ONOaARWN
The Post Office Horizon IT Inquiry
Tuesday 17 December 2024
(9.29 am)
SIR WYN WILLIAMS: Mr Beer, curious is a word which has been
much used in this Inquiry, and people may have noticed
how curious I was to see people sitting in different
places.
MRBEER: Yes.
SIR WYN WILLIAMS: Ms Greaney, I think we're ready for you
though the door hasn't shut at the back yet, so I'll let
you know when they've shut the door so that you have the
floor to yourself.
Closing submissions by MS GREANEY
MS GREANEY: Sir, the Inquiry has received detailed written
closing submissions from Post Office in Phases 2 to 7.
I do not intend to rehearse the content of those
submissions orally. I propose to address some headline
points which will not take up the full hour that has
been allocated.
Post Office recognises that its actions, as explored
by this Inquiry, have caused harm and suffering to
postmasters, their families and to many others.
I would like to start by reiterating Post Office's
apology for the damage that it has caused to every
person who has been affected by the Horizon IT scandal.
This Inquiry has been a humbling experience, not only
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Post Office acknowledges that it will, rightly, be
judged in the months and years to come by what it does,
not by what it says it is going to do.
Post Office has sought to assist the Inquiry in
fulfilling its terms of reference to understand and
acknowledge what went wrong in relation to Horizon in
order to identify what key lessons must be learnt for
the future. The scale and scope of the evidence heard
by the Inquiry over the last two plus years is vast.
That includes evidence from postmasters, as well as from
a very significant number of witnesses who were or are
employees of Post Office.
The Inquiry heard from those in senior positions in
Post Office, as well as those in less senior roles,
dealing with day-to-day issues with postmasters.
Post Office acknowledges that the Inquiry will
rightly be critical of a number of individuals, not only
from Post Office. It invites the Inquiry to bear in
mind the serious governance and structural failures that
permitted their actions to be unchecked, resulting in
failings to the detriment of postmasters.
Post Office raises this not to excuse but to explain
the context in which those failures occurred. The
combined testimony of the witnesses heard and the
hundreds of thousands of documents disclosed by Post
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for those that gave evidence but for those that
currently work at Post Office or used to, and who are
all equally appalled by Post Office's failures.
No one who has read and listened to the evidence
during this Inquiry could come to any conclusion other
than that the Horizon IT scandal is the most widespread
miscarriage of justice in British legal history, and
that its roots lay in fundamental structural and
governance failings.
As the Inquiry will have seen from the evidence read
and heard in Phase 7, Post Office today is a different
organisation from the one that was in place during the
failures of the past but it still has a long way to go
to reset its relationship with postmasters and the
public. Post Office is not perfect, and does not
pretend to be, but it is firmly committed to continuing
to learn lessons from this Inquiry. It will be
considering the proposals for improvements made by other
Core Participants in their closing statements as part of
its ongoing work.
The new leadership at Post Office brings a fresh
perspective and they are committed to making the changes
that are necessary to restore confidence in the business
and to ensure that nothing like this will or could ever
happen again.
Office to the Inquiry has, Post Office hopes, given the
Inquiry detailed insight into the workings of every
relevant aspect of Post Office's business over the last
30 years.
In the early phases, the Inquiry heard from
witnesses who joined the Post Office in the '60s and
‘70s, several coming to occupy the most senior positions
some 20 or 30 years later. A picture emerged of
a company in the late 20th century and the early part of
this century, which certainly at a senior level had
little experience and understanding of the IT revolution
which had already taken place in many other companies,
and which it was inevitable that Post Office had to
join.
Itis a source of deep regret to Post Office that
the reliance on Fujitsu and the belief of the
reliability of Horizon, which emerged in those early
days, was allowed to take root within Post Office in the
decades that followed.
Post Office has referred in its written closings in
earlier phases to a mindset that took hold in Post
Office, to the effect that: Horizon had no bugs, errors
or defects; such problems as did arise in Horizon were
due to user error or dishonesty; a strong resistance to
countenancing the existence of any flaws in Horizon;
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The Post Office Horizon IT Inquiry
a mindset that saw it as an advantage not to keep
postmasters informed about systems issues that were
identified; a mindset that positively discouraged more
widespread dissemination of information; a mindset that
focused on protecting the Post Office brand and the
commercial interests of the company.
This mindset was compounded by an organisational
hierarchy, which meant that junior employees did not
feel able to escalate issues upwards. This in turn
resulted in insufficient overview being taken at senior
level. Important senior roles were occupied by
individuals who regrettably lacked sufficient
understanding of the obligations and responsibilities
attaching to those roles. They either did not have
sufficient personal experience of Horizon technology, or
were not sufficiently senior within the overall
organisation to carry out those roles effectively.
Similar themes again emerged during the evidence
heard during Phases 5 and 6. Post Office has accepted
in its written submissions for those phases that there
was a series of governance failings in the organisation.
Key information about Horizon and prosecutions based on
Horizon was not shared effectively, either horizontally
or vertically, within the Post Office, and there was no
clear structure to ensure that relevant knowledge was
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a deliberate attempt to prevent the advice being
considered by the Board.
Consistent with the prevailing mindset that has been
revealed in the evidence in Phases 3 and 4, Post
Office's response to the Second Sight Interim Report
showed multiple failings on the part of the Executive.
They adopted a defensive attitude from the start to
Second Sight's negative findings and, consistent with
an assumption of postmaster fault, refused to entertain
the possibility that Horizon or Post Office's treatment
of postmasters, including inadequate training and
support, were to blame.
The evidence also shows that the Board failed
properly to scrutinise either the Second Sight Interim
Report or Susan Crichton's update paper for the July
2013 Board meeting. Given the concerns raised about the
existence of bugs, about Post Office's investigation
function and about the treatment of postmasters, the
Board's failure to challenge the Executive was
a significant one, particularly given the concerns
raised by the Board about claims for wrongful
prosecution leading to a notification to insurers.
As I said at the outset, I do not intend to rehearse
or seek to summarise the points that have been made in
the written closing statements of Post Office for all
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consistently and appropriately communicated throughout
the organisation.
As Post Office has acknowledged in its written
closing statement for Phases 5 and 6, the apparent lack
of knowledge or understanding on the part of senior
executives and Board members that Post Office conducted
its own prosecutions against postmasters was
particularly striking. When Post Office separated from
Royal Mail Group in 2012, there was a failure to ensure
that incoming Board members and senior executives were
briefed either on the fact that Post Office was
a prosecutor or on the central importance of Horizon
data to those prosecutions. There was a lack of clear
lines of accountability for reporting on prosecutions to
the Board, which created the structural conditions for
inadequate Board oversight of prosecutions.
This, in turn, severely reduced the Board's
effectiveness in holding the Executive to account.
Similarly, there was a failure to share the first Clarke
Advice or its substance with the Post Office Board.
This appears to have arisen from a collective failure on
the part of the then Post Office Legal team to
appreciate its full significance and inadequate
processes being in place for sharing the substance of
key legal advice with the Board, rather than
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phases. Post Office focuses the remainder of this oral
statement on aspects of the work that it has done since
the judgments of Mr Justice Fraser in the Common Issues
and Horizon Issues trials to bring about organisational
and cultural change to address the failures identified
and to ensure that the wrongs of the past will not be
repeated.
Since 2019 Post Office has taken steps to shift its
focus to postmasters. Post Office accepts that the pace
of change in the organisation has been too slow. Post
Office acknowledges that it has a lot of work to do in
order to address its shortcomings and rebuild the trust
of postmasters that has been so severely damaged by its
failures and that it is actions rather than words that
count.
Post Office has implemented a number of changes
since 2019 to start re-orientating the business towards
the interests of postmasters, which I will deal with
under the following headings: (1) listening to the views
of postmasters; (2) changes to its discrepancy processes
and the support it provides to postmasters: (3) Horizon
improvements; (4) cultural changes; (5) governance
changes; and (6) post Office's plans for the future.
First, Post Office acknowledges that it failed to
listen to and act on the concerns of postmasters about
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The Post Office Horizon IT Inquiry
the Horizon system. Since the events which are the
subject of this Inquiry, it has taken steps to bring the
views of postmasters into the centre of the business.
Since June 2021 Postmaster NEDs have sat on the Post
Office Board, which has enabled the views of postmasters
to be heard on matters of strategic and key operational
importance.
Following the recent point of two new Postmaster
NEDs, continuity will be ensured by one current
Postmaster NED remaining in post until June 2025.
In addition to the Postmaster NEDs, in 2021, Post
Office appointed a Postmaster Experience Director, who
spends two days a week in Post Office Head Office
liaising with the executive teams to inform them about
the operational experiences and concerns of postmasters.
Furthermore, Post Office has plans to expand the
mechanisms for enabling the views of postmasters to be
heard and taken into account in the business. First,
the Post Office panel will work with Post Office to
ensure that the postmaster voice is heard at
an operational level by considering and challenging key
policies and processes, and communicating the work of
the panel to postmasters in order to build confidence.
Secondly, the consultative council will enable Post
Office to consult with postmasters on the future plans
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information, including manuals and training materials,
to help and support postmasters and their staff on
a day-to-day basis and which postmasters can also use to
report IT issues. Any defects or issues relating to
Horizon are set out in Knowledge Articles, which are
published on Branch Hub within 48 hours of being
identified. These articles serve an important role in
ensuring postmasters are kept up to date and have the
information they need should a discrepancy arise.
Post Office intends that these processes will be
kept under review by the postmaster panel with the aim
of ongoing improvement.
The Inquiry will bear in mind that Post Office no
longer exercises a prosecutorial function. It does not
now and has no intention in the future of conducting its
own criminal investigations or prosecutions. Post
Office will support law enforcement agencies in their
investigations, as it plainly should.
Third, the Inquiry has heard detailed evidence from
Simon Oldnall, Branch Technology Director at Post
Office, and Tracy Marshall, in written and oral
evidence, that Post Office has worked hard through the
Horizon Improvements Programme to remediate bugs, errors
and defects, including those identified by Mr Justice
Fraser. It has put in place a programme to identify and
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for Post Office that arise from the implementation of
the Strategic Review, so as to make sure that the views
of postmasters are taken into account and considered in
the changes that are proposed.
Second, Post Office has changed fundamentally the
way it investigates discrepancies shown on the Horizon
system and the support it provides to postmasters. The
Inquiry has read and heard detailed evidence from Tracy
Marshall, Retail Engagement Director, and Melanie Park,
Central Operations Director. The burden of proof is now
‘on Post Office to establish that a discrepancy is
a genuine loss to Post Office and the fault of the
postmaster or their assistant.
This is a crucial step in addressing the imbalance
of power that previously existed in Post Office's
policies, procedures and practices. In cases where the
postmaster does not agree with the Post Office's
position, there is a "Dispute" button on Horizon that
a postmaster can press to raise a discrepancy or dispute
a transaction correction that has been issued. There is
a three-tier Dispute Resolution Procedure, and the
option of a referral to a Dispute Resolution Review
Committee.
Post Office provides improved support to postmasters
through Branch Hub, a digital platform which provides
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fix any new bugs, errors and defects in Horizon, and
carried out significant work to establish an ongoing
programme of improvements to a wide range of procedures
across many parts of Post Office's operations, including
training and business support.
The Inquiry has also received detailed written
evidence from Mr Oldnall about the way in which Post
Office now better monitors Fujitsu's compliance with
Fujitsu's own contractual obligations to provide
a secure and reliable Horizon system.
The Inquiry is aware that Post Office continues to
be in ongoing discussions with Fujitsu about
an extension to the Horizon contract.
Fourth, the Inquiry has heard that, from the end of
2019, Post Office has introduced initiatives intended to
bring about cultural changes across the organisation.
Post Office has recognised the need for fundamental
cultural change. As Nick Read said in his first
statement to this Inquiry, Post Office recognises the
presence of oppressive behaviour and intimidating
actions in the past, which led to a lack of respect and
trust between Post Office and its postmasters. It
acknowledges that there has been a lack of effective
leadership, a lack of effective training and support and
a lack of responsibility within the organisation. It
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accepts that it has work to do to restore trust with
postmasters and with the public as a whole. Cultural
changes in the Post Office are integral to the
rebuilding of that trust.
To remind the Inquiry, those initiatives to reset
the Post Office's culture include the following: the
introduction of new training modules, including
substantial induction training which educates new
employees about the Horizon IT scandal and mandatory
Horizon scandal training and GLO awareness.
In June and July 2024, the Post Office launched
a Behaviours Framework that applies to all those working
in Post Office, which is intended to act as a guide and
to instil behaviours that are seen as key to preventing
a repeat of the wrongs of the past.
New complaints channels have been implemented via
the postmaster survey, college engagement survey, and
strategic partner survey.
These changes are not just aspirational. The new
Behaviours Framework is embedded into the recruitment
process and used to measure the performance of everyone
at Post Office. The Board takes ultimate responsibility
for ensuring that cultural change takes place but every
person working at Post Office has their part to play.
Cultural change, of course, takes time. However,
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improvements in succession planning and a cultural shift
towards accountability and long-term planning.
To address the need for a unifying purpose in group
strategy, which Grant Thornton considers lies at the
heart of governance dysfunction in the Post Office, Post
Office has commissioned a Strategic Review. Post Office
has taken action to address governance issues identified
by Grant Thornton, where it has been able to, pending
the outcome of the Strategic Review. It has taken steps
to improve the composition and competency of the Board,
the Interim General Counsel is now a standing attendee
at Board meetings.
Action has also been taken to improve the quality of
information on which the Board reaches decisions, and
measures have been introduced to avoid the Board being
overburdened with issues that ought to be dealt with at
Executive level.
The Group Executive, now called the Senior Executive
Group, has been restructured so as to focus discussions
better and improve the speed of decision making.
A wholesale review of Executive Committees is under way.
Post Office notes the proposals put forward by
others for alternative governance structures, including
an oversight committee as proposed by the NFSP. It also
notes the view of the governance experts that
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recognising that changes has not happened quickly
enough, Post Office has put in place plans, including
a Strategic People Plan, which are intended to embed
cultural change from the foundation of the organisation
upwards, focusing on building better relationships with
postmasters, with a real emphasis on restoring trust.
Akey objective of Post Office's recent Strategic
Review, which I shall come on to talk about shortly, is
the commencement of a new relationship between Post
Office and postmasters, in which there will be
a significant increase in postmaster remuneration,
improved support and the strengthening of the postmaster
voice. Post Office sees this proposal as underpinning
the drive towards a reset of the culture in its
business.
Fifth, Post Office has acknowledged in the course of
written closing statements made in respect of earlier
phases, including 5 and 6, that there were serious
governance failings in the organisation which played
a substantial part in the injustices that occurred.
Post Office commissioned Grant Thornton to review its
corporate and operational governance in 2023. Post
Office accepted Grant Thornton's conclusions that it
requires a unifying strategy, greater role clarity,
streamlined decision-making processes, significant
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responsibility and accountability should rest with the
Board. Post Office considers that, at least to some
extent, the NFSP's proposals for an oversight committee
will be addressed by the proposal for a Postmaster
Consultative Council, which will work together with Post
Office on the implementation of proposals arising from
the Strategic Review.
Six, through the Strategic Review, the new team at
Post Office has put forward a proposal to Government for
the future of the Post Office, which will enable it
better to serve the interests of postmasters and thereby
the public that they serve. Post Office has been
pressing for a review of Government's policy as sole
shareholder in respect of Post Office for some years.
Post Office has been loss-making since its
separation from RMG in 2012 and, in the face of
significant commercial and structural challenges, those
losses are expected to worsen in the future.
The Government has nonetheless long held the view
that Post Office should be financially self-sustaining
and not rely on government subsidy. Post Office is
looking forward to receiving greater clarity from
ministers as to how that could or should be achieved and
the policy objectives that would underpin it.
Post Office considers that the changes that it seeks
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to make as part of implementing its Strategic Review
will be far reaching and to the benefit of postmasters
first and foremost but also to the long-term future of
Post Office as a whole, and the communities that are
served by Post Office.
The review carried out between June and September
2024 drew on Post Office members of staff, Board
members, postmasters and other stakeholders and experts.
Nigel Railton, Interim Chair of Post Office, stated in
his speech on 13 November 2024:
"Fundamental to the implementation of the Strategic
Review is Post Office's plan to deliver a new deal for
postmasters. This will significantly increase the total
annual income of postmasters through a vastly improved
share of revenues and strengthen their role in the
direction of the organisation. The implementation of
the Strategic Review will be informed by strong
postmaster engagement through the establishment of a new
consultative council and a postmaster panel. The
Strategic Review is also aimed at refocusing the Post
Office's operations, so that there is a streamlined
central organisation which serves the interests of
postmasters so that they may serve their communities via
sustainable businesses."
Nigel Railton, the Interim Chair, explained in his
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technological changes, whilst waiting for funding
decisions. Ultimately, it is in the Government's hands
as to whether it agrees with the proposed strategy, and
whether that strategy will be funded.
Post Office considers that its plan to transform the
Post Office offers the best opportunity for the
organisation to flourish and benefit those whom it
serves, namely postmasters and the public.
Post Office recognises that, until all postmasters
receive full and fair redress, there is no prospect of
them achieving closure in respect of these terrible
events. Post Office remains fully committed to playing
its part in ensuring that postmasters receive full and
fair redress as quickly as possible.
It has been the long held view of Post Office that
the compensation scheme should be run independently of
Post Office because the perpetrator of injustice should
not administer the assessment of redress.
It is also Post Office's view that legal advice
should be offered when the 75,000 fixed sum is offered
to postmasters. Simon Recaldin has informed DBT of his
view that there should be consideration of extending the
schemes to family members, and Post Office welcomes
DBT's consideration of this.
Post Office notes that DBT is providing an update on
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evidence to the Inquiry that, as a result of the
Strategic Review and subject to DBT approval, Post
Office proposes to reset the NBIT programme, to improve
confidence in its delivery and to ensure that it
provides what postmasters need. Post Office intends to
work closely with postmasters to define the new
programme.
Post Office acknowledges that work needs to be done
to ensure that its proposal remains aligned with the
work being carried out by DBT, with Grant Thornton,
Boston Consulting Group and the Government Internal
Audit Agency. Post Office welcomes continued
involvement in DBT's reviews. The Inquiry has also
heard that the Government is planning a Green Paper on
the future of Post Office, which will be published in
2025.
Post Office is now at a critical juncture. The
organisation has a new and experienced Interim Chair and
Interim Acting CEO, a relatively new Board, and a SEG
team who are skilled in delivering transformation change
of this nature and are committed to implementing the
plans so critical to the Post Office's future, as set
out in the Strategic Review.
Post Office is already doing what it can to push
forward its plan for transformation with structural and
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financial redress in its written submissions. Post
Office regularly updates the HSS and the OCS web pages
with the current figures. Post Office would be happen
to provide further written updates to the Inquiry as to
the progress of the redress schemes, if that would
assist the Inquiry.
Furthermore, if the Inquiry would be assisted by
receiving written updates or further information from
Post Office on other matters, then Post Office will of
course provide such information as may be requested.
Post Office would like to extend its thanks to
postmasters who have given evidence or engaged with this
Inquiry as Core Participants or by responding to the
YouGov survey.
Post Office wishes to thank the Chair,
Ms Eliasson-Norris, Mr Page and the Inquiry Counsel and
solicitor teams for their thorough investigation and
examination of the evidence. Post Office will reflect
carefully on the findings in the forthcoming Inquiry
report and will take the Inquiry's recommendations
extremely seriously.
Post Office must end this closing statement as it
began: with an apology. Post Office repeats its
sincerest apology to all who have been affected by its
actions and reiterates its determination to continue
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with the process of learning the lessons from this
Inquiry.
Post Office remains firmly committed to ensuring
that nothing like this could ever happen again but
acknowledges that it will rightly be judged in the
months and years to come by what it does, not by what it
says it is going to do.
SIR WYN WILLIAMS: = Thank you, Ms Greaney.
Ms Leek, it's a matter for you. If you're going to
take -- well, I'm addressing Ms Leek now.
If you're going to take a full hour, or thereabouts,
then I think we'll probably take a break now, rather
than ask you to break somewhere in the middle. I guess
you'd prefer that, yes?
MS LEEK: I would, sir.
‘SIR WYN WILLIAMS: Right so we'll take a break now.
MS LEEK: Thank you.
SIR WYN WILLIAMS: What's the time now?
So we'll break until 10.15 and then we'll hear from
Ms Leek.
(10.00 am)
(A short break)
(10.15 am)
SIR WYN WILLIAMS: All right, I think we're about to start
again. I'm glad there's some self-discipline going on
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witnesses will now seek to distance themselves from
Ms Vennells.
Just two examples, if I may. First, Jo Swinson said
in her oral evidence that Ms Vennells knew about the
Clarke Advice. When I asked her questions about this,
Ms Swinson conceded that this assertion was based on
a single email, which she had not seen at the time.
That email does not withstand the weight which
Ms Swinson now seeks to load upon it. She did not have
any personal knowledge on the issue but clearly, and in
retrospect, wanted to assume the worst of Ms Vennells
and sought to point the finger at her.
In his oral evidence, Alan Cook, the Managing
Director of Post Office between March 2006 and early
2010, stated that Ms Vennells probably authorised in
2006 substantial legal costs for Post Office's claim
against Mr Castleton. This could not be correct. In
fact, Ms Vennells did not join Post Office until January
2007.
Sir, I now turn to the chronology of Ms Vennelis'
involvement, which cannot, for obvious reasons, be
a complete chronology. Even in 140 pages of written
submissions, we could not set out a complete chronology
with a reference to every relevant document.
Ms Vennells was CEO of a newly separated, highly
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by people in the audience telling other people to be
quiet because they won't listen to me!
Right, Ms Leek. Over to you, Ms Leek.
Closing submissions by MS LEEK
MS LEEK: Thank you, sir. Sir, in our written submissions
we have sought to analyse carefully and forensically the
chronology of what Ms Vennells did and did not know
about various key matters and what she did and did not
do with that knowledge. That document has now been
published by the Inquiry. We submit that it is only by
looking forensically at all of the documentation that
a fair picture of Ms Vennells' actions can be seen.
In the time we have allotted to us today, I shall
highlight a number of points from our written
submissions which go to information provided to
Ms Vennells which was incomplete or incorrect, or which
she was not given at all.
In our written paper, we have made submissions of
general application on several topics. I do not propose
to repeat them here save to make one point: when
witnesses have given recent evidence of matters relevant
to Ms Vennells, without there being supporting
contemporaneous documents, this evidence should be
approached cautiously. It is inevitable, having regard
to the very human desire for self-preservation, that
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complex business with more than 11,000 branches. Her
role as CEO and, before that, as Network Director,
stretched far more broadly than Horizon, to financial
management, stakeholder engagement, strategic planning
and decision making, regulatory matters and the
financial success of the company.
Sir, I do not raise that to downplay in any way the
importance of Horizon, simply to highlight the huge
demand of competing priorities on the CEO of a business
of this size and nature.
Sir, I now turn to bugs, errors, defects and remote
access before Ms Vennells became CEO.
Paragraph 88 of Mr Stein's submission suggest, and
I quote:
"It is simply not credible for Ms Vennells to have
uncritically adopted the mantra that she put forward in
a letter to Lord Arbuthnot on 9 January 2012. She said:
“There has been no evidence to support any of the
allegations and we have no reason to doubt the integrity
of the system, which we remain confident is robust and
fit for purpose’."
He relies on this assertion to suggest that the
organisation was corrupt from the top. Sir, itis easy
to make assertions such as this with hindsight, knowing
what we know now about what has been found regarding
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bugs, errors and defects but, from a close analysis of
the contemporaneous documentation, it can be seen
exactly why it was reasonable for Ms Vennells to make
this statement, and it was not out of a corrupt motive.
So far as Ms Vennells was aware, she had a competent
Head of IT and a competent General Counsel on whom she
believed she was entitled to rely.
Taking over the helm of Post Office at the time of
separation from RMG, as we have heard, was a gargantuan
task. It was simply not possible to delve personally
into each matter raised nor realistic that she would
have the expertise in all disciplines to do so. Why
should she not have been entitled to trust Ms Crichton,
Mr Young and Ms Sewell to give her the unvarnished
position?
Ms Vennells had no background in IT and was never
employed by Post Office in an IT role. Post Office had
an IT Department, which included IT technical
specialists and Senior Managers, for example Mr Young
and later Ms Sewell, whose role was to keep the Board
and the Executive Team informed of important matters.
Ms Vennells relied, and submits that she was
entitled to rely, on Post Office's IT function to
provide accurate information to her, to the Board and to
the Executive Team in relation to matters of Horizon
25
was reliable. He approved the approach and wording of
a draft letter sent in Ms Vennells' name to Mike Weir MP.
in November 2011 which described Horizon as "rigorously
tested", and said that there was no evidence at all that
Horizon has in some way been at fault.
Mr Young's evidence is that he first became aware
about the integrity of Horizon becoming an issue when he
was contacted by Computer Weekly shortly before the
publication of its article in May 2009. He told
Computer Weekly this:
"Horizon is an extremely robust system which
operates over our entire Post Office Network and
successfully records millions of transactions every day.
There is no evidence that points to any fault with the
technology. We would always look into and investigate
any issues raised by subpostmasters."
It was around the same time that Ms Vennells first
became aware of concerns by way of the Network
Functional Report for April 2009. That report recorded
this unambiguous statement:
"Legal advice is that we have no reason to doubt the
system's integrity and this has been tested in the
courts."
Ms Vennells was given assurances from experts that
there was nothing wrong with the system. The clear
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integrity.
Sir, until March 2012 when he left Post Office, Mike
Young was the most Senior Manager with responsibility
for IT in the business. He reported directly to the
Managing Director, first Alan Cook, then to Dave Smith
and then to Ms Vennells. Mr Young confirmed in his
evidence that it was his responsibility to ensure that
IT related issues were resolved, and to ensure that the
Board was notified of IT issues which required its input
or oversight.
Mr Young said that he was only ever aware of two
bugs, errors or defects, otherwise known as BEDs, in
Legacy Horizon: blue screen and ISDN errors.
The only BEDs he was aware of in relation to HNG-X
were BEDs which affected the Oracle database during the
test and the pilot rollout. He said he had no knowledge
of any BEDs that would have caused transaction or
reconciliation errors in branch accounts and the only
occasion mentioned in his witness statement or indeed
seen in the documentation on which he escalated concerns
about Horizon integrity to the Board or the Executive
Team, was when he alerted Mr Cook and the Executive Team
about the Computer Weekly article in May 2009.
Mr Young repeatedly made and supported comments to
Ms Vennells and the Board which asserted that Horizon
26
message being given by both Legal and IT was that there
was nothing to worry about.
Sir, the receipts and payments mismatch bug in HNG-X
was discovered in September 2010. It was discovered to
have affected up to 62 branches, with two branches being
impacted twice.
Fujitsu prepared a paper dated 29 September 2010 for
a meeting with POL to discuss the bug. They noted that
the bug was impacting around 40 branches. Mr Young
accepted that he was informed of the bug in February
2011, several months after its discovery. Ms Sewell was
aware of the bug by 4 March 2011. Ms Vennells was not
made aware of the bug until May 2013. The Inquiry has
heard no evidence to the contrary.
Mr Young and Ms Sewell both accepted that they did
not escalate their knowledge of the bug to Ms Vennells
when they first became aware of it. The evidence is
clear that Mr Young did not escalate his knowledge of
the bug before he left POL in 2012 and that Ms Sewell
did not escalate her knowledge at any point prior to May
2013.
Sir, coming to remote access between 2007 and 2011.
The evidence before the Inquiry establishes that,
between 2008 and 2010, a number of POL managers,
including Andrew Winn, Rod Ismay and Angela van den
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Bogerd, then a Senior Network Manager, were made aware
that Fujitsu had the power or a potential power to
change branch accounts remotely, without the authority
or knowledge of the affected subpostmasters. This
information was not passed on to the Board or to
Ms Vennells.
On the contrary, the message given internally to
POL's Executive Team was that it was not possible to
make changes to branch accounts without the knowledge or
consent of the relevant subpostmaster.
Ms van den Bogerd and Mr Ismay knew, at the latest
in early 2011, that Fujitsu could, in certain
circumstances, alter branch data remotely without
subpostmasters' knowledge. They were two of
a substantial number of POL managers who had been made
aware of this by 5 January 2011. There is no evidence
that any of these managers escalated their knowledge to
the Board or the Executive Team.
Itis clear from the oral evidence of two of the
most Senior Managers involved, Mr Ismay and Ms van den
Bogerd, that they did nothing to escalate their
knowledge. Ms Vennells still does not understand why
they would not have done so. The knowledge with which
Mr Ismay is fixed runs directly contrary to what he had
written in the Ismay Report, as to there being no
29
briefing. Sir, this very issue was considered at the
Post Office Board meeting on 29 May 2011 at which the
Board discussed the steps being taken to implement EY's
recommendations.
What Ms Vennells did not know, though, was the
significance of the finding which EY had made. She did
not know this because she was not told that the
existence of the APPSUP role created this risk to the
integrity of the accounting data held in the system.
Ms Vennells gave oral evidence that it is unlikely that
she would have understood at the time, without advice
from an IT expert, that EY's comments about the APPSUP
role showed that Fujitsu could make changes to branch
accounts without the authorisation of subpostmasters.
Sir, the Inquiry can be confident that Ms Vennells
is right that she was not told that the APPSUP role
could potentially be used to make unauthorised changes
to branch accounts: first, there is no evidence that she
was told; and, second, the reason why she was not told
is obvious from Mr Young's evidence. He knew that, as
with most IT systems, it was possible to gain access to
the system remotely, and that Fujitsu could make changes
to branch accounts with subpostmasters' consent.
However, he, Head of IT, had in his words:
"... no belief, understanding or even inkling that
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backdoors in Horizon. He did not return to his report
and seek to correct anything. When asked why this was
the case, he offered no explanation for his failure to
do so, other than he could not recall receiving the
message as to remote access being possible.
Turning to the 2010/2011 Ernst & Young audit. The
EY audit of the control environment at Fujitsu for the
financial year ended 27 March 2011 included the
reporting of weaknesses in the IT Governance and Control
Framework, particularly in relation to Fujitsu and
Horizon, and made recommendations for improvements.
EY's detailed observations included, on page 33 of the
manager letter, that:
"There are inappropriate system privileges assigned
to the APPSUP role."
The risk associated with that is weakness was,
I quote:
"Unrestricted access to privileged IT functions
increases the risk of inappropriate/unauthorised access
which may lead to the processing of unauthorised or
erroneous transactions.”
Ms Vennells was briefed on this audit report by
means of a document which appears to have been prepared
by Fujitsu in April 2011, with input from Ms Sewell.
Ms Vennells has no reason to think she did not see this
30
Fujitsu made changes to branch accounts without the
authorisation of subpostmasters."
Ms Vennells was not told that there was a risk that
Fujitsu could use it's APPSUP privileges to tamper with
branch data because Mr Young did not himself appreciate
that this was a real risk.
In the meantime, in a report to the Royal Mail Group
ARC in September 2011 Chris Day, the CFO, together with
Lesley Sewell and Rod Ismay, stated, and I quote:
“As a result of the process and controls in place,
POL is fully confident in the Horizon computer system
‘operating in its branches. This accounting system and
the processes around it enable our branches to maintain
accurate and reliable accounts."
The text of this report, sir, was run past Mr Young
and Ms Crichton for comment. The report also stated,
with regard to prosecutions, that:
"POL remains satisfied that this money was missing
due to theft in the branch. Due to the controls set out
above, POL does not believe the account balances against
which the audits were conducted were corrupt."
This is the very same message that Ms Vennells was
receiving from Finance, from IT, and from Legal.
Sir, moving on chronologically to the instigation of
the Second Sight review. We see other clear examples of
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Ms Vennells receiving incomplete or incorrect
information from trusted colleagues in the information
and briefing documents she received from meetings with
MPs on 17 May and 18 June 2012. Ms Vennells'
straightforward submission in this regard is that she
was entitled to rely on an unequivocal statement to the
Board by the General Counsel for its factual accuracy.
Ms Crichton had said at the Board meeting in January
2012:
"The business has also won every criminal
prosecution in which it has used evidence based on the
Horizon system's integrity.”
Ms Vennells had no reason to question this. This
information was then transposed directly into what
Ms Vennells said to James Arbuthnot on 18 June 2012:
"Every case taken to prosecution has found in favour
of the Post Office.”
Ms Vennells now knows and accepts that that was
false. She still does not understand why Ms Crichton
failed to give her accurate information, but would not
have considered that she needed to verify what she was
being told by her General Counsel.
As for the conduct of the Second Sight review,
between mid-2012 and July 2013, Second Sight and POL.
investigated the cases referred to Second Sight by MPs
33
with the Horizon IT system. The information she
received during the review was that neither Second Sight
nor Post Office had identified any system-wide problems
with the IT system, being briefed in those terms in
an email from Ms Crichton on 19 March 2013, and for the
call with Lord Arbuthnot on 23 May 2013, the key message
in that briefing being:
"We are concerned that the investigation is
overrunning, that the findings will not be definitive
and there will be no satisfactory outcome to the Horizon
question."
The message at 2.6 was:
"The investigation has been running for a year and,
to date, no evidence of systemic failures has been
found.”
At 5.3:
"Post Office is not saying Horizon is free from
defects. Systems of this nature occasionally encounter
problems. We are confident, though, that no
subpostmaster has been wrongly convicted or suspended
due to Horizon defects."
In addition, she was briefed for the Board call on
1 July 2013 as follows:
"Notes for Board update on Second Sight
Investigation."
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and the JFSA. Ms Vennells was not involved in the
investigation. It required subject matter expertise.
Post Office established a working group to consider the
evidence presented by Second Sight and to formulate
POL's response. Its membership drew together knowledge
and expertise in IT, accounting, security and network
operations.
In addition, a group of managers, including
Mr Baker, an IT specialist, and Ms van den Bogerd,
a Senior Network Manager, were tasked with liaising
directly with Second Sight. Ms Vennells did not attend
meetings of the working group. She had no role in
directing or deciding what information Post Office would
provide to Second Sight and she was not involved in or
consulted about Post Office's substantive responses to
the cases.
These were operational matters which required the
specialist know-how of the teams dealing with Second
Sight. The evidence shows that Ms Vennells received
oral and written updates, mainly from Ms Lyons and
Ms Crichton, to report on the progress of the review,
and to prepare her for meetings with stakeholders.
Sir, one matter on which Ms Vennells did need
visibility was whether Second Sight or the Post Office
teams engaged in the project had identified problems
34
She was told:
"Second Sight due to present initial findings at
a meeting with James Arbuthnot, MPs and JFSA next
Monday. Report will focus on four best cases in detail,
following an initial review of nearly 50 cases overall.
Key point to emphasise is that we understand Second
Sight have not identified any systemic issues with
Horizon itself. However, the report still presents
significant reputational risks for Post Office. SS
nervous about perceptions of a whitewash, and so may
draw attention to two points ..."
The two points being:
"... (a) issues with Post Office's wider support,
and (b) the fact that we have disclosed two previous
anomalies with the Horizon system, which they may
suggest means we cannot be confident that there are not
more widespread problems with the system."
Sir, this is what Ms Vennells is told specifically
about this point. This is a red herring, she is told:
"In both cases the errors were picked up and have
either been or are in the process of being addressed
with the affected subpostmasters. A comprehensive audit
has been performed to check that there weren't further
cases we weren't aware of and new procedures are being
put in place to ensure such anomalies are spotted at
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an early stage in the future."
What was she to take from this? It was a red
herring. The bugs had been dealt with. There's been
an audit to check whether there were other cases POL
wasn't aware of. Sir, she is also then told:
"We also have other concerns around Second Sight's
handling of the investigation. They haven't yet
reviewed all the evidence we have given them and, hence,
may not be in a position to set out definitive
conclusions on all four cases."
She is also told:
"It appears that they are not focusing on empirical
evidence in the way we would expect forensic accountants
to."
Sir, on the back of that last briefing note,
Ms Vennells briefed the Board on 1 July 2013.
Ms Vennells shared with the Board no more and no less
than she herself knew about the likely contents of the
Second Sight Interim Report as of 1 July 2013. It was
correct, based on what Ms Vennells had been told, that
the investigation to date had found no systemic issues.
Ms Vennells, in briefing the Board, noted:
"Horizon, like any large computer system, would
occasionally have anomalies and two were known of over
recent years."
37
full, professional opinion on that issue. A reasonable
reader of the Interim Report as a whole would not have
understood that the conclusion in 8.2(a) was based
solely on the four spot reviews, as opposed to the
totality of the investigatory work carried out by Second
Sight, which they described in section 2 of the Interim
Report.
Further, the written briefing prepared for
Ms Vennells stated that Post Office understood that
Second Sight had not identified any systemic issues in
the four spot reviews to be attached to the Second Sight
Interim Report, nor in the other six spot reviews sent
to Post Office, nor otherwise during its investigation.
In short, Ms Vennells was told, both by Second Sight
and POL's internal team of specialists, that no systemic
issues had been found during the investigation.
Ms Vennells submits that she was entitled to rely on
what she was told.
Sir, turning to Ms Vennells' understanding of the
bugs that she was made aware of in 2013. Ms Vennells
was not an IT specialist and, as I've said, she relied
on POL's IT specialists for information about the bugs
and their implications for the reliability of the
system.
Two IT specialists reported to Ms Vennells at the
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Ms Vennells described these anomalies, which she now
recognises should have been called "bugs", at the same
time as stating that there were no systemic issues.
That understanding of the belief of her colleagues and
the findings of Second Sight was based directly on
information she had been given by the Working Group.
Two days later, a briefing note on the Second Sight
Interim Report was sent to Ms Vennells by Chief of Staff
Martin Edwards, with input from Susan Crichton, Alwen
Lyons and others. Ms Perkins was copied in. This was
produced before Second Sight had begun to circulate
drafts of the Second Sight Interim Report and was
therefore based on the work that Post Office had carried
out during the review, and what they had been told by
Second Sight.
This repeated that Post Office believed that Second
Sight had not found evidence of systemic problems within
the Horizon IT system. The Interim Report at
paragraph 8.2(a) clearly stated:
"We have found no evidence of system-wide systemic
problems with the Horizon software."
Second Sight were not required to include this
conclusion in their Interim Report, they chose to
include it and a person reading the Interim Report was.
entitled to assume that it represented Second Sight's
38
relevant time: Ms Sewell and Mr Baker. Ms Vennells said
that she relied on and was reassured by what she was
told about the bugs. She submits that she relied on the
Post Office IT Team through Mr Baker and Ms Sewell, in
four main respects: first, to obtain and inform her of
facts in relation to the bugs; second, to provide their
opinion on the significance of the bugs to the
reliability of the Horizon IT system; third, to inform
her of any other bugs or defects which they were aware
had impacted permits; and, fourth, to inform her if, in
their opinion, Post Office should carry out
investigations into whether there were or could be other
problems.
As to these four issues, Ms Vennells was told that
the bugs had been detected by Post Office Limited
processes, that the underlying technical problems had
been diagnosed and fixed, that Post Office had been
transparent with the affected subpostmasters and that no
subpostmaster had been left out of pocket.
Ms Vennells was told that the bugs were normal
‘occurrences in a system the size of Horizon and did not
indicate other or wider problems. What was important
was how Post Office had dealt with the bugs.
The 3 July 2013 briefing note to Ms Vennells on the
interim report gave the impression that the two bugs in
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HNG-X and the Falkirk bug were the only bugs which
impacted subpostmaster accounts of which Post Office was
aware. It dealt with the two bugs in Horizon Online and
introduced the Falkirk bug by stating:
"We are also aware of a further anomaly in Horizon.
Post Office IT did not recommend a further investigation
of possible defects in the system.”
Similarly unambiguous information was given to
Ms Vennells by Ms Sewell in July 2013 in respect of
Michael Rudkin's assertion that he had met an individual
in the basement at Fujitsu who demonstrated an ability
to pass transactions directly into the Horizon system
and, in doing so, alter in realtime or overnight, the
recording holdings of foreign currency in Post Office
branch offices.
Ms Sewell said this to Ms Vennells, in an email on
7 July:
"Rudkin. We and Fujitsu have provided evidence to
Second Sight that there was only testing systems in the
basement in 2008. The equipment (hardware) and the
testing system were located in the basement. This has
been a constant challenge with Second Sight, as they
contest that Rudkin has signed an affidavit and
therefore there is a conflict of evidence. There
appears to be a lack of willingness to accept the detail
41
as prosecutors and explains how internal and external
lawyers would apply the same checks and balances as
would be applied by the CPS. On 3 July 2013,
Ms Crichton sent an email to Mr Edwards and
Mr Flemington, discussing what would go into a speaking
note for Ms Vennells and Ms Perkins to use at a meeting
with Lord Arbuthnot. Ms Crichton wrote in the email:
"Nothing has emerged from the interim findings given
to us by Second Sight which would point to specific
convictions being unsafe. Cases have been through the
judicial process and the court considers all relevant
evidence, not just that relating to the Horizon computer
system.
That was 3 July 2013. Sir, these words made their
way verbatim into the speaking note. Again, this is
characteristic of the clear messaging that Ms Vennells
had been receiving, and continued to receive, from her
General Counsel and upon which she was entitled to rely.
Turning to the Clarke Advice and the prosecution
case review. Simon Clarke sent his expert evidence
advice to Post Office on 17 July 2013, the day after the
16 July Board meeting. Its circulation appears to have
been limited to Ms Crichton, Mr Williams, Mr Flemington,
and Mr Parsons of Bond Dickinson. Ms Crichton confirmed
that the document was not sent to the Board.
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we have provided. We have also had the tester, who
Rudkin believes took him to the basement, complete
awitness statement. He has confirmed that there was
only a testing system in the basement. This has been
a constant challenge with Second Sight and I'm not sure
how this will get resolved."
The message that was communicated to Ms Vennells in
the contemporaneous documents was that Mr Rudkin's
allegations had been investigated and that Post Office
was satisfied that they had no substance.
Sir, turning to advice on prosecutions. Ms Vennells
stated in a letter to the BEIS Select Committee on
24 June 2020 that she had discussed prosecutions with
Ms Crichton shortly after she became CEO. She was told
that POL approached POL's prosecutions with the same
rigour as the CPS, applying the Police and Criminal
Evidence Act 1984 and the Code for Crown Prosecutors.
The documentary evidence that Ms Vennells has seen since
she wrote to the Committee in June 2020 supports her
recollection that she was given assurances that Post
Office conducted prosecutions responsibly through
a structured and professional legal process.
This is consistent with the speaking note prepared
for Ms Vennells to use in May 2012 when speaking to Lord
Arbuthnot. That note describes the role of Post Office
42
Ms Crichton did not set out in writing anywhere
a complete or accurate summary of the substance of
Mr Clarke's advice. It was her job to do so. Nor did
her successor, Mr Aujard. Indeed, while Mr Aujard
received a copy of the advice in a briefing pack from
Cartwright King, he claimed not to recall whether he had
read it in detail.
He suggested that his view at the time was that it
was a historic detail that was being dealt with through
the case review process. This might go some way to
explaining the messaging received by Ms Vennells.
Parts of Mr Clarke's advice were communicated to
Ms Vennells between July and October 2013, though in
a way that was piecemeal, unstructured and incomplete.
First, Cartwright King's advice that Post Office was
obliged to review past prosecutions was summarised in
Ms Crichton's update paper for the Board meeting of
16 July 2013. Second, this paper did not mention
Mr Jenkins nor the fact that Cartwright King had advised
Post Office that it was obliged to disclose the two bugs
in HNG-X and the Helen Rose Report.
Third, it also did not mention that Mr Jenkins and
Post Office had breached their duties as an expert
witness and prosecutor respectively. The reason for
this admission is that, as he said in his evidence,
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Mr Clarke did not reach a conclusion that Mr Jenkins and
Post Office had breached their duties until shortly
before he completed the Clarke expert evidence advice.
As I mentioned, that was not sent to Post Office
until 17 July, after the July Board meeting.
Fourth, Ms Vennells says that she was never told
about Mr Jenkins’ and Post Office's breaches of duty.
She was also never told about the disclosure issues
relating to the Helen Rose Report.
Fifth, Post Office obtained three pieces of written
advice from Brian Altman, King's Counsel, between August
and October 2013, an interim review of Cartwright King's
process for reviewing criminal cases for disclosure on
2 August 2013, a general review of the prosecution case
review on 15 October 2013, and a forward-looking review
of Post Office's role as prosecutor.
Each of these documents discussed the issue with
Mr Jenkins; none of them was provided to the Board.
They were each summarised for the Board by the General
Counsel in a way that gave the impression that Mr Altman
had not identified any significant issues with
Cartwright King's conduct of the disclosure review, or
Post Office's conduct of past prosecutions.
For example, Ms Crichton emailed Ms Vennells after
a conference with Mr Altman on 9 August 2013, stating:
45
to the disclosure issues was to conduct a review of past
cases to ensure that Post Office complied with its
disclosure duties. She was told that this review was in
the hands of experienced external criminal lawyers, and
that their approach was being checked by Brian Altman,
King's Counsel, a senior and experienced criminal
barrister.
She was also advised that Mr Altman agreed with the
approach of the external lawyers and had not found any
fault in their work.
Sir, Ms Vennells made no attempt to influence or
direct that process, save that she asked why the review
should not extend further back in time to look at more
cases. It was entirely for the lawyers to determine the
steps that Post Office needed to take to comply with its
legal duties, including what materials should be
disclosed, and to whom.
Ms Vennells was given the impression by successive
GCs that the case review exercise was being carried out
competently and professionally and, fundamentally, that
the exercise was what Post Office should be doing as
a matter of law to address the disclosure issues. As
anon-lawyer, Ms Vennells could not be expected to have
understood the significance of an unsafe witness, and
was entitled to rely on her General Counsel, Cartwright
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“Overall, his opinion in conference was that the
work that had already been completed was fine and along
the right lines, taking into account Post Office's
prosecutorial duties to disclose evidence/information to
the defence."
