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The Post Office Horizon IT Inquiry
Tuesday, 12 November 2024
(10.07 am)
MR BEER: Good morning, sir. May I call Professor Dame
Sandra Dawson and Dr Katy Steward, please.
PROFESSOR DAME SANDRA JUNE NOBLE DAWSON (affirmed)
DR KATY MARY STEWARD (affirmed)
Questioned by MR BEER
MR BEER: Good morning, Dame Sandra and Dr Steward. My name
is Jason Beer, as you know, and I ask questions on
behalf of the Inquiry. Can you each tell us your full
names, please?
DAME SANDRA: = Sandra June Noble Dawson.
DR STEWARD: Katie Mary Steward.
SIR WYN WILLIAMS: I should say before you start, Mr Beer,
that nothing ever surprises me in this life, it's taken
more than 50 years in the law to see two persons in the
witness box at the same time.
MR BEER: I was about to say that trained observers will
notice that there are two witnesses.
SIR WYN WILLIAMS: Well, I'm on the ball this morning, as
you can see!
MR BEER: Unusually --
‘SIR WYN WILLIAMS: = Thank you!
MR BEER: There was another part to that sentence:
unusually, we have two witnesses in the witness box.
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possibility of discussion in the witness box and also to
ensure that we've got a clear record of the evidence
that the witnesses give collectively.
So the reports: you've prepared two reports.
I think, the first, dated 26 March 2024, is 133 pages
long, including its appendices; and the second is dated
29 October 2024, and is 154 pages long, including its
appendices.
You updated both reports recently in large measure
to correct formatting and referencing issues and both
reports were reissued yesterday. It those reissued
reports that we're going to use in the Inquiry today and
tomorrow.
So the first report. Can we have it on the screen,
please. EXPG0000006_R. You should have a copy of that
in front of you as well in hard copy.
DAME SANDRA: I do.
MR BEER: You'll see from the title page, 26 March 2024.
It's the first report, Report 1, updated 11 November,
ie yesterday. Can we go to page 133, please.
This is the expert witness declaration and the
statement of truth. Those are redacted in the copies
that we have, but to start with, Dame Sandra, is that
your signature?
DAME SANDRA: It is.
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I should therefore set out the process that we intend to
adopt when asking questions of the witnesses and indeed,
please, when Core Participants ask their questions,
which is going to be tomorrow.
The purpose, sir, of setting out these ground rules
now is to ensure the orderly and efficient receipt of
evidence from the witnesses in circumstances where the
witnesses are giving evidence currently.
So the ground rules, if I may. Firstly, the
questions that I will ask you, Dame Sandra and
Dr Steward, in a moment, about the signing of your
reports and whether the contents are true will be asked
of you individually.
Secondly, the questions that I shall ask in a moment
about your qualifications will be addressed to you
individually.
But third, however, questions that will be addressed
to you collectively thereafter, it has been agreed that
you, Dame Sandra will, in the first instance address
each of them either by an answer, or inviting Dr Steward
to answer.
Fourthly, we'll work on the basis that Dr Steward
agrees with Dame Sandra's answers, unless she agrees
otherwise or wishes to intervene.
The aim of that approach, sir, is to reduce the
2
MR BEER: Are the contents of that first report true to the
best of your knowledge and belief?
DAME SANDRA: They are.
MR BEER: Dr Steward is that your signature?
DR STEWARD: tis.
MR BEER: Are the contents of that first report true to the
best of your knowledge and belief?
DR STEWARD: They are.
MR BEER: Thank you very much. Can we turn to the second
report, please, EXPG0000010_R.
You'll see this is headed Report 2, it's dated
29 October 2024, and it was again updated yesterday,
11 November.
I think there are some corrections to make, even to
that. Can we look, please, to start with at page 33.
SIR WYN WILLIAMS: I think I'd better stop you there because
neither assessor is having these things on their screen
at the moment. I've got it but they haven't. So that
needs to be fixed before we go any further, I think.
MRBEER: Yes, I'll just pause and usually somebody from RTS
appears.
That's not going to happen on this occasion, sir.
We need a five-minute break to correct the position. So
could I ask you to rise for five minutes, and we'll all
wait here.
(1) Pages 1-4
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SIR WYN WILLIAMS: _ I'll go out but if you'll all sit here to
save us coming backwards and forwards, I'd be grateful.
MR BEER: Thank you, sir.
(10.15 am)
(A short break)
(10.20 am)
MR BEER: Thank you, sir. Take 2.
Can we go to the second report. We were making some
amendments. Page 33, please, if that can come up on the
screen. In paragraph 114, in the second line, should we
cross through the words, "and" and then into the third
line, "investigations"; is that right, Dame Sandra?
DAME SANDRA: That is correct. Now, it's correct.
MR BEER: Page 48, paragraph 176, two corrections. In the
third line, into the fourth line, should we omit the
words "and investigations", which are being highlighted
‘on the screen, and should we omit the words
"investigation and", after the acronym "SPM"; is that
right?
DAME SANDRA: That is correct.
MR BEER: Thank you very much. Page 60, paragraph 222, in
the quotation in italics, three lines from the bottom,
should we replace the word "about" with the word "that";
is that correct?
DAME SANDRA: Correct.
two-thirds of that page your qualifications, experience
and expertise are set out?
DAME SANDRA: Yes.
MR BEER: Can I summarise the important parts, tell me if
you agree. Firstly, you have taught, researched,
written and consulted, on organisational behaviour,
leadership and governance?
DAME SANDRA: Correct.
MR BEER: Secondly, you held academic posts at Imperial
College London in the University of London before moving
to Cambridge?
DAME SANDRA: Indeed.
MR BEER: At Cambridge you were the master of Sidney Sussex
College, a Deputy Vice Chancellor and, most relevantly
for us, the Director of the Judge Business School for
11 years between 1995 and 2006?
DAME SANDRA: Correct.
MR BEER: You're now Professor Emerita at the university?
DAME SANDRA: Correct.
MR BEER: In addition to your academic interests and the
positions that you have held, you have personal and
practical experience of organisational behaviour,
leadership and governance, and you set that out in that
substantial paragraph that's at the foot of the page
that we're looking at now. Just picking out some
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MR BEER: Thank you very much. Then lastly, page 99,
paragraph 370. In the second line, should we insert the
word "are" between the words “there” and "no", so that
I reads "and consistently be don
are no decisions"?
DAME SANDRA: Correct.
MRBEER: Thank you. Can we go to page 154, please, and
scroll to the bottom. Firstly, is that your signature,
Dame Sandra?
DAME SANDRA: It is.
MR BEER: With those corrections brought into account, are
the contents of the report true to the best of your
knowledge and belief?
DAME SANDRA: They are.
MR BEER: Thank you. Dr Steward, is that your signature?
DR STEWARD: Itis.
MR BEER: Are the contents with those corrections brought
into account true to the best of your knowledge and
belief?
DR STEWARD: They are.
MRBEER: Thank you very much. Can we go back to the first
report please, and turn to your qualifications,
expertise and experience. It's the first report at
page 131.
Starting with you, Dame Sandra, I think on the first
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sorry, "if there
highlights, I think you've been the chair of an NHS
Trust?
DAME SANDRA: Correct.
MR BEER: You have been a Senior Independent Director,
a SID, and chair of a Remuneration Committee?
DAME SANDRA: Correct.
MR BEER: That was at TSB. You have been a NED,
a Non-Executive Director, and a member of an Audit
Committee, that was at both Barclays Plc and JPMorgan.
DAME SANDRA: JPMorgan Claverhouse Investment Trust, yes.
MR BEER: You were a member of the Senior Salaries Review
Body?
DAME SANDRA: Correct.
MR BEER: You have been a Non-Executive Director and
a Senior Independent Director at a public body, namely
the Financial Services Authority?
DAME SANDRA: Correct.
MR BEER: Thank you.
Dr Steward, staying with page 131, if we scroll
down, please, and this goes over to page 132, this sets
‘out your qualifications, experience and expertise, and
can I summarise. Firstly you have taught, advised,
coached and consulted in leadership, organisational
culture and governance for 30 years?
DR STEWARD: Correct.
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The Post Office Horizon IT Inquiry
1 MRBEER: You were the head of the National Culture and
2 Leadership Programme for NHS England?
3 DRSTEWARD: Correct.
4 MRBEER: Thereafter, a visiting fellow at the Cambridge
5 Judge Business School and now a visiting scholar at
6 Sidney Sussex College, Cambridge?
7 DRSTEWARD: Correct.
8 MRBEER: You have also served on the boards of public
9 sector bodies and charities, including an NHS Trust and
10 the UNHCR.
11 DRSTEWARD: That's right.
12 MRBEER: Thank you very much. That can come down.
13 Can I turn to the third topic, then: the methodology
14 that you deployed in approaching your task and the
15 purpose of each of your reports. If we can turn to
16 page 6 of Report 1.
17 Thank you. Does this set out a summary of your
18 instructions?
19 DAME SANDRA: It does.
20 MRBEER; Thank you. In summary, this report, Report 1, was
21 prepared and completed, remembering it's dated 26 March
22 2024, before we commenced hearing any evidence in
23 Phases § and 6 of the Inquiry; that evidence started on
24 9 April 2024. So it’s unaffected by any of the evidence
25 that we were subsequently to hear about what actually
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1 presented chronologically, split into columns: the
2 left-hand side are the requirements and guidance which
3 apply to companies, special attention paid to publicly
4 listed companies; the right hand requirements are the
5 public companies or entities which are wholly owned or
6 controlled by the Government. You say, and we're going
7 to look at Annex A, in a moment:
8 “Whilst there are differences between publicly
9 listed and publicly owned companies, it is notable that
10 in matters of governance during the relevant period, one
11 finds the requirements and expectations for all
12 organisations in the UK have tended, and tended to be
13 encouraging by governments and regulators, to follow the
14 approach adopted in law and guidance for publicly listed
15 companies.”
16 DAME SANDRA: That's correct.
17 MRBEER: If we can look at Annex A, I am not going to go
18 through the detail but just want to establish how it
19 works. It begins on page 93.
20 In we scroll down after the preamble, we can see the
21 two columns you mention, one is headed "Formal Legal
22 Requirements for Corporate Governance", and on the
23 right-hand side "Formal Legal Requirements that would
24 apply to Public Corporations/Companies in Government”.
25 DAME SANDRA: Correct.
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happened at the Post Office, what happened in the
exchanges between the Post Office and UKGI, and what
happened involving UKGI, and before it the Shareholder
Executive, and central government, from 2000 onwards; is
that right?
DAME SANDRA: That's correct.
MRBEER: Thank you. In paragraph 1, in (i) there, you say:
"We are instructed to provide a report which sets
‘out what might typically be expected/best practice ...”
In paragraph (ii), in the second line, you say that
the report deals with "generally expected standards".
Do I understand correctly that the standards which
you say ought to have been achieved in this period do
not represent, in your view, a counsel of perfection?
DAME SANDRA: That's exactly right. The standards are ones
which are generally expected. They're not the highest
level or the lowest level.
MR BEER: So they're, is this right, the standards
reasonably to be expected from a company in the position
of the Post Office?
DAME SANDRA: Indeed.
MR BEER: Thank you. Looking at (iii) and (iv), you tell us
that Annex A to your first report provides a chronology
of the laws and guidance on governance of companies
which applied during the relevant period, 1999 to 2019,
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MR BEER: You essentially track across time, we can see on
this page 1998 and 2006, and if we go over the page and
keep scrolling, and keep scrolling, nothing relevant in
‘93 and '94, for example. So that's the way the thing
works.
If we can go back, please, to page 93 and look at
box 1.1 and 2.1. Thank you. Here you note some of the
requirements of the Companies Acts in 1995 and 2006, on
the left-hand side, that applied to companies. Then on
the right side, public corporations or companies
essentially in Government ownership; is that right?
DAME SANDRA: That's correct.
MR BEER: You note that the Companies Act, on the right-hand
side, covers companies in Government ownership,
ie incorporated companies in which the Government is
a large or sole shareholder.
DAME SANDRA: Indeed.
MR BEER: So you're essentially suggesting that we should
read what we read in the left-hand box into the right
hand box; is that right?
DAME SANDRA: Indeed.
MR BEER: Thank you. Can we look at another example of how
this works at page 100, and scroll to the foot of the
page, please, and look at paragraph 1.8 and 2.3. 1.8,
the left-hand column, normal companies; right-hand side,
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companies in Government ownership. You point out there
that in relation to ordinary companies in 2005, there
was revised guidance on the Combined Code --
DAME SANDRA: Indeed.
MR BEER: -- in the same year, issued by the Treasury and
the Cabinet Office, a Corporate Governance Code in
central government departments?
DAME SANDRA: That's correct.
MR BEER: Is, just by way of detail, that -- what's recorded
in box 2.3 -- the first occasion on which Government
issued a Corporate Governance Code?
DAME SANDRA: Yeah.
MR BEER: So the first time that there was a formal document
issued by Government about government-owned companies
was that issued by Treasury and the Cabinet Office in
2005?
DAME SANDRA: Yes. You'll note that there was -- in 2001,
we've noted the "Management of Risk -- a Strategic
Overview", rapidly became known as The Orange Book,
which had, we thought, some relevance.
MR BEER: If we go back --
DAME SANDRA: It was in 2001.
MR BEER: If we go back to that, that's on the top of
page 99. You're referring to The Orange Book. Was that
principally about risk management for Accounting
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please. Essentially new headings, maintaining the same
approach: left-hand side companies; right-hand side
companies in Government ownership, here dealing with
other instruments, codes, guidance, and similar
documents.
DAME SANDRA: That's correct.
MRBEER: Thank you very much.
Can we go back to page 6 of your first report,
please. You'll see in (vi), at the foot of the page,
you say:
"Beyond identifying specific requirements and
guidance for governance [as summarised in that table
we've just looked at], we have commented on what might
normally be regarded as known reasonable practice in
governance, management and leadership. [That
commentary] is based on our experience and expertise."
Just so that I understand what you're saying there:
you're saying that part of your report is founded on law
or one of the other instruments summarised in Annex A,
but other parts of your report are not founded on such
instruments: they are based upon your experience and
expertise?
DAME SANDRA: That's correct.
MR BEER: You then set out, if we go over the page, please,
over eight chapters, the headings of which are set out
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Officers?
DAME SANDRA: It was, yes. It was about the management of
risk.
MR BEER: Rather than the broader subject of corporate
governance?
DAME SANDRA: Indeed, indeed.
MR BEER: Thank you. So that's how Annex A works, and that
will be an important source of material for the Inquiry
in due course. I'm not going to go through it. It
speaks for itself.
DAME SANDRA: May I add that on page 94, we've moved from
formal legal requirements into codes and guidance, which
I think you didn't directly
MR BEER: I skipped over.
DAME SANDRA: Yes.
MRBEER: Thank you, you're right to pick me up, the second
person that's done that this morning. Page 93, just so
we can all understand what you're speaking about. The
two headings there are both about formal legal
requirements, they both start in that way and address
law -—
DAME SANDRA: Mm-hm.
MR BEER: --ie primary legislation and Act of Parliament.
DAME SANDRA: Mm.
MR BEER: Then, over the page to 94, and scroll down,
44
there, your views on what might reasonably be expected
of a company in the position of the Post Office between
1999 and 2019?
DAME SANDRA: That's correct.
MR BEER: Thank you. This does not comment, Report 1, upon
the extent to which those standards reasonably to be
expected of the Post Office were, in fact, realised.
DAME SANDRA: Makes no comment.
MR BEER: Thank you.
Can we go to Report 2, please -- I apologise for the
delay, the system is taking a little while today -- and
turn to page 6. Here you've set out your approach, your
methodology, in relation to Report 2, and this report,
is it right, was prepared in the course of, and then
after, the evidence was heard in Phases 5 and 6?
DAME SANDRA: That's correct.
MR BEER: You tell us in paragraph 2 that it wasn't your
intention, nor indeed were you instructed to establish
any matters of fact. In paragraph 3, you tell us that
you have applied, you have been mindful of, the
standards of expected behaviour that you set out in
Report 1. That is -- I've used the language within the
Inquiry in the past -- Report 1 as being essentially the
Highway Code of corporate governance; is that an unfair
description of it?
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The Post Office Horizon IT Inquiry
DAME SANDRA: That's entirely right and, in relation to
Report 1, the concluding section 8, as we identify
there, also includes a commentary on what it's like to
experience organisations, particularly in relation to
authority, power, leadership, culture and communication.
MR BEER: You tell us in paragraph 4, by way of a reminder,
what Annex A, an important document of Report 1 consists
of. In paragraph 5 you say the instruments you mention
provide the foundation for considerable consensus
reflected in the large volume of written and broadcast
advice on what makes good board governance and executive
management. What was the point you were making there,
that the volume of material --
DAME SANDRA: Yes, one might have expected expert evidence
from an academic to be replete with references. The
truth of the matter is that there is an enormous amount
which is written and expressed about management,
leadership and Government, there is a general consensus
which may be available at any book stall or advice from
a professional services organisation, and we felt that
that consensus was sufficiently strong for us to rely
upon it.
MR BEER: Thank you. You tell us in paragraph 6 that in
preparing this second report you drew on your reading of
your selection of the evidence, including excerpts from
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was such that we made selection but there may be people
who think, "Well, they should have looked at this", or,
"They should have looked at that", which we didn't do.
MR BEER: So you're telling us that, even in the case of the
case studies, the examination of the material has not
been exhaustive, ie looking at every document?
DAME SANDRA: We cannot know.
MR BEER: Can we turn, please, to pages 8 and 9. This sets
‘out the scheme of your report. Is this a fair summary
if we look at page 9 first. You looked at three case
studies: the Wolstenholme case in 1994; the
consideration of the Second Sight Interim Report by the
Post Office Board in 2013; and the handling of Simon
Clarke's Advice, or one of them, by the Post Office
Executive in 2013?
DAME SANDRA: Indeed.
MR BEER: Those are the three case studies. Can you help
us: why did you pick those three case studies?
DAME SANDRA: We reviewed in general the material that we
had before us. We considered the -- our instructions,
and we thought, as illustrations, those case studies
were ones that we would wish to go into some depth with.
At the beginning of our work, we were more optimistic
and we thought there may be indeed other case studies,
but we did -- we were only able to do three.
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witness statements and transcripts of oral evidence and,
I think, reading some of the underlying material --
DAME SANDRA: That's correct.
MR BEER: -- the primary documents.
You tell us in paragraph 7 that you reviewed that
evidence and yourself chose three case studies for
analysis?
DAME SANDRA: Correct.
MR BEER: Am I right in believing that those case studies
chosen for Report 2 do not represent the entirety of any
view on the propriety of the Post Office's governance,
over the time period relevant to this Inquiry?
DAME SANDRA: That's correct.
MR BEER: Instead, they are prepared to assist the Inquiry
but do not reflect any conclusion of the entirety of any
good or bad practice in the governance of the Post
Office between 1999 and 2019?
DAME SANDRA: That's correct.
MR BEER: You tell us that in being selective -- the third
line of paragraph 8, of themes and evidence you:
"... appreciate there may be additional or
alternative constructions based on the body of evidence
before the Inquiry which we have not considered.”
Can you explain what lay behind that evidence?
DAME SANDRA: The vast body of material before the Inquiry
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MR BEER: Then if we go back to page 8, please. You say in
paragraph 13 that:
"_. the Overview, provides a thematic summary of
[your] observations on [the Post Office's] Board
Governance and ... Executive Management and
Organisation, which are based largely on the description
and analysis of the three selected case studies,
informed by a wider reading of a selection of evidence
before the Inquiry.”
Then you identify your themes. If we just scroll
down, are they split between themes that relate to,
essentially, governance by the Board and then themes
that relate to the executive, for its part?
DAME SANDRA: That's correct.
MR BEER: So the first six relate to the Board and then, if
we scroll down, please, the remaining three relate to
the Executive?
DAME SANDRA: That's correct.
MR BEER: So just pausing there: approaches three case
studies across time. We've seen one in 2024 and two in
2013.
DAME SANDRA: Yes.
MR BEER: Using those as your evidential base, you've
identified or isolated nine themes --
DAME SANDRA: Correct.
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MR BEER: six which relate to board level governance and
three of which relate to management and organisation by
the executive?
DAME SANDRA: Indeed, correct.
MR BEER: While there are no case studies picked up by you
between 2004 and 2013, that does not mean that there are
no questions of governance arising for you; is that
right?
DAME SANDRA: Neither before 2004 nor between 2004 and 2013,
nor subsequent to 2013.
MR BEER: So we shouldn't take from that that there are no
questions of governance arising which the Inquiry
therefore shouldn't look at? The Inquiry should look at
those by reference to the -- firstly, the principles
that are derived from your first report but, secondly,
from your analysis of the three case studies and the
themes in your second report?
DAME SANDRA: That is exactly the case.
MR BEER: Thank you. That can come down.
Throughout this second report, you identify actions
on the part of the Executive, the Chief Executive, the
Chair and the Board, which amount in your view to
a failure of governance?
DAME SANDRA: We'd identified a number of things which we
believe are indeed a failure of governance. Governance,
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MR BEER: So to take an example, if there were facts on
which it might reasonably be concluded that the Chief
Executive or the Chair or members of the Executive had
critical information about risk that was not provided to
the Board, you could break down by reference to the law,
the policy or the guidance identified in Report 1 how
that would, in fact, be a governance failure?
DAME SANDRA: Indeed.
MR BEER: I think it's right to say you don't do that on
every occasion --
DAME SANDRA: We don't.
MR BEER: -- because you've already identified in Report 1
what the relevant standards are?
DAME SANDRA: Indeed.
MR BEER: So where we read "failure of governance",
"governance failure" or "failure", that's to be taken as
a reference back to the standards in Report 1?
DAME SANDRA: It does, absolutely.
MR BEER: So in the scenario I've just described, the
failure to provide relevant information about risk by
a member of ExCo or the CEO to the Board, there could be
a possible breach of Directors' duties in the Companies
Act?
DAME SANDRA: It could be.
MR BEER: It could be a breach of duties of common law or it
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of course, is a series of processes, structures, systems
and rules, underpinned by behaviour and culture. And,
therefore, where the failure exactly occurs in that
overall network of structures, systems, processes,
behaviour and control, we hope we've indicated. But
failures of governance could be many things.
MR BEER: What does “failure”, “governance failure" or
“failure of governance" mean?
DAME SANDRA: When one is concerned with the governance of
organisations, you're concerned with the structure,
systems, processes, behaviour and culture which will
secure the governance and management of the organisation
in the best interests of that organisation and,
therefore, if one identifies a failure, it is that it
does not appear to be, to us, to be in the best
interests of that organisation to pursue its purposes.
MR BEER: And also a failure to meet the reasonably expected
standards of good governance identified in Report 1?
DAME SANDRA: And that was the basis on which I made my
prior comment.
MR BEER: So where, in each case in Report 2, a failure is
identified by you and Dr Steward, that would have been
a failure according to the standards in play at the
time?
DAME SANDRA: Indeed, in our belief.
22
could be a failure to adhere to reasonably accepted
standards in a Corporate Governance Code?
DAME SANDRA: Indeed.
MR BEER: It might indicate a possible failure in the
relationship between one of the individuals and the
Board?
DAME SANDRA: Indeed.
MR BEER: Can we turn, please, to Report 1, then. I want to
try to deal with this briefly if we can, and start by
looking at paragraph 1.2 on page 8.
DAME SANDRA: 1.2?
MRBEER: On page 8. So just to remember, Report 1 has.
eight topics and this is topic 1: Governance, Principles
and Codes. We see that from the top of the page. It
might be helpful if you just -- this chapter runs for,
I think, 12 or 13 pages up to page 20. Could you, in
a paragraph or two, describe sort of the purpose or
coverage of this chapter?
DAME SANDRA: We were eager to lay out the historical
context and how that had then developed into codes of
practice. We identify that, in a way, the roots of
governance were around protecting the rights of
shareholders, which became very important when you got
a split between ownership and control, and the question
was: how were the executive, who no longer owned the
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business, going to be held to account and who was going
to hold them to account? And that led to the formation
of boards and, in time, particularly in relation to the
development of the contemporary governance, the work
that followed the Cadbury Committee, which then
became -- that was in 1992, and then together with
Greenbury in '95 and Hampel in '98 became enshrined in
the Combined Code on Corporate Governance, which really
is the first time that these matters have been brought
together, which dealt with the need to separate the
Chief Executive and the Chair and which identified
roles, specific roles, for Non-Executive Directors.
In the subsequent 25 years, that Combined Code, from
2010, understood as the UK Corporate Governance Code,
has increasingly identified areas beyond roles and
responsibilities dealing, for example, with audit;
dealing with risk; dealing with the need to disclose
certain matters with relation to conflicts of interest;
and then latterly, matters to do with diversity,
equality and inclusion, and other societal aspects.
What can be seen, I believe, from Annex A is that
this is an evolving story and I'm mindful that the
Inquiry is dealing with 20 years of that evolving story,
and we've tried to be careful to look at what would have
been contemporarily expected at the time.
25
MR BEER: In what sense was it combined?
DAME SANDRA: I've often wondered that. It was combined in
the sense that it amalgamated these different reports
from different committees and these different
expectations of governance, and that word "combined" is
just asserted.
MRBEER: Thank you. If we go over the page to page 9, you
tell us that that code in 1.2.4, through its principles
and provisions, gives a well established base set of
regulations and guidance on the two things that you
mention there:
"The structure and operation of Boards of Directors,
including roles and responsibilities of Chairs and Chief
Executives; and
"Roles and responsibilities of Shareholders
(particularly institutional shareholders, with
relatively large shareholdings)."
So is the point you're making there that this code,
across the entirety of the period that we're looking at,
was an easy-to-find instrument which set out detailed
and a well-established base of guidance?
DAME SANDRA: I am afraid I didn't hear the word you said
before "set out something" --
MR BEER: Detailed and well established set of guidance on
the two things that you mentioned?
27
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MRBEER: Thank you. If we just scroll down on this page,
just some terminology. You tell us in 1.2.1 that UK
practice is to have a unitary board of executive and
non-executive directors. That is opposed to what?
DAME SANDRA: That is opposed particularly, if one looks to
organisations in Continental Europe, where there is
often a two-tier board: the overseeing board, which will
have a representative of a larger number of
stakeholders; and executive board, which is responsible
for running the business.
In the UK, the custom has been for the executives
and the non-executives to sit together and it's normal
that the Chief Executive and often the Chief Finance
Director or Finance Director will sit as board members,
as well as having their executive responsibility and, in
that sense, it's called a unitary board.
MR BEER: Thank you. In 1.2.3 at the foot of the page, you
tell us what you have just mentioned about Cadbury,
Greenbury, and the Hampel Committees becoming enshrined
in the Combined Code, which you told us was called the
Combined Code, up until 2010 --
DAME SANDRA: Correct.
MR BEER: -- after which time it was known as the UK
Governance Code or the Code of Governance.
DAME SANDRA: Yeah.
26
DAME SANDRA: Indeed. That's correct.
MR BEER: So the point, is this right, that you're making,
is that one doesn't have to search very far? It's not
a voyage of discovery to find out what corporate
governance standards and principles were in this period?
DAME SANDRA: No, absolutely not and I think the coming of
Cadbury was really a very momentous period for UK
governance and, as we've seen in relation to Appendix A,
Government itself looked back and looked at commercial
organisations and said, "Ah, these standards, they
should indeed apply as best as they can to those
organisations". Charities similarly looked at them and
thought they should apply, and other private
organisations began to think, "Oh, these criteria, these
recommendations, these principles, are basic and sound,
and we should apply them".
MR BEER: In terms of the duties to comply, you tell us in
paragraph 1.25 that:
"Boards in their ... annual reports have either to
‘[complain] or explain’ why, in their
‘special/individual circumstances’, the Code's
requirements are not in their view appropriate or
advisable in the circumstances."
DAME SANDRA: They may indeed "complai ut they are
required to "comply or explain". And so if, for
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example, it says the chair and the chief executive
should have separate -- should be separated, no one man
or woman should hold them both, there were some
organisations where it was felt by the board that it was
appropriate in their circumstances that they should be
combined, in which case, in their annual report, they
would have to explain why it was in their particular
circumstances they were not complying.
MR BEER: Thank you. Can we go over to page 10, please, and
look at paragraph 1.3.1. You say that:
"It has become increasingly accepted that Corporate
Governance codes for commercial companies offer guidance
to other forms of ownership, notably ..."
Then (c), which concerns us:
“Publicly owned assets, where the owner is the
national government (or local authority) and a major
element of funding comes from the taxpayer, sometimes in
combination with revenue from commercial activity. The
governance of such publicly owned companies is central
to our instructions."
So is the point that you're making there that, what
we read in the Combined Code and then the UK governance
codes, should be something which is applied to a company
which has publicly-owned assets?
DAME SANDRA: That is indeed the case, and Government
29
Accountability".
DAME SANDRA: Yes.
MR BEER: I find this a little complicating (sic). Can you
explain: firstly, the four levels of accountability, are
they levels that you have designed or thought of --
DAME SANDRA: Yes.
MR BEER: -- in connection with the Post Office?
DAME SANDRA: They are our invention of trying to make sense
of who is accountable to whom at different stages of the
period, the relevant period. And that's why, in
Appendix B, we identify each of the levels. So I'll
explain each of the levels. The first level is who was
accountable for running the Post Office business,
which --
MR BEER: Sorry to speak across you there, Dame Sandra, I'm
going to come to Appendix B in a moment.
DAME SANDRA: Right.
MR BEER: I just want to work out, at the moment --
DAME SANDRA: Okay.
MR BEER: = -- what these levels of accountability are. So,
firstly, they're not a concept from corporate
governance, academic research that everyone in the
corporate governance world would know, "Ah, the four
levels of accountability"; they're your design for this
problem?
31
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frequently asserted, when looking at different public
bodies, that the expectation was that, insofar as was
appropriate for their circumstances, these codes and
principles should apply.
MRBEER: Thank you. Can we look at the foot of the page
please, which, I think, is the point you have just
mentioned. You say in 1.4.1:
"The government has drawn on corporate governance
for publicly listed companies to provide a framework for
how the governance of an array of public bodies should
be governed."
Then I think you quote from the Treasury publication
that we looked at in Appendix A:
"Good corporate governance is fundamental to any
effective and well managed organisation and is the
hallmark of an entity that is run accountably and with
the long-term interest clearly in mind."
Is that right: that's one of the pronouncements that
you rely on to support the assertion that our Government
has suggested compliance with the corporate governance
codes for companies in public ownership?
DAME SANDRA: That is correct.
MRBEER: Thank you. Can we go forward, please, to page 15.
You start off here dealing with what you describe in the
cross-heading above, 1.6.2, with "Four Levels of
30
DAME SANDRA: They are our design for this problem.
MR BEER: Okay. If you then just talk us through. Level 1,
POB, the Post Office Business. Here you start appealing
to lawyers by using these acronyms. But the Post Office
Business, just explain what that level is, please?
DAME SANDRA: That is the level which is running the Post
Office Business, including, for example, the
subpostmasters network and matters connected with
Horizon. They had -- okay.
MR BEER: Then if we scroll down, please, to 1.6.4, the
second level of accountability. OPOD, the intermediate
‘ownership of Post Office Business. Can you summarise
that for us, please?
DAME SANDRA: This the level above the Post Office Business,
so, very initially, the Post Office Authority, and then
in that period when the Post Office was owned -- was
a subsidiary of variously called Royal Mail Holdings and
other holding companies, this was that intermediately
ownership level, so it was the ownership of the Post
Office Business.
MR BEER: Thank you. Then level 3, AGS, Active Government
Shareholder. Can you briefly summarise this for us?
DAME SANDRA: Yes, that is where the Government, as
shareholder, identified its role and required some
accountability from both the Post Office Business and
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the intermediate ownership of the Post Office to that
shareholder.
MR BEER: Thank you. Then over the page, level 4: the
Government, the fourth level, if you can briefly explain
that for us?
DAME SANDRA: Ministers and senior civil servants in the
relevant sponsoring Department on whose behalf investors
were providing oversight.
MR BEER: Thank you very much.
Then the next part of your report deals with what
you describe as three phases in accountability. So this
is essentially a chronological account --
DAME SANDRA: Yes.
MR BEER: -- across time, between 1999, right up until 2019,
which is your relevant 20-year period. So if I can
understand what's going on here, is it right to say that
you then looked chronologically at how the four levels
of accountability applied across time and split that
broadly into three periods, three phases?
DAME SANDRA: That's correct, and the periodicity was our
construction again.
MR BEER: Thank you. So Phase 1 is between 1999 and 2001.
What you do is then you narrate for us in 1.6.8(a) what
level 1 was and its relationship to level 2, taking us
back to your concepts.
33
DAME SANDRA: That's exactly correct.
MR BEER: Is that represented in more detail in Annex B of
your report, starting at page 112?
DAME SANDRA: That was our intention.
MR BEER: If we turn that up please, page 112. So, rather
than setting out essentially in narrative format, which
is what you did in the body of the report, the phases
and the levels, this seeks to combine the pair of them
in a table; is that right?
DAME SANDRA: That is correct.
MR BEER: This is for real aficionados, if we look, for
example, in Phase 1, 1999 to 2000, we can see in 1999
the existence of levels 1, 2 and 4, but not level 3, as
you've just described. You have described the nature of
the entity at levels 1, 2 and 4, as respectively Post
Office Counters Limited, and you've put the company's
number, it's how it was incorporated and the fact that
it was a subsidiary of the Post Office Authority, which
was a statutory corporation. You tell us in about the
fifth column along, a statutory corporation with power
to issue directions to the Post Office. The sponsoring
Department was the Department of Trade and Industry, the
DTI, and the Secretary of State was Stephen Byers.
DAME SANDRA: That's correct.
MR BEER: If we just scroll down we see you track that
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DAME SANDRA: Indeed.
MR BEER: Then if we scroll down, please, and over the page.
Then in (b) at the top of the page, "Level 2 and its
relationship with Level 4", that's because there was no
level 3 at that stage?
DAME SANDRA: Indeed.
MRBEER: Then Phase 2, again, you're essentially applying
these two dimensions/levels, across time.
DAME SANDRA: Indeed.
MR BEER: Tell us in 1.6.9(a) what level 1 and its
relationship to level 2 was in this 11 or 12-year period
and in (b) the relationship of levels 1 and 2 to 4, and
the relationship of levels 1 and 2 to 3.
DAME SANDRA: Indeed.
MR BEER: Then over the page, please. The last phase, the
six or seven-year period between 2013 and 2019, in (a)
you tell us about level 1's relationship to 2, the
relationship of 1 and 2 to 3 in (b), and then, over the
page and scroll down, please, level 3's relationship to
level 4?
DAME SANDRA: Indeed.
MR BEER: So what you were trying to do, is this right, is
bring some sense to a changing picture of corporate
structures with either more or less intermediate levels
between level 1 and level 4 across time?
34
across time from the year 2000 on that page, 2001 into
Phase 2, the second period, from the following page, and
so on.
DAME SANDRA: That's correct.
MR BEER: So this is a two-dimensional representation in
tabular format of the concepts that you have isolated,
ie what is the overall corporate structure at four
levels, and how did it change across time?
DAME SANDRA: That's correct.
MR BEER: Thank you very much.
Was there any relevance or significance to these
what might be described as shifting sands of corporate
identity across time?
DAME SANDRA: The relevance for us was that the essential
part of governance is accountability: to whom am
I accountable for what? And therefore, it was very
important to understand that accountability in overall
terms that was based on the corporate structure.
MR BEER: Thank you. Well, that's very valuable work, if
I may say so, and will be of use to the Inquiry in due
course. I am not going to go through the many pages of
the table because we've got --
DAME SANDRA: Thank you.
MR BEER: Can we go back to page 20 in the body of the
report, at 1.6.11, at the top of the page there, you
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The Post Office Horizon IT Inquiry 12 November 2024
summarise this exercise by saying:
“In conclusion, based on the guidance (Annex A)
[which we've looked at in summary to see how it works],
and the information available to the authors as
summarised in Annex B [which we've looked at in
summary], from 2001, one would expect governance
structures in [levels 1 and 2] to be modelled on the
corporate governance of commercial companies with [a]
fully functioning executive and (where applicable) board
structures including NEDs, board committees etc, whilst
also paying regard to aspects derived from their public
‘ownership by government."
DAME SANDRA: That's correct.
MR BEER: Thank you very much.
Sir, we've been going for 1 hour and 15 now, even
despite the break. Might we take the morning break now
until 11.30?
SIR WYN WILLIAMS: Yes, certainly.
MR BEER: Thank you very much.
(11.15 am)
(A short break)
(11.30 am)
SIR WYN WILLIAMS: Just give them a second or two.
MR BEER: Will do, sir.
Can I turn, Dame Sandra, Dr Steward, to Chapter 2 of
37
for one's actions to a third party is a fundamental
aspect of accountability.
MRBEER: Thank you. Then from paragraph 2.2 onwards, that
big bold heading "Board Accountabilities Arising from
the Corporate Code", do you set out, right up until
page 30, the elements of a corporation arising from the
corporate code and describing the accountability
responsibilities of each of them?
DAME SANDRA: Indeed we do and so we begin there with the
board as a whole.
MR BEER: Then if we go over the page, please, at the foot
of the page 22, you deal with board committees.
DAME SANDRA: Indeed.
MR BEER: Then if we go on to page 24, you address the
accountabilities of and to a chair of a board.
DAME SANDRA: Correct.
MR BEER: Then page 27, non-executive directors.
DAME SANDRA: Correct.
MR BEER: Over the page, SIDs or senior independent
directors, then halfway down the page the chief
executive and then to page 29, other executive board
members, the chief finance officer, et cetera, and then
at the foot of the page, the company secretary.
DAME SANDRA: That's correct. And with regard to the other
executive board members, it particularly says, for
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your first report, that starts at page 21. This chapter
runs from pages 21 to 35 of the first report. It's
under the heading of "Accountability"; can you describe
for us in a paragraph or two the purpose and coverage of
this chapter of your report?
DAME SANDRA: Accountability is at the heart of governance.
It explains to whom am I accountable for what?
Governance is about relationships and responsibilities.
So if I am responsible for doing A, who is going to see
that I exercised that responsibility; to whom am
I accountable for doing that?
Accountability is formal obligation: it can be
specified in job descriptions, it can be specified
indeed in the codes of governance. But it's also
informal expectation. Since those to whom I am
accountable or who are accountable to me will be --
understand their accountability by the way in which our
relationship develops.
There is also a voluntary choice exercise which is
that one may emphasise one's accountability, for
example, to the sense of public interest, or one might
emphasise one's accountability for ensuring the
corporate success of the organisation, which is beyond
the formal obligation. And the importance of accepting
responsibility and understanding that one has to account
38
example, because they wouldn't necessarily be on the
board but if they were, as an executive director, this
would be their duties and accountability.
MR BEER: Does it follow that, in the pages we've just
looked at, that is essentially not you speaking, ie the
pair of you speaking: this is you explaining the
elements of the Corporate Code speaking?
DAME SANDRA: This is indeed that basis. We haven't
invented these.
MR BEER: No, exactly. So these are references to the
accountabilities of each of the organisations or things,
or individuals by reference to an instrument, which the
Post Office ought to have abided by or explained why
not.
DAME SANDRA: Yes.
MR BEER: Just one question on the detail of what you have
narrated there then, page 27, under the heading
“Non-Executive Directors", and you divide into (a) and
(b) two groups of NEDs --
DAME SANDRA: Yes.
MR BEER: what you describe as INEDs and NINEDs.
DAME SANDRA: Yes.
MR BEER: I think this is a distinction we may not have come
across in the Inquiry, can you explain please between
INEDs and NINEDs, in simple terms, if you could?
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DAME SANDRA: Yes, INEDs are independent non-executive
directors. They are appointed for the purposes of the
fact that they are independent and they will bring that
independent perspective as well as their specialist,
relevant expertise to the board.
Some non-executive directors, that is they are not
executives responsible for running the company, are not
in fact independent NEDs, INEDs, they are NINEDs, that
is they're non-independent non-executive directors, and
non-independent non-executive directors have already got
some link to the company or the corporation. They can
be nominated by the shareholders because they've got
a special relationship with the shareholders. And, in
the case before the Inquiry, there are examples of the
shareholder appointing non-executive directors, and they
would be NINEDs, or they may have had a previous
executive position in the organisation and they move
from an executive position to a non-executive position
but they're not independent because they're utterly
steeped in the company.
They may, indeed, have been responsible for
developing various aspects of its strategy or operation,
so they cannot be seen to be independent but they are
thought by the board of those companies to have such
special expertise that they wish to retain them as
41
a difference.
MR BEER: Do they fall to be treated any differently by the
balance of the board?
DAME SANDRA: The way any board operates is very much open
to the interpretation within the bounds of the guidance
by the chair and the board collectively. In my personal
experience, occasionally there will be matters where it
is thought that their particular shareholder interest
may make it inappropriate for them to continue with the
discussion, and they may feel a conflict or their
particular position requires them to absent themselves.
or they may indeed be asked to absent themselves.
In my experience, that's comparatively rare, but the
very fact that they have a particular relationship with
the shareholder may mean that there are times when they
are not party to certain board discussions. Apart from
that, they are fully members of the board.
MR BEER: Thank you. Can we go on, please, after checking
that point of detail, to page 30. This is the next big
heading in the report, concerning "The Role of the
Shareholder". Then if we look over the page to
paragraph 2.4, "The Role of the Executive", and then
over the page to paragraph 2.5, "Strategy".
Can I just check the status of those big paragraphs.
That's essentially the pair of you speaking; is that
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a non-executive director.
MR BEER: So within that subcategorisation of NINEDs we're
concerned with the first of them --
DAME SANDRA: We are.
MR BEER: -- as you've explained, namely nomination by
shareholders, in this case the shareholder, the
Government. Did that nomination occur both when ShEx
and then UKGI were the level 3 intermediary?
DAME SANDRA: That is correct.
MR BEER: Are there any different duties that apply to
a non-independent NED as opposed to an independent NED.
DAME SANDRA: All directors of the board are governed by
their individual and collective responsibility as
directors and they share that responsibility as
directors.
Ordinary, one might say, non-executive directors are
there for the reasons given above. Non-independent
non-executive directors are there for the reason of
being a director, but also to keep the shareholder
regularly informed about matters of concern, to keep the
shareholder in touch with what's going on with the
business, to consult with the shareholder on major
decisions, and to ensure a two-way channel of
communication between the board and the shareholder.
They also bring their specialist expertise. So there is
42
right?
DAME SANDRA: With regard to the role of the shareholder and
the role of the executive, is that the question?
MR BEER: Yes, and strategy, as opposed to being drawn from
codes?
DAME SANDRA: Well, the role of shareholder is implicit in
the whole of Corporate Governance Codes and one would
say that's not entirely us speaking because the role of
the shareholder is a driver, as we say, a quiet driver,
of governance to hold the company to account for what
they're doing with their asset. Hence, the reasons that
‘one has annual reports, one has annual general meetings,
and so on, in order to see -- allow the shareholder to
question.
I think that in the mind, for example, of Adrian
Cadbury, going back to the beginning, there was
a feeling that shareholders should be more active in
holding companies to account and so, in many of the
codes and their revisions, the role of the shareholder
is identified as an area of expectation. So the role of
the shareholder is both our view, plus informed by the
way the codes have developed.
MR BEER: Thank you. Can we move on from Chapter 2 to
Chapter 3, which starts at page 36. This addresses
monitoring and audit. Again, can you help us, please,
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by summarising the purpose and coverage of this chapter.
DAME SANDRA: Throughout the development of corporate
governance it's been understood that the way information
is sought about what is going on in the company means
that there should be appropriate means of auditing and
monitoring that activity. And executives are required
to and expected to monitor and report on finance flows
in and out of the company, including verifiable data to
show such things as tax liabilities and payments,
turnover, expenses of profit, so expected to show what
they're doing with the finances.
Executives need to be held to account and these are
the processes by which executives are held to account
for the using of the assets. It then developed in terms
of requirements for boards and executives to assess
risks to the company and risk -- specific relations to
risk arose out of audit and then, as it were, assumed
a role of its own.
MR BEER: Thank you I've got no more questions on Chapter 3,
can we move to Chapter 4 please, page 47, where you
address the topic of risk and, again, can you help us by
summarising the purpose and coverage of that chapter,
which runs up to page 54.
DAME SANDRA: Well, as we indicate there risk is a necessary
part of executive and responsibilities. Historically,
45
therefore, it would have been wise to pay regard to what
the financial services authority was actually saying
about risk but, beyond that, the FSA became a leader for
identifying risk, which then was taken into the
Corporate Governance Code and the FRC, the Financial
Reporting Council, then took up some of those ideas. So
this is relevant both in terms of it being a leader, in
terms of it identifying risk but also bearing in mind
that the Post Office itself was in financial services.
MRBEER: Thank you very much. Can we move to Chapter 5
please, page 55, "Governance and Management of
Technically Complex Major Projects".
I think you explain here, in 5.1.2, that you
classified the introduction of rollout of the Horizon
computer system as such a project?
DAME SANDRA: Indeed.
MRBEER: Can you again help us with a broad description of
the purpose and coverage of this section of your report,
Chapter 5?
DAME SANDRA: We first of all felt that it would be wise to
identify three characteristics of major project
management: uncertainty, complexity and scale, which can
be found in relation to nearly all such projects, and
that, inevitably, there are tensions and trade-offs
which need to be made and one can think simply in terms
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it was really designated as something specifically
identifiable because it was simply seen as a key part of
running the business. One couldn't run the business
without awareness of risk. What has happened in
corporate governance is that the requirement for
executives and the board to look very carefully at the
identification of risks to their business, and the way
in which, once identified, those risks are monitored,
evaluated and proposals for their mitigation has become
an essential part of both governance and management.
MRBEER: Thank you, just one question arising from
Chapter 4, if we can go to page 48, please, at the foot
of the page. The text there in 4.2.9 and 4.2.10 seems
to arise from an FSA statement of 2003, FSA being the
Financial Services Authority.
DAME SANDRA: Yes, yes.
MR BEER: I think that was an agency that regulated
financial services in the UK between 2001 and 2013.
DAME SANDRA: Yes.
MR BEER: It then was split and part of it became the
Financial Conduct Authority, the FCA. To what extent
should a company like the Post Office from, 2003
onwards, have regard to statements like these emanating
from the FSA?
DAME SANDRA: Post Office handled financial services and,
46
of three groups: time, cost and quality, or delivery.
And it is, in our experience, the case that there
are always these trade-offs because there's never enough
resource, there's never enough time, and you always want
a better quality than you're going to get. So that's
an inherent part of, as it were, their management.
Another part of their management is the use of
third-party suppliers, both in assurance and in
provision, and we thought that was relevant. We then go
into the role of the Executive and the role of the Board
in relation to what we see as critical aspects to be
expected of their management.
MR BEER: You divide that up essentially into what you
describe as pre-go ahead --
DAME SANDRA: Yes.
MR BEER: -- and then part of go ahead.
DAME SANDRA: Yes.
MR BEER: Then, once the project is under way?
DAME SANDRA: Indeed.
MR BEER: Thank you. Can we turn to Chapter 6, please,
which is page 63, this relates to "Governance and
Management of Whistleblowing". Although I've no
questions about this, can you explain why you included
a chapter concerning the governance and management of
whistleblowing?
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DAME SANDRA: It's become a fundamentally important part of
governance that boards should make sure that they are
enabling people who wish to speak up, to speak up
without fear of discrimination and to speak up in ways
that will be honest and transparent. And this has been
something which has been significantly developed in
terms of board responsibilities. And we felt that it
was appropriate to look at both the role of the
executive and the role of the board in relation to
whistleblowing, as it is called.
We relate that also to the behaviour and cultural
requirements for effective whistleblowing. This is, for
example, how one handles the communication, how one
looks at the lived experience of whistleblowers and
whether they do in fact enable assumptions about what is
accepted to be challenged.
MR BEER: Thank you. Can we turn to Chapter 7, Stakeholder
Management.
