 4/1 4/21 8/6 8/24I 96/7 99/4 99/5 99/7
62/10 77/22 99/25 require [7] 10/10 128/20 129/7 155/7 I 9/13 11/24 13/1 13/6 I 99/8 99/15 106/14
118/21 133/16 133/16I 2/12 65/15 81/7 81/8I 161/9 163/15 167/7 I 13/23 15/3 18/15 121/14 143/13 143/15)
133/25 134/1 134/3. I 118/14 134/24 167/23 168/18 19/11 21/11 23/16 159/11 162/21 163/18)
134/14 134/16 136/11I"eauired [13] 6/16 Iresponsibility [21] 27/17 31/4 32/18 166/4 168/8
136/13 137/2 145/6 I 48/6 66/1 87/24 108/5I 3/19 3/25 56/17 107/2I 35/13 36/5 38/17 roles [11] 2/22 17/6
445/21 152/10 155/21I 127/8 129/12 163/18 I 110/6 113/21 113/24 I 38/23 39/2 39/7 39/17) 94/20 96/15 105/11
166/14 166/14 167/10I 168/5 169/4 171/2 115/1 115/5 119/22 I 40/3 40/11 41/10 105/18 106/20 120/5
171/18 194/25 120/3 120/24 120/25 I 48/23 49/18 50/1 158/1 160/4 161/12
Spans 184/23 191/7 requirement [2] 131/25 149/22 159/10) 56/19 57/12 65/13 Rolfe [1] 8/4
reported [4] 19/6 116/6 121/18 175/20 179/15 181/12I 67/4 68/6 69/8 70/17 IRolfe's [3] 132/25
31/1 85/18 118/25 requirements [6] 202/2 203/9 72/7 72/19 74/15 203/19 203/25
reporting [28] 16/21 68/25 69/5 69/23 responsible [13] 78/17 79/9 79/17 rollout [1] 64/4
16/25 18/6 18/19 112/25 160/8 169/1 I 17/19 17/20 18/19 79/18 80/20 80/25 room [3] 25/25
18/24 19/1 19/25 20/2I"equires [6] 19/6 46/23 110/19 116/11 I 82/24 85/25 87/19 101/13 103/13
20/6 20/7 20/13 20/21I 52/9 69/1 69/6 69/18 I 119/24 130/13 133/1 I 88/25 88/25 94/9 root [1] 148/24
126/11 142/24 159/12 175/19I 105/16 106/21 107/8 Iroute [2] 44/24 45/12
aoe Boe requiring [1] 168/24 I 195/18 107/21 110/25 112/14Iroutes [1] 47/13
117/68 117/22 118/20 Irescheduled [1] responsibly [3] 114/17 116/22 120/1 I routinely [2] 23/24
118/23 121/8 161/24 139/5 46/20 47/2 47/6 120/13 121/14 121/21 I 24/1
4167/4 167/7 176/21 _ \resentful [2] 157/18 Irest [2] 64/9 102/14 I 122/10 124/8 124/10 Irow [1] 171/23
reports [13] 17/15 I 194/11 restoration [1] 100/5 I 127/2 130/23 132/4 IRoyal [2] 6/5 111/24
try 23/22 133/18 IFeservations [1] restrict [1] 122/7 132/8 133/15 135/4 rule [1] 150/19
43618 13715 1611 I 172/21 rests [1] 18/20 137/24 139/3 139/15 Irun [14] 64/18 76/7
reserving [1] 181/12 Iresult [8] 19/2 29/15 I 147/13 147/18 154/5 I 98/5 98/8 112/22
(78) remember... -run
INQ00001203
INQ00001203
R 119/5 124/16 125/6 I 123/13 136/21 139/17I 138/14 139/7 140/6 I senior [10] 7/24
run... [6] 113/22 130/1 134/3 149/11 I 145/23 200/2 140/7 147/25 149/9 I 11/15 21/23 61/6 72/6
130/16 158/12 158/14I 152/20 153/1 169/8 Iscale [1] 66/4 sector [8] 15/10 72/16 74/5 107/2
162/15 168/17 172/17 181/15 scandal [6] 80/2 82/3I 15/21 16/3 16/8 66/4 I 107/6 128/6
running [4] 10/1 say [144] 2/20 7/5 83/16 92/11 93/4 73/5 105/21 128/25 Isense [17] 16/6 42/2
10/17 64/1 110/19 8/21 9/24 11/21 14/20} 99/22 see [59] 1/3 1/8 1/12 I 43/1 78/22 119/13
16/25 17/16 18/22 scarce [1] 117/10 2/4 24/2 27/9 27/19 I 134/22 135/2 146/1
runs [1] 2/1 18/22 21/16 21/25 Ischedule [2] 150/4 I 29/9 31/18 31/19 32/2I 147/8 149/22 171/14
rushes [1] 180/7
22/1 2211 22/8 24/14 I 200/6 34/18 36/24 49/7 I 176/5 181/11 181/14
s 24/25 25/8 25/21 Ischeme [18] 38/25 I 56/11 62/2 70/22 76/3I 183/25 184/5 198/19
sack [i] 183719) 27/11 29/17 30/7 I 39/23 40/2 41112 I 81/4 82/20 83/8 83/11] sensible [2] 57/24
sacking [1] 83/2 I 30/24 32/5 36/13 36/3I 42/13 42/15 42/19 I 99/7 109/11 110/12 I 63/15
sadly [1] 183/6 36/11 39/4 40/14 I 43/7 43/17 44/16 I 11/3 119/2 123/21 _I sensitive [1] 149/11
Saf [6] 24/10 25/22 40/23 41/3 43/2 43/14] 88/23 89/11 90/21 127/19 133/21 136/17I sent [8] 28/6 28/11
29/2 30/14 31/4 31/13I 46/2 46/21 47/7 50/25I 91/9 91/11 108/17 137/7 139/13 144/5 I 68/15 88/18 88/25
safe [1] 136/4 51/20 52/21 53/20 I 110/4 200/10 148/16 155/1 155/12 I 90/14 127/20 188/12
said [70] 9/16 14/4 I 56/8 56/19 57/4 57/16 schemes [3] 38/17 I 155/16 156/20 157/2 Isentence [4] 23/17
24/25 28/20 32/13 I 60/3 61/7 62/2 62/9 I 38/18 38/22 158/22 162/1 164/14 I 104/15 141/8 203/8
40/21 41/3. 49/25 _I 62/9 63/1 63/5 63/11 IScience [3] 52/16 I 165/11 165/13 166/14I sentiment [2] 46/16
53/15 63/22 56/14 I 63/2064/23.65/3 I 106/9 111/21 170/15 170/18 171/13) 46/22
59/9 60/7 63/18 66/17) 67/11 68/15 68/23 I scope [3] 62/14 I 174/17 176/4 181/20 Isentiments [1] 13/22
87/13 75/15 83/24 I 69/2 71/7 71/23 73/13I 147/20 167/19 188/11 189/6 190/2_Iseparate [8] 6/18
35/16 85/1891/8 I 73/17 73/20 73/23 I screen [16] 82/10 I 191/14 191/15 195/12) 33/11 43/1 64/2 97/1
91/18 92/16 92/17 I 74/18 80/8 80/24 81/1] 88/15 108/1 115/12 I 201/21 109/2 113/3 123/17
92/19 94/25 95/3 I 82/7 83/5 86/12 86/18) 117/2 121/13 127/18 Iseeing [1] 157/14 I separated [1] 6/4
95/25 96/9 99/3 89/2 89/13 89/20 _I 130/25 139/11 150/21Iseek [3] 89/9 90/20 Iseparately [1] 43/4
111/13 111/24 18/7 I 89/24 89/25 90/4 90/7I 154/14 162/19 168/23] 170/12 September [9] 1/23
418/13 119/14 123/9 I 93/11 95/16 96/1 99/1I 172/12 185/25 188/10Iseeking [5] 65/8 8/4 75/6 75/10 92/15
425/15 128/16 131/14] 99/3 102/8 109/13 scroll [3] 49/6 55/17 I 65/10 65/11 78/11 106/12 127/16 129/16)
109/21 110/24 111/6 I 186/8 186/20 139/4
oo qed e624 114/6 115/16 120/11 Iscrutiny [11] 11/23 Iseem [2] 137/20 Isequence [1] 180/15
4155/4 155/5 155/6 _ I 120/22 121/1 121/16 I 12/6 12/14 12/16 13/7] 150/15 series [3] 33/23
465/22 166/13 170/18) 129/1 132/7 133/25 I 13/10 13/17 167/13 Iseemed [2] 129/21 I 139/21 204/11
47211 173110 1761 I 139/6 141/14 143/12 I 184/24 194/7 194/15 I 169/3 serious [7] 56/3
176/12 176/23 176/23) 145/22 150/23 154/14Iseat [1] 201/10 seems [8] 127/15 I 59/11 60/12 85/20
1477/3 178/10 182/10 I 154/24 158/9 159/16 Isecond [24] 31/17 149/4 152/12 176/5 I 135/24 145/14 178/5
482/11 188/5 189/24 I 160/19 161/2 161/16 I 55/17 73/4 78/17 83/8) 180/20 180/23 188/17Iseriously [5] 33/22
189/25 190/4 190/20 I 161/17 162/20 163/11] 92/1 115/15 136/7 201/16 59/18 71/14 86/3
497/18 199/16 202/11I 163/19 164/10 164/20] 136/8 136/11 136/16 Iseen [22] 55/3 84/24 I 121/1
202/15 166/24 169/2 170/9 I 136/22 137/4 137/10 I 87/3 123/17 125/14 I seriousness [2]
sale [1] 140/3 171/8 172/13 172/25 I 137/12 137/18 145/4 I 125/14 125/15 126/14) 50/22 55/25
same [12] 17/7 22/24 173/9 174/19 174/25 I 145/6 145/21 151/5 I 128/11 144/15 153/6 Iservant [2] 105/15
35/18 49/22 58/16 175/13 176/24 178/23) 151/25 152/1 171/22 I 153/9 161/6 162/8 107/2