Sixth, Ms Vennells has a recollection of receiving
two pieces of information by word of mouth after July
2013. First, she says that she was told by Lesley
Sewell that Post Office had stood down a Fujitsu expert
witness because he had not revealed bugs during the
prosecution of Mrs Misra. Second, she was told by
Ms Crichton that POL was required to review the cases in
which the expert had given evidence.
Seventh, when Ms Vennells was informed, most likely
in October 2013, that Post Office had used an unsafe
witness from Fujitsu, she informed Ms Perkins, copying
in the CFO, Mr Day, and directed Ms Perkins to contact
Mr Edwards if she needed more information about this
issue. We submit that the inference to be drawn is that
the information in the email was given to Ms Vennells by
a Post Office lawyer.
Sir, Ms Vennells was neither wilfully blind, as
suggested by Core Participants, nor did she purposefully
close her eyes. She trusted her General Counsel. She
was advised by Ms Crichton that the right legal response
46
King and Brian Altman, King's Counsel, to ensure that
Post Office was responding in an appropriate manner.
Ms Vennells was not responsible for Post Office's
failure to give disclosure of the fact that Mr Jenkins
had withheld information about his knowledge of bugs in
Horizon in his expert evidence.
Mr Altman, King's Counsel, stated in his evidence
that it did not occur to him at the time that this fact
should have been considered for disclosure, and
disclosed in appropriate cases, although he accepted
with hindsight that it should have done.
The evidence before the Inquiry has shown that this
was not the only misjudgement or mistake made by the
lawyers.
First, Mr Altman, King's Counsel, did not consider
the procedure by which Mr Jenkins had been instructed as
an expert witness because no one at Post Office told him
that Mr Jenkins had not been properly instructed. He
stated, however, that, looking back, this was something
that he should have queried. Mr Altman agreed that, if
he had been informed that Mr Jenkins may not have been
properly instructed or properly informed about his
duties as an expert witness, this may have led to
inquiries into broader failings by Cartwright King as
prosecuting lawyers, and whether Cartwright King had
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a conflict of interest in advising Post Office on past
prosecutions in which they had acted as prosecuting
lawyers.
Second, Mr Clarke accepted in his oral evidence that
there was a view that Cartwright King's review of past
prosecutions, and I quote, "probably wasn't
as independent as it ought to have been", and that
Cartwright King's review may have become less rigorous
and less observant of potential trends or themes in the
cases as the review progressed.
When he was asked whether Cartwright King may have
become case hardened during the review he said:
"That's exactly what I'm referring to. That's the
point I'm making, that because you become slightly
cynical, jaded, as inevitably is going to be the case,
then you do miss things. Yes, I accept that."
Third, Mr Clarke accepted that he was wrong not to
have recommended disclosure following his review of
Mrs Misra's case. Ms Vennells was not to know any of
this. As Mr Moloney, King's Counsel, said yesterday:
"Regulated legal professionals might be expected to
provide requisite independence."
Ms Perkins made the point in her evidence that the
summaries of the external legal advice presented to the
Board were inadequate. They failed to alert the Board
49
setting out the options for Post Office's future
prosecutions policy, he was doing so with the ARC
proceeding on materially incomplete information, and he
knew or ought to have known that this was the case,
since it was he and his predecessor who had failed to
provide the ARC with that information.
There was no suggestion, for example, in Mr Aujard's
paper that Post Office should discontinue prosecutions
because of there being any reason to suspect that its
past conduct of prosecutions had been inadequate or
inappropriate.
The starting point of Mr Aujard’s analysis was that
Mr Altman had not identified anything during his review
of POL's prosecutorial role to suggest that POL's
approach to prosecutions had been anything other than
well organised, structured and efficient. That was not
an accurate summary of what Mr Altman had said, nor did
it sit happily with Mr Clarke's expert evidence advice,
or the Helen Rose Report. The Post Office Board was
entitled to assume that he was competent and that he
would provide accurate summaries of the advice being
provided to Post Office.
Sir, throughout her role as CEO, Ms Vennells and the
Board made use of highly reputable external advisors,
including Deloitte, Linklaters, Bond Dickinson,
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to, amongst other matters: (i) the conclusions of the
clerk expert evidence advice; (ii) the existence and
significance of the Helen Rose Report; (iii) Mr Altman's
view in his October 2013 General Advice that Mr Jenkins
was tainted and that his future role as a witness was
untenable; (iv) the statement in Mr Altman's general
advice that he was left unclear about whether POL had
challenged Mr Jenkins about his non-disclosures; (v)
Mr Altman's criticisms of the disorder of POL's
prosecution policies and past prosecutions; and (vi) the
possibility that Cartwright King were conflicted due to
their role in past prosecutions, including those in
which Mr Jenkins had given evidence.
Ms Vennells and the Board, at this time, assumed,
and were entitled to assume, that the General Counsel
were complying with their core responsibilities to alert
the Board to legal risks and to provide accurate and
complete summaries of external legal advice. That was
their role.
Ms Perkins shared that belief. That is the only way
to understand her evidence that the omissions from the
summaries were shocking and extraordinary.
When, therefore, Mr Aujard presented his papers to
the Audit and Risk Committee at the meeting in November
2013, and subsequently in writing in February 2014,
50
Cartwright King and leading counsel. As a non-lawyer,
Ms Vennells did not seek to reach her own conclusions on
legal advice but preferred, as she ought to do, to take
advice from experts. That can be seen, for example, in
Ms Vennells speaking directly with David Cavender,
King's Counsel, about the tone of Post Office's case
ahead of the Common Issues trial and subsequently
ensuring that the Board was briefed on the proceedings
by the external Legal Team the week before proceedings
commenced.
Matters such as the tone of POL's voice were matters
‘on which Ms Vennells, as a non-lawyer, could properly
involve herself in the detail of decisions being taken.
In contrast, a CEO could and should not be expected to
add value in relation to questions of law on which,
quite properly, the General Counsel took the lead with
Ms Vennells and the Board receiving appropriate
briefings.
As for the Mediation Scheme, this process for
seeking resolution of cases was recommended by
Ms Crichton, following discussions with Bond Dickinson.
On 19 July 2013 Bond Dickinson prepared a mediation
proposal paper which contained, under the heading
"Workflow", what is clearly an outline of what became
the Mediation Scheme.
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The statement that there were no grounds for
a blanket compensation scheme appears to have come from
advice set out in the Bond Dickinson mediation proposal
paper that:
“At present, there is insufficient evidence to
justify a blanket compensation scheme for
subpostmasters. Each case needs to be considered on its
individual merits.”
As the mediation continued, Ms Vennells received
assurance that the investigation of the cases had not
revealed any faults with Horizon through a paper
prepared by Chris Aujard on 17 September 2014 to update
the Board on the progress of the Mediation Scheme, and
in briefing notes prepared by Mr Bourke in October 2014
and November 2014.
Ms Vennells was also led to understand that the
cases in the Mediation Scheme had been reviewed by
external criminal lawyers who had concluded that there
was no evidence of unsafe convictions within the
Mediation Scheme caseload. Again, Ms Vennells submits
that she was entitled to rely on statements made by the
General Counsel and Mr Bourke, a qualified solicitor,
for their accuracy. She was also entitled to believe
and did believe that these statements were an honest and
professional review, based on the evidence reviewed by
53
access to legal files."
Sir, Ms Vennells played no material role in
decisions regarding disclosure or statements of factual
witnesses and experts in the GLO proceedings. She does
not recall being asked to be involved in any decisions
about disclosure and no questions were put to her in
oral evidence on this topic.
Ms MacLeod, as General Counsel, took the view, set
out in her witness statement for this Inquiry, that, in
respect of whether or not to call somebody like
Mr Jenkins as a witness:
"_. my expectation was that this would have been
decided by the Legal Team."
The Inquiry may in fact have been surprised if it
had heard evidence that Ms Vennells had personally made
decisions regarding disclosure and witness evidence.
That is far from the role of the CEO.
Sir, the protection of POL's reputation.
Ms Vennells submits that the protection of a company's
reputation is a legitimate objective of a CEO. Itis
clear from the documents that Ms Vennells saw no.
conflict between the protection of Post Office's
reputation and positive engagement with the Second Sight
Interim Report. As she informed the Board in an email
on 4 July 2013:
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the Post Office.
Ms Vennells was aware that Bond Dickinson had been
engaged by Post Office as its primary legal advisor in
relation to the review and that Post Office's
investigation work included reviewing transaction data
sourced from Fujitsu. At the time, Ms Vennells had no
basis to second-guess what she was told about Post
Office's view of the outcome of the investigation.
Even contemporaneously, there is evidence in the
documents that the Post Office senior team and its
lawyers recognised that on occasion, Ms Vennells had not
been given correct or incomplete information. When
Ms Vennells gave evidence to the BEIS Select Committee
on 3 February 2015, she was not aware that Second Sight
had requested access to Post Office prosecution files.
Two days later, she wrote to Mr Richardson of Bond
Dickinson on 5 February 2015 stating:
"It was tough but I felt that, other than the issue
of withholding prosecution files, which caught us
completely by surprise, we did as you said.”
Further, an email from Ms Crowe to Mr Cameron
Mr Davies, Ms MacLeod and Mr Aujard on 27 February,
which was copied to Ms Vennells, states that:
"A clear, major breakdown in communications between
Legal and the CEO surfaced at the Select Committee on
54
"To summarise very briefly, we have taken the view
that the best way to minimise the reputational risks
associated with the review and to do the right thing for
the business and the people is to welcome the broad
thrust of the report and commit to acting on its key
findings in relation to the need for improvements in our
support and training processes.”
This is entirely consistent, she said, with the
broader imperative for cultural change across the
organisation which the Board has discussed in recent
months.
Ms Vennells saw the implementation of the Interim
Report's recommendations on support and training as the
primary means of preserving Post Office's reputation.
In circumstances where Ms Vennells was being told that
the IT Horizon system was reliable but that there were
areas for improvement in training, support and culture,
it is understandable why she took the approach that she
did: to emphasise Post Office's confidence in the IT
system, while accepting that it should proactively
identify and improve culture, training, and support.
She was aware that Post Office served vulnerable
individuals in thousands of Post Office's nationwide and
it was of great importance to her that those people did
not lose their confidence in the Post Office and
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The Post Office Horizon IT Inquiry 17 December 2024
continued to feel able to collect benefits and pensions
and carry out other important transactions.
Sir, in conclusion, Ms Vennells understands the
strength of feeling about her, that of subpostmasters,
those directly affected by the wrongful convictions, and
that of the public. She heard what Mr Moloney said
yesterday about apologies being difficult to hear, and
she understands that position. She knows that any
apology will offer little comfortable to those affected.
She cannot and does not try to hide from the fact that,
whilst CEO, she did not manage to uncover the truth
about the extent of the bugs, errors and defects in
Horizon, as found by Mr Justice Fraser. This is
a matter of deep and constant regret to Ms Vennells, as
is the fact that the convictions of the subpostmasters
were not overturned sooner.
Sir, Ms Vennells simply did not receive the
information which she ought to have been given by her
senior team, whom she trusted and to whom she delegated
responsible roles.
As she said herself, in her evidence to you:
“lam very sorry that I was not able to find out
what the Inquiry has found out. I don't know today how
much wasn't told to me. I do know information that
I didn't get, and I don't know in some cases why it
57
hear from Mr Whittam.
(11.11 am)
(A short break)
(11.25 am)
SIR WYN WILLIAMS: = Mr Whittam.
Closing submissions by MR WHITTAM
MR WHITTAM: Sir, Fujitsu thanks you for the opportunity to
make this short oral closing statement to supplement
Fujitsu's written closing submissions to the Inquiry.
‘As you know, Fujitsu has made careful evidence-based
written closing statements for Phases 2, 3, 4, and
collectively 5, 6 and 7. I do not repeat the content of
those closing submissions.
Fujitsu has reflected carefully upon the evidence
given to the Inquiry. In Phase 1, the Inquiry heard
clear, detailed and profoundly affecting evidence of the
human impact of hostile investigations and wrongful and
civil and criminal proceedings commenced by Post Office
against subpostmasters and their employees. Phases 2 to
7 of the Inquiry have exposed in detail the failings
which brought about those appalling miscarriages of
justice. The Human Impact phase of the Inquiry
reinforced the devastating impact of those events
described by the subpostmasters and the impact it had on
their lives.
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didn't reach me."
Ms Vennells still does not know why key information
was not passed on to her and explained. She believed
her senior team and General Counsel to be working hard,
and doing their best to investigate the subpostmasters’
complaints in good faith. She had faith in them and, as
far as she was concerned, had good working relationships
with them. She is devastated by the fact that
information was not shared with her. She has no desire
to point the finger at others nor to speculate as to why
information was not shared. She trusts that you, sir,
together with your panel, will establish the true extent
of the information that was not shared and perhaps why
it was not shared.
Throughout Ms Vennells' written and oral evidence,
and borne out throughout the documents and evidence of
others which have been adduced during the Inquiry, we
submit that there has been nothing to show that
Ms Vennells acted in bad faith. Ms Vennells wanted to
do right by the subpostmasters.
Sir, notwithstanding that the evidence phase of this
Inquiry has now concluded, Ms Vennells will continue to
assist your investigation in any way she can.
SIR WYN WILLIAMS: = Thank you, Ms Leek.
So we'll break off now until 11.25, when we will
58
As it has done previously, Fujitsu apologises for
its role in the suffering of affected subpostmasters,
employees and their families.
Fujitsu's written closing submissions for each of
the phases of this Inquiry have accepted, clearly and
candidly, where it's own systems, processes and people
have gone wrong. Nothing I say in this oral submission
is intended to detract from those acceptances.
The evidence received by the Inquiry has
demonstrated that the issues which have arisen are not
exclusively or even primarily IT issues. The
miscarriages of justice with which this Inquiry is
concerned were not caused by technical failures alone
but are the product of serious human and organisational
failures in conduct, ethics, governance and culture.
Fujitsu's commitments to helping the Inquiry
understand what happened is reflected in the extent of
its cooperation with the Inquiry. Fujitsu responded to
the Inquiry's Rule 9 requests as fully and
comprehensively as possible. At the start of the
Inquiry, warehouses were searched, databases were
processed and electronic documents from approximately
120 Fujitsu individuals were collected. More than
30 million records, electronic and hard copy, going back
more than 25 years have been collected. Throughout,
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Fujitsu has remained fully committed to supporting the
important work of this Inquiry, having produced over
240,000 evidential documents, assisted more than 30
witnesses in the provision of written and oral evidence,
and produced five detailed corporate statements.
From the outset of this Inquiry, Fujitsu has been
clear about the technical matters that have now been the
subject of substantial and careful examination.
The first of these relates to the existence,
identification, communication and resolution of bugs,
errors and defects in the Horizon IT system. The second
relates to the existence and use of remote access by
certain Fujitsu staff. I address these matters briefly
in turn.
In its opening statement to the Inquiry, Fujitsu
acknowledged that there have been a number of bugs,
errors and defects within the Horizon system and that,
in some instances, those bugs, errors and defects had
the potential to, and indeed did, affect the integrity
of subpostmasters' branch accounts. Fujitsu has
repeated this acknowledgement variously throughout the
Inquiry process.
Fujitsu has also explained that no complex IT system
will ever be completely free of bugs, errors and
defects. That common-sense proposition has been
61
uniformly so.
The evidence heard over the course of the Inquiry
nonetheless compels the conclusion that, in general,
Fujitsu routinely and continually shared information
concerning the existence of the impact of bugs, errors
and defects with Post Office. It therefore follows that
contemporaneous knowledge of bugs, errors and defects
within Post Office went well beyond acknowledgement of
the mere theoretical possibility of bugs, errors and
defects.
Post Office has been aware for at least 25 years of
a potential for, and existence of, bugs, errors and
defects in the Horizon IT system, as well as the
potential for those which are unknown and unresolved to
exist. Post Office was also aware in 1999 of the
potential for bugs, errors and defects to impact upon
the integrity of branch accounts.
By way of illustration, in the annex to Fujitsu's
final written closing submissions in this Inquiry,
Fujitsu has identified at least 70 individuals within
Post Office and Royal Mail in relation to whom the
Inquiry has received unequivocal evidence of their
knowledge of bugs, errors and defects. This includes
members of the Post Office Board, senior executives,
in-house lawyers, as well as individuals working in Post
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accepted, repeated in evidence, by numerous Post Office
witnesses working across the Inquiry's relevant period.
Horizon is a multi-functional system encompassing
points of sale services and over 100 additional
services, including, amongst other things, financial
services, Government services and Lottery purchases. It
is a large, bespoke and highly complex system developed
by Fujitsu in conjunction with Post Office for use in
Post Office branches.
It interfaces with numerous different Post Office
and third-party systems. Initially, Horizon was rolled
out between 1999 and 2001, and remains in use in Post
Office branches across the United Kingdom today.
Horizon was and remains but one part of the Post
Office's IT infrastructure, supported not only by
Fujitsu but various other third-party suppliers.
Both the inherent complexity of the system and the
‘obvious potential for bugs, errors and defects
necessitated that processes governing the
identification, communication, escalation and resolution
of bugs, errors and defects were put in place at the
start and remain in place between Post Office and
Fujitsu. Fujitsu has frankly accepted that, whilst
these formal and informal information-sharing systems
were generally effective in practice, they were not
62
Office's Security and Investigations Teams. That
knowledge spans the entirety of the period being
examined by the Inquiry.
The sheer number of Post Office and Royal Mail
personnel who were aware of the existence of bugs,
errors and defects is potentially relevant to the
Inquiry's work in another way. A number of witnesses
before the Inquiry could either not recall with accuracy
whether, or in what circumstances, they were made aware
of the existence of bugs, errors or defects, or
positively denied such knowledge in circumstances which
might be thought to be surprising.
In assessing that evidence, the Inquiry will be
entitled to conclude that: while of course knowledge
held by one person cannot unfairly be attributed to
another and while Post Office's corporate knowledge
cannot be abrogated for all-purposes, the Inquiry is
entitled to infer from the breadth and depth of
awareness of bugs, errors and defects within Post
Office, that it is likely that key institutional
decision makers did, in fact, have such knowledge.
The question of why this expansive institutional
knowledge was not appropriately considered by Post
Office or its legal representatives in the context of
proceedings against subpostmasters is a significant one,
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and a matter that will no doubt be the subject of
careful deliberation by this Inquiry.
Further, in its opening statement to the Inquiry,
Fujitsu accepted that Fujitsu staff had, and continues
to have, the ability to remotely access Horizon. That
access was and is possible in multiple ways, via various
ingress access types, from the time of the initial
rollout until now, including in both Legacy Horizon and
HNG-X.
Fujitsu has reiterated this position throughout the
Inquiry. Remote access was and remains a necessary part
of the suite of support tools available to manage the
live operation of the Horizon IT system, including the
attempts to rectify bugs, errors and defects. Indeed,
support staff from Fujitsu state in evidence that they
could have not done their jobs or operated Horizon
without it.
In its opening statement to this Inquiry, Fujitsu
submitted -- I'm sure you'll recall, sir -- that Post
Office had been aware from an early stage of Fujitsu's
ability to remotely access the Horizon system. That
submission has been borne out by the evidence given to
the Inquiry and was belatedly accepted by Post Office in
its final closing submissions.
Whilst abuse of remote access privileges by a malign
65
for it share of organisational failings in its
submissions to the Court of Appeal, in March 2001, in
the case of Hamilton v The Post Office. The Court of
Appeal rejected that attempt, holding that:
"POL knew there were serious issues about the
reliability of Horizon. If POL needed further
information, it could have obtained it from Fujitsu.”
That was a finding that was omitted by the Post
Office when quoting that same section of the judgment in
paragraph 10 of its written closing submissions.
The evidential basis for that conclusion is even
stronger on the evidence before this Inquiry and we
would invite you to adopt the same course as the Court
of Appeal.
To the extent that it is ever appropriate to
describe one party to an extensive and sophisticated
commercial contractual arrangement, like the Horizon
contact, as "subordinate" it is clear beyond argument
that the Post Office is not such a party. The Post
Office has been, and remain, very much in the driving
seat of that contractual relationship. As we saw in
Phases 2 and 3, it was Post Office who specified the
technical requirements by which the Horizon IT system
was developed and by which it has been changed over
time.
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actor cannot positively be excluded on the evidence,
there is no evidence for it and no reason to suppose it
occurred. Most importantly, there is no evidence to
support the suggestion that remote access privileges
were used for any purpose other than to provide
necessary technical support to Post Office branches. In
other words, there is no evidence to support any
suggestion of the malign use of remote access
capabilities.
It's regrettable that, in its written closing
submissions, Post Office sought to obfuscate its proper
share of responsibility for the events which are the
subject of this Inquiry, by seeking wrongly to deflect
blame to Fujitsu and other third parties. Post Office
has sought to characterise itself as the subordinate
partner in the relationship with Fujitsu and as
operationally and technically dependent on Fujitsu.
Perhaps tellingly, sir, you might have observed that
these submissions -- it's paragraph 101 in the Post
Office written closing submissions -- are unsupported by
any reference to the evidence before this Inquiry.
That's unsurprising because the submissions bear no
resemblance to that evidence.
Sir, you'll be aware that Post Office previously has
sought to shirk liability by deflecting responsibility
66
As we saw in Phase 4, it was Post Office who
determined the nature and extent of the Prosecution
Support which Fujitsu was required to provide,
including, by way of example, stipulating the form by
which the ARQ requests were made. Even in Phase 7 we
see the arrangements for the end of service life of
Horizon IT system continue to be sensitive to Post
Office's commercial needs, despite Fujitsu's serious
reservations.
More generally, the evidence for Post Office
dependency on Fujitsu is conspicuously thin. Post
Office has at all material times had its own IT
function. It's employed a number of IT specialists,
including highly experienced individuals such as Lesley
Sewell, who held positions of management and oversight
concerning all of Post Office's IT functions, including
the Horizon IT system.
As would be expected, the business as usual
operation of the Horizon IT system entails the sharing
of vast quantities of information about the system,
including, again entirely unsurprisingly, about
technical issues and bugs, errors and defects. In the
annex to our closing submissions, Fujitsu has summarised
some of those key means of information sharing. Post
Office has also had, at significant times throughout the
68
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life of Horizon, its own testing teams tasked with
ensuring the quality of certain releases of Horizon.
Post Office relies upon what it described as
repeated assurances from Fujitsu that Horizon was
reliable. It does not cite even a single example of
such an assurance being given. To the extent that
certain Post Office witnesses similarly suggested that
they'd been provided with assurances as to the integrity
of the Horizon IT system by Fujitsu, there was
a complete lack of evidence to support those claims.
Indeed, as Fujitsu pointed out in its Phase 3
closing submissions, those claims were either entirely
vague and, confusingly, often made by individuals with
no direct engagement with Fujitsu at all.
The better view of the evidence, sir, as Fujitsu
submitted at the end of Phase 3, is that a message from
the top within Post Office, consistently emphasised
without evidence, the robustness of the system. Having
said that, sir, to be absolutely clear, despite the
observations that I've just made and also will continue
to make about Post Office, I repeat: Fujitsu stands by
all the matters it has accepted in its written closing
statements.
Post Office investigations and prosecutions did not
begin with the introduction of the Horizon IT system.
69
Office contained novel propositions, contractually
obliging Fujitsu to provide support to Post Office in
respect of prosecutions. That work was atypical for
an IT service provider such as Fujitsu and was outside
the normal work of Fujitsu technical staff.
It is a matter of profound regret to Fujitsu that it
ever provided services to support Post Office
proceedings against subpostmasters.
Fujitsu was never sighted on the full scale of Post
Office's prosecutorial conduct and misconduct and, sir,
that's plain from the fact that it did not provide
evidence in all the cases. Nonetheless, Fujitsu accepts
that it was inappropriately deferential to Post Office
as its client and its senior management were
sufficiently interventionist in their management and
oversight of the Post Office Account. This led to
a failure to properly challenge or scrutiny the
appropriateness of requests made by Post Office and
resulted in Fujitsu providing a service and Prosecution
Support which fell short of its own corporate values.
In light of this, Fujitsu recognises that it failed
properly to support those of its employees who engaged
directly with Post Office and its lawyers in respect of
Prosecution Support. This is particularly so for those
who engaged in the provision of documentary and witness.
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Post Office had an established active investigation and
prosecution function in place prior to the national
rollout of the Horizon IT system in 2000. The available
evidence demonstrates a significant increase in
investigative and prosecutorial activity during the
period of 1992 to 1998. This initial increase in
investigative and prosecutorial activity occurred
following the introduction of an in-house accounting
system called Capture into Post Office branches in 1992,
and pre-dates the rollout of the Horizon IT system.
The conduct of criminal prosecutions on behalf of
Post Office fell considerably short of the important
duties which apply to a private prosecutor. Hundreds of
subpostmasters were wrongfully prosecuted. Indeed, the
evidence now available to the Inquiry suggests that the
failings in the conduct of Post Office prosecutors were
considerably more fundamental than even those
acknowledged in the Court of Appeal in the Hamilton v
Post Office case.
In Phase 4 of the written closing submissions,
Fujitsu made detailed submissions as to the wide range
of serious deficiencies which undermined the integrity
of Post Office prosecutions. I do not repeat those
submissions today. Fujitsu nevertheless acknowledges
that the Codified Agreement between Fujitsu and Post
70
evidence in relation to Post Office prosecutions and
civil actions, with technical employees often left to
engage directly with Post Office internal and external
lawyers, rather than having appropriate mechanisms by
which to monitor and support those employees.
In his written closing submissions, Gareth Jenkins
notes particular failings of Fujitsu in its management
and oversight of the Prosecution Support which he came
to be required to provide. Sir, I can make it clear
that Fujitsu accepts those failings.
In the course of Phase 7 the Inquiry explored issues
regarding ongoing and future criminal investigations and
prosecutions involving Post Office. Post Office's
renewed interest in criminal investigation and
prosecutions appears to be driven by perceived need
within the Post Office for a deterrent and to recover
apparent shortfalls. Despite the startling evidence
heard during Phase 4 of the Inquiry, in relation to
conduct of Post Office Investigators and lawyers in the
context of proceedings against subpostmasters, as
recently as July 2022, Post Office boasted in internal
documents that its investigations unit, the first
recognised investigations unit in the world, it claims,
has an unblemished reputation.
A significant focus of that evidence and,
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regrettably, a source of some confusion in the Phase 7
evidence, was the nature of assistance, if any, which
Fujitsu had provided or was willing to provide in
support of such investigations. Moreover, Post Office's
engagement with ongoing law enforcement investigations
raises real questions as to the extent to which lessons
have been learned regarding the matters which have been
the subject of this Inquiry.
Fujitsu has set out the position in detail in its
final written closings to ensure that that concern is
fully aired. But, in summary, it is as follows: between
February and July 2024, Fujitsu was contacted by four
police forces in relation to four cases. This apparent
flurry of criminal investigations, each of which
appeared to have been referred to the relevant police
forces by Post Office, caused Paul Patterson and his
colleagues at Fujitsu such concern that Mr Patterson
felt it necessary to escalate the matter to Nick Read as
the CEO of Post Office. Mr Patterson was particularly
aggrieved by some of the language used by Post Office
staff in context of these criminal investigations and
the apparent inference by those members of staff in what
appeared to be matters relevant to the police forces.
Fujitsu does not know why it has not been contacted
by the other police forces in connection with other
73
to those criminal investigations. Fujitsu is, however,
determined not to repeat mistakes of the past which have
been so starkly revealed by this Inquiry.
In this context, Fujitsu is acutely aware that it is
not in a position to offer independent expert opinion
from any employee regarding the operation of the Horizon
IT system. Fujitsu is also aware of the need to make
full and appropriate disclosure regarding its knowledge
of bugs, errors and defects in the Horizon IT system,
including the potential for unknown, undiscovered and
unresolved bugs, errors and defects affecting the live
system, particularly as it ages without further
investment, and the existence of remote access.
In addition, Fujitsu is also mindful that
a consistent theme of the evidence before the Inquiry
was the error in producing evidence for criminal
proceedings from the Horizon IT system data, of focusing
overly narrowly on whether there is a specific evidence
of a bug or error or defect affecting a particular
branch at a particular time, as compared to the
potential for bugs, errors and defects, including the
unknown ones, within the network more broadly, and is
eager that police forces do not repeat the same error,
in other words by asking Fujitsu to provide evidence
limited to a particular branch.
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investigations. It's been suggested by some Core
Participants that this correspondence and Fujitsu's
correspondence with some police forces may reflect
tactical positioning for the purposes of the Inquiry.
Sir, I can be completely clear on that front:
inevitably, Fujitsu's attitude to the use of data
derived from the Horizon IT system in criminal
investigations and prosecutions has been informed by the
shocking evidence heard by this Inquiry. Fujitsu is
astute to ensure that it does not repeat the mistakes of
the past and to ensure that it does not lend its
assistance to Post Office in repeating those mistakes.
Moreover, far from that tactical positioning,
Fujitsu's position regarding ongoing and future criminal
prosecutions has remained consistent since its declared
position on the 16 June 2020, in its letter to the BEIS
Select Committee, that it will provide information to
the police and other appropriate judicial authorities
but not to Post Office-led prosecutions. To reiterate,
Fujitsu has offered and will continue to offer full
cooperation to any police force conducting
an investigation into potential criminal wrongdoing in
connection with Post Office branches. Fujitsu will
cooperate with police forces in the preparation of
factual witness statements to address matters relevant
74
Relatedly, Fujitsu has become concerned by some of
the correspondence it's reviewed between the Post Office
and the relevant police forces, in particular the letter
sent by Post Office to the Lancashire Constabulary on
25 April this year and then provided by the Lancashire
Constabulary to Fujitsu some three months later on
24 July 2024. It's significant in a number of material
respects.
Fujitsu sets auditor the severe deficiencies of the
content of that letter in its written closing
submissions, where, from the context of the apparent
resurrection of the Post Office's criminal enforcement
activity and the quick dismissal of Fujitsu's concern by
both Mr Read and Owen Woodley, the content of that
letter seemed to Fujitsu to be so egregious that
Mr Patterson decided to write to Post Office two days
later to cease any further correspondence on the matter.
There is no merit whatsoever in the suggestion,
principally made by John Bartlett, that Fujitsu has been
obstructive or uncooperative to police investigations.
Fujitsu is surprised by that suggestion, which is
plainly at odds with the evidence. Further, given the
significant miscarriages of justice with which this
Inquiry is concerned, a cautious approach in these cases
is both reasonable and appropriate.
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In its opening statement to the Inquiry on 4 October
2022, Post Office submitted that it embarked on
an ambitious and accelerated large-scale effort to
retire Horizon by 2025 and replace it with a new system.
Over the course of Phase 7, the Inquiry has received
evidence concerning NBIT and the progress that has been
made towards replacing the Horizon IT system.
Increasingly, it's become clear that the NBIT programme
has experienced prolonged delays and technical
challenges. It has also become clear that Post Office
is no closer to replacing the Horizon IT system than it
was at the beginning of this Inquiry when it made its
‘opening statement.
In the interim, and something of concern,
insufficient investment has been made in the Horizon IT
system. The Horizon IT system is on an end of service
life IT infrastructure and, due to this status and its
age, there's an increasing risk of the existing Horizon
IT system infrastructure failing. That could inversely
impact the delivery of services to the public.
Since 2020, Fujitsu has consistently indicated its
concerns to Post Office in relation to supporting end of
service life infrastructure and that it wishes to exit
the Horizon contract.
Sir, as I've said, the core of this Inquiry are the
77
and organisational failures in conduct, ethics,
governance and culture.
Fujitsu hopes that, having supported the Inquiry
through its work, it has gone some way to demonstrating
its commitment to learning lessons from the Inquiry
process and, most importantly, to ensuring that the
mistakes of the past are never repeated.
Thank you, sir.
‘SIR WYN WILLIAMS: = Thank you, Mr Whittam.
So it's just about 12.00. Ms Dobbin, would you like
to make your submissions in one go, answer, I suspect,
yes, so would you like to have an early lunch or make
them now?
MS DOBBIN: Sir, I would like to make them in one go, if
that's okay.
SIR WYN WILLIAMS: Would you prefer to make them now or
shall we take an early lunch?
MS DOBBIN: Perhaps if we took an early lunch, if that was
all right?
SIR WYN WILLIAMS: Yes.
MS DOBBIN: Thank you.
‘SIR WYN WILLIAMS: So we'll begin again at -- well, 1.00.
(11.58 am)
(The Short Adjournment)
(1.00 pm)
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subpostmasters and their families, who were so
profoundly and tragically affected by the appalling
miscarriages of justice. Fujitsu reiterates its sincere
apology to the subpostmasters, employees and their
families.
The Inquiry has conducted a thorough and searching
investigation. The work of the Inquiry has revealed the
technical, human and organisational failings which
contribute to the suffering of said subpostmasters and
their families. Fujitsu accepts its share of those
failings and has set out in writing the detailed matters
which it does accept.
That said, the relative brevity of this oral closing
and the shorter-than-some written closing, should not be
taken as an acquiescence to all the criticisms levelled
at Fujitsu, particularly some of those I've touched on,
by the Post Office.
As already I have submitted, prior to the
commencement of this Inquiry, the appalling miscarriages
of justice that have now been laid bare by the evidence
received by this Inquiry, were framed as resulting
primarily or inclusively as IT issues. As evidence has
demonstrated, these miscarriages of justice were not
caused by technological failures exclusively or even
primarily but are, instead, the product of serious human
78
SIR WYN WILLIAMS: = Okay. I think we're all set, Ms Dobbin.
Closing submissions by MS DOBBIN
MS DOBBIN: Thank you.
Sir, Gareth Jenkins was interviewed by the police in
2021, just after this Inquiry had started in its current
incarnation, before the vast disclosure that it has
afforded. He told the police in that interview that he
had not been instructed as an expert by Post Office in
the cases in which he had been a witness.
That might have been surprising for the police
investigators to hear. That might have been confusing
for them, given the Clarke Advice was premised upon
Mr Jenkins’ failures of disclosure as an expert witness,
given the Horizon Issues Judgment and given the Court of
Appeal judgments and their focus on the Clarke Advice.
Confusing, given that Post Office's position before the
Court of Appeal was that the fact that Mr Jenkins had
given evidence in a case meant that Post Office did not
disclose the full and accurate position regarding the
reliability of Horizon -- see paragraph 207 of the
Hamilton judgment -- in other words, that the focus was
squarely on Mr Jenkins and his failures of disclosure,
as an expert witness.
It was no less shocking to Mr Jenkins, who retired
in 2015, to have found himself the focus of so many
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criticisms and indeed singled out in the Horizon Issues
Judgment, and then to find himself blamed by Post Office
before the Court of Appeal for a number of miscarriages
of justice. These were criticisms made of him that he
had no opportunity to address. He had no chance to
explain to Mr Justice Fraser, as then, that he was not
correct in the way that he attributed to Mr Jenkins.
blame for inaccuracies in the evidence of some
witnesses. He wasn't able to explain that there had
been a large number of people who had commented upon the
witness statements.
Mr Jenkins wasn't able to explain the role that he
had within that team. He wasn't able to explain that
when it came to correcting the position about the use of
remote access, that it was he, Mr Jenkins, who did so,
despite the fact that there were members of the SSC who
were involved in the civil litigation. Mr Jenkins
wasn't able to explain where he had obtained the
information about the Callendar Square bug from. He
wasn't able to explain that its existence had been
disclosed in Mrs Misra's trial, contrary to the letter
that Mr Justice Fraser sent to the DPP. He wasn't able
to explain the background to his communications with
Ms Rose.
There were many things that he was not able to
81
litigation. No one saw fit to tell Mr Jenkins why he
wasn't being called as a witness. No one told him, "The
reason you're not being called as a witness, Mr Jenkins,
is that Post Office has blamed you in a series of cases
for failing to disclose bugs".
You will draw your own conclusions, sir, as to what
that says about the lawyers involved.
Mr Jenkins didn't have the opportunity to speak to
Mr Clarke about his Advice. Mr Jenkins didn't have the
chance to tell Mr Clarke that his statement was
a response to four questions that Mr Singh had asked him
to answer. He did not have the opportunity to tell
Mr Clarke that he had not been instructed as an expert
when he gave this statement. He wasn't able to explain
that in cases in which that statement had been used, he
had explained to lawyers what the ARQ data might show
and that lawyers from Cartwright King had said no to
obtaining that data.
Sir, what this Inquiry has established are four
essential truths, of which neither Lord Justice Fraser
nor the Court of Appeal were aware: first, that Post
Office was well aware of the bugs and issues that it was
accusing Mr Jenkins or Fujitsu of not having disclosed;
second, that Mr Jenkins was not instructed as an expert
in a single case in which he gave evidence; third, that
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explain to Mr Justice Fraser and which would have put
a very different complexion on matters. These are the
things that show him not to have been the ventriloquist
that my learned friend, Mr Henry, King's Counsel,
accuses him of being and which are set out in detail in
his fourth witness statement.
Mr Jenkins had no opportunity to tell the Court of
Appeal that he had not been instructed as an expert in
Post Office cases and had provided information to Post
Office that he was now being criticised for not having
disclosed. He had no opportunity to tell the Court of
Appeal that, in fact, Post Office knew a lot about the
bugs which it was accusing him of having not disclosed.
There was no one in the Court of Appeal able to
point out the hypocrisy and the inaccuracy of Post
Office's position, that the issue was not that of the
single expert who had failed in his duties of
disclosure, but that Post Office, as an organisation,
and individual investigators and lawyers, had no concept
of basic laws and ethics of prosecuting, that this
incompetence extended to their use of Mr Jenkins.
Mr Jenkins, in fact, had no idea until 2021 of the
existence of the Clarke Advice. He had been misled in
2013 as to why Post Office no longer needed assistance.
He had been asked by Post Office to assist in the civil
82
this failure to instruct Mr Jenkins as an expert was
apparent to Cartwright King and Post Office from the
point of the Clarke Advice in 2013; fourth, that Post
Office, as an organisation, and individual investigators
and prosecutors, did not know or did not apply basic
laws and rules and guidance which applied to
prosecuting.
Returning to the critical point about what
Mr Jenkins told the police in 2021, that he hadn't been
instructed as an expert in any case. In summary, that
Post Office had put Mr Jenkins forward as an expert in
criminal cases, had sought out his opinions and then to
rely on them but had never actually instructed him as
an expert witness, appeared extraordinary and giving
rise to the question: how could that possibly have
happened?
Sir, this Inquiry having disclosed in excess of
270,000 documents, confirms not just the truth of what
Mr Jenkins told the police but the answer to the
question how it happened that he wasn't instructed as
an expert. There are two fundamental reasons. First,
quite simply, because investigators and lawyers did not
know or ignored the law that they ought to have been
applying. The evidence before this Inquiry demonstrates
a profoundly more disturbing picture of prosecutorial
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incompetence than could have been imagined at its
outset, disturbing for its back of regard for a very
basic law and ethics which govern prosecuting,
disturbing because it was being done by a private
prosecutor, cloistered from the usual forms of scrutiny
that applied to a public prosecutor and given all of the
vested interests at stake.
The second reason why it happened was that
prosecuting lawyers didn't address the capacity in which
they were relying upon Mr Jenkins to give evidence.
They didn't distinguish between Mr Jenkins as a Horizon
technical expert and Mr Jenkins as an expert witness as
a matter of law.
The fact alone that every single one of Mr Jenkins’
statements was an ordinary Section 9 witness statement
that contained none of the content necessary to render
it admissible as expert evidence demonstrates this and,
ultimately, Mr Warwick Tatford's evidence confirmed it
and demonstrated in human terms how it happened.
Throughout the prosecution of Mrs Misra there was, in
his words, a "muddle" as to the capacity in which
Mr Jenkins was being relied on.
Sir, given that Mr Jenkins gave oral evidence in
Mrs Misra's cases, without being taken through any of
the steps to establish that he was giving evidence as
85
allegations and insinuation that he lied or was party to
presenting the veneer of Horizon as though it was
infallible.
There are two fundamental obstacles to this
characterisation of Mr Jenkins. First, that he provided
the sort of information that he is accused of
withholding, notwithstanding the way he was communicated
with and used by prosecutors. Indeed, Mr Jenkins openly
adverted to information which it has been submitted in
this Inquiry there was a campaign to keep secret.
For example, Mr Jenkins told Professor McLachlan and
the prosecution in Mrs Misra's case about the Known
Error Log and told them that there were 200,000 faults
in the live and test system on Horizon. This material
was known to the defence because Mr Jenkins told them.
In his 2012 statement in the Wylie case, Mr Jenkins
confirmed Fujitsu's ability to use remote access. This
was the first public confirmation of the position. This
statement was regarded in 2015 by Post Office and
Mr Parsons of Womble Bond Dickinson as going
significantly beyond that which Post Office had ever
confirmed about remote access. Mr Parsons described
that it would be a "red rag" to Second Sight.
The second obstacle is that Mr Jenkins never sought
to convey Horizon as infallible, rather, for example, he
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an expert, that he was not taken through expert duties,
that no steps were taken in his evidence to rectify that
none of his statements complied with the requirements of
expert evidence, that he wasn't asked any questions as
to why his statements didn't comply with the
requirements of expert evidence, that no one asked if he
had prepared his evidence compliantly with expert
duties, that this makes clear that the muddle on the
part of prosecutors as to what sort of witness he was
continued into his giving oral evidence.
Sir, I want to be clear at the outset of this
submission that it focuses, in part, upon the failure of
Post Office to instruct Mr Jenkins as an expert because
the key allegation that he has always faced is that, as
an expert witness, he breached expert duties by not
providing disclosure of bugs, errors and defects. The
fact that Mr Jenkins was not instructed as an expert is
critically important because the evidence that he gave
and how he provided it, was a product of the approach
which Post Office took to him and, specifically, the
communications which Post Office had with him as to what
his evidence was to address.
The Inquiry's evidence has proved the negative: that
he wasn't instructed as an expert in any case and so the
allegations against him have shifted to generalised
86
advocated an approach of obtaining the data for a given
branch in order to see what may have happened.
The assessment of Mr Jenkins does not lie in
generalisations. It lies in the reconstruction of how
he was approached by Post Office lawyers, what evidence
he was asked to provide and how he responded. It lies
in the assessment of the information he did provide to
Post Office prosecutors and how they treated it, and why
some of that information never came to be recorded on
any disclosure schedule.
Sir, he did not lie. He sought to answer the
questions that Post Office lawyers asked him to address.
He was demonstrably not part of any approach which
sought to perpetuate Horizon as infallible.
Sir, my learned friends yesterday focused on events
after the Clarke Advice and the allegations of cover-up
about it. There is a very obvious irony that it was
Mr Jenkins’ openness with Second Sight and his provision
of information about bugs to Second Sight that meant he
became subject to allegations of non-disclosure.
Mr Henderson of Second Sight contemporaneously
described Mr Jenkins as having been straight as a die.
When he was asked about this observation in his
evidence, Mr Henderson explained:
"He wasn't being evasive. He was happy to help. He
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was answering my questions. He provided promptly with
follow-up material that I requested. I mean, there was
no hesitation in his willingness to answer our questions
and to provide assistance.
"So he was willing to discuss remote access when
Post Office was not?
"Yes."
Mr Henderson also explained:
"I saw him as a technical expert and that he
approached things from a technology perspective, almost
exclusively. He didn't strike me as a company person or
feeling that he had to stick to a particular party line
in terms of supporting Fujitsu. He was dealing with
things at a technical level as a technical expert and
I find that rather refreshing.
"Was he taking the defensive position that Post
Office was, which you describe in your statement?
"No."
Sir, these points are not just important to
demonstrate that Mr Jenkins had provided Post Office
with information relevant to the operation of Horizon,
but that there was clearly no design, no strategy on his
part to withhold information. To the contrary, that he
provided guilelessly in the course of criminal cases the
sort of information that Post Office was claiming to
89
and have been amnesiac until they have remembered things
that have been helpful to them.
Sir, Mr Jenkins was not that sort of witness. He
came and gave evidence before you for four days. He
answered all questions, despite the position he was in,
and he demonstrated himself to be incapable of putting
a self-serving gloss upon his evidence. He stands in
stark contrast to many of those who have given evidence
before you.
Before addressing some specifics, I wanted to make
three observations, if I may, three overarching
observations. The first is this: that Mr Jenkins was
an engineer in a legal world. Mr Jenkins was a computer
engineer to the core. He had been one for over
30 years, before being asked by Mr Pinder of the Fujitsu
Legal Support Team to help in Mr Thomas' case. He had
no legal training whatsoever, no training about being
an expert witness. He was involved in designing parts
of Horizon and, as part of his role as fourth line
support, in identifying the root causes of problems
which arose in Horizon.
He had been schooled by these decades of computer
engineering to think in terms of system and logic and
problem solving. As Mr Henderson said, this was a sort
of exclusively technological perspective. He was at
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have been unaware of.
Indeed, sir, it might have been thought that
Mr Jenkins’ willingness to provide information to Second
Sight was another good reason to speak to him in 2013,
to investigate the circumstances in which he had given
evidence.
So we respectfully agree with those representing the
Hudgell and the Hodge Jones & Allen Core Participants,
that there ought to have been an examination in 2013 of
the circumstances in which Post Office had used
Mr Jenkins. For, had that happened, it would have
demonstrated Cartwright King’s involvement in obtaining
the very witness statements which Mr Clarke was
considering in his advice, an involvement which
Mr Atkinson, King's Counsel, has been so critical of in
this Inquiry.
It would have demonstrated Cartwright King's failure
to instruct Mr Jenkins as an expert and perhaps, sir,
most important of all, it may have revealed or begun to
reveal the sorts of prosecutorial incompetence that Post
Office's use of Mr Jenkins demonstrates, and which has
only been revealed here in this Inquiry.
About this Inquiry, sir. I pause at this point to
reflect on Mr Moloney, King's Counsel's, observation
about the witnesses who have come before this Inquiry
90
a very considerable, if not total, remove from the type
of expert usually called in criminal proceedings.