SIR WYN WILLIAMS: Before we do, just as a citizen, the word
“whistleblowing" has come to my notice more recently,
shall we say, than, say, the year 2000.
DAME SANDRA: Oh, indeed, and I think --
SIR WYN WILLIAMS: So in the period we're talking about, has
the whole -- how can I put it? The concept of
whistleblowing seems to me, as a citizen, to have been
49
Public Interest Disclosure Act 1998 amended the
Employment Rights Act 1996, and we can see that from
page 93 of your report. Just scroll down, under
identical sections in 1.0 and 2.0 that, in ‘98, the 1998
Act, introduced a law had protected what you've
described as whistleblowers -- it doesn't use those
words in the Act itself -- from negative treatment or
unfair dismissal.
DAME SANDRA: Yes, correct.
MR BEER: So the protection was there from at least before
the relevant period --
DAME SANDRA: Yeah.
MR BEER: -- that we're considering.
DAME SANDRA: Correct.
MR BEER: But the nomenclature may have changed.
DAME SANDRA: The nomenclature has changed and also the very
specific requirements, for example, on boards to have
a whistleblowing champion, which does come later.
MR BEER: Thank you. If we go back, please, to where we
were, which is Chapter 7 we were about to turn to, which
is page 70. In this chapter you deal with what's
described as "Stakeholder Management”, which again may
be a word or words that didn't exist in the late 1990s.
Can you describe the purpose and coverage of this part
of your report, please?
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developing over this period, can I put it in that way,
so that those responsible in 2000 might not have the
same perception of those responsible now; is that
reasonable?
DAME SANDRA: Sir Wyn, that is exactly the case. As is the
case for quite a number of things that we are looking
at. The concept of speaking up, and the arrangements
for ensuring that those who wish to speak up can do so
freely, has been very significantly developed over this
time.
SIR WYN WILLIAMS: Fine. Thank you.
MR BEER: Albeit, I think, if you look at the foot of
page 63, you note in paragraph 6.2.2 that the concept of
whistleblowing, even though it might not have been
called that, was embedded from at least the mid-1990s in
the Employment Rights Act 1996.
DAME SANDRA: Yes, and I'm very grateful to you for pointing
that out because I was thinking in my mind the Public
Disclosure Act is very important in protecting workers.
So workers that the right from that period. The
response and what was seen to be the responsibilities by
the executive and the board developed later, one might
say. So the right was there; the arrangements were not
always in place.
MR BEER: So, essentially, I think, what happened was the
50
DAME SANDRA: Yes, I think "stakeholders" would have been
very well understood in 1999.
MR BEER: Okay.
DAME SANDRA: These are people, groups of people, who both
believe and also in fact they have a stake or interest
in what the organisation does, how it does it, and what
it may do in the future.
These may be internal stakeholders, employees, or
elected internal representatives, for example in trade
unions; or they may be external stakeholders, customers,
clients, suppliers, distributors. We give a whole list
in 7.1.3.
And the development of governance, that I think was
very clearly there in 1999, is that boards of directors
should, if they are interested, as they should be, in
serving the best interests of their company, must have
an understanding of what these key stakeholder groups
are.
Now, what and who is a key stakeholder group would
be a matter for the board to decide and, sometimes,
their gaze falls perhaps more one stakeholder, rather
than another.
The one stakeholder that definitely has a direct
impact is, of course, the shareholder but we have used
this chapter to talk about stakeholders beyond
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shareholders.
MR BEER: I think you identified in addition to the
Government and its representatives, as owner, as a key
stakeholder --
DAME SANDRA: Yes.
MRBEER: -- Fujitsu as a key supplier -
DAME SANDRA: Yes.
MR BEER: -- and subpostmasters.
DAME SANDRA: Indeed, and we did that because we felt there
were three stakeholders that were perhaps of particular
interest to the Inquiry.
MR BEER: Thank you. Lastly, Chapter 8, which begins on
page 77. This runs from pages 77 to 92, and is headed
"Experiencing Governance and Management". Again, can
you explain the purpose and coverage of this chapter?
DAME SANDRA: Yes, Chapter 8 is different to Chapters 1 to
7, which have been constructed around the scaffolding
provided by Annex A, paying particular attention to
Annex B. In section A we take a different perspective
and we take a different perspective more informed from
our expertise in organisational behaviour than in the
specific requirements of governance, and this is, well,
what is it like to experience governance and management?
And we do there look at authority, power, interest,
interest and conflict together, leadership, culture and
53
to the first drafts of Mrs Wolstenholme's case and the
Simon Clarke Advice case, Dr Steward did the first draft
of those, which we then discussed entirely together, and
I did the first draft of the second case on Second
Sight. I think we're happy to proceed under option C,
which is that you address questions to me but that is
the way in which we have constructed the cases.
MRBEER: Thank you very much.
So can we look at Case Study 1, please. Your
analysis runs between page 42, right up until page 54.
The way that you deal with each of the case studies is
you set out an approach which sometimes involves
a description of the facts. You then break down issues,
or isolate issues that arise in the case study and then
you ask a question at then answer it in a subheading
"Conclusion" under each issue. Have I got that right?
DAME SANDRA: Yes.
MR BEER: Thank you. So if we start, please, with
paragraph 150 on page 43. There's a very nice, pithy
summary in paragraph 150 of the case:
"... Julie Wolstenholme was a subpostmistress who
ran a branch in Cleveleys, Lancashire. The Post Office
pursued her for a £25,000 shortfall in the civil courts.
During her case, a report by Jason Coyne into her system
found Horizon was defective. Her branch had been closed
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communication.
Now, various elements of those are identified in
governance codes, for example culture becomes something
which is very important in governance codes, but we in
this section look at its experience.
MRBEER: Thank you. I have got no more questions on
Report 1. Can we turn to Report 2, please.
You remember the approach that we discussed at the
beginning of your evidence session, namely you
identified three case studies and, through those case
studies, identified nine themes, and in the first part
of this report you addressed the nine themes and then
you turn to the case studies. I'm going to invert that
order, ie consider matters the other way round, by
looking at the case studies first then looking at the
schemes and then, thirdly, by exploring some very
specific topics with you.
So can we turn, please, to Case Study 1, that starts
at page 42.
Out of the pair of you, are either of you more
expert or across the detail of any of the three case
studies?
DAME SANDRA: The way in which we approached these has been
to work entirely together. We've discussed everything,
we have come to our conclusions together. With regard
54
down but she pursued the Post Office for £180k."
DAME SANDRA: Correct.
MRBEER: Then paragraphs 155, starting on page 44, right
through to 160 on 45. They set out, do they, your
references to some of the underlying material that you
have considered in formulating a view on this case?
DAME SANDRA: That is correct.
MR BEER: Then if we move to 161 on page 45, we set out your
conclusions.
DAME SANDRA: Indeed.
MR BEER: I'm going to take these in some detail in relation
to each of the cases.
You say, in your view the Royal Mail Group General
Counsel and the Post Office Chief Executive Officer must
have understood from the exchange about
Mrs Wolstenholme's case that the Horizon system posed
a risk to the validity of subpostmaster branches and
therefore the safety of prosecutions on Horizon data,
yet they did not act.
Do I take correctly from that that that you have
sought to draw a wider conclusion arising from the facts
in Mrs Wolstenholme's case about the impact that it
‘ought to have had on criminal proceedings, even though
this was a civil case?
25 DAME SANDRA: That is correct, since the problems identified
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with Horizon were being used in prosecutions and,
therefore, that understanding should have been seen to
be relevant.
MR BEER: In the spectrum of failures or criticisms, how
serious a failure is this?
DAME SANDRA: It's a failure to connect what was going on in
the civil proceedings with read across to prosecutions,
and it was a failure to understand that here was
material which suggested that Horizon was not bug free,
which could impact the use of that Horizon data in both
civil and prosecution cases. The connections weren't
made and action wasn't taken. So, in this specific
thing, one would have expected that the connection to
have been made.
MR BEER: In 162, you tell us that:
"The Chief Executive Officer should have talked
immediately to the Chief Operating Officer and the IT
Director about the concerns brought into sharp focus by
the risk of £1 million that was sitting on the risk
register. Had he [that's the CEO] talked to the Chief
Operating Officer in May [I think that's 2004] about the
tisk, it's likely that when the Chief Operating Officer
was asked to sign off the significant settlement to
Mrs Wolstenholme in July 2004, he would have brought
this to the attention of the CEO, something which he
57
evidence of Sir Michael Hodgkinson but I think it's your
view that it ought to have been.
DAME SANDRA: Indeed it is.
MR BEER: That was a failure, have I got this right, of the
Executive to do so?
DAME SANDRA: Yes, to escalate.
MR BEER: Yes.
You tell us in 165 that the independent expert
evidence relating to the civil case against
Mrs Wolstenholme, ie Jason Coyne's report, should have
been brought to the attention of the Chief Operating
Officer when asked to approve the settlement, if he
hadn't asked for it, and it should have been discussed
at a Board Risk Committee.
DAME SANDRA: Correct.
MR BEER: These 'should haves’, are they formulated on the
basis of the reasonably expected principles of good
governance that you've identified in Report 1?
DAME SANDRA: They are, and they are also based, as we have
said, on our experience. But they are based in the
expectations that we've laid out in Report 1.
MR BEER: You say that both the £1 million risk on the
register and Jason Coyne's report should have been
escalated to the Chair, and that, if he had known about
these matters, he should have escalated to the Group
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should have done anyway."
DAME SANDRA: That's correct. He should have done it
anyway, but the very fact that there was this prior
knowledge should have alerted him to bring it into the
executive discussion.
MRBEER: Over the page, please, to paragraph 163. You say
that it seemed to the pair of you that ExCo: who were
you referring to as ExCo there? Not by name, but by
description.
DAME SANDRA: No, that is the senior leadership team that
the chief executive or managing director chooses to have
as their most senior team.
MR BEER: "[They] did not pool their piecemeal knowledge of
emergent issues and so opportunities to share and create
a collective understanding of the risks were lost."
What risks were you referring to there?
DAME SANDRA: We were referring to the risk that the use of
Horizon data in civil and prosecution cases posed risks
for the Post Office Business.
MR BEER: You tell us in --
DAME SANDRA: (To Dr Steward) Do you want to add anything to
that?
DR STEWARD: No.
MR BEER: You tell us in paragraph 164 that this was not
escalated to the Post Office Board, according to the
58
Chair or to the Royal Mail Group Chief Executive
Officer, and that, so far as you were aware, none of
them were told about the case or its settlement.
DAME SANDRA: That was our belief.
MR BEER: In 168 you described the questions that might have
arisen and, over to 169, you say you've looked at the
board minutes and meetings of the Post Office Limited
Board.
DAME SANDRA: Yes.
MR BEER: "... there was always a majority of Executives
over Non-Executives. Although there was movement to
a point Independent NEDs they were out numbered by
Executives and therefore a relatively weak base for
independent challenge by way of viewing the business."
Is this a linked point or is this is an independent
point concerning the Wolstenholme case?
DAME SANDRA: I think it's both linked and independent.
It's linked because the lack of scrutiny which we have
identified, one might have expected to have been greater
if there were more NEDs available. The fact that there
weren't NEDs available was not a failure of governance
because they weren't required at the time for this
subsidiary organisation, which was subsidiary to Royal
Mail Holdings. So there wasn't a deficit in governance
terms that there were no NEDs but there was a practical
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result of there being few NEDs, that there was less
challenge being made. I'm not sure if that answers your
question of whether it was linked or separate.
MR BEER: It does, thank you.
DAME SANDRA: Thank you.
MR BEER: In paragraphs 170 and 171, you tell us about what
the Post Office Board's focus was at this time.
DAME SANDRA: Yes.
MR BEER: Do I understand you to say that, in these
paragraphs, it was because of the focus that this may
have been missed, or you simply don't know?
DAME SANDRA: We're pointing out that that these matters did
not get an airing and we are also pointing out that
there was a strong emphasis upon survival, on new
products and growth, and that, it seems to us, led other
matters which could be seen to be operational as not
being the subject of interrogation at the Board.
MR BEER: So! think you come to a conclusion at 172 in the
first sentence:
"... if the Chief Executive Officer had acted
differently then a collective understanding within the
Post Office Executive could have been developed.”
Then the following things that you identify you
think ought reasonably to have followed?
DAME SANDRA: Indeed. And we also identify that these risks
61
civil cases were taken actually lay formally with Royal
Mail Group.
Nonetheless, Post Office understood that they
were -- they had some responsibility because it was
conducted in their name. But, nonetheless, Royal Mail,
as the parent holding company, was the overall group
responsible for prosecutions and civil cases, and their
General Counsel -- the Post Office didn't have a General
Counsel at that time, it was the RMG General Counsel who
was, as it were, responsible here.
MR BEER: Thank you. Can we turn to your conclusions on
this issue, which are on page 50.
You say:
"The way in which Post Office related to RMG added
to a situation in which matters concerned with
prosecutions went without challenge at the Post Office
Board. By the time Sir Michael Hodgkinson, the Chair,
left in 2007, ownership for reporting to the Post Office
Board on prosecutions was not established and processes
for monitoring (Horizon risks, prosecutions policies and
practice, whistleblowing, subpostmaster feedback) do not
appear to us have been in place.
"The Board of Royal Mail Group paid little attention
to Post Office Business operations, even though their
group functions, for example, Legal and HR, were
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could have been made explicit in a whole different way
of -- a whole variety of ways. It could have been the
one-to-one conversation; it could have been the Board
risk register. It could have been the Risk and
Compliance Committee. It could have been discussed with
the Chair, the truth is that it did not feature in any
of these forum.
MR BEER: That's issue 1 under Wolstenholme: what in
particular should the CEO have done when receiving the
email relating to Mrs Wolstenholme.
You then turn, if you go to page 48, to the second
issue you isolate as arising of the Wolstenholme case,
namely the relationship between the Post Office as
subsidiary and the Royal Mail Group as a parent holding
company.
Can you help us: why did you address this issue in
relation to the Wolstenholme case?
DAME SANDRA: Because we were making the relationship
earlier between what was going on in the civil cases and
what was going on in the criminal cases. And the legal
function for the Post Office was not independent. It
was a centrally held function by Royal Mail Group -- or
however it was addressed at that point, I mean in terms
of its name. And, therefore, the responsibility for
interrogating the way in which prosecutions and indeed
62
responsible for functional management in some areas of
[Post Office].
"The [Post Office] Chair should have been told of
the IT risk facing [Post Office] of £1 million. This
risk ... should also have been escalated to the RMG
Board directly or via the Risk and Audit Committee. The
link between Horizon risk and prosecutions is very clear
in the Wolstenholme case, even though not a criminal
case because of the Coyne review. This link should have
been discussed by both the POL Executive and the Board
and should have raised enough concerns about the
inherent risks in concerning prosecutions based on
Horizon data to warrant discussion between the [Post
Office] Chair and the Royal Mail Group Board directly or
via the Royal Mail Group CEO."
Those are your conclusions on issue 2.
Collectively, how serious a failing are you describing
here?
DAME SANDRA: I think it is a failure of accountability
because there is no doubt, as far as we can see, that
RMG had this overall responsibility and therefore they
should have ensured that what was going on in POL
enabled that to be -- that responsibility to be secured.
It was in a way their choice: they had a central
function, they could have said to POL, "Down to you, you
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make sure that you are monitoring these risks, that
you're understanding them, and so on, because we want
you as a subsidiary to do that".
It seems to us had that was not done. That doesn't
excuse the POL Board and Executive from not picking them
up, but one might think that they would have thought,
“Well, this function doesn't lie with us; it lies up
there".
So with regard to how serious, it is a serious
failure to understand the responsibilities of a holding
company, the responsibilities of the subsidiary company
and, above all, for those two to sort out appropriate
arrangements for risk and for monitoring.
MR BEER: You mention in that last answer that it doesn't
absolve the Post Office Board of responsibility, the
failures you described. You turn to that in issue 3.
Can we turn to that, it's page 51.
This is the third of three issues you identify in
the Wolstenholme case. You tell us in paragraph 187:
"The Board and Executive should understand their
role in creating culture in the business and in the
boardroom. This includes challenge, curiosity and
looking for ‘the bigger picture'.”
188:
"The Board at the time of Mrs Wolstenholme's case
65
that?
DR STEWARD: I mean, we heard numerous times during the
testimony that people weren't aware that POL -- that RMG
did prosecutions. So I think that's the basis of the
finding that it was deep in the culture, that POL
wasn't, if you like -- had a clear sense of ownership,
if you like, over the prosecutions.
MR BEER: It was just something that happened?
DAME SANDRA: Exactly.
DR STEWARD: It appears to be something that happened.
MR BEER: In 194, I'd like you, if you could, to explain the
first sentence that "Post Office Executives failed to
conceptualise the operational problem of faults in
Horizon as a risk factor"
What do you mean, “failed to conceptualise"?
DAME SANDRA: Well, they didn't imagine it, they didn't
think about it. They thought they were dealing with
a technology system, and were there problems -- as far
as we could tell -- and were there problems with that
technology system? That relationship to what was going
on in the routine business of prosecutions defending
public money was not connected.
MR BEER: I see, so meaning they failed properly even to
think about it?
DAME SANDRA: Yes, they failed to conceptualise; they failed
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was not a full Board", for reasons you had identified,
ie because the absence of a strong non-executive
presence.
DAME SANDRA: Mm, mm.
MR BEER: Then if we go over the page, please, to 193, you
set out your conclusions between paragraphs 193 and 196,
in relation to the POL Board culture when addressing the
Wolstenholme case. You say:
"There was a lack of focus on prosecutions at the
Post Office Board, which was in [your] view a reflection
of the embedded [Post Office] culture."
Can you tell us what the foundation for that is,
please?
DAME SANDRA: It is from both transcripts and witness
statements that we have read, which talk about the fact
that prosecutions was seen as something that the Post
Office did. It didn't feature, for example, in the
induction to new Board members; it was not -- it was
seen to be non-problematic and, indeed, a very important
part of the Post Office defending its public duty and
its public right to defend Post Office monies, which
were the public's monies. So there was an embedded view
that it was an accepted part and it appears to us to
have been accepted that it was done in a due process.
(To Dr Steward): Would you like to add anything to
66
to think about it.
DR STEWARD: If! might, I mean, the way I see that is that
there were, in the Executive Team, at least four
functions who were aware of or could have been aware of
the Coyne Report: finance function; the IT, it was on
the IT risk register; the operator -- Chief Operating
Officer; the Chief Executive. And had, at that point,
there been a conversation between those four functional
leads about "What do you know about the Coyne Report?
What's this telling us? Is this telling us that we have
an issue with technology or is this telling us that we
have an issue with prosecutions?", then you can see how
that conversation would have developed into a broader
conceptualisation of the role that POL had in conducting
prosecutions and the technology is that -- being at the
heart of that.
MR BEER: Thank you.
Paragraph 195 you say:
it [I think they're the failures you mentioned
in the previous paragraphs] was exacerbated by a lack of
challenge to the Post Office Executive. The governance
of Post Office was in embryonic form ...’
Can you explain what you mean by that and why you
say it?
DAME SANDRA: In embryonic form, we mean that there were --
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The Post Office Horizon IT Inquiry
as we've seen, there was the Non-Executive Chair and
there was the first Non-Executive, by this time,
appointed, they were getting their feet under the table
understanding Post Office Business and they did not
challenge what was accepted, taken for granted and they
didn't say, "Well, what's the real problem beneath this
information we're getting about Horizon? Does it have
implications outside the civil context?", because this
of course was a civil case, such as for prosecutions.
Now, one might say well how could they do that if
they weren't told about it? And that is a recurring
theme, we've found, in the cases that we've looked at.
Nonetheless, the POL -- the Post Office Chief Executive
was a member of the Board the Post Office Chief
Executive did have a relationship with the independent,
the Non-Executive Chair, and the -- it could have been
challenged, and it wasn't.
MR BEER: Can I ask you, Dame Sandra, just to move the
microphone. As you've moved to the screen, you've moved
away from the microphone --
DAME SANDRA: Ab, right.
MR BEER: -- and, as you've warmed to your theme, you've
sped up alittle bit. If you could slow down your
answers, we would be grateful. That's my fault for not
properly controlling your evidence.
69
we see as being germane to the interests of the Inquiry.
Many of these matters are individual issues -- not
issues, individual events, which, if you add them all
up, you would say that's a failure to know something to
connect with something that we already know, and for us
to take a view on. This is one such matter.
If it was alone, then the governance system, one
could say, was quite robust, but because this, as we
will see in relation to other things, this neglect of
seeing the risk inherent in prosecutions in relation to
Horizon, this is part of what we see to be a general
failure.
MR BEER: You set out your overall conclusions on the
Wolstenholme case study in paragraphs 198 to 205. Here,
are you essentially drawing the threads together in
relation to the Wolstenholme case?
DAME SANDRA: We are trying to do so.
MRBEER: Thank you. Could you talk us through, then, your
views when drawing the threads together in the
Wolstenholme case?
DAME SANDRA: Yes. Firstly, that POL prosecutions, policies
and practices didn't have priority for either the RMG or
for POL. Furthermore, there is a lack of clarity about
if they had looked at it, who was really responsible.
So we think neither of them gave it priority, and that
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In paragraph 195, you set out some questions at the
end of the paragraph, as to questions that might have
been asked and you identify in paragraph 196 that,
although Royal Mail Group acted as a challenge to the
Post Office in some areas, prosecutions was not one of
them?
DAME SANDRA: Correct.
MR BEER: Looking at this issue, the third issue, the
culture of the Board and the failure properly to
challenge by the Group, how serious are the series of
failings that you identify here?
DAME SANDRA: I'm sorry, can you repeat?
MR BEER: Yes, looking at paragraphs 193 to 196, in the
scheme of things, in the spectrum of seriousness of
failings, where does this sit? I realise I'm asking you
‘on every occasion to pitch on a spectrum --
DAME SANDRA: Yes.
MR BEER: -- and that's because you don't do so in the
report.
DAME SANDRA: No.
MR BEER: That may be because you're unwilling to do so, but
I'm asking nonetheless.
DAME SANDRA: We're willing to help the Inquiry in any way
we can. We haven't come here with a sort of measure of
failure. What we've done is identified failures which
70
the lack of clarity probably exacerbated this matter,
the lack of clarity on who had oversight of
prosecutions.
The POL Board was largely made up of executives, as
we've talked about. There was little independent
challenge. It's not unusual for there to be little
independent challenge at subsidiary boards because it
puts then greater responsibility on the holding company
to challenge. But that would have required, if! can
elaborate on this, as I said earlier, that would have
required there to be a clear agreement about, well, with
regard to POL -- Post Office prosecutions, who is really
going to monitor and oversee this? And there wasn't
that clarity.
The Coyne Report, an independent specialist, was
neglected but, what's more, we haven't seen any evidence
that there were independent specialists to advise the
Post Office Board on key areas of technology and legal.
That was especially important because of the lack of
independent challenge and advice one might get from
non-executives.
We then go on in 201, the risk wasn't elevated, as
we've already talked about, and it should have been.
There was a lack of focus on -- prosecutions on the POL
Board and the whole risk system seems to us to have
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lacked a coherent framework for risk identification,
evaluation and escalation, particularly in the
connections that could be made between Horizon and
prosecutions.
MR BEER: Just stopping there on that, the sentence or the
part of the sentence which says, "the whole risk system
seems to have lacked a coherent framework for risk
identification, evaluation and escalation", that's in
a sentence, which you've just spoken about. You said in
particular in relation to prosecutions. Does that
conclusion apply more generally?
DAME SANDRA: We have looked particularly at the aspect of
prosecutions and Horizon, and we haven't looked at risk
identification in relation to other areas. I think
I"m
DR STEWARD: Not specifically.
DAME SANDRA: Not specifically.
MR BEER: No, there could be all sorts of other things
like -
DAME SANDRA: There could be --
MR BEER: -- manual --
DAME SANDRA: Insolvency.
MR BEER: Insolvency or manual handling by employees --
DAME SANDRA: There could have been.
MR BEER: -- or injury to members of staff on duty, or that
73
and manage these risks; is that right?
DAME SANDRA: Indeed.
MR BEER: Because it was the parent holding company that, in
fact, functionally had carried out the conduct of
prosecutions?
DAME SANDRA: Yes, and had they wanted it to be held at the
level of the Post Office, that should have -- that could
have happened and it could have been clear in delegated
duties that that was the case. But that did not, as far
as we know, happen.
MR BEER: Overall, how significant was the relatively early
episode of the Wolstenholme case being in 2004 to the
issues which you examined?
A. I think it was -- it's significant, in retrospect, as we
look at it, because it seems to be that this pattern is
repeated. At the time, I would say it showed, with
regard to prosecutions, that we had an Executive Team
and a Board that were not paying attention to the risks
posed in prosecutions, dependent upon Horizon data, and
that is a neglected risk throughout the story of this is
Inquiry.
MRBEER: Thank you. Can we turn to the second case study,
then, please, which is the Second Sight Interim Report
and the consideration of it by the Post Office Board in
July 2013. That starts, thank you very much, on
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kind of thing?
DAME SANDRA: Yes.
MR BEER: This is particularly in relation to the conduct of
prosecutions?
DAME SANDRA: Yes, and I guess that relates to the opening
of that sentence: there was a lack of focus at the POL
Board, so lack of focus on prosecutions.
MR BEER: Thank you very much, then over the page, please,
you tell us about a missed opportunity about by both the
Executive and the Board in 203.
DAME SANDRA: I think this is exactly the point you were
making earlier. Do you want to add anything to it?
DR STEWARD: I think we've made the point that actually
there was an initial moment when things could have
turned out very differently, perhaps, had the
conversation happened in the Executive Team, had that
then been elevated to the Board, had that then been
discussed with the Chair, had the Chair then discussed
it with RMG or the routes through to the RMG, Audit and
Risk, used.
MRBEER: Thank you. Then skipping to paragraph 205, you
set out your views on the attribution of responsibility,
and, really, it's a two-pronged conclusion --
DAME SANDRA: Yes.
MR BEER: -- that it's the responsibility of RMG to identify
74
page 55. This is a much longer analysis; it runs right
through until page 108 of your report.
DAME SANDRA: Yes.
MR BEER: Can we read, please, paragraphs 212 to 214, on
pages 56 and 57, which are essentially a short summary
of the episode. You call it a context of the case but
it is a good primer.
DAME SANDRA: Yes.
MR BEER: "Second Sight was appointed by Post Office in
mid-2012 to carry out a review into the alleged problems
with the Horizon IT system. The Inquiry has heard that
the appointment was in part a response to increasing
pressure from James Arbuthnot and other MPs, persistent
critical questions from investigative journalists and
ministerial interest. The appointment of Second Sight
was handled by the Post Office Executive with very
little Board involvement, apart from that of the Chair.
The Inquiry has heard that the terms of reference were
subject to several iterations between the parties and
‘no formal letter of engagement’ was ever signed.
"Second Sight summarised their appointment as
follows", and you set that out.
Then 214:
"The Board met via conference call on 1 July and
received their first, very brief account of the work
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from the Post Office Chief Executive Officer. They were
told of the imminent publication of the Second Sight
Report. The report was published on 8 July when it was
made available to the Board. The Board received
an update paper in the light of the report at their
meeting on 16 July.”
Were you essentially, therefore, considering the
period up until but not after 16 July?
DAME SANDRA: That was our focus. Our focus was very much
on the preparation for publication, the publication of
Second Sight, and its consideration at that Board. As
we'll see, there were a few matters that we felt we
should extend our concerns with but, in the main, that
was it. It's a case of the Board's handling of the
Interim Report of Second Sight, at that time.
MR BEER: If we could look at the top of page 56, please.
I think, if we just pan out a little bit on the screen,
to the top half of the page, thank you, we can see that
you isolated nine issues arising from this episode; is
that right?
DAME SANDRA: That's correct.
MR BEER: They're listed there as issues 1 to 9.
DAME SANDRA: That's correct.
MR BEER: What I'd like to do, if I may, is go to the
conclusions which you reach in relation to each of the
77
was falling on securing Government agreement for ongoing
funding, it was securing on -- it was focused on getting
Government support for the strategic plan, which was
connected to funding. It was helping RMG prepare for
privatisation, and it was continuing to create the Post
Office, an independent business, separate from RMG, in
which they had to build their own standalone governance
structures and central functions. All good priorities.
But, at the same time, there was the, as we've
indicated, media, ministerial, Parliamentary interest
and identity of what, on the face of it, appeared to be
serious problems in the use of Horizon data in
prosecutions. This, as far as we could see, was not
a priority for the Board at all.
MR BEER: Issue 2, please, over the page at the top.
Perceptions of the Horizon IT system, Second Sight and
post Office Prosecution Policy and practices and of
subpostmasters. Can we look at your conclusion, please,
on that issue, at page 65, paragraph 238 onwards. You
tell us in 238 -- it goes right up to 242 -- that:
"The dependence of prosecutions on Horizon data was
not articulated as a concern by either the Executive or
the Board as they approached the discussions of the
report on 16 July. So taken were the Executive with
their sense of mission, their distrust of Second Sight,
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nine issues, rather than examining the run-up to those
conclusions in each case.
DAME SANDRA: Absolutely.
MR BEER: So in relation to issue 1, can we look, please, at
page 58, paragraph 217. It should identify what issue
‘one was, just look at page 57, please, at the foot of
the page. Issue 1, the priorities of the Board in July
2013. Then if we go forwards, please, to paragraph 217
‘on page 58, you say:
".., the findings of the report contain sufficient
information to warrant the Board giving priority to
getting a stronger grip on Post Office's investigations
and prosecutions policy and practice, particularly, but
not solely, when Horizon data was used. The Board
should also have been paying attention to what they were
being told by Second Sight about Post Office's attitudes
and approach to subpostmasters, particularly as it had
resonance with what was becoming a familiar refrain from
investigative journalists and MPs. [You] had not seen
evidence that either the Executive or the Board saw
those issues as priorities
So can you expand upon or explain the conclusion
that you reached there? This is about prioritisation.
DAME SANDRA: It's about, yes, where the gaze of the Board
was falling. It was falling on brand and reputation, it
78
they did not take the advantage of handling
an ‘independent' reviewer in their midst, who was
offering various bits of evidence which could have
shaken their firmly held perceptions. Not surprisingly
then, they did nothing to alert the Board that serious
issues were being raised in the Second Sight Report."
I'll ask the question that I've asked number of
times: in the spectrum of importance or significance,
where does this sit?
DAME SANDRA: I think it's a serious failing. Here was
an independent reviewer that they had deliberately
brought in, and yet they were approaching it from
a position of fairly fixed views that Horizon was
robust; that they -- they formed the view that Second
Sight weren't really independent and were partisan; they
had fixed views about subpostmasters; and they had fixed
views about the importance of their prosecutions which
they thought were being conducted, one assumes,
appropriately.
This meant that when these bits of information came
in from the Second Sight review and, as we'll see later,
they don't come in in a sort of well capsulated way but
they come in, nonetheless, but they simply aren't
identified.
MR BEER: Do you expand upon that in 239? I think you
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largely covered that in your previous answer.
DAME SANDRA: Yes.
MR BEER: In 240 you explain that there was no challenge in
July 2013 to the accepted view that any problems with
the operations of Horizon lay with the people rather
than the technology?
DAME SANDRA: Yes, correct.
MR BEER: Could you ascertain why that was, ie there was no
challenge?
DAME SANDRA: What was the first part of your question?
Could we --
MR BEER: You say there wasn't a challenge to the accepted
view --
DAME SANDRA: Yes.
MR BEER: -- yet here was a report that arrived that did
challenge it -
DAME SANDRA: Yes.
MR BEER: -- why was there no escalation by the Executive or
mere acceptance by the Board of the Executive's
perceptions?
DAME SANDRA: I think that's a $50,000 question. Why was
there no challenge? There was no challenge and we in
this part tie it to the fact that they were
concentrating on and looking at things in a way that
made them blind to the pieces of information that were
81
to the Executive.
DAME SANDRA: Mm.
MR BEER: Is that seen by the Board as operational matters?
DAME SANDRA: It is, and probably by the Executive too, and
perhaps this is relevant to make the general point that,
in Governance Codes, inspected understandings of
Government, the role of the executive is to run the
company: if they're a building company, to do the
building; if they're -- and to ensure safety
precautions -- if they're a financial services company,
to offer financial services. They run the company and,
in operational matters, to do with running the company,
are the executive responsibility.
The board has a responsibility to oversee those
operational matters, to ensure that they are being
appropriately undertaken but, if you assume that they
are -- everything is going fine, then it would be
inappropriate for the board to enquire into operations.
I don't know if you'd like me to go on to
circumstances, it might come later, where the board
would be expected to delve into those operational
matters. But I guess what I'm saying is, if I'm sitting
at a boardroom and I'm a non-executive director and
I regard a particular aspect of the company's
operations, in this case prosecuting -- investigating
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coming forward.
MR BEER: Is that the basis on which you form the conclusion
at 241, the last sentence, that the Board did nothing to
provide a corrective challenge to the Executive's
defensive position?
DAME SANDRA: Yes, I see we did encapsulate what I was
trying to say, that --
MR BEER: In 241?
DAME SANDRA: _-- the belief of Horizon was robust, Second
Sight's independence was questionable, policies and
practices of investigations and prosecutions didn't
warrant urgent investigations and a tiny minority of
subpostmasters, as before the introduction, were guilty
of misappropriating public funds. The Board, as we
shall see, many of them did not appear to appreciate how
the Post Office was approaching investigations and
prosecutions and, although they asked questions when
pieces of Private Eye came out, or so on, when told that
"There's nothing in this, Horizon is robust", they did
nothing further to question. And I think we go on later
to show how they might have questioned it.
MR BEER: Thank you.
Lastly on this issue, paragraph 242, you make the
point that the Horizon System and Post Office
prosecutions were seen as operational matters to be left
82
and prosecuting subpostmasters, if I regard that as
a matter that's always been done, that's part of regular
operations, that doesn't excite any particular mention,
then its legitimate for me, as a board, to leave the
executive to run that.
MR BEER: You say the irony is that what was seen by the
NEDs as operational matters were, in fact, the basis of
existential risk.
DAME SANDRA: Yes.
MR BEER: When you say "irony", what do you mean?
DAME SANDRA: I mean that they got it wrong, that they saw
that it's operational and, therefore, nothing to do with
them, but in fact it contained existential risk to the
company and therefore -- and, I'm told, suffering to
subpostmasters -- and, therefore, if only they had said,
“Perhaps these aren't regular operational matters,
perhaps we should have enquired into that", they would
have revealed the extent of the risk that was there.
MR BEER: You say that "more such curiosity and challenge
may have dislodged the blindfold". Who was wearing the
metaphoric blindfold?
DAME SANDRA: I think both the Executive and the Board were
wearing a blindfold --
MR BEER: Thank you.
DAME SANDRA: -- and that blindfold we relate here to the
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perceptions we have just identified.
MR BEER: Thank you.
Sir, that's a convenient moment. May we break now
until 1.45.
SIR WYN WILLIAMS: Yes, 1.45.
(12.45 pm)
(The Short Adjournment)
(1.45 pm)
MR BEER: Good afternoon, sir.
Good afternoon, Dame Sandra and Dr Steward.
We were in the middle of Case Study 2, we had dealt
with two issues and we were turning to the third issue
you had identified. Can we turn up in the second
report, please, page 70. Here you express your
conclusions on the third issue, which is the roles of
the Chief Executive Officer and her Executive
colleagues, and between paragraphs 262 and 271, you set
‘out your conclusions on this issue.
You make the point that how a CEO leads his or her
team is not an exact science. Do you mean that, within
the Governance Codes and other similar instruments,
there is a reasonable body of divergence in how you
discharge the obligations?
DAME SANDRA: I believe that the principles are set at such
a high level that how one fulfils those principles ~
85
her Executive Team, so that she would have been well
aware of the significant views and actions of each of
her Executive Directors, so she could bring all
significant relevant information into her decisions.
Can you assist us with what you're referring to
there?
DAME SANDRA: I'm referring to the fact that, as Chief
Executive, she naturally delegates and expects her
different Executive Directors, her members of her top
team, to be more in touch with details of their
particular areas than she is but, nonetheless, we would
expect that the way in which she operated that team,
that if there were significant areas identified within
individual Executive Directors’ areas, that they would
be brought to her attention.
MR BEER: You say that, in dealing with the report, in
paragraph 264, she and some of her Executive colleagues,
appear to be disproportionately focused on
communications and public relations. That whilst
messaging and communication are vital parts of executive
responsibility, the executive responsibilities in
matters covered by the report extend to many areas;
including or especially technology, business operations,
prosecutions and the law. What led you to the
conclusion that she and some to her colleagues appeared
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I don't mean a high level in terms of height of
standard; I mean in terms of generality, such a level of
generality, that it's possible to be an effective chief
executive and adopt different styles.
MR BEER: You go on to explain -- and remembering this is in
connection with the treatment and administration and
response to the Second Sight Report -- you would have
expected the Chief Executive, that's Paula Vennells, to
be well aware of all issues which were covered in the
report, insofar as they significantly impact Post
Office.
By that, do you mean you would have expected her to
have been well aware of issues before receipt of the
report, or upon receipt of the report?
DAME SANDRA: That we would expect her to be aware of the
issues of which she was aware before receiving the
report but, upon receiving the report, we would have
expected her to be aware of those issues that were
within the report.
MR BEER: Okay, so she should have been across the detail of
the report upon receipt?
DAME SANDRA: Across the particular aspects which we pick
out in the report, which we see to have been
significant.
MR BEER: You say you would have expected her to be leading
86
to be disproportionately focused on public relations and
communications?
DAME SANDRA: Because from the evidence that we saw, there
was a great deal of communication about how the
positioning of the publication of the Second Sight
Interim Report should be put, how communication should
go to James Arbuthnot and other MPs and what the media
statement would say. Looking beneath what the Second
Sight Interim Report said, where, as we shall see, they
identified a number of issues to do with Horizon, to do
with prosecutions, to do with the impact of current
processes on subpostmasters, that they didn't seem so
concerned with those things.
MR BEER: Do you accept that a board owes a fiduciary
obligation to protect a company's reputation?
DAME SANDRA: Do I accept that the board has that
responsibility?
MR BEER: Yeah, fiduciary --
DAME SANDRA: Yes.
MR BEER: Do you accept that a general counsel has
a fiduciary obligation to protect a company's
reputation?
DAME SANDRA: Well, a general counsel has many different
roles. Would you like me to expand upon that? The
general counsel has a role as an independent adviser to
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the board, to bring her expertise to the board and to
the company on a legal basis.
If the general counsel is a director of the company,
then she or he also has duties as a director, which, as
we covered earlier, relate to director's duties. If --
that's the second role she may have, although in
relation to the Post Office the general counsel didn't
have that role.
If she also has functional responsibilities for
areas of work, for example the legal area of work, or
the risk area of work, or aspects of the operations area
of work, for example, security, she also has duties in
relation to her functional leadership. This means that
she can be both a member of the executive team and
an independent adviser, and general counsels are often
put in the position of holding those dual roles.
MR BEER: If it is the case that members of the Board, and
they say this, received assurances from within the
business that Horizon was a robust system, and that any
and all allegations about it were unfounded, would it be
appropriate or inappropriate for a Board to respond to
those allegations in a way that sought to protect the
company's reputation?
DAME SANDRA: One would expect the Board to enquire into any
matters which suggested that the assurances that they
89
we've got to do with regard to training and support, and
we'll do them". But what was really understood about
the nature of the technology? What was really
understood about the meaning of bugs and defects? What
was really understood about the experiences of
subpostmasters, as related in the Second Sight Interim
Report?
We were looking for a broader sense of contribution
from the Executive Team into the meaning behind the
Second Sight Interim Report.
MR BEER: You say in the fifth line:
“It is as if specialist functions are in different
‘black boxes’ which non-experts cannot assess and do not
feature as part of their shared executive
responsibility"?
You cross reference to some sections of Ms Vennells'
oral evidence where she says she's not an expert in this
or an expert in that. Then, over the page to
paragraph 266, you say that she appears to have left the
preparation of the Horizon Update paper to the General
Counsel, Susan Crichton:
"The Inquiry heard that [Ms Crichton] discussed
a draft with the Company Secretary and made amendments
... for example to refer to ‘defects rather than bugs’
... [You] do not know if the CEO and General Counsel
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had been given were not as foolproof as they had been
led to believe. And, if we look at the particular
instance of the Second Sight Interim Report, whilst
there was the general conclusion of no systemic problems
so far discovered, there was discovery of
bugs/anomalies, whatever one wishes to call, and
therefore that might have been a basis for saying,
"Well, given that we've been told on the one hand it's
robust, and yet, given on the other hand we've been told
that there are bugs and defects, should we not think
about what is the connection between those two pieces of
information, and should we not then enquire further into
what it means that this is robust?”
MR BEER: Thank you, at 265 you say you haven't seen
evidence that the CEO, Paula Vennells:
"... ensured broad collective executive discussions
about the findings of [the report] which included
contributions from, or challenges to, all functions and
aspects of the business."
Can you explain what you mean by what you were
looking for in the evidence there?
DAME SANDRA: We were looking for something more than what
are the top-level messages we can give, namely the
top-level messages were "Horizon is robust, there's no
systemic problems with it, there are a number of things
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discussed the contents of the paper ... [We] heard that
the CEO felt uncomfortable and ill equipped when she was
suddenly required to present the paper at the Board
meeting", which to you suggested:
"... an Executive Team which is fragmented where
a sense of shared collective responsibility for all
aspects of the business is feint; a mindset which has
grown within an organisation where functional silos,
certainly in Legal and IT, extend from the top to the
bottom."
Can you expand in any way on conclusions which you
drew there?
DAME SANDRA: I think we then have to look at the role of
the chief executive. The chief executive cannot be
an expert in all matters of running the business.
That's very, very well understood, which is why the
chief executive needs to delegate to a number of her
executive team specialist responsibility. But that very
action of delegation does not absolve the chief
executive from seeking to understand the whole picture.
So whilst there is delegation, there is also
inclusion of bringing these matters up into the chief
executive's mind so that she is sufficiently aware of
all the aspects which impact the consideration of any
particular issue.
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So that's the chief executive role. The chief
executive's role is also to ensure that the -- her
executive directors, to which she delegates -- imagine
them all in their little functional boxes -- that they
not only communicate upwards and downwards to her, but
she ensures that they communicate across each other and
that they bring to bear areas of their specialist
expertise, to their collective understanding.
And that's what we did not see evidence of. Of
course, we're very happy to look at evidence which
suggests something different to that, but we did not see
any evidence of that. And we understand that that sense
of both delegation, and yet bringing together that sense
of individual responsibility and yet collective
responsibility, was something which we did not see in
relation to consideration of the Interim Report of
Second Sight.
MR BEER: I think it's right that you have not examined, and
do not opine on the motives for that approach.
DAME SANDRA: We do not.
MR BEER: In paragraph 268, in the second line, you say in
your view the Chief Executive Officer, Paula Vennells:
"... did not ensure that the Board, before the
meeting [that's the meeting of 16 July], was fully
briefed on important matters, particularly those
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Can we go over the page please, to 270. You say it
would have been more appropriate to accompany
notification to the non-executives of publication of the
report with an executive summary of the key points,
rather than to do what the memo did, which was to focus
on inaccuracies, and that did nothing to dent the
important messages which could be discerned from the
report.
DAME SANDRA: Exactly. That was the point I anticipated
when I spoke earlier.
MR BEER: Thank you. Is there anything else you want to say
in relation to this sub-issue?
DAME SANDRA: Well, we'll probably come onto it but the lack
of an executive summary of the key points, either from
the Second Sight Interim Report or in the Board Update
paper meant that the job of the Board in interrogating
that paper was made, to an extent, more difficult.
MR BEER: Thank you. Can we turn to issue 4, the role of
the Chair, which we can see starts at the bottom of that
page, and go to your conclusions on page 75, please.
You make a similar point, as you did in relation to the
CEO, as regards the Chair, in paragraph 284 and I think
you make a similar point in 285 as you had in relation
to the CEO; is that right?
DAME SANDRA: That's exactly right.
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relating to Post Office policy and practice on
prosecutions ... It was reasonable that she should flag
her immediate concerns about communications. But they
were concerning how the story was being told, not about
the nature of the story itself."
Is there anything you wish to expand upon that?
DAME SANDRA: I believe that is quite clear, unless there
were further questions you'd like to ask.
MR BEER: No, thank you.
You develop that theme in 269 by saying
communications to the non-executives in between 1 and
16 July were focusing on PR rather than substance; is
that right?
DAME SANDRA: That is correct.
MR BEER: Then over the page --
DAME SANDRA: Perhaps I should just add, that's relevant to
that, there's this memo, three-page memorandum that went
with the circulation of the Second Sight Interim Report,
it was a very detailed analysis of where the Executive
felt there were factual inaccuracies, which didn't
really affect the substance of the report, and it meant
that the concentration was on those factual
inaccuracies, not the substance of the report.
MR BEER: Would it be fair -- no, I think that's probably
a bridge too far.
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MR BEER: You say you would have expected the Chair, that's
Alice Perkins, to have interrogated the report to see
for herself if there were any issues or problems flagged
in the findings beyond those identified by the CEO:
"... we would have expected her to give careful
consideration to: how she wished the Board to engage
with all the findings of the Second Sight Interim
Report; and the purpose and expected outcome of the
Board discussion."
Why would you have those expectations of the Chair?
DAME SANDRA: Because I believe and we believe, based on the
role of the chair in governance, that her responsibility
is to ensure that any paper or any matter which is
brought to the Board, that she understand what the
issues and problems are which it is being suggested.
MRBEER: Over the page to paragraph 287. Is this
essentially your view or your counterpoint, setting out
what should have happened in the Board meeting itself,
as opposed to what did happen?
DAME SANDRA: Yes, indeed, and I perhaps should say that, in
relation to each of these case studies, we are using the
base of Report 1, as we described. If we feel there is
need for additional background information, then we have
provided it in the introduction to the cases. Here,
where we talk about the chair at an administrative level
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to agree how the paper is to be presented, and so on, we
felt perhaps we hadn't put enough information in
Report 1, so we added it here.
MR BEER: Okay, so here you're saying there needed to be
agreement or direction as to who was going to present
this important paper -- is that right -
DAME SANDRA: Exactly.
MR BEER: -- whether they were to be invited into the
meeting and involved in both presentation and
discussion, and then carry those directions into
effect --
DAME SANDRA: That's correct.
MR BEER: -- is that right?
DAME SANDRA: That's correct.
MR BEER: What view, if any, did you form of the evidence as
to what, in fact, happened at 16 July?
DAME SANDRA: I believe we come to that later, which we can
take now or we can take later.
MR BEER: Can you discuss it now in the context of this
expectation?
DAME SANDRA: Well, the expectation, as we'll see, was, as
we understood, that the General Counsel would present --
would be present and would present the report. That did
not happen.
MR BEER: You say in 288 that you would have expected Alice
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decision, but she would probably discuss these with the
chief executive and the company secretary.
So the idea that the chair has responsibility for
the agenda is absolutely the case, whatever the item
which is there before the board.
MR BEER: So you're not picking out the Second Sight Report
here for special treatment?
DAME SANDRA: No, no.
MR BEER: Okay, got it.
DAME SANDRA: If that's the question the answer is no.
MR BEER: Gotit. You say that you found no evidence that
Alice Perkins prepared in this way and that, once in the
Board, that she chaired the meeting in such a way as to
ensure that the full import of the findings of the
report were appreciated and discussed with decisions on
follow-up actions agreed.
DAME SANDRA: And we'll come to it in more detail,
I believe, in subsequent issues.
MR BEER: Yes, can we turn to sub-issue 5, then. That set
out what the issue is on page 76, the role of the NEDs,
and your conclusions are expressed in paragraphs 302 to
304 on pages 75 and 80, if we can turn to those, please.
302, just scroll down, thank you. You say:
"Given the amount of external interest in Horizon,
its role in prosecution of [subpostmasters] and the fact
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Perkins to make it a priority that Susan Crichton was
present at the meeting, and that Alice Perkins had been
fully briefed by Susan Crichton, despite the apparent
strain in their relationship. Why is it that you pick
this topic, the Horizon report by Second Sight, for such
treatment?