88/19 90/20 128/16 I 181/22 183/18 185/3 I 179/8 176/2 176/14 176/20 I servants [3] 92/7
144/4 178/2 178/16 I 186/11 187/23 191/14I secondly [3] 71/15 I 181/3 188/11 191/6 I 93/15 113/6
4190/1 191/17 191/20 193/7 I 132/25 175/25 191/9 194/12 serve [4] 3/4 16/5
sanction [1] 185/6 197/13 197/15 197/24I Secretary [47] 2/21 Iself [11] 5/18 5/24 92/23 93/9
sanctions [1] 93/16 198/18 202/19 204/16I 3/4 21/3 51/18 52/10 I 6/11 6/14 6/19 6/23 I served [3] 3/18 36/19}
Sarah [3] 46/10 saying [35] 21/15 52/11 52/17 52/19 37/13 109/23 121/23 I 106/5
52/18 53/9 27/21 29/3 32/5 37/1 I 52/20 53/13 53/16 157/14 190/15 serves [1] 73/1
sat [1] 3/21 37/1 54/3 54/25 57/23) 53/18 54/6 54/10 self-absorbed [1] service [10] 2/17 3/2
satisfaction [1] 62/6 84/16 89/5 111/4I 54/20 74/13 80/9 157/14 6/25 65/24 68/18
193/4 123/24 134/22 135/12I 80/12 81/3 82/22 self-funded [1] 93/19 105/22 106/17
satisfactorily [1] 142/1 144/6 152/13 I 84/25 86/17 86/17 109/23 163/10 168/1
443/21 157/4 158/22 168/4 I 86/23 106/6 106/11 I self-sufficiency [5] _Iservices [7] 5/12
satisfactory [2] 170/5 170/6 170/19 I 106/19 106/25 107/1 I 5/18 5/24 6/11 6/14 I 5/14 5/15 33/3 109/23
119/18 188/1 176/15 180/9 187/11 I 109/22 111/20 112/5 I 6/23 159/3 159/5
satisfied [2] 133/5 193/6 195/15 199/25 I 124/18 126/18 128/6 Iself-sufficient [2] serving [2] 74/23
434/10 200/16 201/7 201/16 I 142/8 159/14 161/23 I 6/19 37/13 190/15
saving [1] 26/11 204/1 163/7 167/8 174/14 Isemi [1] 187/13 sessions [1] 33/25
savings [1] 46/3 says [16] 22/22 181/15 182/17 185/5 Isemi-contractual [1] Iset [27] 5/19 5/22
saw [16] 37/10 66/14 29/11 49/17 52/11 185/5 190/3 202/25 I 187/13 12/13 13/14 15/14
67/21 68/3 118/12 52/25 66/9 81/2 97/9 Isecretly [1] 175/21 Iseminal [1] 124/19 I 40/1 43/4 52/24 56/7
104/17 110/18 117/4 Isection [7] 25/21 send [2] 21/7 21/7 64/12 88/24 107/14
(79) run... - set
INQ00001203
1NQ00001203
s 13/21 14/5 14/7 14/7 I 78/16 85/18 140/15 I 183/17 skill [1] 162/25
set...[15] 11022 I 14/11 14/16 16/12 I 146/24 148/5 148/9_Isign [1] 75/24 skills [1] 162/8
115/18 121/14 127/23) 17/5 17/6 17/17 18/16Ishorthand [1] 192/5 Isignature [3] 2/4 _Iskillset [1] 9/13
428/19 130/4 141/6 I 20/5 20/25 21/19 I shortly [7] 9/23 24/8 I 104/5 104/7 slight [2] 29/16
4148/3 148/6 159/22 I 21/20 22/18 27/4 27/12 27/19 48/18 I signed [2] 4/13 161/9I 131/19
s69/21 186/6 1988/4 I 39/10 35/24 49/24 I 70/15 114/24 significance [2] slightly [6] 5/23 7/1
200/10 202/20 50/15 51/5 65/7 65/7 Ishould [87] 1/22 5/17I 10/14 158/6 13/13 30/17 64/23
set-up [1] 202/20 I 65/6 95/11 65/12 9/20 9/21 9/25 10/1 I significant [11] 9/14 I 192/21
sets [6] 5/3 35/4 65/15 73/6 82/16 10/23 16/6 21/14 12/6 16/11 25/4 54/16Islow [1] 149/12
35/11 36/14 36/16 I 83/14 83/18 84/7 84/8) 21/17 23/10 33/1 33/4) 60/20 144/8 146/17 I slower [1] 70/7
150/5 84/10 84/11 84/14 I 33/13 35/2 35/11 37/4I 147/22 148/20 153/7 Ismall [6] 39/16 39/20
setting [6] 57/13 86/15 87/21 87/23 _I 39/18 39/24 40/18 _I significantly [3] 40/3 40/15 114/19
89/22 120/18 128/4 I 87/25 95/20 99/4 99/5I 48/9 50/2 65/22 72/18I 12/13 58/9 124/6 140/10
4139/7 174/13. 99/8 99/13 99/14 72/24 73/3 77/18 I silk [1] 204/2 Smith [1] 39/20
settle [8] 156/15 109/19 119/25 120/4 I 79/21 85/3 86/19 _Isimilar [4] 42/9 63/12Ismooth [1] 164/18
170/17 184/20 193/3 I 120/11 120/12 126/3 I 91/20 91/22 93/1 97/2I 134/8 145/19 so [343]
495/12 198/7 199/14 I 197/22 159/17 159/24] 98/17 98/24 100/14 I similarly [1] 40/17 I so-called [5] 130/15
201/8 160/22 164/7 177/14 I 102/7 102/18 103/5 _Isimple [1] 137/8 131/10 131/22 159/3
settled [3] 170/20 I 180/21 103/23 104/21 118/13Isimply [6] 78/22 95/2I 197/3
198/12 198/15 shareholder's [4] 118/14 123/17 124/3 I 95/9 103/1 196/19 _I social [8] 6/16 16/6
settlement [50] 15/9 I 10/10 13/13 36/8 125/17 127/12 128/1 I 202/1 36/21 36/22 121/4
15/11.41/19 41/20 I 87/22 130/3 130/21 145/1 simultaneously [1] _ I 122/13 158/20 158/23
42/23 43/6 44/2 44/15IShareholder-owned I 151/3 151/5 1514/7 I 2/23 soft [2] 7/20 8/23
45/16 45/18 46/5 [1] 9/19 151/15 154/20 156/5 Isince [11] 3/18 6/4 I software [2] 145/8
47/40 53/8 125/21 sharing [6] 125/10 I 160/19 164/17 167/3 I 40/16 81/13 81/15 145/23
125/23 129/24 130/4 I 131/23 155/2 159/20 I 167/14 167/15 170/20] 81/18 87/3 90/11 solicitor [1] 135/12
144/23 149/25 150/2 I 182/9 194/11 173/4 173/11 173/16 I 99/23 168/10 182/24 Isolicitors [1] 172/3
4150/7 168/21 169/14 ISharma [1] 190/3 173/22 174/1 174/23 Isingle [2] 9/19 117/5 Isolid [1] 203/2
169/20 169/23 169/25IShe [21] 74/14 117/3 I 175/16 175/17 176/13) sir [50] 1/5 1/14 38/3 I solution [4] 145/2
170/10 170/14 174/1, I 117/18 133/1 143/25 I 178/25 182/11 183/9 I 38/13 70/12 70/18 170/1 172/19 203/4
1741/5 183/10 183/11 I 145/12 146/6 177/21 I 183/11 183/12 183/18] 70/22 77/8 100/18 —_I some [84] 2/12 4/8
189/10 193/25 194/3 I 178/8 178/19 179/2 I 186/13 187/11 188/2 I 101/3 101/9 101/14 I 5/15 7/16 8/20 13/20
1495/4 195/20 195/23 I 179/5 179/24 180/1 I 190/4 195/3 195/22 I 102/23 103/4 103/11 I 16/19 19/10 19/11
4196/18 196/22 197/4 I 182/6 182/8 182/10 I 203/15 203/22 103/12 103/15 103/17I 20/2 25/6 25/9 26/22
4198/9 198/19 199/4_ I 182/11 182/11 184/2 Ishouldn't [7] 126/23 I 105/3 105/5 111/18 I 27/7 28/24 30/14
499/17 199/21 20012 I 184/2 144/20 175/21 179/7 I 121/13 131/3 1314/6 I 31/15 32/2 33/1 33/15
200/9 200/11 200/14 [She'd [2] 182/3 182/4I 179/8 180/10 180/14 I 132/3 150/22 153/24 I 34/20 39/14 41/9
settlements [1] 39/7 [She's [1] 177/25 show [9] 98/2 123/4 I 154/6 154/10 154/12 I 42/17 44/21 47/21
settling [1] 144/21 Sheffield [2] 3/15 I 12/7 148/24 152/22 I 162/19 172/12 190/6 I 58/3 58/5 58/7 61/19
setup [1] 198/20 16/13 155/14 173/14 176/7 I 190/11 190/14 192/6 I 68/21 70/16 71/3 71/4
seventh [1] 81/2 shifted [1] 47/8 188/3 196/3 196/24 199/9 I 75/14 79/3 83/24 85/8}
several [3] 80/9 shifting [1] 148/23 Ishowed [5] 124/22 I 199/19 201/1 201/6 I 91/23 96/16 96/19
109/9 190/7 shilling [1] 193/9 I 134/4 134/5 152/21 I 202/10 204/3 204/21 I 97/19 99/9 99/20
shall [5] 2/1136/6 [Shock [1] 20124 I 186/22 204/23 204/24 205/5 I 103/4 111/19 112/7
38/8 101/3 154/2_ IShocked [2] 135/11 Ishowing [1] 155/19 I 206/6 206/14 114/12 115/24 118/8
shameful [1] 1299 I 1363 shown [7] 8/22 68/5 ISir Alex [4] 102/23 I 124/6 130/9 130/19
share [6] 22/2 30/2 [Shocking [2] 152/24 I 135/7 136/3 146/3 I 103/4 103/12 103/17 I 134/25 135/22 136/6