It's not simply that he wasn't a professional expert
witness, that he wasn't giving evidence in a recognised
field of expertise, that he wasn't a member of an expert
institute, that he wasn't involved in research or bore
any of the hallmarks of a professional expert, but that
he was being called upon to give an opinion on the very
computer system he'd spent so many years working on and
continued to do so.
Some of my learned friends' submissions proceed as
though Mr Jenkins was appearing as a witness on a near
consistent basis. For example, my learned friends
Mr Moloney and Ms Patrick's written submissions suggest
that, time and time again, Mr Jenkins was reading expert
reports or meeting with experts or signing joint
reports.
Mr Jenkins was, at all times, a full-time and busy
engineer on Horizon. His involvement in cases was
sporadic and the nature of that involvement varied
greatly. As the Inquiry has seen, his involvement in
Mr Thomas' case in 2006 was limited to the issue of zero
transactions. He didn't encounter a defence expert
until his involvement in Mrs Misra's case in 2010, which
I'll come back to in detail. But this was the high
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point of his involvement in any of the Post Office's
criminal cases and the only one in which he gave
evidence.
In that case, Mr Jenkins and Professor McLachlan
made a short joint statement but, conspicuously, it did
not have an expert declaration on it. Mr Jenkins didn't
agree a document again with a defence expert until 2013,
in Mr Ishaq's case, and again, here, it's conspicuous
that this document was Ms Ibbotson's report with some of
Mr Jenkins' narrative added. The expert declaration was
Ms Ibbotson's alone. Indeed, the document was not
signed by Mr Jenkins.
After Mrs Misra's case, Mr Jenkins only made
a statement in one other case until the 2012 generic
statement. The nature of the generic statement and
Mr Jenkins' subsequent involvement in the 2012 and 2013
cases was very different again to Mrs Misra's case.
Sir, quite simply, the broad language of "time and
time again" is not borne out by consideration of the
detail. Rather, Mr Jenkins was an engineer navigating
from time to time a legal world he was unequipped and
untrained for, which alone would be concerning before
considering Post Office's purported use of him as
an expert.
He was entitled to trust the lawyers that he was
93,
Counsel, asked Mr Atkinson, King's Counsel, this:
"If it's right that the Post Office or its agents,
Cartwright King, later did not provide Mr Jenkins with
written instructions that conformed to the requirements
we've mentioned, didn't provide Mr Jenkins with
instructions as to his duties as an expert and none of
the statements included the necessary elements that
we've identified, would you be able to draw an overall
conclusion that there was a fundamental failure to
instruct Mr Jenkins as an expert?”
To which Mr Atkinson replied:
"Clearly, that's ultimately a conclusion for others
than me, but certainly, it's not a conclusion from which
I would dissent at all.
“With the limitation you have included, was it
a persistent failure?
"Yes."
Sir, the evidence overwhelmingly demonstrates that
Post Office did not provide Mr Jenkins with written
instructions that conformed to the requirements of
instructions for expert evidence. Written
communications with him didn't even approximate expert
instructions.
The evidence goes much further. The failures were
not simply those of omission; they were failures of
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dealing with and to trust that they were competent and
acting lawfully, indeed people like Mr Singh, who had
the Post Office endorsement of being a senior lawyer, or
the Head of Criminal Law. Mr Jenkins didn't have the
framework to know that what any of these lawyers were
saying or doing was wrong or to challenge them. It's
important to emphasise, sir, that, in Mr Jenkins' case,
every single lawyer and investigator with whom he dealt
was incompetent or acted in ways that was inconsistent
with their duties.
Sir, you need only think of the case studies before
you to see this. Mr Ward and Ms Matthews in Mr Thomas’
case; Mr Singh in Mrs Misra's case; Mr Singh in relation
to the generic statement; and then Mr Bowyer, Mr Smith
and Mr Bole, and the very junior paralegal, Ms Panter,
in the 2012 and 2013 cases.
As Mr Smith of Cartwright King observed:
"Quite why Cartwright King thought it was
appropriate to take on prosecution work, really, with
hindsight, I've no idea because we certainly didn't have
the training for it and I was unaware of the duties on
a prosecutor in relation to the instruction of an expert
witness."
Sir, the second overarching point: Mr Jenkins was
never instructed as an expert. Sir, Mr Beer, King's
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commission. Lawyers misstated to Mr Jenkins what his
role was or what the evidence was he was to give. Post
Office didn't provide Mr Jenkins with instructions as to
his duties as an expert. There isn't a single document
before this Inquiry in which Post Office provided
Mr Jenkins with these instructions. Every single lawyer
who has appeared before you conceded that they had not
Mr Jenkins as to expert duties and, sir, I include
Mr Warwick Tatford in that for reasons which I will
return to. So sir, none of the statements included the
necessary inclusions to make it admissible as expert
evidence.
Sir, the third overarching point: the fact that
Mr Jenkins was never instructed as an expert cannot be
treated as irrelevant.
Sir, this third point can be made shortly: it is
impossible to treat as irrelevant that Mr Jenkins was
not instructed as an expert. In other words, to take
an approach to Mr Jenkins which accepts that he was not
instructed as an expert but which proceeds on the basis
that this does not matter and that his evidence in
criminal proceedings can be looked at in isolation from
the manner of his instruction or how he was used by Post
Office. That would not be a sustainable forensic
exercise and would be unfair for these reasons: first
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and fundamentally, Mr Jenkins was not being treated as
a witness of fact. He was being asked questions to
undertake work to respond to expert reports in
Mrs Misra's case and to provide opinions. In short, he
was being asked to provide evidence and being put in
a position that no witness of fact would be put in.
As stated already, the evidence that he gave and how
he gave it was a product of Post Office's approach to
him and, specifically, the product of communications
with Post Office had with him about what his evidence
was to address. It was impossible to disentangle these
from each other and it applies to every single case
study.
Third, it would also overlook that the evidence that
Mr Jenkins gave was in the context of a series of
grossly defective communications which misrepresented
his role and the sort of evidence that he was to give.
Again, this was a feature of every single case study.
Far from prosecutors sending the message that
Mr Jenkins was to be treated as independent or, for
example, his evidence as independent, they informed him,
for example, "You are our Horizon expert. You're
an expert for Fujitsu", that he rebut and disprove or
discredit what the defence were alleging, that he
preserve the Horizon system.
97
instructed as an expert, is that it would hold
Mr Jenkins to the standards and duties of an expert
witness when he was a layperson, uninstructed and
uneducated in those standards and duties.
Sixth, this approach would negate the importance
attached to the duties on lawyers when they instruct
an expert to ensure that they understand the content of
expert duties.
Sir, that is all by way of introduction, and
I wanted, if I may, to deal with some specific points.
But before I do, sir, to thank the Inquiry and
particularly all of those whose very hard work has
enabled a forensic reconstruction of how number of the
case studies were prosecuted. It's only by that process
that it's been possible to demonstrate that Post Office
failures in relation to Mr Jenkins were part of a much
broader canvas of prosecutorial failure.
Of these failures, the most significant which relate
to Post Office's use of Mr Jenkins is its failure to
understand that the Criminal Procedure and
Investigations Act applied to it as a holder of material
relevant to its prosecutorial function.
In other words, sir, that Post Office elected to
prosecute at scale without ever having understood that
it had a statutory obligation to ensure that information
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These are just examples of what lawyers told
Mr Jenkins that his role was and yet, despite that,
Mr Jenkins provided precisely the sort of information to
Post Office that he is being accused of having withheld.
This was an approach in 2012 on the part of both
Mr Singh and the Cartwright King lawyers which
Mr Atkinson, King's Counsel, described as "woefully
inadequate" or the antithesis of how an expert should
have been instructed.
Fourth, Mr Jenkins was also, in his purported
capacity as an expert, being asked to undertake
functions which were those of the prosecutor and which
he should not have been asked to do. I will deal with
disclosure as a separate topic but, for example, you
know, sir, that he was sent the Defence Case Statement
in Mrs Misra's case and, in Mr Ishaq's case, asked to
comment on it. That should never have happened. It is
the prosecutor who is charged with the statutory
obligation of considering disclosure in light of
a Defence Case Statement; it is not the duty of
awitness. You might think, sir, that that was just
another example of Post Office delegating to a witness
functions that were its.
Fifth, the unfairness of this approach, that is of
treating it as irrelevant that Mr Jenkins was not
98
it held about the operation of Horizon was retained and
recorded, and potentially revealed for the purposes of
the CPIA.
The second is Post Office's failures to make
properly considered and properly formulated third-party
disclosure applications to Fujitsu.
The third significant failure is that investigators
and prosecutors consistently did not discharge their
statutory obligations under the CPIA in individual
cases. In other words, that information or material
that fell to be included on unused schedules was not
recorded on, them, and was not disclosed to the defence.
This was a feature of every single case study in
which Mr Jenkins featured. Had that happened, had
drafts of his witness statements or communications with
him been listed on the unused schedule, then the picture
would be a profoundly different one.
The fourth, sir, is the failure on the part of every
Post Office investigator, lawyer and external lawyer in
the case studies, in which Mr Jenkins featured, to
discharge the obligations on a prosecutor where they
seek to rely on expert evidence.
Returning to Mr Jenkins and setting him against this
canvas. Well, despite his being a Fujitsu engineer,
despite his lack of experience, all of that, there was
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no recognition on the part of any lawyer that this made
it imperative that, if he was going to be relied upon as
an expert, that, first, he was actually instructed as
one; second, that he understood that his evidence had to
be independent, that he was providing evidence to the
court, not on behalf of Fujitsu or Post Office; that
this made him subject to the special expert duties.
What those duties were and how they applied to him and,
in particular, how the duty of disclosure might apply to
him and how he might go about discharging that duty.
As Mr Atkinson put it:
“Even with the professional expert witness, even if
you are singing to the choir, a prosecutor instructing
an expert should ensure that they understand these
duties to which they are subject."
Itis just extraordinary that no lawyer ever saw any
need to circumstances with Mr Jenkins the very distinct
and unusual position that he was being put into.
The instruction of an expert is usually a carefully
considered step in litigation, not undertaken lightly.
The discipline of drafting a letter of instruction means
that proper consideration is given to what the expert is
being asked to address. This isn't advanced lawyering,
this is the material of everyday work.
In 2005 and 2006, the subject of expert evidence had
101
that they saw no need to apply this law to their
prosecutions?
This may go to a point I understand my learned
friend Mr Moloney to make: that it is suggestive of some
sort of sense of exceptionalism. But whatever you might
conclude, sir, Post Office just didn't have this kind of
guidance. In fact, a series of investigators and
lawyers lined up to tell you that they did not know
about the duties on them when they instructed an expert.
Sir, I am going to deal, if I may swiftly, with some
matters of chronology.
Sir, first of all, as regards -- and I start in
2005, sorry, I should have said, with Mr Castleton's
case, and about the 2005 Bond Pearce letter. You'll
recall, sir, that this was a letter addressed to Fujitsu
in November 2005 and related to Mr Castleton's
proceedings. Time doesn't permit me to deal with that
at any length but I notice that none of the Core
Participants have sought to seriously contend that this
letter put Mr Jenkins on notice that expert duties
applied to him, still less that it would have meant that
he understood the content of expert duties, how they
applied to him and that he would have carried this
knowledge with him in the years to come.
It is dealt with in the written submissions on his
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been an intense focus on the part of the Court of
Appeal. Criminal lawyers had been reminded that the
Ikarian Reefer applied to criminal litigation. This in
turn had been reflected in the Criminal Procedure Rules
and, in March 2006, the CPS produced its own guidance
specific to how experts were to discharge the duties of
disclosure when they were instructed by the CPS, and
that guidance, pithy though it is, encapsulated core
concepts: concepts like recording, revealing and
retaining; it explained what unused material was; it
explained the requirement that the expert retain
everything that they generated in the course of their
work, for example explanations that they had been
provided with.
The CPS discharged its obligations to ensure that
the expert understood this by requiring them to sign
a declaration of understanding. Sir, if Post Office was
going to use powers of private prosecution against
subpostmasters, to do so routinely and knowing that it
put them at risk of conviction, of imprisonment, of
financial loss, why wasn't Post Office or its
prosecutors abiding by Court of Appeal judgments, by the
Criminal Procedure Rules, or promulgating this sort of
guidance? What does that say about the culture and
ethos of the organisation and the lawyers within it,
102
behalf but the fact alone that it was sent to Mr Jenkins
when it was not in contemplation that he would be
a witness may be the best indicator that it wouldn't
have seemed terribly significant to him at the time.
Sir, of course, in the Castleton litigation, it was
decided that Mr Jenkins would be a witness of fact, and
on that basis, Mr Dilley prepared a statement for him.
Mr Jenkins refused to agree to making this statement,
that there were no grounds for believing that the
problems that Mr Castleton said he experienced with his
computer would have caused either theoretical or real
losses. As Mr Jenkins noted on the statement, this was
not something he felt able to agree with, without
looking more closely at what had gone on.
Sir, this is a complete answer to the allegation
made by my learned friends Mr Moloney and Ms Patrick in
their written submissions: that Mr Jenkins had been
a party in Mr Castleton's case to Mr Pinder's obvious
attempt to remove ambiguity or nuance from Fujitsu's
message in that case, that the problem was not theirs
but the SPMs, or to avoid a close examination of the
data. It was exactly that, a close examination of the
data, which Mr Jenkins was advocating was needed in
Mr Castleton's case.
Sir, we have dealt with Mr Jenkins’ willingness to
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use the term "system failure" in Mr Thomas’ case and
that the opposition to it was entirely that of Mr Ward,
in written submissions, so I won't expand on that
orally. But, sir, I did wish, through Mr Thomas' case,
to make some submissions on the issue of the boilerplate
paragraphs.
Sir, we invite the Inquiry to consider with care any
claim that it was understood by Post Office lawyers or
investigators that the boilerplate paragraphs were
attesting to the integrity of the Horizon system. These
paragraphs were a standard part of every statement made
by Ms Lowther and Ms Thomas when they produced the ARQ
data. Ms Lowther and Ms Thomas were not technicians.
The idea that, by producing this ARQ data, which is
understood would normally have been for limited periods,
they would have understood themselves to be attesting to
the integrity of the entire system seems far fetched.
So the Inquiry did not hear from Ms Lowther and
Ms Thomas, so it has no direct evidence from them as to
what they understood the boilerplate passages to mean
and, in respect of Ms Thomas, this is particularly
significant, given that she wrote the Litigation Support
manuals in force at important times.
However, the evidence strongly suggests that these
apology plate passages related to their production of
105
Ms Thomas' line manager, Ms Munro's, understanding, in
her words, about the boilerplate paragraphs, was that
they were in regards to the audit workstations where
they retrieved the data from, rather than the integrity
of the Horizon system itself, how they pulled the data
off, rather than the Horizon system.
This was something that Mr Lenton, heavily involved
in the civil proceedings, also said:
"My understanding is that it's referring to the
audit retrieval system.
"You didn't understand it to be a generalised
comment about the integrity of the system?
"No."
Finally, Duncan Atkinson, King's Counsel, agreed
that the meaning of the boilerplate paragraphs was not
altogether clear, at least open to interpretation Sir,
if Mr Duncan Atkinson considers that they are open to
interpretation it should give real pause before the
conclusion that they are only capable of one meaning is
arrived at.
Returning to Mr Jenkins, the boilerplate paragraphs
were in the draft statement that Ms Lowther prepared for
him in Thomas. As he explained in his Inquiry
statement, having queried how he could include these
paragraphs when he had only been provided with the
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the ARQ data. Indeed, it's respectfully submitted, sir,
this must be correct. First, for the reason just
alluded to: that neither of them could possibly speak to
the overall integrity of the system, and sir, I use that
term cognisant of the fact that it's not a term of art
and it doesn't have a statutory meaning.
Ms Thomas and Ms Lowther could, however, speak to
the process by which they had extracted the ARQ data.
The standard statements producing the data set out the
processes which resulted in the data being stored in the
audit server and the processes, by which the ARQ data
was produced. In other words, the substantive content
of the statement was consistent with the ability of them
to attest to the production of the ARQ data.
The Fujitsu manuals provided for a detailed,
process-driven mechanism by which the ARQ data was to be
produced. The manuals did not provide at all for any
other process, which needed to be gone through in order
to make the boilerplate statements. It's unthinkable
that guidance intended to regulate the making of the
statement for producing ARQ data would make detailed
provision for that but not provide any guidance to
non-technicians as to how they were supposed to attest
to the overall working of the Horizon system.
You may not have heard from her but you do know that
106
spreadsheets of the zero transactions, he believes that
he would have spoken to Ms Lowther and Ms Thomas about
them. He sought to explain in his oral evidence what he
thought these paragraphs meant in his statement in
Mr Thomas' case, and he did explain that he thought the
paragraphs related to the computers involved in the
production of that, so not just the typing up, but
actually the extraction of the ARQ data as well.
Sir, asides the point in Mr Thomas' case that he was
‘only commenting on the zero transactions, Mr Jenkins was
emphatic that he would not have described the Horizon
system as a "computer". It simply wouldn't have made
any sense to him.
Sir, I turn then to Mrs Misra’s case.
What emerged clearly from the evidence in
Mrs Misra's case was that Mr Jenkins was being asked to
do three separate things: he was being asked to deal
with Post Office's disclosure obligations under the
CPIA, but never actually told that; he was being asked
to respond to Professor McLachlan's report; and he was
also being asked, in Mr Tatford's words, to assist
Professor McLachlan. Over time, those three things
became conflated and confused.
For all of the reasons set out in our written
submissions, insofar as Post Office sought to discharge
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its disclosure obligations through Mr Jenkins, this was
an impermissible delegation of its statutory duties.
But that aside, Post Office did not tell Mr Jenkins or
Fujitsu that it was doing this. It didn't explain to
him or Fujitsu what its disclosure obligations were. It
did not explain to him or to Fujitsu what might be
potentially relevant.
Relatedly, prosecutors did not address the capacity
in which they were using Mr Jenkins. Mr Tatford
conceded this: neither he nor Mr Singh confronted what
their reliance on Mr Jenkins amounted to. There was no
point at which this crystallised in Mrs Misra's case.
According to Mr Tatford, until Mr Jenkins came to
provide his final statement, he was not being treated as
an expert witness. This is what Mr Tatford called the
“muddled thinking" about Mr Jenkins' role, which, in his
words:
"... tarnished the thought process throughout
Mr Jenkins' instruction, and I regret that. It was
a mistake."
In an important passage of his evidence, he went on
to explain, when he was asked why none of the statements
had the necessary content to be expert statements, he
said that he thought that they should have been in all
of the statements and that he thought this at the point
109
with him, Mr Jenkins provided to Post Office the sort of
information it purported to be seeking. Mr Jenkins
provided information to prosecutors which was never
explored. Neither Mr Singh nor Mr Tatford asked any
questions when Mr Jenkins said he couldn't give a clear
answer to whether there were problems with Horizon.
They never asked any questions about the locking problem
which caused transactions to be lost, still less ensured
that this was recorded on the unused schedule. Neither
asked about the process about which Fujitsu checked NT
events.
Mr Singh and Mr Tatford were well aware that
Mr Jenkins didn't know anything about the Callendar
Square bug, but didn't ask what records Fujitsu kept of
previous issues that had affected accounts. It was
Mr Jenkins who had to press and press in the face of
resistance, that the ARQ data from Mrs Misra's branch be
obtained and that, for example, the full message store
be provided to Professor McLachlan.
The argument that he sought to withhold information
about bugs and problems in Horizon is wholly undermined
by the fact that he informed Professor McLachlan about
the Known Error Log and the 200,000 faults on the test
and live system. Mr Jenkins also informed the
prosecutors that Fujitsu might be able to provide
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at which the final statement was made.
He thought that the final statement should have
complied properly with the CPR but it didn't because
there was only two days left before trial.
Of course, sir, that statement did omit the
necessary content, and Mr Tatford's explanation doesn't
make much sense when one has regard to the fact that he
was able to make quite extensive comments on that draft
statement and suggest that Mr Jenkins say -- which
Mr Jenkins said no to -- that it was more likely that
Mrs Misra had stolen the money than that the loss could
be explained by computer error. Again, sir, you may
reflect on what that says about Mr Jenkins.
Also important in this regard is his concession
that, in seeking to change what Mr Jenkins said, that
this was not consistent with the concept of Mr Jenkins
as an expert evidence (sic).
Sir, you'll have in mind what Mr Tatford finally
said in his evidence: that he felt worse because it had
been quite clear in the way that the evidence was
properly put before him that there were many failings
that he had ignored on his part, and:
"... perhaps created a rosier version in my memory
that wasn't really there."
Sir, despite the series of defective communications
110
Professor McLachlan with the information about the
system changes sought in the disclosure request. By
18th August 2010, Mr Jenkins spoke to his colleagues
within Fujitsu and told them what he thought this
exercise would involve, including the collation of PEAKs
and change proposals. In other words, Mr Jenkins put
into motion the scoping exercise to provide Post Office
with all of the PEAKs related to the issues which had
required changes to be made to the counter.
This is precisely the sort of information which
Mr Jenkins is being criticised for not having provided,
yet it was there for the taking by Post Office, and the
only reason why it wasn't is because Post Office refused
the defence requests for disclosure of that information
in Mrs Misra's case.
Sir, I'm going to deal, finally, with the receipts
and payments mismatch bug, a bug that Mr Jenkins was
accused by Post Office of not disclosing. As this
Inquiry has uncovered, in fact Post Office lawyers were
well aware of it and decided that it did not need to be
disclosed in Mrs Misra's case. The Court of Appeal was
not told that.
Mr Jenkins was emphatic that, from his technical
perspective, a bug that occurred in Horizon Online in
2010 had no logical connection with Mrs Misra's case,
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that she experienced problems in Horizon in 2005 and
2006. His was the technician's perspective. The
Inquiry can now assess the position knowing that the
issue wasn't that Mr Jenkins concealed that bug from
Post Office. Indeed, it was well known about and the
options for remedying it within Post Office. It can
assess the position known that those statutorily charged
with making disclosure decisions elected not to disclose
it.
The main point which appeared to be put by my
learned friend Mr Henry, King's Counsel, about the
receipts and payments mismatch bug, in relation to
Mrs Misra's trial was that it wasn't disclosed because
it would have revealed the possibility of remote access.
Sir, that argument assumes that Mr Jenkins would
have thought that the fact that there was remote access
into Horizon meant that cases couldn't be prosecuted or
that revealing the fact of remote access would have had
a significant impact upon prosecutions.
There is no evidence that Mr Jenkins ever thought
this. Indeed, the fact that he made the statement in
the Wylie case in 2012, confirming that there was remote
access is to entirely opposite effect.
There is no evidence that he knew that remote access
was ever done in a way so that the SSC left no trace of
113
which could be served in any case in which Horizon was
raised -- as inconsistent with the duties of
a prosecutor because, fundamentally, it meant that
prosecutions were not being considered on a case-by-case
basis.
Mr Bowyer formulated the four questions that
Mr Jenkins was to answer. In order to answer these
questions, Mr Jenkins was sent the Helen Rose Report and
spreadsheet, in other words information that Post Office
had gathered about cases it had prosecuted in which
Horizon issues had been raised. It is wholly unclear
why anyone thought that Mr Jenkins should be providing
evidence about matters which were wholly within the
provenance of Post Office, and unconnected with him.
Again, you might think another attempt to delegate to
him matters for which Post Office was responsible.
In terms of the email that Mr Singh sent Mr Jenkins,
instructing him, so to speak, well, sir, that's the
email that you've already heard described as the
antithesis of how any expert should be approached.
Mr Jenkins provided his answers to the questions by
way of a technical Fujitsu report and sought the input
of others. However, they and he clearly understood that
it was to be expressed at quite a high level, reflected
in its content. Mr Jenkins provided the overview sought
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it in the audit trail. Mr Jenkins was sent a single
email by Mrs Chambers in 2006 when she mentioned access
at the counter. There's no reply from him and he's not
mentioned in the subsequent PEAK, but there's nothing in
that email to suggest that access at the counter meant
that the SSC obtained access and changed data but didn't
leave any trace of that in the audit trail.
In his paper, in the R&P mismatch bug, Mr Jenkins
set out a proposal for the correction of the data at
each branch and said:
"We need to agree a timetable with Post Office to
correct the other branches and ensure that this is
communicated with the branches to ensure that everyone
is happy."
Put shortly, Mr Jenkins foresaw a process of
correcting the bug as one which entailed the consent of
both the Post Office and the affected SPMs. His note
did not refer to any ongoing prosecutions, still less
any concerns about them.
Sir, I turn briefly then to 2012. Sir, there is no
doubt that the generic statement conceived by Mr Bowyer
of Cartwright King was part of a response to the
commission of the Second Sight review and that it was
poorly conceived. Mr Atkinson regarded the approach
taken -- in other words to formulate a general statement
114
as to how the Horizon system worked. He explained that
he had no knowledge of 21 of the cases that Ms Rose
referred to.
That report was in turn turned into the witness
statement and subject to editing by Post Office and
Cartwright King lawyers. In particular, the part of the
report that explained that Mr Jenkins didn't know about
the vast majority of cases that Ms Rose alluded to was
taken out.
Consistent with Mr Jenkins's report, the statement
continued to explain the Horizon system at a high level.
It explained the challenges to Horizon that Mr Jenkins
himself was familiar with. The evidence does
demonstrate that Mr Jenkins wasn't clear about the use
to which it was going to be put. Ms Jennings’
contemporaneous email of 19 October 2012 said that she
had put the statement into a Section 9 format, and that
she'd been in contact with Mr Jenkins, and that he
didn't know that it related to a specific case, and that
he wasn't aware that he would be required in court.
It was after this point that Mr Jenkins was
contacted by Ms Panter and told that she intended to use
his statement. It was in that email that she told
Mr Jenkins:
"It doesn't matter that you haven't mentioned
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a specific case in your report because there haven't
been any specific criticisms raised by any of the
defendants provided in my list of cases."
It's important to be clear, sir, that what
Mr Jenkins was being told by the prosecutors was that
his generic statement would be used in cases in which no
specific criticism of Horizon had been made.
Those representing the Hudgells Core Participants
submit that the generic statement itself demonstrates
that Mr Jenkins's position was always to start with
a set view of likely evidence but this isn't correct,
because the evidence in the Allen, Sefton and Nield and
Ishaq cases show that Mr Jenkins made clear when Post
Office were proposing using the generic statement,
having been told that no specific criticism was made,
that he pressed that ARQ data could be obtained for
those branches and what it might show.
In Mr Allen's case, he made clear to Mr Bolc that
the ARQ data could demonstrate exactly what had
happened. Mr Bolc understood that. He communicated to
Mr Bradshaw:
"Gareth tells me that it is in fact possible for him
to retrieve the actual data to see what actually
occurred in the branch."
But Mr Bolc said no to obtaining that data and,
117
Sir, I remind you again of what Mr Atkinson KC said
about this in his usual understated terms:
"Well, it's moderately remarkable to expect any
Witness, but certainly an expert witness, to deal with
complex issues and to try to narrow down those complex
issues with another expert, not knowing what the expert
said, not knowing what material they had seen, not being
able to check either anything that they had said or that
they have seen. I can't quite think how anyone thought
that was a good idea."
Sir, it's very hard to see how Mr Jenkins could be
responsible for what happened in the Ibbotson case. He
came to court and he did his best to deal with the
situation that confronted him.
Sir, may I end by saying this -- and, sir, you're
probably smiling at me because you know that my hour is
about up.
‘SIR WYN WILLIAMS: I have a very reliable time piece here,
Ms Dobbin.
MS DOBBIN: Maybe your reliable timekeeper will be slightly
less reliable --
‘SIR WYN WILLIAMS: I I'll allow you a conclusion --
MS DOBBIN: -- for a couple of minutes.
SIR WYN WILLIAMS: Don't let's lose time for you.
MS DOBBIN: Ofcourse. Sir, a public inquiry isn't a trial.
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similarly in the cases of Ms Sefton and Ms Nield,
Mr Jenkins suggested the issues that could be looked
into but, again, Mr Bolc rejected obtaining the audit
data.
In summary in these cases, despite being told that
they did not raise Horizon issues, Mr Jenkins went on to
explain what the ARQ data could be used for, and
Mr Atkinson observed of this that what Mr Jenkins was
offering to undertake would have been more in line with
Post Office's duties as a prosecutor, both in terms of
reasonable lines of inquiry and disclosure, and that
their refusal to do this was clearly a missed
opportunity for which little justification was offered.
Sir, I don't have time to deal with the disaster
that was the prosecution of Mr Ishaq but it says
everything about how Cartwright King conducted
prosecutions. It suffices for my part to remind you
today that Mr Jenkins was asked to turn up on the first
day of that trial in order to deal with a defence
expert, in circumstances where he had seen no defence
expert report and hadn't even been provided with any of
the materials that the defence expert had. He spent the
first day and night of the trial trying to ascertain the
extent to which he agreed with Ms Ibbotson's analysis as
to how the loss figure had been calculated.
118
The rules don't require allegations to be put to
witnesses. It's not unusual for different theories to
be put to witnesses or even inconsistent cases to be put
to witnesses by different Core Participants.
But, in respect of Mr Jenkins, if the allegation is
that he failed to disclose bugs or was part of an effort
to convey Horizon as infallible, or that he sought to
conceal that there was information available that would
reveal problems in Horizon, or to conceal that there
were investigations that could be carried out at
a branch to investigate what may have happened, then
those points are, in my respectful submission,
unsustainable, having regard to his consistent approach.
Starting in March 2006 with his being entirely happy
to use the language of "system error" in his statement
in Mr Thomas’ case, his genuine lack of understanding as
to why Mr Ward had any problem with the use of those
words, it's demonstrated by his providing an explanation
of the PEAK system in his draft statement in Mr Thomas’
case, explaining quite openly:
"Fujitsu have a fault management system called the
PEAK system which is used for passing faults around the
team and tracking faults raised regarding the Post
Office Account."
It's demonstrated by, in May 2006, his unwillingness
120
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The Post Office Horizon IT Inquiry 17 December 2024
1 to sign up to the language of Mr Dilley in
2 Mr Castleton's case, unless there had been
3 an examination of the data.
4 It's demonstrated in February 2010 by his absolute
5 insistence in Mrs Misra's case that the branch data be
6 obtained so that he and Professor McLachlan could
7 examine it, in the face of POL resistance that had been
8 going on for months by that point.
9 It's demonstrated again in February 2010 by his
10 immediate answer in Mrs Misra's case of whether there
"1 are known problems, that, yes, he could not make a clear
12 statement because transactions could be lost due to
13 locking issues.
14 It's demonstrated in March 2010 by his suggestions
15 at the end of his statement on 9 March about other
16 aspects of the data that could be looked at in
17 Mrs Misra's case.
18 It's demonstrated in July 2010 by the information
19 which Mr Jenkins gave to Professor McLachlan and which
20 led directly to the defence requests for the disclosure
21 of the Known Error Log, the system change requests, the
22 new release documentation, again by his guileless
23 reference to the fact that there were 200,000 faults in
24 the Horizon system.
25 It's demonstrated in August 2010 by the fact that
121
1 high level rough analysis of this stuff."
2 His concession that he had no way of knowing whether
3 money was lost due to theft and that he could not say
4 that any money had been lost in Mrs Misra's case.
5 It's demonstrated in September 2012 by his mindset
6 and approach towards Second Sight and openly discussing
7 bugs in Horizon and remote access with them.
8 It's demonstrated by what he said in the statement
9 in Ms Wylie's case.
10 It's demonstrated by his approach in October 2012
11 and February 2013 by his attempts to explain that there
12 was ARQ data that he was willing to examine and which
13 might show what had happened at the branches in
14 question.
15 Sir, Mr Jenkins was an engineer in a legal world.
16 He was navigating it without essential tools that he
17 ‘ought to have been provided with by Post Office and by
18 Fujitsu. Despite that and despite the obstacles put in
19 his path by lawyers, he took an honest technician's
20 approach: providing the information that Post Office
21 purported to want. The issue was not the lone expert.
22 It was Post Office and its lawyers.
23 SIRWYN WILLIAMS: Thank you.
24 MSDOBBIN: Sir, thank you.
25 SIRWYN WILLIAMS: We'll start again at 2.15 -- no, 2.20.
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Mr Jenkins was willing to undertake and set in motion
an assessment of what he thought could be provided to
the defence, including every counter release applied to
the live estate in the last seven years, a list of the
PEAKs, the change proposals that had been addressed in
that period. Again, I remind you, sir, it was Post
Office who refused to disclose that.
Itis demonstrated in October 2010 by his provision
of the PEAK in the Callendar Square case to Professor
McLachlan.
It's demonstrated again in October 2010 by his
objections to the changes that Mr Tatford had proposed
to his witness statement, including that he refused to
give an opinion to the effect that it was more likely
that Mrs Misra had stolen money than the loss being
explained by a computer error.
Itis demonstrated again by the evidence he gave at
Mrs Misra's trial which was modest and which made clear
its limits. It included his acceptance that there could
be Horizon issues that he didn't know about that could
have affected Mrs Misra's branch, given that he hadn't
known about Callendar Square.
His caveated response to the question whether he had
seen the slightest symptomatic of a computer fault at
West Byfleet, his answer: "I've been doing the sort of
122
No, I think 2.15 is okay.
2.15 for Mr Chapman.
(2.06 pm)
(A short break)
(2.17 pm)
SIR WYN WILLIAMS: = Mr Chapman.
Closing submissions by MR CHAPMAN
MR CHAPMAN: Sir, I make this closing statement on behalf of
the Department for Business and Trade.
THE STENOGRAPHER: = Your microphone is not on.
MR BEER: Sir, might I suggest that Mr Chapman swaps seats
and comes forward to the seat that Mr Moloney normally
occupies?
SIR WYN WILLIAMS: Far be it from me to think that Mr Henry
has deliberately muted him!
MR STEIN: Ms Pepper, can you confirm this one is working?
This one is?
MR CHAPMAN: Right? Is that better? Yes. Right, trying
again.
Sir, I make this closing statement on behalf of the
Department for Business and Trade. As the Department
has stated on many occasions in the course of this
Inquiry, in Parliament and elsewhere, the Horizon
scandal is truly appalling. No one in this room needs
reminding of the devastation to so many good people's
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The Post Office Horizon IT Inquiry
lives, the trashed reputations, the financial ruin, the
dreams unrealised, the chances lost, the families and
communities weakened and divided and, of course,
innocent and good people thrown in jail and, in those
especially tragic cases, driven to suicide.
The Post Office itself bears principal
responsibility for this scandal but it did not act
alone. Indeed, as a corporate body, the Post Office was
a manifestation of its people and the culture that they
inculpated and embodied. It acted in the despicable way
that it did because of the choices of those people,
individually and collectively.
This scandal involves a cast of characters from
inside and outside the Post Office, including, but by no
means limited to, the Post Office Board and Executives,
staff in its Branch Support, Communications, IT and
Security Investigation Teams, employees of Fujitsu, the
NFSP leadership, Central Government and its agencies
and, perhaps most invidiously and reprehensibly of all,
lawyers.
All contributed in their own way to this scandal,
for the Horizon scandal is not merely about hopelessly
buggy IT software, unchecked backdoors, poor quality
hardware, superficial training and a helpline that
provide anything but help. Those were certainly causes
125
relation to Horizon and, ultimately, it failed to
escalate and expose the right information to the right
people in Government.
The Shareholder Executive, ShEx, was, until 2016,
a Directorate within the Department itself and,
therefore, the Department must accept direct
responsibility for ShEx's failures, whether structural
or individual.
The fact that ShEx's functions were assumed by UKGI
in 2016 does not absolve the Department of
responsibility for mistakes after that point. The
Department recognises that it retained ultimate
responsibility for overseeing the Post Office, and that
it was ultimately responsible and accountable for the
arrangements in place for doing so. That the Department
delegated its responsibilities to UKGI, which acted
essentially as its adviser and agent, does not change
that fact.
Similarly, the Department recognises that a focus on
the organisational niceties within Government may give
the appearance of shabby internal buck passing. It's
essential, of course, for the Inquiry to consider
carefully the organisational mechanics that allowed this
scandal to happen so that the right lessons can be
learned for the future. However, as the only Central
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but they were not the only causes, for the Horizon
scandal is also a story of false assurances; of
a culture of secrecy, of spin doctors; of untruths and
half-truths repeated as mantra to Board members,
Officials, ministers, MPs and the Great British public,
of institutional and individual arrogance, incompetence,
dishonesty and cover-up; of misleading official advice;
of false testimony; of disclosure failures; of bad
lawyers.
Most of all, perhaps, it's a story which has its
origins in Post Office's corporate attitude of contempt
for the very people who were the face and the heart of
the institution.
The Department does not attempt to shirk its share
of responsibility for the mistakes which allowed this
scandal to happen. As the Post Office's sole
shareholder, the Department recognises that it is
ultimately accountable for the actions perpetrated by
the Post Office. The simple and inescapable truth is
that it failed to prevent this scandal from happening.
And the Department is responsible for the system of
oversight over the Post Office which was in place. For
reasons which have been thoroughly explored by the
Inquiry, and which I'll go on to address, that system
failed to provide adequate scrutiny and challenge in
126
Government Department with Core Participant status in
this Inquiry, the Department wishes me to state clearly
and unequivocally that wherever within this
organisational structure the finger of blame may point,
be that the Post Office, ShEx, UKGI or the Department
itself, the Government accepts ultimate responsibility.
The Department has offered its sincere apologies for
its role in this dreadful scandal. Whilst its
recognition of these failures cannot change nor atone
for the devastation inflicted on postmasters and their
families, the Department hopes that its and the
Government's genuine commitment to learning the lessons
of this tragedy will go a long way to preventing its
recurrence in future.
The eight issues that I intend to address in this
closing statement are, in turn: procurement development
and rollout of the Horizon IT system; the organisational
structures for management, governance, oversight and
accountability; breaches of trust and the duty of
candour; the culture of the Post Office; ShEx and UKGI's
two-hatted role and the perception of conflict; the
broader legal and regulatory ecosystem; redress and
cultural transformation.
I turn first and relatively briefly to the birth of
Horizon, its procurement, development and rollout.
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As you'll remember, sir, several departmental and
other Central Government witnesses gave written and oral
evidence to the Inquiry during Phase 2 and the
Department provided a detailed written closing statement
at the end of that phase of the Inquiry.
From the Department's perspective, the main
headlines to emerge from that evidence were as follows:
first, during the 1990s it was almost universally
recognised and accepted that the development of
an integrated electronic point of sale and accounting
system was absolutely necessary to preserve the Post
Office Network and the livelihoods of postmasters. The
underlying aims and objectives of the Horizon project
were readily understandable and indeed laudable. But
there were serious problems from the outset in the way
in which the Horizon project was organised, in large
measures from failing to agree on specifications at
an early enough strange. The three-way contractual
relationship led to predictable difficulties with each
of the contracting parties, the Post Office, the
Benefits Agency and ICL Fujitsu, having different and
not easily reconcilable ambitions for the system.
As Sir Adrian Montague explained when giving
evidence to the Inquiry:
"The PFI contractual relationship was a poor fit for
129
Byers described as a blank cheque going forward, and
they did not merely leave it to the Post Office to
ensure that its new IT system would work. It was for
this reason that they, ministers, insisted, despite Post
Office resistance, on a live trial in 300 post offices
before contractual acceptance. They also set up the
Horizon Working Group with the specific purpose of
hearing the voice from the frontline, a forum for
postmasters through the representative bodies and other
stakeholders to raise technical and practical problems
with Horizon directly with Government ministers.
These were sensible measures and could have had
a genuinely revelatory role, and it is surprising and
regrettable, to put it lightly, that the NFSP leadership
chose not to alert the Government to their members’
concerns about bugs and other technical problems in the
Working Group or elsewhere.
Its failure to do so defeated the whole purpose of
the Working Group and actively provided real and
material, but false, reassurance to the Government, and
the NFSP continued to act as a vocal defender of Horizon
cover the years that followed.
When, in late 1999, the then Minister Alan Johnson
was informed of issues with Horizon's system ability,
accounting integrity and support, he immediately
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any IT procurement, especially one of this scale and
complexity, and really required much more detail and
specificity than was in the Horizon contract. And the
fact that the requirements for Horizon changed
materially during the development phase, the biggest
example being the cancellation of the Benefit Payments
Card functionality, was symptomatic and undermined the
smooth running and delivery of the project from early
on."
But none of this meant that Horizon was
irredeemable. As the expert reports commissioned by the
Government at the time made clear, the project remained,
to quote, "technically viable". Sir Adrian Montague
explained that this meant it was possible to develop the
system so it met the specification at the point it was
to be rolled out and, as Lord Mandelson stated in
evidence:
"The alternative to progressing with Horizon was
very unclear, technically and financially and it was
accepted that cancellation would have been a significant
setback to the modernisation of the Post Office.”
So, armed with this knowledge, pressing on with the
project made sense at the time.
However, ministers realised the experts weren't
given what they'd described as ~- or what's Stephen
130
intervened and had rollout paused for an extended period
so that the issues could be resolved. It did not
recommence until he was given assurances that these
issues had been or were being resolved satisfactorily.
Sir lan McCartney and David Sibbick both considered,
with the benefit of hindsight, that on an IT project of
this size and complexity, the Government should have
commissioned a further independent and expert review to
confirm that Horizon was indeed fit for purpose at the
point of rollout.
That may well be right and, clearly, in the
hindsight knowledge that Horizon was not fit for purpose
at the point of rollout, a further expert report or
reports may well have help expose and resolve problems
at that stage.
At the same time, of course, the line needs drawing
somewhere. The Inquiry will no doubt wish to evaluate
whether the information available to the Government at
the time should necessarily have led it to commission
such further reports with the attendant further delays
and uncertainty for postmasters. There was here
a balance.
The procurement development and rollout of Horizon
took place in the very early days of PFI Government IT
projects, and it's not the only Government IT project
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ever to have gone wrong. Whilst it's clear that many
lessons have been learnt along the way with many success
stories, the Passport Office being a good recent
example, IT procurement and development in Government
remain difficult and complex.
The history of the Post Office's project to replace
Horizon, despite the shortened arm and more intensive
Government scrutiny of the Post Office over these past
few years, is a good illustration of things going wrong,
though, of course, that's a project managed by Post
Office and not Central Government directly.
For now, the point is that the Government realises
that it needs to look hard at where things have gone
wrong in some of its major IT projects, including
Horizon, and to think creatively as part of a nonstop
effort to improve.
Pat McFadden, Chancellor of the Duchy of Lancaster,
commented in his UCL speech last week about the benefits
of the small scale, nimble and enterprising test and
learn approach favoured by successful private tech.
That may of one possible solution. The Government would
welcome other ideas.
I turn next to the organisational structure, in
other words the formal systems of Post Office
management, governance, oversight and lines of
133
witnesses that the arm's-length model remains the only
sensible option for the Post Office, for so long as it
remains in public ownership. The Department agrees.
The arms-length legislative arrangement implied
a presumptive starting point that ministers should not
get involved in operational matters. The Department's
view is that, as a starting point, that was good and
sensible and indeed necessary. But ShEx/UKGI officials
were wrong to treat this as inflexible dogma. It was
always open to ministers to scrutinise and challenge the
way the Post Office was conducting its operations and to
use the levers that were available to them, if they were
unhappy with what they saw.
The general trust of the evidence is that ministers
understood this and did get engaged whenever they
thought it appropriate, based on the information
available to them. As I'll go on to explore, the
‘operative problem was not some arid concept of strict
strategic operational divide: it was that the ministers
were not given the information they needed, and so did
not realise there was a problem that required their
attention. In fact, they were consistently managed,
misled and deceived.
Ministers sat towards the top of a pyramidal
structure of management, governance, oversight and
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accountability, including in relation to the management
of risks. As Mr Sheldon said yesterday, the importance
of this issue is difficult to overstate, though we
realise not altogether exciting.
The Department set out in some detail its
observations on the structure that was in place during
this scandal, and I don't intend to rehearse those
observations in very great detail now. I can summarise
it as follows, starting with the arm’s-length
arrangement. For over half a century, the Post Office
has existed at arm's length from Government. With the
passage of the Postal Services Act 2000, Parliament
decided to maintain and indeed strengthen through
legislation the Post Office's operational independence
free of Government interference.
The autonomy and independence given to the Post
Office was and remains a specific Parliamentary
objective, for which the practical and principled
reasons are readily apparent: first, that ministers have
neither the time nor, generally, the expertise to get
involved in running large and complex commercial
organisations such as the Post Office; and, second, to
enable the Post Office to operate as a commercial
business free of incessant Government interference.
There was almost universal consensus amongst
134
accountable, typical of and necessary in any large and
complex organisation.
At the bottom of that pyramid were central Post
Office employees, for example, members of its Branch
Support, Communications, IT and Security Investigation
Teams.
They reported to and were managed through a number
of increasingly senior management tiers, up to,
ultimately, the Post Office Executive Team, led by the
CEO; the Executive Team were overseen by the Post Office
Board of Directors; the Post Office Board of Directors
was, until 2012, overseen by the Royal Mail Board of
Directors; the Post Office and/or Royal Mail Board of
Directors was overseen by the Shareholder Team at the
Government's Corporate Governance Centre of
Excellence -- first ShEx and, thereafter, UKGI; ShEx
UKGI reported, in relation to the Post Office, to the
junior minister and in extremis to the Secretary of
State; and ministers and the Secretary of State were
scrutinised by and accountable to Parliament and,
through Parliament, the British public.
This was not a system that lacked tiers of oversight
and, in common with the witnesses who spoke about this
structure, the Department believes that these
arrangements were broadly appropriate with one caveat
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that I'll come on to later. But there are two really
critical points here. First, the Post Office Board of
Directors was and remains the body with principal and
direct responsibility for overseeing the activities of
the Post Office. This was the clear and consistent view
of the Inquiry's own experts and of the senior UKGI
witnesses.
Each additional tier of oversight, in turn
ShEx/UKGI, ministers and Parliament, has an increasingly
high-level role inherent in the increasingly wide range
of responsibilities falling within their domain, and
their job is not to redo, review or second-guess all of
the work of each of the tiers below them.