DAME SANDRA: Why did we choose Second Sight?
MR BEER: Yes, so on the occasion of the Board meeting there
were a number of papers before the Board.
DAME SANDRA: Yes.
MR BEER: Not just this one.
DAME SANDRA: No, but we were -- our case study is about the
handling of the Second Sight Interim Report --
MR BEER: Yes.
DAME SANDRA: -- and therefore that is what we addressed.
MRBEER: Yes. I am asking you indirectly, and I'll make it
more direct: would you expect this kind of liaison and
prior agreement to occur in relation to all papers
tabled before a board.
DAME SANDRA: I would expect the chair to be fully aware of
the agenda that she has either proposed or agreed with
the company secretary, and to know how that agenda was
going to unfold, who was going to present what, who was
going to prepare what. She herself, as the chair, would
have views on that, and it would be ultimately her
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that Second Sight would be reporting on ‘Alleged
problems with the Horizon system’, [you] would that have
expected the CEO to keep the NEDs sufficiently apprised
at a high summary level, of any emerging issues from the
work. The minutes of the Board meeting of 23 January
2013 record the Chair, [rather than] the CEO, giving
a brief update on the work being undertaken by Second
Sight including ‘to date there was no evidence to
suggest fault’. Had the NEDs had a hint of any major
issues, they may have been alerted to questions they may
wish to raise. However, they received no such
information until the Board call on 1 July [was
received].”
So are you speaking essentially about priming the
NEDs here in the run-up to the delivery of the Second
Sight Report?
DAME SANDRA: Yeah, yeah. I'm talking about the fact that
when you're a non-executive director, and there is
a matter going on for over a year, and the board have
specifically asked for some updates, probably after
January, that, if there was anything emerging, of course
there may not have been anything emerging, but if there
was anything emerging we'd expect a brief update so that
the NEDs are aware, a hint of any major issues, they'll
be alerted to questions they may wish to raise. If what
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The Post Office Horizon IT Inquiry
they're told -- which may have been all there was to
tell, I don't know -- if they're told to date there is
no evidence to suggest fault, that is an indication that
we can relax, all things going well.
MR BEER: I think you point to a second aspect in which the
NEDs were not properly briefed in paragraph 303. This
focuses on the Board call on 1 July 2013.
DAME SANDRA: Yes.
MR BEER: You say, the limited time for the call, the fact
that the report wasn't listed as an agenda item or
flagged in advance by email, there was no briefing paper
that related to it before the call, created
circumstances in which the NEDs could not begin to
exercise their role in scrutiny or challenge?
DAME SANDRA: Yes.
MR BEER: Essentially, are you saying here that this was an
item that was just dropped in?
DAME SANDRA: It was entirely dropped in, the Board call was
about strategy, we believe, or we're led to believe, and
it opened with the Chief Executive saying, "We're
expecting the interim report to be published on 8 July",
and that they would get a copy of it then. But they
didn't know this was what was going to be the subject of
the call. They got no briefing paper, and so it was in
a way the first they'd heard of the publication.
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paragraphs 310 to 312, and you say it, the report,
contained much information which should have attracted
the attention of the NEDs, warranted serious discussion
by the Board because it raised issues about Post Office
Investigations and prosecutions policy and practice, the
attitudes of the Post Office to subpostmasters, the
impact of their contracts and contested evidence about
the robustness of Horizon. Much of the information does
not feature in the conclusions or in some easily
accessible summary form in the Second Sight report.
Are you there pointing out that you have to read the
report carefully and slowly in order to extract the
important issues that you have there identified?
DAME SANDRA: I am. It's not handed on a plate. It's
hardly handled in any way but, within the report, very
important matters are raised.
MR BEER: Not handed on a plate in terms of a good executive
summary.
DAME SANDRA: Exactly.
MR BEER: You say in 311 that it would have been good
practice for Post Office to require Second Sight to
write such a summary, and for the Post Office to have
written their own executive summary for the Board, and
that, in the absence of both of those things, it was
even more important that the Non-Executives interrogated
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MR BEER: You say, I think, drawing those threads together
in 304, the Non-Executive Directors were, in your view,
inadequately briefed. This was exactly the time when
they were expected to exert their independence, and that
the circumstances prevented them from doing so.
DAME SANDRA: Yeah.
MR BEER: Is that right?
DAME SANDRA: I believe that to be the case. And the reason
why -- you might say "Well, how is it that it would be
exactly the time they should exert their independence if
they knew nothing of it?" But they knew nothing of it
from within the Post Office but they were however aware
of the large-scale media influence and the influence and
the interest of MPs into the matters that Second Sight
were enquiring into.
So one might have thought they'd be alert to say,
“Well, let's try and understand this a bit better", but
they couldn't do that on the basis of the 1 July call
because they didn't know that they were going to hear
about it.
Q. Thank you. Turning to sub-issue 6 within this case
study, it's set out there:
"What could the Board have taken from the contents
of the ... report published on 8 July?”
You set your conclusions out on page 82. On to 83,
102
the report for themselves. You say:
"The messages identified above are evident."
By that, do you mean obvious when one reads the
document?
DAME SANDRA: A careful read, particularly against the
background that we have described, would have meant that
these matters were obvious, in our view.
MR BEER: Likely to be seen as highly significant by
a careful reader, but without executive signpost, they
needed to be drawn out from a reading of the report and
fully interrogated and that's what the NEDs should have
done?
DAME SANDRA: Yeah.
MR BEER: Can we turn, please, to the Board meeting itself,
‘on 16 July, and this is where you deal with issues 7, 8
and 9. Issue 7, you identify as "What were the contents
of the Board paper” -- that's for the purposes of the
meeting on 16 July -- "prepared, and how was the Board
paper received by the Board"?
DAME SANDRA: Yes.
MRBEER: Your conclusions are set out at paragraph 323,
which start on page 86. You refer us back to the first
time that the Board had seen anything of substance or
heard anything of substance was the Board call on 1 July
when they were given a brief and partial introduction to
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the report. When they got the Second Sight Report, it
wasn't accompanied or followed by a note from either
Paula Vennells or Susan Crichton, summarising the major
issues. The report isn't identified as a subject for
Board discussion on 16 July. Do you mean in the Board
papers?
DAME SANDRA: I mean, yes, the paper is called "Update",
“Following on", or I can't remember the exact words, but
it's an update subsequent to the Second Sight Interim
Report. So the Second Sight Interim Report is never as
such laid before the Board meeting. It has been made
available to the Board on 8 July, when it is published,
and then this is an update consequent upon that. In
a way, it's implied, as a presence in the board, but it
is not expressly put in the board papers.
MR BEER: So you're identifying the absence of a note which
says, for example, “Discussion of the contents of the
Second Sigh report of 8 July"?
DAME SANDRA: Yes, or a summary of the contents.
MR BEER: You say the update paper covers some but not all
of the issues identified in the report but does so in
a structure which makes some of them somewhat opaque.
What were you referring to there, if you can recall?
DAME SANDRA: What I was referring to was the fact that, as
I've indicated, the Second Sight Interim Report had lots
105
happened.
MR BEER: And that it is a departure from the reasonably
expected standards that you set out in Report 1.
DAME SANDRA: Also, if we look at paragraph 325, we had
a checklist of normal expectations of a board. Now you
wouldn't find this in the code of conduct for -- on the
code of governance. This is more drawing upon our own
experience, and also the experience that you can find in
many board evaluation processes, where one of the
subjects for discussion is usually about how your board
paper is presented; do you have any areas where you
think they should be improved; what's the normal
standard you expect?
So this summary is our summary based on our
experience on the experience of other experts in board
governance, and in thinking about the way in which one
can run effective boards.
MR BEER: In summary, you find that out, of the eight-items
‘on the nominal checklist, four were non-existent, two
were partially existent, and two were in existence?
DAME SANDRA: Indeed.
MR BEER: If we go over the page, please, to 327, and 8 you
say that Paula Vennells should have ensured
a comprehensive summary of the major issues was
explicitly and comprehensively drawn to the Board's
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of bits of information which were highly germane to the
issue of POL's -- the Post Office's prosecutions and
investigations, attitudes to subpostmasters, the use of
Horizon data in prosecutions, and the robustness of
Horizon. They were peppered around, and that, as I've
said before, wasn't handed on a plate.
And that, then -- the update report, deals with
what's happened after the publication, and that update
report addresses a number of matters which are, I hope,
in this section, identified, but which -- the fact that
there wasn't an executive summary meant that the
significance of some of the point had to be extracted by
the reader, rather than, again, being given on a plate
of an executive summary.
MR BEER: Again, in your examination of the issues, I don't
think you attribute motive or intention --
DAME SANDRA: We do not.
MR BEER: -- to the relevant actors here, ie why this was
done.
DAME SANDRA: Didn't hear.
MR BEER: You don't attribute motive or intention to the
relevant actors --
DAME SANDRA: We don't.
MR BEER: -- ie why this was done in this way.
DAME SANDRA: We don't. We note that that was what
106
attention. However, there was, nonetheless, sufficient
information in the report and the Update paper to alert
an engaged NED that the Board should fully interrogate
the issues and require the CEO urgently to report back
on whether there were major risks in the three things
you mentioned, and that wasn't done according to the
evidence you have seen.
DAME SANDRA: That's correct.
MR BEER: Is there anything else you want to speak to or
identify in relation to this sub-issue 7?
DAME SANDRA: We're dealing with an expectation that NEDs
should be informed of major issues, and we're dealing
with an expectation that the Chief Executive will gather
together all the information that she has to been to the
attention of the Board. Little bits of that process may
not happen, and they may not happen in many boards, but
when you have the confluence of those various aspects
coming together, particularly given that this is
known -- we're now in 2013, this is known to be -- to
address a number of very serious issues for the Post
Office, then we would expect there to have been more
attention paid to the areas that we've identified.
MR BEER: Thank you can we turn to issue 8, the quality of
the discussion and the quality of the decisions made at
the Board meeting on 16 July, issue 8. Now, you've set
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out a series of conclusions here. They begin at
page 92. Within this subtheme you identify, if we
scroll down to paragraph 346, some subsubthemes or
conclusions, and there are six of them. I'm not going
to ask you to speak to each of those six points that
arise from the discussion at, and the decision making
of, the Board on 16 July, but instead turn to your
overarching conclusions about them. That's page 100,
paragraph 375 and following.
So in the light of the six subpoints you've
examined, you say:
"In [your] view, the Board's receipt and discussion
of the Update paper was a missed opportunity for the
Board. Notwithstanding their annoyance with the
management of the process, the Board knew that [the Post
Office's] present unresolved situation with
[subpostmasters] and [its] defence of the Horizon system
was consuming large amounts of time and energy in the
business and threatening that which the Board held dear,
namely the public reputation of the [Post Office]. It
knew of the accounts of human hardship and suffering
from [subpostmasters] which were current in the press
and media and of great concern amongst some MPs."
So you were saying, notwithstanding the manner in
which the issue and the materials were presented to the
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operational matters, which are matters for the Executive
to run. However, if the Board believes, and believes
there is evidence to suggest that those operations are
not proceeding within the reasonable bounds of expected
performance, or if they believe there are other
questions or matters that they should consider, then
they should enquire of the executive, "Well, what really
is going on here?" And that doesn't mean they would be
coverstepping and interfering, rather it means that they
would be exercising their due responsibility in relation
to the matters.
MR BEER: Thank you. Can we turn to the last issue, in this
case study, number 9, which is the behaviour by relevant
actors, in fact before the Board, ie in a pre-meet, and
in the Board itself. Your conclusions start at
paragraph 389 on page 103. You're addressing two things
there: the pre-meeting of the NEDs and then the
exclusion of Susan Crichton from the Board meeting
itself. You say:
"It's relevant to ask if such a series of events is
unusual in the conduct of board affairs.”
How did you answer that question?
DAME SANDRA: We answered the question to say non-executive
directors getting very exercised and angry about
something that is in their board papers is not totally
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Board, there was a failure by the Board?
DAME SANDRA: To look above their annoyance, to look above
the irritations, the lack of immediate evidence, the
lack of evidence on a plate: to look above and also then
to go into the detail, that is what we would have
expected.
MR BEER: In paragraph 377, you say that:
"The Executive did not help the Board to see the
bigger picture, or take a longer time perspective, but
the Board could itself still have required more focused
coordinated and sustained work which is likely to have
revealed the magnitude and interconnectedness of the
risks in front of them."
Then over to 378:
if the NEDs had made such challenges ... it
would not have crossed the line between business and
Board, or mean that the NEDs were necessarily not
supportive of the Executive. NED challenge to the
executive is a fundamental part of their role."
Can you explain what you meant by that paragraph,
please?
DAME SANDRA: Yes, well, it's often said in governance terms
that NEDs shouldn't interfere with the running of the
business. It goes back to the earlier point we had this
morning about the Board not involving itself in
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unusual in pre-meets. In pre-meets of non-executive
directors, there's often expressions of unhappiness in
relation to certain things that are being done. So,
a NED pre-meet, which is exercised by what they see to
be failings of the executive, is not totally unusual.
I think in both our experiences, we've come across them.
And, indeed, it's often said that one of the reasons
for a NED pre-meet is that they can get together and
share their experiences without totally voicing them in
the board. So annoyed non-executives meeting before
a board meeting is not totally unusual.
Excluding people who expected to be at a board
meeting is also not totally unusual. I mean, sometimes
because of pressure of time, sometimes because at the
pre-meet people have decided that the board paper isn't
yet ready to be considered, people may be stood down.
Perhaps we'll go on to the manner of standing down in
aminute. So excluding executive members from a board
meeting is again, not outside our experience.
The general counsel, one could argue, is in
a special case because, as we addressed her
responsibilities earlier, she has both responsibilities
as an executive director and she has responsibilities as
the general counsel. And I have never personally come
across, nor have I ever seen it written about, where
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a general counsel was expected to be before a board and
was then subsequently excluded. So the exclusion of
executive directors because there's not time or because
their paper isn't ready, is not that unusual; excluding
a general counsel is pretty unusual and I've never come
across it.
MR BEER: Can I ask, unusually, Dr Steward, whether you
have?
DR STEWARD: I have never come across it, no.
MR BEER: Thank you. What view did you form of the reasons
given or what the reactions ought to have been for the
reasons given for excluding the General Counsel on this
occasion, ie that there were concerns over how she had
managed the product?
DAME SANDRA: The question to me is?
MR BEER: Did you form a view as to the reasons given for
excluding Susan Crichton from the Board?
DAME SANDRA: It appeared to be -- and this is our reading
of the evidence we've seen -- it appeared to be that the
Non-Executives were so exercised with their irritation
with how the Second Sight work and the conclusions in
the interim report have been raised, they were so
annoyed about that that they were expressing a lot of
criticism of the General Counsel. And that appears to
have, insofar as she speaks about this, have caused the
113
general counsel in boards has developed over time, and
I am mindful of the fact that we're dealing here with
2013, not with 2024.
Nonetheless, as it happens, I can remember
facilitating a discussion of general counsels around
this time, about their role in the board, and I can say
that in general -- and these may be larger businesses
rather than smaller businesses -- in general, a Board
would have had a general counsel who was either --
probably not a member of the Board but who was a routine
attendee.
But, in this case, they had no one who was a regular
attendee, Susan Crichton only came in if she was
specifically requiring. That, in our sense -- view is
er ... probably in 2013, most general counsels would
have been regularly in attendance, probably, but not
all.
But she was the most important senior lawyer in the
organisation. There were important legal matters on the
agenda, not simply this update but also there was this
Significant Litigation Report for noting.
So what was happening, by her not being at that
Board, was that Board was denied its own legal
specialist, who appeared to be the only person who
understood the legal matters raised by claims for
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Chair to think, "Well, the best thing is that we have
this discussion in the Board without the presence of the
General Counsel".
We go on to consider other matters, I think, later.
MR BEER: Page 105, paragraph 396, is that you essentially
setting out your proposed solution, if the facts are as
described by the Chair --
DAME SANDRA: Indeed.
MR BEER: -- ie there were two issues: one said to be about
the General Counsel's performance, in relation to the
project --
DAME SANDRA: Yes.
MR BEER: -- but, nonetheless, there was a remaining issue
as to the substance of the report. The substance needs
a discussion, she's the person who knows most about it?
DAME SANDRA: Exactly.
MR BEER: You draw, I think, a wider conclusion in
paragraph 397, that takes us outside the case study.
DAME SANDRA: Mm-hm.
MRBEER: Can you explain that, please?
DAME SANDRA: It comes -- arises from our analysis of the
case study. The Board had no senior lawyer, either as
a member of the Board or as a routine attendee. Perhaps
I should say, in context, the generally accepted
standards -- and I should also say that the role of the
114
wrongful prosecution because, as we've seen earlier, the
Chief Executive, who ended up presenting this report,
herself asserted on many occasions or several occasions
that she herself was not a lawyer and did not altogether
understand these matters.
MR BEER: Can we go over the page please to paragraphs 399
and 400. You draw a third point from this episode, and
you mention the impersonal, public and, some might say,
humiliating treatment of Susan Crichton which implies
a disrespect for colleagues and lack of human sympathy.
You say in 400 that this appears to give you strong
signals about the culture of the Boardroom. You can be
sure that, even as this was happening, rumours,
speculation, et cetera, would have been rife within HQ.
It suggests a disrespect for colleagues, a Board which
doesn't care about people, a rift between the General
Counsel, the Chair and the Board and a silence in the
face of consideration for others.
How serious a state of affairs are you describing
there?
DAME SANDRA: I'm describing there something which both
reflects and then becomes instantiated within the
culture of the boardroom and has wider ramifications for
the culture of the organisation. cultures are made up of
stories, of accounts of things that have happened,
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sometimes they're mythical, sometimes substantive. And
I think this, leaving a General Counsel, a very senior
member of the Executive Team, sitting outside
a boardroom which she is expecting to go into is
a very -- a significant matter, and it would have been
a subject for great, I imagine, discussion and
speculation within the organisation.
I don't know if you want add to anything to that?
DR STEWARD: Only the general point, I think, which is that
cultures are exactly that. They morph and they change,
cultures are made up of what you see going on around you
and what you experience. And if you see going on around
you people being excluded from meetings, then the
culture becomes one in which it is easier to accept that
this is the way we do things around here.
MRBEER: Thank you. Can we tum to Case Study 3, please.
That begins on page 109, and concerns, Case Study 3, the
handling of Simon Clarke's Advice by the Executive in
2013. You set out this case study over a large number
of pages, over 30 pages, from page 109 onwards. Again,
there's a crisp summary of the facts from paragraph 412.
You say:
"Susan Crichton received legal advice from
Cartwright King, Post Office's prosecuting solicitors,
because preliminary conclusions from the Second Sight
117
to be conducted by Cartwright King.
"When the General Counsel received the written
advice on 17 July she shared it with members of the
Legal Team (Hugh Flemington and Rodric Williams). She
doesn't remember reading it herself, she says in her
witness statement.
"By this time actions on the Sift Review were well
under way.”
Then over the page to 4.16:
"The Clarke Advice outlines the duties of an expert
witness. It shows how the evidence relied on by the
expert witness, Mr Jenkins, was tainted. It concludes
that Post Office will need to conduct a disclosure
exercise for subpostmasters where convictions have been
secured on the basis of Horizon evidence and that those
grounds for appeal will be able to go to the Court of
Appeal. It says emphatically that the existing witness,
Mr Jenkins, cannot be used again."
You then set out over the following pages, I think
six issues, the first of which is who should have
received the advice. Your conclusions on that appear
between paragraphs 438 and 448 and they start on
page 116. You say, if it is found that neither Susan
Crichton, from July to November '13, nor her successor
Chris Aujard, until 2015, informed the Board of the
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Report were showing that there were bugs in the system
which impacted branches. Mr Clarke realised this
finding might call into question the integrity of some
prosecutions, and might have resulted in some
miscarriages of justice, and volunteered the advice.
Ms Crichton understood from Mr Clarke that some sort of
review of cases may be needed to establish the size of
the problem and to enable some sort of disclosure to
defendants, if there was a risk their convictions were
unsafe.
"Susan Crichton met Cartwright King and received
a summary oral report of what would become known as the
Simon Clarke Advice on 3 July.
You say you've assumed that the oral summary would
have been explicit about the serious problems of
Fujitsu's Gareth Jenkins as a witness, which were at the
centre of the Simon Clarke Advice. This was five days
before the publication of the interim report on 8 July
2013:
“Although the written advice was received by the
Post Office Legal Team on 17 July, it was sufficiently
clear from the face-to-face meeting on 3 July that
immediate action was needed. A review of cases and
requirements for disclosure, which became known as the
Sift Review was instituted on Ms Crichton's instructions
118
Clarke Advice, specifically that criminal prosecutions
may have been undermined by the failure of Gareth
Jenkins to disclose evidence of bugs in the system, then
this is a failure of governance, in so much as
governance is a combination of formal roles, competence,
formal and informal relationships. It is not a failure
which can be laid simply on those two General Counsel.
The general counsel must be able to speak their
mind, represent their professional responsibilities in
the sure confidence they will be listened to.
What were you implying there, if anything?
DAME SANDRA: One could say simply that the General Counsels
did not give explicitly the information contained in the
Simon Clarke Advice in all its elements. They did give
bits of the evidence, even as early as the Board Update
paper, written by Susan Crichton, where she said that
the -- they had a legal duty to review some
prosecutions, which is informed by the Simon Clarke
Advice but, even if they didn't let it all out, as
appears to us, then whether or not someone speaks,
whether or not someone presents information, is a matter
of how they think both it will be received, and what
they believe other people to know, and so, in that
sense, we would say that it's not simply on them that
they didn't speak it in total.
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They gave out bits of it, and perhaps they -- we
have no idea, but it's possible that they just thought
they should get on with doing the bits that they could
do, namely, in Susan Crichton's way, she had immediately
started the Sift Review, which was a direct response to
the Simon Clarke.
Do you want to add?
DR STEWARD: Yes, I think there are number of different
routes to Board for the Simon Clarke Advice. There was
Susan Crichton talking to the Chief Executive, the Chief
Executive said she -- apparently said she didn't
understand it and didn't communicate it to the Chair.
Susan Crichton could have escalated it to the Chair.
There is the opportunity that was missed, if you like,
when Susan Crichton was in the Boardroom on 16 June for
her to communicate face-to-face the contents of the
Simon Clarke Advice.
So this 439, what we're trying to pull out is that
actually the communication of this advice, getting into
the Boardroom needed a collective effort, it needed --
it's about the relationships, it's about the social
processes, which mean that the information gets to the
place where it needs to be got to.
DAME SANDRA: I think there's also an indication -- there's
an email, I think, from Alwen Lyons to Paula Vennells
121
Report, we have evidence of bugs and defects in the
system, what are we doing to understand the implications
of that for us?" And that the general counsel would
have legal knowledge, but it wouldn't just sit with the
general counsel; it would sit within the general counsel
and the chief executive in communication, because this
is a significant risk to the business, and the chief
executive has -- is ultimately pivotal in terms of
taking that risk to the board.
So it's not something which sits just within a legal
silo, and I think that's what we're trying to pull out
here, is the extent to which it sat within a legal silo,
or it was seen as a collective appreciation of the risk
to the business.
MR BEER: Thank you.
Sir, that's a convenient moment for the afternoon
break. Can we break until 3.00, please, before we turn
to issue 2.
(2.47 pm)
(A short break)
(3.00 pm)
MR BEER: Thank you, sir.
Dame Sandra, Dr Steward, we were in the middle of
Case Study 3, looking at the ending of issue 1 and
moving to issue 2. Can we turn up page 117, please, of
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relating the fact that she has spoken to Susan Crichton,
shortly after Susan Crichton's exclusion from the Board
in, which Susan Crichton says she would have talked
about the criminal cases, had she been in there.
Whether or not she would have included specifically the
Simon Clarke Advices, we do not know.
MR BEER: Can we look, please, at paragraphs 447 and 448 on
the next page. You refer back to some of the evidence
given by Paula Vennells to the effect that this is
a legal matter, this is an issue for Legal, implying
a failure to integrate legal knowledge into collective
executive discussions and decisions and, if it's the
case that legal knowledge is in a black box, which the
CEO and others do not need to or cannot understand, you
say:
"This implies that Legal is almost semi-detached
from the business and Paula Vennells is happy for issues
of a legal nature to remain the responsibility wholly of
the General Counsel and legal advisers."
Can you explain, please, how this relates to the
distribution of the Clarke Advice?
DR STEWARD: The distribution of the Clarke Advice, I think
if you have a -- what I imagine happening, in those
circumstances, would be that a chief executive would say
to her general counsel, "We have got the Second Sight
122
the second report. You're dealing with the question
from this paragraph onwards: what should have been done
with the Simon Clarke Advice of July 2013?
Can we look at your conclusions on that issue,
please, page 128, paragraph 483 at the foot of the page.
You say:
"When looking at what should have been done with the
Advice, we make the following observations:
"On receipt, the Post Office Executive, led by the
General Counsel, needed to take immediate action to
review past and present criminal cases and start the
disclosure exercise using the process agreed with Post
Office's lawyers, Cartwright King. Susan Crichton
recognised that immediate action was needed and acted on
the advice of the lawyers so that the Sift Review was
under way by the time of 16 July Board meeting.
"It was a broad Executive, not just a legal,
responsibility to review the conclusions of the Simon
Clarke Advice and make recommendations. Initially,
discussed and agreed with the ExCo to the Board all
functional heads share responsibility for briefing the
CEO and their team colleagues, but the CEO's role, in
focusing the team on the issues for the business, is
crucial.
"The prosecution policies would almost certainly
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have been thought a priority by ExCo had they considered
it, it should have been addressed as a matter of great
urgency. Any member of ExCo who were Board directors
have an ultimate duty to the Board to bring any matters
of consequence to the Board.
"The General Counsel should have been in regular
contact with the CEO throughout the week before the
Board meeting conveying to the CEO the lawyers’
proposals and initial work and they should have been
jointly discussing any implications for the business in
assessing risk.
"The general counsel generally has a duty to fully
inform the Audit and Risk Committee and the Board, in
order to protect the business in situations where the
CEO may not be doing this.
"The General Counsel has a direct duty to the Board
if they felt at any time, when the Board was making
important decisions of policy, the Board was being given
incomplete or inaccurate information. Whilst obviously
in a difficult situation, they must inform the Chair of
their concerns and express their opinion at the Audit
and Risk Committee, even when it differs with that of
the CEO. They should discuss or continue to discuss
differences of opinion with the CEO.
"The Post Office was slow to react to breaches in
125
DAME SANDRA: You will know I didn't have that spectrum in
my mind, but I'm happy to respond to your spectrum. But
before I do that, I think a very strong element of that
conclusion is that elements of the Advice were known.
All the Advice was known to the General Counsel.
Elements of it were known to the Board, who knew that
they had to review all criminal cases. Elements of it
were known by the CEO, who knew that they had to review
all criminal cases, and also, who quite quickly knew
there was a problem with the witness, but as she says,
she didn't fully understand what that problem was.
So it's not a question that this is the Simon Clarke
Advice, coherently bound up, and it was kept from
people. Bits of it had come off and were held by
various people. And the first point, I think, of our
conclusions, taking them, as you're wanting us to do, as
a sum, is that there was no -- nobody apparently thought
to draw all those together. All the players had bits,
and they were bits which were related to the -- to Post
Office's prosecutions of subpostmasters, which was
a major issue for MPs, the media, and so on.
And as such, you would have expected -- we would
have expected, that they would have been pooled
together, and that one would have taken this coherently.
So what should have been done with the Simon Clarke
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their duties as a prosecutor because the CEO and ExCo
collectively did not acknowledge that the Simon Clarke
Advice (or the substance of it) revealed a problem with
prosecutions, nor did they take them as a coherent
picture to the Board. The Board also has a duty to
challenge the small issues before they become big ones.
The Board knew about the need for disclosures, about the
possibility of some miscarriages of justice and about
the problems with bugs. These were either explicit or
implicit in the content of, and subsequent Board Update
on, the report.
"The Board should have had frank discussion with the
CEO about what the Board must understand in relation to
miscarriages of justice in order to be able to recognise
the problem before it got out of hand. Had they done
so, management might have shown that they knew much more
about the issues associated with disclosures than was
revealed."
That's quite a list of issues and problems.
DAME SANDRA: Mm.
MR BEER: Can you help us, the series of issues that you
list there, in relation to the, essentially, consequence
management, as a result of the advice, in the spectrum
that I have notionally got in my mind of seriousness,
where does this sit?
126
Advice, in -- it would have been wonderful, had it been
bundled up and immediately distributed. It wasn't done
that. Nonetheless, elements were known and those
elements should have been brought together by the
various people and interrogated. That is what I think
we are concluding.
I'm going to find out from Dr Steward if she wants
to add any more.
DR STEWARD: I think there is a serious, if you like,
dropping of the ball or slipping between the cracks here
as well, that this was an opportunity to review Post
Office's policy on prosecutions, and the seriousness of
not having that conversation, either at the Audit and
Risk Committee, until later on, and even then, with
information that was not unambiguously clear, meant that
there was a material decision, if you like, which was
delayed as a result of the handling of this case.
MR BEER: So, if I've understood both of you correctly,
you're saying, although the Advice or the substance of
the Advice should unequivocally have been passing to the
Board, there were nonetheless fragments of it that both
the CEO and the Board knew about, which was sufficient
basis for each of them to have taken the further action
that you recommend?
25 DAME SANDRA: That is exactly of the case and we do see some
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parallels between that and the previous case that we
have looked at, where similarly important fragments were
known.
MR BEER: Can we turn to issue 3, please, which is in fact
identified on the screen here: internal and external
conflicts of interest.
You set out your conclusions here on page 131, which
is just over the page, at the foot of the page at 490,
in this paragraph and 491. Can you summarise for us, at
490 and 491, this issue that you're addressing here,
internal and external conflicts of interest?
DAME SANDRA: You would like us to summarise?
MR BEER: Yes.
DAME SANDRA: Right back in the Companies Act and in --
throughout the Codes of Corporate Governance for the UK,
the identification of conflicts of there are always
present. It's understood that in governance and in
management, conflicts/divergent interests can inevitably
emerge. Their existence isn't the problem; the problem
is how you address them.
And what we identified here is that -- well, and
I should say that if the conflicts exist within the
Executive, then it's the chief executive's ultimate
responsible to identify them and to handle them,
although one would expect members of her organisation to
129
they would be handled.
MR BEER: So to summarise on internal conflicts, you're
saying that the Second Sight Report, the Clarke Advice
and the work thereafter, highlighted or potentially
highlighted the existence of failings on the part of the
prosecution function, or risked the revelation of such
problems, and that it might be in the interests of the
general counsel that the full extent of such failings
did not come to light or minimised --
DAME SANDRA: That can be argued. We're not making
conclusions on that whatsoever but the very fact that
these structures were such as you've described and
I described, means that the conflict was potentially
there and should have been addressed.
MR BEER: Can we go over the page to 491, please. Here
you're dealing with external conflicts. Is the summary
of it this: that, in respect of Cartwright King, the
potential conflict was stark. They were reviewing cases
that they had previously had conduct of?
DAME SANDRA: Indeed.
MR BEER: Is that the long and short of it?
DAME SANDRA: That is the long and the short of it.
MR BEER: You pose some questions: what was put in place to
ensure that the firm were not overly concerned to make
sure their own part in the prosecutions historically was
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represent them to her, but she is ultimately responsible
for the structures over any conflicts that occur there.
In the Board, if the conflicts exist, it's the
Chair's responsibility to call them out and to say,
"Well, how are we handling these?" So if someone has
a conflict of interest, they should have been discussed.
It seemed to us that the General Counsel, as we've
said, had multiple hats, she had the hat of being the
General Counsel, with her independent advice, she had
the hat of being Head of Legal, which embraced and
included the conduct of prosecutions, and she was
a member of the Executive Team.
Elements to do with prosecutions which required
enquiry meant that, in a way, she was enquiring into
aspects for which she was responsible and one would
normally expect that at least to be acknowledged and
consider how that should be handled. With regard to the
previous case study that we've looked at, she was also
asked to enquire into what had gone wrong with the
management for which she had been responsible.
So our conclusion is that there were conflicts
there. They may not have had any impact. We're not
saying they had an #impact, but we're saying they
existed. They should have been addressed and they
should have been discussed on how they would be -- how
130
protected? Did the Board and the CEO ask these
questions about whether Cartwright King could ever be
truly independent?
You say it was a question the Board should have
addressed with the CEO. Did you see any evidence that
those questions were addressed with the CEO?
DR STEWARD: I think I'm right in saying that Brian Altman
did review or was asked to review, in one of his
advices, the independence of Cartwright King.
MR BEER: That's right.
DR STEWARD: It is -- to be absolutely frank, I think that
was legally privileged information, so it's quite
difficult to tell where that went to and who saw that.
So we -- that's the ...
DAME SANDRA: But there was reference to the fact that
they -- it was understood. I think it was, indeed, the
General Counsel who felt that it would be appropriate,
and probably others as well, that they should be somehow
assured that this conflict did not, in any way,
influence what they were doing, and the advice was that
the sift was very well conducted.
MR BEER: You're essentially saying that the Board ought to
have become involved in probing that?
DAME SANDRA: I believe that would have been appropriate,
given the conflicts that we have described, and, given
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the spotlight which should have been upon the way in
which the Post Office was conducting its prosecutions,
it would have been appropriate for the Board to assure
itself that that -- those conflicts were not in
evidence.
MR BEER: You turn underneath these paragraphs to issue 4,
in Case Study 3, communicating risk, and set out your
conclusions on page 134 in paragraphs 500 to 503.
Is there anything you wish to add to those
paragraphs about communication in this episode?
DR STEWARD: I mean, the only thing I would add, to sort of
sum all this together, is that, across number of these
case studies, there seems to be a common theme of the
communication being -- of shying away from confronting
where there has been wrongdoing or fault. So the
partial telling of the stories, the leaving of half the
story, but not the full story.
DAME SANDRA: I think if you look earlier on, before the
conclusions, you'll see a number of examples of that.
This, again, as it says in 502, or as we say in 502,
there was opportunities, perhaps, for the Non-Executives
in our words, leaning in, being curious, challenging the
case for future prosecutions, and what should be done
about past prosecutions within a more holistic risk
framework, in which we took account of the risks which
133
are posed for the organisation, then it's extremely
difficult for those lower down in the organisation to
see what that bigger picture is and then begin to
contribute in their information which will be held lower
down in the organisation towards constructing a richer
framework.
MR BEER: You turn to issue 6, immediately underneath these
paragraphs, which is Post Office culture, and give us
your conclusions on page 141 at the bottom, in
paragraph 535, and you tell us that it seems to you
that:
".. Post Office culture, with its underlying taken
for granted assumptions, was so strong that the CEO and
ExCo did not see any link between persistent underlying
flaws in the prosecutorial process and the evidence that
[the Post Office] had not taken the concerns of
[subpostmasters] seriously. They lived, without
question, within their accepted beliefs. It was as if
miscarriages of justice were a mirage, not quite real
and the Sift Review was required because of the
disclosure about bugs, not an unsafe witness."
Is there anything you wish to add to that?
DAME SANDRA: No, I believe we have laid out earlier on the
prevailing views about the robustness of Horizon, the
public duty to prosecute to protect public money, the
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were not to crystallise until several years later about
the way in which POL was conducting its prosecutions,
the way it which it had conducted its prosecutions, and
its reliance upon Horizon data.
MR BEER: Thank you. Can we turn to the executive
understanding of risk, page 135, and then your
conclusion, please, on page 137. You say that:
"The role of the CEO is critical in creating
an executive and management focus on risk discussions.
The CEO was not able to bring prosecutions risk to the
attention of [the Post Office Executive] because, at
a minimum, she did not understand it.
“Without the risks relating to the Simon Clarke
Advice being clearly framed in the Executive, it was
impossible for managers to go back to their functions
and start building governance around risks. Good
governance of risks requires the risk to be fully shared
and agreed in ExCo, cascaded into the teams where it is
discussed and plans and mitigations formulated for
consideration within the risk framework."
So here you're essentially looking down rather than
up; is that right?
DAME SANDRA: Exactly, and we're saying, at this sort of
pivotal point of the executive, if you don't have
a coherent understanding of what the risks are, how they
134
approach to subpostmasters, and that these gave a set of
taken for granted assumptions, which meant that
information which was readily available and indeed, in
the case of the Simon Clarke Advice, explicit in a piece
of advice, was not taken into as we've said, a holistic
view of what was going on in the business.
Do you want add to anything?
DR STEWARD: No.
MR BEER: Over the page to 537. You say that:
"It seems odd to [youl that the Chief Executive and
her ExCo did not seriously challenge the assumption that
Post Office had historically been right to pursue
prosecutions on the basis of Horizon evidence, even
though both General Counsels in the period 2013-14 held
personal views that Post Office should not be conducting
private prosecutions and at least some members of the
team were aware that Post Office had breached its duties
from the Simon Clarke Advice."
Can you explain or expand upon the oddity which you
discovered or the oddity about which you speak?
DAME SANDRA: Trying to put ourselves into the position, we
find it very, very difficult to understand that with all
these pieces of information, it didn't lead someone to
say "Should we immediately agree to stop private
prosecutions", even though, as we've said, both General
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Counsels have said that, in their view, they don't feel
that this is something that should continue. The fact
that they didn't continue because they were looking for
another witness, the fact that they were ceased or
paused is neither here nor there with regard to should
we be doing this in this manner, and we find it odd that
that assumption wasn't challenged.
Do you want to add?
DR STEWARD: No, thank you.
MR BEER: Thank you. Can we turn to your overall
conclusions on Case Study 3. They're at the foot of
page 143. You tell us that:
"[Case Study 3] provides [your] description,
analysis and conclusions on six issues which are
important in evaluating the way in which the Post Office
Executive handled the Clarke Advice. It should have
been escalated to the Board. However, if it is found
that there was a failure to do so, in our view it's not
a failure that can simply be laid on the General
Counsel.
“It was a responsibility of the CEO and the
Executive, not just the General Counsel, to have
reviewed the conclusions of the Clarke Advice and made
recommendations to the Board and, ultimately,
a responsible of the Chief Executive to ensure there's
137
page 13, you set out your conclusions.
Essentially, is what you're doing from paragraph 31
onwards, identify material from each of the three case
studies that's relevant to the theme that you have
identified?
DR STEWARD: Indeed, that's the case.
MR BEER: To take this as an example, you say in 31, the
Second Sight case, that's our second case study,
illustrates the Board did not see the major problems in
prosecutions, investigations and culture that had been
included in the report.
"All three cases, (Second Sight, Simon Clarke and
Wolstenholme) illustrate that the Executive did not
systematically identify the key risks in prosecutions or
in their approach to [subpostmasters] or propose how
they should be mitigated. They didn't challenge the
executive approach, even though they had information
before them that suggested serious risks. In 2013, the
Board did not take the opportunity to open a window to
see the bigger picture ...
“In our view, events and discussions during July
2013 reinforced, rather than challenged, the prevailing
view of the nature of the problems. The approach that
all things to do with Horizon were operational, and
therefore an Executive responsibility, regardless of
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a focus on all top level risks in the business, so that
all members of the Executive Team feel part of a shared
endeavour, in which they will identify, communicate and
mitigate risks in their areas and escalate them with
urgency when needed."
Is there anything you wish to add to that overall
conclusion on Case Study 3?
DAME SANDRA: No, thank you.
DR STEWARD: No.
MR BEER: Thank you, that's the end of the case studies.
Can we go back briefly, then, to look at the nine themes
that you identified, in the light of them, at page 13 of
the report - I should have started at page 11,
actually.
I'm not going to adduce each of these in evidence in
the same way, the report speaks for itself and others
can ask you questions if necessary about them, but just
work out what's going on in the report, so we can all
understand it. This is the first of the nine themes,
"Board Level Governance".
If we go on that page, you identify what the issue
is or what the importance of the issue is. Here, it's
about strategy and risk. Then over the page, in
paragraph 23, and right through to 30, you identify
evidence relevant to that issue. Then at the foot of
138
indications of serious risk, particularly in prosecution
policies and practices, was a governance failure."
You do that in relation to each of the nine themes;
is that right?
DAME SANDRA: That's correct.
MR BEER: Essentially, the structure that I've outlined?
DAME SANDRA: Yes.
MR BEER: So in relation to this one, for example, and
perhaps building on what you say, would you agree that
the way in which the Post Office exercised its powers of
private prosecution as a routine part of the business,
for example the creation of an investigations
department, a prosecutorial department, was
a significant risk across the period that you've
examined?
DAME SANDRA: When you say the creation, that of course goes
back hundreds of years or decades.
MR BEER: Yes, maintenance of.
DAME SANDRA: Thank you, so the maintenance, the
continuation of that.
MR BEER: Yes.
DAME SANDRA: The question is: do we see that as a serious
risk?
MR BEER: Yes.
DAME SANDRA: Yes.
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DR STEWARD: Yes, if -- unless there is very, very good
governance in place, for prosecutions.
DAME SANDRA: Ah, sorry, that's certainly the case.
DR STEWARD: tis a serious risk and there needs to be
proportionate levels of governance in order to ensure
that the risk of prosecutions is --
MR BEER: Let's look at it another way round, rather than
through the prism of whether there was a risk or not.
Would you have expected the Executive Team and the Post
Office Board to have had a clear understanding that the
Post Office routinely conducted its own prosecutions of
subpostmasters on a very significant scale?
DAME SANDRA: We would have had that expectation that they
would have understood that.
MR BEER: That they were engaged in that activity?
DAME SANDRA: Yes, that they -- that they understood that
the Post Office was engaged in that activity.
MR BEER: Is that because the exercise of a private
prosecution function is an exceptional activity on the
part of a company?
DAME SANDRA: Well, first of all, it's because all business,
which is undertaken in the name of the company, the
executive, who is running the company, has
a responsibility to understand what they're doing, and
the board has a responsibility to have oversight of what
144
does, what its purpose is and what its various
activities are and how those activities are organised.
So I would expect a board member to have that general
understanding.
If I then was in this Board and I understood that
part of those activities were to bring exceptionally and
perhaps anachronistically, as I believe Brian Altman
says, prosecutions under the private route, I would have
expected them to be particularly interested in that, had
they known it, yes.
Is that --
DR STEWARD: Yes.
MR BEER: What about if we add this into the equation: that
the Post Office was in perhaps an unusual position
because it was the alleged victim of any crime, it was
the investigator of an alleged crime, it was the
decision maker as to whether or not to bring proceedings
or not about the alleged crime, it was the generator of
the evidence about the alleged crime, it was the
prosecutor for the alleged crime, and it was the
potential beneficiary of a Proceeds of Crime order for
the payment of money back to the Post Office. Would
that series of roles have added to the risk register?
DAME SANDRA: I think it would have both added to the risk
register for exactly the reasons that you're alluding
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the executive is doing in running the business. So it's
an element of the business it should be duly understood
and managed by the executive.
In this particular case, there was a lot of external
evidence that there were problems in this area, and so
we would be expecting them to be particularly focused
upon it.
MR BEER: I'm focusing on the area in between those two
things, a Board should be aware of all of the activities
that the company undertakes, I think it was the first
part of your answer, and then the last part of the
answer was: but here, there was evidence of problems
with discharge of this function.
DAME SANDRA: Yes.
MR BEER: I'm asking about the part in the middle, perhaps:
was the nature of the activity being undertaken one
which you would reasonably expect a Board to have paid
particular attention to, irrespective of whether it was
problematic, in fact, ie bringing employees or
quasi-employees before the criminal courts?
DAME SANDRA: I'm going to slightly step back and say --
still addressing the first point, which you say is
between the first and the third point, as a board
member, when you join the board of an organisation, it
is important that you understand what that organisation
142
to, and it would also have -- because of that, it would
have had a special interest, if I'd been on the Board
and understood that, it would have had a special
interest to me to understand what governance and
safeguards were being employed in that aspect of the
business.
MR BEER: Would you have wanted to know, for example, the
extent to which there was any external oversight of
those functions by, for example, a regulator?
DAME SANDRA: I imagine that that would be a question that
I would have wished to ask.
MRBEER: Thank you. Can we go back to your themes. If we
can turn to the second theme, please, which begins on
page 14. Halfway down, we've got it at the top there
“Accountability and Clarity in Board Roles, with special
reference to the identification and escalation of
serious problems".
I think you set your conclusions out about this at
the foot of page 17 and, in fact, it's just a heading on
page 17. The substance begins on page 18. From
paragraph 49, right through to 56, you address the issue
of accountability and clarity in board roles with
special reference to the identification and escalation
of serious problems.
Without going through the each of those eight or
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nine paragraphs, can you help us overall with what you
found, what your conclusions were?
DAME SANDRA: Yes. I think at the beginning of this report
we talk about the fact that board governance and
executive management are separate, and yet entirely
interdependent activities to ensure appropriate
governance of an organisation. The executive have
a responsibility to bring information to the board; the
board have a responsibility to look into the
organisation and see what they think they should know in
addition to that which the executive is bringing.
And accepting that the executive does the
operational running of the business, the board does the
‘oversight and the determination of strategy and the
other things that we've managed. So accepting that
there are differences, nonetheless, the two elements
need to work together. And we have found, I believe,
that these two elements didn't work effectively together
in order to bring relevant information into the Board,
and it's the responsibility of both of those sides.
That's the first thing.
The second thing concerns the separation between
operational, which is the executive's role, and
oversight, which is the board role. And we've --
I believe -- is it here that we say that that
145
You set out your conclusions on page 22 at
paragraph 66. You say:
"The identification of, or change in, a major risk
should quickly lead to a communication to the Board
about the risk, ideally accompanied by proposals for
Board discussion and decision about how it will be
tackled, including an outline programme of work which
would enable ongoing Board oversight. We have seen no
evidence that this was done in any of the three cases,
as information was surfacing about major risks arising
from [Post Office] past and current investigations and
prosecutions.
"The Execs did not do this either before or at the
board meeting of 16 July, on receipt of the Clarke
Advice in 2013 or in 2004 when Mrs Wolstenholme's
brought a counterclaim against the Post Office for
£180,000 ..."
Then 68:
"Relevant information in each of our three cases was
neither offered nor elicited in ways which in our view
would have represented effective communication between
the Executives and the Board ..."
DAME SANDRA: This goes back to the point I made earlier,
which is about the requirement to offer and the
requirement to elicit, and we find no evidence of that
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distinction is good, and it prevents the Board overly
interfering with what's going on in the business,
because that's the Executive job, but it does depend
upon the Board believing that performance is within
accepted bounds of acceptable, and that they've got
a good and strong Executive Team.
If they've got doubts about either of those matters,
then they need to enquire further and deeper into what's
going on. And we don't feel that, as is often -- as is
asserted in the evidence where people have said, "Well,
it was an operational matter so we weren't concerned
with that from the Board". We don't think that's
a robust enough defence for what happens because it was.
an operational matter in which there were clearly
problems.
In prosecutions there were problems as was being
evidenced by -- as we said, all the external evidence
and, with regard to Horizon, there was also evidence
that there were indeed bugs, defects and anomalies which
could call into question the robustness of the system.
Do you want add?
DR STEWARD: (The witness shook her head)
MR BEER: Can we turn to the third theme please, page 20,
the heading above paragraph 57, "Effective
communications in and around the Board".
146
being thoroughly and effectively done with regard to the
matters before the Inquiry.
MR BEER: Can we turn, please, to theme 4. The heading is
set out there above paragraph 69, "Expected experience,
development and competence of the Board and its
members". You set out your conclusions on page 26.
A sseries of conclusions right up until paragraph 90 on
page 27.
You address a range of things: experience of
individual Board members; composition of the Board; role
that the NEDs played; the NEDs' understanding of what
their role was.
You say in paragraph 90, on page 27, that you
haven't seen evidence that sufficient thought was given
to the development and operation of a unitary Board in
circumstances in which Post Office ownership changed
several times and problems with Horizon, prosecutions
and culture were surfacing in many places, but not in
the Board.
Can you expand upon or explain your conclusions
here, please?