6/10 135/15 149/12 I 152/25 157/3 166/9 Sir Wyn [4] 131/6 I 136/13 136/15 136/24
194/6 shockingly [1] shows [3] 93/18 196/24 199/19 201/6 I 138/6 140/12 140/17
shared [17] 8/17 6/19 152/19 99/25 134/17 sit [4] 18/8 18/16 141/3 141/9 141/18
23/10 23/24 24/1 [Short [16] 6/12 38/11 Ishutting [1] 179/3 I 38/19 202/15 145/9 149/20 150/2
40/21 40/25 43/17 I 60/4 70/13 70/20 —_Isic [2] 88/23 106/9 sitting [2] 34/10 157/1 160/7 160/15
73/6 73/24 7ar2 ea/g I 71/13 74/17 83/19 I SID [2] 73/5 74/8 178/16 166/3 166/19 168/14
84/10 117/10 128/12 I 1091/6 101/12 106/5 Iside [5] 33/2 54/17 _Isituation [12] 26/12 I 174/13 176/3 181/5
151/18 180/6 139/8 140/8 153/20 I 98/14 181/17 200/19 I 28/25 36/24 36/25 I 184/4 184/11 189/17
shareholder [84] 154/8 185/20 sides [2] 137/16 37/5 37/7 85/6 87/17 I 191/2 191/6 193/14
3/14 3/22 3/25 4/15 [Short-circuit (1] 139/23 4122/2 122/18 172/16 I 195/11
5/19/17 9/19 9/22 I 83/19 sight [10] 121/25 I 203/5 somebody [3] 62/19
9/25 10/12 10/16 [Short-term [1] 6/12 I 136/9 136/22 137/5 _Isituations [2] 96/20 I 87/7 182/25
10/22 11/15 11/18 [Shortfall [5] 38/25 I 145/4 145/6 145/21 I 96/21 someone [2] 15/20
41/19 12/1 12/5 12/8 I 42/15 148/11 148/14 I 151/5 151/25 152/1 _Isix [6] 92/15 129/18 I 87/8
42/9 12/12 12/16 200/10 Sight's [4] 136/7 141/23 162/2 162/4 I something [24]
42/20 12/25 13/12 IShortfalls [10] 75/1 I 136/11 136/16 137/18] 196/2 12/15 21/6 34/13,
77/21 77/22 78/12 sighted [2] 86/21 size [2] 7/10 7/11 37/24 42/5 57/16
(80) set... - something
INQ00001203
INQ00001203
s
something... [18]
66/17 70/6 70/7 78/24
92/12 98/14 100/4
113/11 118/2 143/22
147/4 154/22 162/8
165/3 178/22 179/9
182/7 202/12
sometimes [8] 10/9
10/11 14/10 158/16
163/16 163/19 164/12)
190/15
somewhat [2] 187/9
201/14
soon [2] 141/21
195/21
sooner [1] 123/1
sorry [18] 13/12
15/18 39/15 43/12
46/21 67/9 71/20
72/15 73/10 73/25
76/13 79/22 80/21
91/1 132/2 199/8
203/24 204/3
sort [68] 6/22 7/1
8/13 9/4 14/12 14/14
16/17 18/9 19/13
19/14 19/24 23/2
28/16 28/24 32/13
32/15 33/1 33/10
34/25 35/4 35/10
35/11 39/18 39/25
41/2 41/14 42/10
45/12 46/13 52/24
53/2 53/6 56/5 58/2
59/21 64/11 64/14
64/16 65/10 66/7
66/25 67/7 67/9 69/7
70/4 73/15 75/24 76/3,
76/21 82/20 84/4 84/6
84/14 84/24 95/12
97/1 128/25 133/21
145/21 165/25 168/18)
169/24 170/14 171/17)
175/21 183/23 187/13}
202/4
sought [3] 66/17
67/14 148/17
sound [2] 1/9 17/4
source [2] 117/12
157/10
sources [3] 23/9
23/18 23/20
space [2] 9/16 58/7
speak [14] 17/14
55/18 59/21 78/10
79/11 124/5 157/11
165/20 168/12 177/22)
179/2 181/2 183/1
184/11
Speak-Up [1] 55/18
speaking [8] 11/5
14/19 26/17 35/2
67/12 114/25 152/12
162/12
speaks [1] 147/11
special [2] 119/16
168/4
specialist [2] 100/9
202/22
specific [5] 15/24
29/20 87/18 128/10
130/19
specifically [5] 37/11
54/7 116/3 118/10
146/5
specifics [1] 85/5
spectrum [1] 167/2
speculate [1] 86/1
speculation [1] 41/10)
speech [3] 92/6
92/14 92/20
speed [2] 42/20 70/5
spend [5] 46/8 69/16
116/3 117/15 168/25
spending [11] 12/19
13/7 13/11 39/20 47/3)
48/5 48/7 53/9 54/14
66/8 114/16
spent [5] 45/18 65/16
68/7 108/4 108/7
split [2] 52/14 137/11
spoke [3] 49/14
83/25 187/9
spoken [3] 179/23
192/15 194/10
sponsored [1]
107/19
Sport [1] 3/8
spotted [1] 118/6
spring [1] 156/4
squarely [1] 181/13
SRA [1] 90/3
stabilise [1] 6/7
staff [13] 15/9 15/11
15/13 30/20 31/2 61/6)
61/25 68/15 70/3
71/11 108/6 158/13
160/9
stage [16] 50/21 55/5
55/24 62/2 63/18
92/22 111/19 124/11
133/6 134/12 151/20
170/13 179/8 180/2
188/22 198/13
stages [1] 76/8
stakeholders [3]
32/18 130/16 169/11
stance [1] 181/23
stand [5] 29/16
153/13 163/11 163/19)
197/21
standard [1] 116/12
standardised [1]
128/15
standards [3] 110/21
128/9 129/12
standing [3] 32/14
163/4 179/19
stands [1] 5/8
start [7] 1/12 34/17
34/18 78/8 79/25
88/22 105/10
started [9] 43/14
44/8 44/10 63/24
142/12 150/17 157/23
162/1 198/19
starting [3] 6/6
115/15 117/4
starts [3] 27/19 167/2)
169/10
state [18] 74/14
80/10 80/12 81/4
82/22 84/25 86/17
93/10 124/19 126/18
167/8 174/14 178/17
181/15 182/17 185/5
190/3 202/25
stated [2] 11/8 192/8
statement [78] 1/23
2/1 2/5 2/7 2/20 4/3
4/10 7/14 8/1 8/21
9/24 11/21 13/19
14/20 15/4 16/23
18/23 22/6 23/8 23/15
24/7 24/9 34/22 36/3
38/24 40/21 42/19
43/2 43/10 68/21
71/23 73/17 73/20
80/5 80/6 82/8 86/13
88/10 88/12 88/17
94/18 100/22 101/12
101/15 103/23 103/24:
104/10 105/1 105/4
105/5 105/8 107/16
107/18 107/23 109/21
116/24 120/15 120/23
121/14 125/15 125/19)
134/9 134/13 140/8
150/22 154/13 156/22
161/2 162/20 166/20
168/23 170/9 170/25
172/13 183/20 191/16
202/10 204/25
statements [4] 19/11
23/3 144/5 152/14
Statistics [1] 108/18
status [3] 108/15
111/25 164/21
statute [1] 112/23
Statutory [1] 191/5
Staunton [4] 27/13
71/2 73/9 73/11
stay [1] 139/12
steer [5] 6/9 9/20
185/21 186/16 186/18
step [1] 57/14
Stephen [1] 175/5
stepped [1] 182/13
stepping [1] 81/19
steps [5] 33/19 34/15
81/7 151/9 151/16
stewardship [1] 4/6
still [10] 45/9 45/11
54/24 76/20 78/13
79/20 158/17 170/7
174/16 185/10
stock [5] 145/18
155/12 164/13 166/10)
194/21
stop [1] 48/9
stopped [2] 142/10
142/11
stories [1] 143/17
straight [1] 186/2
straightforward [1]
168/16
strange [1] 64/6
strategic [1] 115/23
strategically [1]
172/23
strategy [4] 4/5 50/2
106/11 120/18
strength [1] 177/9
stress [3] 31/5 31/8
102/22
stressed [1] 128/1
stretch [1] 176/9
Strictly [1] 139/16
striking [3] 12/21
13/1 13/23
strive [1] 5/17
strong [2] 160/20
185/21
stronger [2] 144/7
166/3
strongly [4] 10/13
16/4 149/24 184/19
structural [2] 159/20
203/4
structure [1] 202/13
structures [3] 100/13
100/14 167/15
struggled [3] 163/3
165/3 165/5
struggling [1] 1/13
stuck [1] 163/20
study [1] 132/22
stuff [2] 35/2 187/15
sub [1] 109/10
subject [10] 27/2
29/23 37/20 72/2 84/4
85/10 103/7 137/14
139/16 194/2
submission [7] 52/11
52/21 53/16 74/12
86/22 86/25 87/9
submissions [2]
86/16 87/14
submit [1] 102/2
subpostmaster [2]
148/14 169/5
subpostmaster's [1]
146/25
subpostmasters [32]
80/1 85/16 88/13 93/3,
122/3 124/21 130/12
136/15 140/12 140/24)
143/1 143/1 143/5
144/1 145/14 146/8
146/22 148/6 148/9
148/17 149/23 150/9
151/12 168/3 168/12
170/2 181/19 183/14
189/9 193/4 198/11
200/4
subsequent [2] 57/8
61/20
subsequently [4] 3/7
149/17 185/4 191/3
subsidised [1] 5/13
subsidises [1] 6/21
subsidy [11] 6/21
36/12 36/17 36/20
37/11 52/2 52/4 52/22