As for the ministers, the evidence indicates that
they are busy to an extent and with such a range of
issues that is almost impossible for most of us to
imagine. Their role was essentially to satisfy
themselves that an appropriate structure was in place
beneath them, and then to decide, based on the
information available to them, where to focus their own
time on the issues arising across their portfolio.
Second, any organisation depends on honest and
truthful flows of information, up through the lines of
management and oversight and, as part of that, it
requires honest and truthful information in response to
137
with ShEx/UKGI in its devolved role as corporate
governance experts and shareholder representative.
This reservation arises with hindsight. Several
witnesses have observed how simply putting in place more
tiers of oversight is not a panacea and, indeed, may in
many cases, act as a hindrance to good governance.
Dame Sandra Dawson emphasised more than once the
downsides to multiple governance and oversight tiers and
the importance of the unitary Board of Directors taking
proper ownership and accountability for the company.
Sir Martin Donnelly explained that: "When you have
the level of complexity that we're dealing with, you
have to be able to empower people to take decisions and
follow them through in a structure because, otherwise,
you're not going to get effective outcomes, and that the
challenge of adding additional layers as if you do not
have additional information on which to base your
challenge, it can merely add bureaucracy and actually
make it more difficult to get at the truth.”
But it's also clear, in retrospect, that additional
oversight of the Post Office from a departmental Policy
Team may have led to greater or more astute scrutiny and
challenge of the Post Office and uncovered some of the
problems where ShEx/UKGI did not.
The creation in 2018 of the Policy Team within the
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scrutiny and challenge from the tiers above.
Sir Ed Davey expressed the point as follows:
“Our system of Government is essentially built on
the assumption that people in positions of trust, such
as the leadership of the Post Office, tell the truth."
The right to expect timely and accurate information
should be self-evident and was emphasised time and again
by the various witnesses, including senior UKGI
officials, permanent secretaries, ministers and
Secretaries of State, and the Inquiry's governance
experts.
Governance and oversight structures can only do so
much. As Dame Sandra Dawson put the point:
"A framework cannot control the behaviour. It sets
the boundaries and sets the expectations."
Sir Alex Chisholm made the same point more directly:
"No structural solution [he said] can fully deal
with the realities of the situation which depend on the
quality of the people you have in there and their
dealings with each other."
I said before that there was a caveat to the
Department's view that the overall governance and
oversight system was the right one. Its reservation
relates to the absence at the relevant times of
an internal departmental Policy Unit working in parallel
138
core department has been a positive development,
providing, as it does, a cadre of dedicated civil
servants who work alongside UKGI to provide additional
scrutiny and challenge to the Post Office.
It is common ground, then, that this system
necessarily depended on individuals acting in good
faith, providing honest and truthful information up the
chain. The evidence heard by the Inquiry indicates that
the Post Office and several of its senior people were,
at best, recklessly indifferent to the truth and, at
worst, culpably dishonest.
Time and again, the Post Office provided materially
false, misleading, or incomplete information to
Government ministers, to Parliament, to the criminal
courts and to the British public at large and,
frequently, especially before mid-2018, the officials
from ShEx/UKGI whose job it was to scrutinise and
challenge the Post Office at the tier above the Board,
identify and surface risks and provide impartial,
objective and well-researched information and advice to
ministers, appear to have done not much more than repeat
what the Post Office told them.
The evidence is well known to the Inquiry, so
I refer briefly to just a small handful of the many,
many examples where ministers were provided with
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misleading or untruthful information.
You'll remember Sir Ed Davey receiving a briefing
from ShEx officials based on information provided by the
Post Office to ShEx, which assured him that Horizon had
proved robust, that there were no systemic integrity
issues, that the unions had expressed confidence in
Horizon, that there was proper training, that there were
proper audit processes and no back doors, that there'd
been regular reviews, there was an appeals process and
legal representation, and that no court had ever found
problems with Horizon. Much of that was, of course,
untrue.
Following Sir Ed Davey's meeting with Sir Alan
Bates, he, Sir Ed, asked ShEx officials for further
information on each of the issues Sir Alan raised. In
response the Post Office gave ShEx definitive but false
assurances, including that Horizon is fully robust, that
its integrity and sound basis have been demonstrated
over many years and that the JFSA's allegations were
unsubstantiated.
Each of those assurances would appear to bear the
hallmarks, we suggest, of the Post Office's
Communications Team. ShEx passed these assurances on to
the Minister and drafted a letter for him along the same
lines. These assurances included untrue statements that
141
the inner workings of Government. Jo Swinson was at
times memorably apoplectic when, during her evidence,
she was shown documents that she'd never seen or been
given access to during her time as Minister.
Sir Ed Davey and Margot James were more restrained
but nevertheless clear, in their view, that they were
not given the sort of accurate, reasonably complete and
balanced information that they were entitled to expect.
While other ministers questioned and sought further
information and assurances, Baroness Neville-Rolfe was
in the minority in having had doubts at the time about
what she was being told. She said: "By this time
[August 2015], I'd lost confidence in the quality of
ShEx's advice. We were going round in circles and they
were unwilling to engage with the issues in the way
I felt they needed to. In my view, ShEx had lost
objectivity and its officials were unable or unwilling
to scrutinise POL properly, even though that was
an essential part of their role. The advice they gave
seemed close minded, deaf to the issues and constantly
repeating the same mantra. As time went by, I felt as
though they were trying to obstruct or shut down my
efforts to get to grips with the issues."
Ministers understand that one of their roles is to
scrutinise and challenge but the evidence demonstrates
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there was no remote access and proper independent audit
logs.
Paula Vennells gave Jo Swinson the explicit
assurance, in writing and to her face, that the Post
Office was compliant with its post-conviction duty of
disclosure and that there was no reason to conclude any
prosecutions were unsafe. There was no mention of the
Clarke Advice. The assurance was false.
Baroness Neville-Rolfe was given a misleading
summary of Second Sight's conclusions and, by Tim
Parker, a misleading summary of the progress of the
review he had commissioned at her instigation, and
a misleading summary of Jonathan Swift KC's most damning
findings. Nor did Tim Parker ever inform her or her
ministerial successors, that the continuing work he'd
promised as part of his review had been shelved.
More generally, ministers were never told about such
crucial pieces of information as contained in, for
example, Jason Coyne's expert report in the Julie
Wolstenholme prosecution, the Helen Rose Report, or the
Clarke Advice, to name just a few examples.
Ministers of different political stripes were
vocally critical of some of the information and advice
provided to them by officials and ShEx/UKGI. Their
evidence provided an unvarnished and candid insight into
142
it's totally unrealistic to think that they can
challenge more than a small fraction of the information
and advice provided to them on a daily basis.
Ministers’ offices received vast quantities of
correspondence from other MPs, constituents and
stakeholders raising a wide variety of issues, concerns,
complaints and requests for action, much of which would
never be put before the minister themselves. The
trickle of correspondence in relation to Horizon was
a tiny proportion of the total.
So ministers are necessarily, to a very large
extent, reliant on officials to highlight the
correspondence and other information they need to focus
‘on, and the inevitable result of the consistently
misleading information, partial advice and false
assurances given to ministers by the Post Office, via
ShEx/UKGI, essentially being told, "Nothing to see
here", was that these busy ministers, by and large,
focused on the issues in other areas of their portfolio
which were seemingly in greater need of their attention.
All the ministers explained how their usual
experience was that civil servants acted with
appropriate objectivity. But the Department agrees with
UKGI that there were certainly occasions on which
ShEx/UKGI advice to ministers was insufficiently
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objective.
This is not the only public inquiry to reveal
evidence of officials falling short of the expectation
that they act in accordance with the Nolan Principles.
We refer in our written closing statement to the
Infected Blood Inquiry and the Magnox Inquiry, and there
are other examples, perhaps, most obviously,
Hillsborough.
It's also obvious that the Department's clear
expectation that the Post Office would ensure that its
staff too acted with candour and consistently with the
Nolan Principles was misplaced. The Government realises
it needs to look again at how appropriately high
standards of conduct are observed at its public
corporations and other arm's-length bodies.
It will be for the Inquiry to identify the reasons
why accurate and objective information was in such short
supply. I will, in due course, offer some suggestions
as to some of the causes, and the Department would
welcome suggestions that the Inquiry has for
improvements in the future.
As you know, sir, the Government has committed to
putting forward legislation to introduce a new statutory
duty of candour, backed up by criminal sanctions. That
was one of the recommendations of Sir Brian Langstaff's
145
symptoms of groupthink and draw attention to the
findings and recommendations of other recent public
inquiries in this respect.
It is regrettable, to say the least, that ministers
were never informed of these profound cultural problems.
Likewise, Jo Swinson was understandably aggrieved that
the Post Office Board's and ShEx officials’ shared
concerns over Paula Vennells' aptitude and performance
as CEO were never drawn to her or any other ministers’
attention.
lI return to the theme of culture and cultural
transformation in due course.
Asecond theme is the extent to which ShEx/UKGI
Officials saw it as their role to scrutinise and
challenge the Post Office. Clearly, that was their role
on behalf of the Department but it seems this was not
always clearly understood and acted upon by all relevant
Officials.
As a responsible and self-critical public body, UKGI
has clearly reflected on the reasons why that may have
been the case. The Department agrees with UKGI's
observations and adds any the following:
First, we strongly agree that the starting point is
that ShEx/UKGI officials were entitled to place
substantial reliance on the information and assurances
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Infected Blood Inquiry report, in turn, a development of
‘one of the recommendations of Bishop James Jones' report
into the Hillsborough disaster. The Department
presently sees no reason in principle why this duty of
candour should not extend to public corporations like
the Post Office and, indeed, across Government.
So, what were the reasons why justifiable
expectations of candour were frustrated in the course of
this scandal? The starting point -- as Alisdair Cameron
put it, "the original sin" -- was, we suggest, the Post
Office's institutional culture. It was a culture which
seemingly tolerated indifference to the truth and
a culture, embodied in its Postmaster Contracts which
looked down on, mistrusted and exploited postmasters.
The Inquiry will form its own view of the Executive
and Board level culture in the Post Office at relevant
times. The evidence may suggest that it was, at least
some stages, weak, arrogant, unintelligent, defensive,
incurious and close minded, with far too much emphasis
on internal consensus, too little space for internal
challenge and firm resistance to any external scrutiny.
We suggest in our written closing statement that
this was an institution which was, at Board and
Executive level, badly infected by groupthink. In our
written closing statement, we discuss the causes and
146
provided to it by the Post Office.
As Sir Stephen Lovegrove observed:
"It's not ShEx/UKGI's role to challenge everything
they are told."
At the same time, clearly there was a need for
ShEx/UKGI officials to review the available information
and ensure that the advice and information they provided
to ministers was clear as to its sources. As Baroness
Neville-Rolfe stated:
"If Ihad been my previous self as civil servant
sitting in that seat, I would have gone away and I would
have read the whole of the Second Sight Report and
I would have gone through all of the negative findings,
understanding what was right and what it was wrong.
That wasn't done. What they did was take advice from
the Post Office because they felt the Post Office could
give the answers, and that isn't what you do. As a good
civil servant, you bring -- you look at different -- you
know, you look at different sources."
Second, the evidence indicates that the two-hatted
role as a NED on the one hand and as a shareholder
representative on the other, may have led some ShEx/UKGI
Officials to perceive that there was a conflict as
between their duties to the shareholder and their duties
as a Companies Act director. It appears that this may
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have led to confusion as to the importance of
independent scrutiny and challenge, and the importance
of providing independent, objective, and impartial
advice and information to ministers.
The Department notes that the IOD -- the Institute
of Directors -- in its recent report, concluded that at
times, the two-hatted role may have led to confusion,
and suggested that the parameters of the Shareholder NED
role should be reconsidered.
Third, the Inquiry heard evidence which may suggest
that the confusion which flowed from this two-hatted
role, if indeed it did flow from the two-hatted role,
led the Shareholder NED at times to increase
susceptibility to the Post Office's own groupthink and
acceptance of the Post Office's internal norms. For
example, Jo Swinson suggested that Richard Callard had
gone native and Baroness Neville-Rolfe suggested that
the Shareholder Team led by Mr Callard had lost
objectivity.
Fourth, many ShEx/UKGI staff do not or at least did
not have classic Civil Service backgrounds. Given its
highly-specialist work, that's perfectly understandable,
but the evidence may have tended to suggest, as is
hardly surprising, that may have meant the Nolan
Principles as expressed in the Civil Service Code were
149
exist ina vacuum. They all formed part of a broader
legal, regulatory and indeed ethical ecosystem.
That ecosystem includes not only the Financial
Reporting Council Code and the Civil Service Code, but
also the Companies Act, employment and disciplinary law,
the criminal law and the criminal justice system and
professional regulation, including, as relevant, the
regulation of solicitors and barristers. In a healthy
society, it also includes ordinary codes of morally
acceptable behaviour.
That ecosystem serves to drive high standards of
behaviour and deter inappropriate behaviour. It
cumulatively failed in those objectives here with
catastrophic results. The question is: why? One answer
may be that the jeopardy for improper behaviour,
breaches of professional codes, breaches of criminal
law, was insufficiently serious. As I've mentioned, the
Government has committed to give sharper teeth to the
Nolan Principles through the new statutory duty of
candour backed up by criminal sanctions.
As the Department described in its written closing
statement, the role played by lawyers in this scandal
was particularly deplorable. The regularity and
seriousness of disclosure failings is astonishing.
Ministers quite justifiably placed real weight on the
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not always so deeply ingrained. This was a point made
by Baroness Neville-Rolfe.
In addition, the early Shareholder NEDs indicated
that they were given almost no training in this
inherently difficult role. The Department therefore
warmly welcomes the improvements that UKGI has made to
its operations in the wake of this scandal, including
but certainly not limited to, improved recruitment and
training and embedding with greater force the importance
of the Civil Service Code.
The Department is clear in its view that a Centre of
Excellence for corporate governance within Government
remains essential.
The Department also recognises that, had the
Department had its own Post Office Policy Team at the
relevant times this would have provided an additional
mechanism to scrutinise and challenge the Post Office
and thereby reduce the Government ministers’ reliance on
ShEx/UKGI.
In our written closing submissions, we make the
point that the management, governance and oversight
structures that were in place did not exist ina vacuum.
In the same way, the justified expectation of, and
entitlement to, honest and truthful information and
advice in accordance with the Nolan Principles did not
150
assurances that the Post Office had always complied with
its duties of disclosure to the criminal courts.
And the evidence of the role played by lawyers in
misusing and abusing the important principle of legal
professional privilege to evade external scrutiny was
eye opening. But the Inquiry has also seen evidence
which may suggest that the Post Office leadership set
a culture which was critical of lawyers who deigned to
place their professional integrity above the interests
of the business.
You'll recall Paula Vennells' extraordinary
September 2013 note. The Government has heard the
submissions made by the Hudgells Core Participant group
concerning the regulation of lawyers and will welcome
any recommendations that the Inquiry has in that
respect.
I next turn to address relatively briefly the issue
of redress.
I start by restating the Department's position that
it has worked very hard and in good faith to ensure that
full, fair and prompt redress is paid to the Post
Office's victims. There's been no lack of effort. But
the Department realises that this has been too slow for
many postmasters and their families, and it is acutely
conscious that the list of those who have tragically
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passed away before receiving full and fair redress
continues to grow.
In its written closing statement, the Department has
set out its position on redress in some detail, and
I won't repeat that now. Instead, I'll use my time to
address some of the bigger themes that emerge from the
evidence in relation to redress.
The first is to pick up a point made by number of
witnesses and indeed by the National Audit Office in its
Government Compensation Schemes Lesson Learnt Report
published in July of this year, that is that there is
presently no centre of expertise within Government to
provide guidance, expertise, or a framework for public
bodies seeking to set up a compensation scheme. This
means that each new compensation scheme involves a newly
reinvented wheel or, once a compensation scheme has been
launched, rebuilding the plane whilst flying it, to
paraphrase Sarah Munby’s evidence.
The second point, related to that first point, is
that it's easy in hindsight to criticise
an incrementalist approach to compensation scheme design
and delivery because, as Sarah Munby described:
"There's a tendency to assume that it was possible
to build a perfect scheme in the first place."
‘As Sarah Munby explained, the least bad option is
153
Government as a whole has approached redress. It acted
to go behind the GLO settlement by creating the GLO
compensation scheme and, ultimately, secured primary
legislation to ensure the continuing power to pay.
It found creative solutions to speed up redress,
most obviously fixed-sum offers, which were a novel and
genuinely game-changing development and it promoted the
controversial and ground speaking legislation, resulting
in the mass exoneration of mass postmasters convicted of
Horizon offences.
These were not small things and they were not
well-worn solutions.
As a mark of its seriousness, the Government has set
aside funding of £1.8 billion which the Treasury has
publicly confirmed is not a limit, and it has so far
paid out around £0.5 billion in financial redress.
These are big sums and the Department is proactively
looking to identify gaps in the existence schemes. The
Government is pleased that Fujitsu has recognised that
it must share the responsibility for meeting the costs
of the scandal. The Horizon Compensation Advisory
Board's paper on the future of redress goes further than
the National Audit Office's report. As well as
advocating an independent body to deliver redress, it
proposes that that body should have a role in monitoring
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often to get going and make changes later, rather than
attempting to design the perfect scheme to start with.
There's an element here of the test-and-learn approach
suggested by Pat McFadden. Of course, so much the
better if the initial design, even if imperfect, were to
benefit from expert input of the type proposed by the
NAO.
Third, the Department has regularly, proactively and
constructively engaged with the postmasters’
representatives and has regularly made improvements to
the schemes in line with their suggestions. It's set up
the Horizon Compensation Advisory Board, which has
played a hugely important roll. It involved the
representatives of the postmasters in the design of the
Group Litigation Order Scheme and the Horizon
Convictions Redress Scheme from the outset, and it will
continue with this process of engagement and incremental
improvement in furtherance of those aims, full fair and
prompt, out of the glare of this Inquiry.
Fourth, whilst Sarah Munby and Kemi Badenoch
suggested a lack of creativity in the Government's
response, and we note the Hudgell Core Participant Group
refer to a business as usual approach in their written
closing statement, there has, in fact, at times been
genuine innovation in the way the Department and the
154
the behaviour of Government organisations through
looking at both unresolved complaints and management
information.
The Government would welcome the Inquiry's view on
this point.
The Department recognises that there is still much
work to be done. It realises that every day that
postmasters and their families continue to wait for full
and fair financial redress is a day too long. It will
continue to work hard to make improvements to the
schemes, in the interests of ensuring full and fair
compensation is paid as quickly as possible.
It publishes regular progress reports, it's subject
to ongoing Select Committee and other Parliamentary
scrutiny. For example, the Minister has just today made
a further statement to Parliament, a written ministerial
statement.
The Department would, of course, be happy to provide
further updates to the Inquiry for as long as you would
find that helpful, sir, and it will welcome the
Inquiry's recommendations on how to improve the system
by which Government provides redress and compensation
for the future.
Finally, sir, I return to the critical matter of
culture and cultural transformation at the Post Office.
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The evidence heard by the Inquiry has indicated that the
profound cultural problems at the Post Office have
existed over decades. The Department has recognised the
need for a complete reset of the Post Office's culture
and a rebalancing of its corporate mission.
Together with UKGI and the Post Office Board, the
Department has taken real and material steps to improve
the culture: an example is the innovation of Postmaster
NEDs. But cultural transformation of a large and
complex organisation like the Post Office, with such
deep rooted problems, takes time. Whilst the Department
has seen signs that the culture is genuinely improving,
serious problems have remained.
Without attempting to provide an exhaustive list,
this is clear from the YouGov evidence, the evidence of
Saf Ismail and Elliot Jacobs, the evidence about the
untouchables, the executive bonus metrics, the history
of the Horizon replacement project, and the
circumstances leading to and following the dismissal of
Henry Staunton.
Clearly, the Post Office has remained an institution
under real stress. Changing the culture of a large and
complex organisation like the Post Office is not easy
and there have been and will be choppy waters to be
navigated but there are reasons to be optimistic.
157
making Board appointments.
As the Minister Gareth Thomas and the Secretary of
State Jonathan Reynolds explained in their evidence to
the Inquiry, the Government wishes to facilitate
a wide-ranging conversation about the future of the Post
Office and its culture, which includes the perspectives
of the public at large.
It recognises that profound questions about the
future model of the Post Office should not be kicked
down the road any further. That is why the Department
has committed to publishing a Green Paper in the first
half of next year, which will seek views on a range of
different proposals for a future Post Office Network.
The Department urges all those with an interest in
a future in which the Post Office and its postmasters
can flourish to respond to that consultation.
In sum, the Government does not accept that the Post
Office is not worth saving. To the contrary, it is
essential that the Post Office is able, once again, to
take its proper role as a trusted and trustworthy
institution at the centre of our national life.
Sir, the Department remains committed to learning
from the Horizon scandal in the interests of preventing
anything similar happening in the future. It will
continue to reflect on the evidence that has been heard
159
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
RYOUNRNNNBSBaean anne
BSRESNVSSSUSHBRSRIS
17 December 2024
The Department has faith that, under Nigel Railton's
leadership as Chair, the Post Office is heading in the
right direction and the Department endorses and supports
his efforts towards a renewed and rebalanced Post
Office. He has set a new tone at the top of the
organisation, giving a clear vision of a future Post
Office with postmasters at its centre. He has also
started implementing the recommendations of the Grant
Thornton report, in relation to Board effectiveness.
The Inquiry has heard evidence that there has been
a noticeable improvement in the working relationships at
Board level, more streamlined governance arrangements
and much better communication with Government and the
Government hopes and expects that the new statutory duty
of candour will help to drive improved standards across
the Post Office. Mr Railton needs time, and he needs
the support of the Department.
New appointments to the Board will be crucial. The
Department, with UKGI's assistance, is making progress
in appointing NEDs with experience in organisational
design, public sector ownership, and major IT projects.
We note the IOD's recommendations in its recent policy
paper and recognise that in relation both to the Post
Office and to public corporations in general, the
Government needs to act with real intelligence when
158
throughout this Inquiry and it will look forward to
receiving the Inquiry's recommendations in due course.
‘SIR WYN WILLIAMS: Thank you, Mr Chapman.
Closing remarks by THE CHAIR
SIR WYN WILLIAMS: At this point, in the area of South Wales
from which I come and in which I live, I'd say, "Well,
there we are". Except it's not quite "there we are"
because there's a rather important next step. Before
I get to the next step, can I pay my tribute to all
those who have participated in, written and articulated,
the closing submissions that I have received. It goes
without saying that I have already found them extremely
helpful and I will continue to do so. I am grateful to
you all.
I would also like to thank again all the persons who
have attended this Inquiry and shown such interest in
it. I would particularly like to thank those people who
attend in person, as opposed to remotely, for their good
humour, discipline and ability to sit through evidence
and submissions, which no doubt some of them found
extremely difficult to hear and take in. So thank you
all for your very disciplined and good behaviour.
I thank my team often enough that it becomes almost
part of every day in my life but I have had great
assistance from a great team.
160
(40) Pages 157 - 160
The Post Office Horizon IT Inquiry
So what remains is the question on all your lips:
but when will he report? I can hardly say I don't
remember but I will say, genuinely, I do not know, and
so I make no promises other than I will report as
quickly as I sensibly can once I am satisfied, and I'll
need to be satisfied, of all my crucial conclusions.
That is, without doubt, many months away but I hope
it's not much longer than that, and that's all you're
getting from me by way of a prediction.
So thank you all again and now we will depart.
(3.18 pm)
(The hearing concluded)
161
17 December 2024
(41) Pages 161 - 161
MR BEER: [2] 1/7
124/11
MR CHAPMAN: [2]
124/8 124/18
MR STEIN: [1]
124/16
MR WHITTAM: [1]
59/7
MS DOBBIN: [8]
79/14 79/18 79/21
80/3 119/20 119/23
119/25 123/24
MS GREANEY: [1]
113,
MS LEEK: [3] 21/15
24/17 22/5
SIR WYN WILLIAMS:
[22] 1/3 1/8 21/8
21/16 21/18 21/24
58/24 59/5 79/9 79/16
79/20 79/22 80/1
119/18 119/22 119/24]
123/23 123/25 124/6
124/14 160/3 160/5
THE
STENOGRAPHER:
[4] 124/10
"60s [1] 4/6
‘70s [1] 4/7
‘There [1] 24/18
0
0.5 billion [1] 155/16
1
4 July [3] 35/23
37/16 37/19
4.00 [2] 79/22 79/25
1.8 billion [1] 155/14
10 [1] 67/10
10.00 [1] 21/21
10.15 [2] 21/19 21/23
100 [1] 62/4
101 [1] 66/19
11,000 [1] 24/1
44.11 [4] 59/2
11.25 [2] 58/25 59/4
11.58 [1] 79/23
12.00 [1] 79/10
120 [1] 60/23
13 November [1]
17/10
140 pages [1] 23/22
15 October [1] 45/15
16 July [2] 43/22
44/18
16 June [1] 74/16
17 December 2024
[4] 11
47 July [2] 43/21
45/5
17 May [1] 33/4
17 September [1]
53/12
18 June [2] 33/4
33/15
18th August [1]
112/3
19 July [1] 52/22
19 March [1] 35/5
19 October [1]
116/16
1984 [1] 42/17
1990s [1] 129/8
1992 [2] 70/6 70/9
1998 [1] 70/6
1999 [3] 62/12 63/15
131/23
2
2 August [1] 45/14
2.06 pm [1] 124/3
2.15 [3] 123/25 124/1
124/2
2.47 [A] 124/5
2.20 [1] 123/25
2.6 [1] 35/12
20 [1] 4/8
200,000 [3] 87/13
111/23 121/23
2000 [2] 70/3 134/12
2001 [2] 62/12 67/2
2005 [5] 101/25
103/13 103/14 103/16)
113/1
2006 [9] 23/14 23/16
92/22 101/25 102/5
113/2 114/2 120/14
120/25
2007 [2] 23/19 28/22
2008 [2] 28/24 41/20
2009 [3] 26/23 27/9
27/119
2010 [14] 23/15 28/4
28/7 28/24 92/24
112/3 112/25 121/4
121/9 121/14 121/18
121/25 122/8 122/11
2010/2011 [1] 30/6
2011 [11] 27/3 28/11
28/12 28/22 29/12
29/16 30/6 30/8 30/24
31/2 32/8
2012 [21] 6/9 16/16
24/17 26/2 28/19 33/4
33/9 33/15 33/24
42/24 87/16 93/14
93/16 94/16 98/5
113/22 114/20 116/16)
123/5 123/10 136/12
2013 [36] 7/16 28/13
28/21 33/24 35/5 35/6
35/23 37/16 37/19
39/20 40/24 41/9 43/3)
43/14 43/21 44/13
44/18 45/12 45/14
45/15 45/25 46/8
46/15 50/4 50/25
52/22 55/25 82/24
84/3 90/4 90/9 93/7
93/16 94/16 123/11
152/12
2014 [4] 50/25 53/12
53/14 53/15
2015 [5] 54/14 54/17
80/25 87/19 143/13
2016 [2] 127/4
127/10
2018 [2] 139/25
140/16
2019 [3] 8/8 8/17
12/15
2020 [4] 42/13 42/19
74/16 77/21
2021 [5] 9/4 9/11
80/5 82/22 84/9
2022 [2] 72/21 77/2
2023 [1] 14/22
2024 [6] 1/1 13/11
17/7 17/10 73/12 76/7
2025 [3] 9/10 18/16
77/4
207 [1] 80/20
20th century [1] 4/9
21 [1] 116/2
23 May [1] 35/6
24 July [1] 76/7
24 June [1] 42/13
240,000 [1] 61/3
25 April [1] 76/5
25 years [2] 60/25
63/11
27 February [1]
54/22
27 March [1] 30/8
270,000 [1] 84/18
29 May [1] 31/2
29 September [1]
28/7
3
3 February [1] 54/14
3 July [3] 40/24 43/3
43/14
3.18 [4] 164/11
30 [1] 61/3
30 million [1] 60/24
30 years [3] 4/4 4/8
91/15
300 [1] 131/5
33 [1] 30/12
4
4 July [1] 55/25
4 March [4] 28/12
4 October [1] 77/1
40 [1] 28/9
48 hours [1] 11/6
5
5 February [1] 54/17
5 January [1] 29/16
5.3 [1] 35/16
50 [1] 36/5
6
62 [1] 28/5
7 July [1] 41/17
70 [4] 63/20
75,000 [1] 19/20
8
8.2 [2] 38/19 39/3
88 [1] 24/13
9
9 August 2013 [1]
45/25
9 March [1] 121/15
9.29 [1] 1/2
A
abiding [1] 102/22
ability [7] 41/11 65/5
65/21 87/17 106/13
131/24 160/19
able [20] 5/9 15/8
57/1 57/22 81/9 81/12,
81/13 81/18 81/20
81/22 81/25 82/14
83/14 95/8 104/13
110/8 111/25 119/8
139/13 159/19
about [104] 5/2 5/22
7/16 7/17 7/18 7/21
8/4 8/25 9/14 12/7
12/12 12/16 13/9 14/8}
21/24 22/8 23/4 23/5
24/25 26/21 26/23
27/7 28/2 31/12 34/15)
36/10 36/19 37/18
39/22 40/3 45/7 45/8
46/18 48/5 48/22 50/7
50/8 52/6 54/7 55/6
57/4 57/7 57/12 59/21
61/7 67/5 68/20 68/21
69/21 79/10 81/14
81/19 82/12 83/7 83/9)
84/8 87/12 87/22
88/17 88/19 88/23
90/23 90/25 91/17
97/10 100/1 101/10
102/24 103/9 103/14
107/2 107/12 108/2
109/16 110/13 111/7
111/10 111/10 111/13}
111/21 111/22 112/1
113/5 113/11 114/19
115/10 115/13 116/7
116/14 118/16 119/2
119/17 121/15 122/20}
122/22 125/22 131/16
133/18 136/23 142/17)
143/11 157/16 159/5
159/8
above [4] 32/20
138/1 140/18 152/9
abrogated [1] 64/17
absence [1] 138/24
absolute [1] 121/4
absolutely [2] 69/19
129/11
absolve [1] 127/10
abuse [1] 65/25
abusing [1] 152/4
accelerated [1] 77/3
accept [5] 41/25
49/16 78/12 127/6
159/17
acceptable [1]
151/10
acceptance [3]
122/19 131/6 149/15
acceptances [1] 60/8)
accepted [15] 5/19
14/23 28/10 28/15
48/10 49/4 49/17 60/5)
62/1 62/23 65/4 65/23
69/22 129/9 130/20
accepting [1] 56/20
accepts [8] 8/9 13/1
33/18 71/12 72/10
78/10 96/19 128/6
access [33] 24/12
28/22 30/5 30/18
30/19 31/21 54/15
55/1 61/12 65/5 65/6
65/7 65/11 65/21
65/25 66/4 66/8 75/13
81/15 87/17 87/22
89/5 113/14 113/16
113/18 113/23 113/24}
114/2 114/5 114/6
123/7 142/1 143/4
accordance [2]
145/4 150/25
According [1] 109/13}
account [7] 6/18 9/18
10/3 32/20 46/3 71/16I
120/24
accountability [6]
6/14 15/2 16/1 128/19
134/1 139/10
accountable [4]
126/18 127/14 136/1
136/20
accountants [1]
37/13
accounting [6] 31/9
32/12 34/6 70/8
129/10 131/25
accounts [12] 26/18
29/3 29/9 31/14 31/18}
31/23 32/1 32/14 41/2I
61/20 63/17 111/15
(42) MR BEER: - accounts
A
accuracy [3] 33/7
53/23 64/8
accurate [11] 25/24
32/14 33/20 44/2
50/17 51/17 51/21
80/19 138/6 143/7
145/17
accused [3] 87/6
98/4 112/18
accuses [1] 82/5
accusing [2] 82/13
83/23
achieved [1] 16/23
achieving [1] 19/11
acknowledge [1] 3/6
acknowledged [4]
6/3 14/16 61/16 70/18
acknowledgement
[2] 61/21 63/8
acknowledges [8]
3/1 3/16 8/11 8/24
12/23 18/8 21/5 70/24
acquiescence [1]
78/15
across [8] 12/4 12/16)
56/9 62/2 62/13
137/21 146/6 158/15
act [12] 8/25 13/13
42/17 99/21 125/7
131/21 134/12 139/6
145/4 148/25 151/5
158/25
acted [9] 49/2 58/19
94/9 125/10 127/16
144/22 145/11 147/17)
155/1
acting [4] 18/19 56/5
94/2 140/6
action [3] 15/7 15/13
144/7
actions [8] 1/19 3/20
8/14 12/21 20/25
22/12 72/2 126/18
active [1] 70/1
actively [1] 131/19
activities [1] 137/4
activity [3] 70/5 70/7
76/13
actor [1] 66/1
actual [1] 117/23
actually [6] 84/13
101/3 108/8 108/19
117/23 139/18
acutely [2] 75/4
152/24
add [2] 52/15 139/18
added [1] 93/10
adding [1] 139/16
addition [5] 9/11 34/8)
35/22 75/14 150/3
additional [7] 62/4
137/8 139/16 139/17
139/20 140/3 150/16
address [19] 1/16 8/5)
8/12 15/3 15/7 47/22
61/13 74/25 81/5 85/9)
86/22 88/12 97/11
101/23 109/8 126/24
128/15 152/17 153/6
addressed [4] 16/4
36/21 103/15 122/5
addressing [3] 10/14
21/10 91/10
adds [1] 147/22
adduced [1] 58/17
adequate [1] 126/25
Adjournment [1]
79/24
administer [1] 19/18
admissible [2] 85/17
96/11
admission [1] 44/25
adopt [1] 67/13
adopted [2] 7/7 24/16]
Adrian [2] 129/23
130/13
advanced [1] 101/23
advantage [1] 5/1
adverted [1] 87/9
advice [47] 6/20 6/25
7/1 19/19 23/5 27/21
31/11 42/11 43/19
43/21 44/3 44/5 44/12
44/15 45/3 45/11
49/24 50/2 50/4 50/7
50/18 51/18 51/21
52/3 52/4 53/3 80/12
80/15 82/23 83/9 84/3
88/16 90/14 126/7
140/20 142/8 142/21
142/23 143/14 143/19)
144/3 144/15 144/25
148/7 148/15 149/4
150/25
advised [3] 44/19
46/25 47/8
adviser [1] 127/17
advising [1] 49/1
advisor [1] 54/3
advisors [1] 51/24
Advisory [2] 154/12
155/21
advocated [1] 88/1
advocating [2]
104/23 155/24
affect [1] 61/19
affected [14] 1/24
20/24 26/15 28/5 29/4
36/22 40/18 57/5 57/9
60/2 78/2 111/15
114/17 122/21
affecting [3] 59/16
75/11 75/19
affidavit [1] 41/23
afforded [1] 80/7
after [11] 28/11 42/14)
43/21 45/5 45/24 46/7
80/5 88/16 93/13
116/21 127/11
again [31] 2/25 5/18
21/4 21/25 43/15
53/20 68/21 79/22
92/15 93/7 93/8 93/17,
93/19 97/18 110/12
115/15 118/3 119/1
121/9 121/22 122/6
122/11 122/17 123/25]
124/19 138/7 140/12
145/13 159/19 160/15}
161/10
against [10] 6/7
23/17 32/20 59/19
64/25 71/8 72/20
86/25 100/23 102/18
age [1] 77/18
agencies [2] 11/17
125/18
Agency [2] 18/12
129/21
agent [1] 127/17
agents [1] 95/2
ages [1] 75/12
aggrieved [2] 73/20
147/16
agree [8] 10/17 90/7
93/7 104/8 104/13
114/11 129/17 147/23}
agreed [4] 47/8 48/20)
107/14 118/24
Agreement [1] 70/25
agrees [4] 19/3 135/3
144/23 147/21
ahead [1] 52/7
aim [1] 11/11
ed [1] 17/20
aims [2] 129/13
154/18
aired [1] 73/11
Alan [5] 23/13 26/5
131/23 141/13 141/15}
Alan Johnson [1]
131/23
alert [3] 49/25 50/16
131/15
alerted [1] 26/22
Alex [1] 138/16
aligned [1] 18/9
Alisdair [1] 146/9
all [52] 2/3 7/25
13/12 19/9 20/24
21/24 22/11 22/17
25/12 27/4 37/8 37/10
43/11 64/17 68/12
68/16 69/14 69/22
71/12 78/15 79/19
80/1 85/6 90/19 91/5
92/18 95/14 99/9
99/12 100/25 103/12
106/17 108/24 109/24
112/8 125/19 125/21
126/10 137/12 144/21
147/17 148/13 151/1
159/14 160/9 160/14
160/15 160/22 161/1
161/6 161/8 161/10
all-purposes [1]
64/17
allegation [3] 86/14
104/15 120/5
allegations [8] 24/19
42/9 86/25 87/1 88/16)
88/20 120/1 141/19
alleging [1] 97/24
Allen [2] 90/8 117/12
Allen's [1] 117/18
allocated [1] 1/18
allotted [1] 22/13
allow [1] 119/22
allowed [3] 4/18
126/15 127/23
alluded [2] 106/3
116/8
almost [6] 89/10
129/8 134/25 137/16
150/4 160/23
alone [6] 60/13 85/14
93/11 93/22 104/1
125/8
along [3] 46/2 133/2
141/24
alongside [1] 140/3
already [7] 4/12
18/24 46/2 78/18 97/7}
115/19 160/12
also [45] 7/13 11/3
12/6 15/13 15/24 17/3}
17/20 18/13 19/19
32/16 33/10 37/5 37/6
37/11 41/5 42/1 44/22,
45/8 47/8 53/16 53/23)
61/23 63/15 68/25
69/20 75/7 75/14
77/10 89/8 97/14
98/10 107/8 108/21
110/14 111/24 126/2
131/6 139/20 145/9
150/14 151/5 151/9
152/6 158/7 160/15
alter [2] 29/13 41/13
alternative [2] 15/23
130/18
although [1] 48/10
Altman [11] 45/11
45/20 45/25 47/5 47/8
48/1 48/7 48/15 48/20)
51/13 51/17
Altman's [3] 50/3
50/6 50/9
altogether [2] 107/16
134/4
always [7] 27/15
86/14 117/10 135/10
147/17 150/1 152/1
Alwen [1] 38/9
am [10] 1/2 21/21
21/23 57/22 59/2 59/4I
79/23 103/10 160/13
161/5
ambiguity [1] 104/19
ambitions [1] 129/22
ambitious [1] 77/3
amnesiac [1] 91/1
amongst [3] 50/1
62/5 134/25
amounted [1] 109/11
analyse [1] 22/6
analysis [4] 25/1
51/12 118/24 123/1
Andrew [1] 28/25
Angela [1] 28/25
annex [2] 63/18
68/23
annual [1] 17/14
anomalies [4] 36/15
36/25 37/24 38/1
anomaly [1] 41/5
another [6] 64/7
64/16 90/4 98/22
115/15 119/6
answer [12] 79/11
83/12 84/19 88/11
89/3 104/15 111/6
115/7 115/7 121/10
122/25 151/14
answered [1] 91/5
answering [1] 89/1
answers [2] 115/21
148/17
antithesis [2] 98/8
115/20
any [70] 2/5 4/25
11/4 12/1 23/10 24/7
24/18 26/17 27/14
27/16 28/20 29/17
35/3 36/7 37/23 39/10
40/9 45/21 47/9 49/19)
51/9 53/11 55/5 57/8
58/23 66/5 66/7 66/21
73/2 74/21 75/6 76/17I
84/10 85/24 86/4
86/24 88/10 88/13
92/7 93/1 94/5 101/1
101/16 103/18 105/7
106/17 106/22 108/13)
111/4 111/7 114/7
114/18 114/19 115/1
115/20 117/2 117/2
118/21 119/3 120/17
123/4 130/1 136/1
137/22 142/6 146/21
147/9 147/22 152/15
159/10
anyone [2] 115/12
119/9
anything [7] 30/2
51/13 51/15 111/13
119/8 125/25 159/24
anywhere [1] 44/1
(43) accuracy - anywhere
A
apologies [2] 57/7
128/7
apologises [1] 60/1
apology [6] 1/23
20/23 20/24 57/9 78/4,
105/25
apoplectic [1] 143/2
appalled [1] 2/3
appalling [4] 59/21
78/2 78/19 124/24
apparent [7] 6/4
72/17 73/13 73/22
76/11 84/2 134/19
Appeal [14] 67/2 67/4I
67/14 70/18 80/15
80/17 81/3 82/8 82/12
82/14 83/21 102/2
102/22 112/21
appeals [1] 141/9
appear [2] 140/21
141/21
appearance [1]
127/21
appeared [5] 73/15
73/23 84/14 96/7
113/10
appearing [1] 92/12
appears [8] 6/21
30/23 37/12 41/25
43/22 53/2 72/15
148/25
application [1] 22/19
applications [1]
100/6
applied [9] 43/3 84/6
85/6 99/21 101/8
102/3 103/21 103/23
122/3
applies [2] 13/12
97/12
apply [5] 43/2 70/13
84/5 101/9 103/1
applying [2] 42/16
84/24
appointed [1] 9/12