DAME SANDRA: In the transcripts and witness statements that
we have reviewed, Non-Executives joining the Board, more
or less to a man and woman, I think, said that they were
not given explicit induction into the Post Office's
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approach to prosecutions or to any problems in relation
to Horizon. That's the first point.
The second point is that, given the changes in
ownership over this period, the issue of accountability
on who had the locus for doing what needed to be very
clearly explained, going back to very much where we
began this morning in understanding who was accountable
to whom for what in those different structures. And
it's not clear to us that that was really thought
through.
The third element is that the appointment of
non-executives was mainly, it seems to us, driven by the
need, as was seen at the time, to introduce people with
commercial experience of how to run a successful
commercial business, which would be mindful of cutting
costs, of making profit, of running it in a way in which
people understood private companies run.
The very fact that it was a commercial enterprise,
and yet with a very strong public service requirement,
indeed in the entrustment, how that was to be played out
within the Board and where the attention of the
Non-Executives was to go in relation to all those
aspects doesn't seem to have been confronted in
induction or, indeed, in the way in which particularly
the Non-Executives saw their role, which they saw as
149
DAME SANDRA: Mm.
MR BEER: Is the overall responsibility for the handling of
a company’s legal obligations and regulatory compliance
normally dealt with by the company secretary?
DAME SANDRA: At an administrative level, that is certainly
the case. That is keeping all the records, maintaining,
as is said there.
You'll note that it says "working with the chair to
ensure that all board members are aware of their duties
and powers", and working with the chair on the board
agendas. So the relationship -- the company secretary
cannot be said to be solely and singly responsible for
all that compliance, that is ensuring the compliance,
but if he or she were to notice that the board was
non-compliant, then she would have a duty to identify
that.
MRBEER: Where, as between a company secretary and, if the
company has one, a general counsel, does overall
responsible for regulatory compliance sit?
DAME SANDRA: Well, the general counsel, as I think I said
this morning, is not formally identified in the Codes of
Governance, as we've identified here.
MR BEER: Just stopping you there. It's right, is it, that
there is not any legal requirement for a company such as
the Post Office, whether under the Companies Act or the
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mainly offering commercial expertise and advice and,
indeed, their backgrounds were very much from that —-
from that background.
(To Dr Steward) Do you want to add?
DR STEWARD: No.
MRBEER: Can I ask you about the role of the company
secretary in this regard. Can we just go back to your
first report, please, and page 29. It'll come up.
At the foot of the page, paragraph 2.2.33, you tell
us that:
"[The] company secretary is an officer who is
appointed by the directors to advise the board on all
governance matters and codes. They will normally seek
to ensure compliance with company's legal obligations.
Accountability is to the Board and to the Chair to
ensure that all appropriate governance measures are
brought to the board's attention. As regards
functioning of the Board, they are technically
independent of the CEO and accountable to the Chair. As
an executive colleague (and in a sense subordinate to
the CEO) they need a very good working relationship with
the CEO, who is likely to be very influential in their
relationship."
Then you set out a company secretary's
accountabilities over the remaining five paragraphs.
150
Code, to have a general counsel?
DAME SANDRA: There is no requirement.
MR BEER: Sorry, I interrupted you. I probably interrupted
your chain of thought.
DAME SANDRA: So as there isn't that requirement, you can't
say, well, what is that split between the company
secretary and the general counsel?
MR BEER: If the company does have one, as this one did,
where does responsibility for regulatory compliance
reside as between those individuals.
DAME SANDRA: I think that the role of the company secretary
can be kept separately from the role of the General
Counsel. I think the fact that you may have a general
counsel does not alter the requirements of the Company
Secretary, unless there was some specific agreement
about the way in which these relationships and duties
were to be performed, which would be very formally laid
down and may therefore lead to some change. But I don't
think that an occasional "Do we have a general counsel
or not" can impact on the duties of the company
secretary. That's my view, although -- yes, that's my
view.
MR BEER: In terms of the role of the general counsel, is
the general counsel normally accountable to the board or
to the CEO?
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DAME SANDRA: I think, again, you might find particular
arrangements. It's normally the case that the general
counsel for what one might say, sort of, pay and rations
administratively is going to work to the chief
executive, especially if the general counsel also has
other responsibilities, which are to do with their
functional responsibilities for -- in the case of the
Post Office, for the legal teams, and for other
elements.
Indeed, as you will be aware, the General Counsel,
until the day after the Board meeting of 16 July, also
had responsibility for HR, which would mean that she was
definitely working to the Chief Executive.
Having said all that, the normal expectation is that
the general counsel would have at least an informal
dotted line to the chair and to the board, so that if he
or she felt that they had a matter which was germane to
their legal position, which the chief executive either
didn't understand or wasn't interested in, that they
would be able to take that indeed to the board and to
the chair.
So how these relationships actually work out is
going to depend upon the way in which the organisation
works. What one can't do, and although I'm not
an expert on it, one can't take away from the general
153
consistent in their views. Their main rule was to
instil commercial disciplines to improve performance.
Your analysis of those two cases in 2013 illustrates
situations where the culture and conduct of the Board
did not encourage the Board in effective prioritisation,
discussion and decision making about what Post Office
should do with regard to past prosecutions and with
future prosecutions, policy and practice.
This is under the heading of I think "Culture". Why
is this relating to culture or board culture?
DAME SANDRA: I think it goes back to the earlier questions
of what were the -- culturally, what were the things
that were pre-occupying the Board and how did the Board
also behave? So, culturally, we have seen these
dominance ideas of Horizon's robust; prosecutions are in
the public interest; subpostmasters occasionally are
subject -- are guilty of wrongdoing; and we must defend
‘our public position.
And that prior -- that set a context in which one
approached or they approached past prosecutions and
future prosecutions policy and practice. And even
though there were indications that this was an area
which needed their strong attention, they didn't focus
upon it.
We've also seen how, in the particular Board meeting
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counsel's requirements as a qualified lawyer to meet
certain professional obligations.
MR BEER: Do you know, in fact, whether there is
a requirement for general counsel to hold a practising
certificate or even for a general counsel to be
a qualified lawyer?
DAME SANDRA: I personally do not. I'm not aware of that.
It's not an area of my expertise.
MR BEER: Thank you. I won't ask you the questions that
follow from that.
Can we go back to theme 5, please, in Report 2,
which is page 29 in Report 2.
Your conclusions here are addressing theme 5, which
is whether there was a Board culture supportive of
effective discussion and decision making.
You say that you have seen how Post Office's
governance structures were still developing in 2013.
The Executives were inexperienced in working with NEDs
and running an independent company.
Earlier in 2004, the Post Office was still
a subsidiary of Royal Mail Group and had only one-year
experience of working with a Non-Executive Chair. The
first NED to join the Chair was only appointed in that
year.
The NEDs appointed at different times were
154
of 16 July, issues that were available to the Board were
clouded over by the Non-Executive irritation with the
way in which the Second Sight work had been handled, and
they were not then brought into a focused discussion by
the Chair. That's why we have identified that in terms
of conduct and culture.
MR BEER: Thank you. You address theme 6, "Policy and
practice for handling conflicts of interest", from
paragraph 98 onwards, and set out your conclusions at
paragraph 108, at the foot of page 31.
I think there is nothing additional in that
paragraph beyond which you leave mentioned already; is
that right?
DAME SANDRA: Yes.
MRBEER: Thank you. Theme 7 starts over the page, and this
is moving from Board to Executive; is that right?
DAME SANDRA: Yes.
MR BEER: The last three themes, 7, 8 and 9, are all to do
with the Executive, the first of which is "Structures
and relationships", and you set out your conclusions on
this issue at paragraph 116 at the foot of page 33. You
say:
"The case studies featured in the report suggest
a number of obstacles to effective Executive teamworking
and collective accountability."
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Over the page, thank you:
"It is the CEO's responsibility to make appointments
to senior exec positions of individuals who have the
experience and skills to enable the CEO to delegate
responsibility ... the CEO cannot absolve themselves
from responsibility on the basis they have delegated or
they are not an expert in any field. They have
a responsibility to create relationships with their
executive colleagues so that, whilst not an expert in
every field, they can rely on and invite their
colleagues to keep them informed of major matters. This
is especially important if the colleague is not a Board
member nor is regularly in attendance at the Board."
Are you referring there to the General Counsel?
DAME SANDRA: I am.
MR BEER: You say, if we scroll down, please, at 120, that
you found very little evidence that the group of Senior
Executives in Post Office felt they were working as
a team in any of the three cases featured in the report.
So that's across the three case studies; is that
right?
DAME SANDRA: Yes.
MR BEER: Then over the page, please, at 123, you say:
"The Second Sight and Simon Clarke cases suggest
a strained relationship between the CEO and the General
157
we think we have illustrated in relation to the case
studies -- and of course the case studies are only
illustrations, and as we've said, we've selected them
but there may be other evidence of which we're not --
which we did not review -- but it seems to us that that
compound effect -- there were strained relationships,
there were structural silos asserted. There was a CEO
who said sometimes that she was not an expert in that,
or that she was not aware of certain matters, and yet
she could have been, had she asked the Executives
responsible for them, to contribute in a stronger way to
a collective Executive understanding.
That's especially difficult if any member is not
a member of the Board, then it's the CEO's special
responsibility to be able to understand sufficient about
that area to be able to represent it to the Board.
So a combination of these effects meant that the
effective role of Executive management and organisation,
that one part of the governance which interrelates with
the Board, worked suboptimally.
MR BEER: Thank you. Can we turn to theme 8, which is
identified in the heading that's on the page there
“Performance and capability", and turn to your
conclusions on page 36 at paragraphs 128 and 129. You
say:
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Counsel, as well as between the Chair and the General
Counsel.
"... problems and dysfunctions in the way the CEO
operated with some of their Senior Executive colleagues,
and the apparent lack of an effective Executive Team
taking collective responsibility, which were revealed in
[those two cases] are a reflection of the compound
impact of strained relationships, structural silos,
a CEO who did not see her role as needing to be closely
in touch with the all areas of the business and the fact
that the GC was not a member of the Board.”
Again, that's quite the list.
DAME SANDRA: Mm-hm.
MR BEER: On my imaginary spectrum -- and you and perhaps
even me don't know the beginning and the end of it --
where does the list of issues that you have identified
there sit in the spectrum of seriousness? If you're
more content to simply say this was or was not a failure
in governance, then please do say so.
DAME SANDRA: As we've explained, governance isn't a cup of
water which is either fallen -- either broken or not.
I mean, it is a cup of water, which may be beautifully
overfilling with beautiful water or it may lose bits
along the way. And what we've identified there is the
problems that can arise within an Executive Team, which
158
it is the role of the board to challenge and
support the executive unless there is consensus amongst
the NEDs that there are sufficient concerns about
executive performance to conclude there should be
a change at the top.
"Boards and shareholders can find themselves at
a pivot point between continued support and time to plan
for executive exit. One cannot, in our view, sustain
a long period of ‘half support’ or ‘half exit. Having
got to such a point it would be usual to follow through
on the expressed concerns with a view to clearly
demonstrated improvement, or to put in place succession
plans about an exit."
What are you referring to, or to whom are you
referring here?
DAME SANDRA: I don't know if it is in this evidence, I'm
afraid I can't recall where we talk about it. UKGI had
identified that there were concerns, both by the Board
and by UKGI, about the performance of the Chief
Executive. They were raised at a committee in UKGI,
they went for review. The review concluded that there
were problems, both with regard to the fulfilment of the
strategy and with regard to the capacity to form
effective relationships within the Executive Team,
especially if they were with people whom the Chief
160
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Executive found to be challenging. I think I've got
that right.
And we also heard in testimony, in oral evidence,
from the Non-Executive Directors that there'd been some
concerns about -- there were certainly concerns about
the General Counsel but there were also concerns about
the Chief Executive. And so concerns raised, they took
them to a particular point. In fact, UKGI undertook
an exercise with an external headhunter to see what
would be in scope for -- if the Chief Executive were to
be replaced.
In fact, it was decided that she shouldn't be
replaced -- it seems to us largely on the basis of the
fact that she wasn't doing that badly and, also, that it
was difficult to find a replacement for the given
salaries.
To us, that -- how you leave that, and we -- perhaps
we haven't seen all the evidence, but how you leave that
is unsatisfactory from a board perspective because
you're neither concluding that everything is fine, nor
are you concluding that everything is awful. And that
creates tensions, which we haven't looked at because
this is post-2013, but it creates an unsteadiness in the
board.
Do you want add anything?
161
But it wasn't a wholesome and wholehearted endorsement.
MR BEER: Can we turn to theme 9, please. It's identified
in the heading there, "Organisational culture", and you
set out your conclusions on page 39 in relation to this,
through to page 41.
At 138, you say that:
"Horizon represented a huge investment and change in
operations. By its scale and nature, it inevitably
posed risks ... if only from popular public discourse
about other large-scale system changes in public
services, people involved in the commissioning and
rollout of Horizon, its various guises, would have been
likely to countenance that serious problems may arise
during its commissioning and operation ...
"By any normal analysis of major system change,
subpostmasters were very important end users. They were
in the frontline of customer public service
have been normal ... to listen, learn from and follow up
‘on subpostmasters' views and experiences
In paragraph 140, you say it seems to you that the
culture of Post Office did not encourage listening or
learning from subpostmasters. The nature of their
contract with the Post Office and their experience of
Post Office investigation and audit teams seems to be
part of the company ethos in which subpostmasters were
163
would
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MR BEER: So if we just scroll up to paragraph 127, you were
rightly remembering the evidence of January 2014, where
UKGI or ShEx was considering the suitability of Paula
Vennells to remain as CEO. And I think you've had drawn
to your attention some other material that exists --
DAME SANDRA: Yes.
MR BEER: -- showing continued consideration of that issue
well into 2014, including discussions with the
Minister's office, Jo Swinson's private office,
including a speaking note about what might be said to
the Minister about Paula Vennells --
DAME SANDRA: Mm-hm.
MR BEER: -- including email exchanges about what the
minister might be told about ShEx's view of Paula
Vennells, and the tender document that you've just
mentioned --
DAME SANDRA: Mm.
MR BEER: -- for essentially recruitment consultants to go
out and recruit a new CEO.
Does any of that alter the substance of what you say
in paragraphs 128 and 129?
DAME SANDRA: We were left with the view, even having
reviewed that, that it still seemed to be half support.
Perhaps it wasn't half exit because the half exit had
not -- proved not to be a viable avenue in their view.
162
taken for granted and seen as insignificant. Then
paragraph 141:
"The report was an opportunity for the Board to see
that it was important to hear and listen to
subpostmaster experiences of working both with Post
Office and with Horizon and their voices remain
unheard."
Then if we go on to paragraph 144, just at the foot
of the previous page:
"The Board's handling of the report, it is striking
that no member of the Executive of the Board asked out
loud what is the right thing to do about the
subpostmasters who were suffering so much and are
protesting their innocence?
"So deep were the assumptions embedded in the
culture of the organisation, so corrosive was the
company ethos, that the Board did not call the Executive
to account to face up to the Post Office's role in
perpetuating miscarriages of justice, which were
increasingly evident to others. Failure to uncover and
correct the dark spots in the culture is a failure of
management and governance.”
I think they're probably the strongest words that
you use in the course of this report; would I be right?
DAME SANDRA: Mm, yes. Would you like me to expand?
164
(41) Pages 161 - 164
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MRBEER: Well, if you can explain, yes.
DAME SANDRA: Yes. And they're strong because the issue of
the culture of the Post Office, with its perceptions, as
we've said several times, about what Horizon was, what
subpostmasters' role and approach was, and what the
public duty of the Post Office was, created such
a strong sense of what was right in the organisation
that they found it impossible, apparently, to really
hear, in 2013, that people were talking about, and had
bits of evidence about, miscarriages of justice,
wrongful prosecutions, and an arrogant and defensive
approach. It was as if they somehow couldn't be heard.
And so we conclude on that note because we do think
that it actually underlies a lot of the matters that
we've been discussing today.
Perhaps before I ask Dr Steward to also comment,
I say that at the beginning of these conclusions, we say
even if you don't take account of these moral cultural
points that we're making, actually, having a major
systems development, putting in new systems, one of the
basic points that we understand is that you find out
from the end users what's actually happening, because in
these complex systems, the end user, the facing to the
public, is the place where the system is experienced
absolutely at the frontline.
165
Those are the questions that I ask. Thank you very
much for answering all of them.
Can we take a break now, sir, until tomorrow. There
are questions from Core Participants and it will give
them an opportunity to formulate them. I would ask,
however, we start at 9.30 to ensure that we finish by
12.30.
SIR WYN WILLIAMS: Fine. Can you just give me an idea of
how many sets of questioners there are?
MR BEER: There are five sets of questioners: the Hodge
Jones & Allen Core Participants; the Howe+Co Core
participants; the Hudgells Core Participants; the
National Federation of SubPostmasters; and the
representatives of Paula Vennells.
SIR WYN WILLIAMS: You'll agree with counsel suitable time
estimates for each of them?
Can I say now, since it's something that concerns
me, I would strongly take the view, I think, that
questions from Ms Vennells' advocate should come last
because I suspect, though I don't know, that questions
from most other people will be with a view to making
things worse for the Post Office, whereas questions from
Ms Vennells may be to opposite effect, and I think she
should know the full scale of what's being said before
she asks her questions.
167
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So even if you didn't take the moral and ethical
matters that we're addressing at the end, you would say,
from an instrumental management effectiveness approach,
you'd want to listen and learn from what was going on at
the frontline. And in 2013, and indeed in 2004, I think
that should have been understood. So there was an
instrumental reason, as well as our conclusion on the
moral reason.
But on the cultural matter --
DR STEWARD: Well, just that sort of topping and tailing
that is that the Board should ask questions about the
culture. They can't know the culture in the way the
Executive can know it, they can't shake the culture in
exactly and precisely the same way that the Executive
and the Management Team can, but the Board and the
non-executives' question, particularly with everything
that is going on around it, should be asking questions
about what is the ethos of this organisation and what is
the culture of this organisation.
If you look across the three case studies, there
are, if you like, examples in all of them where there
is -- we use the word "insignificant" or an indifference
to the experiences of subpostmasters, and that appears
to be part of the culture.
MR BEER: Thank you.
166
I said that's a strong view. I'm always open to
persuasion, but that's what I currently think.
MRBEER: Thank you very much, sir.
‘SIR WYN WILLIAMS: Now, then, how do I direct a witness
about not talking to anybody when there are two of them?
MR BEER: I hadn't addressed that.
‘SIR WYN WILLIAMS: I think you can talk to each other.
MRBEER: Thank you very much.
SIR WYN WILLIAMS: See you tomorrow morning.
(4.11 pm)
(The hearing adjourned until 9.30 am the following day)
168
(42) Pages 165 - 168
The Post Office Horizon IT Inquiry 12 November 2024
INDEX
PROFESSOR DAME SANDRA JUNE NOBLE DAWSON (affirmed)
DR KATY MARY STEWARD (affirmed) ..
Questioned by MR BEER ...
169
(43) Pages 169 - 169
DAME SANDRA:
[345]
DR STEWARD: [33]
1/13 4/5 4/8 6/16 6/20}
8/25 9/3 9/7 9/11
58/23 67/2 67/10 68/2
73/16 74/13 113/9
117/9 121/8 122/22
128/9 132/7 132/11
133/11 136/8 137/9
138/9 139/6 141/1
141/4 143/12 146/22
150/5 166/10
MR BEER: [368]
SIR WYN WILLIAMS:
[16] 1/14 1/20 1/23
4/16 5/1 37/18 37/23
49/19 49/23 50/11
85/5 167/8 167/15
168/4 168/7 168/9
S$
$50,000 [1] 81/21
43 [1] 119/24
"93 [1] 12/4
"94 [1] 12/4
"95 [1] 25/7
"98 [2] 25/7 51/4
‘Alleged [1] 100/1
‘black [1] 91/13
‘bugs’ [1] 91/24
‘defects' [1] 91/24
‘half [2] 160/9 160/9
‘independent’ [1]
80/2
‘no [1] 76/20
‘should [1] 59/16
"special [1] 28/21
‘special/individual [1]
28/21
‘the [1] 65/23
‘to [1] 100/8
1
1 hour [1] 37/15
41 July [5] 76/24
100/12 101/7 102/18
104/24
4 million [3] 57/19
59/22 64/4
1's [1] 34/17
1.0 [1] 51/4
1.1 [1] 12/7
1.2 [2] 24/10 24/11
1.2.1 [1] 26/2
1.2.3 [1] 26/17
1.2.4 [1] 27/8
1.25 [1] 28/18
1.3.1 [1] 29/10
1.4.1 [4] 30/7
1.45 [3] 85/4 85/5
85/8
1.6.11 [1] 36/25
1.6.2 [1] 30/25
1.6.4 [4] 32/10
1.6.8 [1] 33/23
1.6.9 [1] 34/10
1.8 [2] 12/24 12/24
10 [4] 29/9
10.07 [1] 1/2
10.15 [1] 5/4
10.20 [1] 5/6
100 [2] 12/23 109/8
103 [1] 111/16
105 [1] 114/5
108 [2] 76/2 156/10
109 [2] 117/17
117/20
44 [2] 34/11 138/13
11 November [2]
3/19 4/13
11 years [1] 7/16
11.15 [1] 37/20
11.30 [2] 37/17 37/22
112 [2] 35/3 35/5
114 [1] 5/10
116 [2] 119/23
156/21
417 [4] 123/25
12 [2] 1/1 24/16
12-year [1] 34/11
12.30 [1] 167/7
12.45 [1] 85/6
120 [1] 157/16
123 [1] 157/23
127 [1] 162/14
128 [3] 124/5 159/24
162/21
129 [2] 159/24
162/21
13 [3] 20/2 138/12
139/1
13 pages [1] 24/16
131 [3] 6/24 8/19
129/7
132 [4] 8/20
133 [1] 3/20
133 pages [1] 3/5
134 [4] 133/8
135 [1] 134/6
137 [1] 134/7
138 [1] 163/6
14 [2] 136/14 144/14
140 [1] 163/20
141 [2] 135/9 164/2
143 [1] 137/12
144 [1] 164/8
15 [2] 30/23 37/15
150 [2] 55/19 55/20
154 [1] 6/7
154 pages [1] 3/7
155 [1] 56/3
16 [4] 97/16 104/18
105/5 108/25
16 July [11] 77/6
77/8 79/24 93/24
94/12 104/15 109/7
124/16 147/14 153/11
156/1
16 June [1] 121/15
160 [1] 56/4
161 [1] 56/8
162 [1] 57/15
163 [1] 58/6
164 [1] 58/24
165 [1] 59/8
168 [1] 60/5
169 [1] 60/6
17 [2] 144/19 144/20
17 July [2] 118/21
119/3
170 [1] 61/6
171 [1] 61/6
172 [1] 61/18
176 [1] 5/14
418 [1] 144/20
180,000 [1] 147/17
180k [1] 56/1
187 [1] 65/19
188 [1] 65/24
193 [3] 66/5 66/6
70/13
194 [1] 67/11
195 [2] 68/18 70/1
196 [3] 66/6 70/3
70/13
198 [1] 71/14
1990s [2] 50/15
51/23
1992 [1] 25/6
1994 [1] 19/11
1995 [2] 7/16 12/8
1996 [2] 50/16 51/2
1998 [3] 12/2 51/1
51/4
1999 [9] 10/25 16/3
18/17 33/14 33/22
35/12 35/12 52/2
52/14
2
2.0 [4] 51/4
2.1 [1] 12/7
2.2 [1] 39/3
2.2.33 [1] 150/9
2.3 [2] 12/24 13/10
2.4 [1] 43/22
2.47 [1] 123/19
2.5 [1] 43/23
20 [3] 24/16 36/24
146/23
20 years [1] 25/23
20-year [1] 33/15
2000 [5] 10/4 35/12
36/1 49/21 50/2
2001 [6] 13/17 13/22
33/22 36/1 37/6 46/18
2003 [2] 46/14 46/22
2004 [9] 21/6 21/9
21/9 57/21 57/24
75/12 147/15 154/20
166/5
2005 [2] 13/2 13/16
2006 [3] 7/16 12/2
12/8
2007 [1] 63/18
204 [1] 72/22
2010 [2] 25/14 26/21
2012 [1] 76/10
2013 [27] 19/13
19/15 20/21 21/6 21/9}
21/10 34/16 46/18
75/25 78/8 81/4 100/6
101/7 108/19 115/3
115/15 117/19 118/19}
124/3 139/18 139/22
147/15 154/17 155/3
161/23 165/9 166/5
2013-14 [1] 136/14
2014 [2] 162/2 162/8
2015 [1] 119/25
2019 [5] 10/25 16/3
18/17 33/14 34/16
2024 [9] 1/1 3/5 3/7
3/18 4/12 9/22 9/24
20/20 115/3
203 [4] 74/10
205 [2] 71/14 74/21
21 [2] 38/1 38/2
212 [1] 76/4
214 [2] 76/4 76/23
217 [2] 78/5 78/8
22 [2] 39/12 147/1
222 [1] 5/21
23 [1] 138/24
23 January [1] 100/5
238 [2] 79/19 79/20
239 [1] 80/25
24 [1] 39/14
240 [1] 81/3
241 [2] 82/3 82/8
242 [2] 79/20 82/23
25 [1] 25/13
25,000 [1] 55/23
26 [1] 148/6
26 March [3] 3/5 3/18}
9/21
262 [1] 85/17
264 [1] 87/17
265 [1] 90/14
266 [1] 91/19
268 [1] 93/21
269 [1] 94/10
27 [4] 39/17 40/17
148/8 148/13
270 [1] 95/1
271 [1] 85/17
284 [1] 95/22
285 [1] 95/23
287 [1] 96/16
288 [1] 97/25
29 [3] 39/21 150/8
154/12
29 October [2] 3/7
4/12
3
3 July [2] 118/13
118/22
3's [1] 34/19
3.00 [2] 123/17
123/21
30 [3] 39/6 43/19
138/24
30 pages [1] 117/20
30 years [1] 8/24
302 [2] 99/21 99/23
303 [1] 101/6
304 [2] 99/22 102/2
31 [3] 139/2 139/7
156/10
310 [1] 103/1
311 [4] 103/20
312 [4] 103/1
323 [1] 104/21
325 [1] 107/4
327 [4] 107/22
33 [3] 4/15 5/9
156/21
346 [1] 109/3
35 [4] 38/2
36 [2] 44/24 159/24
370 [1] 6/2
375 [4] 109/9
377 [4] 110/7
378 [1] 110/14
389 [4] 111/16
39 [1] 163/4
396 [1] 114/5
397 [1] 114/18
399 [4] 116/6
4
4.114 pm [1] 168/10
4.16 [1] 119/9
4.2.10 [1] 46/13
4.2.9 [1] 46/13
400 [2] 116/7 116/11
41 [1] 163/5
412 [1] 117/21
42 [2] 54/19 55/10
43 [1] 55/19
438 [1] 119/22
439 [1] 121/18
44 [1] 56/3
447 [1] 122/7
448 [2] 119/22 122/7
45 [2] 56/4 56/8
47 [1] 45/20
48 [3] 5/14 46/12
62/11
483 [1] 124/5
49 [1] 144/21
490 [2] 129/8 129/10
491 [3] 129/9 129/10
131/15
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5
5.1.2 [1] 47/13
50 [4] 63/12
50 years [1] 1/16
500 [1] 133/8
502 [2] 133/20
133/20
503 [1] 133/8
51 [1] 65/17
535 [1] 135/10
537 [1] 136/9
54 [2] 45/23 55/10
55 [2] 47/11 76/1
56 [3] 76/5 77/16
144/21
57 [3] 76/5 78/6
146/24
58 [2] 78/5 78/9
6
6.2.2 [1] 50/13
60 [4] 5/21
63 [2] 48/21 50/13
65 [1] 79/19
66 [1] 147/2
68 [1] 147/18
69 [4] 148/4
7
7.4.3 [1] 52/12
70 [2] 51/21 85/14
75 [2] 95/20 99/22
76 [1] 99/20
77 [2] 53/13 53/13
go
8 July [6] 77/3
101/21 102/24 105/12}
105/18 118/18
80 [4] 99/22
82 [1] 102/25
83 [1] 102/25
86 [1] 104/22
9
9 April [1] 9/24
9.30 [2] 167/6 168/11
90 [2] 148/7 148/13
92 [2] 53/13 109/2
93 [4] 11/19 12/6
14/17 51/3
94 [2] 14/11 14/25
98 [1] 156/9
99 [2] 6/1 13/24
A
abided [1] 40/13
able [8] 19/25 119/16
120/8 126/14 134/10
153/20 159/15 159/16I
about [136] 1/18 2/11
2/15 5/23 9/25 13/14
13/25 14/2 14/18
14/19 17/17 23/4
23/20 26/18 34/17
35/19 38/8 42/20 45/4
47/3 48/23 49/15
49/23 51/20 52/25
56/15 56/22 57/18
57/21 59/24 60/3 61/6)
64/11 66/15 67/17
67/24 68/1 68/9 68/9
69/7 69/11 71/23 72/5)
72/11 72/23 73/9 74/9)
74/9 78/16 78/23
78/24 80/16 80/17
88/4 89/20 90/11
90/17 91/2 91/4 91/5
94/3 94/4 96/25 98/12
100/14 100/17 101/19)
102/20 103/4 103/7
107/10 107/16 109/8
110/25 111/24 112/25)
113/23 113/25 114/9
114/15 115/6 116/12
116/16 118/15 121/21
121/21 122/4 126/7
126/7 126/8 126/13
126/17 128/22 132/2
133/10 133/24 134/1
135/21 135/24 136/20)
138/17 138/23 142/15)
143/13 143/18 143/19)
144/18 145/4 146/7
147/5 147/6 147/10
147/24 150/6 152/16
155/6 159/15 160/3
160/13 160/17 160/19)
161/5 161/5 161/6
162/10 162/11 162/13)
162/14 163/10 164/12)
165/4 165/9 165/10
166/11 166/18 168/5
above [10] 30/25
32/14 42/17 65/12
104/2 110/2 110/2
110/4 146/24 148/4
absence [3] 66/2
103/24 105/16
absent [2] 43/11
43/12
absolutely [6] 23/18
28/6 78/3 99/4 132/11
165/25
absolve [3] 65/15
92/19 157/5
academic [4] 7/9
7/20 17/15 31/22
accept [4] 88/14
88/16 88/20 117/14
acceptable [1] 146/5
acceptance [1] 81/19
accepted [11] 24/1
29/11 49/16 66/23
66/24 69/5 81/4 81/12
114/24 135/18 146/5
accepting [3] 38/24
145/12 145/15
accessible [1]
103/10
accompanied [2]
105/2 147/5
accompany [1] 95/2
according [3] 22/23
58/25 108/6
account [14] 6/11
6/18 25/1 25/2 33/12
38/25 44/10 44/18
45/12 45/13 76/25
133/25 164/18 165/18}
accountabilities [4]
39/4 39/15 40/11
150/25
accountability [25]
31/1 31/4 31/20 31/24
32/11 32/25 33/11
33/18 36/15 36/17
38/3 38/6 38/12 38/17
38/20 38/22 39/2 39/7
40/3 64/19 144/15
144/22 149/4 150/15
156/25
accountable [10]
31/9 31/13 36/16 38/7
38/11 38/16 38/16
149/7 150/19 152/24
accountably [1]
30/16
Accounting [1] 13/25
accounts [2] 109/21
116/25
achieved [1] 10/13
acknowledge [1]
126/2
acknowledged [1]
130/16
acronym [1] 5/18
acronyms [1] 32/4
across [25] 12/1
20/20 27/19 31/15
33/14 33/18 34/8
34/25 36/1 36/8 36/13)
40/24 54/21 57/7
86/20 86/22 93/6
112/6 112/25 113/6
113/9 133/12 140/14
157/20 166/20
act [12] 12/13 14/23
23/23 50/16 50/19
51/1 51/2 51/5 51/7
56/19 129/14 151/25
acted [3] 61/20 70/4
124/14
action [6] 57/12
92/19 118/23 124/10
124/14 128/23
actions [5] 21/20
39/1 87/2 99/16 119/7
active [2] 32/21
44/17
activities [5] 142/9
143/2 143/2 143/6
145/6
activity [6] 29/18
45/6 141/15 141/17
141/19 142/16
actors [3] 106/18
106/22 111/14
Acts [1] 12/8
actually [10] 9/25
47/2 63/1 74/13
121/19 138/14 153/22}
165/14 165/19 165/22)
add [19] 14/11 58/21
66/25 71/3 74/12
94/16 117/8 121/7
128/8 133/9 133/11
135/22 136/7 137/8
138/6 143/13 146/21
150/4 161/25
added [4] 63/14 97/3
143/23 143/24
addition [3] 7/20 53/2!
145/11
additional [3] 18/21
96/23 156/11
address [11] 2/19
14/20 39/14 45/21
55/6 62/16 108/20
129/20 144/21 148/9
156/7
addressed [12] 2/15
2/17 54/12 62/23
98/15 112/21 125/2
130/24 131/14 132/5
132/6 168/6
addresses [2] 44/24
106/9
addressing [6] 66/7
111/16 129/10 142/22
154/13 166/2
adduce [1] 138/15
adhere [1] 24/1
adjourned [1] 168/11
Adjournment [1]
85/7
administration [1]
86/6
administrative [2]
96/25 151/5
administratively [1]
153/4
adopt [2] 2/2 86/4
adopted [1] 11/14
Adrian [1] 44/15
advance [1] 101/11
advantage [1] 80/1
advice [45] 17/11
17/19 19/14 55/2
72/20 117/18 117/23
118/5 118/13 118/17
118/20 119/3 119/10
119/21 120/1 120/14
120/19 121/9 121/17
121/19 122/21 122/22)
124/3 124/8 124/15
124/19 126/3 126/23
127/4 127/5 127/13
128/1 128/19 128/20
130/9 131/3 132/20
134/14 136/4 136/5
136/18 137/16 137/23)
147/15 150/1
advices [2] 122/6
132/9
advisable [1] 28/23
advise [2] 72/17
150/12
advised [1] 8/22
adviser [2] 88/25
89/15
advisers [1] 122/19
advocate [1] 167/19
affairs [2] 111/21
116/19
affect [1] 94/21
affirmed [4] 1/5 1/6
169/2 169/4
aficionados [1] 35/11
afraid [2] 27/22
160/17
after [10] 5/18 11/20
16/15 26/23 43/18
77/8 100/20 106/8
122/2 153/11
afternoon [3] 85/9
85/10 123/16
again [16] 4/12 33/21
34/7 44/25 45/21
A7IN7 51/22 53/14
106/13 106/15 112/19}
117/20 119/18 133/20)
153/1 158/12
against [3] 59/9
104/5 147/16
agency [1] 46/17
agenda [5] 98/21
98/22 99/4 101/10
115/20
agendas [1] 151/11
agree [5] 7/5 97/1
136/24 140/9 167/15
agreed [6] 2/18 98/21
99/16 124/12 124/20
134/18
agreement [5] 72/11
79/1 97/5 98/18
152/15
agrees [2] 2/23 2/23
AGS [1] 32/21
Ah [4] 28/10 31/23
69/21 141/3
ahead [2] 48/14
48/16
aim [1] 2/25
airing [1] 61/13
Albeit [1] 50/12
alert [3] 80/5 102/16
108/2
alerted [3] 58/4
(45) 5.1.2 - alerted
A
alerted... [2] 100/10
100/25
Alice [4] 96/2 97/25
98/2 99/12
all [58] 4/24 5/1
11/11 14/18 42/12
47/20 47/23 65/12
71/3 73/18 79/8 79/14,
86/9 87/3 89/20 90/18
92/6 92/15 92/24 93/4
96/7 98/18 101/1
101/4 105/20 108/14
115/17 120/14 120/19)
124/20 127/5 127/7
127/9 127/18 127/18
133/12 136/22 138/1
138/2 138/18 139/12
139/24 141/21 141/21
142/9 146/17 149/22
150/12 150/16 151/6
151/9 151/13 153/14
156/18 158/10 161/18
166/21 167/2
allegations [2] 89/20
89/22
alleged [6] 76/10
143/15 143/16 143/18}
143/19 143/20
Allen [4] 167/11
allow [1] 44/13
alluding [1] 143/25
almost [2] 122/16
124/25
alone [1] 71/7
along [2] 35/20
158/24
already [5] 23/12
41/10 71/5 72/23
156/12
also [43] 3/1 9/8 17/3
22/17 37/11 38/14
38/19 42/19 42/25
47/8 49/11 51/16 52/5)
59/19 61/13 61/25
64/5 78/15 89/4 89/9
89/12 92/21 93/2
107/4 107/8 110/4
112/13 114/25 115/20
121/24 126/5 127/9
130/18 144/1 146/18
153/5 153/11 155/14
155/25 161/3 161/6
161/14 165/16
alter [2] 152/14
162/20
alternative [1] 18/22
although [10] 48/22
60/11 70/4 82/17 89/6
118/20 128/19 129/25
152/21 153/24
Altman [2] 132/7
143/7
altogether [1] 116/4
always [7] 48/3 48/4
50/24 60/10 84/2
129/16 168/1
Alwen [1] 121/25
am [19] 1/2 5/4 5/6
11/17 18/9 27/22
36/15 36/21 37/20
37/22 38/7 38/9 38/10
38/15 98/16 103/14
115/2 157/15 168/11
amalgamated [1]
27/3
amended [1] 51/1
amendments [2] 5/9
91/23
amongst [2] 109/23
160/2
amount [3] 17/16
21/22 99/24
amounts [1] 109/18
anachronistically [1]
143/7
analysis [10] 18/7
20/7 21/16 55/10 76/1
94/19 114/21 137/14
155/3 163/15
angry [1] 111/24
Annex [12] 10/23
11/7 11/17 14/7 15/19)
17/7 25/21 35/2 37/2
37/5 53/18 53/19
Annex A [8] 10/23
11/7 11/17 14/7 15/19)
25/21 37/2 53/18
Annex B [3] 35/2
37/5 53/19
annoyance [2]
109/14 110/2
annoyed [2] 112/10
113/23
annual [4] 28/19 29/6
44/12 44/12
anomalies [2] 90/6
146/19
another [6] 1/24
12/22 48/7 52/22
137/4 141/7
answer [9] 2/20 2/21
55/15 65/14 81/1
99/10 111/22 142/11
142/12
answered [1] 111/23
answering [1] 167/2
answers [3] 2/23
61/2 69/24
anticipated [1] 95/9
any [53] 4/19 9/22
9/24 16/19 17/19
18/10 18/15 18/15
30/14 36/11 42/10
43/2 43/4 54/21 62/6
70/23 72/16 81/4 84/3)
89/19 89/24 92/11
92/24 93/12 96/3
96/13 96/13 97/15
100/4 100/9 100/24
103/15 107/11 125/3
125/4 125/10 125/17
128/8 130/2 130/22
132/5 132/19 135/14
143/15 144/8 147/9
149/1 151/24 157/7
163/15
anybody [1] 168/5
anything [18] 58/21
66/25 74/12 94/6
95/11 100/21 100/22
108/9 117/8 120/11
133/9 135/22 136/7
138/6 161/25
anyway [2] 58/1 58/3
apart [2] 43/16 76/17
apologise [1] 16/10
apparent [2] 98/3
158/5
apparently [3]
121/11 127/17 165/8
appeal [2] 119/16
119/17
appealing [1] 32/3
appear [5] 22/15
63/22 82/15 87/18
119/21
appeared [5] 79/11
87/25 113/18 113/19
115/24
appears [8] 4/21
66/23 67/10 91/19
113/24 116/11 120/20}
166/23
appendices [2] 3/6
3/8
Appendix [4] 28/8
30/13 31/11 31/16
Appendix A [2] 28/8
30/13
Appendix B [2] 31/11
31/16
applicable [1] 37/9
applied [5] 10/25
12/9 16/20 29/23
33/18
apply [8] 11/3 11/24
28/11 28/13 28/16
30/4 42/10 73/11
applying [1] 34/7
appointed [6] 41/2
69/3 76/9 150/12
154/23 154/25
appointing [1] 41/15
appointment [4]
76/12 76/15 76/21
149/11
appointments [1]
157/2
157/19 159/13 162/20
100/23 104/23 104/24
appreciate [2] 18/21
82/15
appreciated [1]
99/15
appreciation [1]
123/13
apprised [1] 100/3
approach [16] 2/25
11/14 15/2 16/12 54/8
55/12 78/17 93/19
136/1 139/15 139/17
139/23 149/1 165/5
165/12 166/3
approached [4]
54/23 79/23 155/20
155/20
approaches [1]
20/19
approaching [3] 9/14
80/12 82/16
appropriate [13]
28/22 29/5 30/3 45/5
49/8 65/12 89/21 95/2)
132/17 132/24 133/3
145/6 150/16
appropriately [2]
80/19 83/16
approve [1] 59/12
April [1] 9/24
Arbuthnot [2] 76/13
88/7
are [157] 1/19 2/8
2/12 3/22 4/1 4/3 4/6
4/8 4/14 5/16 6/3 6/5
6/11 6/14 6/17 6/20
7/2 10/8 10/15 10/16
11/2 11/4 11/5 11/8
14/19 15/20 15/21
15/25 18/14 19/17
20/6 20/11 21/5 21/6
21/11 21/15 21/25
23/13 28/15 28/22
28/24 31/4 31/8 31/20)
32/1 38/16 40/10 41/1
41/2 41/3 41/6 41/7
41/8 41/14 41/23 42/4)
42/10 42/12 42/16
42/18 43/15 43/16
43/17 45/6 45/12
45/13 46/8 47/24 48/3
49/2 50/6 52/4 52/15
52/18 54/2 54/20
59/16 59/19 59/19
59/20 61/13 63/12
64/16 64/17 65/1
70/10 71/2 71/15
TAIT 76/5 83/13
83/15 83/17 85/24
87/20 89/15 90/10
90/23 90/25 91/12
96/15 96/21 99/21
100/14 100/24 101/16)
103/11 103/16 104/2
104/21 106/9 109/4
4111/1 111/3 1114/5
112/3 114/6 116/19
116/24 117/10 117/11
121/8 123/2 128/6
129/16 130/5 134/25
135/1 137/14 143/2
143/2 145/5 145/16
150/16 150/18 151/9
153/6 154/13 155/15
155/16 155/17 156/18)
157/7 157/14 158/7
159/2 160/3 160/14
160/14 161/21 164/13)
166/21 167/1 167/4
167/9 167/10 168/5
area [9] 44/20 89/10
89/11 89/11 142/5
142/8 154/8 155/22
159/16
areas [15] 25/15 64/1
70/5 72/18 73/14
87/11 87/13 87/14
87/22 89/10 93/7
107/11 108/22 138/4
158/10
aren't [2] 80/23 84/16)
argue [1] 112/20
argued [1] 131/10