52/23 104/16 114/10
substance [6] 29/5
72/14 72/15 73/13
73/15 172/24
substantial [2]
123/16 171/17
substantive [1]
171/21
substantively [1]
173/16
succeed [1] 172/15
success [7] 9/20
9/22 35/20 64/13
125/16 144/4 151/13
succession [2] 164/7I
203/23
such [18] 4/16 7/17
7/22 17/10 17/25 20/4,
49/21 53/5 86/24
87/10 87/14 94/24
98/11 123/22 127/11
155/21 171/4 191/12
suddenly [1] 1/16
suffer [1] 67/6
suffered [4] 40/4
45/1 93/8 139/25
sufficiency [5] 5/18
5/24 6/11 6/14 6/23
sufficient [8] 6/19
12/24 20/20 34/15
37/13 84/13 150/24
159/9
sufficiently [4] 21/13
60/12 71/14 99/23
suggest [5] 8/1 36/7
164/19 188/17 204/10)
suggestion [3] 47/25
57/2 103/4
suicide [1] 140/23
sum [4] 46/3 47/8
91/22 203/9
summaries [2]
121/25 138/4
summarised [1]
(81) something... - summarised
INQ00001203
INQ00001203
Ss
132/15
summary [6] 74/17
134/3 134/15 136/19
137/3 139/19
summer [5] 33/23
78/23 79/15 152/21
152/22
sums [1] 125/25
Sunday [1] 180/2
super [1] 176/9
superseded [1] 89/3
supervising [1]
164/11
supervision [1]
supervisory [3]
17/24 111/6 121/7
supplementary [1]
101/22
supplied [1] 164/15
supply [2] 157/17
204/9
support [15] 27/22
111/2 136/15 140/12
186/20
supported [2] 42/6
43/19
supporting [1]
142/25
supportive [1] 76/17
suppose [1] 129/1
supposed [2] 93/9
109/5
Supreme [1] 180/5
sure [29] 19/18 29/16)
34/4 35/3 62/9 67/19
67/20 68/10 68/12
78/25 111/7 112/8
114/10 114/16 118/15)
119/10 119/17 128/15)
129/13 133/19 136/20)
143/20 153/9 156/17
168/13 171/8 175/25
198/17 198/22
surely [1] 192/10
surname [1] 49/12
surprised [4] 54/11
54/20 64/18 64/24
surprising [1] 150/15)
survey [6] 19/19
19/20 74/22 74/24
84/2 85/15
suspect [1] 172/5
suspicious [1] 183/5
sustainability [4]
5/21 5/23 5/25 6/10
sustainable [1] 37/10
Swift [13] 133/16
summarised... [1]
134/13 151/7 151/17
1914/7 203/16 203/18
sworn [2] 103/15
206/14
143/19
sympathies [1]
181/18
sympathy [1] 45/2
system [35] 34/7
34/8 SO/7 51/7 64/4
64/12 67/4 67/19
67/20 70/1 70/9 78/4
79/7 102/7 122/3
132/21 134/20 136/9
137/9 140/3 140/14
140/25 145/7 145/8
146/2 146/7 146/15
152/7 169/6 171/10
197/18 197/21
system-wide [2]
145/7 145/22
37/3 69/10 89/7 91/23I Systemic [4] 133/13
136/12 136/22 145/7
143/16 145/10 145/24ISystems [1] 33/9
145/25 165/12 165/16IT
table [1] 97/5
tactically [1] 178/18
tailored [2] 14/22
15/1
tailoring [2] 15/22
16/1
tainted [2] 135/17
153/5
take [37] 4/25 6/8
6/22 9/20 14/22 15/1
43/5 54/21 69/15
77/40 80/24 82/10
82/16 91/22 93/22
93/23 101/14 170/23
175/16 175/22 175/22
176/17 179/1 179/7
179/15 180/14 185/11
189/17 189/20 191/14
196/13 199/8 201/7
takeaways [1] 183/4
taken [25] 33/19 34/2
44/6 57/4 59/18 68/11
7143 73/11 75/13
76/22 88/17 91/3
91/25 96/3 96/5 131/9
133/6 133/24 134/11
138/15 138/16 151/9
153/7 175/17 189/23
takers [1] 103/10
takes [3] 20/13
158/11 199/13
taking [12] 22/21
30/9 33/21 39/24 45/4
133/23 133/23 134/10)
87/22 179/2 186/12
152/15 155/21 184/23I takings [1] 183/3
talk [5] 20/10 104/16
108/24 152/10 155/5
talked [5] 19/25
sympathetic [2] 30/6 I 22/25 53/9 150/1
155/8
104/13
talks [2] 141/14
200/1
tangible [1] 186/15
target [1] 35/1
task [1] 69/2
tax [1] 159/1
taxpayer [1] 69/13
taxpayers [2] 13/11
68/6
145/13 145/15 145/22Itaxpayers' [3] 13/8
39/21 48/8
Teach [1] 2/16
teaching [1] 2/15
team [41] 3/25 4/4
12/23 18/23 21/1
21/23 22/4 28/19
28/24 30/11 30/15
33/21 38/17 42/7
43/19 44/21 49/22
73/21 77/4 86/15
86/19 86/24 87/1
97/20 101/19 116/5
132/1 138/23 166/11
171/3 172/6 172/7
202/24
teams [3] 17/6
161/14 167/25
Tech [1] 3/9
23/14 24/12 38/4 40/3Itechnical [5] 110/10
202/4
technically [3] 53/12
108/17 126/4
technology [4] 64/2
64/5 65/22 69/12
tell [3] 78/9 86/6
104/12
telling [4] 78/2
tells [1] 42/4
ten [3] 70/14 97/4
99/11
ten-ish [1] 99/11
tend [1] 157/13
tended [1] 157/17
tens [2] 109/2 109/9
tense [2] 30/13 31/9
tension [1] 163/3
tenure [7] 16/11
42/18 111/19 120/13
128/5 162/24 163/8
term [4] 6/12 99/10
148/5 148/18
talking [3] 41/2 91/10
47/16 77/21 83/4 86/2I terminated [1]
140/20
terms [38] 5/9 12/21
13/10 19/13 23/18
26/10 31/20 34/10
67/9 75/21 75/24
76/15 78/3 98/21
120/21 121/15 127/1
128/4 131/22 132/14
144/11 147/23 150/2
151/19 156/1 158/12
187/3 189/10 198/16
199/4 199/20
terrible [2] 40/4
83/16
terrific [1] 168/2
test [3] 164/12 196/3
199/2
testing [3] 50/6 50/7
50/7
text [1] 164/14
14/13 15/16 18/13
22/23 29/4 30/21
30/23 39/9 40/12 42/1
42/22 44/2 47/16
53/10 58/13 59/19
50/15 51/1 51/6 52/10 61/21 70/7 73/7 83/9
53/15 56/6 58/13 68/8} 108/21 113/11 125/18] 53/8 56/6 60/12 62/8
126/7 137/18 141/12
146/2 153/22 157/9
157/19 162/12 164/22)
178/14 181/2 182/22
185/19 192/14 192/17)
195/19 196/18 199/6
thank [61] 1/14 2/10
3/2 16/19 16/24 24/3
24/7 27/2 27/9 38/2
48/14 49/5 51/14
134/19 192/21 197/19I 54/23 55/7 55/16
56/10 70/11 70/18
70/23 70/24 71/21
74/21 77/6 77/7 79/17
79/21 82/10 86/11
88/3 88/4 88/5 92/1
94/6 94/12 99/17
100/17 100/23 100/25
103/14 103/21 104/11
119/21 130/18 131/6
137/23 150/20 154/6
186/1 190/13 194/16
199/3 199/6 199/9
201/3 204/18 204/21
204/24 205/3 205/6
205/7
thanks [2] 132/2
191/4
that [1343]
that's [84] 1/12 8/13
10/1 15/3 18/10 19/7
20/6 21/12 31/24
33/14 36/6 37/9 37/10
42/10 46/4 47/9 57/12I 96/13 99/10 100/7
100/15 119/22 120/10] 123/5 123/19 123/21
than [43] 10/19 12/20I theft [1] 140/18
38/9 38/23 39/17
48/16 57/7 59/5 71/2
71/19 72/1 79/21 80/6
86/11 89/11 91/5 92/2
92/21 95/10 96/11
102/19 110/23 110/25)
114/19 118/12 118/17)
123/22 131/2 131/15
131/17 134/15 137/8
141/7 144/19 146/2
150/22 154/13 157/23)
158/2 158/8 159/2
159/4 159/5 159/6
160/24 162/20 163/20)
165/22 172/13 174/16)
175/24 180/8 180/15
187/16 187/22 188/1
188/4 192/17 194/24
194/25 195/22 195/23)
198/23 199/19 200/16)
203/12 204/19
their [92] 9/18 14/13
17/6 17/15 18/12
21/23 22/16 25/1
25/13 25/14 25/18
25/19 25/19 26/1 31/6
31/7 32/1 41/18 41/19)
62/9 62/14 62/16
77/10 85/2 87/12
89/10 94/20 95/18
95/23 96/15 97/18
111/23 111/25 114/1
114/12 115/2 115/4
119/19 125/7 126/5
128/19 129/12 130/1
130/8 135/16 136/23
140/19 141/18 143/2
143/6 143/14 144/2
145/21 147/12 150/12)
151/10 156/7 156/12
156/20 157/16 158/10)
162/9 162/24 163/11
163/18 164/7 167/25
169/21 175/22 179/14)
180/8 181/10 182/1
183/8 183/13 186/25
187/11 188/6 189/20
192/16 193/24 197/25)
198/4 198/4 198/5
198/10 202/6 203/6
them [71] 4/25 14/17
20/10 21/7 21/8 24/2