appointing [1]
158/20
appointments [2]
158/18 159/1
appreciate [2] 6/23
32/5
approach [23] 27/1
47/5 47/9 51/15 56/18)
76/24 86/19 88/1
88/13 96/19 97/8 98/5
98/24 99/5 114/24
120/13 123/6 123/10
123/20 133/20 153/21
154/3 154/23
approached [6]
22/24 42/15 88/5
89/10 115/20 155/41
appropriate [13] 48/2
48/10 52/17 67/15
72/4 74/18 75/8 76/25)
94/19 135/16 136/25
137/18 144/23
appropriately [3] 6/1
64/23 145/13
appropriateness [1]
7118
approval [1] 18/2
approved [1] 27/1
approximate [1]
95/22
approximately [1]
60/22
APPSUP [5] 30/15
31/8 31/12 31/16 32/4
April [3] 27/19 30/24
76/5
aptitude [1] 147/8
Arbuthnot [6] 24/17
33/15 35/6 36/3 42/25
43/7
ARC [3] 32/8 51/2
51/6
are [61] 2/2 2/22 2/23
3/11 9/1 10/3 10/4
11/5 11/5 11/8 13/3
13/14 13/19 14/3
16/18 17/4 18/20
18/21 30/14 35/8
35/19 36/16 36/21
36/24 36/25 37/12
41/5 60/10 60/14
63/14 66/12 66/20
77/25 78/25 79/7 82/2
82/5 83/19 84/21 87/4
89/19 97/22 98/1
101/13 101/15 107/17)
107/19 120/12 121/11
128/16 134/19 137/1
137/15 144/11 145/7
145/14 148/4 155/17
157/25 160/7 160/7
area [1] 160/5
areas [2] 56/17
144/19
argument [3] 67/18
111/20 113/15
arid [1] 135/18
arise [3] 4/23 10/1
11/9
arisen [2] 6/21 60/10
arises [1] 139/3
arising [2] 16/6
137/21
arm [1] 133/7
arm's [4] 134/9
134/11 135/1 145/15
arm's-length [3]
134/9 135/1 145/15
armed [1] 130/22
arms [1] 135/4
arms-length [1]
135/4
arose [1] 91/21
around [6] 27/17
28/9 32/13 37/6
120/22 155/16
ARQ [16] 68/5 83/16
105/12 105/14 106/1
106/8 106/11 106/14
106/16 106/21 108/8
111/17 117/16 117/19
118/7 123/12
arrangement [3]
67/17 134/10 135/4
arrangements [4]
68/6 127/15 136/25
158/12
arrived [1] 107/20
arrogance [1] 126/6
arrogant [1] 146/18
art [1] 106/5
article [2] 26/23 27/9
articles [2] 11/5 11/7
articulated [1]
160/10
as [298]
as independent [1]
49/7
ascertain [1] 118/23
aside [2] 109/3
155/14
asides [1] 108/9
ask [2] 21/13 111/14
asked [30] 23/5 30/2
47/12 49/11 55/5
82/25 83/11 86/4 86/6
88/6 88/12 88/23
91/15 95/1 97/2 97/5
98/11 98/13 98/16
101/23 108/16 108/17]
108/19 108/21 109/22
111/4 111/7 111/10
118/18 141/14
asking [1] 75/24
aspect [1] 4/3
aspects [2] 8/2
121/16
aspirational [1]
13/19
asserted [1] 26/25
assertion [3] 23/6
24/22 41/10
assertions [1] 24/24
assess [2] 113/3
113/7
assessing [1] 64/13
assessment [4]
19/18 88/3 88/7 122/2I
assigned [1] 30/14
assist [5] 3/4 20/6
58/23 82/25 108/21
assistance [6] 73/2
74/12 82/24 89/4
158/19 160/25
assistant [1] 10/13
assisted [2] 20/7
61/3
associated [2] 30/16
56/3
assume [5] 23/11
38/25 50/15 51/20
153/23
assumed [2] 50/14
12719
assumes [1] 113/15
assumption [2] 7/9
138/4
assurance [4] 53/10
69/6 142/4 142/8
assurances [14]
27/24 42/20 69/4 69/8
126/2 132/3 141/17
141/21 141/23 141/25)
143/10 144/16 147/25}
152/1
assured [1] 141/4
astonishing [1]
151/24
astute [2] 74/10
139/22
at [143] 1/9 2/2 2/21
4/10 5/10 7/23 9/20
11/20 13/22 13/24
15/4 15/12 15/16 16/2)
16/8 17/20 18/17
22/11 22/17 23/7
23/12 25/8 27/4 27/5
28/20 29/11 30/7 31/1
31/2 31/11 33/8 35/12
35/16 36/2 36/25 38/2
38/18 39/25 41/11
43/6 44/8 47/13 48/8
48/17 50/14 50/24
53/5 54/6 54/25 58/10)
60/20 62/21 63/11
63/20 68/12 68/25
69/14 69/16 73/17
75/20 76/22 77/12
78/16 79/22 85/1 85/7,
86/11 89/14 90/23
91/25 92/18 95/14
96/22 99/24 102/20
103/18 104/4 104/14
105/23 106/17 107/16
107/20 109/12 109/25}
110/1 114/3 114/5
114/9 115/24 116/11
119/16 120/10 121/15)
121/16 122/17 122/24}
123/13 123/25 129/5
129/17 130/12 130/15]
130/23 132/9 132/13
132/15 132/16 132/18}
133/13 134/11 136/3
136/14 138/24 139/19]
140/10 140/10 140/15}
140/18 142/12 143/1
143/11 145/13 145/14}
146/16 146/17 146/23
148/5 148/18 148/19
149/6 149/13 149/20
150/15 154/24 156/2
156/25 157/2 158/5
158/7 158/11 159/7
159/21 160/5
Atkinson [10] 90/15
95/1 95/11 98/7
101/11 107/14 107/17
114/24 118/8 119/1
atone [1] 128/9
attached [2] 39/11
99/6
attaching [1] 5/14
attempt [6] 7/1 47/11
67/4 104/19 115/15
126/14
attempting [2] 154/2
157/14
attempts [2] 65/14
123/11
attend [2] 34/11
160/18
attendant [1] 132/20
attended [1] 160/16
attendee [1] 15/11
attention [5] 36/11
135/22 144/20 147/1
147/10
attest [2] 106/14
106/23
attesting [2] 105/10
105/16
attitude [3] 7/7 74/6
126/11
attributed [2] 64/15
81/7
atypical [1] 71/3
audience [1] 22/1
audit [17] 18/12 30/6
30/7 30/22 36/22 37/4
50/24 106/11 107/3
107/10 114/1 114/7
118/3 141/8 142/1
153/9 155/23
auditor [1] 76/9
audits [1] 32/21
August [6] 45/11
45/14 45/25 112/3
121/25 143/13
Aujard [5] 44/4 44/4
50/23 53/12 54/22
Aujard's [2] 51/7
51/12
authorisation [2]
31/14 32/2
authorised [1] 23/15
authorities [1] 74/18
authority [1] 29/3
autonomy [1] 134/16
available [9] 65/12
70/3 70/15 120/8
132/18 135/12 135/17
137/20 148/6
(44) apologies - available
A
avoid [2] 15/15
104/21
aware [33] 12/11
25/5 26/11 26/14 27/6
27/18 28/12 28/13
28/17 29/1 29/16
36/24 37/5 39/20 40/9
41/3 41/5 54/2 54/14
56/22 63/11 63/15
64/5 64/9 65/20 66/24
75/4 75/7 83/21 83/22
111/12 112/20 116/20}
awareness [2] 13/10
64/19
away [3] 148/11
153/1 161/7
B
back [8] 1/9 37/15
47/13 48/19 60/24
85/2 92/25 141/8
backdoors [2] 30/1
125/23
backed [2] 145/24
151/20
background [2]
25/16 81/23
backgrounds [1]
149/21
bad [3] 58/19 126/8
153/25
Badenoch [1] 154/20
badly [1] 146/24
Baker [3] 34/9 40/1
40/4
balance [1] 132/22
balanced [1] 143/8
balances [2] 32/20
43/2
bare [1] 78/20
Baroness [5] 142/9
143/10 148/8 149/17
150/2
barrister [1] 47/7
barristers [1] 151/8
Bartlett [1] 76/19
base [1] 139/17
based [12] 5/22 23/6
33/11 37/20 38/5
38/13 39/3 53/25
59/10 135/16 137/19
141/3
basement [5] 41/11
41/20 41/21 42/2 42/4)
basic [3] 82/20 84/5
85/3
basis [9] 11/3 54/7
67/11 92/13 96/20
104/7 115/5 141/18
144/3
Bates [1] 141/14
be [153] 2/16 2/17
3/1 3/7 3/17 3/20 8/6
9/6 9/9 9/17 11/10
12/12 14/10 15/16
16/4 16/20 16/23 17/2
17/17 18/8 18/15 19/4
19/16 19/20 19/22
20/3 20/7 20/10 21/5
22/1 22/12 22/23
23/17 23/21 25/2
31/15 31/17 35/9
35/10 36/16 37/9
39/11 40/12 41/25
43/3 46/19 47/16
47/21 47/23 49/15
49/21 52/4 52/14 53/7
55/5 58/4 61/24 64/12
64/12 64/13 64/15
64/17 65/1 66/1 66/24
68/7 68/18 69/19 72/9)
72/15 73/23 74/5
76/15 78/14 86/11
87/23 88/9 91/6 93/22
95/8 96/14 96/16
96/22 96/24 96/25
97/6 97/20 100/11
100/17 101/2 101/5
104/2 104/3 104/6
105/16 106/2 106/16
106/18 107/11 109/6
109/23 110/12 111/2
1411/8 111/17 111/19
111/25 112/9 112/20
113/10 113/17 115/1
115/12 115/20 115/24)
116/15 116/20 117/4
117/6 117/16 118/2
118/7 119/11 119/20
120/1 120/3 120/3
120/10 121/5 121/12
121/16 122/2 122/20
124/14 127/24 128/5
130/16 132/2 132/11
138/7 139/13 144/8
145/16 149/9 151/15
156/7 156/18 157/24
157/24 157/25 158/18)
159/9 161/6
bear [4] 3/18 11/13
66/22 141/21
bears [1] 125/6
became [8] 24/12
27/6 27/18 28/17
42/14 52/24 88/20
108/23
because [29] 19/17
22/2 31/7 32/5 46/10
48/17 49/14 51/9
66/22 84/22 85/4
86/13 86/18 87/15
94/20 110/3 110/19
112/13 113/13 115/3
117/14 117/12 119/16
121/12 125/11 139/14)
148/16 153/22 160/8
become [6] 49/8
49/12 49/14 76/1 77/8
77/10
becomes [1] 160/23
becoming [1] 27/7
BEDs [4] 26/12 26/14
26/15 26/17
been [159] 1/3 1/18
1/24 1/25 7/3 7/24
8/10 8/13 10/20 12/23
13/16 15/8 15/13
15/15 15/19 16/12
16/15 19/15 20/24
22/9 24/18 24/25
25/13 27/5 27/22
29/15 30/23 35/13
35/14 35/20 36/21
36/23 37/3 37/3 37/20
38/2 38/6 38/14 39/16
40/15 40/17 40/17
40/19 41/22 42/4 42/9
43/10 43/17 43/23
46/2 48/9 48/16 48/18
48/21 48/21 49/7
51/10 51/15 53/17
54/2 54/12 55/12
55/14 57/18 58/17
58/18 60/25 61/6 61/7
61/16 61/25 63/11
65/20 65/22 67/20
67/24 69/8 73/7 73/7
73/15 73/24 74/1 74/8
75/3 76/19 77/6 77/15)
78/20 80/8 80/9 80/10
80/11 81/10 81/20
82/3 82/8 82/23 82/25
83/13 83/15 84/9
84/23 85/1 87/9 88/22
90/1 90/2 90/9 90/15
90/22 91/1 91/2 91/14
91/22 98/9 98/13
99/15 100/16 102/1
102/2 102/4 102/13
104/17 105/15 107/25}
109/24 110/20 115/11
116/18 117/2 117/7
117/15 118/9 118/21
118/25 121/2 121/7
122/5 122/25 123/4
123/17 126/23 130/20
132/4 133/2 140/1
141/9 141/18 142/16
143/3 147/21 148/10
152/22 152/23 153/16
154/24 157/24 158/10
159/25
Beer [2] 1/3 94/25
before [36] 24/2
24/12 27/8 28/19
28/23 38/11 45/3
48/12 52/9 64/8 66/21
67/12 75/15 80/6
80/16 81/3 84/24
90/25 91/4 91/9 91/10
91/15 93/22 94/11
96/5 96/7 99/11
107/18 110/4 110/21
131/6 138/21 140/16
144/8 153/1 160/8
began [1] 20/23
begin [2] 69/25 79/22
beginning [1] 77/12
begun [2] 38/11
90/19
behalf [6] 70/11
101/6 104/1 124/8
124/20 147/16
behaviour [8] 12/20
138/14 151/10 151/12)
151/12 151/15 156/1
160/22
behaviours [3] 13/12
13/14 13/20
behind [1] 155/2
being [69] 5/10 6/24
7/1 11/6 15/15 18/10
22/22 28/1 28/5 29/25)
30/5 31/3 33/22 35/4
35/7 36/12 36/21
36/24 43/10 44/9 47/5)
47/19 51/9 51/21
52/13 55/5 56/15 57/7,
64/2 69/6 82/5 82/10
83/2 83/3 85/4 85/22
85/24 88/25 91/15
91/17 92/8 94/3 97/1
97/2 97/5 97/5 98/4
98/11 100/24 101/18
101/23 106/10 108/16
108/17 108/19 108/21
109/14 112/11 115/4
117/5 118/5 119/7
120/14 122/15 130/6
132/4 133/3 143/12
144/17
BEIS [3] 42/12 54/13
7416
belatedly [1] 65/23
belief [4] 4/16 31/25
38/4 50/20
believe [3] 32/20
53/23 53/24
believed [3] 25/7
38/16 58/3
believes [3] 42/2
108/1 136/24
believing [1] 104/9
below [1] 137/13
beneath [1] 137/19
benefit [5] 17/2 19/7
130/6 132/6 154/6
benefits [3] 57/1
129/21 133/18
bespoke [1] 62/7
best [7] 19/6 36/4
56/2 58/5 104/3
119/13 140/10
better [8] 12/8 14/5
15/20 16/11 69/15
124/18 154/5 158/13
between [18] 12/22
14/9 17/6 23/14 28/22)
28/24 33/24 44/13
45/11 54/24 55/22
62/12 62/22 70/25
73/11 76/2 85/11
148/24
beyond [3] 63/8
67/18 87/21
big [1] 155/17
bigger [1] 153/6
biggest [1] 130/5
billion [2] 155/14
155/16
birth [1] 128/24
Bishop [1] 146/2
blame [4] 7/12 66/14
81/8 128/4
blamed [2] 81/2 83/4
blank [1] 131/1
blanket [2] 53/2 53/6
blind [1] 46/22
Blood [2] 145/6
146/1
blue [1] 26/13
Board [70] 6/6 6/10
6/15 6/16 6/20 6/25
7/2 7/13 7/16 7/21 9/5
13/22 15/10 15/12
15/14 15/15 16/2 17/7)
18/19 25/20 25/24
26/9 26/21 26/25 29/5
29/18 31/2 31/3 33/7
33/8 35/22 35/24
37/16 37/17 37/22
43/22 43/25 44/17
45/5 45/18 45/19
49/25 49/25 50/14
50/17 51/19 51/24
52/8 52/17 53/13
55/24 56/10 63/24
125/15 126/4 136/11
136/11 136/12 136/13}
137/2 139/9 140/18
146/16 146/23 154/12)
157/6 158/9 158/12
158/18 159/41
Board's [4] 6/17 7/19
147/7 155/22
boasted [1] 72/21
bodies [3] 131/9
145/15 153/14
body [5] 125/8 137/3
147/19 155/24 155/25)
Bogerd [4] 29/1
29/11 29/21 34/9
boilerplate [7] 105/5
105/9 105/20 106/19
107/2 107/15 107/21
Bolc [5] 94/15 117/18)
117/20 117/25 118/3
Bond [9] 43/24 51/25
(45) avoid - Bond
B
87/20 103/14
bonus [1] 157/17
bore [1] 92/6
borne [3] 58/16
65/22 93/19
Boston [1] 18/11
both [14] 28/1 28/15
36/20 39/14 62/17
114/17 118/10 132/5
156/2 158/23
bottom [1] 136/3
boundaries [1]
138/15
Bourke [2] 53/14
53/22
Bowyer [3] 94/14
114/21 115/6
Bradshaw [1] 117/21
branch [27] 10/25
11/6 11/20 26/18 29/3}
29/9 29/13 31/13
31/18 31/23 32/1 32/5
32/19 41/15 61/20
63/17 75/20 75/25
88/2 111/17 114/10
117/24 120/11 121/5
122/21 125/16 136/4
branches [15] 24/1
28/5 28/5 28/9 32/12
32/13 62/9 62/13 66/6
70/9 74/23 114/12
114/13 117/17 123/13)
brand [1] 5/5
breached [3] 44/23
45/2 86/15
breaches [4] 45/7
128/19 151/16 151/16
breadth [1] 64/18
break [8] 21/12 21/13
21/16 21/19 21/22
58/25 59/3 124/4
breakdown [1] 54/24
brevity [1] 78/13
Brian [4] 45/11 47/5
48/1 145/25
briefed [6] 6/11
30/22 35/4 35/22
37/16 52/8
briefing [11] 31/1
33/3 35/7 37/15 37/22
38/7 39/8 40/24 44/5
53/14 141/2
briefings [1] 52/18
briefly [6] 56/1 61/13
114/20 128/24 140/24}
152/17
bring [4] 8/4 9/2
12/16 148/18
brings [1] 2/21
Bond... [7] 52/21
52/22 53/3 54/2 54/16
65/8 76/14 76/25 98/5
British [4] 2/7 126/5
136/21 140/15
broad [2] 56/4 93/18
broader [5] 48/24
56/9 99/17 128/22
151/1
broadly [3] 24/3
75/22 136/25
brought [1] 59/21
buck [1] 127/21
bug [20] 28/3 28/8
28/9 28/10 28/12
28/13 28/16 28/19
112/24 113/4 113/12
114/8 114/16
buggy [1] 125/23
bugs [54] 4/22 7/17
11/23 12/1 24/11 25/1
39/22 40/3 40/6 40/7
40/9 40/15 40/20
44/20 46/10 48/5
57/12 61/10 61/16
61/18 61/24 62/18
62/21 63/5 63/7 63/9
63/12 63/16 63/23
64/5 64/10 64/19
65/14 68/22 75/9
75/11 75/21 82/13
83/5 83/22 86/16
88/19 111/21 120/6
123/7 131/16
build [2] 9/23 153/24
building [4] 14/5
built [1] 138/3
burden [1] 10/10
bureaucracy [1]
139/18
business [18] 2/23
4/3 8/17 9/3 9/18 12/5
14/15 24/1 24/9 26/4
33/10 56/4 68/18
124/9 124/21 134/24
152/10 154/23
businesses [1] 17/24
busy [3] 92/18
137/15 144/18
but [76] 2/1 2/13 2/16
3/22 13/23 17/3 21/4
23/10 25/1 33/20 52/3
54/18 56/16 60/14
62/14 62/16 73/11
74/19 78/25 82/18
84/13 84/19 89/22
92/7 92/25 93/5 95/13)
96/20 98/14 99/11
103/5 103/18 104/1
104/21 105/4 106/22
106/25 108/7 108/19
109/3 110/3 111/14
114/4 114/6 117/11
41/1 41/4 75/19 81/19
111/14 112/17 112/17)
26/12 37/3 38/2 39/20
40/23 40/25 41/1 41/3
117/25 118/3 118/15
119/4 120/5 125/7
125/14 125/25 126/1
129/14 130/10 131/20
135/8 137/1 139/20
141/16 143/6 143/25
144/23 147/16 149/23
150/8 151/4 152/6
152/22 157/9 157/25
160/24 161/2 161/3
161/7
button [1] 10/18
Byers [1] 131/1
Byfleet [1] 122/25
Cc
cadre [1] 140/2
calculated [1] 118/25
call [3] 35/6 35/22
55/10
Callard [2] 149/16
149/18
called [9] 15/18 38/2
70/9 83/2 83/3 92/2
92/8 109/15 120/21
Callendar [4] 81/19
111/13 122/9 122/22
came [6] 72/8 81/14
88/9 91/4 109/13
119/13
Cameron [2] 54/21
146/9
campaign [1] 87/10
can [25] 10/19 11/3
18/24 22/12 25/2
31/15 52/4 58/23 72/9
74/5 96/16 96/22
113/3 113/6 124/16
127/24 134/8 138/12
138/17 139/18 144/1
159/16 160/9 161/2
161/5
can't [1] 119/9
cancellation [2]
130/6 130/20
candid [1] 142/25
candidly [1] 60/6
candour [7] 128/20
145/11 145/24 146/5
146/8 151/20 158/15
cannot [9] 23/21
36/16 57/10 64/15
64/17 66/1 96/14
128/9 138/14
canvas [2] 99/17
100/24
capabilities [1] 66/9
capable [1] 107/19
capacity [4] 85/9
85/21 98/11 109/8
Capture [1] 70/9
Card [1] 130/7
care [1] 105/7
careful [3] 59/10 61/8
65/2
carefully [5] 20/19
22/6 59/14 101/19
127/23
carried [8] 12/2 17/6
18/10 38/13 39/5
47/19 103/23 120/10
carry [3] 5/17 40/11
57/2
Cartwright [24] 44/6
90/12 90/17 94/17
94/18 95/3 98/6
114/22 116/6 118/16
case [74] 30/3 33/16
43/20 44/10 45/14
47/19 49/12 49/15
49/19 51/4 52/6 53/7
67/3 70/19 80/18
83/25 84/10 86/24
87/12 87/16 91/16
92/22 92/24 93/4 93/8)
93/13 93/14 93/17
94/7 94/11 94/13
94/13 97/4 97/12
97/18 98/15 98/16
98/16 98/20 99/14
100/13 100/20 103/14)
104/18 104/20 104/24}
105/1 105/4 108/5
108/9 108/14 108/16
109/12 112/15 112/21
112/25 113/22 115/1
115/4 115/4 116/19
4117/1 117/18 119/12
120/16 120/20 121/2
121/5 121/10 121/17
122/9 123/4 123/9
147/21
caseload [1] 53/20
cases [47] 10/16
33/25 34/16 36/4 36/5
36/20 36/24 37/4
37/10 43/10 45/13
46/12 47/2 47/14
48/10 49/10 52/20
53/10 53/17 57/25
71/12 73/13 76/24
80/9 82/9 83/4 83/15
84/12 85/24 89/24
92/19 93/2 93/17
94/16 100/10 113/17
115/10 116/2 116/8
1417/3 117/6 117/13
118/1 118/5 120/3
125/5 139/6
cast [1] 125/13
Castleton [3] 23/17
104/5 104/10
Castleton's [5]
103/13 103/16 104/18
44/15 44/19 45/12 cautious [1] 76/24
45/22 47/25 48/24 cautiously [1] 22/24
48/25 49/5 49/8 49/11] caveat [2] 136/25
50/11 52/1 83/17 84/2
104/24 121/2
catastrophic [1]
151/14
caught [1] 54/19
caused [8] 1/20 1/23
26/17 60/13 73/16
78/24 104/11 111/8
causes [5] 91/20
125/25 126/1 145/19
146/25
138/21
caveated [1] 122/23
Cavender [1] 52/5
cease [1] 76/17
central [8] 6/12 10/10
17/22 125/18 127/25
129/2 133/11 136/3
centre [6] 9/3 136/15
150/11 153/12 158/7
159/21
century [3] 4/9 4/10
134/10
CEO [15] 18/19 23/25}
24/2 24/9 24/12 42/14
51/23 52/14 54/25
55/17 55/20 57/11
73/19 136/10 147/9
certain [4] 29/12
61/13 69/2 69/7
certainly [7] 4/10
94/20 95/13 119/4
125/25 144/24 150/8
CFO [2] 32/8 46/17
chain [1] 140/8
Chair [6] 17/9 17/25
18/18 20/15 158/2
160/4
challenge [20] 7/19
41/22 42/5 71/17 94/6)
126/25 135/10 138/1
139/16 139/18 139/23)
140/4 140/18 143/25
144/2 146/21 147/15
148/3 149/2 150/17
challenged [1] 50/8
challenges [3] 16/17
77/10 116/12
challenging [1] 9/21
Chambers [1] 114/2
chance [2] 81/5
83/10
Chancellor [1]
133/17
chances [1] 125/2
change [15] 8/5 8/10
12/18 13/23 13/25
14/4 18/20 29/3 56/9
110/15 112/6 121/21
122/5 127/17 128/9
changed [4] 10/5
67/24 114/6 130/4
(46) Bond... - changed
Cc
changes [21] 2/22
8/16 8/20 8/22 8/23
10/4 12/16 13/3 13/19
14/1 16/25 19/1 29/9
31/13 31/17 31/22
32/1 112/2 112/9
122/12 154/1
changing [2] 155/7
157/22
channels [1] 13/16
Chapman [5] 124/2
124/6 124/7 124/11
160/3
characterisation [1]
87/5
characterise [1]
66/15
characteristic [1]
43/16
characters [1]
125/13
charged [2] 98/18
113/7
check [3] 36/23 37/4
119/8
checked [2] 47/5
111/10
checks [1] 43/2
cheque [1] 131/1
Chief [1] 38/8
Chisholm [1] 138/16
choices [1] 125/11
choir [1] 101/13
choppy [1] 157/24
chose [2] 38/23
131/15
Chris [2] 32/8 53/12
chronologically [1]
32/24
chronology [5] 22/7
23/20 23/22 23/23
103/11
circles [1] 143/14
circulate [1] 38/11
circulation [1] 43/22
circumstances [9]
29/13 56/15 64/9
64/11 90/5 90/10
101/17 118/20 157/19}
cite [1] 69/5
civil [43] 59/18 72/2
81/17 82/25 107/8
140/2 144/22 148/10
148/18 149/21 149/25)
150/10 151/4
claim [2] 23/16 105/8
claimed [1] 44/6
claiming [1] 89/25
claims [4] 7/21 69/10
69/12 72/23
clarity [2] 14/24
16/22
Clarke [19] 6/19 23/5
43/19 43/20 45/1 45/3
49/4 49/17 80/12
80/15 82/23 83/9
83/10 83/13 84/3
88/16 90/13 142/8
142/21
Clarke's [3] 44/3
44/12 51/18
classic [1] 149/21
clear [38] 5/25 6/13
27/25 28/18 29/19
32/25 43/16 54/24
55/21 59/16 61/7
67/18 69/19 72/9 74/5
77/8 77/10 86/8 86/11
107/16 110/20 111/5
116/14 117/4 117/13
117/18 121/11 122/18)
130/12 133/1 137/5
139/20 143/6 145/9
148/8 150/11 157/15
158/6
clearly [16] 23/10
38/19 52/24 60/5
89/22 95/12 108/15
115/23 118/12 128/2
132/11 147/15 147/17)
147/20 148/5 157/21
clerk [1] 50/2
client [1] 71/14
cloistered [1] 85/5
close [6] 25/1 46/24
104/21 104/22 143/20)
146/19
closely [2] 18/6
104/14
closer [1] 77/11
closing [42] 1/12
1/14 2/19 6/4 7/25
14/17 20/22 22/4 59/6
59/8 59/9 59/11 59/13
60/4 63/19 65/24
66/10 66/20 67/10
68/23 69/12 69/22
70/20 72/6 76/10
78/13 78/14 80/2
124/7 124/8 124/20
128/16 129/4 145/5
146/22 146/25 150/20)
151/21 153/3 154/24
160/4 160/11
closings [2] 4/20
73/10
closure [1] 19/11
Code [5] 42/17
149/25 150/10 151/4
151/4
codes [2] 151/9
151/16
Codified [1] 70/25
cognisant [1] 106/5
collation [1] 112/5
colleagues [4] 33/2
38/4 73/17 112/3
collect [1] 57/1
collected [2] 60/23
60/25
collective [1] 6/21
collectively [2] 59/12
125/12
college [1] 13/17
combined [1] 3/24
come [10] 2/5 3/2
14/8 21/6 53/2 90/25
92/25 103/24 137/1
160/6
comes [1] 124/12
comfortable [1] 57/9
coming [2] 4/7 28/22
commenced [2]
52/10 59/18
commencement [2]
14/9 78/19
comment [3] 32/16
98/17 107/12
commented [2]
81/10 133/18
commenting [1]
108/10
comments [3] 26/24
31/12 110/8
commercial [6] 5/6
16/17 67/17 68/8
134/21 134/23
commission [3] 96/1
114/23 132/19
commissioned [5]
14/21 15/6 130/11
132/8 142/12
commit [1] 56/5
commitment [2] 79/5
128/12
commitments [1]
60/16
committed [10] 2/16
2/22 18/21 19/12 21/3
61/1 145/22 151/18
159/11 159/22
committee [10]
10/23 15/24 16/3
42/12 42/19 50/24
54/13 54/25 74/17
156/14
Committees [1]
15/21
common [5] 8/3 52/7
61/25 136/23 140/5
common-sense [1]
61/25
communicated [6]
6/1 42/7 44/12 87/7
114/13 117/20
communicating [1]
9/22
communication [3]
61/10 62/20 158/13
communications [11]
54/24 81/23 86/21
95/22 97/9 97/16
100/15 110/25 125/16}
136/5 141/23
communities [3]
17/4 17/23 125/3
companies [3] 4/12
148/25 151/5
company [5] 4/9 5/6
24/6 89/11 139/10
company's [1] 55/19
compared [1] 75/20
compels [1] 63/3
compensation [13]
19/16 53/2 53/6
153/10 153/14 153/15)
153/16 153/21 154/12
155/3 155/21 156/12
156/22
competency [1]
15/10
competent [4] 25/5
25/6 51/20 94/1
competently [1]
47/20
competing [1] 24/9
complaints [4] 13/16
58/6 144/7 156/2
complete [9] 23/22
23/23 42/2 44/2 50/18)
69/10 104/15 143/7
157/4
completed [2] 45/3
46/2
completely [3] 54/20
61/24 74/5
complex [10] 24/1
61/23 62/7 119/5
119/5 133/5 134/21
136/2 157/10 157/23
complexion [1] 82/2
complexity [4] 62/17
130/2 132/7 139/12
compliance [1] 12/8
compliant [1] 142/5
compliantly [1] 86/7
complied [4] 47/2
86/3 110/3 152/1
comply [2] 47/15
86/5
complying [1] 50/16
composition [1]
15/10
compounded [1] 5/7
comprehensive [1]
36/22
comprehensively [1]
60/20
computer [14] 26/23
27/8 27/10 32/11
37/23 43/12 91/13
91/22 92/9 104/11
108/12 110/12 122/16}
122/24
computers [1] 108/6
conceal [2] 120/8
120/9
concealed [1] 113/4
conceded [3] 23/6
96/7 109/10
conceived [2] 114/21
114/24
concept [3] 82/19
110/16 135/18
concepts [2] 102/9
102/9
concern [4] 73/10
73/17 76/13 77/14
concerned [5] 35/8
58/7 60/13 76/1 76/24
concerning [5] 63/5
68/16 77/6 93/22
152/14
concerns [12] 7/16
7/20 8/25 9/15 26/20
27/18 37/6 77/22
114/19 131/16 144/6
147/18
concession [2]
110/14 123/2
conclude [3] 64/14
103/6 142/6
concluded [4] 53/18
58/22 149/6 161/12
conclusion [12] 2/5
38/23 39/3 45/1 57/3
63/3 67/11 95/9 95/12!
95/13 107/19 119/22
conclusions [7]
14/23 37/10 50/1 52/2!
83/6 142/10 161/6
conditions [1] 6/15
conduct [12] 33/23
45/22 45/23 47/1
51/10 60/15 70/11
70/16 71/10 72/19
79/1 145/14
conducted [5] 6/6
32/21 42/21 78/6
118/16
conducting [3] 11/15
74/21 135/11
conference [2] 45/25
46/1
confidence [7] 2/23
9/23 18/4 56/19 56/25]
141/6 143/13
confident [5] 24/20
31/15 32/11 35/19
36/16
confirm [2] 124/16
132/9
confirmation [1]
87/18
confirmed [7] 26/6
42/3 43/24 85/18
87/17 87/22 155/15
confirming [1]
113/22
(47) changes - confirming
Cc
confirms [1] 84/18
conflated [1] 108/23
conflict [5] 41/24
49/1 55/22 128/21
148/23
conflicted [1] 50/11
conformed [2] 95/4
95/20
confronted [2]
109/10 119/14
confused [1] 108/23
confusing [2] 80/11
80/16
confusingly [1]
69/13
confusion [4] 73/1
149/1 149/7 149/11
conjunction [1] 62/8
connection [3] 73/25
74/23 112/25
conscious [1] 152/25]
consensus [2]
134/25 146/20
consent [3] 29/10
31/23 114/16
consider [4] 34/3
48/15 105/7 127/22
considerable [1]
92/1
considerably [2]
70/12 70/17
consideration [4]
19/22 19/24 93/19
101/22
considered [11] 7/2
10/3 31/1 33/21 48/9
53/7 64/23 100/5
101/20 115/4 132/5
considering [5] 2/18
9/21 90/14 93/23
98/19
considers [6] 15/4
16/2 16/25 19/5 43/11
107/17
consistent [12] 7/3
7/8 42/23 56/8 74/15
75/15 92/13 106/13
110/16 116/10 120/13
137/5
consistently [7] 6/1
69/17 77/21 100/8
135/22 144/14 145/11
conspicuous [1]
93/8
conspicuously [2]
68/11 93/5
Constabulary [2]
76/4 76/6
constant [3] 41/22
42/5 57/14
constantly [1] 143/20)
constituents [1]
144/5
constructively [1]
154/9
consult [1] 9/25
consultation [1]
159/16
consultative [3] 9/24
16/5 17/19
consulted [1] 34/15
Consulting [1] 18/11
contact [3] 46/17
67/18 116/18
contacted [4] 27/8
73/12 73/24 116/22
contained [4] 52/23
71/1 85/16 142/18
contemplation [1]
104/2
contemporaneous
[5] 22/23 25/2 42/8
63/7 116/16
contemporaneously
[2] 54/9 88/21
contempt [1] 126/11
contend [1] 103/19
content [11] 1/15
59/12 76/10 76/14
85/16 99/7 103/22
106/12 109/23 110/6
115/25
contents [1] 37/18
contest [1] 41/23
context [7] 3/23
64/24 72/20 73/21
75/4 76/11 97/15
continually [1] 63/4
continue [10] 20/25
58/22 68/7 69/20
74/20 154/17 156/8
156/10 159/25 160/13)
continued [8] 18/12
43/17 53/9 57/1 86/10
92/10 116/11 131/21
continues [3] 12/11
65/4 153/2
continuing [3] 2/16
142/15 155/4
continuity [1] 9/9
contract [3] 12/13
77/24 130/3
contracting [1]
129/20
Contracts [1] 146/13
contractual [6] 12/9
67/17 67/21 129/18
129/25 131/6
contractually [4]
71/1
contrary [6] 28/14
29/7 29/24 81/21
89/23 159/18
contrast [2] 52/14
91/8
contribute [1] 78/9
contributed [1]
125/21
control [3] 30/7 30/9
138/14
controls [2] 32/10
32/19
controversial [1]
155/8
conversation [1]
159/5
convey [2] 87/25
120/7
convicted [2] 35/20
155/9
conviction [2] 102/20}
142/5
convictions [5] 43/10]
53/19 57/5 57/15
154/16
Cook [3] 23/13 26/5
26/22
cooperate [1] 74/24
cooperation [2]
60/18 74/21
copied [2] 38/10
54/23
copy [2] 44/5 60/24
copying [1] 46/16
core [16] 2/19 20/13
46/23 50/16 74/1
77/25 90/8 91/14
102/8 103/18 117/8
120/4 128/1 140/1
152/13 154/22
corporate [10] 14/22
61/5 64/16 71/20
125/8 126/11 136/15
139/1 150/12 157/5
corporations [3]
145/15 146/5 158/24
correct [8] 23/17
30/2 37/20 54/12 81/7
106/2 114/12 117/11
correcting [2] 81/14
114/16
correction [2] 10/20
114/9
correspondence [7]
74/2 74/3 76/2 76/17
144/5 144/9 144/13
corrupt [3] 24/23
25/4 32/21
costs [2] 23/16
155/20
could [44] 2/5 2/24
16/23 21/4 23/17
23/23 29/12 30/4
31/13 31/17 31/22
32/4 40/12 47/23
52/12 52/14 64/8
65/16 67/7 77/19
84/15 85/1 106/3
106/7 107/24 110/11
115/1 117/16 117/19
118/2 118/7 119/11
120/10 121/6 121/11
121/12 121/16 122/2
122/19 122/20 123/3
131/12 132/2 148/16
couldn't [2] 111/5
113/17
council [4] 9/24 16/5
17/19 151/4
counsel [29] 15/11
20/16 25/6 33/7 33/22,
43/18 45/11 45/20
46/24 47/6 47/25 48/1
48/7 48/15 49/20
50/15 52/1 52/6 52/16
53/22 55/8 58/4 82/4
90/15 95/1 95/1 98/7
107/14 113/11
Counsel's [1] 90/24
count [1] 8/15
countenancing [1]
4/25
counter [4] 112/9
114/3 114/5 122/3
couple [1] 119/23
course [25] 13/25
14/16 20/10 63/2
64/14 67/13 72/11
77/5 89/24 102/12
104/5 110/5 119/25
124/22 125/3 127/22
132/16 133/10 141/11
145/18 146/8 147/12
154/4 156/18 160/2
court [19] 43/11 67/2
67/3 67/13 70/18
80/14 80/17 81/3 82/7
82/11 82/14 83/21
101/6 102/1 102/22
112/21 116/20 119/13}
141/10
courts [3] 27/23
140/15 152/2
cover [2] 88/16 126/7
cover-up [2] 88/16
126/7
Coyne's [1] 142/19
CPIA [3] 100/3 100/9
108/19
CPR [1] 110/3
CPS [5] 42/16 43/3
102/5 102/7 102/15
created [3] 6/15 31/8
110/23
creating [1] 155/2
creation [1] 139/25
creative [1] 155/5
creatively [1] 133/15
creativity [1] 154/21
credible [1] 24/15
Crichton [17] 25/13
32/16 33/8 33/19
34/21 35/5 38/9 42/14
43/4 43/7 43/23 43/24)
44/1 45/24 46/12
46/25 52/21
Crichton's [2] 7/15
4417
criminal [37] 11/16
33/10 42/16 45/13
47/4 47/6 53/18 59/18)
70/11 72/12 72/14
73/14 73/21 74/7
74/14 74/22 75/1
75/16 76/12 84/12
89/24 92/2 93/2 94/4
96/22 99/20 102/2
102/3 102/4 102/23
140/14 145/24 151/6
151/6 151/16 151/20
152/2
critical [10] 3/17
18/17 18/22 84/8
90/15 137/2 142/23
147/19 152/8 156/24
critically [1] 86/18
criticise [1] 153/20
criticised [2] 82/10
112/11
criticism [2] 117/7
417/15
criticisms [5] 50/9
78/15 81/1 81/4 117/2I
Crowe [1] 54/21
Crown [1] 42/17
crucial [4] 10/14
142/18 158/18 161/6
crystallised [1]
109/12
culpably [1] 140/11
cultural [16] 8/5 8/22
12/16 12/18 13/2
13/23 13/25 14/4 15/1
56/9 128/23 147/5
147/11 156/25 157/2
157/9
culture [22] 13/6
14/14 56/17 56/21
60/15 79/2 102/24
125/9 126/3 128/20
146/11 146/11 146/13)
146/16 147/11 152/8
156/25 157/4 157/8
157/12 157/22 159/6
cumulatively [1]
151/13
curious [2] 1/3 1/5
currency [1] 41/14
current [3] 9/9 20/3
80/5
currently [1] 2/2
cynical [1] 49/15
DO
daily [1] 144/3
damage [1] 1/23
damaged [1] 8/13
Dame [2] 138/13
(48) confirms - Dame
D
Dame... [1] 139/7
Dame Sandra [1]
139/7
damning [1] 142/13
data [38] 6/13 29/13
31/9 32/5 54/5 74/6
75/17 83/16 83/18
88/1 104/22 104/23
105/13 105/14 106/1
106/8 106/9 106/10
106/11 106/14 106/16
106/21 107/4 107/5
108/8 111/17 114/6
114/9 117/16 117/19
117/23 117/25 118/4
118/7 121/3 121/5
121/16 123/12
database [1] 26/15
databases [1] 60/21
date [3] 11/8 35/14
37/21
dated [1] 28/7
dates [1] 70/10
Dave [1] 26/5
Davey [3] 138/2
141/2 143/5
Davey's [1] 141/13
David [2] 52/5 132/5
Davies [1] 54/22
Dawson [2] 138/13
139/7
day [13] 3/15 3/15
11/3 11/3 27/13 32/8
43/21 46/17 118/19
118/23 156/7 156/9
160/24
days [8] 4/18 9/13
38/7 54/16 76/16 91/4
110/4 132/24
DBT [4] 18/2 18/10
19/21 19/25
DBT's [2] 18/13
19/24
deaf [1] 143/20
deal [13] 8/18 17/12
98/13 99/10 103/10
103/17 108/17 112/16}
118/14 118/19 119/4
119/13 138/17
dealing [5] 3/15
34/18 89/13 94/1
139/12
dealings [1] 138/20
dealt [8] 15/16 37/3
40/23 41/3 44/9 94/8
103/25 104/25
decades [3] 4/19
91/22 157/3
deceived [1] 135/23
December [1] 1/1
decide [1] 137/19
decided [5] 55/13
76/16 104/6 112/20
134/13
deciding [1] 34/13
decision [4] 14/25
15/20 24/5 64/21
decision-making [1]
14/25
decisions [8] 15/14
19/2 52/13 55/3 55/5
55/16 113/8 139/13
declaration [3] 93/6
93/10 102/17
declared [1] 74/15
dedicated [1] 140/2
deep [3] 4/15 57/14
157/11
deeply [1] 150/1
defeated [1] 131/18
defect [1] 75/19
defective [2] 97/16
110/25
defects [33] 4/23
11/4 11/24 12/1 24/11
25/1 26/12 35/18
35/21 40/9 41/7 57/12
61/11 61/17 61/18
61/25 62/18 62/21
63/6 63/7 63/10 63/13
63/16 63/23 64/6
64/10 64/19 65/14
68/22 75/9 75/11
75/21 86/16
defence [14] 46/5
87/15 92/23 93/7
97/24 98/15 98/20
100/12 112/14 118/19)
118/20 118/22 121/20)
122/3
defendants [1] 117/3
defender [1] 131/21
defensive [3] 7/7
89/16 146/18
deferential [1] 71/13
deficiencies [2]
70/22 76/9
define [1] 18/6
definitive [3] 35/9
37/9 141/16
deflect [1] 66/13
deflecting [1] 66/25
deigned [1] 152/8
delays [2] 77/9
132/20
delegate [1] 115/15
delegated [2] 57/19
127/16
delegating [1] 98/22
delegation [1] 109/2
deliberate [1] 7/1
deliberately [1]
124/15
deliberation [1] 65/2
deliver [2] 17/12
155/24
delivering [1] 18/20
delivery [4] 18/4
77/20 130/8 153/22
Deloitte [1] 51/25
delve [1] 25/10
demand [1] 24/9
demonstrably [1]
88/13
demonstrate [4]
89/20 99/15 116/14
117/19
demonstrated [21]
41/11 60/10 78/23
85/19 90/12 90/17
91/6 120/18 120/25
121/4 121/9 121/14
121/18 121/25 122/8
122/11 122/17 123/5
123/8 123/10 141/18
demonstrates [7]
70/4 84/24 85/17
90/21 95/18 117/9
143/25
demonstrating [1]
79/4
den [4] 28/25 29/11
29/20 34/9
denied [1] 64/11
depart [1] 161/10
department [51]
25/18 124/9 124/21
124/21 126/14 126/17]
126/21 127/5 127/6
127/10 127/12 127/15
127/19 128/1 128/2
128/5 128/7 128/11
129/4 134/5 135/3
136/24 140/1 144/23
145/19 146/3 147/16
147/21 149/5 150/5
150/11 150/14 150/15}
151/21 152/23 153/3
154/8 154/25 155/17
156/6 156/18 157/3
157/7 157/11 158/1
158/3 158/17 158/19
159/10 159/14 159/22
Department's [5]
129/6 135/6 138/22
145/9 152/19
departmental [3]
129/1 138/25 139/21
depend [1] 138/18
depended [1] 140/6
dependency [1]
68/11
dependent [1] 66/17
depends [1] 137/22
deplorable [1]
151/23
depth [1] 64/18
derived [1] 74/7
describe [2] 67/16
89/17
described [14] 27/3
38/1 39/6 59/24 69/3
87/22 88/22 98/7
108/11 115/19 130/25]
131/1 151/21 153/22
describes [1] 42/25
design [6] 89/22
153/21 154/2 154/5
154/14 158/21
designing [1] 91/18
desire [2] 22/25 58/9
despicable [1]
125/10
despite [14] 68/8
69/19 72/17 81/16
91/5 98/2 100/24
100/25 110/25 118/5
123/18 123/18 131/4
133/7
detail [14] 36/4 41/25
44/7 44/9 52/13 59/20
73/9 82/5 92/25 93/20)
130/2 134/5 134/8
153/4
detailed [13] 1/13 4/2
10/8 11/19 12/6 30/12,
59/16 61/5 70/21
78/11 106/15 106/21
129/4
detected [1] 40/15
deter [1] 151/12
determination [1]
20/25
determine [1] 47/14
determined [2] 68/2
75/2
deterrent [1] 72/16
detract [1] 60/8
detriment [1] 3/21
devastated [1] 58/8
devastating [1] 59/23)
devastation [2]
124/25 128/10
develop [1] 130/14
developed [2] 62/7
67/24
development [9]
128/16 128/25 129/9
130/5 132/23 133/4
140/1 146/1 155/7
devolved [1] 139/1
diagnosed [1] 40/17
Dickinson [8] 43/24
51/25 52/21 52/22
53/3 54/2 54/17 87/20)
did [80] 4/23 5/8 5/14
22/7 22/7 22/8 22/8
23/9 23/18 28/15
28/18 28/20 29/21
30/1 30/25 31/5 31/6
32/5 34/11 34/23
40/21 41/6 44/1 44/3
44/18 44/22 45/1
46/23 48/8 48/15
51/17 52/2 53/24
54/20 56/19 56/24
57/11 57/17 61/19
64/21 69/24 71/11
80/18 81/15 83/12
84/5 84/5 84/22 88/7
88/11 93/5 95/3 95/19]
100/8 103/8 105/4
105/18 106/17 108/5
109/3 109/6 109/8
110/5 112/20 114/18
118/6 119/13 125/7
125/11 131/2 132/2
135/15 135/20 139/24I
142/14 148/15 149/12)
149/20 150/22 150/25}
didn't [25] 57/25 58/1
83/8 83/9 85/9 85/11
86/5 89/11 92/23 93/6
94/4 94/20 95/5 95/22
96/3 103/6 107/11
109/4 110/3 111/13
111/14 114/6 116/7
116/19 122/20
die [1] 88/22
different [13] 1/5
2/11 62/10 82/2 93/17
100/17 120/2 120/4
129/21 142/22 148/18)
148/19 159/13
difficult [6] 57/7
133/5 134/3 139/19
150/5 160/21
difficulties [1] 129/19)
ital [1] 10/25
Dilley [2] 104/7 121/1
direct [5] 47/12 69/14I
105/19 127/6 137/4
directed [1] 46/17
directing [1] 34/13
direction [2] 17/16
158/3
directly [14] 26/4
29/24 33/14 34/11
38/5 41/12 52/5 57/5
71/23 72/3 121/20
131/11 133/11 138/16)
director [8] 9/12 10/9
10/10 11/20 23/14
24/2 26/5 148/25
Directorate [1] 127/5
Directors [7] 136/11
136/11 136/13 136/14I
137/3 139/9 149/6
disaster [2] 118/14
146/3
discharge [4] 100/8
100/21 102/6 108/25
discharged [1]
102/15
discharging [1]
101/10
disciplinary [1] 1571/5]
discipline [3] 21/25
(49) Dame... - discipline
D
discipline... [2]
101/21 160/19
disciplined [1]
160/22
disciplines [1] 25/12
disclose [7] 44/20
46/4 80/19 83/5 113/8)
120/6 122/7
disclosed [12] 3/25
36/14 47/17 48/10
81/21 82/11 82/13
83/23 84/17 100/12
112/21 113/13
disclosing [1] 112/18)
disclosure [37] 45/8
45/13 45/22 47/1 47/3
47/22 48/4 48/9 49/18
55/3 55/6 55/16 75/8
80/6 80/13 80/22
82/18 86/16 88/10
88/20 98/14 98/19
100/6 101/9 102/7
108/18 109/1 109/5
112/2 112/14 113/8
118/11 121/20 126/8
142/6 151/24 152/2
disclosures [1] 50/8
discontinue [1] 51/8
discouraged [1] 5/3
discovered [2] 28/4
28/4
discovery [1] 28/11
discredit [1] 97/24
discrepancies [1]
10/6
discrepancy [4] 8/20
10/11 10/19 11/9
discuss [3] 28/8 89/5
146/25
discussed [4] 31/3
42/13 45/17 56/10
discussing [2] 43/5
123/6
discussions [3]
12/12 15/19 52/21
disentangle [1] 97/11
dishonest [1] 140/11
dishonesty [2] 4/24
126/7
dismissal [2] 76/13
157/19
disorder [1] 50/9
disprove [1] 97/23
dispute [4] 10/18
10/19 10/21 10/22
dissemination [1]
5/4
dissent [1] 95/14
distance [1] 23/1
distinct [1] 101/17
distinguish [1] 85/11
disturbing [3] 84/25
85/2 85/4
divide [1] 135/19
divided [1] 125/3
do [34] 1/15 3/3 7/23
8/11 13/1 21/7 22/9
22/19 24/7 25/12 30/4
44/3 49/16 52/3 56/3
57/24 58/20 59/12
70/23 75/23 92/10
98/13 99/11 102/19
106/25 108/17 118/12)
131/18 138/12 139/16)
148/17 149/20 160/13)
161/3
Dobbin [4] 79/10
80/1 80/2 119/19
doctors [1] 126/3
document [8] 22/9
23/24 30/23 43/25
93/7 93/9 93/11 96/4
documentary [2]
42/18 71/25
documentation [4]
22/11 25/2 26/20
121/22
documents [13] 3/25
22/23 33/3 42/8 45/17
54/10 55/21 58/16
60/22 61/3 72/22
84/18 143/3
does [26] 2/15 3/2
10/17 11/14 21/6 23/8)
29/22 32/20 33/19
55/4 57/10 58/2 69/5
73/24 74/10 74/11
78/12 88/3 96/21
102/24 116/13 126/14)
127/10 127/17 140/2
159/17
doesn't [4] 103/17
106/6 110/6 116/25
dogma [1] 135/9
doing [9] 18/24 41/13
47/21 51/2 58/5 94/6
109/4 122/25 127/15
domain [1] 137/11
don't [7] 57/23 57/25
118/14 119/24 120/1
134/7 161/2
done [11] 8/2 18/8
29/23 48/11 60/1
65/16 85/4 113/25
140/21 148/15 156/7
Donnelly [1] 139/11
door [2] 1/9 1/10
doors [1] 141/8
doubt [7] 24/19 27/21
65/1 114/21 132/17
160/20 161/7
doubts [1] 143/11
down [5] 46/9 119/5
143/22 146/14 159/10)
downplay [1] 24/7
downsides [1] 139/8
DPP [4] 81/22
draft [4] 27/2 107/22
110/8 120/19
drafted [1] 141/24
drafting [1] 101/21
drafts [2] 38/12
100/15
draw [4] 36/11 83/6
95/8 147/1
drawing [1] 132/16
drawn [2] 46/19
147/9
dreadful [1] 128/8
dreams [1] 125/2
drew [2] 17/7 34/5
drive [3] 14/14
151/11 158/15
driven [3] 72/15
106/16 125/5
driving [1] 67/20
Duchy [1] 133/17
due [12] 4/24 32/19
32/19 35/21 36/2
50/11 77/17 121/12
123/3 145/18 147/12
160/2
Duncan [2] 107/14
107/17
during [21] 2/5 2/12
5/18 5/19 26/15 35/2
38/14 39/13 39/16
46/10 49/12 51/13
58/17 70/5 72/18
129/3 129/8 130/5
134/6 143/2 143/4
duties [33] 44/23
45/2 46/4 47/3 47/16
48/23 70/13 82/17
86/1 86/8 86/15 94/10
94/21 95/6 96/4 96/8
99/2 99/4 99/6 99/8
101/7 101/8 101/15
102/6 103/9 103/20
103/22 109/2 115/2
118/10 148/24 148/24
152/2
duty [10] 45/7 98/20
101/9 101/10 128/19
142/5 145/24 146/4
151/19 158/14
dysfunction [1] 15/5
E
each [15] 25/11
45/17 45/19 53/7 60/4
73/14 97/12 114/10
129/19 137/8 137/13
138/20 141/15 141/21
153/15
eager [1] 75/23
earlier [2] 4/21 14/17
early [14] 4/5 4/9
4117 23/14 29/12 37/1
65/20 79/12 79/17
79/18 129/18 130/8
132/24 150/3
easily [1] 129/22
easy [3] 24/23
153/20 157/23
ecosystem [4]
128/22 151/2 151/3
151/11
Ed [5] 138/2 141/2
141/13 141/14 143/5
editing [1] 116/5
educates [1] 13/8
Edwards [3] 38/9
43/4 46/18
effect [3] 4/22 113/23
122/14
effective [4] 12/23
12/24 62/25 139/15
effectively [2] 5/17
5/23
effectiveness [2]
6/18 158/9
efficient [1] 51/16
effort [4] 77/3 120/6
133/16 152/22
efforts [2] 143/23
158/4
egregious [1] 76/15
eight [1] 128/15
either [9] 5/14 5/23
6/11 7/14 36/21 64/8
69/12 104/11 119/8
elected [2] 99/23
113/8
electronic [3] 60/22
60/24 129/10
element [1] 154/3
elements [1] 95/7
Eliasson [1] 20/16
Elliot [1] 157/16
elsewhere [2] 124/23
131/17
email [15] 23/7 23/8
35/5 41/16 43/4 43/7
46/20 54/21 55/24
114/2 114/5 115/17
115/19 116/16 116/23}
emailed [1] 45/24
embarked [1] 77/2
embed [1] 14/3
embedded [1] 13/20
embedding [1] 150/9
embodied [2] 125/10
146/13
emerge [2] 129/7
153/6
emerged [5] 4/8 4/17
5/18 43/8 108/15
emphasis [2] 14/6
146/19
emphasise [3] 36/6
56/19 94/7
emphasised [3]
69/17 138/7 139/7
emphatic [2] 108/11
112/23
empirical [1] 37/12
employed [2] 25/17
68/13
employee [1] 75/6
employees [11] 3/12
5/8 13/9 59/19 60/3
71/22 72/2 72/5 78/4
125/17 136/4
employment [1]
151/5
empower [1] 139/13
enable [4] 9/24 16/10
32/13 134/23
enabled [2] 9/5 99/13
enabling [1] 9/17
encapsulated [1]
102/8
encompassing [1]
62/3
encounter [2] 35/18
92/23
end [9] 12/14 20/22
68/6 69/16 77/16
77/22 119/15 121/15
129/5
ended [1] 30/8
endorsement [1]
94/3
endorses [1] 158/3
enforcement [3]
11/17 73/5 76/12
engage [2] 72/3
143/15
engaged [7] 20/12
34/25 54/3 71/22
71/25 135/15 154/9
engagement [8] 10/9
13/17 17/18 24/4
55/23 69/14 73/5
154/17
engineer [6] 91/13
91/14 92/19 93/20
100/24 123/15
engineering [1]
91/23
enough [3] 14/2
129/18 160/23
ensure [26] 2/24 5/25]
6/9 8/6 9/20 18/4 18/9I
26/7 26/8 36/25 47/2
48/1 73/10 74/10
74/11 99/7 99/25
101/14 102/15 114/12)
114/13 131/3 145/10
148/7 152/20 155/4
ensured [2] 9/9
111/8
ensuring [8] 11/8
13/23 19/13 21/3 52/8)
69/2 79/6 156/11
entailed [1] 114/16
entails [1] 68/19
(60) discipline... - entails
E
enterprising [1]
133/19
entertain [1] 7/9
entire [2] 27/12
105/17
entirely [7] 47/14
56/8 68/21 69/12
105/2 113/23 120/14
entirety [1] 64/2
entitled [17] 25/7
25/13 25/23 33/6
38/25 39/17 43/18
47/25 50/15 51/20
53/21 53/23 64/14
64/18 93/25 143/8
147/24
entitlement [1]
150/24
environment [1] 30/7
equally [1] 2/3
equipment [1] 41/20
Ernst [1] 30/6
erroneous [1] 30/21
error [10] 4/24 75/16
75/19 75/23 87/13
110/12 111/23 120/15
121/21 122/16
errors [31] 4/22
11/23 12/1 24/11 25/1
26/12 26/13 26/18
36/20 57/12 61/11
61/17 61/18 61/24
62/18 62/21 63/5 63/7
63/9 63/12 63/16
63/23 64/6 64/10
64/19 65/14 68/22
75/9 75/11 75/21
86/16
escalate [7] 5/9
28/16 28/18 28/20
29/21 73/18 127/2
escalated [2] 26/20
29/17
escalation [1] 62/20
especially [3] 125/5
130/1 140/16
essential [6] 83/20
123/16 127/22 143/19
150/13 159/19
essentially [4]
127/17 137/17 138/3
144/17
establish [4] 10/11
12/2 58/12 85/25
established [3] 34/3
70/1 83/19
establishes [1] 28/23
establishment [1]
17/18
estate [1] 122/4
ethical [1] 151/2
ethics [4] 60/15 79/1
82/20 85/3
ethos [1] 102/25
evade [1] 152/5
evaluate [1] 132/17
evasive [1] 88/25
even [16] 23/22
31/25 54/9 60/11
67/11 68/5 69/5 70/17
78/24 95/22 101/12
101/12 118/21 120/3
143/18 154/5
events [6] 9/1 19/12
59/23 66/12 88/15
111/11
ever [14] 2/24 21/4
26/11 61/24 67/15
71/7 87/21 99/24
101/16 113/20 113/25)
133/1 141/10 142/14
every [18] 1/23 4/2
13/23 23/24 27/13
33/10 33/16 85/14
94/8 96/6 97/12 97/18
100/13 100/18 105/11
122/3 156/7 160/24
everyday [1] 101/24
everyone [2] 13/21
114/13
everything [3]
102/12 118/16 148/3
evidence [193]
evidence-based [1]
59/10
evidence/information
[1] 46/4
evident [1] 138/7
evidential [2] 61/3
67/11
exactly [4] 25/3
49/13 104/22 117/19
examination [6]
20/18 61/8 90/9
104/21 104/22 121/3
examine [2] 121/7
123/12
examined [1] 64/3
example [22] 25/19
45/24 51/7 52/4 68/4
69/5 87/11 87/25
92/13 97/21 97/22
98/14 98/22 102/13
111/18 130/6 133/4
136/4 142/19 149/16
156/15 157/8
examples [6] 23/3
32/25 98/1 140/25
142/21 145/7
Excellence [2]
136/16 150/12
Except [1] 160/7
exceptionalism [1]
103/5
excess [1] 84/17
exciting [1] 134/4
excluded [1] 66/1
exclusively [4] 60/11
78/24 89/11 91/25
excuse [1] 3/22
executive [20] 6/18
7/6 7/19 9/14 15/17
15/18 15/18 15/21
25/21 25/25 26/21
26/22 29/8 29/18
127/4 136/9 136/10
146/15 146/24 157/17
executives [4] 6/6
6/10 63/24 125/15
exercise [5] 47/19
47/21 96/25 112/5
112/7
exercises [1] 11/14
exhaustive [1]
157/14
exist [3] 63/15
150/22 151/1
existed [3] 10/15
134/11 157/3
existence [14] 4/25
77 31/8 50/2 61/9
61/12 63/5 63/12 64/5}
64/10 75/13 81/20
82/23 155/18
existing [1] 77/18
exit [1] 77/23
exoneration [1]
155/9
expand [2] 9/16
105/3
expansive [1] 64/22
expect [4] 37/13
119/3 138/6 143/8
expectation [4]
55/12 145/3 145/10
150/23
expectations [2]
138/15 146/8
expected [5] 16/18
47/23 49/21 52/14
68/18
expects [1] 158/14
experience [7] 1/25
4/11 5/15 9/12 100/25
144/22 158/20
experienced [7]
18/18 47/4 47/6 68/14
77/9 104/10 113/1
experiences [1] 9/15
expert [101] 31/12
43/20 44/23 45/3 46/9
46/13 48/6 48/17
48/23 50/2 51/18 75/5
80/8 80/13 80/23 82/8
82/17 83/13 83/24
84/1 84/10 84/11
84/14 84/21 85/12
85/12 85/17 86/1 86/1
86/4 86/6 86/7 86/13
86/15 86/15 86/17
86/24 89/9 89/14
90/18 91/18 92/2 92/3,
92/5 92/7 92/15 92/23)
93/6 93/7 93/10 93/24
94/22 94/25 95/6
95/10 95/21 95/22
96/4 96/8 96/11 96/14)
96/18 96/20 97/3
97/22 97/23 98/8
98/11 99/1 99/2 99/7
99/8 100/22 101/3
101/7 101/12 101/14
101/19 101/22 101/25}
102/11 102/16 103/9
103/20 103/22 109/15
109/23 110/17 115/20
118/20 118/21 118/22}
119/4 119/6 119/6
123/21 130/11 132/8
132/13 142/19 154/6
expertise [7] 25/12
34/2 34/6 92/5 134/20)
153/12 153/13
experts [11] 15/25
17/8 27/24 52/4 55/4
92/16 102/6 130/24
137/6 138/11 139/2
explain [18] 3/22
81/6 81/9 81/12 81/13,
81/18 81/20 81/23
82/1 83/14 108/3
108/5 109/4 109/6
109/22 116/11 118/7
123/11
explained [20] 17/25
58/3 61/23 83/16
88/24 89/8 102/10
102/11 107/23 110/12
116/1 116/7 116/12
122/16 129/23 130/14}
139/11 144/21 153/25}
159/3
explaining [2] 44/11
120/20
explains [1] 43/1
explanation [3] 30/3
110/6 120/18
explanations [1]
102/13
explicit [1] 142/3
exploited [1] 146/14
explore [1] 135/17
explored [4] 1/19
72/11 111/4 126/23
expose [2] 127/2
132/14
exposed [1] 59/20
expressed [4] 115/24!