arise [5] 46/14 55/14
109/6 158/25 163/13
arisen [1] 60/6
arises [1] 114/21
arising [9] 21/7 21/12
39/4 39/6 46/11 56/21
62/12 77/19 147/10
arose [1] 45/17
around [10] 24/22
53/17 106/5 115/5
117/11 117/12 117/15)
134/16 146/25 166/17)
arrangements [4]
50/7 50/23 65/13
153/2
array [1] 30/10
arrived [1] 81/15
arrogant [1] 165/11
articulated [1] 79/22
as [212]
ascertain [1] 81/8
ask [21] 1/9 2/3 2/10
2/14 4/24 55/15 69/18}
80/7 94/8 109/5
111/20 113/7 132/1
138/17 144/11 150/6
154/9 165/16 166/11
167/1 167/5
asked [13] 2/12
43/12 57/23 59/12
59/13 70/3 80/7 82/17)
100/20 130/19 132/8
159/10 164/11
asking [6] 2/2 70/15
70/22 98/16 142/15
166/17
(46) alerted... - asking
A
asks [1] 167/25
aspect [5] 39/2 73/12
83/24 101/5 144/5
aspects [12] 25/20
37/11 41/22 48/11
86/22 89/11 90/19
92/7 92/24 108/17
130/15 149/23
asserted [5] 27/6
30/1 116/3 146/10
159/7
assertion [1] 30/19
assess [2] 45/15
91/13
assessing [1] 125/11
assessor [1] 4/17
asset [1] 44/11
assets [3] 29/15
29/24 45/14
assist [2] 18/14 87/5
associated [1]
126/17
assume [1] 83/16
assumed [2] 45/17
118/14
assumes [1] 80/18
assumption [2]
136/11 137/7
assumptions [4]
49/15 135/13 136/2
164/15
assurance [1] 48/8
assurances [2] 89/18)
89/25
assure [1] 133/3
assured [1] 132/19
at [194]
at page 36 [1] 44/24
attendance [2]
115/16 157/13
attendee [3] 114/23
115/11 115/13
attention [18] 11/3
53/18 57/25 59/11
63/23 75/18 78/15
87/15 103/3 108/1
108/15 108/22 134/11
142/18 149/21 150/17
155/23 162/5
attitudes [3] 78/16
103/6 106/3
attracted [1] 103/2
attribute [2] 106/16
106/21
attribution [1] 74/22
audit [10] 8/8 25/16
44/25 45/17 64/6
74/19 125/13 125/21
128/13 163/24
auditing [1] 45/5
Aujard [1] 119/25
authority [9] 8/16
17/5 29/16 32/15
35/18 46/15 46/21
47/2 53/24
authors [1] 37/4
available [8] 17/19
37/4 60/20 60/21 77/4
105/12 136/3 156/1
avenue [1] 162/25
aware [20] 60/2 67/3
68/4 68/4 86/9 86/13
86/15 86/16 86/18
87/2 92/23 98/20
100/24 102/12 136/17)
142/9 151/9 153/10
154/7 159/9
awareness [1] 46/4
away [3] 69/20
133/14 153/25
awful [1] 161/21
back [28] 6/21 12/6
13/21 13/23 15/8 20/1
23/17 28/9 33/25
36/24 44/16 51/19
104/22 108/4 110/24
122/8 129/14 134/15
138/11 140/17 142/21
143/22 144/12 147/23)
149/6 150/7 154/11
155/11
background [3]
96/23 104/6 150/3
backgrounds [1]
150/2
backwards [1] 5/2
bad [1] 18/16
badly [1] 161/14
balance [1] 43/3
ball [2] 1/20 128/10
Barclays [1] 8/9
base [5] 20/23 27/9
27/21 60/13 96/22
based [11] 15/16
15/21 18/22 20/6
36/18 37/2 59/19
59/20 64/12 96/11
107/14
basic [2] 28/15
165/21
basis [15] 2/22 22/19
40/8 59/17 67/4 82/2
84/7 89/2 90/7 102/18)
119/15 128/23 136/13)
157/6 161/13
be [207]
bear [1] 93/7
bearing [1] 47/8
beautiful [1] 158/23
beautifully [1] 158/22
became [7] 13/19
24/23 25/6 25/7 46/20
47/3 118/24
because [58] 4/16
23/12 34/4 36/22 40/1
41/12 41/19 44/8 46/2
48/3 50/18 53/9 60/18
60/22 61/10 62/18
63/4 64/9 64/20 65/2
66/2 69/8 70/18 70/21
71/8 72/7 72/19 75/3
75/15 88/3 96/11
102/19 103/4 112/14
112/14 112/21 113/3
113/3 116/1 117/25
123/6 126/1 134/11
135/20 137/3 141/18
141/21 143/15 144/1
146/3 146/13 161/19
161/22 162/24 165/2
165/13 165/22 167/20
become [6] 29/11
46/9 49/1 118/12
126/6 132/23
becomes [3] 54/3
116/22 117/14
becoming [2] 26/19
78/18
been [115] 2/18 8/1
8/4 8/7 8/14 10/13
16/20 19/6 22/22 25/9)
25/25 26/11 37/15
41/21 45/3 47/1 49/5
49/6 49/25 50/9 50/14
52/1 53/17 54/23
55/25 57/2 57/14 59/2
59/11 59/13 59/23
60/19 61/11 61/22
62/1 62/2 62/3 62/4
62/5 63/22 64/3 64/5
64/10 66/24 68/4 68/8
69/16 70/3 72/23
73/24 74/17 74/17
75/8 78/15 84/2 86/13)
86/20 86/23 87/1 90/1
90/1 90/7 90/8 90/9
95/2 98/2 100/10
100/22 101/1 103/20
105/11 108/14 108/21
113/11 113/22 115/16}
116/14 117/5 118/15
119/14 120/2 122/4
124/2 124/7 125/1
125/2 125/6 125/9
127/23 127/25 128/1
128/1 128/4 128/20
130/6 130/20 130/24
130/25 131/14 132/24
133/1 133/3 133/15
136/12 137/17 139/10
144/2 149/23 156/3
159/10 161/4 163/12
163/18 165/15 166/6
BEER [4] 1/7 1/9
1/14 169/6
before [40] 1/14 4/19
7/10 9/22 10/3 18/23
18/25 19/20 20/9 21/9}
27/23 41/14 49/19
51/10 82/13 86/13
86/16 93/23 98/9
98/19 99/5 101/12
105/11 106/6 111/14
112/10 113/1 118/18
123/17 125/7 126/6
126/15 127/3 133/18
139/18 142/20 147/13
148/2 165/16 167/24
began [2] 28/14
149/7
begin [4] 39/9 101/13
109/1 135/3
beginning [6] 19/23
44/16 54/9 145/3
158/15 165/17
begins [5] 11/19
53/12 117/17 144/13
144/20
behalf [2] 1/10 33/7
behave [1] 155/14
behaviour [9] 7/6
7/22 16/21 22/2 22/5
22/11 49/11 53/21
111/13
behind [2] 18/24 91/9]
being [36] 5/16 16/23
18/19 42/19 44/4
46/14 47/7 57/1 61/1
61/2 61/17 68/15 71/1
75/12 78/16 80/6
80/18 83/15 94/4
96/15 100/7 106/13
112/3 115/22 117/13
125/18 130/8 130/10
133/14 133/22 134/14}
142/16 144/5 146/16
148/1 167/24
belief [7] 4/2 4/7 6/13
6/19 22/25 60/4 82/9
beliefs [1] 135/18
believe [20] 21/25
25/21 52/5 85/24 90/2,
94/7 96/11 96/11
97/17 99/18 101/19
101/19 102/8 111/5
120/23 132/24 135/23
143/7 145/17 145/25
believes [2] 111/2
111/2
believing [2] 18/9
146/4
beneath [2] 69/6 88/8)
beneficiary [1]
143/21
best [10] 4/2 4/7 6/12
6/18 10/9 22/13 22/15)
28/11 52/16 114/1
better [3] 4/16 48/5
102/17
between [46] 6/3
7/16 10/2 11/8 16/2
18/17 20/11 21/6 21/9
24/5 24/24 33/14
33/22 34/16 34/25
40/24 42/24 46/18
55/10 62/13 62/19
64/7 64/13 66/6 68/8
73/3 76/19 85/17
90/11 94/11 110/16
116/16 119/22 128/10)
129/1 135/14 142/8
142/23 145/22 147/21
151/17 152/6 152/10
157/25 158/1 160/7
beyond [7] 15/11
25/15 38/23 47/3
52/25 96/4 156/12
big [4] 39/4 43/19
43/24 126/6
bigger [4] 65/23
110/9 135/3 139/20
bit [3] 69/23 77/17
102/17
bits [12] 80/3 80/20
106/1 108/15 120/15
121/1 121/3 127/14
127/18 127/19 158/23)
165/10
black [1] 122/13
blind [1] 81/25
blindfold [4] 84/20
84/21 84/23 84/25
board [274]
board's [6] 61/7
77/14 107/25 109/12
150/17 164/10
boardroom [7] 65/22
83/23 116/12 116/23
117/4 121/15 121/20
boards [13] 9/8 25/3
27/12 28/19 45/15
49/2 51/17 52/14 72/7)
107/17 108/16 115/1
160/6
bodies [3] 9/9 30/2
30/10
body [7] 8/12 8/15
18/22 18/25 35/7
36/24 85/22
bold [1] 39/4
book [3] 13/19 13/24
17/19
both [38] 3/9 3/10 8/9)
14/19 14/20 29/3
32/25 42/7 44/21
46/10 47/7 48/8 49/8
52/4 57/10 59/22
60/17 64/10 66/14
74/9 84/22 89/14
93/13 97/9 103/24
112/6 112/22 116/21
120/22 128/18 128/21
136/14 136/25 143/24}
145/20 160/18 160/22)
164/5
bottom [5] 5/22 6/8
(47) asks - bottom
B
bottom... [3] 92/10
95/19 135/9
bound [1] 127/13
bounds [3] 43/5
111/4 146/5
box [8] 1/17 1/25 3/1
12/7 12/19 12/20
13/10 122/13
boxes [1] 93/4
boxes' [1] 91/13
branch [2] 55/22
55/25
branches [2] 56/17
118/2
brand [1] 78/25
breach [2] 23/22
23/25
breached [1] 136/17
breaches [1] 125/25
break [12] 4/23 5/5
23/5 37/16 37/16
37/21 55/13 85/3
123/17 123/17 123/20}
167/3
Brian [2] 132/7 143/7
bridge [1] 94/25
brief [4] 76/25 100/7
100/23 104/25
briefed [4] 93/25
98/3 101/6 102/3
briefing [3] 101/11
101/24 124/21
briefly [4] 24/9 32/22
33/4 138/11
bring [13] 34/23 41/3
42/25 58/4 87/3 89/1
93/7 125/4 134/10
143/6 143/17 145/8
145/19
bringing [4] 92/22
93/13 142/19 145/11
broad [3] 47/17
90/16 124/17
broadcast [1] 17/10
broader [3] 14/4
68/13 91/8
broadly [1] 33/19
broken [1] 158/21
brought [13] 6/11
6/17 25/9 57/18 57/24,
59/11 80/12 87/15
96/14 128/4 147/16
150/17 156/4
bug [1] 57/9
bugs [9] 90/6 90/10
91/4 118/1 120/3
123/1 126/9 135/21
146/19
bugs/anomalies [1]
90/6
build [1] 79/7
building [4] 83/8 83/9)
134/16 140/9
bundled [1] 128/2
business [48] 7/15
9/5 25/1 26/10 31/13
32/3 32/5 32/7 32/12
32/14 32/20 32/25
42/22 46/3 46/3 46/7
58/19 60/14 63/24
65/21 67/21 69/4 79/6
87/23 89/19 90/19
92/7 92/15 109/19
110/16 110/24 122/17)
123/7 123/14 124/23
125/10 125/14 136/6
138/1 140/11 141/21
142/1 142/2 144/6
145/13 146/2 149/15
158/10
businesses [2] 115/7)
115/8
but [107] 2/17 3/23
4/18 5/1 11/18 15/20
18/15 19/1 19/25
21/15 22/5 28/24 32/4
35/13 38/14 40/2
41/19 41/23 42/19
43/13 47/3 47/8 51/15
52/24 54/4 55/6 56/1
58/3 58/8 59/1 59/20
60/25 63/5 65/6 70/21
71/8 72/9 72/16 75/9
76/6 77/8 77/13 78/13)
79/9 80/22 80/23
83/16 83/22 84/13
86/17 87/11 91/2
92/18 93/5 93/11 94/3
95/13 98/12 99/1
100/22 101/22 102/11
102/12 102/17 103/15)
104/9 105/8 105/14
105/20 105/21 106/10)
108/16 109/7 110/9
114/13 115/10 115/12)
115/16 115/18 115/20)
120/19 121/2 123/4
124/22 127/2 127/2
127/10 130/1 130/23
131/11 132/15 133/17)
138/17 142/12 146/3
148/18 151/14 152/18)
159/4 159/5 161/6
161/18 161/23 163/1
166/9 166/15 168/2
Byers [1] 35/23
c
Cabinet [2] 13/6
13/15
Cadbury [4] 25/5
26/18 28/7 44/16
call [16] 1/3 76/6
76/24 90/6 100/12
101/7 101/9 101/12
101/18 101/24 102/18)
104/24 118/3 130/4
146/20 164/17
called [6] 26/16
26/20 32/17 49/10
50/15 105/7
Cambridge [4] 7/11
7/13 9/4 9/6
came [3] 80/20 82/18
115/13
can [159] 1/10 1/21
3/14 3/20 4/9 4/15 5/8
5/9 6/7 6/21 7/4 8/22
9/12 9/13 9/15 11/17
11/20 12/1 12/6 12/22
14/18 15/8 16/10
18/24 19/8 19/17
21/19 24/8 24/9 25/21
28/11 29/9 30/5 30/23)
31/3 32/12 32/22 33/4
33/15 35/12 36/24
37/25 38/3 38/12
38/13 40/24 41/11
43/18 43/24 44/23
44/25 45/20 45/21
46/12 47/10 47/17
47/22 47/25 48/20
48/23 49/17 49/24
50/1 50/8 51/2 51/24
53/14 54/7 54/18 55/9)
62/16 63/11 64/20
65/17 66/12 68/12
68/23 69/18 70/12
70/24 72/9 75/22 76/4
77/18 78/4 78/22
79/18 85/13 87/5
89/14 90/20 90/23
92/11 95/1 95/18
95/19 97/17 97/18
97/19 99/19 99/22
101/4 104/14 105/23
107/8 107/17 108/23
110/20 111/12 112/8
113/7 114/20 115/4
115/6 116/6 116/12
117/16 120/7 122/7
122/20 123/17 123/25
124/4 126/21 129/4
129/9 129/18 131/10
131/15 134/5 136/19
137/10 137/19 138/11
138/17 138/18 144/12
144/13 145/1 146/23
148/3 148/20 150/6
150/7 152/12 152/20
154/11 157/10 158/25]
159/21 160/6 163/2
165/1 166/13 166/15
167/3 167/8 167/17
168/7
can't [7] 105/8 152/5
153/24 153/25 160/17]
166/12 166/13
cannot [9] 19/7 41/23}
91/13 92/14 119/18
122/14 151/12 157/5
160/8
capability [1] 159/23
capacity [1] 160/23
capsulated [1] 80/22
care [1] 116/16
careful [4] 25/24 96/5]
104/5 104/9
carefully [2] 46/6
103/12
carried [1] 75/4
carry [2] 76/10 97/10
Cartwright [7]
117/24 118/11 119/1
124/13 131/17 132/2
132/9
cascaded [1] 134/18
case [105] 18/6 18/9
19/4 19/5 19/10 19/11
19/17 19/18 19/21
19/24 20/7 20/19 21/5}
21/16 21/18 22/21
29/6 29/25 41/14 42/6)
48/2 50/5 50/6 54/10
54/10 54/13 54/15
54/18 54/21 55/1 55/2)
55/4 55/9 55/11 55/14
55/20 55/24 56/6
56/16 56/22 56/24
59/9 60/3 60/16 62/12)
62/17 64/8 64/9 65/19
65/25 66/8 69/9 71/14)
71/16 71/20 75/9
75/12 75/22 76/6
77/14 78/2 83/25
85/11 89/17 96/21
98/12 99/4 102/8
102/21 111/13 112/21
114/18 114/22 115/12}
117/16 117/17 117/19}
122/13 123/24 128/17
128/25 129/1 130/18
133/7 133/13 133/23
136/4 137/11 137/13
138/7 138/10 139/3
139/6 139/8 139/8
141/3 142/4 151/6
153/2 153/7 156/23
157/20 159/1 159/2
166/20
cases [24] 55/7
56/12 57/11 58/18
62/19 62/20 63/1 63/7
69/12 96/24 118/7
118/23 122/4 124/11
127/7 127/9 131/18
139/12 147/9 147/19
155/3 157/19 157/24
158/7
caused [1] 113/25
ceased [1] 137/4
central [5] 10/4 13/7
29/19 64/24 79/8
centrally [1] 62/22
centre [1] 118/17
CEO [45] 23/21 57/20)
57/25 62/9 64/15
85/19 90/15 91/25
92/2 95/22 95/24 96/4
100/3 100/6 108/4
122/14 124/22 125/7
125/8 125/15 125/23
125/24 126/1 126/13
127/8 128/22 132/1
132/5 132/6 134/8
134/10 135/13 137/21
150/19 150/21 150/22)
152/25 157/4 157/5
157/25 158/3 158/9
159/7 162/4 162/19
CEO's [3] 124/22
157/2 159/14
certain [5] 25/18
43/16 112/3 154/2
159/9
certainly [6] 37/18
92/9 124/25 141/3
151/5 161/5
certificate [1] 154/5
cetera [2] 39/22
116/14
chain [1] 152/4
chair [45] 8/1 8/5
21/22 23/3 25/11 29/1
39/15 43/6 59/24 60/1
62/6 63/17 64/3 64/14I
69/1 69/16 74/18
74/18 76/17 95/19
95/22 96/1 96/10
96/12 96/25 98/20
98/24 99/3 100/6
1414/1 114/7 116/17
121/12 121/13 125/20)
150/15 150/19 151/8
151/10 153/16 153/21
154/22 154/23 156/5
158/1
Chair's [1] 130/4
chaired [1] 99/13
Chairs [1] 27/13
challenge [26] 60/14
61/2 63/16 65/22
68/21 69/5 70/4 70/10
72/6 72/7 72/9 72/20
81/3 81/9 81/12 81/16I
81/22 81/22 82/4
84/19 101/14 110/18
126/6 136/11 139/16
160/1
challenged [4] 49/16
69/17 137/7 139/22
challenges [2] 90/18
110/15
challenging [2]
133/22 161/1
champion [1] 51/18
Chancellor [1] 7/14
change [7] 36/8
(48) bottom... - change
Cc
change... [6] 117/10
147/3 152/18 160/5
163/7 163/15
changed [3] 51/15
51/16 148/16
changes [2] 149/3
163/10
changing [1] 34/23
channel [1] 42/23
chapter [23] 24/15
24/18 37/25 38/1 38/5
44/23 44/24 45/1
45/19 45/20 45/22
46/12 47/10 47/19
48/20 48/24 49/17
51/20 51/21 52/25
53/12 53/15 53/16
Chapter 2 [1] 44/23
Chapter 3 [2] 44/24
45/19
Chapter 4 [2] 45/20
46/12
Chapter 5 [2] 47/10
47/19
Chapter 6 [1] 48/20
Chapter 7 [2] 49/17
51/20
Chapter 8 [2] 53/12
53/16
chapters [2] 15/25
53/16
Chapters 1 [1] 53/16
characteristics [1]
47/21
charities [2] 9/9
28/12
check [1] 43/24
checking [1] 43/18
checklist [2] 107/5
107/19
chief [54] 21/21 23/2
25/11 26/13 26/13
27/13 29/1 39/20
39/22 56/14 57/16
57/17 57/20 57/22
58/11 59/11 60/1
61/20 68/6 68/7 69/13
69/14 77/1 85/16 86/3
86/8 87/7 92/14 92/14
92/17 92/19 92/22
93/1 93/1 93/22 99/2
101/20 108/13 116/2
121/10 121/10 122/24)
123/6 123/7 129/23
136/10 137/25 153/4
153/13 153/18 160/19}
160/25 161/7 161/10
choice [2] 38/19
64/24
choose [1] 98/7
chooses [1] 58/11
chose [1] 18/6
chosen [1] 18/10
Chris [1] 119/25
chronological [1]
33/12
chronologically [2]
11/1 33/17
chronology [1] 10/23
circulation [1] 94/18
circumstances [10]
2/7 28/23 29/5 29/8
30/3 83/20 101/13
102/5 122/24 148/16
circumstances' [1]
28/21
citizen [2] 49/19
49/25
civil [12] 33/6 55/23
56/24 57/7 57/11
58/18 59/9 62/19 63/1
63/7 69/8 69/9
claims [1] 115/25
clarity [6] 71/23 72/1
72/2 72/14 144/15
144/22
Clarke [29] 55/2
118/2 118/6 118/13
118/17 119/10 120/41
120/14 120/18 121/6
121/9 121/17 122/6
122/21 122/22 124/3
124/19 126/2 127/12
127/25 131/3 134/13
136/4 136/18 137/16
137/23 139/12 147/14)
157/24
Clarke's [2] 19/14
117/18
classified [1] 47/14
Claverhouse [1] 8/10
clear [10] 3/2 64/7
67/6 72/11 75/8 94/7
118/22 128/15 141/10)
149/9
clearly [6] 30/17
52/14 134/14 146/14
149/6 160/11
Cleveleys [1] 55/22
clients [1] 52/11
closed [1] 55/25
closely [1] 158/9
clouded [1] 156/2
Co [1] 167/11
coached [1] 8/23
code [22] 13/3 13/6
13/11 16/24 24/2 25/8)
25/13 25/14 26/20
26/21 26/24 26/24
27/8 27/18 29/22 39/5
39/7 40/7 47/5 107/6
107/7 152/1
Code's [1] 28/21
codes [20] 14/12
15/4 24/14 24/20
29/12 29/23 30/3
30/21 38/14 44/5 44/7
44/19 44/22 54/3 54/4
83/6 85/21 129/15
150/13 151/21
coherent [4] 73/1
73/7 126/4 134/25
coherently [2]
127/13 127/24
colleague [2] 150/20
157/12
colleagues [9] 85/17
87/17 87/25 116/10
116/15 124/22 157/9
157/11 158/4
collective [13] 42/13
58/15 61/21 90/16
92/6 93/8 93/14
121/20 122/11 123/13
156/25 158/6 159/12
collectively [5] 2/18
3/3 43/6 64/17 126/2
College [3] 7/10 7/14
9/6
column [2] 12/25
35/20
columns [2] 11/1
11/21
combination [3]
29/18 120/5 159/17
combine [1] 35/8
combined [10] 13/3
25/8 25/13 26/20
26/21 27/1 27/2 27/5
29/6 29/22
come [24] 5/9 9/12
21/19 31/16 40/23
49/20 51/18 54/25
61/18 70/24 80/22
80/23 83/20 95/13
97/17 99/17 112/6
112/24 113/5 113/9
127/14 131/9 150/8
167/19
comes [2] 29/17
114/21
coming [4] 5/2 28/6
82/1 108/18
commenced [1] 9/22
comment [4] 16/5
16/8 22/20 165/16
commentary [2]
15/16 17/3
commented [1]
15/13
commercial [9] 28/9
29/12 29/18 37/8
149/14 149/15 149/18)
150/1 155/2
commissioning [2]
163/11 163/14
committee [10] 8/5
8/9 25/5 59/14 62/5
64/6 125/13 125/22
128/14 160/20
committees [4]
26/19 27/4 37/10
39/12
common [2] 23/25
133/13
communicate [5]
93/5 93/6 121/12
121/16 138/3
communicating [1]
133/7
communication [13]
17/5 42/24 49/13 54/1
87/20 88/4 88/6
121/19 123/6 133/10
133/14 147/4 147/21
communications [5]
87/19 88/2 94/3 94/11
146/25
companies [31]
10/24 11/3 11/4 11/5
11/9 11/15 11/24 12/8}
12/9 12/10 12/13
12/14 12/15 12/25
13/1 13/2 13/14 15/2
15/3 23/22 29/12
29/19 30/9 30/21
32/18 37/8 41/24
44/18 129/14 149/17
151/25
company [50] 10/19
16/2 29/23 39/23 41/7,
41/11 41/20 44/10
45/4 45/8 45/16 46/22)
52/16 62/15 63/6
65/11 65/11 72/8 75/3
83/8 83/8 83/10 83/11
83/12 84/14 89/2 89/3
91/23 98/22 99/2
141/20 141/22 141/23}
142/10 150/6 150/11
150/24 151/4 151/11
151/17 151/18 151/24)
152/6 152/8 152/11
152/14 152/20 154/19}
163/25 164/17
company's [7] 35/16
83/24 88/15 88/21
89/23 150/14 151/3
comparatively [1]
43/13
competence [2]
120/5 148/5
complain [2] 28/20
28/24
completed [1] 9/21
complex [2] 47/12
165/23
complexity [1] 47/22
compliance [8] 30/20)
62/5 150/14 151/3
151/13 151/13 151/19}
152/9
compliant [1] 151/15
complicating [1]
31/3
comply [2] 28/17
28/25
complying [1] 29/8
composition [1]
148/10
compound [2] 158/7
159/6
comprehensive [1]
107/24
comprehensively [1]
107/25
computer [1] 47/15
concentrating [1]
81/24
concentration [1]
94/22
concept [4] 31/21
49/24 50/7 50/13
concepts [2] 33/25
36/6
conceptualisation [1]
68/14
conceptualise [3]
67/13 67/15 67/25
concern [3] 42/20
79/22 109/23
concerned [7] 22/9
22/10 42/3 63/15
88/13 131/24 146/11
concerning [5] 43/20
48/24 60/16 64/12
94/4
concerns [18] 29/14
57/18 64/11 77/13
94/3 113/13 117/17
125/21 135/16 145/22)
160/3 160/11 160/18
161/5 161/5 161/6
161/7 167/17
conclude [2] 160/4
165/13
concluded [2] 23/2
160/21
concludes [1] 119/12)
concluding [4] 17/2
128/6 161/20 161/21
conclusion [18]
18/15 37/2 55/16
56/21 61/18 73/11
74/23 78/22 79/18
82/2 87/25 90/4
114/17 127/4 130/21
134/7 138/7 166/7
conclusions [47]
54/25 56/9 63/11
64/16 66/6 71/13
77/25 78/2 85/15
85/18 92/11 95/20
99/21 102/25 103/9
104/21 109/1 109/4
109/8 111/15 113/21
117/25 119/21 124/4
124/18 127/16 129/7
(49) change... - conclusions
Cc
conclusions... [20]
131/11 133/8 133/19
135/9 137/11 137/14
137/23 139/1 144/18
145/2 147/1 148/6
148/7 148/20 154/13
156/9 156/20 159/24
163/4 165/17
conduct [10] 46/21
74/3 75/4 107/6
111/21 119/13 130/11
131/19 155/4 156/6
conducted [6] 63/5
80/18 119/1 132/21
134/3 141/11
conducting [4] 68/14
133/2 134/2 136/15
conference [1] 76/24
confidence [1]
120/10
conflict [6] 43/10
53/25 130/6 131/13
131/18 132/19
conflicts [14] 25/18
129/6 129/11 129/16
129/18 129/22 130/2
130/3 130/21 131/2
131/16 132/25 133/4
156/8
conflicts/divergent
[1] 129/18
confluence [1]
108/17
confronted [1]
149/23
confronting [1]
133/14
connect [2] 57/6 71/5I
connected [3] 32/8
67/22 79/4
connection [4] 31/7
57/13 86/6 90/11
connections [2]
57/11 73/3
consensus [4] 17/9
17/18 17/21 160/2
consequence [2]
125/5 126/22
consequent [1]
105/13
consider [4] 54/14
111/6 114/4 130/17
considerable [1]
17/9
consideration [9]
19/12 75/24 77/11
92/24 93/16 96/6
116/18 134/20 162/7
considered [5] 18/23
19/20 56/6 112/16
125/1
considering [3]
51/13 77/7 162/3
consistent [1] 155/1
consistently [1] 6/4
consists [1] 17/7
constructed [2]
53/17 55/7
constructing [1]
135/5
construction [1]
33/21
constructions [1]
18/22
consult [1] 42/22
consultants [1]
162/18
consulted [2] 7/6
8/23
consuming [1]
109/18
contact [1] 125/7
contain [1] 78/10
contained [3] 84/13
103/2 120/13
contemporarily [1]
25/25
contemporary [1]
25/4
content [2] 126/10
158/18
contents [11] 2/12
4/1 4/6 6/12 6/17 92/1
102/23 104/16 105/17)
105/19 121/16
contested [1] 103/7
context [6] 24/20
69/8 76/6 97/19
114/24 155/19
Continental [1] 26/6
continuation [1]
140/20
continue [4] 43/9
125/23 137/2 137/3
continued [2] 160/7
162/7
continuing [1] 79/5
contract [1] 163/23
contracts [1] 103/7
contribute [2] 135/4
159/11
contribution [1] 91/8
contributions [1]
90/18
control [2] 22/5
24/24
controlled [1] 11/6
controlling [1] 69/25
convenient [2] 85/3
123/16
conversation [5]
62/3 68/8 68/13 74/16
128/13
conveying [1] 125/8
convictions [2] 118/9I
119/14
coordinated [1]
110/11
copies [1] 3/22
copy [3] 3/15 3/16
101/22
Core [5] 2/3 167/4
167/11 167/11 167/12
corporate [29] 11/22
13/6 13/11 14/4 16/24]
24/2 25/8 25/14 28/4
29/11 30/8 30/14
30/20 31/21 31/23
34/23 36/7 36/12
36/18 37/8 38/23 39/5)
39/7 40/7 44/7 45/2
46/5 47/5 129/15
corporation [4] 35/19}
35/20 39/6 41/11
corporations [2]
11/24 12/10
Corporations/Compa
nies [1] 11/24
correct [66] 3/10
4/23 5/13 5/13 5/20
5/24 5/25 6/6 7/8 7/17,
7/19 8/3 8/6 8/13 8/17
8/25 9/3 9/7 10/6
11/16 11/25 12/12
13/8 15/6 15/23 16/4
16/16 18/3 18/8 18/13}
18/18 20/14 20/18
20/25 21/4 26/22 28/1
30/22 33/20 35/1
35/10 35/24 36/4 36/9
37/13 39/16 39/18
39/24 42/9 51/9 51/14
56/2 56/7 56/25 58/2
59/15 70/7 77/21
77/23 81/7 94/14
97/12 97/14 108/8
140/5 164/21
corrections [4] 4/14
5/14 6/11 6/17
corrective [1] 82/4
correctly [3] 10/12
56/20 128/18
corrosive [1] 164/16
cost [1] 48/1
costs [1] 149/16
could [50] 4/24 22/6
23/5 23/21 23/24
23/25 24/1 24/16
40/25 57/10 61/16
61/22 62/1 62/2 62/3
62/4 62/5 64/25 67/11
67/19 68/4 69/10
69/16 69/23 71/8
71/18 73/3 73/18
73/20 73/24 74/14
75/7 75/8 77/16 79/13
80/3 81/8 81/11 87/3
95/7 101/13 102/23
110/10 112/20 120/12
121/3 121/13 132/2
146/20 159/10
couldn't [3] 46/3
102/18 165/12
Council [1] 47/6
counsel [63] 10/14
56/14 63/8 63/9 63/9
88/20 88/23 88/25
89/3 89/7 91/21 91/25
97/22 112/20 112/24
113/1 113/5 113/12
113/24 114/3 115/1
115/9 116/17 117/2
119/2 120/7 120/8
122/19 122/25 123/3
123/5 123/5 124/10
125/6 125/12 125/16
127/5 130/7 130/9
131/8 132/17 137/20
137/22 151/18 151/20}
152/1 152/7 152/13
152/14 152/19 152/23}
152/24 153/3 153/5
153/10 153/15 154/4
154/5 157/14 158/1
158/2 161/6 167/15
counsel's [2] 114/10
154/1
counsels [6] 89/15
115/5 115/15 120/12
136/14 137/1
countenance [1]
163/13
counterclaim [1]
147/16
counterpoint [1]
96/17
Counters [1] 35/16
course [11] 14/9
16/14 22/1 36/21
52/24 69/9 93/10
100/21 140/16 159/2
164/24
Court [1] 119/16
courts [2] 55/23
142/20
coverage [7] 24/18
38/4 45/1 45/22 47/18
51/24 53/15
covered [4] 81/1 86/9)
87/22 89/5
covers [2] 12/14
105/20
Coyne [5] 55/24 64/9
68/5 68/9 72/15
Coyne's [2] 59/10
59/23
cracks [1] 128/10
create [3] 58/14 79/5
157/8
created [2] 101/12
165/6
creates [2] 161/22
161/23
creating [2] 65/21
134/8
creation [2] 140/12
140/16
Crichton [20] 91/21
91/22 98/1 98/3 105/3
111/18 113/17 115/13}
116/9 117/23 118/6
118/11 119/24 120/16)
121/10 121/13 121/15]
122/1 122/3 124/13
Crichton's [3] 118/25)
121/4 122/2
crime [6] 143/15
143/16 143/18 143/19)
143/20 143/21
criminal [9] 56/23
62/20 64/8 120/1
122/4 124/11 127/7
127/9 142/20
crisp [1] 117/21
criteria [1] 28/14
critical [4] 23/4 48/11
76/14 134/8
criticism [1] 113/24
criticisms [1] 57/4
cross [3] 5/11 30/25
91/16
cross-heading [1]
30/25
crossed [1] 110/16
crucial [1] 124/24
crystallise [1] 134/1
cultural [3] 49/11
165/18 166/9
culturally [2] 155/12
155/14
culture [36] 8/24 9/1
17/5 22/2 22/11 53/25}
54/3 65/21 66/7 66/11
67/5 70/9 116/12
116/23 116/24 117/14}
135/8 135/12 139/10
148/18 154/14 155/4
155/9 155/10 155/10
156/6 163/3 163/21
164/16 164/21 165/3
166/12 166/12 166/13}
166/19 166/24
cultures [3] 116/24
117/10 117/11
cup [2] 158/20
158/22
curiosity [2] 65/22
84/19
curious [1] 133/22
current [3] 88/11
109/22 147/11
currently [2] 2/8
168/2
custom [1] 26/11
customer [1] 163/17
customers [1] 52/10
cutting [1] 149/15
(50) conclusions... - Dame
D
Dame Sandra [10]
2/10 2/19 3/23 5/12
6/9 6/25 31/15 37/25
85/10 123/23
Dame Sandra's [1]
2/23
dark [1] 164/21
data [11] 45/8 56/18
57/10 58/18 64/13
75/19 78/14 79/12
79/21 106/4 134/4
date [2] 100/8 101/2
dated [4] 3/5 3/6 4/11
9/21
Dawson [4] 1/4 1/5
1/12 169/2
day [2] 153/11
168/11
days [1] 118/17
deal [6] 24/9 39/12
51/21 55/11 88/4
104/15
dealing [13] 15/3
25/16 25/17 25/17
25/23 30/24 67/17
87/16 108/11 108/12
115/2 124/1 131/16
deals [3] 10/11 33/10
106/7
dealt [3] 25/10 85/11
151/4
dear [1] 109/19
decades [1] 140/17
decide [1] 52/20
decided [2] 112/15
161/12
decision [7] 99/1
109/6 128/16 143/17
147/6 154/15 155/6
decisions [7] 6/5
42/23 87/4 99/15
108/24 122/12 125/18)
declaration [1] 3/21
deep [2] 67/5 164/15
deeper [1] 146/8
defective [1] 55/25
defects [4] 90/10
91/4 123/1 146/19
defence [2] 109/17
146/13
defend [2] 66/21
155/17
defendants [1] 118/9
defending [2] 66/20
67/21
defensive [2] 82/5
165/11
deficit [1] 60/24
definitely [2] 52/23
153/13
delay [1] 16/11
delayed [1] 128/17
delegate [2] 92/17
157/4
delegated [2] 75/8
157/6
delegates [2] 87/8
93/3
delegation [3] 92/19
92/21 93/13
deliberately [1] 80/11
delivery [2] 48/1
100/15
delve [1] 83/21
demonstrated [1]
160/12
denied [1] 115/23
dent [1] 95/6
department [5] 33/7
35/22 35/22 140/13
140/13
departments [1] 13/7
departure [1] 107/2
depend [2] 146/3
153/23
dependence [1]
79/21
dependent [1] 75/19
deployed [1] 9/14
depth [1] 19/22
Deputy [1] 7/14
derived [2] 21/15
37/11
describe [7] 24/17
30/24 33/11 38/3
40/21 48/14 51/24
described [14] 23/19
35/14 35/14 36/12
51/6 51/22 60/5 65/16
96/22 104/6 114/7
131/12 131/13 132/25)
describing [4] 39/7
64/17 116/19 116/21
description [6] 16/25
20/6 47/17 55/13 58/9
137/13
descriptions [1]
38/13
design [2] 31/24 32/1
designated [1] 46/1
designed [1] 31/5
despite [2] 37/16
98/3
detached [1] 122/16
detail [10] 11/18 13/9
35/2 40/16 43/19
54/21 56/11 86/20
99/17 110/5
detailed [3] 27/20
27/24 94/19
details [1] 87/10
determination [1]
145/14
develop [1] 94/10
developed [9] 24/20
44/22 45/14 49/6 50/9)
50/22 61/22 68/13
115/1
developing [3] 41/22
50/1 154/17
development [6]
25/4 45/2 52/13 148/5
148/15 165/20
develops [1] 38/18
did [64] 19/18 19/25
35/7 36/8 42/7 53/9
55/2 55/4 56/19 58/13)
61/12 62/6 62/16
66/17 67/4 69/4 69/15)
75/9 80/1 80/5 81/15
82/3 82/6 82/15 82/19
93/9 93/11 93/15
93/23 95/5 95/6 95/21
96/19 97/15 97/23
98/7 110/8 111/22
113/10 113/16 116/4
120/13 120/14 126/2
126/4 131/9 132/1
132/5 132/8 132/19
134/12 135/14 136/11
139/9 139/13 139/19
147/13 152/8 155/5
155/13 158/9 159/5
163/21 164/17
didn't [30] 14/13 19/3
27/22 51/23 63/8
66/17 67/16 67/16
69/6 71/22 82/11
88/12 89/7 94/20
101/23 102/19 106/20
120/19 120/25 121/11
121/12 127/1 127/11
136/23 137/3 139/16
145/18 153/19 155/23}
166/1
difference [1] 43/1
differences [3] 11/8
125/24 145/16
different [18] 27/3
27/4 27/4 30/1 31/9
42/10 53/16 53/19
53/20 62/1 86/4 87/9
88/23 91/12 93/11
121/8 149/8 154/25
differently [3] 43/2
61/21 74/15
differs [1] 125/22
difficult [7] 95/17
125/20 132/13 135/2
136/22 159/13 161/15}
dimensional [1] 36/5
dimensions [1] 34/8
dimensions/levels [1]
34/8
direct [5] 52/23 98/17,
121/5 125/16 168/4
direction [1] 97/5
directions [2] 35/21
97/10
directly [3] 14/13
64/6 64/14
director [17] 7/15 8/4
8/8 8/14 8/15 26/14
26/14 40/2 42/1 42/19)
57/18 58/11 83/23
89/3 89/4 100/18
112/23
director's [1] 89/5
directors [27] 25/12
26/4 27/12 39/17
39/20 40/18 41/2 41/6)
41/9 41/10 41/15
42/12 42/14 42/15
42/16 42/18 52/14
87/3 87/9 93/3 102/2
111/24 112/2 113/3
125/3 150/12 161/4
Directors’ [2] 23/22
87/14
discerned [1] 95/7
discharge [2] 85/23
142/13
disciplines [1] 155/2
disclose [2] 25/17
120/3
disclosure [7] 50/19
51/1 118/8 118/24
119/13 124/12 135/21
disclosures [2]
126/7 126/17
discourse [1] 163/9
discovered [2] 90/5
136/20
discovery [2] 28/4
90/5
discrimination [1]
49/4
discuss [4] 97/19
99/1 125/23 125/23
discussed [15] 54/8
54/24 55/3 59/13 62/5
64/10 74/18 74/18
91/22 92/1 99/15
124/20 130/6 130/25
134/19
discussing [2]
125/10 165/15
discussion [22] 3/1
43/10 58/5 64/13 96/9)
97/10 103/3 105/5
105/17 107/10 108/24}
109/6 109/12 114/2
114/15 115/5 117/6
126/12 147/6 154/15
155/6 156/4
discussions [7]
43/16 79/23 90/16
122/12 134/9 139/21
162/8
dislodged [1] 84/20
dismissal [1] 51/8
disproportionately
[2] 87/18 88/1
disrespect [2]
116/10 116/15
distinction [2] 40/23
146/1
distributed [1] 128/2
distribution [2]
122/21 122/22
distributors [1] 52/11
distrust [1] 79/25
divergence [1] 85/22
divergent [1] 129/18
diversity [1] 25/19
divide [2] 40/18
48/13
do [90] 3/17 10/12
10/13 18/10 18/15
19/3 19/25 23/9 25/19}
33/23 34/22 37/24
39/5 39/9 43/2 49/15
49/19 50/8 52/7 53/24
56/4 56/20 58/21 59/5
61/9 63/21 65/3 67/15}
68/9 69/10 70/18
70/21 71/17 74/12
77/24 80/25 83/8
83/12 84/10 84/12
85/20 86/12 88/10
88/10 88/11 88/14
88/16 88/20 91/1 91/2I
91/13 91/25 93/19
93/20 95/5 102/18
104/3 105/5 106/17
107/11 117/15 121/4
121/7 122/6 122/14
127/3 127/16 128/25
130/13 136/7 137/8
137/18 139/24 140/3
140/22 146/21 147/13)
150/4 152/19 153/6
153/24 154/3 154/7
155/7 156/18 158/19
161/25 164/12 165/13)
168/4
document [5] 13/13
17/7 19/6 104/4
162/15
documents [2] 15/5
18/4
does [30] 9/17 9/19
16/5 21/6 22/7 22/15
23/18 40/4 51/18 52/6I
52/6 61/4 69/7 70/15
73/10 80/9 92/19
103/8 105/21 126/25
143/1 145/12 145/13
146/3 151/18 152/8
152/9 152/14 158/16
162/20
doesn't [10] 28/3
51/6 65/4 65/7 65/14
84/3 111/8 116/16
119/5 149/23
doing [15] 38/9 38/11
44/11 45/11 102/5
121/3 123/2 125/15
(61) Dame Sandra - doing
D
doing... [7] 132/20
137/6 139/2 141/24
142/1 149/5 161/14
dominance [1]
155/15,
don't [22] 23/9 23/11
61/11 70/18 80/22
83/19 86/1 101/2
106/15 106/21 106/23)
106/25 117/8 134/24
137/1 146/9 146/12
152/18 158/15 160/16)
165/18 167/20
done [22] 6/4 14/17
58/1 58/2 62/9 65/4
66/24 70/25 84/2
104/12 106/19 106/24
108/6 112/3 124/2
124/7 126/15 127/25
128/2 133/23 147/9
148/1
dotted [1] 153/16
doubt [1] 64/20
doubts [1] 146/7
down [29] 8/20 9/12
11/20 14/25 20/11
20/16 21/19 23/5 26/1
32/10 34/2 34/19
35/25 39/20 51/3
55/13 56/1 64/25
69/23 99/23 109/3
112/16 112/17 134/21
135/2 135/5 144/14
152/18 157/16
downwards [1] 93/5
Dr [21] 1/4 1/6 1/8
2/11 2/20 2/22 4/4
6/15 8/19 22/22 37/25
55/2 58/21 66/25
85/10 113/7 123/23
128/7 150/4 165/16
169/4
Dr Katy [1] 1/4
Dr Steward [13] 2/11
4/4 6/15 8/19 22/22
37/25 55/2 58/21
85/10 113/7 123/23
128/7 165/16
draft [3] 55/2 55/4
91/23
drafts [1] 55/1
draw [4] 56/21
114/17 116/7 127/18
drawing [4] 71/15
71/19 102/1 107/7
drawn [5] 30/8 44/4
104/10 107/25 162/4
drew [2] 17/24 92/12
driven [1] 149/12
driver [2] 44/9 44/9
dropped [2] 101/17
101/18
dropping [1] 128/10
DTI [1] 35/23
dual [1] 89/16
due [4] 14/9 36/20
66/24 111/10
duly [1] 142/2
during [6] 10/25
11/10 55/24 67/2
139/21 163/14
duties [15] 23/22
23/25 28/17 40/3
42/10 75/9 89/4 89/5
89/12 119/10 126/1
136/17 151/9 152/16
152/20
duty [10] 66/20 73/25
120/17 125/4 125/12
125/16 126/5 135/25
151/15 165/6
dysfunctions [1]
158/3
each [25] 1/10 2/20
9/15 22/21 31/11
31/12 39/8 40/11
55/11 55/16 56/12
77/25 78/2 87/2 93/6
96/21 109/5 128/23
138/15 139/3 140/3
144/25 147/19 167/16)
168/7
eager [1] 24/19
earlier [13] 62/19
72/10 74/12 89/5
95/10 110/24 112/22
116/1 133/18 135/23
147/23 154/20 155/11
early [2] 75/11
120/15
easier [1] 117/14
easily [1] 103/9
easy [1] 27/20
effect [4] 97/11 122/9
159/6 167/23
effective [12] 30/15
49/12 86/3 107/17
146/24 147/21 154/15)
155/5 156/24 158/5
159/18 160/24
effectively [2] 145/18
148/1
effectiveness [1]
166/3
effects [1] 159/17
efficient [1] 2/6
effort [1] 121/20
eight [4] 15/25 24/13
107/18 144/25
eight-items [1]
107/18
either [19] 2/20 28/19
34/24 54/20 71/22
78/20 79/22 95/14
98/21 105/2 114/22
115/9 126/9 128/13
146/7 147/13 153/18
158/21 158/21
elaborate [1] 72/10
elected [1] 52/9
element [4] 29/17
127/3 142/2 149/11
elements [13] 39/6
40/7 54/2 120/14
127/4 127/6 127/7
128/3 128/4 130/13
145/16 145/18 153/9
elevated [2] 72/22
747
elicit [4] 147/25
elicited [1] 147/20
else [2] 95/11 108/9
email [4] 62/10
101/11 121/25 162/13}
emanating [1] 46/23
embedded [4] 50/15
66/11 66/22 164/15
embraced [1] 130/10
embryonic [2] 68/22
68/25
emerge [1] 129/19
emergent [1] 58/14
emerging [4] 100/4
100/21 100/22 100/23}
Emerita [1] 7/18
emphasis [1] 61/14
emphasise [2] 38/20
38/22
emphatically [1]
119/17
employed [1] 144/5
employees [4] 52/8
73/23 142/19 142/20
Employment [2]
50/16 51/2
enable [4] 49/15
118/8 147/8 157/4
enabled [1] 64/23
enabling [1] 49/3
encapsulate [1] 82/6
encourage [2] 155/5
163/21
encouraging [1]
11/13
end [7] 70/2 138/10
158/15 163/16 165/22
165/23 166/2
endeavour [1] 138/3
ended [1] 116/2
ending [1] 123/24
endorsement [1]
163/1
energy [1] 109/18
engage [1] 96/6
engaged [3] 108/3
141/15 141/17
engagement [1]
76/20
England [1] 9/2
enormous [1] 17/16
enough [5] 48/3 48/4
64/11 97/2 146/13
enquire [6] 83/18
89/24 90/12 111/7
130/19 146/38
enquired [1] 84/17
enquiring [2] 102/15
130/14
enquiry [1] 130/14
enshrined [2] 25/7
26/19
ensure [17] 2/6 3/2
42/23 83/9 83/15 93/2)
93/23 96/13 99/14
131/24 137/25 141/5
145/6 150/14 150/16
151/9 167/6
ensured [3] 64/22
90/16 107/23
ensures [1] 93/6
ensuring [3] 38/22
50/8 151/13
enterprise [1] 149/18
entirely [6] 17/1 44/8
54/24 55/3 101/18
145/5
entirety [3] 18/10
18/15 27/19
entities [1] 11/5
entity [2] 30/16 35/15
entrustment [1]
149/20
episode [5] 75/12
76/6 77/19 116/7
133/10
equality [1] 25/20
equation [1] 143/13
equipped [1] 92/2
er [1] 115/15
escalate [2] 59/6
138/4
escalated [6] 58/25
59/24 59/25 64/5
121/13 137/17
escalation [5] 73/2
73/8 81/18 144/16
144/23
especially [6] 72/19
87/23 153/5 157/12
159/13 160/25
essential [2] 36/14
46/10
essentially [26] 12/1
12/11 12/18 15/1
16/23 20/12 33/12
34/7 35/6 40/5 43/25
48/13 50/25 71/15
76/5 77/7 96/17
100/14 101/16 114/5
126/22 132/22 134/21
139/2 140/6 162/18
establish [3] 11/18
16/18 118/7
established [4] 27/9
27/21 27/24 63/19
estimates [1] 167/16
et [2] 39/22 116/14
et cetera [1] 39/22
etc [1] 37/10
ethical [1] 166/1
ethos [3] 163/25
164/17 166/18
Europe [1] 26/6
evaluated [1] 46/9
evaluating [1] 137/15)
evaluation [3] 73/2
73/8 107/9
even [23] 4/14 19/4
37/15 50/14 56/23
63/24 64/8 67/23
103/25 116/13 120/15}
120/19 125/22 128/14I
136/13 136/25 139/17
154/5 155/21 158/15
162/22 165/18 166/1
events [3] 71/3
111/20 139/21
ever [4] 1/15 76/20
112/25 132/2
every [4] 19/6 23/10
70/16 157/10
everyone [1] 31/22
everything [5] 54/24
83/17 161/20 161/21
166/16
evidence [67] 2/7 2/8
3/2 9/22 9/23 9/24
16/15 17/14 17/25
18/1 18/6 18/20 18/22)
18/24 20/8 54/9 59/1
59/9 69/25 72/16
78/20 80/3 88/3 90/15]
90/21 91/17 93/9
93/10 93/12 97/15
99/11 100/8 101/3
103/7 108/7 110/3
110/4 111/3 113/19
119/11 119/15 120/3
120/15 122/8 123/1
132/5 133/5 135/15
136/13 138/15 138/25]
142/5 142/12 143/19
146/10 146/17 146/18)
147/9 147/25 148/14
157/17 159/4 160/16
161/3 161/18 162/2
165/10
evidenced [1] 146/17
evident [2] 104/2
164/20
evidential [1] 20/23
evolving [2] 25/22
25/23
exacerbated [2]
68/20 72/1
exact [2] 85/20 105/8
(62) doing... - exact
E
exactly [20] 10/15
21/18 22/3 35/1 40/10)
50/5 67/9 74/11 95/9
95/25 97/7 102/3
102/10 103/19 114/16)
117/10 128/25 134/23}
143/25 166/14
examination [2] 19/5
106/15
examined [4] 75/13
93/18 109/11 140/15
examining [1] 78/1
example [25] 12/4
12/22 23/1 25/16 29/1
32/7 35/12 38/21 40/1
44/15 49/13 51/17
52/9 54/3 63/25 66/17
89/10 89/12 91/24
105/17 139/7 140/8
140/12 144/7 144/9
examples [3] 41/14
133/19 166/21
exceptional [1]
141/19
exceptionally [1]
143/6
excerpts [1] 17/25
exchange [1] 56/15
exchanges [2] 10/2
162/13
excite [1] 84/3
excluded [2] 113/2
117/13
excluding [5] 112/12
112/18 113/4 113/12
113/17
exclusion [3] 111/18
113/2 122/2
ExCo [10] 23/21 58/7
58/8 124/20 125/1
125/3 126/1 134/18
135/14 136/11
excuse [1] 65/5
exec [1] 157/3
Execs [1] 147/13
executive [195]
executive's [6] 81/19
82/4 92/23 93/2
129/23 145/23
executives [29]
26/11 26/12 27/14
41/7 45/6 45/12 45/13
45/15 46/6 60/10
60/11 60/13 67/12
72/4 72/21 94/11 95/3
103/25 112/10 113/20}
133/21 147/22 148/23)
149/12 149/22 149/25)
154/18 157/18 159/10
executives’ [1]
166/16
exercise [7] 37/1
38/19 101/14 119/14
124/12 141/18 161/9
exercised [5] 38/10
111/24 112/4 113/20
140/10
exert [2] 102/4
102/10
exhaustive [1] 19/6
exist [3] 51/23
129/22 130/3
existed [1] 130/24
existence [4] 35/13
107/20 129/19 131/5
existent [2] 107/19
107/20
existential [2] 84/8
84/13
existing [1] 119/17
exists [1] 162/5
exit [4] 160/8 160/13
162/24 162/24
exit' [1] 160/9
expand [8] 78/22
80/25 88/24 92/11
94/6 136/19 148/20
164/25
expect [13] 37/6
86/15 87/12 89/24
98/17 98/20 100/23
107/13 108/21 129/25)
130/16 142/17 143/3
expectation [9] 30/2
38/15 44/20 97/20
97/21 108/11 108/13
141/13 153/14
expectations [5]
11/11 27/5 59/21
96/10 107/5
expected [37] 10/9
10/11 10/16 10/19
16/1 16/7 16/21 17/14
22/17 25/25 45/7
45/10 48/12 57/13
59/17 60/19 83/21
86/8 86/12 86/18
86/25 96/1 96/5 96/8
97/25 100/3 102/4
107/3 110/6 111/4
112/12 113/1 127/22
127/23 141/9 143/9
148/4
expected/best [1]
10/9
expecting [3] 101/21
117/4 142/6
expects [1] 87/8
expenses [1] 45/10
experience [26] 6/23
7/1 7/22 8/21 15/16
15/21 17/4 43/7 43/13
48/2 49/14 53/23 54/5)
59/20 107/8 107/8
107/15 107/15 112/19)
exercising [1] 111/10
117/12 148/4 148/9
149/14 154/22 157/4
163/23
experienced [1]
165/24
experiences [6] 91/5
112/6 112/9 163/19
164/5 166/23
Experiencing [1]
53/14
expert [13] 3/21
17/14 54/21 59/8
91/17 91/18 92/15
119/10 119/12 153/25}
157/7 157/9 159/8
expertise [13] 6/23
7/2 8/21 15/16 15/22
41/5 41/25 42/25
53/21 89/1 93/8 150/1
154/8
experts [2] 91/13
107/15
EXPG0000006 [1]
3/15
EXPG0000010 [1]
4/10
explain [23] 18/24
28/25 29/7 31/4 31/12
32/5 33/4 40/24 47/13)
48/23 53/15 67/11
68/23 78/22 81/3 86/5
90/20 110/20 114/20
122/20 136/19 148/20
165/1
explain’ [1] 28/20
explained [4] 40/13
42/5 149/6 158/20
explaining [1] 40/6
explains [1] 38/7
explicit [5] 62/1
118/15 126/9 136/4
148/25
explicitly [2] 107/25
120/13
exploring [1] 54/16
express [2] 85/14
125/21
expressed [3] 17/17
99/21 160/11
expressing [1]
113/23
expressions [1]
112/2
expressly [1] 105/15
extend [3] 77/13
87/22 92/9
extent [7] 16/6 46/21
84/18 95/17 123/12
131/8 144/8
external [9] 52/10
99/24 129/5 129/11
131/16 142/4 144/8
146/17 161/9
extract [1] 103/12
extracted [1] 106/12
extremely [1] 135/1
Eye [1] 82/18
F
face [7] 79/11 116/18
118/22 118/22 121/16}
121/16 164/18
facilitating [1] 115/5
facing [2] 64/4
165/23
fact [41] 16/7 16/19
23/7 35/17 41/3 41/8
43/14 49/15 52/5 58/3)
60/20 66/15 75/4
81/23 84/7 84/13 87/7,
97/16 99/25 100/17
101/9 105/24 106/10
111/14 115/2 122/1
129/4 131/11 132/15
137/2 137/4 142/19
144/19 145/4 149/18
152/13 154/3 158/10
161/8 161/12 161/14
factor [1] 67/14
facts [5] 23/1 55/13
56/21 114/6 117/21
factual [2] 94/20
94/22
failed [5] 67/12 67/15
70/15 112/5 131/5
131/8
failure [39] 21/23
21/25 22/3 22/7 22/7
22/8 22/14 22/17
22/21 22/23 23/7
23/15 23/16 23/16
23/20 24/1 24/4 57/5
57/6 57/8 59/4 60/21
64/19 65/10 70/9
70/25 71/4 71/12
110/1 120/2 120/4
120/6 122/11 137/18
137/19 140/2 158/18
164/20 164/21
failures [5] 22/6 57/4
65/16 68/19 70/25
fair [2] 19/9 94/24
fairly [1] 80/13
fall [1] 43/2
fallen [4] 158/21
falling [3] 78/25
78/25 79/1
falls [1] 52/21
familiar [1] 78/18
far [8] 28/3 60/2
64/20 67/18 75/9
79/13 90/5 94/25
fault [3] 69/24 101/3
133/15
67/23 67/25 67/25 —_I financial [10] 8/16
failing [2] 64/17 46/15 46/18 46/21
80/10 46/25 47/2 47/5 47/9
failings [5] 70/11 83/10 83/11
fault’ [1] 100/9
faults [1] 67/13
FCA [1] 46/21
fear [1] 49/4
feature [4] 62/6
66/17 91/14 103/9
featured [2] 156/23
157/19
Federation [1]
167/13
feedback [1] 63/21
feel [5] 43/10 96/22
137/1 138/2 146/9
feeling [1] 44/17
feet [1] 69/3
feint [1] 92/7
fellow [1] 9/4
felt [13] 17/20 29/4
47/20 49/7 53/9 77/12
92/2 94/20 97/2
125/17 132/17 153/17)
157/18
few [2] 61/1 77/12
fiduciary [3] 88/14
88/18 88/21
field [2] 157/7 157/10
fifth [2] 35/20 91/11
finance [5] 26/13
26/14 39/22 45/7 68/5
finances [1] 45/11
find [14] 27/20 28/4
31/3 107/6 107/8
107/18 128/7 136/22
137/6 147/25 153/1
160/6 161/15 165/21
finding [2] 67/5 118/3
findings [5] 78/10
90/17 96/4 96/7 99/14
finds [1] 11/11
fine [4] 50/11 83/17
161/20 167/8
finish [4] 167/6
firm [1] 131/24
firmly [1] 80/4
first [46] 2/19 3/5
3/14 3/19 4/1 4/6 6/21
6/23 6/25 10/23 13/10I
13/13 15/8 19/10
20/15 21/15 25/9
31/12 38/1 38/2 42/3
47/20 54/11 54/15
55/1 55/2 55/4 61/19
67/12 69/2 76/25
81/10 101/25 104/22
119/20 127/15 138/19)
141/21 142/10 142/22!