40/25 41/21 41/24
45/4 45/9 45/13 52/12
58/16 60/4 63/19 64/7,
77/22 78/6 85/14 88/9
93/9 95/25 97/1 100/4,
108/22 112/13 113/25)
118/14 124/22 127/3
129/12 129/12 134/6
(82) summarised... - them
INQ00001203
INQ00001203
T 164/13 165/9 165/11 I think [354] 178/16 189/8 times [10] 28/9 111/3
them... [37] 136/20 _ 179/5 187/14 191/5 I thinking [6] 92/18 three-year [2] 115/23) 143/4 156/19 162/25
1437/7 140/21 151/9 200/6 158/15 168/14 180/8 I 189/8 163/3 165/20 165/24
152/6 152/21 158/22 Ithereafter [3] 114/23 I 189/20 196/9 through [39] 1/17 171/23 198/14
1459/6 163/16 166/5 176/3 179/11 thinks [3] 83/19 6/21 7/7 7/23 17/12 _Itimetable [1] 196/6
1466/9 167/16 167/16 thereby [1] 204/14 91/19 102/12 18/14 23/3 27/24 timing [2] 131/7
170/13 170/23 172/4 therefore [8] 20/12 I third [6] 34/8 49/9 28/21 44/24 45/3 131/13
1475/22 179/1 179/7 25/3 71/5 105/7 142/1I 62/12 72/5 75/19 45/10 51/9 59/19 timings [1] 90/10
1479/9 180/11 184/18 149/23 173/10 192/3 I 186/10 59/20 62/18 66/2 66/5Itipped [1] 185/1
1484/20 185/11 188/25I these [37] 7/17 17/3 Ithird-party [1] 62/12 I 79/14 87/5 109/23 title [1] 186/17
1489/11 192/17 194/5 17/7 33/22 34/23 this [254] 114/15 116/14 118/7 Itoday [9] 1/14 78/10
194/25 195/2 195/3 35/13 35/13 45/19 Thornton [2] 32/3 129/1 146/18 146/20 I 85/8 90/17 93/13
1495/4 195/11 195/13 82/2 85/20 117/11 99/25 150/6 154/15 160/11 I 103/21 103/23 157/13}
1498/4 201/16 203/16 122/25 129/3 132/17 Ithose [96] 2/22 5/5 I 168/6 174/11 176/25 I 160/24
theme [1] 140/1 135/9 135/9 138/9 8/23 11/5 13/22 13/25] 178/23 178/24 178/25I together [6] 53/11
themselves [22] 140/1 140/3 140/17 I 14/9 15/1 16/1 16/5 I 188/5 189/6 198/1 54/5 64/17 93/23
14/12 65/14 85/20 141/19 142/21 143/17I 18/1 20/8 21/7 21/10 Ithroughout [6] 76/1 I 151/1 169/11
94/21 95/7 96/20 143/19 145/18 146/19] 21/13 21/21 23/20 98/25 101/17 120/12 Itold [11] 19/12 60/24
97/12 102/5 143/1 151/2 155/12 158/24 I 23/24 25/2 33/25 34/9I 146/3 162/23 62/19 79/10 82/1
145/1 149/17 149/17 I 160/3 1641/8 162/12 I 34/15 35/19 37/4 Thursday [1] 1/1 118/19 134/6 137/4
156/17 160/20 166/12I 174/17 180/9 183/25 I 37/11 38/18 39/10 thus [2] 46/17 55/3 I 140/24 151/22 154/20
184/5 187/17 39/14 40/24 45/7 I Tidswell [2] 27/23 I Tolhurst [13] 131/25
19717 20018 20277 '® they [297] 46/23 47/22 50/20 I 74/8 139/14 142/24 143/18
203/14 they'd [15] 31/6 33/6 I 58/11 58/1261/18 _—_Itied [1] 37/11 143/23 144/17 172/19)
then [81] 2/24 2/25 I 41/11.46/24 85/16 I 63/21 68/22 71/9 74/7 tightened [2] 184/18 I 174/15 178/5 178/20
B12 5/15 6/7 6/20 I 86/8. 119/13 136/25 I 75/22 78/5 81/8 85/18) 194/25 179/22 182/2 183/23
9/11 12/9 18/7 19/15 I 141/20 142/2 156/7 I 92/8 92/10 93/8 94/25) Tim [2] 115/17 133/2 I Tolhurst's [3] 145/11
21/4 23/12 24/3 31/22I 161/17 193/15 198/8 I 95/6 97/13 101/17 time [107] 8/12 9/14 I 146/5 177/21
33/4 35/10 36/22 198/9 102/13 108/12 111/3 I 14/1 24/4 31/4 31/9 ITom [10] 50/15
37/10 41/21 42/11 they're [14] 12/18 1114/5 113/10 113/18 I 31/12 31/13 32/4 38/4I 174/13 174/20 175/8
45/11 49/17 49/25 12/18 13/13 17/12 114/13 114/16 116/7 I 38/6 39/20 44/8 44/10) 176/21 177/3 178/3
62/14 70/15 73/10 30/10 37/18 75/20 116/14 118/2 126/13 I 45/5 52/1 52/6 54/25 I 181/3 185/21 187/9
74/21 76/2 78/9 80/16I (9/4 96/7 97/6 97/12 I 127/1 129/7 134/5 70/6 71/13 71/14 tomorrow [1] 205/4
80/24 87/22 87/23 134/23 159/4 187/12 I 135/11 135/21 136/18] 77/25 78/11 80/22 —_Itone [1] 147/5
89/1 89/24 102/3 they've [9] 14/18 139/25 150/5 151/2 I 96/16 104/15 107/19 Itoo [10] 9/10 32/24
103/12 104/17 105/21] 24/14 24/24 31/14 151/10 152/2 152/22 I 109/22 110/17 111/8 I 101/25 163/16 170/6
4106/5 106/8 106/16 I 33/22 33/24 76/14 152/25 153/13 153/17) 113/9 118/23 119/1 I 172/15 182/7 191/19
4089 110/5 110/14. I 119/5 119/6 158/15 159/2 162/4 I 122/1 125/4 129/16 I 192/22 204/14
114/20 114/21 115/6 Ithick [1] 90/7 165/3 165/8 166/8 I 129/24 131/3 131/6 _Itook [15] 30/18 36/18
122/16 124/18 125/12]thing [31] 14/16 167/5 167/14 171/23 I 131/11 132/22 132/23) 48/18 121/1 121/3
131/19 133/1 139/4 I 19/20 17/23 22/24 178/2 182/20 184/21 I 133/13 133/20 135/8 I 142/7 144/2 158/2
4140/5 140/13 155/4._ I 32/13. 41/1 41/3 42/5 I 189/24 189/25 190/6 I 137/8 142/7 142/19 I 161/4 161/23 170/25
164/16 168/1 168/16 I 45/22 46/1 48/7 53/6 I 191/8 197/25 204/17 I 142/22 144/20 144/25] 173/2 180/11 181/23
170/21 172/17 174/23I 99/14 62/3 64/6 64/17Ithough [6] 22/1 146/21 150/14 150/16) 182/20
178/16 179/9 182/16 I 99/2 67/24 67/24 68/6I 37/25 108/23 135/14 I 153/19 154/21 154/24) tool [1] 168/15
183/8 183/8 184/6 84/4 84/24 98/13 136/15 137/4 156/10 157/12 158/2 Itools [3] 65/23 68/17
184/13 184/22 186/10I 190/11 152/24 176/23Ithought [26] 45/13 I 163/7 164/5 166/18 I 98/10
187/10 187/18 190/2 I 178/10 185/16 187/25] 56/3 59/7 73/3 77/14 I 170/20 170/25 172/8 Itop [6] 21/4 54/24
1490/4 191/20 192/1_ I 200/1 203/18 86/5 86/8 119/5 172/10 174/17 174/22I 109/24 132/5 161/6
1492/5 197/9 204/15 Ithing’ [1] 175/12 119/17 130/5 165/18 I 176/4 178/7 180/4 186/10
theory [2] 84/6 87/16 things [42] 17/22 172/22 178/9 178/23 I 182/2 182/5 182/12 Itop-up [1] 109/24
there [241] 19/8 19/10 19/11 178/24 178/25 179/10) 182/20 185/2 185/7 I topic [14] 6/2 10/16
there'd [1] 153/20 19/14 19/15 22/1 26/9I 182/11 184/4 184/4 I 185/11 188/21 189/1 I 24/4 27/15 38/4 38/15]
there's [36] 9/10 39/23 52/1 53/1 64/7 I 186/22 187/5 190/4 I 189/2 189/17 189/20 I 48/14 70/13 71/3
12/15 14/10 18/11 67/11 72/23 75/15 190/17 190/25 192/19] 190/1 190/21 191/11 I 74/18 74/21 92/1 92/2)
21/6 31/15 32/7 35/9 I 82/18 83/24 99/20 thoughts [1] 158/11 I 191/25 192/3 192/11 I 99/1
57/2 60/16 60/24 110/22 111/7 118/22 Ithousands [2] 109/2 I 192/23 192/25 194/1 I topics [3] 70/25 88/8
61/22 65/1 66/25 123/25 127/7 127/10 I 109/9 I 194/15 194/18 194/20] 94/15
72/23 78/9 80/24 128/16 129/3 129/9 I threatening [1] 195/5 195/8 195/9 —_Itotal [1] 99/25
82/25 98/14 126/7 138/15 143/8 144/14 I 157/15 195/25 197/13 200/14I totality [1] 192/6
133/25 138/11 138/18I 1922/3 155/22 158/15 Ithree [13] 13/5 53/5 I 201/19 202/22 203/3 Itouch [1] 71/6
140/9 144/5 148/1 164/12 164/18 164/19] 53/7 53/11 54/15 204/8 204/13 touched [4] 26/3
152/25 156/3 156/16 I 184/2 187/22 191/12 I 88/24 102/20 104/16 Itimeline [3] 56/7 58/5) 75/14 159/18 168/22
195/18 200/7 201/17 I 115/23 143/18 156/19] 58/9 Towards [1] 173/8