138/2 141/6 149/25
extend [3] 20/11
47/13 146/5
extended [2] 82/21
132/1
extending [1] 19/22
extension [1] 12/13
extensive [2] 67/16
110/8
extent [12] 16/3
57/12 58/12 60/17
67/15 68/2 69/6 73/6
118/24 137/15 144/12)
147/13
external [12] 43/1
47/4 47/9 49/24 50/18
51/24 52/9 53/18 72/3}
100/19 146/21 152/5
extracted [1] 106/8
extraction [1] 108/8
extraordinary [4]
50/22 84/14 101/16
152/11
extremely [4] 20/21
27/11 160/12 160/21
extremis [1] 136/18
EY [2] 30/7 31/6
EY's [3] 30/12 31/3
31/12
eye [1] 152/6
eyes [1] 46/24
F
face [5] 16/16 111/16
121/7 126/12 142/4
faced [1] 86/14
facilitate [1] 159/4
fact [39] 6/11 23/18
36/14 44/19 48/4 48/8)
55/14 57/10 57/15
58/8 64/21 71/11
80/17 81/16 82/12
82/22 85/14 86/17
96/13 97/2 97/6 103/7I
104/1 104/6 106/5
110/7 111/22 112/19
113/16 113/18 113/21
117/22 121/23 121/25)
127/9 127/18 130/4
135/22 154/24
facts [1] 40/6
factual [3] 33/7 55/3
74/25
failed [12] 7/13 8/24
33/20 49/25 51/5
71/21 82/17 120/6
126/20 126/25 127/1
151/13
failing [3] 77/19 83/5
129/17
failings [15] 2/9 3/21
5/21 7/6 14/19 48/24
59/20 67/1 70/16 72/7I
72/10 78/8 78/11
110/21 151/24
failure [18] 6/9 6/19
6/21 7/19 30/3 48/4
71/17 84/1 86/12
90/17 95/9 95/16
99/17 99/19 100/7
(61) enterprising - failure
F
failure... [3] 100/18
105/1 131/18
failures [21] 2/3 2/13
3/19 3/23 8/5 8/14
35/14 60/13 60/15
78/24 79/1 80/13
80/22 95/24 95/25
99/16 99/18 100/4
126/8 127/7 128/9
fair [8] 19/10 19/14
22/12 152/21 153/1
154/18 156/9 156/11
faith [6] 58/6 58/6
58/19 140/7 152/20
158/1
Falkirk [2] 41/1 41/4
falling [2] 137/11
145/3
false [8] 33/19 126/2
126/8 131/20 140/13
141/16 142/8 144/15
familiar [1] 116/13
families [9] 1/21 60/3
78/1 78/5 78/10 125/2
128/11 152/24 156/8
family [1] 19/23
far [11] 17/2 24/3
25/5 55/17 58/7 74/13
97/19 105/17 124/14
146/19 155/15
fault [7] 7/9 10/12
27/5 27/14 47/10
120/21 122/24
faults [6] 53/11 87/13
111/23 120/22 120/23)
121/23
favour [1] 33/16
favoured [1] 133/20
feature [2] 97/18
100/13
featured [2] 100/14
100/20
February [9] 28/10
50/25 54/14 54/17
54/22 73/12 121/4
121/9 123/11
February 2010 [1]
121/4
feel [2] 5/9 57/1
feeling [2] 57/4 89/12
fell [3] 70/12 71/20
100/11
felt [7] 54/18 73/18
104/13 110/19 143/16
143/21 148/16
fetched [1] 105/17
few [2] 133/9 142/21
field [1] 92/5
Fifth [3] 14/16 45/10
98/24
figure [1] 118/25
figures [1] 20/3
files [3] 54/15 54/19
55/1
final [6] 63/19 65/24
73/10 109/14 110/1
110/2
finally [4] 107/14
110/18 112/16 156/24)
Finance [1] 32/23
financial [10] 20/1
24/3 24/6 30/8 62/5
102/21 125/1 151/3
155/16 156/9
financially [2] 16/20
130/19
find [4] 57/22 81/2
89/15 156/20
finding [2] 31/6 67/8
findings [10] 7/8
20/19 35/9 36/2 38/5
43/8 56/6 142/14
147/2 148/13
fine [1] 46/2
finger [3] 23/12
58/10 128/4
firm [1] 146/21
firmly [2] 2/16 21/3
first [38] 6/19 8/24
9/18 12/18 17/3 23/3
26/5 27/6 27/17 28/17
31/18 40/5 44/15 46/8
48/15 61/9 72/22
83/21 84/21 87/5
87/18 91/12 96/25
101/3 103/12 106/2
118/18 118/23 128/24)
129/8 134/19 136/16
137/2 147/23 153/8
153/19 153/24 159/11
fit [5] 24/21 83/1
129/25 132/9 132/12
five [1] 61/5
fix [4] 12/1
fixed [4] 19/20 29/24
40/17 155/6
fixed-sum [1] 155/6
flaws [1] 4/25
Flemington [2] 43/5
43/23
floor [1] 1/11
flourish [2] 19/7
159/16
flow [1] 149/12
flowed [1] 149/11
flows [4] 137/23
flurry [1] 73/14
flying [1] 153/17
focus [11] 8/9 15/19
36/4 72/25 80/15
80/21 80/25 102/1
127/19 137/20 144/13}
focused [3] 5/5 88/15)
144/19
focuses [2] 8/1 86/12
focusing [3] 14/5
37/12 75/17
follow [2] 89/2
139/14
follow-up [1] 89/2
followed [2] 4/19
131/22
following [10] 8/19
9/8 13/6 36/5 49/18
52/21 70/8 141/13
147/22 157/19
follows [6] 35/23
63/6 73/11 129/7
134/9 138/2
force [3] 74/21
105/23 150/9
forces [8] 73/13
73/16 73/23 73/25
74/3 74/24 75/23 76/3
foreign [1] 41/14
foremost [1] 17/3
forensic [3] 37/13
96/24 99/13
forensically [2] 22/6
22/11
foresaw [1] 114/15
form [2] 68/4 146/15
formal [2] 62/24
133/24
format [1] 116/17
formed [1] 151/1
forms [1] 85/5
formulate [2] 34/4
114/25
formulated [2] 100/5
115/6
forthcoming [1]
20/19
forum [1] 131/8
forward [11] 15/22
16/9 16/22 18/25
24/16 45/15 84/11
124/12 131/1 145/23
160/1
found [15] 24/25
33/16 35/15 37/21
38/17 38/20 39/16
47/9 57/13 57/23
80/25 141/10 155/5
160/12 160/20
foundation [1] 14/4
four [12] 36/4 37/10
39/4 39/11 40/5 40/14
73/12 73/13 83/11
83/19 91/4 115/6
fourth [10] 12/14
40/10 45/6 82/6 84/3
91/19 98/10 100/18
149/20 154/20
fraction [1] 144/2
framed [1] 78/21
framework [6] 13/12
13/20 30/10 94/5
138/14 153/13
frankly [1] 62/23
Fraser [7] 8/3 11/25
57/13 81/6 81/22 82/1
83/20
free [4] 35/17 61/24
134/15 134/24
frequently [1] 140/16
fresh [1] 2/21
friend [3] 82/4 103/4
113/11
friends [3] 88/15
92/13 104/16
friends’ [1] 92/11
front [1] 74/5
frontline [1] 131/8
frustrated [1] 146/8
Fujitsu [112] 4/16
12/12 28/7 29/2 29/12}
30/7 30/10 30/24
31/13 31/22 32/1 32/4,
41/11 41/18 46/9
46/16 54/6 59/7 59/10
59/14 60/1 60/18
60/23 61/1 61/6 61/13
61/15 61/20 61/23
62/8 62/16 62/23
62/23 63/4 63/20 65/4
65/4 65/10 65/15
65/18 66/14 66/16
66/17 67/7 68/3 68/11
68/23 69/4 69/9 69/11
69/14 69/15 69/21
70/21 70/24 70/25
71/2 71/4 71/5 71/6
71/9 71/12 71/19
71/21 72/7 72/10 73/3
73/9 73/12 73/17
73/24 74/9 74/20
74/23 75/1 75/4 75/7
75/14 75/24 76/1 76/6
76/9 76/15 76/19
76/21 77/21 78/3
78/10 78/16 79/3
83/23 89/13 91/15
97/23 100/6 100/24
101/6 103/15 106/15
109/4 109/5 109/6
111/10 111/14 111/25}
112/4 115/22 120/21
123/18 125/17 129/21
155/19
Fujitsu's [14] 12/8
12/9 59/9 60/4 60/16
63/18 65/20 68/8 74/2
74/6 74/14 76/13
87/17 104/19
fulfilling [1] 3/5
full [17] 1/17 6/23
19/10 19/13 21/11
39/1 71/9 74/20 75/8
80/19 92/18 111/18
152/21 153/1 154/18
156/8 156/11
fully [7] 19/12 32/11
60/19 61/1 73/11
138/17 141/17
function [6] 7/18
11/14 25/23 68/13
70/2 99/22
functional [2] 27/19
62/3
functionality [1]
130/7
functions [5] 30/18
68/16 98/12 98/23
127/9
fundamental [7] 2/8
12/17 17/11 70/17
84/21 87/4 95/9
fundamentally [4]
10/5 47/20 97/1 115/3I
funded [1] 19/4
funding [2] 19/1
155/14
further [24] 20/4 20/8I
36/23 39/8 41/5 41/6
47/13 54/21 65/3 67/6)
75/12 76/17 76/22
95/24 132/8 132/13
132/20 132/20 141/14)
143/9 155/22 156/16
156/19 159/10
furtherance [1]
154/18
Furthermore [2] 9/16
20/7
future [25] 3/8 8/23
9/25 11/15 16/10
16/18 17/3 18/15
18/22 37/1 50/5 51/1
72/12 74/14 127/25
128/14 145/21 155/22)
156/23 158/6 159/5
159/9 159/13 159/15
159/24
Go
gain [1] 31/21
game [1] 155/7
game-changing [1]
155/7
gaps [1] 155/18
Gareth [4] 72/6 80/4
117/22 159/2
gargantuan [1] 25/9
gathered [1] 115/10
gave [20] 2/1 31/10
40/25 45/20 54/13
83/14 83/25 85/23
86/18 91/4 93/2 97/7
97/8 97/15 121/19
122/17 129/2 141/16
142/3 143/19
GCs [1] 47/19
general [21] 15/11
22/19 25/6 33/7 33/22)
43/18 45/14 45/19
46/24 47/25 50/4 50/6)
50/15 52/16 53/22
(62) failure... - general
G
general... [6] 55/8
58/4 63/3 114/25
135/14 158/24
generalisations [1]
88/4
generalised [2]
86/25 107/11
generally [4] 62/25
68/10 134/20 142/17
generated [1] 102/12
generic [7] 93/14
93/15 94/14 114/21
117/6 117/9 117/14
genuine [4] 10/12
120/16 128/12 154/25
genuinely [4] 131/13
155/7 157/12 161/3
get [10] 42/6 57/25
134/20 135/6 135/15
139/15 139/19 143/23)
154/1 160/9
getting [1] 161/9
give [13] 25/14 33/20
48/4 85/10 92/8 96/2
97/17 107/18 111/5
122/14 127/20 148/17
151/18
given [47] 4/1 7/16
7/20 20/12 22/17
22/21 27/24 28/1 29/7
37/8 38/6 41/8 42/20
43/8 46/13 46/20
47/18 50/13 54/12
57/18 59/15 65/22
69/6 76/22 80/12
80/14 80/14 80/16
80/18 85/6 85/23 88/1
90/5 91/8 101/22
105/22 122/21 130/25)
132/3 134/16 135/20
142/9 143/4 143/7
144/16 149/21 150/4
giving [6] 84/14
85/25 86/10 92/4
129/23 158/6
glad [1] 21/25
glare [1] 154/19
GLO [4] 13/10 55/4
155/2 155/2
gloss [1] 91/7
go [12] 2/13 22/15
43/5 44/10 79/11
79/14 101/10 103/3
126/24 128/13 135/17)
155/2
goes [3] 95/24
155/22 160/11
going [19] 3/3 21/7
21/9 21/11 21/25
49/15 60/24 87/20
101/2 102/18 103/10
112/16 116/15 121/8
1314/1 133/9 139/15
143/14 154/1
gone [9] 60/7 79/4
104/14 106/18 133/1
133/13 148/11 148/13)
149/17
good [15] 58/6 58/7
90/4 119/10 124/25
125/4 133/3 133/9
135/7 139/6 140/6
148/17 152/20 160/18)
160/22
govern [1] 85/3
governance [26] 2/9
3/19 5/21 8/22 14/19
14/22 15/5 15/7 15/23
15/25 30/9 60/15 79/2
128/18 133/25 135/25)
136/15 138/10 138/12!
138/22 139/2 139/6
139/8 150/12 150/21
158/12
governing [1] 62/19
government [51]
16/9 16/19 16/21
18/11 18/14 62/6
125/18 127/3 127/20
128/1 128/6 129/2
130/12 131/11 131/15)
131/20 132/7 132/18
132/24 132/25 133/4
133/8 133/11 133/12
133/21 134/11 134/15)
134/24 138/3 140/14
143/1 145/12 145/22
146/6 150/12 150/18
151/18 152/12 153/10)
153/12 155/1 155/13
155/19 156/1 156/4
156/22 158/13 158/14)
158/25 159/4 159/17
Government's [5]
16/13 19/2 128/12
136/15 154/21
Grant [6] 14/21 14/23
15/4 15/8 18/10 158/8)
grateful [1] 160/13
Greaney [3] 1/8 1/12
21/8
great [5] 56/24 126/5
134/8 160/24 160/25
greater [5] 14/24
16/22 139/22 144/20
150/9
greatly [1] 92/21
Green [2] 18/14
159/11
grips [1] 143/23
grossly [1] 97/16
ground [2] 140/5
155/8
grounds [2] 53/1
104/9
group [16] 6/9 15/3
15/18 15/19 18/11
32/7 34/3 34/8 34/12
38/6 131/7 131/17
131/19 152/13 154/15}
154/22
groupthink [3]
146/24 147/1 149/14
grow [1] 153/2
guess [3] 21/13 54/7
137/12
guidance [8] 84/6
102/5 102/8 102/24
103/7 106/20 106/22
153/13
guide [1] 13/13
guileless [1] 121/22
guilelessly [1] 89/24
H
had [186]
hadn't [3] 84/9
118/21 122/21
half [3] 126/4 134/10
159/12
half-truths [1] 126/4
hallmarks [2] 92/7
141/22
Hamilton [3] 67/3
70/18 80/21
hand [1] 148/21
handful [1] 140/24
handling [1] 37/7
hands [2] 19/2 47/4
happen [5] 2/25 20/3
21/4 126/16 127/24
happened [14] 14/1
60/17 84/16 84/20
85/8 85/19 88/2 90/11
98/17 100/14 117/20
119/12 120/11 123/13
happening [2]
126/20 159/24
happily [1] 51/18
happy [4] 88/25
114/14 120/14 156/18}
hard [8] 11/22 58/4
60/24 99/12 119/11
133/13 152/20 156/10}
hardened [1] 49/12
hardly [2] 149/24
161/2
hardware [2] 41/20
125/24
harm [1] 1/20
has [178]
hasn't [1] 1/9
hatted [5] 128/21
148/20 149/7 149/11
149/12
have [179]
haven't [3] 37/7
116/25 117/1
having [18] 22/24
61/2 69/18 72/4 79/3
82/10 82/13 83/23
84/17 88/22 98/4
99/24 107/24 112/11
117/15 120/13 129/21
143/11
he [225]
he'd [2] 92/9 142/15
he's [1] 114/3
Head [4] 9/13 25/6
31/24 94/4
heading [2] 52/23
158/2
headings [1] 8/19
headline [1] 1/16
headlines [1] 129/7
healthy [1] 151/8
hear [6] 21/19 57/7
59/1 80/11 105/18
160/21
heard [29] 2/11 3/8
3/13 3/24 4/5 5/19 9/6)
9/18 9/20 10/8 11/19
12/14 18/14 25/9
28/14 55/15 57/6
59/15 63/2 72/18 74/9)
106/25 115/19 140/8
149/10 152/12 157/1
158/10 159/25
hearing [2] 131/8
161/12
heart [2] 15/5 126/12
heavily [1] 107/7
held [6] 16/19 19/15
31/9 64/15 68/15
100/41
Helen [6] 44/21 45/9
50/3 51/19 115/8
142/20
helm [1] 25/8
help [6] 11/2 88/25
91/16 125/25 132/14
158/15
helpful [3] 91/2
156/20 160/13
helping [1] 60/16
helpline [1] 125/24
hence [1] 37/8
Henderson [4] 88/21
88/24 89/8 91/24
Henry [4] 82/4
113/11 124/14 157/20}
her [43] 23/4 23/5
23/12 24/1 25/14
25/24 28/20 33/20
33/22 34/22 38/4 40/5)
40/9 40/10 42/19
43/17 44/3 44/4 46/24)
46/24 47/25 49/23
50/21 51/23 52/2 55/6)
55/9 56/24 57/4 57/18
57/21 58/3 58/4 58/9
106/25 107/2 142/4
142/12 142/14 142/14}
143/2 143/4 147/9
here [9] 22/20 90/22
93/8 119/18 132/21
137/2 144/18 151/13
154/3
herring [2] 36/19
37/3
herself [3] 37/18
52/13 57/21
hesitation [1] 89/3
hide [1] 57/10
hierarchy [1] 5/8
high [7] 92/25 115/24)
116/11 123/1 137/10
145/13 151/11
high-level [1] 137/10
highlight [3] 22/14
24/18 144/12
highly [5] 23/25
51/24 62/7 68/14
149/22
highly-specialist [1]
149/22
Hillsborough [2]
145/8 146/3
him [46] 42/2 48/8
48/17 81/4 82/3 82/5
82/13 83/2 83/11
84/13 86/20 86/21
86/25 88/12 89/9 90/4I
93/23 95/22 97/9
97/10 97/21 100/16
100/23 101/7 101/8
101/10 103/21 103/23)
103/24 104/4 104/7
107/23 108/13 109/5
109/6 110/21 111/1
114/3 115/14 115/16
115/18 117/22 119/14I
124/15 141/4 141/24
himself [5] 32/5
80/25 81/2 91/6
116/13
hindrance [1] 139/6
hindsight [7] 24/24
48/11 94/20 132/6
132/12 139/3 153/20
his [417] 12/18 17/10
17/25 19/21 23/13
26/6 26/7 26/19 28/18
30/1 30/3 31/24 43/20)
44/8 44/25 46/1 48/5
48/6 48/7 48/22 49/4
49/18 50/4 50/5 50/8
50/23 51/5 51/13 72/6I
73/16 80/22 81/23
82/6 82/17 83/9 83/10
84/12 85/21 86/2 86/3
86/5 86/7 86/10 86/22I
87/16 88/18 88/23
89/3 89/22 90/14 91/7
91/19 92/19 92/21
92/24 93/1 95/6 96/1
96/4 96/21 96/23
97/10 97/17 97/21
(53) general... - his
H
his... [53] 98/2 98/10
100/15 100/24 100/25)
101/4 103/25 104/10
107/23 108/3 108/4
109/14 109/16 109/21
110/14 110/19 110/22)
112/3 112/23 113/2
114/8 114/17 115/21
116/23 117/6 119/2
119/13 120/13 120/14}
120/15 120/16 120/18
120/19 120/25 121/4
121/9 121/14 121/15
121/22 122/8 122/11
122/13 122/19 122/23
122/25 123/2 123/5
123/10 123/11 123/19}
133/18 142/16 158/4
historic [1] 44/9
history [3] 2/7 133/6
157/17
HNG [5] 26/14 28/3
41/1 44/21 65/9
HNG-X [5] 26/14 28/3
41/1 44/21 65/9
Hodge [1] 90/8
hold [2] 4/21 99/1
holder [1] 99/21
holding [2] 6/18 67/4
holdings [1] 41/14
honest [6] 53/24
123/19 137/22 137/25}
140/7 150/24
hope [1] 161/7
hopelessly [1]
125/22
hopes [4] 4/1 79/3
128/11 158/14
Horizon [160] 1/24
2/6 3/6 4/17 4/22 4/23
4/25 5/15 5/22 5/23
6/12 7/10 8/4 8/21 9/1
10/6 10/18 11/5 11/23
12/1 12/10 12/13 13/9
13/10 24/3 24/8 25/25)
26/13 26/21 26/25
27/3 27/5 27/7 27/11
30/1 30/11 32/11
33/12 35/1 35/10
35/17 35/21 36/8
36/15 37/23 38/18
38/21 40/8 40/21 41/3
41/5 41/12 43/12 48/6)
53/11 56/16 57/13
61/11 61/17 62/3
62/11 62/14 63/13
65/5 65/8 65/13 65/16)
65/21 67/6 67/17
67/23 68/7 68/17
68/19 69/1 69/2 69/4
69/9 69/25 70/3 70/10
TAIT 75/6 75/9 75/17
77/4 77/7 77/11 77/15)
77/16 77/18 77/24
80/14 80/20 81/1
85/11 87/2 87/14
87/25 88/14 89/21
91/19 91/21 92/19
97/22 97/25 100/1
105/10 106/24 107/5
107/6 108/11 111/6
111/21 112/24 113/1
113/17 115/14 115/11
116/1 116/11 116/12
117/7 118/6 120/7
120/9 121/24 122/20
123/7 124/23 125/22
126/1 127/1 128/17
128/25 129/13 129/16)
130/3 130/4 130/10
130/18 131/7 131/11
131/21 132/9 132/12
132/23 133/7 133/15
141/4 141/7 141/11
141/17 144/9 154/12
154/15 155/10 155/21
157/18 159/23
Horizon's [1] 131/24
horizontally [1] 5/23
hostile [1] 59/17
hour [3] 1/17 21/11
119/16
hours [1] 11/6
house [2] 63/25 70/8
how [36] 1/5 16/23
34/18 40/23 42/6 43/1
57/23 84/15 84/20
85/19 86/19 88/4 88/6
88/8 96/23 97/7 98/8
99/13 101/8 101/9
101/10 102/6 103/22
106/23 107/5 107/24
115/20 116/1 118/16
118/25 119/9 119/11
139/4 144/21 145/13
156/21
however [10] 13/25
31/24 36/8 48/19 75/1
105/24 106/7 115/23
127/25 130/24
HSS [1] 20/2
Hub [2] 10/25 11/6
Hudgell [2] 90/8
154/22
Hudgells [2] 117/8
152/13
huge [1] 24/8
hugely [1] 154/13
human [7] 22/25
59/17 59/22 60/14
78/8 78/25 85/19
humbling [1] 1/25
humour [1] 160/19
hundreds [2] 3/25
70/13
hypocrisy [1] 82/15
l accept [1] 49/16
laddress [1] 61/13
lam [4] 57/22 103/10
160/13 161/5
lasked [1] 23/5
I can [4] 72/9 74/5
134/8 161/2
lcan't [1] 119/9
I come [1] 160/6
I did [1] 105/4
I didn't [1] 57/25
Ido [9] 1/15 7/23
22/19 24/7 57/24
59/12 70/23 99/11
161/3
I don't [5] 57/23
57/25 118/14 134/7
161/2
lend [1] 119/15
I felt [3] 54/18 143/16
143/21
I find [1] 89/15
I get [4] 160/9
I guess [1] 21/13
Ihad [1] 148/10
Ihave [5] 78/18
119/18 160/11 160/12
160/24
I hope [1] 161/7
include [1] 96/8
lintend [1] 128/15
I live [1] 160/6
I make [3] 124/8
124/20 161/4
I may [4] 23/3 91/11
99/10 103/10
I mean [1] 89/2
I mentioned [1] 45/4
Inext [1] 152/17
I notice [1] 103/18
I now [2] 23/20 24/11
I pause [1] 90/23
I pay [1] 160/9
I propose [1] 1/16
I quote [4] 24/14
30/17 32/9 49/6
I refer [1] 140/24
I regret [1] 109/19
l remind [2] 119/1
122/6
I repeat [1] 69/21
l requested [1] 89/2
Ireturn [1] 156/24
I said [2] 7/23 138/21
I saw [1] 89/9
I say [1] 60/7
I sensibly [1] 161/5
I shall [2] 14/8 22/13
I should [1] 103/13
I start [2] 103/12
152/19
I suggest [1] 124/11
I suspect [1] 79/11
I thank [1] 160/23
I think [5] 1/8 21/12
21/24 80/1 124/1
Iturn [4] 108/14
114/20 128/24 133/23}
I understand [1]
103/3
I want [1] 86/11
I wanted [2] 91/10
99/10
Iwas [3] 1/5 57/22
94/21
Iwill [7] 8/18 96/9
98/13 145/18 160/13
161/3 161/4
I won't [2] 105/3
153/5
I would [9] 1/22
21/15 79/14 95/14
148/11 148/11 148/13}
160/15 160/17
I'd [2] 143/13 160/6
I'd say [1] 160/6
Il [9] 1/9 92/25
119/22 126/24 135/17]
137/1 147/11 153/5
161/5
I'm [7] 21/10 21/25
42/5 49/13 49/14
65/19 112/16
I've [7] 39/21 69/20
77/25 78/16 94/20
122/25 151/17
lan [1] 132/5
Ibbotson [1] 119/12
Ibbotson's [3] 93/9
93/11 118/24
ICL [1] 129/21
idea [4] 82/22 94/20
105/14 119/10
ideas [1] 133/22
identification [2]
61/10 62/20
identified [13] 5/3 8/5]
11/7 11/24 15/7 34/25]
35/3 36/7 39/10 45/21
51/13 63/20 95/8
identify [6] 3/7 11/25
56/21 140/19 145/16
155/18
identifying [1] 91/20
if [31] 20/5 20/7 21/9
21/11 23/3 40/10
46/18 48/20 55/14
67/6 73/2 79/14 79/18
79/18 86/6 91/11 92/1
95/2 99/10 101/2
101/12 102/17 103/10}
107/17 120/5 135/12
139/16 148/10 149/12)
154/5 154/5
ignored [2] 84/23
110/22
ii [4] 50/2
iii [1] 50/3
Ikarian [1] 102/3
illustration [2] 63/18
133/9
imagine [1] 137/17
imagined [1] 85/1
imbalance [1] 10/14
immediate [1] 121/10)
immediately [1]
131/25
impact [8] 59/17
59/22 59/23 59/24
63/5 63/16 77/20
113/19
impacted [3] 28/6
40/10 41/2
impacting [1] 28/9
impartial [2] 140/19
149/3
imperative [2] 56/9
101/2
imperfect [1] 154/5
impermissible [1]
109/2
implement [1] 31/3
implementation [5]
10/1 16/6 17/11 17/16)
56/12
implemented [2]
8/16 13/16
implementing [3]
17/1 18/21 158/8
implications [1]
39/23
implied [1] 135/4
importance [10] 6/12
9/7 24/8 56/24 99/5
134/2 139/9 149/1
149/2 150/9
important [18] 5/11
11/7 25/21 40/22 57/2I
61/2 70/12 86/18
89/19 90/19 94/7
105/23 109/21 110/14)
1417/4 152/4 154/13
160/8
importantly [2] 66/3
79/6
impossible [3] 96/17
97/11 137/16
impression [3] 40/25
45/20 47/18
imprisonment [1]
102/20
improper [1] 151/15
improve [8] 15/10
15/13 15/20 18/3
56/21 133/16 156/21
157/7
improved [5] 10/24
14/12 17/14 150/8
158/15
improvement [4]
(64) his... - improvement
improvement... [4]
11/12 56/17 154/18
158/11
improvements [11]
2/18 8/22 11/23 12/3
15/1 30/11 56/6
145/21 150/6 154/10
156/10
improving [1] 157/12
inaccuracies [1] 81/8)
inaccuracy [1] 82/15
inadequate [6] 6/16
6/23 7/11 49/25 51/10
98/8
inappropriate [4]
30/14 30/19 51/11
151/12
inappropriate/unauth
orised [1] 30/19
inappropriately [1]
7113
incapable [1] 91/6
incarnation [1] 80/6
incessant [1] 134/24
include [5] 13/6
38/22 38/24 96/8
107/24
included [10] 25/18
30/8 30/12 54/5 95/7
95/15 96/10 100/11
122/19 141/25
includes [5] 3/10
63/23 151/3 151/9
159/6
including [32] 7/11
11/1 11/24 12/4 13/7
14/2 14/18 15/23
28/25 34/8 47/16
50/12 51/25 62/5 65/8
65/13 68/4 68/14
68/16 68/21 75/10
75/21 112/5 122/3
122/13 125/14 133/14}
134/1 138/8 141/17
150/7 151/7
inclusions [1] 96/11
inclusively [1] 78/22
income [1] 17/14
incoming [1] 6/10
incompetence [4]
82/21 85/1 90/20
126/6
incompetent [1] 94/9
incomplete [6] 22/16
33/1 44/14 51/3 54/12
140/13
inconsistent [3] 94/9
115/2 120/3
incorrect [2] 22/16
33/1
increase [5] 14/11
17/13 70/4 70/6
149/13
increases [1] 30/19
increasing [1] 77/18
increasingly [4] 77/8
136/8 137/9 137/10
incremental [1]
154/17
incrementalist [1]
153/21
inculpated [1] 125/10]
incurious [1] 146/19
indeed [24] 26/19
44/4 61/19 65/14
69/11 70/14 81/1 87/8)
90/2 93/11 94/2 106/1
113/5 113/21 125/8
129/14 132/9 134/13
135/8 139/5 146/6
149/12 151/2 153/9
independence [3]
49/22 134/14 134/16
independent [10]
49/7 75/5 97/20 97/21
101/5 132/8 142/1
149/2 149/3 155/24
independently [1]
19/16
indicate [1] 40/22
indicated [3] 77/21
150/3 157/1
indicates [3] 137/14
140/8 148/20
indicator [1] 104/3
indifference [1]
146/12
indifferent [1] 140/10
individual [7] 41/10
53/8 82/19 84/4 100/9
126/6 127/8
individually [1]
125/12
individuals [9] 3/17
5/12 56/23 60/23
63/20 63/25 68/14
69/13 140/6
induction [1] 13/8
inescapable [1]
126/19
inevitable [3] 4/13
22/24 144/14
inevitably [2] 49/15
74/6
infallible [4] 87/3
87/25 88/14 120/7
infected [3] 145/6
146/1 146/24
infer [1] 64/18
inference [2] 46/19
73/22
inflexible [1] 135/9
inflicted [1] 128/10
influence [1] 47/11
inform [5] 9/14 40/5
40/8 40/10 142/14
informal [1] 62/24
information [92] 5/4
5/22 11/1 11/9 15/14
20/8 20/10 22/15
25/24 29/5 33/2 33/2
33/14 33/20 34/13
35/1 38/6 39/22 41/8
46/4 46/7 46/18 46/20
48/5 51/3 51/6 54/12
57/18 57/24 58/2 58/9
58/11 58/13 62/24
63/4 67/7 68/20 68/24
74/17 81/19 82/9 87/6
87/9 88/7 88/9 88/19
89/21 89/23 89/25
90/3 98/3 99/25
100/10 111/2 111/3
111/20 112/1 112/10
112/14 115/9 120/8
121/18 123/20 127/2
132/18 135/16 135/20
137/20 137/23 137/25}
138/6 139/17 140/7
140/13 140/20 141/1
141/3 141/15 142/18
142/23 143/8 143/10
144/2 144/13 144/15
145/17 147/25 148/6
148/7 149/4 150/24
156/3
information-sharing
[1] 62/24
informed [16] 5/2
17/17 19/21 25/21
28/10 46/14 46/16
48/21 48/22 55/24
74/8 97/21 111/22
111/24 131/24 147/5
infrastructure [4]
62/15 77/17 77/19
77/23
ingrained [1] 150/1
ingress [1] 65/7
inherent [2] 62/17
137/10
inherently [1] 150/5
initial [5] 36/2 36/5
65/7 70/6 154/5
Initially [1] 62/11
initiatives [2] 12/15
13/5
injustice [1] 19/17
injustices [1] 14/20
inkling [1] 31/25
inner [1] 143/1
innocent [1] 125/4
innovation [2]
154/25 157/8
input [5] 26/9 30/24
38/9 115/22 154/6
inquiries [2] 48/24
147/3
inquiry [138] 1/4 1/13
1/20 1/25 2/5 2/10
2/17 3/4 3/9 3/13 3/16
3/18 4/1 4/2 4/5 9/2
10/8 11/13 11/19 12/6}
12/11 12/14 12/19
13/5 18/1 18/13 20/4
20/6 20/7 20/13 20/16
20/19 21/2 22/10
28/13 28/23 31/15
48/12 55/9 55/14
57/23 58/17 58/22
59/9 59/15 59/15
59/20 59/22 60/5 60/9
60/12 60/16 60/18
60/21 61/2 61/6 61/15)
61/22 63/2 63/19
63/22 64/3 64/8 64/13
64/17 65/2 65/3 65/11
65/18 65/23 66/13
66/21 67/12 70/15
72/11 72/18 73/8 74/4
74/9 75/3 75/15 76/24,
77/1 77/5 77/12 77/25)
78/6 78/7 78/19 78/21
79/3 79/5 80/5 83/19
84/17 84/24 87/10
90/16 90/22 90/23
90/25 92/21 96/5
99/11 105/7 105/18
107/23 112/19 113/3
118/11 119/25 124/23}
126/24 127/22 128/2
129/3 129/5 129/24
132/17 140/8 140/23
145/2 145/6 145/6
145/16 145/20 146/1
146/15 149/10 152/6
152/15 154/19 156/19)
157/1 158/10 159/4
160/1 160/16
Inquiry's [10] 20/20
60/19 62/2 64/7 86/23
137/6 138/10 156/4
156/21 160/2
inside [1] 125/14
insight [2] 4/2 142/25)
insinuation [1] 87/1
insisted [1] 131/4
insistence [1] 121/5
insofar [1] 108/25
instances [1] 61/18
instead [2] 78/25
153/5
instigation [2] 32/24
142/12
instil [1] 13/14
institute [2] 92/6
149/5
institution [4] 126/13
146/23 157/21 159/21
institutional [4]
64/20 64/22 126/6
146/11
instruct [5] 84/1
86/13 90/18 95/10
99/6
instructed [21] 48/16
48/18 48/22 80/8 82/8)
83/13 83/24 84/10
84/13 84/20 86/17
86/24 94/25 96/14
96/18 96/20 98/9 99/1
101/3 102/7 103/9
instructing [2]
101/13 115/18
instruction [5] 94/22
96/23 101/19 101/21
109/19
instructions [7] 95/4
95/6 95/20 95/21
95/23 96/3 96/6
insufficient [3] 5/10
53/5 77/15
insufficiently [2]
144/25 151/17
insurers [1] 7/22
integral [1] 13/3
integrated [1] 129/10
integrity [20] 24/19
26/1 26/21 27/7 27/22I
31/9 33/12 61/19
63/17 69/8 70/22
105/10 105/17 106/4
107/4 107/12 131/25
141/5 141/18 152/9
intelligence [1]
158/25
intend [4] 1/15 7/23
128/15 134/7
intended [6] 12/15
13/13 14/3 60/8
106/20 116/22
intends [2] 11/10
18/5
intense [1] 102/1
intensive [1] 133/7
intention [1] 11/15
interest [4] 49/1
72/14 159/14 160/16
interests [8] 5/6 8/18
16/11 17/22 85/7
152/9 156/11 159/23
interfaces [1] 62/10
interference [2]
134/15 134/24
interim [22] 7/5 7/14
15/11 17/9 17/25
18/18 18/19 37/19
38/8 38/12 38/18
38/23 38/24 39/2 39/6I
39/12 40/25 43/8
45/12 55/24 56/12
T7IM14
internal [10] 18/11
39/15 43/1 72/3 72/21
127/21 138/25 146/20)
146/20 149/15
internally [1] 29/7
interpretation [2]
(55) improvement... - interpretation
interpretation... [2]
107/16 107/18
intervened [1] 132/1
interventionist [1]
71/15
interview [1] 80/7
interviewed [1] 80/4
intimidating [1]
12/20
into [25] 4/2 9/3 9/18
10/3 13/20 25/11
27/15 33/14 40/12
41/12 43/5 43/15 46/3)
48/24 70/9 74/22
86/10 101/18 112/7
113/17 116/4 116/17
118/3 142/25 146/3
introduce [1] 145/23
introduced [3] 12/15
15/15 41/4
introduction [4] 13/7
69/25 70/8 99/9
inversely [1] 77/19
investigate [4] 27/15
58/5 90/5 120/11
investigated [2]
33/25 42/9
investigates [1] 10/6
investigation [21]
7IN7 20/17 34/2 35/8
35/13 35/25 37/7
37/21 39/13 39/16
41/6 53/10 54/5 54/8
58/23 70/1 72/14
74/22 78/7 125/17
136/5
investigations [19]
11/16 11/18 40/12
59/17 64/1 69/24
72/12 72/22 72/23
73/4 73/5 73/14 73/21
74/1 74/8 75/1 76/20
99/21 120/10
investigative [2] 70/5
70/7
investigator [2] 94/8
100/19
investigators [8]
72/19 80/11 82/19
84/4 84/22 100/7
103/7 105/9
investigatory [1]
39/5
investment [2] 75/13
7715
invidiously [1]
125/19
invite [2] 67/13 105/7
invites [1] 3/18
involve [2] 52/13
112/5
involved [13] 29/20
34/1 34/14 55/5 81/17)
83/7 91/18 92/6 107/7I
108/6 134/21 135/6
154/13
involvement [10]
18/13 23/21 90/12
90/14 92/19 92/20