142/23 145/21 149/2
150/8 154/23 156/19
firstly [8] 2/9 6/8 7/5
8/22 21/14 31/4 31/21
(63) exactly - firstly
five [5] 4/23 4/24
118/17 150/25 167/10
fixed [4] 4/19 80/13
80/16 80/16
flag [1] 94/2
flagged [2] 96/3
101/11
flaws [1] 135/15
Flemington [1] 119/4
flows [1] 45/7
focus [13] 57/18 61/7
61/10 66/9 72/24 74/6
TAIT 77/9 77/9 95/5
134/9 138/1 155/23
focused [6] 79/2
87/18 88/1 110/10
142/6 156/4
focuses [1] 101/7
focusing [3] 94/12
124/23 142/8
follow [6] 11/13 40/4
99/16 154/10 160/10
163/18
follow-up [1] 99/16
followed [3] 25/5
61/24 105/2
following [7] 36/2
61/23 105/8 109/9
119/19 124/8 168/11
follows [1] 76/22
foolproof [1] 90/1
foot [19] 7/24 12/23
15/9 26/17 30/5 39/11
39/23 46/12 50/12
78/6 124/5 129/8
137/11 138/25 144/19
150/9 156/10 156/21
164/8
form [8] 68/22 68/25
82/2 97/15 103/10
113/10 113/16 160/23)
formal [10] 11/21
11/23 13/13 14/12
14/19 38/12 38/24
76/20 120/5 120/6
formally [3] 63/1
151/21 152/17
format [2] 35/6 36/6
formation [1] 25/2
formatting [1] 3/10
formed [1] 80/14
forms [1] 29/13
formulate [1] 167/5
formulated [2] 59/16
134/19
formulating [1] 56/6
forum [1] 62/7
forward [2] 30/23
82/1
forwards [2] 5/2 78/8
found [11] 47/23
55/25 69/12 99/11
119/23 137/17 145/2
145/17 157/17 161/1
165/8
foundation [2] 17/9
66/12
founded [2] 15/18
15/20
four [8] 30/25 31/4
31/23 33/17 36/7 68/3)
68/8 107/19
fourth [2] 5/15 33/4
Fourthly [4] 2/22
fragmented [1] 92/5
fragments [2] 128/21
129/2
framed [1] 134/14
framework [6] 30/9
73/1 73/7 133/25
134/20 135/6
frank [2] 126/12
132/11
FRC [1] 47/5
free [1] 57/9
freely [1] 50/9
frequently [1] 30/1
front [2] 3/16 110/13
frontline [3] 163/17
165/25 166/5
FSA [4] 46/14 46/14
46/24 47/3
Fujitsu [1] 53/6
Fujitsu's [1] 118/16
fulfilment [1] 160/22
fulfils [1] 85/25
full [6] 1/10 66/1
99/14 131/8 133/17
167/24
fully [10] 37/9 43/17
93/24 98/3 98/20
104/11 108/3 125/12
127/11 134/17
function [8] 62/21
62/22 64/25 65/7 68/5)
131/6 141/19 142/13
functional [8] 64/1
68/8 89/9 89/13 92/8
93/4 124/21 153/7
functionally [1] 75/4
functioning [2] 37/9
150/18
functions [7] 63/25
68/4 79/8 90/18 91/12
134/15 144/9
fundamental [3]
30/14 39/1 110/19
fundamentally [1]
49/1
funding [3] 29/17
79/2 79/4
funds [1] 82/14
further [6] 4/19 82/20
90/12 94/8 128/23
146/8
Furthermore [1]
71/23
future [4] 52/7
133/23 155/8 155/21
G
Gareth [2] 118/16
120/2
gather [1] 108/13
gave [3] 71/25 121/1
136/1
gaze [2] 52/21 78/24
GC [4] 158/11
general [79] 17/18
19/19 44/12 56/13
63/8 63/8 63/9 71/11
83/5 88/20 88/23
88/25 89/3 89/7 89/15
90/4 91/20 91/25
97/22 112/20 112/24
113/1 113/5 113/12
113/24 114/3 114/10
115/1 115/5 115/7
115/8 115/9 115/15
116/16 117/2 117/9
119/2 120/7 120/8
120/12 122/19 122/25)
123/3 123/5 123/5
124/10 125/6 125/12
125/16 127/5 130/7
130/9 131/8 132/17
136/14 136/25 137/19]
137/22 143/3 151/18
151/20 152/1 152/7
152/12 152/13 152/19!
152/23 152/24 153/2
153/5 153/10 153/15
153/25 154/4 154/5
157/14 157/25 158/1
161/6
generality [2] 86/2
86/3
generally [5] 10/11
10/16 73/11 114/24
125/12
generator [1] 143/18
germane [3] 71/1
106/1 153/17
get [6] 48/5 61/13
72/20 101/22 112/8
121/3
gets [1] 121/22
getting [6] 69/3 69/7
78/12 79/2 111/24
121/19
give [11] 3/3 37/23
52/11 90/23 96/5
116/11 120/13 120/14
135/8 167/4 167/8
given [19] 42/17 90/1
90/8 90/9 99/24
104/25 106/13 108/18}
113/11 113/12 113/16}
122/9 125/18 132/25
132/25 148/14 148/25)
149/3 161/15
ives [1] 27/9
giving [3] 2/8 78/11
100/6
go [58] 3/20 4/19 5/1
5/8 6/7 6/21 11/17
12/2 12/6 13/21 13/23}
14/9 15/8 15/24 16/10)
19/22 20/1 27/7 29/9
30/23 36/21 36/24
39/11 39/14 43/18
46/12 48/9 48/14
48/16 51/19 62/11
66/5 72/22 77/24 78/8
82/20 83/19 86/5 88/7
95/1 95/20 107/22
110/5 112/17 114/4
116/6 117/4 119/16
131/15 134/15 138/11
138/21 144/12 149/22}
150/7 154/11 162/18
164/8
goes [6] 8/20 79/20
110/24 140/16 147/23}
155/11
going [51] 2/4 3/12
4/22 11/6 11/17 14/9
25/1 25/1 31/16 33/16)
36/21 37/15 38/9
42/21 44/16 45/4 48/5)
54/13 56/11 57/6
62/19 62/20 64/22
67/20 72/13 83/17
97/5 98/23 98/23
98/24 100/19 101/4
101/23 102/19 109/4
4111/8 117/114 117/12
128/7 136/6 138/15
138/18 142/21 144/25)
146/2 146/9 149/6
153/4 153/23 166/4
166/17
gone [1] 130/19
good [18] 1/3 1/8
17/11 18/16 22/18
30/14 59/17 76/7 79/8
85/9 85/10 103/17
103/20 134/16 141/1
146/1 146/6 150/21
got [25] 3/2 4/18
24/23 36/22 41/10
41/12 45/19 54/6
55/16 59/4 84/11 91/1
99/9 99/11 101/24
105/1 121/23 122/25
126/15 126/24 144/14
146/5 146/7 160/10
161/1
governance [107]
TIT 7123 8/24 10/24
11/10 11/22 13/6
13/11 14/5 15/12
15/15 16/24 17/11
18/11 18/16 20/5
20/12 21/1 21/7 21/12I
21/23 21/25 21/25
22/6 22/7 22/8 22/9
22/12 22/18 23/7
23/15 23/16 24/2
24/13 24/22 25/4 25/8)
25/14 26/24 26/24
27/5 28/5 28/8 29/12
29/19 29/22 30/8
30/10 30/14 30/20
31/22 31/23 36/15
37/6 37/8 38/6 38/8
38/14 44/7 44/10 45/3}
46/5 46/10 47/5 47/11
48/21 48/24 49/2
52/13 53/14 53/22
53/23 54/3 54/4 59/18}
60/21 60/24 68/21
71/7 79/7 83/6 85/21
96/12 107/7 107/16
110/22 120/4 120/5
129/15 129/17 134/16)
134/17 138/20 140/2
141/2 141/5 144/4
145/4 145/7 150/13
150/16 151/22 154/17
158/19 158/20 159/19)
164/22
governed [2] 30/11
42/12
government [27]
10/4 11/6 11/24 12/11
12/14 12/15 13/1 13/7)
13/10 13/14 13/14
15/3 17/18 28/9 29/16)
29/25 30/8 30/19
32/21 32/23 33/4
37/12 42/7 53/3 79/1
79/3 83/7
government-owned
[4] 13/14
governments [1]
11/13
granted [4] 69/5
135/13 136/2 164/1
grateful [3] 5/2 50/17
69/24
great [4] 88/4 109/23
117/6 125/2
greater [2] 60/19
72/8
Greenbury [2] 25/7
26/19
grip [4] 78/12
ground [2] 2/5 2/9
grounds [1] 119/16
group [16] 52/19
56/13 59/25 60/1
62/14 62/22 63/2 63/6
63/23 63/25 64/14
64/15 70/4 70/10
154/21 157/17
groups [4] 40/19
(64) firstly... - groups
G
52/4 52/17
grown [1] 92/8
growth [1] 61/15
guess [2] 74/5 83/22
guidance [14] 10/24
27/21 27/24 29/12
37/2 43/5
guilty [2] 82/13
155/17
guises [1] 163/12
H
had [95] 13/20 19/20
51/5 55/25 56/23
57/20 59/24 61/20
66/1 67/6 68/7 68/14
71/24 72/2 74/15
74/16 74/17 74/18
78/19 79/7 80/11
80/16 80/16 84/15
85/11 85/13 90/1 90/1
95/23 98/2 100/9
100/9 104/23 105/25
106/12 107/4 110/15
115/9 115/12 120/17
121/4 122/4 125/1
126/12 126/15 127/7
127/8 127/14 127/18
128/1 130/8 130/8
130/9 130/19 130/20
130/22 130/23 131/19
131/19 134/3 135/16
136/12 136/17 139/10}
139/17 141/10 141/13)
143/9 144/2 144/3
149/5 153/12 153/17
154/21 156/3 159/10
160/17 162/4 162/24
165/9
hadn't [3] 59/13 97/2
168/6
half [5] 77/18 133/16
162/23 162/24 162/24
halfway [2] 39/20
144/14
hallmark [1] 30/16
Hampel [2] 25/7
26/19
hand [14] 11/2 11/4
11/23 12/9 12/13
12/19 12/20 12/25
12/25 15/2 15/2 90/8
90/9 126/15
handed [3] 103/14
103/17 106/6
groups... [3] 48/1
11/2 11/14 13/3 14/12)
15/4 15/12 23/6 27/10)
23/3 24/20 32/9 41/16
63/4 64/21 64/24 65/4
75/4 75/6 75/17 78/17,
110/24 113/13 114/22)
handle [1] 129/24
handled [7] 46/25
76/16 103/15 130/17
131/1 137/16 156/3
handles [1] 49/13
handling [11] 19/13
73/23 77/14 80/1
98/13 117/18 128/17
130/5 151/2 156/8
164/10
happen [6] 4/22
75/10 96/19 97/24
108/16 108/16
happened [14] 10/1
10/1 10/3 46/4 50/25
96/18 97/16 106/8
107/1 116/25
happening [4]
165/22
happens [2] 115/4
146/13
happy [4] 55/5 93/10
122/17 127/2
hard [1] 3/16
hardly [1] 103/15
hardship [1] 109/21
has [52] 2/18 19/5
24/12 25/15 26/11
29/11 29/24 30/8
30/20 38/25 44/12
44/12 46/4 46/9 49/5
51/16 52/23 54/23
76/11 76/18 83/14
88/16 88/20 88/23
88/25 89/4 89/9 89/12
92/7 98/21 99/3
105/11 108/14 112/22)
112/23 115/1 116/23
122/1 123/8 125/12
125/16 126/5 130/5
133/15 141/23 141/25)
151/18 153/5
hat [2] 130/8 130/10
hats [1] 130/8
have [286]
haven't [9] 4/18 40/8
70/24 72/16 73/13
90/14 148/14 161/18
161/22
haves' [1] 59/16
having [7] 4/17 26/15
128/13 153/14 160/9
162/22 165/19
he [10] 57/20 57/24
57/25 58/2 59/12
59/24 59/25 89/4
151/14 153/16
head [3] 9/1 130/10
146/22
headed [3] 4/11
11/21 53/13
67/8 67/10 74/16 75/8
115/22 116/13 122/23)
49/6 49/20 49/23 50/9
heading [11] 30/25
144/19 146/24 148/3
155/9 159/22 163/3
headings [3] 14/19
15/1 15/25
heads [1] 124/21
hear [6] 9/25 27/22
102/19 106/20 164/4
165/9
76/11 76/18 91/22
92/1 101/25 104/24
161/3 165/12
hearing [2] 9/22
168/11
heart [2] 38/6 68/16
height [1] 86/1
held [12] 7/9 7/21
25/1 45/12 45/13
62/22 75/6 80/4
109/19 127/14 135/4
136/14
help [9] 19/17 44/25
45/21 47/17 62/16
70/23 110/8 126/21
145/1
helpful [1] 24/15
helping [1] 79/4
Hence [1] 44/11
her [41] 55/23 55/24
55/24 55/25 85/16
85/19 86/12 86/15
86/18 86/25 87/1 87/3
87/4 87/8 87/9 87/9
87/15 87/17 87/25
89/1 89/13 92/17 93/2
93/5 94/3 96/5 96/12
98/25 112/21 115/22
119/5 119/24 121/16
122/25 129/25 130/1
130/9 136/11 146/22
158/9 167/25
here [46] 4/25 5/1
12/7 15/3 16/12 30/24]
32/3 33/16 47/13 57/8
63/10 64/18 70/11
70/24 71/14 80/10
81/15 84/25 85/14
96/24 97/3 97/4 99/7
100/15 101/16 106/18}
109/1 111/8 115/2
117/15 123/12 128/10
129/5 129/7 129/10
129/21 131/15 134/21
137/5 138/22 142/12
145/25 148/21 151/22
154/13 160/15
herself [5] 96/3 98/24
116/3 116/4 119/5
high [3] 85/25 86/1
100/4
highest [1] 10/16
headhunter [1] 161/9
38/3 39/4 40/17 43/20
heard [10] 16/15 67/2
highlighted [3] 5/16
131/4 1341/5
highlights [1] 8/1
highly [2] 104/8
106/1
Highway [1] 16/24
him [4] 58/4
hint [2] 100/9 100/24
his [2] 85/19 132/8
historical [1] 24/19
historically [3] 45/25
131/25 136/12
hm [4] 14/22 114/19
158/13 162/12
Hodge [1] 167/10
Hodgkinson [2] 59/1
63/17
hold [4] 25/2 29/3
44/10 154/4
holding [8] 32/18
44/18 62/14 63/6
65/10 72/8 75/3 89/16)
Holdings [2] 32/17
60/24
holistic [2] 133/24
136/5
honest [1] 49/5
hope [2] 22/5 106/9
Horizon [51] 32/9
47/14 55/25 56/16
58/18 63/20 64/7
64/13 67/14 69/7
71/11 73/3 73/13
75/19 76/11 78/14
79/12 79/16 79/21
80/13 81/5 82/9 82/19
82/24 88/10 89/19
90/24 91/20 98/5
99/24 100/2 103/8
106/4 106/5 109/17
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136/13 139/24 146/18}
148/17 149/2 163/7
163/12 164/6 165/4
Horizon's [1] 155/15
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30/10 33/17 35/17
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49/24 52/6 57/4 64/17
65/9 68/12 69/10
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56/18 57/1 57/9 57/10)
154/16 155/13 155/25}
161/17 161/18 167/9
168/4
Howe [1] 167/11
however [8] 2/17
62/23 100/11 102/12
108/1 111/2 137/17
167/6
HQ [4] 116/14
HR [2] 63/25 153/12
Hudgells [1] 167/12
huge [1] 163/7
Hugh [4] 119/4
human [2] 109/21
116/10
humiliating [1] 116/9
hundreds [1] 140/17
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36/16 38/7 38/11
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36/21 38/9 38/15
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157/15
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69/18 113/7 150/6
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85/24 94/7 96/11
97/17 99/18 102/8
132/24 135/23 143/7
145/25
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115/4 115/6
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131/13
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83/22
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112/24 113/9 126/24
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l imagine [3] 117/6
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l imagine... [2]
122/23 144/10
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152/3
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68/2 84/11 86/2 105/7
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lreads [1] 6/4
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84/1
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151/20 168/1
I say [2] 165/17
167/17
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82/6
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I should [7] 1/14 2/1
94/16 114/24 114/25
129/22 138/13
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I spoke [1] 95/10
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8/22
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I take [1] 56/20
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4/16 4/19 6/25 8/1
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28/6 30/6 30/12 40/23
44/15 46/17 47/13
49/22 50/12 52/1
52/13 53/2 55/5 57/21
59/1 60/17 61/18
64/19 67/4 68/19
73/14 74/11 74/13
75/14 77/17 80/10
80/25 81/21 82/20
84/22 92/13 93/18
94/24 95/22 101/5
102/1 112/6 114/4
114/17 117/2 119/19
121/8 121/24 121/25
122/22 123/11 127/3
127/15 128/5 128/9
132/7 132/11 132/16
133/18 142/10 143/24}
144/18 145/3 148/24
151/20 152/11 152/13}
153/1 155/9 155/11
156/11 161/1 162/4
164/23 166/5 167/18
167/23 168/7
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I understand [3]
10/12 15/17 61/9
I understood [1]
143/5
I want [1] 24/8
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82/6 105/24
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won't [1] 154/9
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98/20 133/11 143/3
143/8 144/11 167/5
167/18
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77124 144/2
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80/7 98/16
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25/22 31/15 50/17
54/13 56/11 61/2
70/12 70/15 70/22
73/15 83/22 83/22
83/23 84/14 87/7
100/17 109/4 116/21
127/2 128/7 132/7
138/15 142/8 142/15
142/21 153/24 154/7
160/16 168/1
I've [13] 4/18 16/22
23/19 27/2 45/19
48/22 80/7 105/25
106/5 113/5 128/18
140/6 161/1
idea [3] 99/3 121/2
167/8
ideally [1] 147/5
ideas [2] 47/6 155/15
identical [1] 51/4
identifiable [1] 46/2
identification [8]
46/7 73/1 73/8 73/14
129/16 144/16 144/23)
147/3
identified [44] 20/24
21/24 22/18 22/22
23/6 23/12 25/11
25/15 32/24 44/20
46/8 53/2 54/2 54/10
54/11 56/25 59/18
60/19 66/1 70/25
80/24 85/1 85/13
87/13 88/10 96/4
103/13 104/2 105/4
105/21 106/10 108/22)
129/5 129/21 138/12
139/5 151/21 151/22
156/5 158/16 158/24
159/22 160/18 163/2
identifies [1] 22/14
identify [23] 17/2
20/10 21/20 24/21
31/11 47/21 61/23
61/25 65/18 70/3
70/11 74/25 78/5
104/16 108/10 109/2
129/24 138/3 138/21
138/24 139/3 139/14
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identifying [4] 15/11
47/4 47/8 105/16
identity [2] 36/13
79/11
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14/23 19/6 36/7 40/5
54/14 59/10 66/2 81/8
106/18 106/24 111/14
113/13 114/9 142/19
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ie bringing [1]
142/19
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ie in [4] 111/14
ie incorporated [1]
12/15
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ie looking [1] 19/6
ie primary [1] 14/23
ie that [1] 113/13
ie the [1] 40/5
ie there [2] 81/8
114/9
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ie why [2] 106/18
106/24
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if [153] 2/9 5/1 5/9
6/4 7/4 8/19 9/15
11/17 12/2 12/6 13/21
13/23 15/24 19/10
20/1 20/10 20/15
22/14 23/1 24/9 24/15
26/1 26/5 27/7 28/25
32/2 32/10 33/4 33/15)
34/2 35/5 35/11 35/25
36/19 38/9 39/11
39/14 40/2 40/25
43/21 46/12 50/12
51/19 52/15 55/18
56/8 59/12 59/24
60/20 61/2 61/20
62/11 66/5 67/6 67/7
67/11 68/2 69/10
69/23 71/3 71/7 71/24
72/9 77/16 77/17
77/24 78/8 83/8 83/9
83/10 83/16 83/19
83/22 84/1 84/15
87/13 89/3 89/5 89/9
89/17 90/2 91/12
91/25 96/3 96/22
97/15 99/10 99/22
100/21 100/22 100/25
101/2 102/10 105/23
107/4 107/22 109/2
110/15 111/2 111/5
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117/8 117/12 118/9
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121/14 122/12 122/23}
125/17 128/7 128/9
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130/3 130/5 133/18
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143/5 143/13 144/2
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158/17 159/13 160/16
160/25 161/10 162/1
163/9 164/8 165/1
165/12 165/18 166/1
166/20 166/21
ii [1] 10/10
iti [1] 10/22
ill [1] 92/2
illustrate [1] 139/13
illustrated [1] 159/1
illustrates [2] 139/9
155/3
illustrations [2]
19/21 159/3
imaginary [1] 158/14
imagine [5] 67/16
93/3 117/6 122/23
144/10
immediate [5] 94/3
110/3 118/23 124/10
124/14
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57/17 121/4 128/2
135/7 136/24
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impact [11] 52/24
56/22 57/10 86/10
88/11 92/24 103/7
130/22 130/23 152/20}
158/8
impacted [1] 118/2
Imperial [1] 7/9
impersonal [1] 116/8
implications [3] 69/8
123/2 125/10
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implies [2] 116/9
122/16
implying [2] 120/11
122/10
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importance [4] 38/24
80/8 80/17 138/22
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129/2 137/15 142/25
157/12 163/16 164/4
impossible [2]
134/15 165/8
improve [1] 155/2
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improvement [1]
160/12
inaccuracies [3]
94/20 94/23 95/6
inaccurate [1]
125/19
inadequately [1]
102/3
inappropriate [3]
43/9 83/18 89/21
included [5] 48/23
90/17 122/5 130/11
139/11
includes [2] 17/3
65/22
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9/9 17/25 27/13 32/7
37/10 45/8 87/23
100/8 147/7 162/8
162/10 162/13
inclusion [2] 25/20
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125/19
incorporated [2]
12/15 35/17
increasing [1] 76/12
increasingly [3]
25/15 29/11 164/20
indeed [58] 2/2 7/12
10/21 12/17 12/21
13/4 14/6 14/6 16/18
19/16 19/24 21/4
21/25 22/25 23/8
23/14 24/3 24/7 28/1
28/11 28/24 29/25
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34/21 38/14 39/9
39/13 40/8 41/21
43/12 47/16 48/19
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61/25 62/25 66/19
75/2 96/20 107/21
112/7 114/8 131/20
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146/19 149/20 149/24)
150/2 153/10 153/20
166/5
independence [4]
82/10 102/4 102/10
132/9
independent [35] 8/4
8/15 39/19 41/1 41/3
41/4 41/8 41/9 41/10
41/19 41/23 42/11
42/11 42/17 59/8
(66) imagine... - independent
60/12 60/14 60/15
60/17 62/21 69/15
72/20 79/6 80/11
80/15 88/25 89/15
130/9 132/3 150/19
154/19
indicate [2] 24/4
45/24
indicated [3] 22/5
79/10 105/25
indication [2] 101/3
121/24
indications [2] 140/1
155/22
indifference [1]
166/22
indirectly [1] 98/16
individual [7] 28/21
93/14 148/10
individually [2] 2/13
2/16
individuals [4] 24/5
40/12 152/10 157/3
induction [3] 66/18
148/25 149/24
Industry [1] 35/22
INEDs [4] 40/21
40/25 41/1 41/8
inevitably [3] 47/24
129/18 163/8
inexperienced [1]
154/18
influence [3] 102/13
102/13 132/20
influential [1] 150/22
inform [2] 125/13
125/20
informal [3] 38/15
120/6 153/15
information [32] 23/4
23/20 37/4 45/3 69/7
78/11 80/20 81/25
87/4 90/12 96/23 97/2
100/12 103/2 103/8
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120/13 120/21 121/22)
125/19 128/15 132/12)
135/4 136/3 136/23
139/17 145/8 145/19
147/10 147/19
informed [8] 20/8
42/20 44/21 53/20
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157/11
inherent [3] 48/6
64/12 71/10
initial [2] 74/14 125/9
initially [2] 32/15
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independent... [20]
72/5 72/7 72/15 72/17
42/13 71/2 71/3 87/14
injury [1] 73/25
innocence [1] 164/14
Inquiry [24] 1/10 3/12
9/23 14/8 16/23 18/12
18/14 18/23 18/25
20/9 21/12 21/13
25/23 36/20 40/24
41/14 53/11 70/23
71/1 75/21 76/11
76/18 91/22 148/2
insert [1] 6/2
insignificant [2]
164/1 166/22
insofar [3] 30/2
86/10 113/25
Insolvency [2] 73/22
73/23
inspected [1] 83/6
instance [2] 2/19
90/3
instantiated [1]
116/22
instead [2] 18/14
109/7
instil [1] 155/2
instituted [1] 118/25
institutional [1]
27/16
instructed [2] 10/8
16/18
instructions [4] 9/18
19/20 29/20 118/25
instrument [2] 27/20
40/12
instrumental [2]
166/3 166/7
instruments [5] 15/4
15/19 15/21 17/8
85/21
integrate [1] 122/11
integrity [1] 118/3
intend [1] 2/1
intention [4] 16/18
35/4 106/16 106/21
interconnectedness
[4] 110/12
interdependent [1]
145/6
interest [20] 25/18
30/17 38/21 43/8 51/1
52/5 53/11 53/24
53/25 76/15 79/10
99/24 102/14 129/6
129/11 130/6 144/2
144/4 155/16 156/8
interested [3] 52/15
143/9 153/19
interests [7] 7/20
22/13 22/16 52/16
71/1 129/18 131/7
interfere [1] 110/23
interfering [2] 111/9
146/2
interim [19] 19/12
94/18 95/15 96/7
98/13 101/21 105/9
118/18
intermediate [3]
32/11 33/1 34/24
intermediately [1]
32/18
internal [5] 52/8 52/9
129/5 129/11 131/2
interpretation [1]
43/5
interrelates [1]
159/19
interrogate [1] 108/3
interrogated [4] 96/2
103/25 104/11 128/5
interrogating [2]
62/25 95/16
interrogation [1]
61/17
interrupted [2] 152/3
152/3
intervene [1] 2/24
into [50] 5/11 5/15
6/11 6/18 11/1 12/19
14/12 19/22 24/20
33/19 36/1 40/18 47/4
48/10 48/13 55/24
57/18 58/4 68/13
76/10 83/18 83/21
84/17 87/4 89/24
90/12 91/9 92/22 97/8
97/10 102/14 102/15
110/5 117/4 118/3
121/19 122/11 130/14
130/19 134/18 136/5
136/21 143/13 145/9
145/19 146/8 146/20
148/25 156/4 162/8
introduce [1] 149/13
introduced [1] 51/5
introduction [4]
47/14 82/13 96/24
104/25
invented [1] 40/9
invention [1] 31/8
invert [1] 54/13
investigating [1]
83/25
investigation [2]
5/18 163/24
investigations [11]
5/12 5/16 78/12 82/11
82/12 82/16 103/5
106/3 139/10 140/12
147/11
investigative [2]
76/14 78/19
investigator [1]
143/16
75/23 77/15 88/6 88/9
90/3 91/6 91/10 93/16
105/10 105/25 113/22
intermediary [1] 42/8
investment [2] 8/10
163/7
investors [1] 33/7
invite [1] 157/10
invited [1] 97/8
inviting [1] 2/20
involved [3] 97/9
132/23 163/11
involvement [1]
76/17
involves [1] 55/12
involving [2] 10/3
110/25
irony [2] 84/6 84/10
irrespective [1]
142/18
irritation [2] 113/20
156/2
irritations [1] 110/3
is [413]
is particularly [1]
TAIZ
isn't [6] 105/4 112/15
113/4 129/19 152/5
158/20
isolate [2] 55/14
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isolated [3] 20/24
36/6 77/19
issue [53] 35/21
55/16 62/8 62/12
62/16 63/12 64/16
65/16 68/11 68/12
70/8 70/8 78/4 78/5
78/7 79/15 79/19
82/23 85/12 85/15
85/18 92/25 95/12
95/18 99/19 99/20
102/21 104/16 106/2
108/10 108/23 108/25)
109/25 111/12 114/13}
122/10 123/18 123/24
123/25 124/4 127/21
129/4 129/10 133/6
135/7 138/21 138/22
138/25 144/21 149/4
156/21 162/7 165/2
issue 2 [1] 123/18
issue 6 [1] 135/7
issued [4] 13/5 13/11
13/14 13/15
issues [46] 3/10
55/13 55/14 58/14
65/18 71/2 71/3 75/13)
77/19 77/22 78/1
78/21 80/6 85/12 86/9
86/13 86/16 86/18
88/10 96/3 96/15
99/18 100/4 100/10
100/24 103/4 103/13
104/15 105/4 105/21
106/15 107/24 108/4
108/12 108/20 114/9
119/20 122/17 124/23
126/6 126/17 126/19
126/21 137/14 156/1
158/16
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It'll [1] 150/8
it's [67] 1/15 3/19
4/11 5/13 6/23 9/21
9/24 17/3 23/9 26/12
26/16 28/3 35/17 38/2
38/14 45/3 49/1 57/6
57/22 59/1 60/17
60/18 65/17 72/6
74123 74/25 75/14
77/14 78/24 80/10
84/12 86/3 90/8 93/18
102/22 103/14 103/14I
105/9 105/14 110/22
111/20 112/7 120/24
121/2 121/21 121/21
122/12 123/10 127/12
129/17 129/23 130/3
132/12 135/1 137/18
138/22 141/21 142/1
144/19 145/20 149/9
151/23 153/2 154/8
159/14 163/2 167/17
italics [1] 5/22
item [3] 99/4 101/10
101/17
items [1] 107/18
iterations [1] 76/19
its [38] 3/6 3/7 20/13
22/16 27/8 32/24
33/24 34/3 34/10
41/22 45/18 53/3 54/5)
60/3 62/24 66/20
66/21 77/11 84/4
99/25 109/17 115/23
120/14 133/2 134/2
134/3 134/4 135/12
136/17 140/10 141/11
143/1 143/1 148/5
163/8 163/12 163/14
165/3
itself [13] 14/10 28/9
47/9 51/7 94/5 96/18
104/14 110/10 110/25)
111/15 111/19 133/4
138/16
iv [1] 10/22
J
James [2] 76/13 88/7
January [3] 100/5
100/21 162/2
January 2014 [1]
162/2
Jason [4] 1/9 55/24
59/10 59/23
Jenkins [4] 118/16
119/12 119/18 120/3
Jo [1] 162/9
job [3] 38/13 95/16
146/3
(67) independent... - job
J
join [2] 142/24
154/23
joining [1] 148/23
jointly [1] 125/10
Jones [1] 167/11
journalists [2] 76/14
78/19
JPMorgan [2] 8/9
8/10
Judge [2] 7/15 9/5
Julie [1] 55/21
July [37] 57/24 75/25
76/24 77/3 77/6 77/8
78/7 79/24 81/4 93/24
94/12 97/16 100/12
101/7 101/21 102/18
102/24 104/15 104/18}
104/24 105/5 105/12
105/18 108/25 109/7
118/13 118/18 118/21
118/22 119/3 119/24
124/3 124/16 139/21
147/14 153/11 156/1
July 2004 [1] 57/24
JUNE [4] 1/5 1/12
121/15 169/2
just [55] 4/20 7/25
11/18 13/9 14/17
15/13 15/17 20/10
20/19 23/19 24/12
24/15 26/1 26/2 26/18
27/6 30/6 31/18 32/2
32/5 35/14 35/25
37/23 40/4 40/16
43/24 46/11 49/19
51/3 67/8 69/18 73/5
73/9 77/17 78/6 85/1
94/16 98/11 99/23
101/17 121/2 123/4
123/10 124/17 129/8
137/22 138/17 144/19}
150/7 151/23 162/1
162/15 164/8 166/10
167/8
justice [6] 118/5
126/8 126/14 135/19
164/19 165/10
KO
Katie [1] 1/13
Katy [3] 1/4 1/6 169/4
keep [6] 12/3 12/3
42/19 42/20 100/3
157/11
keeping [1] 151/6
kept [2] 127/13
152/12
key [9] 46/2 52/17
52/19 53/3 53/6 72/18
95/4 95/14 139/14
kind [2] 74/1 98/17
King [7] 117/24
118/11 119/14 124/13
131/17 132/2 132/9
knew [10] 102/11
102/11 109/15 109/21
126/7 126/16 127/6
127/18 127/9 128/22
know [27] 1/9 19/7
31/23 61/11 68/9 71/4
71/5 75/10 83/19
91/25 98/22 101/2
101/23 102/19 117/8
120/23 122/6 127/1
144/7 145/10 154/3
158/15 160/16 166/12)
166/13 167/20 167/24)
knowledge [9] 4/2
AIT 6/13 6/18 58/4
58/13 122/11 122/13
123/4
known [15] 13/19
15/14 26/23 59/24
108/19 108/19 118/12)
118/24 127/4 127/5
127/16 127/8 128/3
129/3 143/10
knows [1] 114/15
L
lack [15] 60/18 66/9
68/20 71/23 72/1 72/2
72/19 72/24 74/6 74/7,
95/13 110/3 110/4
116/10 158/5
lacked [2] 73/1 73/7
laid [6] 59/21 105/11
120/7 135/23 137/19
152/17
Lancashire [1] 55/22
language [1] 16/22
large [8] 3/9 12/16
17/10 27/17 102/13
109/18 117/19 163/10)
large-scale [2]
102/13 163/10
largely [4] 20/6 72/4
81/1 161/13
larger [2] 26/8 115/7
last [7] 34/15 65/14
82/3 111/12 142/11
156/18 167/19
lastly [3] 6/1 53/12
82/23
late [1] 51/23
later [10] 50/22 51/18
80/21 82/20 83/20
97/17 97/18 114/4
128/14 134/1
latterly [1] 25/19
law [8] 1/16 11/14
14/21 15/18 23/5
23/25 51/5 87/24
laws [1] 10/24
lawyer [5] 114/22
115/18 116/4 154/1
154/6
lawyers [3] 32/4
124/13 124/15
lawyers’ [1] 125/8
lay [4] 18/24 24/19
63/1 81/5
lead [3] 136/23 147/4
152/18
leader [2] 47/3 47/7
leadership [10] 7/7
7/23 8/23 9/2 15/15
17/5 17/18 53/25
58/10 89/13
leading [1] 86/25
leads [2] 68/9 85/19
leaning [1] 133/22
learn [2] 163/18
166/4
learning [1] 163/22
least [6] 50/15 51/10
68/3 130/16 136/16
153/15
leave [4] 84/4 156/12
161/17 161/18
leaving [2] 117/2
133/16
led [6] 25/2 61/15
87/24 90/2 101/19
124/9
left [9] 11/2 12/9
12/19 12/25 15/2
63/18 82/25 91/19
162/22
left-hand [5] 11/2
12/9 12/19 12/25 15/2I
legal [34] 11/21
11/23 14/12 14/19
62/20 63/25 72/18
89/2 89/10 92/9
115/19 115/23 115/25}
117/23 118/21 119/4
120/17 122/10 122/10}
122/11 122/13 122/16
122/18 122/19 123/4
123/10 123/12 124/17]
130/10 150/14 151/3
151/24 153/8 153/18
legally [1] 132/12
legislation [1] 14/23
legitimate [1] 84/4
less [3] 34/24 61/1
148/24
let [1] 120/19
let's [2] 102/17 141/7
letter [1] 76/20
level [38] 10/17
10/17 21/1 31/12 32/2I
32/5 32/6 32/11 32/14
32/19 32/21 33/3 33/4
33/24 33/24 34/3 34/4
34/5 34/10 34/11
34/17 34/19 34/20
34/25 34/25 35/13
42/8 75/7 85/25 86/1
86/2 90/23 90/24
96/25 100/4 138/1
138/20 151/5
levels [18] 30/25
31/4 31/5 31/11 31/12
31/20 31/24 33/17
34/8 34/12 34/13
34/24 35/8 35/13
35/15 36/8 37/7 141/5
liabilities [1] 45/9
liaison [1] 98/17
lie [1] 65/7
lies [1] 65/7
life [1] 1/15
light [4] 77/5 109/10
131/9 138/12
like [19] 17/3 46/22
46/23 53/23 66/25
67/6 67/7 67/11 73/19
77/24 83/19 88/24
94/8 121/14 128/9
128/16 129/12 164/25)
166/21
likely [5] 57/22 104/8
110/11 150/22 163/13}
limited [3] 35/16 60/7
101/9
line [11] 5/10 5/12
5/15 5/15 6/2 10/10
18/20 91/11 93/21
110/16 153/16
lines [1] 5/22
link [4] 41/11 64/7
64/9 135/14
linked [4] 60/15
60/17 60/18 61/3
list [5] 52/11 126/19
126/22 158/12 158/16
listed [6] 11/4 11/9
11/14 30/9 77/22
101/10
listen [3] 163/18
164/4 166/4
listened [1] 120/10
listening [1] 163/21
Litigation [1] 115/21
little [11] 16/11 31/3
63/23 69/23 72/5 72/6
76/17 77/17 93/4
108/15 157/17
lived [2] 49/14
135/17
local [1] 29/16
locus [1] 149/5
London [2] 7/10 7/10
long [6] 3/6 3/7 30/17
131/21 131/22 160/9
long-term [1] 30/17
longer [3] 24/25 76/1
110/9
look [39] 4/15 11/7
11/17 12/6 12/22
12/24 19/10 21/13
21/13 25/24 29/10
30/5 35/11 43/21 46/6
49/8 50/12 53/24 54/5
55/9 75/15 77/16 78/4I
78/6 79/18 90/2 92/13
93/10 107/4 110/2
110/2 110/4 122/7
124/4 133/18 138/11
141/7 145/9 166/20
looked [20] 15/13
19/2 19/3 19/10 28/9
28/9 28/12 30/13
33/17 37/3 37/5 40/5
60/6 69/12 71/24
73/12 73/13 129/2
130/18 161/22
looking [21] 7/25
10/22 19/6 24/10
27/19 30/1 50/6 54/15}
54/15 65/23 70/8
70/13 81/24 88/8
90/21 90/22 91/8
123/24 124/7 134/21
137/3
looks [2] 26/5 49/14
lose [1] 158/23
lost [1] 58/15
lot [3] 113/23 142/4
165/14
lots [1] 105/25
loud [1] 164/12
lower [2] 135/2 135/4I
lowest [1] 10/17
Lyons [1] 121/25
made [21] 19/1 22/19
47/25 57/12 57/14
61/2 62/1 72/4 73/3
74/13 77/4 81/25
91/23 95/17 105/11
108/24 110/15 116/24I
117/11 137/23 147/23)
magnitude [1]
110/12
Mail [13] 32/17 56/13
60/1 60/24 62/14
62/22 63/2 63/5 63/23
64/14 64/15 70/4
154/21
main [2] 77/13 155/1
mainly [2] 149/12
150/1
maintaining [2] 15/1
151/6
maintenance [2]
140/18 140/19
major [17] 29/16
42/22 47/12 47/21
100/9 100/24 105/3
107/24 108/5 108/12
127/21 139/9 147/3
147/10 157/11 163/15)
165/19
majority [1] 60/10
(58) join - majority
make [16] 4/14 31/8
43/9 49/2 65/1 82/23
83/5 85/19 95/21
95/23 98/1 98/16
124/8 124/19 131/24
157/2
maker [1] 143/17
makes [3] 16/8 17/11
105/22
making [15] 5/8
17/12 27/18 28/2
29/21 62/18 74/12
109/6 125/17 131/10
149/16 154/15 155/6
165/19 167/21
man [2] 29/2 148/24
manage [1] 75/1
managed [4] 30/15
113/14 142/3 145/15
management [33]
13/18 13/25 14/2
15/15 17/12 17/17
20/5 21/2 22/12 46/10
47/11 47/22 48/6 48/7)
48/12 48/22 48/24
49/18 51/22 53/14
53/23 64/1 109/15
126/16 126/23 129/18
130/20 134/9 145/5
159/18 164/22 166/3
166/15
managers [1] 134/15
managing [1] 58/11
manner [3] 109/24
112/17 137/6
manual [2] 73/21
73/23
many [12] 22/6 36/21
44/18 71/2 82/15
87/22 88/23 107/9
108/16 116/3 148/18
167/9
March [3] 3/5 3/18
9/21
MARY [3] 1/6 1/13
169/4
master [1] 7/13
material [11] 14/8
17/13 18/2 18/25 19/5}
19/19 56/5 57/9
128/16 139/3 162/5
materials [1] 109/25
matter [15] 17/16
52/20 71/6 72/1 84/2
96/13 100/19 117/5
120/21 122/10 125/2
146/11 146/14 153/17)
166/9
matters [47] 11/10
16/19 25/9 25/18
25/19 32/8 42/20 43/7
54/14 59/25 61/12
61/16 63/15 71/2
77/12 82/25 83/3
83/12 83/15 83/22
84/7 84/16 87/22
89/25 92/15 92/22
93/25 102/14 103/16
104/7 106/9 111/1
4111/1 111/6 111/11
114/4 115/19 115/25
116/5 125/4 146/7
148/2 150/13 157/11
159/9 165/14 166/2
may [49] 1/3 2/9
14/11 17/19 18/21
19/1 19/24 28/24
36/20 38/20 40/23
41/16 41/21 43/9
43/10 43/12 43/15
51/15 51/22 52/7 52/8)
52/10 57/21 61/10
70/21 77/24 84/20
85/3 89/6 100/10
100/10 100/22 100/25
101/1 108/15 108/16
112/16 115/7 118/7
120/2 125/15 130/22
152/13 152/18 158/22)
158/23 159/4 163/13
167/23
me [15] 1/15 7/4
14/16 38/16 49/25
55/6 83/19 84/4 88/24
113/15 144/4 158/15
164/25 167/8 167/18
mean [26] 21/6 22/8
43/15 62/23 67/2
67/15 68/2 68/23
68/25 84/10 84/11
85/20 86/1 86/2 86/12
90/20 104/3 105/5
105/7 110/17 111/8
112/13 121/22 133/11
153/12 158/22
meaning [3] 67/23
91/4 91/9
means [6] 45/4 45/5
89/13 90/13 111/9
131/13
meant [10] 80/20
94/21 95/16 104/6
106/11 110/20 128/15)
130/14 136/2 159/17
measure [2] 3/9
70/24
measures [1] 150/16
media [5] 79/10 88/7
102/13 109/23 127/21
meet [6] 22/17
111/14 112/4 112/8
112/15 154/1
meeting [26] 77/6
92/4 93/24 93/24
96/18 97/9 98/2 98/8
99/13 100/5 104/14
104/18 105/11 108/25
111/17 111/18 112/10
112/11 112/13 112/19]
118/22 124/16 125/8
147/14 153/11 155/25}
meetings [3] 44/12
60/7 117/13
meets [2] 112/1
112/1
member [17] 8/8
8/11 23/21 69/14
89/14 114/23 115/10
117/3 125/3 130/12
142/24 143/3 157/13
158/11 159/13 159/14
164/11
members [17] 23/3
26/14 39/22 39/25
43/17 66/18 73/25
87/9 89/17 112/18
119/3 129/25 136/16
138/2 148/6 148/10
151/9
memo [2] 94/17 95/5
memorandum [1]
94/17
mention [6] 11/21
17/8 27/11 65/14 84/3
116/8
mentioned [7] 26/18
27/25 30/7 68/19
108/6 156/12 162/16
mere [1] 81/19
messages [4] 90/23
90/24 95/7 104/2
messaging [1] 87/20
met [2] 76/24 118/11
metaphoric [1] 84/21
methodology [2]
9/13 16/13
Michael [2] 59/1
63/17
microphone [2]
69/19 69/20
mid [2] 50/15 76/10
mid-1990s [1] 50/15
mid-2012 [1] 76/10
middle [3] 85/11
123/23 142/15
midst [1] 80/2
might [35] 10/9 15/13
16/1 17/14 23/2 24/4
24/15 36/12 37/16
38/21 42/16 50/2
50/14 50/22 60/5
60/19 65/6 68/2 69/10
70/2 72/20 82/21
83/20 90/7 102/9
102/16 116/8 118/3
118/4 126/16 131/7