(83) them... - Towards
INQ00001203
INQ00001203
T try [19] 9/4 27/23 164/16 165/3 165/6 I 84/10 84/14 121/17 I 42/1 43/13 48/19
Tower[1] 937 27/24 28/20 125/11 I 165/12 166/11 173/1 I 143/19 145/16 146/5 I 52/14 53/16 55/18
track [2] 179/14 130/3 130/9 130/10 I 175/6 176/14 177/8 I 151/12 175/7 186/22 I 57/13 58/6 59/20
203/20 157/25 159/22 161/21I 186/21 187/8 202/23 I 202/21 204/7 59/24 64/13 68/22
tracking [1] 167/5 I 164/9 164/18 165/24 IUKGI's [11] 16/25 I understood [7] 59/23) 78/6 83/23 86/14
traction [21 t7izo._I 173/22 180/14 193/5 I 17/3 17/5 17/11 17/20I 61/22 141/25 145/12 I 87/11 90/22 94/15
pen 195/11 201/8 18/2 18/18 34/22 149/13 174/8 177/22 I 96/13 109/24 126/17
trade [7] 4/12 29/13. I*rying [13] 12515 109/14 131/20 182/5 Iundertake [1] 67/2 I 131/23 131/24 142/7
44/15 69/25 70/5 96/8) 126/2 129/1 130/14 IUKGI00008026 [1] undertaken [2] 72/10I 144/2 145/20 153/10
105/18 130/16 138/13 145/1 I 131/1 74/22 159/23 160/9 161/23
trading [2] 105/19 148/7 157/8 165/16 IUKGI00018641 [1] underthought [1] 166/9 169/22 174/17
4117/8 170/17 182/14 204/10) 127/18 158/16 182/19 184/18 185/24)
train [2] 44/10 44/12 Tuesday [2] 75/8 UKGI00049035 [1] underway [2] 63/10 I 194/25 195/25 197/4
training [4] 37/3 180/12 59/5 141/24 202/20
136/14 145/25 146/1 \turn [8] 2/2 31/17 ultimately [11] 13/8 Iundo [1] 180/14 update [3] 49/15
tranche [1] 43/18 43/13 80/5 86/14 17/19 18/14 19/7 25/3I undoubted [1] 55/21 77/25
transactions [1] 104/2 184/25 198/6 I 48/8 86/19 131/23 134/25 updated [1] 56/4
4160/1 turned [4] 147/14 I 191/5 198/7 204/15 I undoubtedly [1] updates [4] 21/2
transcript [2] 71/21 156/19 192/14 192/20I unable [1] 172/8 166/4 39/13 39/14 79/14
4105/3 Turning [1] 168/21 Iunaltered [1] 147/10 Iuneconomic [2] 6/20] updating [1] 180/8
transcripts [4] turnover [1] 113/9 Iunclear [1] 176/19 52/2 upholding [1] 110/20
piven turns [1] 189/2 undecide [1] 179/10 Iunfair [1] 59/10 upon [9] 2/14 13/23
twice [1] 52/6 under [30] 31/5 31/8 Iunfairly [1] 185/16 37/8 71/6 77/18
transform [1] 64/11 m
transformation [10] two [35] 6/18 13/5 43/6 43/16 43/23 44/3I unfairness [1] 147/7 I 122/11 129/12 162/17,
63/3 63/24 64/16 47/12 47/23 54/15 44/16 51/25 52/2 unfold [1] 173/13 194/5
111/12 114/13 115/19I 60/25 64/2 66/25 55/20 60/6 68/10 unfortunately [2] upset [1] 29/1
1416/2 116/7 117/9 67/11 70/25 72/23 80/12 82/12 108/17 157/15 171/19 upsetting [1] 30/19
tent 73/1 88/8 92/21 96/18 120/24 121/18 126/5 Iunimpressed [1] _I uptime [1] 76/15
transparency [3] I 97/4.98/16 104/20 I 126/8 127121 131/22 I 201/17 us [25] 1/3 1/8 22/18
8/15 20/20 92/2 104/22 114/13 118/22] 135/18 139/18 140/11Iunintentional [1]__I 70/22 75/14 95/14
4119/4 137/4 137/12 I 148/15 162/23 187/18) 164/20 103/17 104/12 109/8
transparent [4] 21/13 .
768 EO 117/11. I 193/47 160/23 170/23) 195/18 197/16 200/18I union [2] 29/13 96/8 I 113/19 114/15 114/21
Treasury [9] 2/18 I 177/20 180/4 184/8 /underestimated [1] IUnit [4] 2/21 2/24 3/1 I 118/14 124/28 132/23}
15/14 54/15 69/15 185/20 190/24 198/14I 53/24 160/17 133/13 154/3 157/18
69/15 109/25 114/15 199/13 204/19 underline [1] 14/23 Iunits [1] 123/17 170/17 185/19 191/11
126/11 155/8 two years [1] 104/20 I underlying [1] university [1] 2/14 I 192/8 193/3 194/19
treat [2] 64/7 2004 It¥ing [1] 193/3 168/20 unless [3] 188/10 I 195/1
treated [5] 64/13 [tye [7] 23/22 33/2 Iundermined [1] 190/10 191/15 use [14] 39/21 59/16
98/22 108/22 112/22 99/19 162/16 169/25 I 135/16 unlike [2] 113/4 71/17 77/19 84/21
123/11 176/23 187/15 undermining [2] 128/22 85/4 85/19 115/1
treating [5] 64/3 typical [1] 158/9 21/22 168/17 unlikely [1] 172/15 115/10 116/2 116/20
64/10 98/20 127/9 typically [4] 9/5 underplayed [1] unnecessarily [1] 116/21 121/22 122/4
157/8 15/18 15/19 52/10 62/24 196/1 used [25] 5/22 15/15
treatment [1] 189/10 u...”~—C understand [30] 5/25Iunpleasant [1] 28/25 I 32/12 46/20 47/2 47/6)
treatments [1] 187/3 I <7 =] 14/3 14/4 14/17 26/16I unsatisfied [1] 79/5 84/20 85/7 85/24,
UK [1] 5/10 28/7 30/15 41/14 201/22 99/10 111/13 114/19
trial [9] 122/22 UKGI [70] 3/12 3/18 I 44/18 50/6 58/10 78/8Iunsound [1] 152/23 I 115/20 115/21 116/6
169/10 188/24 193/22
496/10 196/23 201/5 I 2/24.4/11 4/20 4/25 I 93/22 95/22 97/19 _ I unsuccessful [1] 116/16 124/18 136/21
201/9 201/19 5/4 14/3 16/20 17/2 I 99/13 102/10 104/9 I 181/24 145/18 182/6 186/17
tricky [2] 26/5 94/25 17/20 17/20 17/24 116/4 130/14 142/3 Iunsupportive [1] 193/15 194/23 195/25}
tried [4] 194/20 18/14 18/14 20/21 143/2 143/13 143/15 I 172/14 useful [3] 50/5 83/18
495/114 195/12 202/1 I 22/10 35/1 35/17 146/9 146/21 149/21 Iunsure [2] 128/2 160/5
trouble [2] 1/10 35/23 36/15 37/3 54/4] 150/25 158/17 174/5 I 129/15 user [1] 171/12
199/13 54/25 55/4 56/20 understandable [1] I until [14] 39/11 57/5 Iusing [2] 111/10
true [12] 277 21/17 I 97/16 6316 81/13 87/8) 164/17 64/24 105/19 106/3 I 118/8
94/1 96/11 99/2 99/4 I understanding [37] I 106/14 106/20 122/21Iusual [2] 54/13 54/14
21/18 23/12 23/13
66/3 95/14 95/15 99/8 116/5 116/18 4/11 8/14 8/17 8/20 I 134/4 146/3 153/16 I usually [2] 110/7
117/17 118/4 118/19 I 11/2 13/25 22/25 186/15 197/13 205/9 I 140/18
96/22 10511 155/25 I 12016 132/17 138/12 I 25/24 34/1 44/23 Iunusual [3] 54/18 y
trust [4] 100/5 159/11 159/12 159/23I 47/15 50/24 56/22 I 54/19 202/9 Vo
Terres 168/11 I 190/9 160/11 160/18 I 56/24 57/1161/17 — Iunwise [2] 177/10 _I valid [2] 24/24 28/17
160/19 160/21 161/22] 61/20 62/14 62/16 I 179/11 valuable [1] 162/21
tees 0 oor 162/5 162/9 162/21 I 63/18 64/8 64/15, up [45] 16/23 24/8 I value [7] 24/16 25/22
truth [2] 162/22 163/10 164/6 I 78/14 79/3 79/7 84/9 I 29/16 32/17 37/24 I 45/11 46/11 46/14
(84) Tower - value
INQ00001203
INQ00001203
Vv 21/19 23/4 31/4 31/13) 73/25 101/10 119/18 I 16/7 16/17 26/13 156/23 158/11 158/23)
value...[2] 68/5 34/11 35/25 36/6 131/11 141/19 142/12) 37/14 41/7 43/1 44/10) 159/2 159/4 159/5
200/9 36/19 39/19 41/15 144/2 150/15 152/5 I 51/25 59/22 64/10 159/18 160/24 163/8
varied [1] 107/14 42/9 46/14 54/21 58/3I 155/4 159/8 161/6 65/1 66/8 66/10 67/12I 163/11 164/9 166/17
variety [1] 74/25 58/7 68/4 69/16 73/6 I 161/15 176/4 177/13 I 69/14 70/6 74/3 76/16) 169/17 170/12 175/13,
various [8] 7/14 73/7 73/25 76/1 79/1 I 178/18 180/25 193/11) 78/5 82/7 95/12 98/16I 176/19 177/3 181/20