92/21 92/24 93/1
93/16
involves [2] 125/13
153/15
involving [1] 72/13
OD [1] 149/5
1OD's [1] 158/22
irony [1] 88/17
irredeemable [1]
130/11
irrelevant [3] 96/15
96/17 98/25
is [232]
ISDN [1] 26/13
Ishaq [2] 117/13
118/15
Ishaq's [2] 93/8
98/16
Ismail [1] 157/16
Ismay [6] 28/25
29/11 29/20 29/24
29/25 32/9
isn't [5] 96/4 101/23
117/11 119/25 148/17,
isolation [1] 96/22
issue [14] 23/10 27/7
31/1 39/1 45/17 46/19)
54/18 82/16 92/22
105/5 113/4 123/21
134/3 152/17
issued [1] 10/20
issues [55] 3/15 5/2
5/9 8/3 8/4 11/4 11/4
15/7 15/16 26/8 26/9
27/16 36/7 36/13
37/21 38/3 39/10
39/16 40/14 45/8
45/21 47/1 47/22 52/7)
60/10 60/11 67/5
68/22 72/11 78/22
80/14 81/1 83/22
111/15 112/8 115/11
118/2 118/6 119/5
119/6 121/13 122/20
128/15 131/24 132/2
132/4 137/16 137/21
141/6 141/15 143/15
143/20 143/23 144/6
144/19
it [389]
it's [50] 21/9 32/4
60/6 66/10 66/19
68/13 74/1 76/2 76/7
77/8 79/10 92/3 93/8
94/6 95/2 95/13 99/14
99/15 106/1 106/5
106/19 107/9 117/4
119/3 119/11 120/2
120/18 120/25 121/4
121/9 121/14 121/18
121/25 122/11 123/5
123/8 123/10 126/10
127/21 132/25 133/1
139/20 144/1 145/9
148/3 153/20 154/11
156/13 160/7 161/8
its [146] 1/19 2/8
2/14 2/20 3/5 4/20
5/20 6/3 6/7 6/20 6/23
8/8 8/12 8/13 8/20
14/15 12/22 14/14
14/21 16/15 17/1 18/4]
18/9 18/25 19/5 19/13
20/1 20/11 20/23
20/24 20/25 26/9 27/9
28/11 32/12 33/7 34/5I
39/13 43/22 47/2
47/15 51/9 53/7 54/3
54/10 56/5 60/2 60/18
61/15 64/24 65/3
65/18 65/24 66/10
66/11 67/1 67/10
68/12 69/1 69/11
69/22 71/14 71/14
71120 71/22 71123
72/7 72122 73/9 74/11
74/15 74/16 75/8
76/10 77/1 77/12
7717 77/21 78/3
78/10 79/4 79/5 80/5
81/20 85/1 85/2 95/2
98/23 99/19 99/22
102/5 102/15 102/21
109/1 109/2 109/5
115/25 122/19 123/22]
125/9 125/16 125/18
126/10 126/14 127/16
127/17 128/7 128/8
128/8 128/11 128/13
128/25 131/3 131/18
133/14 134/5 135/11
136/4 138/23 139/1
140/9 141/18 142/5
143/17 145/10 145/14]
146/13 146/15 148/8
149/6 149/21 150/7
150/11 150/15 151/21
152/2 153/3 153/4
153/9 155/13 157/5
158/7 158/22 159/6
159/15 159/20
itself [7] 36/8 66/15
107/5 117/9 125/6
127/5 128/6
iv [4] 50/6
qa
Jacobs [1] 157/16
jaded [1] 49/15
jail [4] 125/4
James [4] 33/15 36/3
143/5 146/2
January [4] 23/18
24/17 29/16 33/8
January 2012 [1]
24/17
Jason [1] 142/19
Jenkins [151] 44/19
44/22 45/1 45/18 48/4
48/16 48/18 48/21
50/4 50/8 50/13 55/11
72/6 80/4 80/17 80/22,
80/24 81/7 81/12
81/15 81/17 82/7
82/21 82/22 83/1 83/3)
83/8 83/9 83/23 83/24
84/1 84/9 84/11 84/19
85/10 85/11 85/12
85/22 85/23 86/13
86/17 87/5 87/8 87/11
87/15 87/16 87/24
88/3 88/22 89/20
90/11 90/18 90/21
91/3 91/12 91/13
92/12 92/15 92/18
93/4 93/6 93/12 93/13)
93/20 94/4 94/24 95/3)
95/5 95/10 95/19 96/1
96/3 96/6 96/8 96/14
96/17 96/19 97/1
97/15 97/20 98/2 98/3}
98/10 98/25 99/2
99/16 99/19 100/14
100/20 100/23 101/17}
103/20 104/1 104/6
104/8 104/12 104/17
104/23 107/21 108/10}
108/16 109/1 109/3
109/9 109/11 109/13
110/9 110/10 110/13
110/15 110/16 111/1
111/2 111/5 111/13
111/16 111/24 112/3
112/6 112/11 112/17
112/23 113/4 113/15
113/20 114/1 114/8
114/15 115/7 115/8
115/12 115/17 115/21
115/25 116/7 116/12
116/14 116/18 116/21
116/24 117/5 117/13
118/2 118/6 118/8
118/18 119/11 120/5
121/19 122/1 123/15
Jenkins’ [11] 45/7
80/13 85/14 88/18
104/25 109/16 109/19)
Jenkins's [2] 116/10
117/10
Jennings’ [1] 116/15
jeopardy [1] 151/15
JFSA [2] 34/1 36/3
JFSA's [1] 141/19
Jo [5] 23/3 142/3
90/3 93/10 93/16 94/7)j
143/1 147/6 149/16
job [3] 44/3 137/12
140/17
jobs [1] 65/16
John [1] 76/19
Johnson [1] 131/23
join [2] 4/14 23/18
joined [1] 4/6
joint [2] 92/16 93/5
Jonathan [2] 142/13
159/3
Jones [1] 90/8
Jones' [1] 146/2
judged [2] 3/2 21/5
judgment [4] 67/9
80/14 80/21 81/2
judgments [3] 8/3
80/15 102/22
judicial [2] 43/11
74/18
Julie [1] 142/19
July [25] 7/15 13/11
33/24 35/23 37/16
37/19 40/24 41/9
41/17 43/3 43/14
43/21 43/22 44/13
44/18 45/5 45/5 46/7
52/22 55/25 72/21
73/12 76/7 121/18
153/11
July 2010 [1] 121/18
duly 2024 [1] 73/12
juncture [1] 18/17
June [9] 9/4 9/10
13/11 17/6 33/4 33/15I
42/13 42/19 74/16
junior [3] 5/8 94/15
136/18
just [17] 13/19 23/3
43/12 69/20 79/10
80/5 84/18 89/19 98/1
98/21 101/16 103/6
106/2 108/7 140/24
142/21 156/15
justice [16] 2/7 8/3
11/24 57/13 59/22
60/12 76/23 78/3
78/20 78/23 81/4 81/6I
81/22 82/1 83/20
151/6
KC [1] 119/4
KC's [1] 142/13
keep [3] 5/1 25/20
87/10
Kemi [1] 154/20
kept [3] 11/8 11/11
¢
(56) interpretation... - kept
KO
kept... [1] 111/14
9/6 9/21 13/14 14/7
22/8 35/6 36/6 56/5
58/2 64/20 68/24
86/14
kicked [1] 159/9
kind [1] 103/6
King [17] 44/6 44/19
48/1 48/24 48/25
49/11 50/11 52/1
83/17 84/2 94/17
94/18 95/3 98/6
114/22 116/6 118/16
King's [22] 44/15
45/11 45/12 45/22
47/6 48/1 48/7 48/15
49/5 49/8 49/20 52/6
82/4 90/12 90/15
90/17 90/24 94/25
95/1 98/7 107/14
113/11
Kingdom [1] 62/13
knew [8] 23/4 29/11
31/20 37/18 51/4 67/5
82/12 113/24
know [27] 1/10 22/7
24/25 31/5 31/7 34/18
49/19 57/23 57/24
57/25 58/2 59/10
73/24 84/5 84/23 94/5
98/15 103/8 106/25
111/13 116/7 116/19
119/16 122/20 145/22)
148/19 161/3
know-how [1] 34/18
knowing [6] 24/24
102/19 113/3 119/6
119/7 123/2
knowledge [30] 5/25
6/5 11/5 22/9 23/10
26/16 28/16 28/18
28/20 29/4 29/9 29/14
29/17 29/22 29/23
34/5 48/5 63/7 63/23
64/2 64/11 64/14
64/16 64/21 64/23
75/8 103/24 116/2
130/22 132/12
known [12] 26/12
37/24 51/4 87/12
87/15 111/23 113/5
113/7 121/11 121/21
122/22 140/23
knows [2] 33/18 57/8
L
lack [12] 6/4 6/13
12/21 12/23 12/24
12/25 41/25 69/10
100/25 120/16 152/22
154/21
key [15] 3/7 5/22 6/25
lacked [2] 5/12
136/22
laid [1] 78/20
Lancashire [2] 76/4
76/5
Lancaster [1] 133/17
Langstaff's [1]
145/25
language [4] 73/20
93/18 120/15 121/1
large [13] 37/23 62/7
77/3 81/10 129/16
134/21 136/1 140/15
144/11 144/18 157/9
157/22 159/7
large-scale [1] 77/3
last [5] 3/9 4/3 37/15
122/4 133/18
late [2] 4/9 131/23
later [9] 4/8 25/20
95/3 137/1 154/1
latest [1] 29/11
laudable [1] 129/14
launched [2] 13/11
153/17
law [12] 11/17 47/22
52/15 73/5 84/23 85/3)
85/13 94/4 103/1
151/5 151/6 151/17
lawfully [1] 94/2
laws [2] 82/20 84/6
lawyer [11] 46/21
47/23 52/1 52/12 94/3
94/8 96/6 100/19
100/19 101/1 101/16
lawyering [1] 101/23
lawyers [41] 43/2
47/4 4719 47/14 48/14
48/25 49/3 53/18
54/11 63/25 71/23
72/4 72/19 82/19 83/7
83/16 83/17 84/22
85/9 88/5 88/12 93/25)
94/5 96/1 98/1 98/6
99/6 102/2 102/25
103/8 105/8 112/19
116/6 123/19 123/22
125/20 126/9 151/22
152/3 152/8 152/14
lay [4] 2/8
layers [1] 139/16
layperson [1] 99/3
lead [2] 30/20 52/16
leadership [7] 2/21
12/24 125/18 131/14
138/5 152/7 158/2
leading [3] 7/22 52/1
157/19
learn [3] 2/17 133/20
154/3
learned [9] 73/7 82/4
88/15 92/11 92/13
103/3 104/16 113/11
38/7 54/16 76/6 76/17,
127/25
128/12 159/22
learnt [3] 3/7 133/2
153/10
least [8] 16/2 63/11
63/20 107/16 146/17
147/4 149/20 153/25
leave [2] 114/7 131/2
led [15] 12/21 48/23
53/16 71/16 74/19
136/9 139/22 148/22
149/1 149/7 149/13
149/18
Leek [7] 21/9 21/10
21/20 22/3 22/3 22/4
58/24
left [7] 26/2 28/19
113/25
Legacy [2] 26/13
65/8
legal [31] 2/7 6/22
6/25 19/19 23/16
27/21 28/1 32/23
42/22 46/25 47/16
49/21 49/24 50/17
50/18 52/3 52/9 54/3
54/25 55/1 55/13
64/24 91/13 91/16
91/17 93/21 123/15
128/22 141/10 151/2
152/4
legislation [4] 134/14
145/23 155/4 155/8
legislative [1] 135/4
legitimate [1] 55/20
lend [1] 74/11
length [6] 103/18
134/9 134/11 135/1
135/4 145/15
Lenton [1] 107/7
Lesley [3] 32/9 46/8
68/14
less [9] 3/14 37/17
49/8 49/9 80/24
103/21 111/8 114/18
119/21
Lesson [1] 153/10
lessons [8] 2/17 3/7
21/1 73/6 79/5 127/24
128/12 133/2
let [4] 1/9
let's [1] 119/24
letter [14] 24/17 27/2
30/13 42/12 74/16
76/3 76/10 76/15
81/21 101/21 103/14
103/15 103/20 141/24]
level [13] 4/10 5/11
9/21 15/17 89/14
115/24 116/11 123/1
137/10 139/12 146/16}
learning [4] 21/1 79/5]
121/20 129/19 132/19}
40/19 50/7 72/2 110/4
146/24 158/12
levelled [1] 78/15
levers [1] 135/12
liability [1] 66/25
liaising [2] 9/14
34/10
lie [2] 88/3 88/11
lied [1] 87/4
lies [3] 15/4 88/4
88/6
life [6] 68/6 69/1
77/17 77/23 159/21
160/24
light [2] 71/21 98/19
lightly [2] 101/20
131/14
like [17] 1/22 2/24
20/11 21/4 37/23
55/10 67/17 79/10
79/12 79/14 94/2
102/9 146/5 157/10
157/23 160/15 160/17}
likely [6] 37/18 46/14
64/20 110/10 117/11
122/14
Likewise [1] 147/6
limit [4] 155/15
limitation [1] 95/15
limited [7] 40/15
43/23 75/25 92/22
105/15 125/15 150/8
limits [1] 122/19
line [6] 89/12 91/19
107/1 118/9 132/16
154/11
lined [1] 103/8
lines [6] 6/14 46/3
118/11 133/25 137/23
141/25
Linklaters [1] 51/25
lips [1] 161/1
list [4] 117/3 122/4
152/25 157/14
listed [1] 100/16
listen [2] 8/25 22/2
listened [1] 2/4
listening [1] 8/19
litigation [7] 81/17
83/1 101/20 102/3
104/5 105/22 154/15
little [4] 4/11 57/9
118/13 146/20
live [7] 65/13 75/11
87/14 111/24 122/4
131/5 160/6
livelihoods [1]
129/12
lives [2] 59/25 125/1
load [1] 23/9
located [1] 41/21
locking [2] 111/7
121/13
Log [3] 87/13 111/23
121/21
logic [1] 91/23
logical [1] 112/25
logs [1] 142/2
lone [1] 123/21
long [9] 2/13 15/2
16/19 17/3 19/15
128/13 135/2 156/9
156/19
long-term [2] 15/2
17/3
longer [3] 11/14
82/24 161/8
look [7] 27/15 47/13
133/13 145/13 148/18)
148/19 160/1
looked [4] 96/22
118/2 121/16 146/14
looking [7] 16/22
22/11 45/15 48/19
104/14 155/18 156/2
Lord [6] 24/17 35/6
42/24 43/7 83/20
130/16
Lord Arbuthnot [3]
24/17 35/6 43/7
Lord Justice [1]
83/20
lose [2] 56/25 119/24
loss [6] 10/12 16/15
102/21 110/11 118/25)
122/15
loss-making [1]
16/15
losses [2] 16/18
104/12
lost [8] 111/8 121/12
123/3 123/4 125/2
143/13 143/16 149/18)
lot [2] 8/11 82/12
Lottery [1] 62/6
Lovegrove [1] 148/2
Lowther [6] 105/12
105/13 105/18 106/7
107/22 108/2
lunch [3] 79/12 79/17)
79/18
Lyons [2] 34/20
38/10
MacLeod [2] 54/22
55/8
made [56] 2/18 7/24
14/17 22/18 26/24
28/13 29/1 29/15
30/11 31/6 32/1 39/20
43/14 47/11 48/13
49/23 51/24 53/21
55/15 59/10 64/9 68/5
69/13 69/20 70/21
71/18 76/19 77/7
77/12 77/15 81/4 93/5I
93/13 96/16 101/1
101/7 104/16 105/11
(67) kept... - made
made... [18] 108/12
110/1 112/9 113/21
4117/7 117/13 117/15
130/23 138/16 150/1
150/6 152/13 153/8
154/10 156/15
Magnox [1] 145/6
Mail [6] 6/9 32/7
63/21 64/4 136/12
136/13
main [3] 40/5 113/10
129/6
mainly [1] 34/20
maintain [2] 32/13
134/13
major [3] 54/24
133/14 158/21
majority [1] 116/38
make [34] 10/2 17/1
22/20 24/24 25/3 29/9
31/13 31/17 31/22
59/8 69/21 72/9 75/7
79/11 79/12 79/14
79/16 91/10 96/11
100/4 103/4 105/5
106/19 106/21 110/7
110/8 121/11 124/8
124/20 139/19 150/20
154/1 156/10 161/4
makers [1] 64/21
makes [1] 86/8
making [11] 2/22
14/25 15/20 16/15
24/5 49/14 104/8
106/20 113/8 158/19
159/1
malign [2] 65/25 66/8
manage [2] 57/11
65/12
managed [3] 133/10
135/22 136/7
management [14]
24/4 68/15 71/14
71/15 72/7 120/21
128/18 133/25 134/1
135/25 136/8 137/24
150/21 156/2
manager [5] 26/3
29/1 30/13 34/10
107/1
managers [6] 25/19
28/24 29/15 29/17
29/20 34/8
Managing [2] 23/13
26/5
mandatory [1] 13/9
Mandelson [1]
130/16
manifestation [1]
125/9
manner [2] 48/2
117/18 122/18 130/12)
96/23
mantra [3] 24/16
126/4 143/21
manuals [4] 11/1
many [19] 1/21 4/12
92/9 110/21 124/22
124/25 133/1 133/2
139/6 140/24 140/25
161/7
March [10] 23/14
26/2 28/12 30/8 35/5
67/2 102/5 120/14
121/14 121/15
March 2006 [1]
120/14
Margot [1] 143/5
mark [1] 155/13
Marshall [2] 10/9
11/21
Martin [2] 38/9
139/11
mass [2] 155/9 155/9
material [12] 55/2
68/12 76/7 87/14 89/2
99/21 100/10 101/24
102/10 119/7 131/20
157/7
materially [3] 51/3
130/5 140/12
materials [3] 11/1
47/16 118/22
matter [14] 21/9
25/11 34/2 34/23
47/22 57/14 65/1 71/6
73/18 76/17 85/13
96/21 116/25 156/24
matters [23] 9/6 20/9
22/8 22/21 24/5 25/21
25/25 34/17 50/1
52/11 52/11 61/7
61/13 69/22 73/7
73/23 74/25 78/11
82/2 103/11 115/13
115/16 135/6
Matthews [1] 94/12
may [51] 1/4 17/23
20/10 23/3 26/23 27/9
28/13 28/20 30/20
31/2 33/4 35/6 36/10
36/15 37/9 42/24
48/21 48/23 49/8
49/11 55/14 74/3 88/2
90/19 91/11 99/10
103/3 103/10 104/3
106/25 110/12 119/15)
120/11 120/25 127/20)
128/4 132/11 132/14
133/21 139/5 139/22
146/17 147/20 148/22)
148/25 149/7 149/10
149/23 149/24 151/15)
105/23 106/15 106/17;
12/4 80/25 81/25 91/8)
141/19 149/20 152/24)
152/7
May 2006 [1] 120/25
May 2009 [1] 27/9
Maybe [1] 119/20
McCartney [1] 132/5
154/4
McLachlan [9] 87/11
93/4 108/22 111/19
111/22 112/1 121/6
121/19 122/10
McLachlan's [1]
108/20
me [11] 22/2 57/24
58/1 89/11 95/13
124/14 128/2 161/9
mean [2] 89/2 105/20
meaning [3] 106/6
107/15 107/19
means [7] 30/23
36/16 56/14 68/24
meant [11] 5/8 80/18
88/19 103/21 108/4
113/17 114/5 115/3
130/10 130/14 149/24]
meantime [1] 32/7
measure [1] 13/21
measures [3] 15/15
129/17 131/12
mechanics [1]
127/23
mechanism [2]
106/16 150/17
mechanisms [2] 9/17]
72/4
mediation [8] 52/19
52/22 52/25 53/3 53/9
53/13 53/17 53/20
meeting [13] 7/16
28/8 31/2 33/8 36/3
43/6 43/22 44/17 45/5
50/24 92/16 141/13
155/20
meetings [4] 15/12
33/3 34/12 34/22
Melanie [1] 10/9
member [1] 92/5
members [10] 6/6
6/10 17/7 17/8 19/23
63/24 73/22 81/16
126/4 136/4
members’ [1] 131/15
membership [1] 34/5
memorably [1] 143/2
memory [1] 110/23
mention [3] 44/18
44/22 142/7
mentioned [7] 26/19
45/4 95/5 114/2 114/4
116/25 151/17
mere [1] 63/9
merely [3] 125/22
McFadden [2] 133/17,
103/17 117/22 119/16
101/21 125/15 153/15}
131/2 139/18
merit [1] 76/18
merits [1] 53/8
message [11] 28/1
29/7 30/5 32/22 35/6
35/12 42/7 69/16
97/19 104/20 111/18
messaging [2] 43/16
44/11
met [2] 41/10 130/15
metrics [1] 157/17
Michael [1] 41/10
microphone [1]
124/10
mid [2] 33/24 140/16
mid-2012 [1] 33/24
mid-2018 [1] 140/16
middle [1] 21/13
might [18] 44/10
49/21 64/12 66/18
80/10 80/11 83/16
90/2 98/21 101/9
101/10 103/5 109/6
123/13 124/11
Mike [2] 26/2 27/2
million [1] 60/24
millions [1] 27/13
mind [3] 3/19 11/13
110/18
minded [2] 143/20
146/19
mindful [1] 75/14
mindset [7] 4/21 5/1
5/3 5/4 S/T 7/3 123/5
minimise [1] 56/2
minister [7] 131/23
136/18 141/24 143/4
144/8 156/15 159/2
ministerial [2]
142/15 156/16
ministers [31] 16/23
126/5 130/24 131/4
131/11 134/19 135/5
135/10 135/14 135/19}
135/24 136/19 137/9
137/14 138/9 140/14
140/21 140/25 142/17]
142/22 143/9 143/24
144/11 144/16 144/18}
144/21 144/25 147/4
148/8 149/4 151/25
ministers’ [3] 144/4
147/9 150/18
minority [1] 143/11
minutes [1] 119/23
miscarriage [1] 2/7
miscarriages [7]
59/21 60/12 76/23
78/3 78/19 78/23 81/3
misconduct [1]
71/10
misjudgement [1]
48/13
111/25 115/15 117/17)
misleading [7] 126/7
140/13 141/1 142/9
142/11 142/13 144/15)
misled [2] 82/23
135/23
mismatch [4] 28/3
112/17 113/12 114/8
misplaced [1] 145/12
Misra [4] 46/11 85/20
110/11 122/15
Misra's [24] 49/19
81/21 85/24 87/12
92/24 93/13 93/17
94/13 97/4 98/16
108/14 108/16 109/12!
411/17 112/15 112/21
112/25 113/13 121/5
121/10 121/17 122/18)
122/21 123/4
misrepresented [1]
97/16
miss [1] 49/16
missed [1] 118/12
missing [1] 32/18
mission [1] 157/5
misstated [1] 96/1
mistake [2] 48/13
109/20
mistakes [6] 74/10
74/12 75/2 79/7
126/15 127/11
mistrusted [1]
146/14
misusing [1] 152/4
model [2] 135/1
159/9
moderately [1] 119/3
modernisation [1]
130/21
modest [1] 122/18
modules [1] 13/7
Moloney [7] 49/20
57/6 90/24 92/14
103/4 104/16 124/12
Monday [1] 36/4
money [5] 32/18
110/11 122/15 123/3
123/4
monitor [1] 72/5
monitoring [1]
155/25
monitors [1] 12/8
Montague [2] 129/23
130/13
months [7] 3/2 21/6
28/11 56/11 76/6
121/8 161/7
morally [1] 151/9
more [30] 5/3 24/1
24/3 36/17 37/17
46/18 47/13 60/23
60/25 61/3 68/10
70/17 75/22 84/25
104/14 110/10 118/9
(68) made... - more
more... [13] 122/14
130/2 133/7 138/16
139/4 139/7 139/19
139/22 140/21 142/17
143/5 144/2 158/12
Moreover [2] 73/4
74/13
most [16] 2/6 4/7
26/3 29/20 31/21
46/14 66/3 79/6 90/19)
99/18 125/19 126/10
137/16 142/13 145/7
155/6
motion [2] 112/7
122/1
motive [1] 25/4
mouth [1] 46/7
moving [1] 32/24
MP [1] 27/2
MPs [5] 33/4 33/25
36/3 126/5 144/5
Mr [332]
Mr Allen's [1] 117/18
Mr Altman [8] 45/20
45/25 47/8 48/7 48/15
48/20 51/13 51/17
Mr Altman's [3] 50/3
50/6 50/9
Mr Atkinson [8]
90/15 95/1 95/11 98/7,
101/11 114/24 118/8
119/1
Mr Aujard [4] 44/4
44/4 50/23 54/22
Mr Aujard's [2] 51/7
51/12
Mr Baker [3] 34/9
40/1 40/4
Mr Beer [2] 1/3 94/25
Mr Bolc [5] 94/15
117/18 117/20 117/25}
118/3
Mr Bourke [2] 53/14
53/22
Mr Bowyer [3] 94/14
114/21 115/6
Mr Bradshaw [1]
117/21
Mr Callard [1] 149/18
Mr Cameron [1]
54/21
Mr Castleton [2]
23/17 104/10
Mr Castleton's [5]
103/13 103/16 104/18
104/24 121/2
Mr Chapman [5]
124/2 124/6 124/7
124/11 160/3
Mr Clarke [7] 45/1
49/4 49/17 83/9 83/10)
83/13 90/13
Mr Clarke's [3] 44/3
44/12 51/18
Mr Cook [1] 26/22
Mr Davies [1] 54/22
Mr Day [1] 46/17
Mr Dilley [2] 104/7
121/1
Mr Duncan [1]
107/17
Mr Edwards [2] 43/4
46/18
Mr Flemington [2]
43/5 43/23
Mr Henderson [4]
88/21 88/24 89/8
91/24
Mr Henry [2] 113/11
124/14
Mr Ishaq [1] 118/15
Mr Ishaq's [2] 93/8
98/16
Mr Ismay [3] 29/11
29/20 29/24
Mr Jenkins [149]
44/19 44/22 45/1
45/18 48/4 48/16
48/18 48/21 50/4 50/8)
50/13 55/11 80/17
80/22 80/24 81/7
81/12 81/15 81/17
82/7 82/21 82/22 83/1
83/3 83/8 83/9 83/23
83/24 84/1 84/9 84/11
84/19 85/10 85/11
85/12 85/22 85/23
86/13 86/17 87/5 87/8)
87/11 87/15 87/16
87/24 88/3 88/22
89/20 90/11 90/18
90/21 91/3 91/12
91/13 92/12 92/15
92/18 93/4 93/6 93/12
93/13 93/20 94/4
94/24 95/3 95/5 95/10)
95/19 96/1 96/3 96/6
96/8 96/14 96/17
96/19 97/1 97/15
97/20 98/2 98/3 98/10
98/25 99/2 99/16
99/19 100/14 100/20
100/23 101/17 103/20)
104/1 104/6 104/8
104/12 104/17 104/23)
107/21 108/10 108/16)
109/1 109/3 109/9
109/11 109/13 110/9
110/10 110/13 110/15)
110/16 111/1 1114/2
111/5 111/13 111/16
111/24 112/3 112/6
112/11 112/17 112/23)
113/4 113/15 113/20
114/1 114/8 114/15
1415/7 115/8 115/12
115/17 115/21 115/25}
116/7 116/12 116/14
116/18 116/21 116/24
117/5 117/13 118/2
118/6 118/8 118/18
119/11 120/5 121/19
122/1 123/15
Mr Jenkins’ [11] 45/7]
80/13 85/14 88/18
90/3 93/10 93/16 94/7
104/25 109/16 109/19!
Mr Jenkins's [2]
116/10 117/10
Mr Justice [3] 11/24
81/22 82/1
Mr Justice Fraser [3]
8/3 57/13 81/6
Mr Lenton [1] 107/7
Mr Moloney [7] 49/20]
57/6 90/24 92/14
103/4 104/16 124/12
Mr Oldnall [1] 12/7
Mr Page [1] 20/16
Mr Parsons [3] 43/24
87/20 87/22
Mr Patterson [3]
73/17 73/19 76/16
Mr Pinder [1] 91/15
Mr Pinder's [1]
104/18
Mr Railton [1] 158/16
Mr Read [1] 76/14
Mr Richardson [1]
54/16
Mr Rudkin's [1] 42/8
Mr Sheldon [1] 134/2
Mr Singh [9] 83/11
94/2 94/13 94/13 98/6
109/10 111/4 111/12
115/17
Mr Smith [2] 94/14
94/17
Mr Stein's [1] 24/13
Mr Tatford [7] 109/9
109/13 109/15 110/18}
111/4 111/12 122/12
Mr Tatford's [2]
108/21 110/6
Mr Thomas' [9]
91/16 92/22 94/12
105/1 105/4 108/5
108/9 120/16 120/19
Mr Ward [3] 94/12
105/2 120/17
Mr Warwick [2]
85/18 96/9
Mr Whittam [4] 59/1
59/5 59/6 79/9
Mr Williams [1]
43/23
Mr Young [10] 25/14
25/19 26/6 26/11
26/24 28/9 28/15
28/18 32/5 32/15
Mr Young's [2] 27/6
31/20
Mrs [29] 46/11 49/19
81/21 85/20 85/24
87/12 92/24 93/13
93/17 94/13 97/4
98/16 108/14 108/16
109/12 110/11 111/17]
112/15 112/21 112/25]
113/13 114/2 121/5
121/10 121/17 122/15)
122/18 122/21 123/4
Mrs Chambers [1]
114/2
Mrs Misra [4] 46/11
85/20 110/11 122/15
Mrs Misra's [24]
49/19 81/21 85/24
87/12 92/24 93/13
93/17 94/13 97/4
98/16 108/14 108/16
109/12 111/17 112/15)
112/21 112/25 113/13}
121/5 121/10 121/17
122/18 122/21 123/4
Ms [195]
Ms Crichton [16]
25/13 32/16 33/8
33/19 34/21 35/5
42/14 43/4 43/7 43/23
43/24 44/1 45/24
46/12 46/25 52/21
Ms Crichton's [1]
44/17
Ms Crowe [1] 54/21
Ms Dobbin [3] 79/10
80/1 119/19
Ms Eliasson-Norris
[1] 20/16
Ms Greaney [2] 1/8
21/8
Ms Ibbotson's [3]
93/9 93/11 118/24
Ms Jennings’ [1]
116/15
Ms Leek [6] 21/9
21/10 21/20 22/3 22/3,
58/24
Ms Lowther [5]
105/12 105/13 105/18}
106/7 107/22
Ms Lyons [1] 34/20
Ms MacLeod [2]
54/22 55/8
Ms Matthews [1]
94/12
Ms Munro's [1] 107/1
Ms Nield [1] 118/1
Ms Panter [2] 94/15
116/22
Ms Patrick [1]
104/16
Ms Patrick's [1]
92/14
Ms Pepper [1]
124/16
Ms Perkins [6] 38/10
43/6 46/16 46/17
49/23 50/20
Ms Rose [3] 81/24
116/2 116/8
Ms Sefton [1] 118/1
Ms Sewell [10] 25/14
25/20 28/11 28/15
28/19 30/24 40/1 40/4I
41/9 41/16
Ms Swinson [2] 23/6
23/9
Ms Thomas [6]
105/12 105/13 105/19}
105/21 106/7 108/2
Ms Thomas' [1]
107/1
Ms van [3] 29/11
29/20 34/9
Ms Vennells [102]
22/7 22/16 22/22 23/2I
23/4 23/11 23/15
23/18 23/25 24/12
24/15 25/3 25/5 25/16
25/22 26/6 26/25
27/17 27/24 28/12
28/16 29/6 29/22
30/22 30/25 31/5
31/10 31/15 32/3
32/22 33/1 33/13
33/15 33/18 34/1
34/11 34/19 34/23
36/18 37/16 37/17
37/20 37/22 38/1 38/8I
39/9 39/14 39/17
39/20 39/25 40/1
40/14 40/20 40/24
41/9 41/16 42/7 42/11
42/18 42/24 43/6
43/16 44/11 44/13
45/6 45/24 46/6 46/14
46/20 46/22 47/11
47/18 47/23 48/3
49/19 50/14 51/23
52/2 52/5 52/12 52/17
53/9 53/16 53/20 54/2
54/6 54/11 54/13
54/23 55/2 55/15
55/19 55/21 56/12
56/15 57/3 57/14
57/17 58/2 58/19
58/19 58/22
Ms Vennells’ [6]
22/12 23/20 27/2 33/4I
39/19 58/15
Ms Wylie's [1] 123/9
much [16] 1/4 57/24
67/20 95/24 99/16
110/7 130/2 138/13
140/21 141/11 144/7
146/19 154/4 156/6
158/13 161/8
(59) more... - much
muddle [2] 85/21
86/8
muddled [1] 109/16
multi [1] 62/3
multiple [3] 7/6 65/6
139/8
Munby [3] 153/22
153/25 154/20
Munby’s [4] 153/18
Munro's [1] 107/1
must [5] 3/7 20/22
106/2 127/6 155/20
muted [1] 124/15
my [23] 55/12 82/4
88/15 89/1 92/11
92/13 103/3 104/16
107/9 110/23 113/10
117/3 118/17 119/16
120/12 143/16 143/22)
148/10 153/5 160/9
160/23 160/24 161/6
N
name [2] 27/2 142/21
namely [1] 19/8
NAO [1] 154/7
narrative [1] 93/10
narrow [1] 119/5
narrowly [1] 75/18
national [4] 70/2
153/9 155/23 159/21
nationwide [1] 56/23
native [1] 149/17
nature [7] 18/21
24/10 35/18 68/2 73/2
92/20 93/15
navigated [1] 157/25
navigating [2] 93/20
123/16
NBIT [3] 18/3 77/6
7718
near [1] 92/12
nearly [1] 36/5
necessarily [3]
132/19 140/6 144/11
necessary [12] 2/23
65/11 66/6 73/18
85/16 95/7 96/11
109/23 110/6 129/11
135/8 136/1
necessitated [1]
62/19
NED [4] 9/10 148/21
149/8 149/13
NEDs [6] 9/4 9/9 9/11
150/3 157/9 158/20
need [18] 11/9 12/17
15/3 18/5 34/23 56/6
72/15 75/7 94/11
101/17 103/1 112/20
114/11 144/13 144/20
148/5 157/4 161/6
needed [9] 33/21
46/18 47/15 67/6
82/24 104/23 106/18
135/20 143/16
needs [10] 18/8 53/7
68/8 124/24 132/16
133/13 145/13 158/16)
158/16 158/25
negate [1] 99/5
negative [3] 7/8
86/23 148/13
neither [8] 35/2
46/22 83/20 106/3
109/10 111/4 111/9
134/20
nervous [1] 36/10
network [9] 24/2
27/12 27/18 29/1 34/6
34/10 75/22 129/12
159/13
never [19] 25/16 45/6
45/8 71/9 79/7 84/13
87/24 88/9 94/25
96/14 98/17 108/19
111/3 111/7 142/17
143/3 144/8 147/5
14719
nevertheless [2]
70/24 143/6
Neville [5] 142/9
143/10 148/9 149/17
150/2
Neville-Rolfe [5]
142/9 143/10 148/9
149/17 150/2
new [24] 2/21 9/8
12/1 13/7 13/8 13/16
13/19 14/9 16/8 17/12
17/18 18/6 18/18
18/19 36/24 77/4
121/22 131/3 145/23
151/19 153/15 158/5
158/14 158/18
newly [2] 23/25
153/15
next [6] 36/3 133/23
152/17 159/12 160/8
160/9
NFSP [4] 15/24
125/18 131/14 131/21
NFSP's [1] 16/3
niceties [1] 127/20
Nick [2] 12/18 73/18
Nield [2] 117/12
118/1
Nigel [3] 17/9 17/25
158/1
night [1] 118/23
nimble [1] 133/19
no [113] 2/4 4/22
5/24 11/13 11/15
19/10 24/18 24/19
25/16 26/16 27/4
27/14 27/21 28/14
29/16 29/25 30/3
30/25 31/18 31/25
33/13 34/12 35/10
35/14 35/19 37/17
37/17 37/21 38/3
38/20 39/15 40/18
42/10 47/11 48/17
51/7 53/1 53/19 54/6
55/2 55/6 55/21 58/9
61/23 65/1 66/2 66/2
66/3 66/7 66/22 69/14
76/18 77/11 80/24
81/5 81/5 82/7 82/11
82/14 82/19 82/22
82/24 83/1 83/2 83/17I
86/2 86/6 89/3 89/18
89/22 89/22 91/17
91/17 94/20 97/6
101/1 101/16 103/1
104/9 105/19 107/13
109/11 110/10 112/25)
113/20 113/24 113/25]
114/3 114/20 116/2
117/6 117/15 117/25
118/20 123/2 123/25
124/1 124/24 125/14
132/17 138/17 141/5
141/8 141/10 142/1
142/6 142/7 146/4
150/4 152/22 153/12
160/20 161/4
Nolan [5] 145/4
145/12 149/24 150/25}
151/19
non [6] 47/23 50/8
52/1 52/12 88/20
106/23
non-disclosure [1]
88/20
non-disclosures [1]
50/8
non-technicians [1]
106/23
none [8] 45/18 85/16
86/3 95/6 96/10
103/18 109/22 130/10}
nonetheless [3]
16/19 63/3 71/12
nonstop [1] 133/15
nor [15] 25/11 35/3
39/12 39/13 44/3
44/19 46/23 51/17
58/10 83/21 109/10
111/4 128/9 134/20
142/14
normal [2] 40/20
71/5
normally [2] 105/15
124/12
norms [1] 149/15
Norris [1] 20/16
not [272]
note [11] 37/15 38/7
40/24 42/23 42/25
43/6 43/15 114/17
152/12 154/22 158/22)
noted [3] 28/8 37/22
104/12
notes [7] 15/22 15/25)
19/25 35/24 53/14
72/7 149/5
nothing [10] 2/24
21/4 27/25 28/2 29/21
43/8 58/18 60/7 114/4
144/17
notice [2] 103/18
103/20
noticeable [1] 158/11
noticed [1] 1/4
notification [1] 7/22
notified [1] 26/9
notwithstanding [2]
58/21 87/7
novel [2] 71/1 155/6
November [5] 17/10
27/3 50/24 53/15
103/16
now [32] 10/10 11/15
12/8 15/11 15/18
18/17 21/10 21/12
21/16 21/18 22/9 23/1
23/9 23/20 24/11
24/25 33/18 38/1
58/22 58/25 61/7 65/8
70/15 78/20 79/13
79/16 82/10 113/3
133/12 134/8 153/5
161/10
NT [4] 111/10
nuance [1] 104/19
number [16] 3/11
3/17 8/16 22/14 28/24
29/15 61/16 64/4 64/7,
68/13 76/7 81/3 81/10)
99/13 136/7 153/8
numerous [2] 62/1
62/10
[e)
obfuscate [1] 66/11
objections [1] 122/12!