153/1 153/3 162/10
162/14
million [3] 57/19
59/22 64/4
mind [8] 30/17 44/15
47/8 50/18 92/23
120/9 126/24 127/2
mindful [4] 16/20
25/22 115/2 149/15
mindset [1] 92/7
minimised [1] 131/9
minimum [1] 134/12
minister [2] 162/11
162/14
Minister's [1] 162/9
ministerial [2] 76/15
79/10
Ministers [1] 33/6
minority [1] 82/12
minute [2] 4/23
112/18
100/5
mirage [1] 135/19
misappropriating [1]
82/14
miscarriages [6]
118/5 126/8 126/14
135/19 164/19 165/10)
missed [4] 61/11
74/9 109/13 121/14
mission [1] 79/25
mitigate [1] 138/4
mitigated [1] 139/16
mitigation [1] 46/9
mitigations [1]
134/19
mm [12] 14/22 14/24
66/4 66/4 83/2 114/19
126/20 151/1 158/13
162/12 162/17 164/25}
Mm-hm [4] 14/22
114/19 158/13 162/12}
modelled [1] 37/7
moment [9] 2/11
2/14 4/18 11/7 31/16
31/18 74/14 85/3
123/16
momentous [1] 28/7
money [3] 67/22
135/25 143/22
monies [2] 66/21
66/22
monitor [2] 45/7
72/13
monitored [1] 46/8
monitoring [5] 44/25
45/6 63/20 65/1 65/13
moral [3] 165/18
166/1 166/8
more [30] 1/16 19/23
34/24 35/2 44/17
45/19 49/20 52/21
53/20 54/6 54/20
60/20 72/16 73/11
84/19 87/10 90/22
95/2 95/17 98/17
99/17 103/25 107/7
minutes [3] 4/24 60/7I
108/21 110/10 126/16
128/8 133/24 148/23
158/18
morning [9] 1/3 1/8
1/20 14/17 37/16
110/25 149/7 151/21
168/9
morph [1] 117/10
most [6] 7/14 58/12
114/15 115/15 115/18)
167/21
motive [2] 106/16
106/21
motives [1] 93/19
move [6] 41/17 44/23
45/20 47/10 56/8
69/18
moved [3] 14/11
69/19 69/19
movement [1] 60/11
moving [3] 7/10
123/25 156/16
MPs [6] 76/13 78/19
88/7 102/14 109/23
127/21
MR [7] 1/7 1/14 118/2I
118/6 119/12 119/18
169/6
Mr Beer [1] 1/14
Mr Clarke [2] 118/2
118/6
Mr Jenkins [2]
119/12 119/18
Mrs [8] 55/1 56/16
56/22 57/24 59/10
62/10 65/25 147/15
Mrs Wolstenholme
[2] 57/24 59/10
Mrs Wolstenholme's
[5] 55/1 56/16 56/22
65/25 147/15
Ms [6] 91/16 91/22
118/6 118/25 167/19
167/23
Ms Crichton [2]
91/22 118/6
Ms Crichton's [1]
118/25
Ms Vennells [1]
167/23
Ms Vennells’ [2]
91/16 167/19
much [27] 4/9 5/21
6/1 6/21 9/12 15/7
33/9 36/10 37/14
37/19 43/4 47/10 55/8
74/8 75/25 76/1 77/9
103/2 103/8 120/4
126/16 149/6 150/2
164/13 167/2 168/3
168/8
multiple [4] 130/8
must [6] 52/16 56/14
120/8 125/20 126/13
(59) make - must
my [13] 4/8 22/19
43/6 43/13 49/20
50/18 69/24 126/24
4127/2 152/21 152/21
154/8 158/14
N
name [5] 1/8 58/8
62/24 63/5 141/22
namely [7] 8/15 42/5
54/9 62/13 90/23
109/20 121/4
names [1] 1/11
narrate [1] 33/23
narrated [1] 40/17
narrative [1] 35/6
167/13
naturally [1] 87/8
nature [8] 35/14 91/3
94/5 122/18 139/23
142/16 163/8 163/22
nearly [1] 47/23
necessarily [2] 40/1
110/17
necessary [2] 45/24
138/17
NED [8] 8/7 42/11
42/11 108/3 110/18
112/4 112/8 154/23
NEDs [27] 37/10
40/19 41/8 60/12
60/20 60/21 60/25
61/1 84/7 99/20 100/3
100/9 100/15 100/24
101/6 101/13 103/3
104/11 108/11 110/15
110/17 110/23 111/17)
148/11 154/18 154/25)
160/3
NEDs' [1] 148/11
need [13] 4/23 25/10
25/17 45/12 47/25
96/23 119/13 122/14
126/7 145/17 146/8
149/13 150/21
needed [11] 97/4
104/10 118/7 118/23
121/20 121/20 124/10}
124/14 138/5 149/5
155/23
needing [1] 158/9
needs [5] 4/19 92/17
114/14 121/23 141/4
negative [1] 51/7
neglect [1] 71/9
neglected [2] 72/16
75/20
neither [7] 4/17 21/9
71/25 119/23 137/5
must... [1] 155/17
mythical [1] 117/1
national [3] 9/1 29/16
147/20 161/20
never [6] 48/3 48/4
105/10 112/24 113/5
113/9
new [5] 15/1 61/14
66/18 162/19 165/20
next [3] 33/10 43/19
122/8
NHS [3] 8/1 9/2 9/9
NHS Trust [1] 9/9
nice [1] 55/19
nine [9] 20/24 54/11
54/12 77/19 78/1
138/11 138/19 140/3
145/1
NINEDs [5] 40/21
no [54] 6/3 6/5 16/8
28/6 29/2 34/4 40/10
45/19 48/22 54/6
58/10 58/23 60/25
64/20 70/20 73/18
81/3 81/8 81/18 81/22
81/22 90/4 90/24 94/9
94/24 98/12 99/8 99/8
99/10 99/11 100/8
100/11 101/3 101/11
101/24 113/9 114/22
115/12 121/2 127/17
135/23 136/8 137/9
138/8 138/9 147/8
147/25 150/5 152/2
164/11
NOBLE [3] 1/5 1/12
169/2
nobody [1] 127/17
nomenclature [2]
51/15 51/16
nominal [1] 107/19
nominated [1] 41/12
nomination [2] 42/5
42/7
non [49] 8/8 8/14
25/12 26/4 26/12
39/17 40/18 41/1 41/6)
41/9 41/9 41/10 41/10
41/15 41/18 42/1
42/11 42/16 42/17
42/18 60/11 66/2
66/19 69/1 69/2 69/16
72/21 83/23 91/13
94/11 95/3 100/18
102/2 103/25 107/19
111/23 112/1 112/10
113/20 133/21 148/23}
149/12 149/22 149/25)
151/15 154/22 156/2
161/4 166/16
non-compliant [1]
151/15
non-executive [20]
25/12 26/4 39/17
network [2] 22/4 32/8)
40/25 41/8 41/16 42/2
21/5 21/7 21/11 24/25
40/18 41/1 41/6 41/9
41/10 41/15 42/16
42/18 66/2 69/1 69/2
69/16 102/2 111/23
112/1 156/2 161/4
non-executives [13]
26/12 60/11 72/21
94/11 95/3 103/25
112/10 113/20 133/21
149/25
non-executives' [1]
166/16
non-existent [1]
107/19
non-experts [1]
91/13
non-independent [3]
41/9 41/10 42/17
non-problematic [1]
66/19
none [1] 60/2
nonetheless [12]
63/3 63/5 69/13 70/22
80/23 87/11 108/1
114/13 115/4 128/3
128/21 145/16
nor [10] 16/18 21/9
21/10 112/25 119/24
126/4 137/5 147/20
157/13 161/20
normal [7] 12/25
26/12 107/5 107/12
153/14 163/15 163/18}
normally [6] 15/14
130/16 150/13 151/4
152/24 153/2
not [193]
notable [1] 11/9
notably [1] 29/13
note [10] 12/7 12/13
13/17 50/13 105/2
105/16 106/25 151/8
162/10 165/13
noted [1] 13/18
nothing [11] 1/15
12/3 80/5 82/3 82/19
82/20 84/12 95/6
102/11 102/11 156/11
notice [3] 1/19 49/20
151/14
notification [1] 95/3
noting [1] 115/21
notionally [1] 126/24
notwithstanding [2]
109/14 109/24
November [4] 1/1
3/19 4/13 119/24
now [20] 2/6 5/13
7/18 7/25 9/5 37/15
37/16 50/3 52/19 54/2
69/10 85/3 97/18
97/19 107/5 108/19
108/25 167/3 167/17
148/23 149/12 149/22
168/4
number [17] 21/24
26/8 35/17 50/6 80/7
88/10 90/25 92/17
98/9 106/9 108/20
111/13 117/19 121/8
133/12 133/19 156/24}
number 9 [1] 111/13
numbered [1] 60/12
numerous [1] 67/2
[e)
obligation [4] 38/12
38/24 88/15 88/21
obligations [4] 85/23
150/14 151/3 154/2
observations [2]
20/4 124/8
observers [1] 1/18
obstacles [1] 156/24
obvious [2] 104/3
104/7
obviously [1] 125/19
occasion [6] 4/22
13/10 23/10 70/16
98/8 113/13
occasional [1]
152/19
occasionally [2] 43/7
155/16
occasions [2] 116/3
116/3
occupying [1] 155/13}
occur [3] 42/7 98/18
130/2
occurs [1] 22/3
October [2] 3/7 4/12
odd [2] 136/10 137/6
oddity [2] 136/19
136/20
off [3] 30/24 57/23
127/14
offer [3] 29/12 83/11
147/24
offered [1] 147/20
offering [2] 80/3
150/1
office [119] 10/1 10/2)
10/20 13/6 13/15 16/2}
16/7 18/17 19/13
19/14 31/7 31/13 32/3
32/4 32/7 32/12 32/14
32/15 32/16 32/20
32/25 33/1 35/16
35/18 35/21 40/13
46/22 46/25 47/9
55/22 56/1 56/14
58/19 58/25 60/7 61/7
61/22 62/13 62/21
63/3 63/8 63/14 63/16
63/18 63/24 64/2 64/3)
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Oh [2] 28/14 49/22
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onto [1] 95/13
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opine [1] 93/19
opinion [2] 125/21
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opportunity [7] 74/9
109/13 121/14 128/11
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opposed [5] 26/4
26/5 42/11 44/4 96/19
opposite [1] 167/23
optimistic [1] 19/23
option [1] 55/5
or [174]
oral [5] 18/1 91/17
118/12 118/14 161/3
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13/24
order [8] 44/13 54/14
103/12 125/14 126/14)
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orderly [1] 2/6
ordinary [2] 13/2
42/16
organisation [29]
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38/23 41/17 52/6
60/23 92/8 115/19
116/24 117/7 129/25
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145/10 153/23 159/18)
164/16 165/7 166/18
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organisational [5]
7/6 7/22 8/23 53/21
163/3
organisations [9]
11/12 17/4 22/10 26/6
28/10 28/12 28/14
29/4 40/11
organised [1] 143/2
other [32] 15/4 15/19
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others [5] 116/18
122/14 132/18 138/16)
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ought [7] 10/13 40/13}
56/23 59/2 61/24
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our [41] 15/16 19/20
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133/22 137/18 139/8
139/21 147/19 147/20}
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ourselves [1] 136/21
out [85] 2/1 2/5 5/1
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outcome [1] 96/8
outline [1] 147/7
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outside [4] 69/8
112/19 114/18 117/3
over [51] 8/20 12/2
14/14 14/25 15/24
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33/3 34/2 34/15 34/18
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overall [12] 22/4 36/7
36/17 63/6 64/21
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138/6 145/1 151/2
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overarching [1]
109/8
overfilling [1] 158/23
overly [2] 131/24
146/1
oversee [2] 72/13
83/14
overseeing [1] 26/7
oversight [7] 33/8
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overstepping [1]
111/9
Overview [2] 13/19
20/3
owes [1] 88/14
own [7] 45/18 79/7
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13/14 24/25 29/15
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ownership [16]
12/11 12/14 13/1 15/3}
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33/1 37/12 63/18 67/6
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pages 21 [1] 38/2
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paid [4] 11/3 63/23
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pair [5] 35/8 40/6
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pan [4] 77/17
paper [21] 77/5 91/20
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papers [5] 98/9 98/18)
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paragraphs [23]
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parallels [1] 129/1
parent [3] 62/14 63/6
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Parliament [1] 14/23
Parliamentary [1]
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part [38] 1/24 15/18
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partial [2] 104/25
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participants [5] 2/3
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particular [19] 29/7
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particularly [18] 17/4
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parties [1] 76/19
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party [3] 39/1 43/16
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passing [1] 128/20
past [6] 16/23 124/11
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pattern [1] 75/15
Paula [12] 86/8 90/15}
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pause [1] 4/20
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people [22] 19/1 49/3)
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period [23] 10/13
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pick [4] 14/16 19/18
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play [1] 22/23
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please [85] 1/4 1/11
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plus [4] 44/21
pm [5] 85/6 85/8
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POB [1] 32/3
point [35] 13/1 17/12
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points [5] 95/4 95/14
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POL [16] 64/10 64/22
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policy [10] 23/6
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155/18
positioning [1] 88/5
positions [2] 7/21
157/3
possibility [2] 3/1
126/8
possible [4] 23/22
24/4 86/3 121/2
post [129] 10/1 10/2
10/20 16/2 16/7 18/11
18/16 19/13 19/14
20/4 31/7 31/13 32/3
32/4 32/6 32/12 32/14
32/15 32/16 32/19
32/25 33/1 35/15
35/18 35/21 40/13
46/22 46/25 47/9
55/22 56/1 56/14
58/19 58/25 60/7 61/7
61/22 62/13 62/21
63/3 63/8 63/14 63/16
63/18 63/24 64/2 64/3
64/4 64/13 65/15
66/10 66/11 66/16
66/20 66/21 67/12
68/21 68/22 69/4
69/13 69/14 70/5
72/12 72/18 75/7
75/24 76/9 76/16 77/1
78/12 78/16 79/5
79/17 82/16 82/24
86/10 89/7 94/1
102/12 103/4 103/6
103/21 103/22 106/2
108/20 109/15 109/20
117/24 118/21 119/13
124/9 124/12 125/25
127/19 128/11 133/2
134/11 135/8 135/12
135/16 136/12 136/15}
136/17 137/15 140/10}
141/9 141/11 141/17
143/14 143/22 147/11
147/16 148/16 148/25)
151/25 153/8 154/16
154/20 155/6 157/18
161/23 163/21 163/23
163/24 164/5 164/18
165/3 165/6 167/22
post-2013 [1] 161/23
posts [1] 7/9
potential [2] 131/18
143/21
potentially [2] 131/4
131/13
power [3] 17/5 35/20
53/24
powers [2] 140/10
151/10
PR [1] 94/12
practical [2] 7/22
60/25
practice [13] 10/9
15/14 18/16 24/21
26/3 63/21 78/13 94/1
103/5 103/21 155/8
155/21 156/8
practices [4] 71/22
79/17 82/11 140/2
practising [1] 154/4
pre [9] 48/14 111/14
411/17 112/1 112/1
112/4 112/8 112/15
155/13
pre-go [1] 48/14
pre-meet [3] 112/4
112/8 112/15
pre-meeting [1]
411/17
pre-meets [2] 112/1
112/1
pre-occupying [1]
155/13
preamble [1] 11/20
precautions [1]
83/10
precisely [1] 166/14
preliminary [1]
117/25
preparation [2] 77/10}
91/20
prepare [2] 79/4
98/24
prepared [6] 3/4 9/21
16/14 18/14 99/12
104/18
preparing [1] 17/24
presence [3] 66/3
105/14 114/2
present [10] 92/3
97/5 97/22 97/23
97/23 98/2 98/23
109/16 124/11 129/17}
presentation [1] 97/9
presented [4] 11/1
97/1 107/11 109/25
presenting [1] 116/2
presents [1] 120/21
press [1] 109/22
pressure [2] 76/13
112/14
pretty [1] 113/5
prevailing [2] 135/24
139/22
prevented [1] 102/5
prevents [1] 146/1
previous [6] 41/16
68/20 81/1 129/1
130/18 164/9
previously [1] 131/19
primary [2] 14/23
18/4
primer [1] 76/7
priming [1] 100/14
pally [4] 13/25
principles [9] 21/14
24/13 27/8 28/5 28/15
EB]
30/4 59/17 85/24
85/25
prior [4] 22/20 58/3
98/18 155/19
priorities [3] 78/7
78/21 79/8
prioritisation [2]
78/23 155/5
priority [6] 71/22
71/25 78/11 79/14
98/1 125/1
prism [1] 141/8
private [9] 28/13
82/18 136/16 136/24
140/11 141/18 143/8
149/17 162/9
privatisation [1] 79/5
privileged [1] 132/12
probably [12] 72/1
83/4 94/24 95/13 99/1
100/20 115/10 115/15)
115/16 132/18 152/3
164/23
probing [1] 132/23
problem [11] 31/25
32/1 67/13 69/6 118/8
126/3 126/15 127/10
127/11 129/19 129/19)
problematic [2]
66/19 142/19
problems [29] 56/25
67/18 67/19 76/10
79/12 81/4 90/4 90/25]
96/3 96/15 100/2
118/15 126/9 126/19
131/7 139/9 139/23
142/5 142/12 144/17
144/24 146/15 146/16
148/17 149/1 158/3
158/25 160/22 163/13)
proceed [1] 55/5
proceeding [1] 111/4
proceedings [3]
56/23 57/7 143/17
Proceeds [1] 143/21
process [6] 2/1 66/24I
108/15 109/15 124/12)
135/15
processes [8] 22/1
22/4 22/11 45/13
63/19 88/12 107/9
121/22
product [1] 113/14
products [1] 61/15
professional [3]
17/20 120/9 154/2
Professor [4] 1/3 1/5
7/18 169/2
Professor Dame [1]
113
Professor Emerita
[1] 7/18
profit [2] 45/10
149/16
(63) persistent - profit
P
programme [2] 9/2
147/7
project [4] 47/15
47/21 48/18 114/11
projects [2] 47/12
47/23
pronged [1] 74/23
pronouncements [1]
30/18
properly [4] 67/23
69/25 70/9 101/6
proportionate [1]
141/5
proposals [3] 46/9
125/9 147/5
propose [1] 139/15
proposed [2] 98/21
114/6
propriety [1] 18/11
prosecute [1] 135/25
prosecuting [3]
83/25 84/1 117/24
prosecution [10]
57/11 58/18 79/17
99/25 116/1 124/25
131/6 140/1 140/11
141/19
prosecutions [79]
56/18 57/1 57/7 62/25
63/7 63/16 63/19
63/20 64/7 64/12 66/9
66/16 67/4 67/7 67/21
68/12 68/15 69/9 70/5
71/10 71/21 72/3
72/12 72/24 73/4
73/10 73/13 74/4 74/7
75/5 75/17 75/19
78/13 79/13 79/21
80/17 82/11 82/17
82/25 87/24 88/11
94/2 103/5 106/2
106/4 118/4 120/1
120/18 126/4 127/20
128/12 130/11 130/13
131/25 133/2 133/23
133/24 134/2 134/3
134/10 136/13 136/16
136/25 139/10 139/14
141/2 141/6 141/11
143/8 146/16 147/12
148/17 149/1 155/7
155/8 155/15 155/20
155/21 165/11
prosecutor [2] 126/1
143/20
prosecutorial [2]
135/15 140/13
protect [5] 88/15
88/21 89/22 125/14
135/25
protected [2] 51/5
132/1
protecting [2] 24/22
50/19
protection [1] 51/10
protesting [1] 164/14
proved [1] 162/25
provide [5] 10/8 17/9
23/20 30/9 82/4
provided [3] 23/4
53/18 96/24
provides [3] 10/23
20/3 137/13
providing [1] 33/8
provision [1] 48/9
provisions [1] 27/9
public [30] 8/15 9/8
11/5 11/24 12/10 30/1
30/10 30/21 37/11
38/21 50/18 51/1
66/20 66/21 67/22
82/14 87/19 88/1
109/20 116/8 135/25
135/25 149/19 155/16)
155/18 163/9 163/10
163/17 165/6 165/24
public's [1] 66/22
publication [9] 30/12
77/2 77/10 77/10 88/5
95/3 101/25 106/8
118/18
publicly [8] 11/3 11/8
11/9 11/14 29/15
29/19 29/24 30/9
publicly-owned [1]
29/24
published [4] 77/3
101/21 102/24 105/12)
pull [2] 121/48
123/11
purpose [11] 2/5
9/15 24/17 38/4 45/1
45/22 47/18 51/24
53/15 96/8 143/1
purposes [3] 22/16
41/2 104/17
pursue [2] 22/16
136/12
pursued [2] 55/23
56/1
put [10] 35/16 49/24
50/1 88/6 89/16 97/2
105/15 131/23 136/21
160/12
puts [1] 72/8
putting [1] 165/20
Qo
qualifications [4]
2/15 6/22 7/1 8/21
qualified [2] 154/1
154/6
quality [4] 48/1 48/5
108/23 108/24
quasi [1] 142/20
quasi-employees [1]
142/20
question [24] 24/24
40/16 44/3 44/14
46/11 55/15 61/3 80/7
81/10 81/21 82/20
99/10 111/22 111/23
113/15 118/3 124/1
127/12 132/4 135/18
140/22 144/10 146/20}
166/16
questionable [1]
82/10
questioned [3] 1/7
82/21 169/6
questioners [2]
167/9 167/10
questions [35] 1/9
2/2 2/3 2/10 2/14 2/17
21/7 21/12 45/19
48/23 54/6 55/6 60/5
70/1 70/2 76/14 82/17
94/8 100/10 100/25
111/6 131/23 132/2
132/6 138/17 154/9
155/11 166/11 166/17
167/1 167/4 167/19
167/20 167/22 167/25
quickly [2] 127/9
147/4
quiet [1] 44/9
quite [8] 50/6 71/8
94/7 126/19 127/9
132/12 135/19 158/12
quotation [1] 5/22
quote [1] 30/12
R
raise [2] 100/11
100/25
raised [8] 64/11 80/6
103/4 103/16 113/22
115/25 160/20 161/7
ramifications [1]
116/23
ran [1] 55/22
range [1] 148/9
rapidly [1] 13/19
rare [1] 43/13
rather [15] 14/4 35/5
52/21 78/1 81/5 91/24,
94/12 95/5 100/6
106/13 111/9 115/8
134/21 139/22 141/7
rations [1] 153/3
reach [1] 77/25
reached [1] 78/23
react [1] 125/25
reactions [1] 113/11
read [9] 12/19 12/19
23/15 29/22 57/7
66/15 76/4 103/11
104/5
reader [2] 104/9
106/13
readily [1] 136/3
reading [6] 17/24
18/2 20/8 104/10
113/18 119/5
reads [2] 6/4 104/3
ready [2] 112/16
113/4
real [3] 35/11 69/6
135/19
realise [1] 70/15
realised [2] 16/7
118/2
really [14] 25/8 28/7
46/1 71/24 72/12
74/23 80/15 91/2 91/3
91/5 94/21 111/7
149/9 165/8
reason [4] 42/18
102/8 166/7 166/8
reasonable [5] 15/14
50/4 85/22 94/2 111/4I
reasonably [10]
10/19 16/1 16/6 22/17
23/2 24/1 59/17 61/24)
107/2 142/17
reasons [8] 42/17
44/11 66/1 112/7
113/10 113/12 113/16}
143/25
recall [2] 105/23
160/17
receipt [7] 2/6 86/13
86/14 86/21 109/12
124/9 147/14
received [12] 76/25
77/4 89/18 100/11
100/13 104/19 117/23)
118/11 118/20 119/2
119/21 120/22
receiving [3] 62/9
86/16 86/17
recently [2] 3/9 49/20
recognise [1] 126/14
recognised [1]
124/14
recommend [1]
128/24
recommendations
[3] 28/15 124/19
137/24
record [2] 3/2 100/6
recorded [1] 13/9
records [1] 151/6
recruit [1] 162/19
recruitment [1]
162/18
recurring [1] 69/11
redacted [1] 3/22
reduce [1] 2/25
refer [3] 91/24
104/22 122/8
reference [9] 21/14
23/5 23/17 40/12
76/18 91/16 132/15
144/16 144/23
references [3] 17/15
40/10 56/5
referencing [1] 3/10
referring [11] 13/24
58/8 58/16 58/17 87/5I
87/7 105/23 105/24
157/14 160/14 160/15)
reflect [1] 18/15
reflected [1] 17/10
reflection [2] 66/10
158/7
reflects [1] 116/22
refrain [1] 78/18
regard [20] 37/11
39/24 44/2 46/23 47/1
54/25 65/9 72/12
75/17 83/24 84/1 91/1
130/17 137/5 146/18
148/1 150/7 155/7
160/22 160/23
regarded [1] 15/14
regardless [1]
139/25
regards [2] 95/22
150/17
register [6] 57/20
59/23 62/4 68/6
143/23 143/25
regular [4] 84/2
84/16 115/12 125/6
regularly [3] 42/20
115/16 157/13
regulated [1] 46/17
regulations [1] 27/10
regulator [1] 144/9
regulators [1] 11/13
regulatory [3] 151/3
151/19 152/9
reinforced [1] 139/22)
reissued [2] 3/11
3/11
relate [9] 20/11 20/13}
20/15 20/16 21/1 21/2I
49/11 84/25 89/5
related [4] 63/14 91/6
101/12 127/19
relates [3] 48/21 74/5I
122/20
relating [6] 59/9
62/10 94/1 122/1
134/13 155/10
relation [41] 13/2
16/13 17/1 17/4 25/3
25/18 28/8 47/23
48/11 49/9 56/11
62/17 66/7 71/9 71/10
71/16 73/10 73/14
74/3 77/25 78/4 89/7
89/13 93/16 95/12
95/21 95/23 96/21
98/18 108/10 111/10
112/3 114/10 126/13
126/22 140/3 140/8
(64) programme - relation
R
relation... [4] 149/1
149/22 159/1 163/4
relations [3] 45/16
87/19 88/1
relationship [21]
24/5 33/24 34/4 34/11
34/12 34/13 34/17
34/18 34/19 38/18
41/13 43/14 62/13
62/18 67/20 69/15
98/4 150/21 150/23
151/11 157/25
relationships [10]
38/8 120/6 121/21
152/16 153/22 156/20
157/8 158/8 159/6
160/24
relatively [3] 27/17
60/13 75/11
relax [1] 101/4
relevance [3] 13/20
36/11 36/14
relevant [25] 10/25
11/10 12/3 18/12
23/13 23/20 31/10
33/7 33/15 41/5 47/7
48/9 51/11 57/3 83/5
87/4 94/16 106/18
106/22 111/13 111/20
138/25 139/4 145/19
147/19
relevantly [1] 7/14
reliance [1] 134/4
relied [1] 119/11
rely [3] 17/21 30/19
157/10
remain [3] 122/18
162/4 164/6
remaining [3] 20/16
114/13 150/25
remember [5] 24/12
54/8 105/8 115/4
119/5
remembering [3]
9/21 86/5 162/2
reminder [1] 17/6
Remuneration [1]
8/5
repeat [1] 70/12
repeated [1] 75/16
replace [1] 5/23
replaced [2] 161/11
161/13
replacement [1]
161/15
replete [1] 17/15
report [158] 3/14
3/19 3/19 4/1 4/6 4/10
4/11 5/8 6/12 6/22
6/23 9/16 9/20 9/20
10/8 10/11 10/23 15/8)
15/18 15/20 16/5
16/10 16/13 16/13
16/22 16/23 17/2 17/7)
17/24 18/10 19/9
19/12 21/15 21/17
21/20 22/18 22/21
23/6 23/12 23/17 24/8
24/12 29/6 33/10 35/3
35/7 36/25 38/1 38/2
38/5 43/20 45/7 47/18
51/3 51/25 54/7 54/7
54/12 55/24 59/10
59/18 59/21 59/23
68/5 68/9 70/19 72/15
75/23 76/2 77/3 77/3
77/5 77/15 78/10
79/24 80/6 81/15
85/14 86/7 86/10
86/14 86/14 86/17
86/17 86/19 86/21
86/23 87/16 87/22
88/6 88/9 90/3 90/17
91/7 91/10 93/16
94/18 94/21 94/23
95/4 95/8 95/15 96/2
96/8 96/22 97/3 97/23
98/5 98/13 99/6 99/15
100/16 101/10 101/21
102/24 103/1 103/10
103/12 103/15 104/1
104/10 105/1 105/1
105/4 105/10 105/10
105/18 105/21 105/25)
106/7 106/9 107/3
108/2 108/4 113/22
114/14 115/21 116/2
118/1 118/12 118/18
123/1 124/1 126/11
131/3 138/13 138/16
138/18 139/11 145/3
150/8 154/11 154/12
156/23 157/19 164/3
164/10 164/24
Report 1 [19] 9/16
9/20 16/5 16/22 16/23
17/2 17/7 22/18 23/6
23/12 23/17 24/8
24/12 54/7 59/18
59/21 96/22 97/3
107/3
Report 2 [7] 16/10
16/13 18/10 22/21
54/7 154/11 154/12
reporting [3] 47/6
63/18 100/1
reports [10] 2/12 3/4
3/4 3/9 3/11 3/12 9/15
27/3 28/19 44/12
represent [5] 10/14
18/10 120/9 130/1
159/16
representation [1]
36/5
representative [1]
26/8
representatives [3]
52/9 53/3 167/14
represented [3] 35/2
147/21 163/7
reputation [5] 78/25
88/15 88/22 89/23
109/20
require [2] 103/21
108/4
required [10] 28/25
32/24 45/6 60/22 72/9
72/11 92/3 110/10
130/13 135/20
requirement [8] 46/5
147/24 147/25 149/19)
151/24 152/2 152/5
154/4
requirements [17]
11/2 11/4 11/11 11/22
11/23 12/8 14/12
14/20 15/11 28/22
45/15 49/12 51/17
53/22 118/24 152/14
154/1
requires [2] 43/11
134/17
requiring [1] 115/14
research [1] 31/22
researched [1] 7/5
reside [1] 152/10
resonance [1] 78/18
resource [1] 48/4
respect [1] 131/17
respectively [1]
35/15
respond [2] 89/21
127/2
response [4] 50/21
76/12 86/7 121/5
responsibilities [18]
25/16 27/13 27/15
38/8 39/8 45/25 49/7
50/21 65/10 65/11
87/21 89/9 112/22
112/22 112/23 120/9
153/6 153/7
responsibility [45]
26/15 38/10 38/25
42/13 42/14 62/24
63/4 64/21 64/23
65/15 72/8 74/22
74/25 83/13 83/14
87/21 88/17 91/15
92/6 92/18 93/14
93/15 96/12 99/3
111/10 122/18 124/18
124/21 130/4 137/21
139/25 141/24 141/25)
145/8 145/9 145/20
151/2 152/9 153/12
157/2 157/5 157/6
157/8 158/6 159/15
responsible [18]
26/9 38/9 41/7 41/21
50/2 50/3 63/7 63/10
64/1 71/24 129/24
130/1 130/15 130/20
137/25 151/12 151/19}
159/11
result [3] 61/1 126/23
128/17
resulted [1] 118/4
retain [1] 41/25
retrospect [1] 75/14
revealed [5] 84/18
110/12 126/3 126/18
158/6
revelation [1] 131/6
revenue [1] 29/18
review [22] 8/11 64/9
76/10 80/21 118/7
118/23 118/25 119/7
120/17 121/5 124/11
124/15 124/18 127/7
127/8 128/11 132/8
132/8 135/20 159/5
160/21 160/21
reviewed [5] 18/5
19/19 137/23 148/23
162/23
reviewer [2] 80/2
80/11
reviewing [1] 131/18
revised [1] 13/3
revisions [1] 44/19
richer [1] 135/5
rife [1] 116/14
rift [1] 116/16
right [66] 5/12 5/19
9/11 10/5 10/15 10/18)
11/4 11/23 12/10
12/11 12/13 12/19
12/20 12/25 14/16
15/2 16/14 17/1 18/9
21/8 23/9 28/2 30/18
31/17 33/14 33/16
34/22 35/9 39/5 44/1
50/20 50/23 55/10
55/16 56/3 59/4 66/21
69/21 75/1 76/1 77/20
79/20 93/18 94/13
95/24 95/25 97/6
97/13 102/7 129/14
132/7 132/10 134/22
136/12 138/24 140/4
144/21 148/7 151/23
156/13 156/16 157/21
161/2 164/12 164/24
165/7
right-hand [4] 11/23
12/13 12/25 15/2
rightly [1] 162/2
rights [3] 24/22
50/16 51/2
rise [1] 4/24
risk [69] 13/18 13/25
14/3 23/4 23/20 25/17]
45/16 45/17 45/21
45/24 46/4 47/3 47/4
47/8 56/17 57/19
57/19 57/22 58/17
59/14 59/22 62/4 62/4
64/4 64/5 64/6 64/7
65/13 67/14 68/6
71/10 72/22 72/25
73/1 73/6 73/7 73/13
74/20 75/20 84/8
84/13 84/18 89/11
118/9 123/7 123/9
123/13 125/11 125/13)
125/22 128/14 133/7
133/24 134/6 134/9
134/10 134/17 134/20)
138/23 140/1 140/14
140/23 141/4 141/6
141/8 143/23 143/24
147/3 147/5
risked [1] 131/6
risks [25] 45/16 46/7
46/8 58/15 58/16
58/18 61/25 63/20
64/12 65/1 75/1 75/18)
108/5 110/13 133/25
134/13 134/16 134/17)
134/25 138/1 138/4
139/14 139/18 147/10)
163/9
RMG [11] 63/9 63/14
64/5 64/21 67/3 71/22
74/19 74/19 74/25
79/4 79/6
robust [10] 71/8
80/14 82/9 82/19
89/19 90/9 90/13
90/24 146/13 155/15
robustness [4] 103/8
106/4 135/24 146/20
Rodric [1] 119/4
role [47] 32/24 43/20
43/22 44/2 44/3 44/6
44/8 44/19 44/20
45/18 48/10 48/10
49/8 49/9 65/21 68/14)
83/7 88/25 89/6 89/8
92/13 93/1 93/2 95/18}
96/12 99/20 99/25
101/14 110/19 114/25}
115/6 124/22 134/8
145/23 145/24 148/10)
148/12 149/25 150/6
152/11 152/12 152/23}
158/9 159/18 160/1
164/18 165/5
roles [12] 25/12
25/12 25/15 27/13
27/15 85/15 88/24
89/16 120/5 143/23
144/15 144/22
rollout [2] 47/14
163/12
roots [1] 24/21
round [2] 54/14
(65) relation... - round
R
round... [1] 141/7
route [1] 143/8
routes [2] 74/19
121/9
routine [4] 67/21
114/23 115/10 140/11
routinely [1] 141/11
Royal [13] 32/17
56/13 60/1 60/23
62/14 62/22 63/1 63/5
63/23 64/14 64/15
70/4 154/21
RTS [1] 4/20
rule [1] 155/1
rules [3] 2/5 2/9 22/2
rumours [1] 116/13
run [11] 30/16 46/3
78/1 83/7 83/11 84/5
100/15 107/17 111/2
149/14 149/17
run-up [2] 78/1
100/15
running [13] 26/10
31/13 32/6 41/7 46/3
83/12 92/15 110/23
141/23 142/1 145/13
149/16 154/19
runs [6] 24/15 38/2
45/23 53/13 55/10
76/1
Ss
safeguards [1] 144/5
safety [2] 56/18 83/9
said [32] 27/22 28/10
59/20 64/25 72/10
73/9 84/15 88/9 106/6
110/22 112/7 114/9
120/16 121/11 121/11
130/8 136/5 136/25
137/1 146/10 146/17
148/24 151/7 151/12
151/20 153/14 159/3
159/8 162/10 165/4
167/24 168/1
salaries [2] 8/11
161/16
same [7] 1/17 13/5
15/1 50/3 79/9 138/16)
166/14
Sandra [16] 1/4 1/5
1/8 1/12 2/10 2/19
3/23 5/12 6/9 6/25
31/15 37/25 69/18
85/10 123/23 169/2
Sandra's [1] 2/23
sands [1] 36/12
sat [1] 123/12
save [1] 5/2
saw [6] 78/20 84/11
88/3 132/13 149/25
149/25
say [112] 1/14 1/18
10/7 10/10 10/13 11/6
15/10 17/8 20/1 23/9
29/10 30/7 33/16
36/20 42/16 44/8 44/9
49/21 49/21 50/23
56/13 58/6 59/22 60/6
61/9 63/13 66/8 68/18
68/24 69/6 69/10 71/4
71/8 75/16 78/9 81/12
82/7 84/6 84/10 84/19)
86/25 87/16 88/8
89/18 90/14 91/11
91/19 93/21 95/1
95/11 96/1 96/20
97/25 99/11 99/23
101/9 102/1 102/9
102/16 103/1 103/20
104/1 105/20 107/23
109/11 110/7 111/19
111/23 114/24 114/25)
115/6 116/8 116/11
117/22 118/14 119/23)
120/12 120/24 122/15)
122/24 124/6 129/22
130/4 132/4 133/20
134/7 136/9 136/24
139/7 140/9 140/16
142/21 142/22 145/25)
147/2 148/13 152/6
153/3 154/16 156/22
157/16 157/23 158/18)
158/19 159/25 162/20)
163/6 163/20 165/17
165/17 166/2 167/17
saying [18] 15/17
15/18 37/1 47/2 83/22
90/7 94/10 97/4
101/16 101/20 109/24}
128/19 130/23 130/23)
131/3 132/7 132/22
134/23
says [12] 29/1 39/25
73/6 91/17 105/17
119/5 119/17 122/3
127/10 133/20 143/8
151/8
scaffolding [1] 53/17
scale [6] 47/22
102/13 141/12 163/8
163/10 167/24
scenario [1] 23/19
scheme [2] 19/9
70/14
schemes [1] 54/16
scholar [1] 9/5
School [2] 7/15 9/5
science [1] 85/20
scope [1] 161/10
screen [7] 3/14 4/17
5/10 5/17 69/19 77/17,
129/5
scroll [17] 6/8 8/19
11/20 12/23 14/25
20/10 20/16 26/1
32/10 34/2 34/19
35/25 51/3 99/23
109/3 157/16 162/1
scrolling [2] 12/3
12/3
scrutiny [2] 60/18
101/14
search [1] 28/3
second [74] 3/6 4/9
5/8 5/10 6/2 10/10
14/16 17/24 19/12
21/17 21/20 32/11
36/2 37/23 55/4 55/4
62/11 75/22 75/23
76/9 76/15 76/21 77/2
77/11 77/15 78/16
79/16 79/25 80/6
80/14 80/21 82/9
85/13 86/7 88/5 88/8
89/6 90/3 91/6 91/10
93/17 93/21 94/18
95/15 96/7 98/5 98/7
98/13 99/6 100/1
100/7 100/15 101/5
102/14 103/10 103/21
105/1 105/9 105/10
105/18 105/25 113/21
117/25 122/25 124/1
131/3 139/8 139/8
139/12 144/13 145/22)
149/3 156/3 157/24
secondly [3] 2/14 7/9
21/15
secretary [14] 35/23
39/23 91/23 98/22
99/2 150/7 150/11
151/4 151/11 151/17
152/7 152/11 152/15
152/21
secretary's [1]
150/24
section [5] 17/2
47/18 53/19 54/5
106/10
section 8 [1] 17/2
sections [2] 51/4
91/16
sector [1] 9/9
secure [1] 22/12
secured [2] 64/23
119/15
securing [2] 79/1
79/2
security [1] 89/12
see [53] 1/16 1/21
3/18 4/11 11/20 12/1
15/9 24/14 35/12
35/25 37/3 38/9 44/13)
48/11 51/2 64/20
67/23 68/2 68/12 71/1
71/9 71/11 77/12
77/18 79/13 80/21
82/6 82/15 86/23 88/9
93/9 93/11 93/15
95/19 96/2 97/21
110/8 112/4 117/11
117/12 128/25 132/5
133/19 135/3 135/14
139/9 139/20 140/22
145/10 158/9 161/9
164/3 168/9
seeing [1] 71/10
seek [1] 150/13
seeking [1] 92/20
seeks [1] 35/8
seem [2] 88/12
149/23
seemed [3] 58/7
130/7 162/23
seems [15] 46/13
49/25 61/15 65/4
72/25 73/7 75/15
133/13 135/10 136/10
149/12 159/5 161/13
163/20 163/24
seen [32] 20/20
25/21 28/8 41/23 46/2
50/21 57/2 61/16
66/16 66/19 69/1
72/16 78/19 82/25
83/3 84/6 90/14 104/8I
104/23 108/7 112/25
113/19 116/1 123/13
147/8 148/14 149/13
154/16 155/14 155/25}
161/18 164/1
selected [2] 20/7
159/3
selection [3] 17/25
19/1 20/8
selective [1] 18/19
semi [1] 122/16
semi-detached [1]
122/16
senior [13] 8/4 8/11
8/15 33/6 39/19 58/10)
58/12 114/22 115/18
117/2 157/3 157/17
158/4
sense [16] 26/16
27/1 27/3 31/8 34/23
38/21 67/6 79/25 91/8
92/6 93/12 93/13
115/14 120/24 150/20}
165/7
sentence [8] 1/24
61/19 67/12 73/5 73/6
73/9 74/6 82/3
separate [5] 25/10
29/2 61/3 79/6 145/5
separated [1] 29/2
separately [1] 152/12)
separation [1]
145/22
series [7] 22/1 70/10
109/1 111/20 126/21
143/23 148/7
serious [20] 57/5
64/17 65/9 65/9 70/10}
79/12 80/5 80/10
103/3 108/20 116/19
118/15 128/9 139/18
140/1 140/22 141/4
144/17 144/24 163/13)
seriously [2] 135/17
136/11
seriousness [4]
70/14 126/24 128/12
158/17
servants [1] 33/6
served [1] 9/8
service [2] 149/19
163/17
services [10] 8/16
17/20 46/15 46/18
46/25 47/2 47/9 83/10
83/11 163/11
serving [1] 52/16
session [1] 54/9
set [44] 2/1 7/2 7/23
9/17 15/24 15/25
16/12 16/21 27/9
27/20 27/23 27/24
39/5 55/12 56/4 56/8
66/6 70/1 71/13 74/22I
76/22 85/17 85/24
99/19 102/22 102/25
104/21 107/3 108/25
117/19 119/19 129/7
133/7 136/1 139/1
144/18 147/1 148/4
148/6 150/24 155/19
156/9 156/20 163/4
sets [5] 8/20 10/8
19/8 167/9 167/10
setting [4] 2/5 35/6
96/17 114/6
settlement [3] 57/23
59/12 60/3
seven [1] 34/16
seven-year [1] 34/16
several [5] 76/19
116/3 134/1 148/17
165/4
shake [1] 166/13
shaken [1] 80/4
shall [4] 2/14 49/21
82/15 88/9
share [4] 42/14 58/14)
112/9 124/21
shared [5] 91/14 92/6
119/3 134/17 138/2
shareholder [21]
10/3 12/16 32/22
32/24 33/2 41/15 42/6I
42/19 42/21 42/22
42/24 43/8 43/15
43/21 44/2 44/6 44/9
44/13 44/19 44/21
52/24
shareholders [9]
(66) round... - shareholders
Ss
shareholders... [9]
24/23 27/15 27/16
41/12 41/13 42/6
44/17 53/1 160/6
shareholdings [1]
2717
sharp [1] 57/18
she [73] 2/23 56/1
86/16 86/20 87/1 87/3
87/8 87/11 87/12
87/17 87/25 89/4 89/6
89/9 89/12 89/14
91/17 91/19 92/2
92/23 93/3 93/6 94/2
96/6 96/14 98/21
98/24 99/1 99/13
108/14 112/22 112/23}
113/13 113/25 115/13
115/18 116/4 117/4
119/3 119/4 119/5
120/16 121/4 121/11
121/11 122/1 122/3
122/4 122/5 127/10
127/11 128/7 130/1
130/8 130/9 130/11
130/14 130/15 130/18
130/20 134/12 151/14}
151/15 153/12 153/17
159/8 159/9 159/10
159/10 161/12 161/14}
167/23 167/25
she's [2] 91/17
114/15
ShEx [2] 42/7 162/3
ShEx's [1] 162/14
shifting [1] 36/12
shook [1] 146/22
short [7] 5/5 37/21