39/13 76/8 76/19 82/17 86/10 87/22 193/12 193/13 195/9 I 99/7 100/20 101/24 I 184/14 186/22 188/14
105/18 143/4 144/1_ I 91/23 91/25 97/13 201/18 102/7 102/9 110/25 I 189/3 189/21 189/22
4197/2 97/13 116/20 121/3 Iwasted [1] 153/11 123/4 124/1 130/8 189/24 189/25 190/14)
vast [1] 21/15 121/21 139/9 149/18 IWatson's [1] 173/20 I 136/20 141/20 144/9 I 190/21 191/1 191/21
Vennells [6] 110/16 151/3 167/14 169/17 IWatt [4] 94/8 94/10 144/18 150/1 155/10 I 191/24 192/1 192/2
115/10 115/13 117/1 I 169/21 171/9 171/18 I 190/9 206/12 158/20 160/24 163/20I 192/3 192/4 199/3
118/24 128/13 173/2 174/8 174/23 Iwaxing [1] 197/2 163/20 164/19 167/7 I 200/12 202/15 202/16
Vennells' [1] 120/17 177/5 177/9 177/19 Iway [48] 1/16 14/25 I 172/23 173/5 176/12 I 202/19 204/10 204/16
178/21 179/22 184/25] 25/9 27/24 28/21 177/13 184/4 188/6 Iwhat's [2] 142/9
Vennells's [1] 119/11
veracity [1] 132/21 186/13 188/17 188/18] 29/19 30/24 31/10 188/25 193/5 195/13 I 168/9
t 188/21 188/21 190/2 I 32/18 32/23 39/17 I 199/24 200/8 201/11 Iwhatever [5] 40/19
vewaum [2] 32/10 I s98/9 20/3 43/11 45/6 47/21 202/18 204/24 54/15 76/15 98/9
version [4] 7/17 IViewing [1] 200/23 II 48/13 67/12 59/25 _Iwell-based [1] 173/5 I 180/18
Tet/T 1edy12 174/14 {views [19] 9/18 10/13 68/19 83/8 83/9 83/18Iwent [5] 2/25 8/10 — Iwhen [65] 4/25 12/18
versus [1] 18815. I 14/6 14/7 14/13 14/14] 90/20 11014 114/17 I S2r17 g7i21 2oarr I 16/13 24/9 25/12
very [109] 10/13 1216) 14/15 22/2 87/7 99/13] 117/1 119/16 121/23 Iwere [242] 28/20 30/24 31/8
Tobey 1373 15/5 19/12) 174/13 175/2 176/17 I 123/10 124/20 125/1 Iweren't [6] 31/10 I 40/14 43/14 48/7 58/2
10/13 20/2 De/e ofan] 177/12 177/15 178/2 I 141/10 150/4 152/3 I 80/22 86/23 97/21 I 60/23 62/25 63/24
28/24 34/13 41/14 178/2 180/20 188/4 I 160/19 161/9 166/8 I 112/17 158/9 63/25 65/25 68/1
45/5 47/11 50/18 vigour [1] 76/23 166/10 172/20 181/19) Westminster [1] 81/18 82/1 82/15
53/11 54/18 54/18 _IViolent [1] 87/10 184/20 191/2 193/18 I 143/8 87/19 92/22 94/23
54/20 56/6 56/6 59/11I Virtue [2] 95/9 97/4 I 196/5 197/16 198/1 Iwhat [165] 4/12 4/14 I 99/2 105/23 108/24
60/16 60/20 61/13 (I Visible [1] 104/5 199/6 200/5 200/24 I 5/25 8/9 8/17 9/21 110/12 112/4 113/15
76/17 77/20 79/20 I Wital [4] 95/17 96/24 Iways [9] 24/24 43/21 I 10/23 11/2 13/8 14/25) 117/13 119/5 122/14
79/21 83/24 86/2 151/2 158/20 47/24 69/19 80/9 16/7 20/1 21/20 22/22I 123/25 128/12 128/15
92/18 94/13 95/21 Voice [4] 31/25 33/23] 98/15 124/22 166/25 I 22/23 23/17 23/20 128/17 128/18 133/1
96/22 100/20 100/23 I 34/6 75/20 202/1 25/17 26/12 28/20 133/3 141/13 141/13
102/8 102/10 104/11 Iolte [1] 173/4 we [277] 29/1 30/21 31/24 142/3 142/23 152/20
410/10 112/6 112/22 IVOTP [1] 31/23 we'd [7] 88/9 125/14 I 33/19 34/23 36/18 155/1 155/3 159/13
113/23 114/16 114/24] WW 144/21 153/9 170/21 I 38/6 39/4 39/10 40/22I 160/10 161/23 162/1
Wo 184/10 188/22 42/9 44/18 45/8 47/14I 170/17 180/8 184/3
1263 1288 12618 waited [1] 181/19 I we'll [8] 9/23 27/15 I 47/18 48/7 50/21 51/4) 185/4 185/7 190/22
4127/7 129/20 129/22 IWaiting [1] 79/19 34/4 54/12 78/20 53/20 55/3 55/4 55/24) 193/17 195/22 195/23
4130/5 131/23 134/15 [Waning [1] 197/2 101/1 120/9 163/2 I 58/1 58/8 58/10 58/25I 198/12 199/20 199/24
437/2 137/8 137/14 IWant [21] 33/12 we're [5] 91/9 102/19I 59/23 60/10 62/6 201/20 201/23
437/14 13/7 13/9 I 24/24 72/12 79/4 80/3] 1314/5 171/14 194/13 I 64/23 65/11 65/14 I Whenever [1] 143/8
444/18 143/19 144/10I 82/28 86/1 86/12 we've [11] 37/3 88/8 I 66/9 67/13 67/21 69/4I where [52] 3/8 6/23
444/11 145/19 148/19I 28/16 88/20 92/1 89/19 90/17 118/7 I 69/21 70/10 70/13 I 8/18 10/13 14/4 14/7
4149/7 150/2 50/3. I 99/24 99/20 131/16 I 419/14 119/15 159/17I 72/12 73/20 74/19 I 15/12 15/25 21/1
153/19 162/5 163/9 I 102/17 165/22 173/14) 191/6 192/18 203/15 I 75/12 75/13 76/8 24/13 29/14 30/14
174/6 186/22 194/5 Iweak [1] 152/17 TINATIN4 TINT — I 31/11 31/17 34/18
130 ree an 198/21 weaknesses [1] 77/19 78/1 78/8 79/9 I 37/23 44/3 44/11
178/15 180/23 1892/3 IWanted [17] 20/1 135/1 80/17 81/1 81/8 82/1 I 45/23 66/14 68/6 75/8}
184/23 184/25 188/3 I 42/9. 45/14 67/19 wearing [1] 77/25 I 82/12 82/25 83/5 76/9 76/20 77/24 78/3
4188/3 188/7 190/13 I 82/25 91/6 95/5 website [2] 89/18 I 84/16 86/6 86/12 91/6I 81/2 82/22 83/12
490/25 192/11 192/14I 102/24 123/7 138/5 I 105/6 91/18 92/17 93/11 85/15 86/5 87/6 87/10
496/24 197/24 199/9 I 138/21 179/14 179/18] week [3] 30/14 46/11 I 96/8 97/21 98/1 99/9 I 96/10 97/1 113/5
4199/9 199/19 199/22 I 181/21 197/8 197/17 I 75/8 100/7 101/24 102/1 I 138/13 142/21 144/22
201/1 201/3 201/16 I 1997/2 weeks [5] 77/14 102/20 104/12 111/5 I 145/9 146/24 147/3
201/20 203/18 204/24I Wanting [3] 45/2 79/12 79/13 92/15 112/20 114/4 122/20 I 161/16 162/8 164/14
205/1 205/6 149/12 156/23 196/10 123/13 124/3 124/4 I 167/11 167/21 196/17
via [1] 59/13 wants [2] 76/3 157/1 Iweeks' [1] 32/3 124/15 125/6 125/11 I 196/21 196/25 197/3
viability [2] 50/9 wariness [4] 154/19 Iwelcome [3] 129/13 I 131/11 131/22 134/6 I 202/2
60/15 155/11 194/22 194/22) 194/7 194/15 134/12 139/20 141/10I whereas [4] 41/15
victims [1] 93/6 was [522] welcoming [2] 144/3 144/4 146/2 137/21 147/9 147/14
view [63] 6/8 6/22 7/2 wasn't [31] 8/12 8/17I 129/21 157/19 148/16 149/14 151/21/ whereby [3] 79/4
25/24 44/22 45/20 __ Iwelfare [1] 142/20 151/22 151/25 152/12I 173/23 179/8
10/11 14/21 18/7 I 48/9 62/6 64/9 73/16 Iwell [59] 5/15 15/15 I 154/1 154/19 156/1 Iwhether [37] 1/11 7/7
(85) value... - whether
INQ00001203
whether... [35] 10/23
13/23 19/5 23/24
29/12 33/8 42/2 48/11
50/12 59/7 61/23
66/21 67/12 67/16
70/2 70/3 71/13 72/12
82/23 85/6 90/12
90/19 90/22 91/22
96/7 102/4 102/5
102/18 112/2 142/18
148/11 156/5 161/13
173/20 174/23
which [224]
while [2] 131/2
140/19
whilst [8] 34/2 57/14
58/8 63/9 109/14
115/23 120/23 132/21
whistleblower [2]
55/23 59/15
whistleblowing [9]
11/10 55/10 55/19
59/19 60/7 63/13
71/10 71/12 71/16
Whitehall [1] 72/21
who [56] 9/6 9/13
16/5 18/16 22/22
22/23 28/11 28/22
28/23 31/10 40/4
44/24 52/19 52/20
62/19 62/19 70/4 73/5
76/7 80/1 84/8 85/16
85/18 88/13 89/9
89/16 95/18 102/9
103/2 108/6 109/1
109/9 110/16 115/7
118/2 128/23 133/22
144/1 144/2 149/22
150/18 158/24 160/2
160/3 165/5 165/19
181/1 182/23 182/25
184/5 190/1 192/25
197/21
whoever [2] 59/15
76/3
whole [21] 11/6 66/4
80/8 124/2 131/11
141/8 147/11 150/3
152/18 163/9 164/14