76/5 85/7 123/20
131/21 131/22
shortfall [1] 55/23
shortly [1] 122/2
should [110] 1/14 2/1
3/15 5/10 5/15 5/17
5/23 6/2 12/18 19/2
19/3 21/13 28/11
28/13 28/16 29/2 29/2
29/3 29/5 29/23 30/4
30/10 44/17 45/5
46/22 49/2 52/15
52/15 57/2 57/16 58/1
58/2 58/4 59/10 59/13,
59/23 59/25 62/9 64/3,
64/5 64/9 64/11 64/22
65/20 72/23 75/7
77/13 78/5 78/15
84/17 86/20 88/6 88/6
90/10 90/12 94/2
94/16 96/18 96/20
102/10 103/2 104/11
107/12 107/23 108/3
108/12 111/6 111/7
114/24 114/25 119/20}
121/3 124/2 124/7
125/2 125/6 125/9
125/23 126/12 127/25)
128/4 128/20 129/22
130/6 130/17 130/24
130/25 131/14 132/4
132/18 133/1 133/23
136/15 136/24 137/2
137/5 137/16 138/13
139/16 142/2 142/9
145/10 147/4 155/7
160/4 166/6 166/11
166/17 167/19 167/24)
shouldn't [4] 21/11
21/13 110/23 161/12
show [3] 45/9 45/10
82/21
showed [1] 75/16
showing [2] 118/1
162/7
shown [1] 126/16
shows [1] 119/11
shying [1] 133/14
sic [1] 31/3
SID [1] 8/5
side [8] 11/2 11/23
12/9 12/10 12/14
12/25 15/2 15/2
sides [1] 145/20
Sidney [2] 7/13 9/6
SIDs [1] 39/19
sift [6] 118/25 119/7
121/5 124/15 132/21
135/20
Sigh [1] 105/18
Sight [47] 19/12 55/5
75/23 76/9 76/15
76/21 77/2 77/11
77/15 78/16 79/16
79/25 80/6 80/15
80/21 86/7 88/5 88/9
90/3 91/6 91/10 93/17,
94/18 95/15 96/7 98/5)
98/7 98/13 99/6 100/1
100/8 100/16 102/14
103/10 103/21 105/1
105/9 105/10 105/25
113/21 117/25 122/25)
131/3 139/8 139/12
156/3 157/24
Sight's [1] 82/10
sign [1] 57/23
signals [1] 116/12
signature [4] 3/24
4/4 6/8 6/15
signed [1] 76/20
significance [3]
36/11 80/8 106/12
significant [13] 57/23)
75/11 75/14 86/24
87/2 87/4 87/13 104/8)
115/21 117/5 123/7
140/14 141/12
significantly [3] 49/6
50/9 86/10
signing [1] 2/11
signpost [1] 104/9
silence [1] 116/17
silo [2] 123/11
123/12
silos [3] 92/8 158/8
159/7
similar [4] 15/4 85/21
95/21 95/23
similarly [2] 28/12
129/2
Simon [21] 19/13
55/2 117/18 118/13
118/17 120/14 120/18}
121/6 121/9 121/17
122/6 124/3 124/18
126/2 127/12 127/25
134/13 136/4 136/18
139/12 157/24
simple [1] 40/25
simply [10] 46/2
47/25 61/11 80/23
115/20 120/7 120/12
120/24 137/19 158/18
since [3] 38/15 56/25
167/17
singly [1] 151/12
sir [17] 1/3 2/5 2/25
4/22 5/3 5/7 37/15
37/24 50/5 59/1 63/17,
85/3 85/9 123/16
123/22 167/3 168/3
Sir Wyn [1] 50/5
sit [10] 5/1 26/12
26/14 70/15 80/9
123/4 123/5 126/25
151/19 158/17
its [1] 123/10
sitting [3] 57/19
83/22 117/3
situation [3] 63/15
109/16 125/20
situations [2] 125/14
155/4
six [8] 20/15 21/1
34/16 109/4 109/5
109/10 119/20 137/14]
size [1] 118/7
skills [1] 157/4
skipped [1] 14/14
skipping [1] 74/21
slightly [1] 142/21
slipping [1] 128/10
slow [2] 69/23
125/25
slowly [1] 103/12
small [1] 126/6
smaller [1] 115/8
so [158] 2/9 3/4 3/14
4/18 4/23 6/3 9/24
10/18 12/4 12/18
13/13 14/7 14/17
15/17 19/4 20/15
20/19 21/11 22/21
23/1 23/15 23/19
24/12 27/18 28/2
28/25 29/21 31/11
31/20 32/15 32/19
33/11 33/15 33/22
34/22 35/5 36/3 36/5
36/20 38/9 39/9 40/10
41/23 42/2 42/25
44/13 44/18 44/20
45/10 47/6 48/5 49/23)
50/2 50/8 50/20 50/23)
50/25 51/10 54/18
55/9 55/18 57/12
58/14 59/5 60/2 60/24
61/18 65/2 65/9 66/22,
67/4 67/23 70/18
70/21 71/17 71/25
TAIT 78/4 78/22 79/24
82/18 86/20 87/1 87/3,
88/12 90/5 92/21
92/23 93/1 97/1 97/3
97/4 98/8 99/3 99/6
100/14 100/23 101/24}
102/5 102/16 105/10
105/16 105/21 107/14
109/10 109/24 112/3
112/10 112/18 113/2
113/20 113/22 115/22}
120/4 120/23 121/18
123/10 124/15 126/16}
127/12 127/21 127/25)
128/18 130/5 130/21
131/2 132/12 132/14
133/15 134/21 135/13}
137/18 138/1 138/18
140/8 140/19 142/1
142/5 143/3 145/15
146/11 151/11 152/5
153/16 153/22 155/14,
157/9 157/20 158/19
159/17 161/7 162/1
164/13 164/15 164/16)
165/13 166/1 166/6
social [1] 121/21
societal [1] 25/20
sole [1] 12/16
solely [2] 78/14
151/12
solicitors [1] 117/24
solution [1] 114/6
some [47] 4/14 5/8
7/25 12/7 13/20 18/2
19/22 26/2 29/3 32/24)
34/23 41/6 41/11 47/6
54/16 56/5 56/11 63/4
64/1 70/1 70/5 87/17
87/25 91/16 100/20
103/9 105/20 105/22
106/12 109/3 109/23
116/8 118/3 118/4
118/6 118/8 120/17
122/8 126/8 128/25
131/23 136/16 152/15}
152/18 158/4 161/4
162/5
somebody [1] 4/20
somehow [2] 132/18
165/12
someone [4] 120/20
120/21 130/5 136/23
something [19]
27/23 29/23 46/1 49/6I
54/3 57/25 66/16 67/8I
67/10 71/4 71/5 90/22
93/11 93/15 111/25
116/21 123/10 137/2
167/17
sometimes [8] 29/17
52/20 55/12 112/13
112/14 117/14 117/1
159/8
somewhat [1] 105/22
sorry [5] 6/4 31/15
70/12 141/3 152/3
sort [10] 24/17 65/12
70/24 80/22 118/6
118/8 133/11 134/23
153/3 166/10
sorts [1] 73/18
sought [3] 45/4 56/21
89/22
sound [1] 28/15
source [1] 14/8
speak [10] 31/15
49/3 49/3 49/4 50/8
108/9 109/5 120/8
120/25 136/20
speaking [9] 14/18
40/5 40/6 40/7 43/25
44/8 50/7 100/14
162/10
speaks [4] 14/10
113/25 120/20 138/16
special [10] 11/3
41/13 41/25 99/7
112/21 144/2 144/3
144/15 144/23 159/14)
specialist [7] 41/4
42/25 72/15 91/12
92/18 93/7 115/24
specialists [1] 72/17
specific [8] 15/11
25/12 45/16 51/17
53/22 54/17 57/12
152/15
specifically [7] 46/1
73/16 73/17 100/20
115/14 120/1 122/5
specified [2] 38/13
38/13
spectrum [9] 57/4
70/14 70/16 80/8
126/23 127/1 127/2
158/14 158/17
speculation [2]
116/14 117/7
(67) shareholders... - speculation
s
sped [1] 69/23
split [6] 11/1 20/11
24/24 33/18 46/20
152/6
SPM [1] 5/18
spoke [1] 95/10
spoken [2] 73/9
122/1
sponsoring [2] 33/7
35/21
spotlight [1] 133/1
spots [1] 164/21
staff [1] 73/25
stage [1] 34/5
stages [1] 31/9
stake [1] 52/5
stakeholder [7]
49/17 51/22 52/17
52/19 52/21 52/23
53/4
stakeholders [6]
26/9 52/1 52/8 52/10
52/25 53/10
stall [1] 17/19
standalone [1] 79/7
standard [2] 86/2
107/13
standards [15] 10/11
10/12 10/15 10/18
16/6 16/21 22/18
22/23 23/13 23/17
24/2 28/5 28/10 107/3
114/25
standing [1] 112/17
stark [1] 131/18
start [14] 1/14 3/23
4/15 14/20 24/9 30/24)
32/3 55/18 104/22
111/15 119/22 124/11
134/16 167/6
started [3] 9/23
121/5 138/13
starting [3] 6/25 35/3
56/3
starts [6] 38/1 44/24
54/18 75/25 95/19
156/15
state [2] 35/23
116/19
statement [4] 3/22
46/14 88/8 119/6
statements [4] 18/1
46/23 66/15 148/22
status [1] 43/24
statutory [2] 35/19
35/20
staying [1] 8/19
steeped [1] 41/20
step [1] 142/21
Stephen [1] 35/23
Steward [22] 1/4 1/6
1/8 1/13 2/11 2/20
2/22 4/4 6/15 8/19
22/22 37/25 55/2
58/21 66/25 85/10
113/7 123/23 128/7
150/4 165/16 169/4
still [5] 110/10
142/22 154/17 154/20)
162/23
stood [1] 112/16
stop [2] 4/16 136/24
stopping [2] 73/5
151/23
stories [2] 116/25
133/16
story [7] 25/22 25/23
75/20 94/4 94/5
133/17 133/17
strain [1] 98/4
strained [3] 157/25
158/8 159/6
strategic [2] 13/18
79/3
strategy [7] 41/22
43/23 44/4 101/19
138/23 145/14 160/23)
striking [1] 164/10
strong [12] 17/21
61/14 66/2 116/11
127/3 135/13 146/6
149/19 155/23 165/2
165/7 168/1
stronger [2] 78/12
159/11
strongest [1] 164/23
strongly [1] 167/18
structural [2] 158/8
159/7
structure [6] 22/10
27/12 36/7 36/18
105/22 140/6
structures [11] 22/1
22/4 34/24 37/7 37/10
79/8 130/2 131/12
149/8 154/17 156/19
studies [27] 18/6
18/9 19/5 19/11 19/17)
19/18 19/21 19/24
20/7 20/20 21/5 21/16
54/10 54/11 54/13
54/15 54/22 55/11
96/21 133/13 138/10
139/4 156/23 157/20
159/2 159/2 166/20
study [21] 54/18 55/9
55/14 71/14 75/22
85/11 98/12 102/22
111/13 114/18 114/22)
117/16 117/17 117/19)
123/24 130/18 133/7
137/11 137/13 138/7
139/8
Study 1 [2] 54/18
55/9
styles [1] 86/4
sub [4] 95/12 99/19
102/21 108/10
sub-issue [4] 95/12
99/19 102/21 108/10
42/2
subheading [1]
55/15
subject [7] 14/4
61/17 76/19 101/23
105/4 117/6 155/17
subjects [1] 107/10
suboptimally [1]
159/20
subordinate [1]
150/20
subpoints [1] 109/10
subpostmaster [3]
56/17 63/21 164/5
subpostmasters [28]
32/8 53/8 78/17 79/18
80/16 82/13 84/1
84/15 88/12 91/6
99/25 103/6 106/3
109/17 109/22 119/14
127/20 135/17 136/1
139/15 141/12 155/16}
163/16 163/22 163/25I
164/13 166/23 167/13
subpostmasters' [2]
163/19 165/5
subpostmistress [1]
55/21
subsequent [5]
21/10 25/13 99/18
105/9 126/10
subsequently [2]
9/25 113/2
subsidiary [9] 32/17
35/18 60/23 60/23
62/14 65/3 65/11 72/7I
154/21
substance [11] 94/12)
94/21 94/23 104/23
104/24 114/14 114/14
126/3 128/19 144/20
162/20
substantial [1] 7/24
substantive [1] 117/1
subsubthemes [1]
109/3
subtheme [1] 109/2
success [1] 38/23
successful [1]
149/14
succession [1]
160/12
successor [1] 119/24I
such [26] 15/20 19/1
29/19 41/24 45/9
47/15 47/23 69/9 71/6
84/19 85/24 86/2 98/5)
99/13 100/11 103/22
105/11 110/15 111/20}
subcategorisation [1]
127/22 131/6 131/8
131/12 151/24 160/10}
165/6
suddenly [1] 92/3
suffering [3] 84/14
109/21 164/13
sufficient [6] 78/10
108/1 128/22 148/14
159/15 160/3
sufficiently [4] 17/21
92/23 100/3 118/21
suggest [5] 100/9
101/3 111/3 156/23
157/24
suggested [6] 30/20
57/9 89/25 92/4 96/15
139/18
suggesting [1] 12/18
suggests [2] 93/11
116/15
suitability [1] 162/3
suitable [1] 167/15
sum [2] 127/17
133/12
summarise [8] 7/4
8/22 32/12 32/22 37/1
129/9 129/12 131/2
summarised [4]
15/12 15/19 37/5
76/21
summarising [3]
45/1 45/22 105/3
summary [26] 9/17
9/20 19/9 20/3 37/3
37/6 55/20 76/5 95/4
95/14 100/4 103/10
103/18 103/22 103/23
105/19 106/11 106/14,
107/14 107/14 107/18}
107/24 117/21 118/12)
118/14 131/16
supplier [1] 53/6
suppliers [2] 48/8
52/11
support [6] 30/19
79/3 91/1 160/2 160/7
162/23
support’ [1] 160/9
supportive [2]
110/18 154/14
sure [6] 49/2 61/2
65/1 116/13 120/10
131/25
surfacing [2] 147/10
148/18
surprises [1] 1/15
surprisingly [1] 80/4
survival [1] 61/14
Susan [20] 91/21
98/1 98/3 105/3
111/18 113/17 115/13}
116/9 117/23 118/11
119/23 120/16 121/4
121/10 121/13 121/15)
122/1 122/2 122/3
124/13
suspect [1] 167/20
Sussex [2] 7/13 9/6
sustain [1] 160/8
sustained [1] 110/11
Swinson's [1] 162/9
sympathy [1] 116/10
system [21] 16/11
47/15 55/24 56/16
67/18 67/20 71/7
72/25 73/6 76/11
79/16 82/24 89/19
109/17 118/1 120/3
123/2 146/20 163/10
163/15 165/24
system’ [1] 100/2
systematically [1]
139/14
systemic [2] 90/4
90/25
systems [6] 22/1
22/4 22/11 165/20
165/20 165/23
T
table [4] 15/12 35/9
36/22 69/3
tabled [1] 98/19
tabular [1] 36/6
tackled [1] 147/7
tailing [1] 166/10
tainted [1] 119/12
take [23] 5/7 21/11
23/1 37/16 53/19
53/20 56/11 56/20
71/6 80/1 97/18 97/18}
110/9 124/10 126/4
139/7 139/19 153/20
153/25 165/18 166/1
167/3 167/18
taken [15] 1/15 23/16
47/4 57/12 63/1 69/5
79/24 102/23 127/24
128/23 135/12 135/16)
136/2 136/5 164/1
takes [1] 114/18
taking [5] 16/11
33/24 123/9 127/16
158/6
talk [8] 32/2 52/25
66/15 71/18 96/25
145/4 160/17 168/7
talked [5] 57/16
57/20 72/5 72/23
122/3
talking [5] 49/23
100/17 121/10 165/9
168/5
task [1] 9/14
taught [2] 7/5 8/22
tax [1] 45/9
taxpayer [1] 29/17
team [28] 58/10
(68) sped - team
T
team... [27] 58/12
68/3 74/16 75/17
85/20 87/1 87/10
87/12 89/14 91/9 92/5
92/18 117/3 118/21
119/4 124/22 124/23
130/12 136/17 138/2
141/9 146/6 157/19
158/5 158/25 160/24
166/15
teams [3] 134/18
153/8 163/24
teamworking [1]
156/24
technically [2] 47/12
150/18
technology [8] 67/18
67/20 68/11 68/15
72/18 81/6 87/23 91/3
tell [31] 1/10 7/4
10/22 16/17 16/19
17/6 17/23 18/5 18/19
26/2 26/18 27/8 28/17
34/10 34/17 35/19
57/15 58/20 58/24
59/8 61/6 65/19 66/12
67/19 74/9 79/20
101/2 132/13 135/10
137/12 150/9
telling [5] 19/4 68/10
68/10 68/11 133/16
tended [2] 11/12
1112
tender [1] 162/15
tensions [2] 47/24
161/22
term [1] 30/17
terminology [1] 26/2
terms [18] 28/17
36/18 40/25 45/14
A7IT 47/8 47/25 49/7
60/25 62/23 76/18
86/1 86/2 103/17
110/22 123/8 152/23
156/5
testimony [2] 67/3
161/3
text [1] 46/13
than [21] 1/16 14/4
35/6 48/5 49/21 52/22
53/21 78/1 81/6 87/11
90/22 91/24 94/12
95/5 100/6 106/13
115/8 126/17 134/21
139/22 141/7
thank [94] 1/23 4/9
5/3 5/7 5/21 6/1 6/7
6/15 6/21 8/18 9/12
9/17 9/20 10/7 10/22
12/7 12/22 14/7 14/16}
15/7 16/5 16/9 17/23
21/19 26/1 26/17 27/7
29/9 30/5 30/23 32/21
33/3 33/9 33/22 36/10
36/19 36/23 37/14
37/19 39/3 43/18
44/23 45/19 46/11
47/10 48/20 49/17
50/11 51/19 53/12
54/6 55/8 55/18 61/4
61/5 63/11 68/17
71/18 74/8 74/21
75/22 75/25 77/18
82/22 84/24 85/2
90/14 94/9 95/11
95/18 99/23 102/21
108/23 111/12 113/10]
117/46 123/15 123/22!
134/5 137/9 137/10
138/8 138/10 140/19
144/12 154/9 156/7
156/15 157/1 159/21
166/25 167/1 168/3
168/8
that [929]
that I [1] 167/1
that's [95] 4/22 7/24
9/11 10/6 10/15 11/16
12/4 12/12 13/8 13/23
14/7 14/17 15/6 15/23
16/4 16/16 17/1 18/3
18/13 18/18 20/14
20/18 23/16 28/1
30/18 31/10 33/20
34/4 35/1 35/24 36/4
36/9 36/19 37/13
39/24 43/13 43/25
44/8 48/5 57/20 57/21
58/2 62/8 67/4 69/24
70/18 71/4 73/8 7/21
77/23 81/21 84/2 84/2
85/3 86/8 89/6 92/16
93/1 93/9 93/24 94/16
94/24 95/25 96/1
97/12 97/14 99/10
104/11 104/17 108/8
109/8 123/11 123/16
126/19 132/10 132/14)
138/10 139/4 139/6
139/8 140/5 141/3
145/21 146/3 146/12
149/2 152/21 152/21
156/5 157/20 158/12
159/13 159/22 168/1
168/2
their [97] 2/3 4/17
26/15 28/19 28/20
28/22 29/5 29/6 29/7
30/3 37/11 38/17 40/3
41/4 42/13 42/25 43/8
43/10 44/11 44/19
46/7 46/9 48/6 48/7
48/12 52/16 52/21
58/12 58/13 63/5 63/7
63/24 64/24 65/20
69/3 76/21 76/25 77/5
79/7 79/25 79/25 80/2
80/4 80/17 87/10
91/14 93/4 93/7 93/8
98/4 101/14 102/4
102/10 103/7 103/23
109/14 110/2 110/19
111/10 111/25 112/9
113/4 113/20 115/6
118/9 120/8 120/9
124/22 125/21 125/21
126/1 129/19 131/25
134/15 135/4 135/18
137/1 138/4 139/15
148/12 149/25 150/2
150/22 151/9 153/6
153/18 155/1 155/1
155/23 157/8 157/10
158/4 162/25 163/22
163/23 164/6 164/14
them [56] 2/20 19/14
25/2 28/12 28/16 29/3
35/8 37/23 39/8 41/25
42/3 43/9 43/11 60/3
65/2 65/5 70/6 71/3
71/25 81/25 82/15
84/13 91/2 93/4 102/5
105/22 109/4 109/8
110/13 112/6 112/9
120/24 126/4 127/16
128/23 129/20 129/24
129/24 130/1 130/4
138/4 138/12 138/17
139/18 142/6 143/9
157/11 159/3 159/11
161/8 166/21 167/2
167/5 167/5 167/16
168/5
thematic [1] 20/3
theme [14] 69/12
69/22 94/10 133/13
139/4 144/13 146/23
148/3 154/11 154/13
156/7 156/15 159/21
163/2
theme 8 [1] 159/21
themes [13] 18/20
20/10 20/11 20/12
20/24 21/17 54/11
54/12 138/11 138/19
140/3 144/12 156/18
themselves [5] 43/11
43/12 104/1 157/5
160/6
then [124] 5/11 6/1
9/13 12/9 14/25 15/24
16/14 20/1 20/10
20/12 20/15 24/8
24/20 25/5 25/6 25/19)
29/14 29/22 30/12
32/2 32/10 32/15
32/21 33/3 33/10
33/17 33/23 34/2 34/3)
34/7 34/15 34/18 39/3
39/11 39/14 39/17
39/20 39/21 39/22
40/17 42/8 43/21
43/22 45/14 45/17
46/20 47/4 47/6 48/9
48/16 48/18 54/12
54/15 54/16 55/3
55/13 55/14 55/15
56/3 56/8 61/21 61/23
62/11 66/5 68/12 71/7
71/18 72/8 72/22 74/8
TAIT 74/17 74/18
74/21 75/23 76/23
78/8 80/5 83/17 84/4
89/4 90/12 91/18
92/13 94/15 96/23
97/10 99/19 101/22
105/13 106/7 108/21
110/4 110/14 111/6
111/17 113/2 116/22
117/13 119/9 119/19
120/3 120/20 128/14
129/23 134/6 135/1
135/3 138/11 138/23
138/25 142/11 143/5
146/8 147/18 150/24
151/15 156/4 157/23
158/19 159/14 164/1
164/8 168/4
there [230]
there'd [1] 161/4
there's [12] 48/3 48/4
55/19 82/19 90/24
94/17 112/2 113/3
117/21 121/24 121/24}
137/25
thereafter [3] 2/18
9/4 131/4
therefore [19] 2/1
21/13 22/3 22/14
36/16 47/1 56/18 57/2,
60/13 62/24 64/21
777 84/12 84/14
84/15 90/7 98/15
139/25 152/18
these [59] 2/5 4/17
25/9 27/3 27/4 28/10
28/14 28/14 28/15
30/3 31/20 32/4 34/8
36/11 40/9 40/10
45/12 46/23 48/3 52/4
52/8 52/17 54/23
56/11 59/16 59/25
61/9 61/12 61/25 62/7
65/1 71/2 75/1 80/20
84/16 92/22 96/21
99/1 104/7 115/7
116/5 126/9 130/5
131/12 132/1 133/6
133/12 135/7 136/1
136/23 138/15 145/18
152/16 153/22 155/14}
159/17 165/17 165/18}
165/23
they [236]
they'd [2] 101/25
102/16
they'll [1] 100/24
they're [21] 10/16
10/18 31/21 31/24
41/9 41/19 41/19
44/11 45/11 68/19
77/22 83/8 83/9 83/10
101/1 101/2 117/1
137/11 141/24 164/23)
165/2
they've [3] 41/12
146/5 146/7
thing [8] 12/4 57/13
74/1 114/1 133/11
145/21 145/22 164/12!
things [29] 4/17
21/24 22/6 27/10
27/25 40/11 45/9 50/6
61/23 70/14 71/9
73/18 74/14 81/24
88/13 90/25 101/4
103/24 108/5 111/16
112/3 116/25 117/15
139/24 142/9 145/15
148/9 155/12 167/22
think [105] 3/5 4/14
4/16 4/19 6/25 8/1
14/13 18/2 19/2 23/9
24/16 28/6 28/14 30/6
30/12 40/23 44/15
46/17 47/13 47/25
49/22 50/12 50/25
52/1 52/13 53/2 55/5
57/21 59/1 60/17
61/18 61/24 64/19
65/6 67/4 67/17 67/24
68/1 68/19 71/25
73/14 74/11 74/13
75/14 77/17 80/10
80/25 81/21 82/20
84/22 90/10 92/13
93/18 94/24 95/22
101/5 102/1 106/16
107/12 112/6 114/1
1414/4 114/17 117/2
117/9 119/19 120/22
121/8 121/24 121/25
122/22 123/11 127/3
127/15 128/5 128/9
132/7 132/11 132/16
133/18 142/10 143/24)
144/18 145/3 145/10
146/12 148/24 151/20)
152/11 152/13 152/19)
153/1 155/9 155/11
156/11 159/1 1641/1
162/4 164/23 165/13
166/5 167/18 167/23
168/2 168/7
thinking [2] 50/18
107/16
third [15] 2/17 5/11
5/15 9/13 18/19 39/1
(69) team... - third
T
70/8 85/12 85/15
116/7 142/23 146/23
149/11
third-party [1] 48/8
thirdly [1] 54/16
thirds [1] 7/4
this [232]
thoroughly [1] 148/1
those [70] 3/11 3/22
6/11 6/17 16/6 18/9
19/17 19/18 19/21
20/23 21/14 28/11
38/15 41/24 43/24
46/8 47/6 50/2 50/3
50/8 51/6 54/2 54/10
78/1 78/21 83/14
83/21 85/25 86/18
88/13 89/16 89/22
90/11 93/25 94/22
96/4 96/10 97/10
99/22 102/1 103/24
108/17 109/5 111/3
119/15 120/7 122/23
127/18 128/3 132/6
133/4 133/9 135/2
142/8 143/2 143/6
144/9 144/25 145/20
146/7 149/8 149/22
152/10 155/3 158/7
167/1
though [9] 50/14
56/23 63/24 64/8
155/22 167/20
thought [18] 13/20
19/21 19/24 28/13
31/5 41/24 43/8 48/9
65/6 67/17 80/18
102/16 121/2 125/1
127/17 148/14 149/9
152/4
threads [3] 71/15
71/19 102/1
threatening [1]
109/19
three [30] 5/22 18/6
19/10 19/17 19/18
19/25 20/7 20/16
20/19 21/2 21/16
33/11 33/19 33/19
47/21 48/1 53/10
54/10 54/21 65/18
94/17 108/5 139/3
139/12 147/9 147/19
156/18 157/19 157/20)
166/20
three-page [1] 94/17
through [18] 5/11
11/18 14/9 27/8 32/2
36/21 54/10 56/4
third... [9] 48/8 65/18
55/3 64/16 65/12 68/8
136/14 136/25 139/17)
71/18 74/19 76/2
138/24 141/8 144/21
163/5
throughout [5] 21/20
45/2 75/20 125/7
129/15
tie [1] 81/23
tier [1] 26/7
time [45] 1/17 12/1
13/13 18/12 20/20
22/24 25/3 25/9 25/25
26/23 33/14 33/18
34/8 34/25 36/1 36/8
36/13 48/1 48/4 50/10
60/22 61/7 63/9 63/17
65/25 69/2 75/16
77/15 79/9 101/9
102/3 102/10 104/23
109/18 110/9 112/14
113/3 115/1 115/6
119/7 124/16 125/17
149/13 160/7 167/15
times [6] 43/15 67/2
80/8 148/17 154/25
165/4
tiny [1] 82/12
title [1] 3/18
today [3] 3/12 16/11
165/15
together [20] 25/6
25/10 26/12 53/25
54/24 54/25 55/3
71/15 71/19 93/13
102/1 108/14 108/18
112/8 127/18 127/24
128/4 133/12 145/17
145/18
told [14] 26/20 60/3
64/3 69/11 77/2 78/16
82/18 84/14 90/8 90/9
94/4 101/1 101/2
162/14
tomorrow [4] 2/4
3/13 167/3 168/9
too [2] 83/4 94/25
took [3] 47/6 133/25
161/7
top [14] 13/23 24/14
34/3 36/25 77/16
77/18 79/15 87/9
90/23 90/24 92/9
138/1 144/14 160/5
top-level [2] 90/23
90/24
topic [4] 9/13 24/13
45/21 98/5
topics [2] 24/13
54/17
topping [1] 166/10
total [1] 120/25
totally [5] 111/25
112/5 112/9 112/11
112/13
144/25 149/10 160/10)
158/10
towards [1] 135/5
track [2] 12/1 35/25
trade [4] 35/22 47/24
48/3 52/9
trade-offs [2] 47/24
48/3
trained [1] 1/18
training [1] 91/1
transcripts [3] 18/1
66/14 148/22
transparent [1] 49/5
Treasury [3] 13/5
13/15 30/12
treated [1] 43/2
treatment [5] 51/7
86/6 98/6 99/7 116/9
tried [4] 25/24
true [5] 2/12 4/1 4/6
6/12 6/18
truly [1] 132/3
Trust [3] 8/2 8/10 9/9
truth [3] 3/22 17/16
62/6
try [2] 24/9 102/17
trying [7] 31/8 34/22
71/17 82/7 121/18
123/11 136/21
TSB [1] 8/7
Tuesday [1] 1/1
turn [42] 4/9 6/22
9/13 9/15 16/12 19/8
24/8 35/5 37/25 48/20}
49/17 51/20 54/7
54/13 54/18 62/11
63/11 65/16 65/17
75/22 85/13 95/18
99/19 99/22 104/14
108/23 109/7 111/12
117/16 123/17 123/25)
129/4 133/6 134/5
135/7 137/10 144/13
146/23 148/3 159/21
159/23 163/2
turned [1] 74/15
turning [2] 85/12
102/21
turnover [1] 45/10
two [34] 1/16 1/19
1/25 3/4 5/14 7/1
11/21 14/19 20/20
24/17 26/7 27/10
27/25 34/8 36/5 37/23
38/4 40/19 42/23
65/12 74/23 85/12
90/11 107/19 107/20
111/16 114/9 120/7
142/8 145/16 145/18
155/3 158/7 168/5
two-thirds [1] 7/1
typically [1] 10/9
touch [3] 42/21 87/10]
U
29/22 46/18 129/15
UKGI [8] 10/2 10/3
42/8 160/17 160/19
160/20 161/8 162/3
ultimate [2] 125/4
129/23
ultimately [4] 98/25
123/8 130/1 137/24
unaffected [1] 9/24
unambiguously [1]
128/15
uncomfortable [1]
92/2
uncover [1] 164/20
under [13] 38/3
124/16 143/8 151/25
155/9
underlies [1] 165/14
underlying [4] 18/2
56/5 135/12 135/14
undermined [1]
120/2
underneath [2] 133/6)
135/7
underpinned [1] 22/2
understand [29]
10/12 14/18 15/17
33/16 36/17 38/17
57/8 61/9 65/10 65/20)
92/20 93/12 96/14
102/17 116/5 121/12
122/14 123/2 126/13
127/11 134/12 136/22}
138/19 141/24 142/25)
144/4 153/19 159/15
165/21
understanding [15]
38/25 52/17 57/2
58/15 61/21 65/2 69/4
93/8 134/6 134/25
141/10 143/4 148/11
149/7 159/12
understandings [1]
83/6
understood [22]
25/14 45/3 52/2 56/15
63/3 91/2 91/4 91/5
92/16 97/22 115/25
118/6 128/18 129/17
132/16 141/14 141/16
142/2 143/5 144/3
149/17 166/6
undertaken [4] 83/16
100/7 141/22 142/16
undertakes [1]
142/10
undertook [1] 161/8
UK [9] 11/12 25/14
26/2 26/11 26/23 28/7
uncertainty [1] 47/22
40/17 48/18 51/3 55/5
55/16 62/8 69/3 119/8I
unequivocally [1]
128/20
unfair [2] 16/24 51/8
unfold [1] 98/23
unfounded [1] 89/20
unhappiness [1]
112/2
UNHCR [1] 9/10
unheard [1] 164/7
unions [1] 52/10
unitary [3] 26/3 26/16
148/15
university [2] 7/10
718
unless [5] 2/23 94/7
141/1 152/15 160/2
unresolved [1]
109/16
unsafe [2] 118/10
135/21
unsatisfactory [1]
161/19
unsteadiness [1]
161/23
until [17] 26/21 33/14)
37/17 39/5 55/10 76/2!
77/8 85/4 100/12
119/25 123/17 128/14}
134/1 148/7 153/11
167/3 168/11
unusual [9] 72/6
111/21 112/1 112/5
112/11 112/13 113/4
113/5 143/14
unusually [3] 1/22
1/25 113/7
unwilling [1] 70/21
up [41] 5/9 14/16
21/5 24/16 26/21
33/14 35/5 39/5 45/23}
47/6 48/13 49/3 49/3
49/4 50/7 50/8 55/10
65/6 65/7 69/23 71/4
72/4 77/8 78/1 79/20
85/13 92/22 99/16
100/15 116/2 116/24
117/11 123/25 127/13}
128/2 134/22 148/7
150/8 162/1 163/18
164/18
update [16] 77/5
91/20 95/15 100/7
100/23 105/7 105/9
105/13 105/20 106/7
106/8 108/2 109/13
115/20 120/15 126/10)
updated [3] 3/9 3/19
42
updates [1] 100/20
upon [22] 15/21 16/5
17/22 61/14 75/19
78/22 80/25 86/14
86/17 86/21 88/24
94/6 105/13 107/7
(70) third... - upon
U
upon... [8] 133/1
134/4 136/19 142/7
146/4 148/20 153/23
155/24
upwards [1] 93/5
urgency [2] 125/3
138/5
urgent [1] 82/12
urgently [1] 108/4
us [77] 1/10 5/2 7/15
10/22 16/17 16/19
17/6 17/21 17/23 18/5}
18/19 19/4 19/18
19/20 22/15 26/2
26/18 26/20 27/8
28/17 29/14 32/2
32/13 32/22 33/5
33/23 33/24 34/10
34/17 35/19 36/14
38/4 44/8 44/25 45/21
47/17 57/15 58/20
58/24 59/8 61/6 61/15
62/16 63/22 65/4 65/7
65/19 66/12 66/23
68/10 68/10 68/11
71/5 71/18 72/25 74/9
79/20 87/5 104/22
114/18 120/20 123/3
126/21 127/16 129/9
129/12 130/7 135/8
135/10 137/12 145/1
149/9 149/12 150/10
159/5 161/13 161/17
use [10] 3/12 36/20
48/7 51/6 57/10 58/17)
79/12 106/3 164/24
166/22
used [6] 16/22 52/24
57/1 74/20 78/14
119/18
user [1] 165/23
users [2] 163/16
165/22
using [5] 20/23 32/4
45/14 96/21 124/12
usual [1] 160/10
usually [2] 4/20
107/10
utterly [1] 41/19
Vv
validity [1] 56/17
valuable [1] 36/19
variety [1] 62/2
various [8] 41/22
54/2 80/3 108/17
127/15 128/5 143/1
163/12
variously [1] 32/17
vast [1] 18/25
Vennells [13] 86/8
90/15 93/22 105/3
107/23 121/25 122/9
122/17 162/4 162/11
Vennells' [2] 91/16
167/19
verifiable [1] 45/8
very [70] 4/9 5/21 6/1
6/21 9/12 15/7 24/23
28/3 28/7 32/15 33/9
36/10 36/16 36/19
37/14 37/19 43/4
43/14 46/6 47/10 50/9)
50/17 50/19 51/16
52/2 52/14 54/4 54/16
55/8 55/19 58/3 64/7
66/19 74/8 74/15
75/25 76/16 76/25
77/9 92/16 92/16
92/18 93/10 94/19
103/15 108/20 111/24)
117/2 117/5 127/3
131/11 132/21 136/22)
136/22 141/1 141/1
141/12 149/5 149/6
149/18 149/19 150/2
150/21 150/22 152/17)
157/17 163/16 167/41
168/3 168/8
vi [4] 15/9
via [3] 64/6 64/15
76/24
viable [1] 162/25
Vice [1] 7/14
victim [1] 143/15
view [39] 10/14 18/11
21/22 28/22 44/21
56/6 56/13 59/2 66/10
66/22 71/6 80/14 81/4
81/13 93/22 96/17
97/15 102/2 104/7
109/12 113/10 113/16)
115/14 136/6 137/1
137/18 139/21 139/23)
147/20 152/21 152/22)
160/8 160/11 162/14
162/22 162/25 167/18)
167/21 168/1
viewing [1] 60/14
views [12] 16/1 71/19
74/22 80/13 80/16
80/17 87/2 98/25
135/24 136/15 155/1
163/19
visiting [2] 9/4 9/5
vital [1] 87/20
voices [1] 164/6
voicing [1] 112/9
volume [2] 17/10
17/13
voluntary [1] 38/19
volunteered [1]
118/5
voyage [1] 28/4
162/15 167/14 167/23)
Ww
wait [1] 4/25
want [17] 11/18 24/8
31/18 48/4 58/21 65/2
74/12 95/11 108/9
117/8 121/7 136/7
137/8 146/21 150/4
161/25 166/4
wanted [2] 75/6
144/7
wanting [1] 127/16
wants [1] 128/7
warmed [1] 69/22
warrant [3] 64/13
78/11 82/12
warranted [1] 103/3
was [371]
wasn't [19] 16/17
57/12 60/24 67/6
69/17 72/13 72/22
81/12 101/10 105/2
106/6 106/11 108/6
128/2 137/7 153/19
161/14 162/24 163/1
water [3] 158/21
158/22 158/23
way [59] 12/4 13/9
14/20 17/6 24/21
38/17 42/23 43/4
44/22 45/3 46/7 48/18
50/1 54/14 54/23 55/7
55/11 60/14 62/1
62/25 63/14 64/24
68/2 70/23 80/22
81/24 87/12 89/22
92/11 99/12 99/13
101/25 103/15 105/14]
106/24 107/16 117/15
119/8 121/4 124/16
130/14 132/19 133/1
134/2 134/3 137/15
138/16 140/10 141/7
149/16 149/24 152/16
153/23 156/3 158/3
158/24 159/11 166/12)
166/14
ways [3] 49/4 62/2
147/20
we [343]
we'd [2] 21/24
100/23
we'll [9] 2/22 4/24
77/12 80/21 91/2
95/13 97/21 99/17
112/17
we're [27] 3/12 7/25
11/6 27/19 42/2 49/23
51/13 55/5 61/12 69/7
70/23 93/10 101/19
101/20 108/11 108/12)
108/19 115/2 121/18
123/11 130/22 130/23
131/10 134/23 159/4
165/19 166/2
we've [45] 3/2 13/18
14/11 15/13 20/20
22/5 25/24 28/8 36/22
37/3 37/5 37/15 40/4
54/24 59/21 69/1
69/12 69/12 70/25
72/5 72/23 74/13 79/9)
90/8 90/9 91/1 108/22
112/6 113/19 116/1
130/7 130/18 136/5
136/25 144/14 145/15}
145/24 151/22 155/25}
158/20 158/24 159/3
159/3 165/4 165/15
weak [1] 60/13
wearing [2] 84/20
84/23
week [1] 125/7
well [49] 1/20 3/16
19/2 26/15 27/9 27/21
27/24 30/15 36/19
41/4 44/6 45/24 52/2
53/22 65/7 67/16 69/6
69/10 72/11 80/22
86/9 86/13 87/1 88/23
90/8 92/16 95/13
97/21 101/4 102/9
102/17 110/22 111/7
114/1 119/7 128/11
129/21 130/5 132/18
132/21 141/21 146/10}
151/20 152/6 158/1
162/8 165/1 166/7
166/10
went [4] 63/16 94/17
132/13 160/21
were [192]
weren't [7] 57/11
60/21 60/22 67/3
69/11 80/15 146/11
what [180]
what's [14] 13/9
33/16 42/21 51/21
68/10 69/6 72/16
106/8 107/12 138/18
146/2 146/8 165/22
167/24
whatever [2] 90/6
99/4
whatsoever [1]
131/11
when [39] 2/2 2/3
22/9 24/23 30/1 32/16
42/7 43/15 57/22
59/12 62/9 66/7 71/19
74/14 77/3 78/14
80/20 82/17 82/18
84/10 92/2 95/10
100/18 102/3 104/3
104/25 105/1 105/12
108/17 119/2 121/15
124/7 125/17 125/22
138/5 140/16 142/24
147/15 168/5
where [46] 2/7 22/3
22/21 23/15 26/6 29/4I
29/15 32/23 37/9 43/7
45/20 51/19 70/15
78/24 80/9 83/20 88/9I
91/17 92/5 92/8 94/19
96/25 104/15 107/9
107/11 112/25 119/14I
120/16 121/23 125/14}
126/25 129/2 132/13
133/15 134/18 146/10}
149/6 149/21 151/17
152/9 155/4 158/16
160/17 162/2 165/24
166/21
whereas [1] 167/22
whether [16] 2/12
49/15 61/3 97/8 108/5)
113/7 120/20 120/21
122/5 132/2 141/8
142/18 143/17 151/25)
154/3 154/14
which [232]
while [2] 16/11 21/5
whilst [7] 11/8 37/10
87/19 90/3 92/21
125/19 157/9
whistleblowers [2]
49/14 51/6
whistleblowing [9]
48/22 48/25 49/10
49/12 49/20 49/25
50/14 51/18 63/21
who [47] 19/2 24/25
25/1 31/9 31/12 38/9
38/16 49/3 50/8 52/4
52/19 55/21 58/7 63/9
68/4 71/24 72/2 72/12I
80/2 84/20 97/5 98/23}
98/23 112/12 114/15
115/9 115/10 115/12
115/24 115/24 116/2
119/20 125/3 127/6
127/8 127/9 132/13
132/17 141/23 149/5
149/7 150/11 150/22
157/3 158/9 159/8
164/13
whole [9] 39/10 44/7
49/24 52/11 62/1 62/2)
72125 73/6 92/20
wholehearted [1]
163/1
wholesome [1] 163/1
wholly [2] 11/5
122/18
whom [8] 31/9 36/15
38/7 38/10 38/15
149/8 160/14 160/25
whose [1] 33/7
why [20] 19/18 28/20
29/7 31/10 40/13
48/23 62/16 68/23
(71) upon... - why
WwW
why... [12] 81/8
81/18 81/21 92/16
96/10 98/4 98/7 102/9
106/18 106/24 155/9
156/5
wider [4] 20/8 56/21
114/17 116/23
will [30] 1/18 2/10
2/12 2/15 2/17 2/19
14/8 22/11 26/7 26/14}
36/20 37/24 38/16
41/3 43/7 49/5 71/9
108/13 119/13 119/16)
120/10 120/22 127/1
135/4 138/3 147/6
150/13 153/10 167/4
167/21
Williams [1] 119/4
willing [1] 70/23
window [1] 139/19
wise [2] 47/1 47/20
wish [10] 19/22
41/25 49/3 50/8 94/6
100/11 100/25 133/9
135/22 138/6
wished [2] 96/6
144/11
wishes [2] 2/24 90/6
within [28] 16/22
42/2 43/5 61/21 85/20
86/19 87/13 89/18
92/8 102/12 102/21
103/15 109/2 111/4
116/14 116/22 117/7
123/5 123/10 123/12
129/22 133/24 134/20)
135/18 146/4 149/21
158/25 160/24
without [9] 46/4 49/4
63/16 104/9 112/9
114/2 134/13 135/17
144/25
witness [17] 1/17
1/25 3/1 3/21 18/1
66/14 118/16 119/6
119/11 119/12 119/17)
127/10 135/21 137/4
146/22 148/22 168/4
witnesses [6] 1/19
1/25 2/2 2/7 2/8 3/3
Wolstenholme [17]
19/11 55/21 57/24
59/10 60/16 62/8
62/10 62/12 62/17
64/8 65/19 66/8 71/14
71/16 71/20 75/12
139/13
Wolstenholme's [5]
55/1 56/16 56/22
65/25 147/15
woman [2] 29/3
148/24
won't [1] 154/9
wondered [1] 27/2
wonderful [1] 128/1
word [8] 5/23 5/23
6/3 27/5 27/22 49/19
51/23 166/22
words [9] 5/11 5/16
5/17 6/3 51/7 51/23
105/8 133/22 164/23
work [24] 2/22 19/23
25/4 31/18 36/19
54/24 76/25 89/10
89/10 89/11 89/12
100/5 100/7 110/11
113/21 125/9 131/4
138/18 145/17 145/18)
147/7 153/4 153/22
156/3
worked [1] 159/20
workers [2] 50/19
50/20
working [8] 150/21
151/8 151/10 153/13
154/18 154/22 157/18)
164/5
works [6] 11/19 12/5
12/23 14/7 37/3
153/24
world [1] 31/23
worse [1] 167/22
would [126] 11/23
19/22 22/22 23/7
25/24 29/7 31/23 37/6
40/3 41/16 44/7 47/1
47/20 52/1 52/19
57/13 57/24 65/6
66/25 68/13 69/24
71/4 72/9 72/10 75/16
83/17 83/21 84/17
86/7 86/12 86/15
86/17 86/25 87/1
87/11 87/14 88/8
88/24 89/20 89/24
94/24 95/2 96/1 96/5
96/10 97/22 97/23
97/23 97/25 98/17
98/20 98/24 98/25
99/1 100/1 100/2
101/22 102/9 103/20
104/6 108/21 110/5
110/16 111/8 111/10
115/9 115/15 116/14
1417/5 118/12 118/14
120/24 122/3 122/5
122/24 122/24 123/3
123/5 124/25 127/22
127/22 127/23 127/24
128/1 129/12 129/25
130/15 130/25 131/1
132/17 132/24 133/3
133/11 140/9 141/9
141/13 141/14 142/6
142/17 143/3 143/8
143/22 143/24 144/1
144/1 144/3 144/7
144/10 144/11 147/8
147/21 149/15 151/15}
152/17 153/12 153/15}
153/20 160/10 161/10}
163/12 163/17 164/24
164/25 166/2 167/5
167/18
wouldn't [3] 40/1
107/6 123/4
write [1] 103/22
written [8] 7/6 17/10
17/17 103/23 112/25
118/20 119/2 120/16
wrong [2] 84/11
130/19
wrongdoing [2]
133/15 155/17
wrongful [2] 116/1
165/11
Wyn [1] 50/5
Y
yeah [8] 13/12 26/25
51/12 88/18 100/17
100/17 102/6 104/13
year [9] 13/5 33/15
34/11 34/16 36/1
49/21 100/19 154/21
154/24
years [7] 1/16 7/16
8/24 25/13 25/23
134/1 140/17
yes [87] 4/20 7/3 8/10
13/17 14/2 14/15
17/14 20/22 31/2 31/6
32/23 33/13 37/18
40/15 40/20 40/22
41/1 44/4 46/16 46/16
46/19 48/15 48/17
50/17 51/9 52/1 53/5
53/7 53/16 55/17 59/6
59/7 60/9 61/8 67/25
70/13 70/17 71/21
74/2 74/5 74/24 75/6
76/3 76/8 78/24 81/2
81/7 81/14 81/17 82/6
84/9 85/5 88/19 96/20
98/8 98/10 98/14
98/16 99/19 101/8
101/15 104/20 105/7
105/19 110/22 114/12
121/8 129/13 140/7
140/18 140/21 140/24
140/25 141/1 141/16
142/14 143/10 143/12
145/3 152/21 156/14
156/17 157/22 162/6
164/25 165/1 165/2
yesterday [3] 3/11
3/20 4/12
yet [10] 56/19 80/12
81/15 90/9 93/13
93/14 112/16 145/5
149/19 159/9
you [583]
you'd [3] 83/19 94/8
166/4
you'll [8] 3/18 4/11
5/1 13/17 15/9 133/19)
151/8 167/15
you're [34] 7/18
12/18 13/24 14/16
14/18 15/17 15/18
19/4 22/10 27/18 28/2)
29/21 34/7 48/5 65/2
70/21 87/5 97/4 99/6
100/18 105/16 111/16)
124/1 127/16 128/19
129/10 131/2 131/16
132/22 134/21 139/2
143/25 158/17 161/20}
you've [23] 3/4 8/1
16/12 20/23 23/12
35/14 35/16 42/5 51/5)
59/18 60/6 69/19
69/19 69/22 69/22
73/9 108/25 109/10
118/14 131/12 140/14}
162/4 162/15
your [111] 1/10 2/11
2/15 3/24 4/2 4/4 4/7
6/8 6/12 6/15 6/18
6/22 7/1 7/20 8/21
9/14 9/15 9/17 10/14
10/23 15/8 15/18
15/20 15/21 16/1
16/12 16/12 16/17
17/24 17/25 19/9 20/4
20/10 20/23 21/15
21/16 21/17 21/22
31/24 33/10 33/15
33/25 35/3 38/1 38/5
47/18 51/3 51/25 54/9)
55/9 56/4 56/8 56/13
59/1 61/2 63/11 64/16
66/6 66/10 69/22
69/23 69/25 71/13
71/18 74/22 76/2
79/18 81/1 81/10
85/14 85/18 93/22
95/20 96/17 96/17
99/21 102/2 102/25
104/21 106/15 107/10}
109/7 109/12 111/15
114/6 119/21 124/4
127/2 129/7 133/7
134/6 135/9 137/10
137/13 139/1 142/11
144/12 144/18 145/2
147/1 148/6 148/20
150/7 152/4 154/13
155/3 156/9 156/20
159/23 162/5 163/4
yourself [1] 18/6
(72) why... - yourself