170/5 172/4 183/4
184/10 186/12 189/12)
197/11 198/1 200/6
201/7
wholesale [2] 156/5
169/4
wholly [1] 69/12
whose [2] 29/22
85/10
why [39] 9/1 11/13
16/15 17/9 26/16 30/7
36/10 41/7 53/21
139/23 142/25 143/18)“
138/3 144/19 149/23
157/6 157/17 157/23
159/2 159/6 161/4
168/14 171/4 174/16
91/22 95/23 101/25
121/25 148/9 148/20
WITN00180100 [2]
105/4 108/1
177/10 180/17 187/16] WITN11310100 [2]
187/17 188/4 188/20
15/4 80/6
190/17 190/18 192/18I witness [22] 1/14
193/25 194/24 194/25] 1/22 3/13 7/21 75/2
wide [4] 61/1 61/5
145/7 145/22
wide-ranging [1]
61/1
widely [3] 8/17 12/20
128/5
wider [10] 25/15
65/17 67/9 119/22
129/6 162/12 165/16
168/3 178/12 186/5
will [49] 18/7 18/9
19/15 21/7 24/7 24/21
34/3 34/9 34/15 34/25
36/12 37/18 37/19
37/21 37/22 37/24
38/1 38/4 70/14 70/15
93/2 93/12 93/14
93/15 93/17 93/21
96/20 97/25 98/2
101/18 101/20 102/4
102/5 103/9 105/6
105/7 111/15 114/24
115/17 116/18 117/11
117/15 117/16 119/15)
148/25 162/17 188/11
204/3 204/8
WILLIAMS [2] 77/8
206/6
ing [2] 9/20
181/25
gness [1] 41/23
window [2] 196/21
201/4
windows [1] 197/3
Windrush [1] 93/6
wish [8] 74/18 82/15
101/12 101/15 102/3
102/11 103/8 179/13
wished [2] 24/2
31/11
withheld [1] 184/24
withhold [4] 51/18
51/24 53/13 53/18
within [39] 5/11 6/3
8/16 18/2 23/19 28/3
30/3 33/16 35/7 35/8
40/1 40/2 44/1 46/16
46/17 46/22 46/24
56/17 79/6 81/7 94/2
105/8 107/20 108/24
110/20 122/20 124/3
158/17 160/17 161/13)
164/5 165/12 171/12
183/13 185/15 191/13)
85/12 88/10 94/18
103/22 103/24 105/5
204/25
witnesses [8] 80/17
101/19 101/22 102/3
125/2 137/15 201/17
202/7
won [1] 198/13
won't [3] 90/6 119/7
188/10
wonder [4] 24/12
38/4 55/15 153/24
word [4] 76/13
102/14 103/7 186/16
worded [1] 121/24
wording [3] 90/4
116/19 117/17
words [3] 77/19
191/17 203/8
work [29] 2/18 32/3
34/11 34/12 44/20
65/4 66/10 67/5 76/20
76/22 89/3 89/14
93/18 97/17 102/9
103/22 117/9 117/12
120/4 134/18 134/19
136/25 137/1 137/18
148/11 153/16 162/25
165/7 165/9
worked [15] 2/20
2/25 3/7 67/19 67/20
102/7 105/18 105/21
108/6 109/1 109/10
118/2 143/18 160/18
165/19
working [23] 33/9
33/13 34/5 43/21
44/22 46/17 46/24
54/4 82/18 93/8
100/14 108/24 109/3
109/8 110/6 111/1
127/1 128/24 160/7
165/8 165/15 168/8
174/16
works [3] 22/17
110/4 168/10
world [3] 157/15
157/16 167/17
worrying [1] 1/11
worse [3] 178/10
185/16 198/3
would [146] 1/8 5/6
6/6 6/14 6/22 7/2 7/2
9/12 16/2 20/8 20/10
23/21 23/21 23/21
36/22 36/24 37/20
39/13 39/14 39/14
41/7 41/21 42/17
75/5 81/14 81/23 84/3I 43/24 46/1 46/3 47/7
49/11 49/17 49/22
100/21 101/12 101/13) 50/5 50/20 56/16 58/3IWYN [6] 77/8 131/6
60/8 61/13 62/9 64/16] 196/24 199/19 201/6
135/14 135/14 191/16] 68/23 70/13 70/18
82/12 82/19 82/20
83/12 84/8 84/12
85/6 86/7 86/8 90/19
90/21 92/24 95/2
100/4 102/14 104/12
108/18 109/9 110/15
112/7 112/13 113/5
113/10 113/19 113/20)
114/6 122/25 125/14
125/15 125/20 126/2
126/15 127/2 128/13
128/16 128/19 129/11
129/13 131/12 131/13)
136/2 136/3 137/3
137/22 142/14 143/7
143/17 143/20 143/25)
144/9 148/7 148/18
148/19 150/19 153/7
154/1 154/3 154/24
160/21 161/16 164/6
164/22 169/3 170/3
17412 174/9 175/3
178/6 178/16 179/11
179/12 179/17 180/18)
181/20 181/22 182/24)
182/25 183/18 184/14)
184/25 184/25 185/14)
185/18 185/25 186/23)
187/23 189/14 189/17)
189/18 189/19 189/25)
190/14 191/15 191/22)
191/24 201/15 202/19)
would-be [1] 90/19
wouldn't [10] 21/16
22/1 84/12 86/1 134/2
167/17 170/4 184/13
191/8 195/10
wrapped [1] 141/11
write [5] 87/1 89/21
167/8 169/22 185/6
write-up [1] 169/22
writes [2] 5/20 52/10
writing [4] 8/4 60/4
89/16 178/3
written [8] 42/10
133/19 133/20 135/11
17415 174/12 174/17
177/19
26/7 27/8 32/12 32/13I wrongful [1] 126/1
84/12 84/17 85/1 85/5IXX [1] 132/5
INQ00001203
Ww 59/23 63/20 83/11 191/22 196/10 196/13Iworsening [1] 6/5 I wrong [16] 8/10 8/18
91/5 120/9 125/22 I without [7] 15/16 worth [2] 32/7 32/12 I 76/13 86/8 99/2
118/12 147/13 149/18)
150/14 156/21 164/1
171/15 171/25 178/14}
180/10 204/5
wrongly [1] 139/24
wrongs [1] 98/9
wrote [6] 58/15
115/12 115/17 174/10)
178/1 180/8
206/6
Y
yeah [25] 8/7 15/3
15/23 21/8 23/16 29/8)
30/1 35/16 43/12
43/12 51/20 51/22
58/24 58/24 66/12
66/12 74/1 74/11 81/6
104/4 107/22 132/12
176/15 194/19 196/24)
year [20] 1/23 26/13
52/6 53/5 53/7 53/11
69/8 75/6 92/6 104/21
104/21 106/20 115/23)
142/11 149/25 150/17)
153/11 184/9 189/8
194/1
years [16] 13/5 54/15
92/21 93/8 102/20
104/16 104/20 107/15)
128/23 143/18 145/17)
146/13 153/18 167/25)
170/23 184/8
yes [208]
yesterday [1] 90/23
yet [3] 6/8 51/2 63/19
you [873]
you'd [5] 104/9 114/2
138/9 183/17 199/16
you'll [2] 88/8 123/21
you're [31] 1/11
27/10 32/5 36/23
37/15 48/7 54/2 54/24,
57/23 60/4 62/6 65/4
68/12 71/20 79/20
83/14 84/16 90/1 90/5)
90/7 92/12 111/1
111/4 111/8 129/2
135/6 170/7 170/7
193/6 195/6 200/12
you've [30] 3/18 10/2
18/17 18/22 21/9
34/17 37/5 42/13
60/23 62/13 62/15
77/1 85/8 85/14 89/24,
90/11 99/3 115/9
(86) whether... - you've
INQ00001203
INQ00001203
Y
you've... [12] 119/2
123/23 138/11 157/3
166/9 168/13 168/18
168/22 179/18 190/17IZ
198/17 204/19
YouGov [5] 19/20
74/23 84/2 85/15 97/7
your [180] 1/10 1/20
2/4 2/4 2/7 2/12 2/20
3/24 4/3 4/10 7/14 8/1
8/21 9/24 10/22 11/8
11/21 12/25 13/19
14/20 14/20 15/4
15/25 16/11 18/22
18/23 19/2 20/2 20/12
22/6 23/4 23/8 24/9
27/20 29/3 30/25 32/9
34/20 34/22 35/15
35/18 35/23 36/3
38/17 38/19 38/24
40/21 40/21 41/16
42/14 42/18 42/19
43/2 43/10 43/14
43/19 48/19 50/10
50/14 50/21 53/6
53/15 55/24 56/19
57/21 59/7 60/2 60/8
60/9 62/13 62/13
63/18 66/15 68/21
71/23 72/12 73/10
73/47 74/2 77/1 7/25
78/21 80/4 80/5 82/8
82/8 85/8 86/10 86/13
86/24 87/13 88/9
88/11 88/12 93/24
93/25 94/1 94/15
94/18 95/5 97/13 99/4
99/17 103/6 103/17
104/7 105/1 105/5
105/8 105/10 105/15
106/25 107/16 107/18
107/23 107/23 109/11
109/21 109/25 110/7
113/13 115/9 115/13
116/14 116/5 116/20
116/24 119/11 119/22
120/13 120/15 120/23
123/3 125/19 127/1
127/9 127/15 127/20
128/5 134/5 134/12
139/8 140/8 142/8
145/15 150/23 151/19
156/22 161/2 161/23
163/8 166/20 167/14
169/7 169/17 170/9
170/12 170/24 170/25
17415 175/7 175/14
178/22 183/20 186/6
186/16 186/17 188/17
188/17 190/20 191/16
192/1 192/4 193/10
198/24 199/3 201/10
202/10 202/10 203/20
yourself [5] 10/24
82/22 83/13 177/11
204/12
Zdravko [2] 49/12
49/13
ZM [3] 49/10 50/3
0/6
ZP [2] 50/1 50/5
(87) you've... - ZP