objective [7] 14/7
55/20 134/18 140/20
145/1 145/17 149/3
objectives [3] 16/24
129/13 151/13
objectivity [3] 143/17
144/23 149/19
obligation [2] 98/19
99/25
obligations [8] 5/13
12/9 100/9 100/21
102/15 108/18 109/1
109/5
obliged [2] 44/16
44/20
obliging [1] 71/2
observant [1] 49/9
observation [2]
88/23 90/24
observations [7]
30/12 69/20 91/11
91/12 134/6 134/8
147/22
observed [6] 66/18
94/17 118/8 139/4
145/14 148/2
obstacle [1] 87/24
obstacles [2] 87/4
123/18
obstruct [1] 143/22
obstructive [1] 76/20
obtain [1] 40/5
obtained [7] 45/10
67/7 81/18 111/18
114/6 117/16 121/6
obtaining [5] 83/18
88/1 90/12 117/25
118/3
obvious [6] 23/21
31/20 62/18 88/17
104/18 145/9
obviously [2] 145/7
155/6
occasion [2] 26/19
54/11
occasionally [2]
35/18 37/24
occasions [2] 124/22
144/24
occupied [1] 5/11
occupies [1] 124/13
occupy [1] 4/7
occur [1] 48/8
occurred [6] 3/23
14/20 66/3 70/7
112/24 117/24
occurrences [1]
40/21
OCS [1] 20/2
October [11] 44/13
45/12 45/15 46/15
50/4 53/14 77/1
116/16 122/8 122/11
123/10
October 2013 [1]
50/4
odds [1] 76/22
off [2] 58/25 107/6
offences [1] 155/10
offer [4] 57/9 74/20
75/5 145/18
offered [6] 19/20
19/20 30/3 74/20
118/13 128/7
offering [1] 118/9
offers [2] 19/6 155/6
Office [379]
Office's [63] 1/22 2/3
4/3 7/5 7/10 7/17 8/23
10/15 10/17 12/4 13/6)
14/7 17/12 17/21
(60) muddle - Office's
[e)
Office's... [49] 18/22
19/19 23/16 25/23
34/15 36/13 45/7
51/1 52/6 54/4 54/8
55/22 56/14 56/19
56/23 62/15 64/1
64/16 68/8 68/16
71/10 72/13 73/4
76/12 80/16 82/16
90/21 93/1 93/23 97/8
99/19 100/4 108/18
118/10 126/11 126/16)
133/6 134/14 141/22
146/11 149/14 149/15
152/22 155/23 157/4
Office-led [1] 74/19
offices [3] 41/15
131/5 144/4
official [1] 126/7
officials [15] 126/5
135/8 138/9 140/16
141/3 141/14 142/24
143/17 144/12 145/3
147/14 147/18 147/24}
148/6 148/23
officials' [1] 147/7
often [4] 69/13 72/2
154/1 160/23
okay [3] 79/15 80/1
124/1
Oldnall [2] 11/20
12/7
omission [1] 95/25
omissions [1] 50/21
omit [1] 110/5
omitted [1] 67/8
on [221]
once [4] 139/7
153/16 159/19 161/5
one [38] 2/4 2/12
7/20 9/9 22/20 34/23
48/17 62/14 64/15
64/25 67/16 79/11
79/14 82/14 83/1 83/2
85/14 86/6 91/14 93/2
93/14 100/17 101/4
107/19 110/7 114/16
124/16 124/17 124/24}
130/1 133/21 136/25
138/23 143/24 145/25)
146/2 148/21 151/14
ones [1] 75/22
ongoing [9] 2/20
11/12 12/2 12/12
72/12 73/5 74/14
114/18 156/14
Online [2] 41/3
112/24
only [29] 1/25 3/17
22/10 26/11 26/14
26/18 41/1 41/19 42/4
45/16 45/23 46/3 48/3
48/13 50/20 62/15
90/22 93/2 93/13
94/11 99/14 107/19
107/25 108/10 110/4
112/13 126/1 127/25
132/25 135/1 138/12
145/2 151/3
open [3] 107/16
107/17 135/10
opening [6] 61/15
152/16
openly [3] 87/8
120/20 123/6
openness [1] 88/18
operate [1] 134/23
operated [1] 65/16
operates [1] 27/12
operating [1] 32/12
operation [5] 65/13
68/19 75/6 89/21
100/1
operational [8] 9/6
134/14 135/6 135/19
operationally [1]
66/17
operations [6] 10/10
12/4 17/21 34/7
135/11 150/7
operative [1] 135/18
opinion [7] 39/1 40/7
40/11 46/1 75/5 92/8
122/14
opinions [2] 84/12
97/4
opportunity [8] 19/6
59/7 81/5 82/7 82/11
83/8 83/12 118/13
opposed [2] 39/4
160/18
opposite [1] 113/23
opposition [1] 105/2
oppressive [1] 12/20
optimistic [1] 157/25
option [3] 10/22
135/2 153/25
options [2] 51/1
113/6
or [131] 2/2 2/24 3/11
4/8 4/23 4/24 5/15
5/24 6/5 6/12 6/20
7IN0 7/15 7/24 10/13
10/19 11/4 11/16
16/23 20/8 20/12
20/13 21/11 22/16
22/16 26/10 26/12
26/17 26/19 26/21
29/2 29/4 29/5 29/9
29/18 30/20 31/25
33/1 34/13 34/14
34/24 35/20 36/21
40/9 40/12 40/22
41/13 44/2 45/22
65/3 65/18 77/1 77/13
9/15 9/21 14/22 34/17,
47/11 48/13 48/22
54/12 55/3 55/10
60/11 64/9 64/10
64/10 64/24 65/16
71/17 73/3 75/19
75/19 76/20 78/22
78/24 79/12 79/16
83/23 84/5 84/23 87/1
89/11 90/19 92/6
92/16 92/16 94/3 94/6
94/6 94/9 95/2 96/2
96/23 97/20 97/23
98/8 100/10 100/15
101/6 102/21 102/23
104/11 104/19 104/21
105/8 109/3 109/5
109/6 113/17 119/8
120/3 120/6 120/7
120/9 127/8 128/5
130/25 131/17 132/4
132/13 136/13 137/12
139/22 140/13 141/1
142/14 142/20 143/3
143/17 143/22 147/9
149/20 153/13 153/16}
Oracle [1] 26/15
oral [18] 8/1 11/21
23/4 23/13 29/19
31/10 34/20 49/4 55/7
58/15 59/8 60/7 61/4
78/13 85/23 86/10
108/3 129/2
orally [2] 1/16 105/4
order [8] 3/7 8/12
9/23 88/2 106/18
115/7 118/19 154/15
ordinary [2] 85/15
151/9
organisation [23]
2/12 5/17 5/21 6/2
8/10 12/16 12/25 14/4
14/19 17/16 17/22
18/18 19/7 24/23
56/10 82/18 84/4
102/25 136/2 137/22
157/10 157/23 158/6
organisational [12]
5/7 8/4 60/14 67/1
78/8 79/1 127/20
127/23 128/4 128/17
133/23 158/20
organisations [2]
134/22 156/1
organised [2] 51/16
129/16
orientating [1] 8/17
original [1] 146/10
origins [1] 126/11
other [57] 2/5 2/18
4/12 17/8 20/9 22/1
30/4 32/25 37/4 37/6
39/12 40/9 40/12
40/22 50/1 51/15
49/9 51/4 51/10 51/19
73/25 74/18 75/24
80/21 93/14 96/18
97/12 99/23 100/10
106/12 106/18 112/6
114/12 114/25 115/9
121/15 129/2 131/9
131/16 133/22 133/24)
138/20 143/9 144/5
144/13 144/19 145/7
145/15 147/2 147/9
148/22 156/14 161/4
others [7] 1/21 15/23
38/10 58/10 58/17
95/12 115/23
otherwise [3] 26/12
39/13 139/14
ought [8] 15/16 49/7
51/4 52/3 57/18 84/23
90/9 123/17
our [16] 22/5 22/14
22/18 27/12 32/13
56/6 68/23 89/3 97/22,
108/24 138/3 145/5
146/22 146/24 150/20}
159/21
out [43] 5/17 11/5
12/2 17/6 18/10 18/23}
23/23 25/4 32/19 37/9
38/14 39/5 40/11
40/19 44/1 47/19 51/1
53/3 55/9 57/2 57/22
57/23 58/16 62/12
65/22 69/11 73/9
78/11 81/1 82/5 82/15)
84/12 93/19 106/9
108/24 114/9 116/9
120/10 130/16 134/5
153/4 154/19 155/16
outcome [3] 15/9
35/10 54/8
outcomes [1] 139/15
outline [1] 52/24
outset [6] 7/23 61/6
85/2 86/11 129/15
154/16
outside [2] 71/4
125/14
over [20] 3/9 4/3 22/3
25/8 27/12 37/24 61/2
62/4 63/2 67/24 77/5
91/14 108/22 126/22
131/22 133/8 134/10
141/19 147/8 157/3
overall [7] 5/16 36/5
46/1 95/8 106/4
106/24 138/22
overarching [3]
91/11 94/24 96/13
overburdened [1]
15/16
overlook [1] 97/14
overly [1] 75/18
54/18 57/2 62/5 62/16)
66/5 66/7 66/14 73/25]
overnight [1] 41/13
overrunning [1] 35/9
overseeing [2]
127/13 137/4
overseen [3] 136/10
136/12 136/14
oversight [20] 6/16
15/24 16/3 26/10
68/15 71/16 72/8
126/22 128/18 133/25)
135/25 136/22 137/8
137/24 138/12 138/23)
139/5 139/8 139/21
150/21
overstate [1] 134/3
overturned [1] 57/16
overview [2] 5/10
115/25
overwhelmingly [1]
95/18
Owen [1] 76/14
own [16] 6/7 11/16
12/9 52/2 60/6 68/12
69/1 71/20 83/6 102/5I
125/21 137/6 137/20
146/15 149/14 150/15)
ownership [3] 135/3
139/10 158/21
P
pace [1] 8/9
pack [1] 44/5
page [2] 20/16 30/12
page 33 [1] 30/12
pages [2] 20/2 23/22
paid [3] 152/21
155/16 156/12
panacea [1] 139/5
panel [5] 9/19 9/23
11/11 17/19 58/12
Panter [2] 94/15
116/22
paper [14] 7/15 18/14
22/18 28/7 44/17
44/18 51/8 52/23 53/4)
53/11 114/8 155/22
158/23 159/11
papers [1] 50/23
paragraph [5] 24/13
38/19 66/19 67/10
80/20
paragraph 10 [1]
67/10
paragraph 101 [1]
66/19
paragraph 207 [1]
80/20
paragraph 8.2 [1]
38/19
Paragraph 88 [1]
24/13
paragraphs [9] 105/6)
105/9 105/11 107/2
107/15 107/21 107/25)
(6
1) Office's... - paragraphs
Poo
paragraphs... [2]
108/4 108/6
paralegal [1] 94/15
parallel [1] 138/25
parameters [1] 149/83
paraphrase [1]
153/18
Park [1] 10/9
Parker [2] 142/11
142/14
Parliament [7]
124/23 134/12 136/20)
136/21 137/9 140/14
156/16
Parliamentary [2]
134/17 156/14
Parsons [3] 43/24
87/20 87/22
part [33] 2/19 4/9 6/5
6/22 7/6 13/24 14/20
17/1 19/13 62/14
65/11 86/9 86/12
88/13 89/23 91/19
98/5 99/16 100/18
101/1 102/1 105/11
110/22 114/22 116/6
118/17 120/6 133/15
137/24 142/16 143/19}
151/1 160/24
partial [1] 144/15
Participant [3] 128/1
152/13 154/22
Participants [8] 2/19
20/13 46/23 74/2 90/8
103/19 117/8 120/4
participated [1]
160/10
particular [8] 72/7
75/19 75/20 75/25
76/3 89/12 101/9
116/6
particularly [11] 6/8
7/20 30/10 71/24
73/19 75/12 78/16
99/12 105/21 151/23
160/17
parties [2] 66/14
129/20
partner [2] 13/18
66/16
parts [3] 12/4 44/12
91/18
party [8] 62/11 62/16
67/16 67/19 87/1
89/12 100/5 104/18
pass [1] 41/12
passage [2] 109/21
134/12
passages [2] 105/20
105/25
passed [4] 29/5 58/3
141/23 153/1
passing [2] 120/22
127/21
Passport [1] 133/3
past [17] 2/13 8/6
12/21 13/15 32/15
44/16 45/23 47/1 49/1
49/5 50/10 50/12
133/8
Pat [2] 133/17 154/4
path [4] 123/19
Patrick [1] 104/16
Patrick's [1] 92/14
Patterson [4] 73/16
73/17 73/19 76/16
Paul [1] 73/16
Paula [3] 142/3 147/8
152/11
pause [2] 90/23
107/18
paused [1] 132/1
pay [2] 155/4 160/9
payments [4] 28/3
112/17 113/12 130/6
PEAK [4] 114/4
120/19 120/22 122/9
PEAKs [3] 112/5
112/8 122/5
Pearce [1] 103/14
pending [1] 15/8
pensions [1] 57/1
people [20] 1/4 1/5
14/3 22/1 22/1 56/4
56/24 60/6 81/10 94/2
125/4 125/9 125/11
126/12 127/3 138/4
138/19 139/13 140/9
160/17
people's [1] 124/25
Pepper [1] 124/16
perceive [1] 148/23
perceived [1] 72/15
perception [1]
128/21
perceptions [1]
36/10
perfect [3] 2/15
153/24 154/2
perfectly [1] 149/22
performance [2]
13/21 147/8
performed [1] 36/23
perhaps [8] 58/13
66/18 79/18 90/18
110/23 125/19 126/10)
145/7
period [5] 62/2 64/2
70/6 122/6 132/1
periods [1] 105/15
Perkins [6] 38/10
43/6 46/16 46/17
49/23 50/20
permanent [1] 138/9
permit [1] 103/17
51/10 74/11 75/2 79/7,
permits [1] 40/10
permitted [1] 3/20
perpetrated [1]
126/18
perpetrator [1] 19/17
perpetuate [1] 88/14
persistent [1] 95/16
person [6] 1/24
13/24 38/24 64/15
89/11 160/18
personal [2] 5/15
23/10
personally [2] 25/10
55/15
personnel [1] 64/5
persons [1] 160/15
perspective [6] 2/22
89/10 91/25 112/24
113/2 129/6
perspectives [1]
159/6
PFI [2] 129/25 132/24
phase [16] 2/11
58/21 59/15 59/22
68/1 68/5 69/11 69/16
70/20 72/11 72/18
73/1 77/5 129/3 129/5
130/5
Phase 1 [1] 59/15
Phase 2 [1] 129/3
Phase 3 [2] 69/11
69/16
Phase 4 [3] 68/1
70/20 72/18
Phase 7 [5] 2/11 68/5
72/11 73/1 77/5
phases [13] 1/14 4/5
4/21 5/19 5/20 6/4 7/4
8/1 14/18 59/11 59/19
60/5 67/22
Phases 2 [4] 1/14
59/11 59/19 67/22
Phases 3 [1] 7/4
Phases 5 [2] 5/19 6/4
pick [1] 153/8
picked [1] 36/20
picture [4] 4/8 22/12
84/25 100/16
iece [1] 119/18
cemeal [1] 44/14
pieces [3] 45/10 46/7
142/18
pilot [1] 26/16
Pinder [1] 91/15
Pinder's [1] 104/18
pithy [1] 102/8
place [21] 2/12 4/12
6/24 11/25 13/23 14/2
32/10 36/25 62/21
62/22 70/2 126/22
127/15 132/24 134/6
137/18 139/4 147/24
150/22 152/9 153/24
placed [1] 151/25
places [1] 1/6
plain [1] 71/11
plainly [2] 11/18
76/22
plan [4] 14/3 17/12
18/25 19/5
plane [1] 153/17
planning [4] 15/1
15/2 18/14 24/4
plans [5] 8/23 9/16
9/25 14/2 18/22
plate [1] 105/25
platform [1] 10/25
play [4] 13/24
played [5] 14/19 55/2
151/22 152/3 154/13
playing [1] 19/12
pleased [1] 155/19
plus [1] 3/9
pm [4] 79/25 124/3
124/5 161/11
pocket [1] 40/19
point [47] 9/8 22/20
23/12 28/20 36/6
36/19 43/9 49/14
49/23 51/12 58/10
82/15 84/3 84/8 90/23
93/1 94/24 96/13
96/16 103/3 108/9
109/12 109/25 113/10
116/21 121/8 127/11
128/4 129/10 130/15
132/10 132/13 133/12)
135/5 135/7 138/2
138/13 138/16 146/9
147/23 150/1 150/21
153/8 153/19 153/19
156/5 160/5
pointed [1] 69/11
points [11] 1/17 7/24
22/14 27/14 36/11
36/12 62/4 89/19
99/10 120/12 137/2
POL [16] 28/8 28/19
28/24 29/15 32/11
32/18 32/20 33/24
37/4 42/15 46/12 50/7,
67/5 67/6 121/7
143/18
POL's [10] 29/8 34/5
39/15 39/22 42/15
50/9 51/14 51/14
52/11 55/18
police [17] 42/16
73/13 73/15 73/23
73/25 74/3 74/18
74/21 74/24 75/23
76/3 76/20 80/4 80/7
80/10 84/9 84/19
policies [3] 9/22
10/16 50/10
policy [8] 16/13
16/24 51/2 138/25
139/21 139/25 150/15}
158/22
political [1] 142/22
poor [2] 125/23
129/25
poorly [1] 114/24
portfolio [2] 137/21
144/19
position [23] 10/18
25/15 37/9 57/8 65/10
73/9 74/14 74/16 75/5I
80/16 80/19 81/14
82/16 87/18 89/16
91/5 97/6 101/18
113/3 113/7 117/10
152/19 153/4
positioning [2] 74/4
7413
positions [4] 3/13 4/7I
68/15 138/4
positive [2] 55/23
140/1
positively [3] 5/3
64/11 66/1
possibility [4] 7/10
50/11 63/9 113/14
possible [14] 19/14
25/10 29/8 30/5 31/21
41/7 60/20 65/6 99/15
117/22 130/14 133/21
153/23 156/12
possibly [2] 84/15
106/3
post [441]
post-conviction [1]
142/15
Postal [1] 134/12
postmaster [19] 7/9
9/4 9/8 9/10 9/11 9/12
9/20 10/13 10/17
10/19 11/11 13/17
14/11 14/12 16/4
17/18 17/19 146/13
157/18
postmasters [55]
1/21 2/14 3/10 3/15
3/21 5/2 6/7 7/11 7/18
8/9 8/13 8/18 8/20
8/21 8/25 9/3 9/5 9/15
9/17 9/23 9/25 10/3
10/7 10/24 11/2 11/3
11/8 12/22 13/2 14/6
14/10 16/11 17/2 17/8)
17/13 17/14 17/23
18/5 18/6 19/8 19/9
19/13 19/21 20/12
128/10 129/12 131/9
132/21 146/14 152/24I
154/14 155/9 156/8
158/7 159/15
postmasters' [1]
154/9
potential [10] 29/2
49/9 61/19 62/18
63/12 63/14 63/16
(62)
) paragraphs... - potential
P
potential... [3] 74/22
75/10 75/21
potentially [4] 31/17
64/6 100/2 109/7
power [4] 10/15 29/2
29/2 155/4
powers [1] 102/18
practical [2] 131/10
134/18
practice [1] 62/25
practices [1] 10/16
pre [1] 70/10
pre-dates [1] 70/10
precisely [2] 98/3
112/10
predecessor [1] 51/5
predictable [1]
129/19
prediction [1] 161/9
prefer [2] 21/14
79/16
preferred [1] 52/3
premised [1] 80/12
preparation [1] 74/24
prepare [1] 34/22
prepared [10] 28/7
30/23 39/8 42/23
52/22 53/12 53/14
86/7 104/7 107/22
presence [1] 12/20
present [2] 36/2 53/5
presented [3] 34/4
49/24 50/23
presenting [1] 87/2
presently [2] 146/4
153/12
presents [1] 36/8
preservation [1]
22/25
preserve [2] 97/25
129/11
preserving [1] 56/14
press [3] 10/19
111/16 111/16
pressed [1] 117/16
pressing [2] 16/13
130/22
presumptive [1]
135/5
pretend [1] 2/16
prevailing [1] 7/3
prevent [2] 7/1
126/20
preventing [3] 13/14
128/13 159/23
previous [3] 36/14
111/15 148/10
previously [3] 10/15
60/1 66/24
primarily [3] 60/11
78/22 78/25
primary [3] 54/3
56/14 155/3
principal [2] 125/6
137/3
principally [1] 76/19
principle [2] 146/4
152/4
principled [1] 134/18
Principles [5] 145/4
145/12 149/25 150/25)
151/19
prior [3] 28/20 70/2
78/18
priorities [1] 24/9
private [4] 70/13 85/4
102/18 133/20
privilege [1] 152/5
privileged [1] 30/18
privileges [4] 30/14
32/4 65/25 66/4
proactively [3] 56/20
154/8 155/17
probably [4] 21/12
23/15 49/6 119/16
problem [6] 91/24
104/20 111/7 120/17
135/18 135/21
problems [27] 4/23
34/25 35/3 35/19
36/17 38/17 38/21
40/13 40/16 40/22
91/20 104/10 111/6
111/21 113/1 120/9
121/11 129/15 131/10)
131/16 132/14 139/24)
141/11 147/5 157/2
157/11 157/13
procedure [5] 10/21
48/16 99/20 102/4
102/23
procedures [3] 10/16
12/3 36/24
proceed [1] 92/11
proceeding [1] 51/3
proceedings [12]
52/8 52/9 55/4 59/18
64/25 71/8 72/20
75/17 92/2 96/22
103/17 107/8
proceeds [1] 96/20
process [21] 13/21
21/1 32/10 36/21
42/22 43/11 44/10
45/13 47/12 52/19
61/22 79/6 99/14
106/8 106/16 106/18
109/18 111/10 114/15)
141/9 154/17
process-driven [1]
106/16
processed [1] 60/22
processes [13] 6/24
8/20 9/22 11/10 14/25)
32/13 40/16 56/7 60/6
62/19 106/10 106/11
141/8
processing [1] 30/20
procurement [5]
128/16 128/25 130/1
132/23 133/4
produced [7] 38/11
61/2 61/5 102/5
105/12 106/12 106/17)
producing [4] 75/16
105/14 106/9 106/21
product [5] 60/14
78/25 86/19 97/8 97/9
production [3]
105/25 106/14 108/7
professional [10]
39/1 42/22 53/25 92/3
92/7 101/12 151/7
151/16 152/5 152/9
professionally [1]
47/20
professionals [1]
49/21
Professor [10] 87/11
93/4 108/20 108/22
111/19 111/22 112/1
121/6 121/19 122/9
Professor
McLachlan [6] 87/11
93/4 111/19 112/1
121/6 121/19
profound [4] 71/6
147/5 157/2 159/8
profoundly [4] 59/16
78/2 84/25 100/17
programme [6] 11/23
11/25 12/3 18/3 18/7
7718
progress [7] 20/5
34/21 53/13 77/6
142/11 156/13 158/19!
progressed [1] 49/10
progressing [1]
130/18
project [11] 34/25
129/13 129/16 130/8
130/12 130/23 132/6
132/25 133/6 133/10
157/18
projects [3] 132/25
133/14 158/21
prolonged [1] 77/9
promised [1] 142/16
promises [1] 161/4
promoted [1] 155/7
prompt [2] 152/21
154/19
promptly [1] 89/1
promulgating [1]
102/23
proof [1] 10/10
proper [7] 66/11
101/22 139/10 141/7
141/8 142/1 159/20
properly [13] 7/14
48/18 48/22 48/22
52/12 52/16 71/17
71/22 100/5 100/5
110/3 110/21 143/18
proportion [1]
144/10
proposal [7] 14/13
16/4 16/9 18/9 52/23
53/3 114/9
proposals [7] 2/18
15/22 16/3 16/6 112/6}
122/5 159/13
propose [2] 1/16
22/19
proposed [5] 10/4
15/24 19/3 122/12
154/6
proposes [2] 18/3
155/25
proposing [1] 117/14
proposition [1] 61/25
propositions [1] 71/1
prosecute [1] 99/24
prosecuted [4] 70/14
99/14 113/17 115/10
prosecuting [6]
48/25 49/2 82/20 84/7)
85/3 85/9
prosecution [20]
7/22 33/11 33/16
43/19 45/14 46/11
50/10 54/15 54/19
68/2 70/2 71/19 71/24,
72/8 85/20 87/12
94/19 102/18 118/15
142/20
prosecutions [37]
5/22 6/7 6/13 6/14
6/16 11/16 32/17
42/11 42/13 42/15
42/21 44/16 45/23
49/2 49/6 50/10 50/12)
51/2 51/8 51/10 51/15)
69/24 70/11 70/23
71/3 72/1 72/13 72/15)
74/8 74/15 74/19
103/2 113/19 114/18
115/4 118/17 142/7
prosecutor [13] 6/12
44/24 45/16 70/13
85/5 85/6 94/22 98/12,
98/18 100/21 101/13
115/3 118/10
prosecutorial [10]
11/14 46/4 51/14 70/5)
70/7 71/10 84/25
90/20 99/17 99/22
prosecutors [14]
42/17 43/1 70/16 84/5)
86/9 87/8 88/8 97/19
100/8 102/22 109/8
111/3 111/25 117/5
prospect [1] 19/10
protecting [1] 5/5
protection [3] 55/18
55/19 55/22
proved [2] 86/23
141/5
provenance [1]
115/14
provide [40] 12/9
20/4 20/10 25/24
34/14 40/6 49/22
50/17 51/6 51/21 66/5I
68/3 71/2 71/11 72/9
73/3 74/17 75/24 88/6I
88/7 89/4 90/3 95/3
95/5 95/19 96/3 97/4
97/5 106/17 106/22
109/14 111/25 112/7
125/25 126/25 140/3
140/19 153/13 156/18)
157/14
provided [41] 22/15
41/18 42/1 45/18
51/22 69/8 71/7 73/3
76/5 82/9 86/19 87/5
89/1 89/20 89/24 96/5]
98/3 102/14 106/15
107/25 111/1 111/3
411/19 112/11 115/21
115/25 117/3 118/21
122/2 123/17 129/4
131/19 140/12 140/25)
141/3 142/24 142/25
144/3 148/1 148/7
150/16
provider [1] 71/4
provides [6] 8/21
10/7 10/24 10/25 18/5)
156/22
providing [10] 19/25
71/19 86/16 101/5
115/12 120/18 123/20)
140/2 140/7 149/3
provision [5] 61/4
71/25 88/18 106/22
122/8
public [22] 2/15 13/2
16/12 19/8 57/6 77/20)
85/6 87/18 119/25
126/5 135/3 136/21
140/15 145/2 145/14
146/5 147/2 147/19
153/13 158/21 158/24)
159/7
publication [1] 27/9
publicly [4] 155/15
published [4] 11/6
18/15 22/10 153/11
publishes [1] 156/13
publishing [1]
159/11
pulled [1] 107/5
purchases [1] 62/6
purported [4] 93/23
98/10 111/2 123/21
purpose [6] 15/3
(63) potential... - purpose
Pp
purpose... [5] 66/5
131/7 131/18 132/9
132/12
purpose’ [1] 24/21
purposefully [1]
46/23
purposes [3] 64/17
74/4 100/2
push [4] 18/24
put [30] 11/25 14/2
15/22 16/9 24/16
36/25 55/6 62/21 82/1
84/11 97/5 97/6
101/11 101/18 102/20)
103/20 110/21 112/6
113/10 114/15 116/15}
116/17 120/1 120/3
120/3 123/18 131/14
138/13 144/8 146/10
putting [3] 91/6
139/4 145/23
pyramid [1] 136/3
pyramidal [1] 135/24
Qu
qualified [1] 53/22
quality [5] 15/13 69/2
125/23 138/19 143/13
quantities [2] 68/20
144/4
queried [2] 48/20
107/24
question [9] 33/13
35/11 64/22 84/15
84/20 122/23 123/14
151/14 161/1
questioned [1] 143/9
questions [17] 23/5
52/15 55/6 73/6 83/11
86/4 88/12 89/1 89/3
91/5 97/2 111/5 111/7,
115/6 115/8 115/21
159/8
quick [1] 76/13
quickly [4] 14/1
19/14 156/12 161/5
quiet [1] 22/2
quite [11] 52/16
84/22 93/18 94/18
110/8 110/20 115/24
119/9 120/20 151/25
160/7
quote [5] 24/14 30/17I
32/9 49/6 130/13
quoting [1] 67/9
R
rag [1] 87/23
Railton [3] 17/9
17/25 158/16
Railton's [1] 158/1
raise [4] 10/19 24/7
118/6 131/10
raised [9] 7/16 7/21
25/11 27/16 115/2
115/11 117/2 120/23
141/15
raises [2] 3/22 73/6
raising [1] 144/6
range [5] 12/3 70/21
137/10 137/15 159/12)
ranging [1] 159/5
rather [11] 6/25 8/14
21/12 72/4 87/25
89/15 93/20 107/4
107/6 154/1 160/8
re [1] 8/17
re-orientating [1]
8/17
reach [3] 45/1 52/2
58/1
reaches [1] 15/14
reaching [1] 17/2
read [8] 2/4 2/10 10/8
12/18 44/7 73/18
76/14 148/12
reader [1] 39/2
readily [2] 129/14
134/19
reading [2] 38/24
92/15
ready [1] 1/8
real [10] 14/6 32/6
73/6 104/11 107/18
131/19 151/25 157/7
157/22 158/25
realise [2] 134/4
135/21
realised [1] 130/24
realises [4] 133/12
145/12 152/23 156/7
realistic [1] 25/11
realities [1] 138/18
really [4] 94/19
110/24 130/2 137/1
realtime [1] 41/13
reason [16] 24/19
27/21 30/25 31/19
33/13 44/24 51/9 66/2
83/3 85/8 90/4 106/2
112/13 131/4 142/6
146/4
reasonable [4] 25/3
39/1 76/25 118/11
reasonably [1] 143/7
reasons [11] 23/21
84/21 96/9 96/25
108/24 126/23 134/19)
145/16 146/7 147/20
157/25
reassurance [1]
131/20
reassured [1] 40/2
rebalanced [1] 158/4
rebalancing [1]
157/5
rebuild [1] 8/12
rebuilding [2] 13/4
153/17
rebut [1] 97/23
Recaldin [1] 19/21
recall [7] 30/4 44/6
55/5 64/8 65/19
103/15 152/11
receipts [3] 28/3
112/16 113/12
receive [4] 19/10
19/13 43/17 57/17
received [14] 1/13
12/6 33/3 34/19 35/2
44/5 44/11 53/9 60/9
63/22 77/5 78/21
144/4 160/11
receiving [11] 16/22
20/8 30/4 32/23 33/1
43/17 46/6 52/17
141/2 153/1 160/2
recent [9] 9/8 14/7
22/21 37/25 56/10
133/3 147/2 149/6
158/22
recently [1] 72/21
recklessly [1] 140/10
recognise [1] 158/23
recognised [7] 12/17
54/11 72/23 92/4
129/9 155/19 157/3
recognises [11] 1/19
12/19 19/9 38/2 71/21
126/17 127/12 127/19]
150/14 156/6 159/8
recognising [1] 14/1
recognition [2] 101/1
128/9
recollection [2]
42/20 46/6
recommence [1]
132/3
recommend [1] 41/6
recommendations
[12] 20/20 30/11
31/4 56/13 145/25
146/2 147/2 152/15
156/21 158/8 158/22
160/2
recommended [2]
49/18 52/20
reconcilable [1]
129/22
reconciliation [1]
26/18
reconsidered [1]
149/9
reconstruction [2]
88/4 99/13
recorded [5] 27/19
88/9 100/2 100/12
111/9
recording [2] 41/14
102/9
records [3] 27/13
60/24 111/14
recover [1] 72/16
recruitment [2] 13/20)
150/8
rectify [2] 65/14 86/2
recurrence [1]
128/14
red [3] 36/19 37/2
87/23
redo [1] 137/12
redress [19] 19/10
19/14 19/18 20/1 20/5}
128/22 152/18 152/21
153/1 153/4 153/7
154/16 155/1 155/5
155/16 155/22 155/24}
156/9 156/22
reduce [1] 150/18
reduced [1] 6/17
Reefer [1] 102/3
refer [4] 114/18
140/24 145/5 154/23
reference [4] 3/5
23/24 66/21 121/23
referral [1] 10/22
referred [4] 4/20
33/25 73/15 116/3
referring [2] 49/13
107/9
reflect [5] 20/18 74/3
90/24 110/13 159/25
reflected [5] 59/14
60/17 102/4 115/24
147/20
refocusing [1] 17/20
refreshing [1] 89/15
refusal [1] 118/12
refused [5] 7/9 104/8
112/13 122/7 122/13
regard [7] 22/24
32/17 33/5 85/2 110/7
110/14 120/13
regarded [2] 87/19
114/24
regarding [10] 24/25
55/3 55/16 72/12 73/7,
74/14 75/6 75/8 80/19
120/23
regards [2] 103/12
107/3
regret [4] 4/15 57/14
71/6 109/19
regrettable [3] 66/10
131/14 147/4
regrettably [2] 5/12
73/1
regular [2] 141/9
156/13
regularity [1] 151/23
regularly [3] 20/2
154/8 154/10
regulate [1] 106/20
Regulated [1] 49/21
regulation [3] 151/7
151/8 152/14
regulatory [3] 24/5
128/22 151/2
rehearse [3] 1/15
7/23 134/7
reinforced [1] 59/23
reinvented [1]
153/16
reiterate [1] 74/19
reiterated [1] 65/10
reiterates [2] 20/25
78/3
reiterating [1] 1/22
rejected [2] 67/4
118/3
relate [1] 99/18
related [7] 26/8
103/16 105/25 108/6
112/8 116/19 153/19
Relatedly [2] 76/1
109/8
relates [3] 61/9 61/12
138/24
relating [3] 11/4
43/12 45/9
relation [24] 3/6
25/25 26/14 30/10
40/6 52/15 54/4 56/6
63/21 72/1 72/18
73/13 77/22 94/13
94/22 99/16 113/12
127/1 134/1 136/17
144/9 153/7 158/9
158/23
relationship [6] 2/14
14/9 66/16 67/21
129/19 129/25
relationships [3]
14/5 58/7 158/11
relative [1] 78/13
relatively [3] 18/19
128/24 152/17
release [2] 121/22
122/3
releases [1] 69/2
relevant [21] 4/3 5/25)
22/21 23/24 29/10
40/1 43/11 62/2 64/6
73/15 73/23 74/25
76/3 89/21 99/22
109/7 138/24 146/16
147/17 150/16 151/7
reliability [5] 4/17
39/23 40/8 67/6 80/20)
reliable [8] 12/10
27/1 32/14 56/16 69/5
119/18 119/20 119/21
reliance [4] 4/16
109/11 147/25 150/18)
reliant [1] 144/12
relied [6] 25/22 39/21
40/2 40/3 85/22 101/2
relies [2] 24/22 69/3
(64) purpose... - relies
R
rely [10] 16/21 25/7
25/23 33/6 39/17
43/18 47/25 53/21
84/13 100/22
relying [1] 85/10
remain [4] 24/20
62/22 67/20 133/5
remainder [1] 8/1
remained [5] 61/1
74/15 130/12 157/13
157/21
remaining [1] 9/10
remains [14] 18/9
19/12 21/3 32/18
62/12 62/14 65/11
134/17 135/1 135/3
137/3 150/13 159/22
161/41
remarkable [1] 119/3
remarks [1] 160/4
remediate [1] 11/23
remedying [1] 113/6
remember [3] 129/1
141/2 161/3
remembered [1] 91/1
remind [4] 13/5
118/17 119/1 122/6
reminded [1] 102/2
reminding [1] 124/25
remote [20] 24/11
28/22 30/5 61/12
65/11 65/25 66/4 66/8
75/13 81/15 87/17
87/22 89/5 113/14
113/16 113/18 113/22)
113/24 123/7 142/1
remotely [6] 29/3
29/13 31/22 65/5
65/21 160/18
remove [2] 92/1
104/19
remuneration [1]
14/11
render [1] 85/16
renewed [2] 72/14
158/4
repeat [10] 13/15
22/20 59/12 69/21
70/23 74/10 75/2
75/23 140/21 153/5
repeated [7] 8/7
38/16 61/21 62/1 69/4
79/7 126/4
repeatedly [1] 26/24
repeating [2] 74/12
143/21
repeats [1] 20/23
replace [2] 77/4
133/6
replacement [1]
157/18
replacing [2] 77/7
77/11
replied [1] 95/11
reply [1] 114/3
report [52] 7/5 7/15
11/4 20/20 27/19
27/19 29/25 30/1
30/22 32/7 32/15
32/16 34/21 36/4 36/8
37/19 38/8 38/12
38/18 38/23 38/24
39/2 39/7 39/12 40/25)
44/21 45/9 50/3 51/19
55/24 56/5 93/9
108/20 115/8 115/22
116/4 116/7 116/10
1417/1 118/21 132/13
142/19 142/20 146/1
146/2 148/12 149/6
153/10 155/23 158/9
161/2 161/4
Report's [1] 56/13
reported [4] 26/4
39/25 136/7 136/17
reporting [3] 6/14
30/9 151/4
reports [7] 92/16
92/17 97/3 130/11
132/14 132/20 156/13)
reprehensibly [1]
125/19
representation [1]
141/10
representative [3]
131/9 139/2 148/22
representatives [3]
64/24 154/10 154/14
represented [1]
38/25
representing [2] 90/7
117/8
reputable [1] 51/24
reputation [5] 55/18
55/20 55/23 56/14
72/24
reputational [2] 36/9
56/2
reputations [1] 125/1
request [1] 112/2
requested [3] 20/10
54/15 89/2
requests [7] 60/19
68/5 71/18 112/14
121/20 121/21 144/7
require [1] 120/1
required [11] 26/9
34/2 34/17 38/22
46/12 68/3 72/9 112/9
116/20 130/2 135/21
requirement [1]
102/11
requirements [6]
67/23 86/3 86/6 95/4
95/20 130/4
requires [2] 14/24
137/25
requiring [1] 102/16
requisite [1] 49/22
research [1] 92/6
researched [1]
140/20
resemblance [1]
66/23
reservation [2]
138/23 139/3
reservations [1] 68/9
reset [5] 2/14 13/5
14/14 18/3 157/4
resistance [5] 4/24
111/17 121/7 131/5
146/21
resolution [5] 10/21
10/22 52/20 61/10
62/20
resolve [1] 132/14
resolved [4] 26/8
42/6 132/2 132/4
respect [12] 12/21
14/17 16/14 19/11
41/9 55/10 71/3 71/23
105/21 120/5 147/3
152/16
respectful [1] 120/12
respectfully [2] 90/7
106/1
respectively [1]
44/24
respects [2] 40/5
76/8
respond [3] 97/3
108/20 159/16
responded [2] 60/18
88/6
responding [2] 20/13
48/2
response [9] 7/5
34/5 46/25 83/11
114/22 122/23 137/25)
141/16 154/22
responses [1] 34/15
responsibilities [4]
5/13 50/16 127/16
137/11
responsibility [15]
12/25 13/22 16/1 26/3
26/7 66/12 66/25
125/7 126/15 127/7
127/11 127/13 128/6
137/4 155/20
responsible [7] 48/3
57/20 115/16 119/12
126/21 127/14 147/19}
responsibly [1]
42/21
rest [1] 16/1
restating [1] 152/19
restore [2] 2/23 13/1
restoring [1] 14/6
restrained [1] 143/5
restructured [1]
15/19
result [3] 18/1 32/10
144/14
resulted [3] 5/10
71/19 106/10
resulting [3] 3/20
78/21 155/8
results [1] 151/14
resurrection [1]
76/12
Retail [1] 10/9
retain [1] 102/11
retained [2] 100/1
127/12
retaining [1] 102/10
retire [1] 77/4
retired [1] 80/24
retrieval [1] 107/10
retrieve [1] 117/23
retrieved [1] 107/4
retrospect [2] 23/11
139/20
return [4] 30/1 96/10
147/11 156/24
Returning [3] 84/8
100/23 107/21
reveal [3] 90/20
120/9 145/2
revealed [9] 7/4
46/10 53/11 75/3 78/7)
90/19 90/22 100/2
113/14
revealing [2] 102/9
113/18
revelatory [1] 131/13
revenues [1] 17/15
review [52] 10/2
10/22 11/11 14/8
14/21 15/6 15/9 15/21
16/7 16/8 16/13 17/1
17/6 17/12 17/17
17/20 18/2 18/23
32/25 33/23 34/21
35/2 36/5 38/14 43/20
44/10 44/16 45/12
45/14 45/15 45/15
45/22 46/12 47/1 47/3
47/12 47/19 49/5 49/8)
49/10 49/12 49/18
51/13 53/25 54/4 56/3)
114/23 132/8 137/12
142/12 142/16 148/6
reviewed [4] 37/8
53/17 53/25 76/2
reviewing [2] 45/13
54/5
reviews [5] 18/13
39/4 39/11 39/12
141/9
revolution [1] 4/11
Reynolds [1] 159/3
Richard [1] 149/16
Richardson [1] 54/16
right [20] 21/16
21/24 22/3 31/16 46/3I
46/25 56/3 58/20
79/19 95/2 124/18
124/18 127/2 127/2
127/24 132/11 138/6
138/23 148/14 158/3
rightly [3] 3/1 3/17
2115
rigorous [1] 49/8
rigorously [1] 27/3
rigour [1] 42/16
rise [1] 84/15
risk [8] 30/16 30/19
31/8 32/3 32/6 50/24
77/18 102/20
risks [5] 36/9 50/17
56/2 134/2 140/19
RMG [2] 16/16 25/9
road [1] 159/10
robust [4] 24/20
27/11 141/5 141/17
robustness [1] 69/18
Rod [2] 28/25 32/9
role [47] 11/7 14/24
17/15 24/2 25/17
25/20 30/15 31/8
31/13 31/16 34/12
42/25 45/16 50/5
50/12 50/19 51/14
51/23 55/2 55/17 60/2
81/12 91/19 96/2
97/17 98/2 109/16
128/8 128/21 131/13
137/10 137/17 139/1
143/19 147/14 147/15)
148/3 148/21 149/7
149/9 149/12 149/12
150/5 151/22 152/3
155/25 159/20
roles [6] 3/14 5/11
5/14 5/17 57/20
143/24
Rolfe [5] 142/9
143/10 148/9 149/17
150/2
roll [1] 154/13
rolled [2] 62/11
130/16
rollout [10] 26/16
65/8 70/3 70/10
128/17 128/25 132/1
132/10 132/13 132/23}
room [1] 124/24
root [2] 4/18 91/20
rooted [1] 157/11
roots [1] 2/8
Rose [9] 44/21 45/9
50/3 51/19 81/24
115/8 116/2 116/8
142/20
rosier [1] 110/23
rough [1] 123/1
round [1] 143/14
(65) rely - round
R
routinely [2] 63/4
102/19
Royal [6] 6/9 32/7
63/21 64/4 136/12
136/13
Rudkin [3] 41/18
41/23 42/2
Rudkin's [2] 41/10
42/8
ruin [1] 125/1
Rule [1] 60/19
Rule 9 [1] 60/19
rules [4] 84/6 102/4
102/23 120/1
run [2] 19/16 32/15
running [3] 35/13
130/8 134/21
runs [1] 29/24
s
Saf [1] 157/16
said [45] 7/23 12/18
23/3 24/17 26/11
26/16 27/4 33/8 33/15
39/21 40/1 41/16
44/25 49/12 49/20
51/17 54/20 56/8 57/6
57/21 69/19 77/25
78/9 78/13 83/17
91/24 103/13 104/10
107/8 109/24 110/10
110/15 110/19 111/5
114/10 116/16 117/25}
119/1 119/7 119/8
123/8 134/2 138/17
138/21 143/12
sale [2] 62/4 129/10
same [14] 27/17
32/22 38/2 42/15 43/2
67/9 67/13 75/23
132/16 138/16 141/24}
143/21 148/5 150/23
sanctions [2] 145/24
151/20
Sandra [2] 138/13
139/7
Sarah [4] 153/18
153/22 153/25 154/20}
sat [2] 9/4 135/24
satisfactorily [1]
132/4
satisfactory [1]
35/10
satisfied [4] 32/18
42/10 161/5 161/6
satisfy [1] 137/17
save [2] 22/20 47/12
saving [1] 159/18
saw [11] 5/1 55/21
56/12 67/21 68/1 83/1
89/9 101/16 103/1
135/13 147/14
say [8] 60/7 102/24
110/9 123/3 147/4
160/6 161/2 161/3
saying [4] 35/17 94/6
119/15 160/12
says [7] 3/3 21/7 45/6)
46/8 83/7 110/13
118/15
scale [6] 3/8 71/9
77/3 99/24 130/1
133/19
scandal [20] 1/24 2/6
13/9 13/10 124/24
125/7 125/13 125/21
125/22 126/2 126/16
126/20 127/24 128/8
134/7 146/9 150/7
151/22 155/21 159/23)
schedule [3] 88/10
100/16 111/9
schedules [1] 100/11
scheme [17] 19/16
52/19 52/25 53/2 53/6
53/13 53/17 53/20
153/14 153/15 153/16)
153/21 153/24 154/2
154/15 154/16 155/3
schemes [6] 19/23
20/5 153/10 154/11
155/18 156/11
schooled [1] 91/22
scope [1] 3/8
scoping [1] 112/7
screen [1] 26/13
scrutinise [7] 7/14
135/10 140/17 143/18)
143/25 147/14 150/17)
scrutinised [1]
136/20
scrutiny [11] 71/17
85/5 126/25 133/8
138/1 139/22 140/4
146/21 149/2 152/5
156/15
searched [1] 60/21
searching [1] 78/6
seat [3] 67/21 124/12
148/11
seats [1] 124/11
second [65] 7/5 7/8
7/14 10/5 31/19 32/25)
33/23 33/24 33/25
34/4 34/11 34/14
34/18 34/24 35/2
35/24 36/2 36/6 37/6
37/19 38/5 38/7 38/11
38/12 38/15 38/16
38/22 38/25 39/5
39/10 39/11 39/14
40/6 41/19 41/22 42/5
43/9 44/18 46/11 49/4
54/7 54/14 55/23
61/11 83/24 85/8
87/23 87/24 88/18
88/19 88/21 90/3
94/24 100/4 101/4
114/23 123/6 134/22
137/12 137/22 142/10
147/13 148/12 148/20}
153/19
second-guess [2]
54/7 137/12
Secondly [1] 9/24
secrecy [1] 126/3
secret [1] 87/10
secretaries [2] 138/9
138/10
Secretary [3] 136/18
136/19 159/2
section [4] 39/6 67/9
85/15 116/17
section 2 [1] 39/6
Section 9 [1] 85/15
sector [1] 158/21
secure [1] 12/10
secured [1] 155/3
security [4] 34/6 64/1
125/17 136/5
see [10] 1/5 30/25
32/25 68/6 80/20 88/2
94/12 117/23 119/11
144/17
seek [6] 7/24 23/1
30/2 52/2 100/22
159/12
seeking [5] 52/20
66/13 110/15 111/2
153/14
seeks [2] 16/25 23/9
seemed [3] 76/15
104/4 143/20
seemingly [2] 144/20
146/12
seems [2] 105/17
147/16
seen [16] 2/10 13/14
22/12 23/7 25/2 26/20
42/18 52/4 92/21
118/20 119/7 119/9
122/24 143/3 152/6
157/12
sees [2] 14/13 146/4
Sefton [2] 117/12
118/1
SEG [1] 18/19
Select [5] 42/12
54/13 54/25 74/17
156/14
self [7] 16/20 21/25
22/25 91/7 138/7
147/19 148/10
self-critical [1]
147/19
self-discipline [1]
21/25
self-evident [1] 138/7I
self-preservation [1]
22/25
self-sustaining [1]
16/20
sending [1] 97/19
senior [26] 3/13 3/14
AIT 4/10 5/10 5/11
5/16 6/5 6/10 15/18
25/19 26/3 29/1 29/20)
34/10 47/6 54/10
57/19 58/4 63/24
71/14 94/3 136/8
137/6 138/8 140/9
sense [5] 61/25
103/5 108/13 110/7
130/23
sensible [3] 131/12
135/2 135/8
sensibly [1] 161/5
sensitive [1] 68/7
sent [14] 27/2 38/8
39/12 43/4 43/20
43/25 45/4 76/4 81/22
98/15 104/1 114/1
115/8 115/17
separate [2] 98/14
108/17
separated [2] 6/8
23/25
separation [2] 16/16
25/9
September [7] 17/6
28/4 28/7 32/8 53/12
123/5 152/12
series [5] 5/21 83/4
97/15 103/7 110/25
serious [10] 3/19
14/18 60/14 67/5 68/8}
70/22 78/25 129/15
151/17 157/13
seriously [2] 20/21
103/19
seriousness [2]
151/24 155/13
servant [2] 148/10
148/18
servants [2] 140/3
144/22
serve [4] 11/7 16/11
16/12 17/23
served [3] 17/5 56/22
115/1
server [1] 106/11
serves [3] 17/22 19/8
151/11
service [9] 68/6 71/4
71/19 77/16 77/23
149/21 149/25 150/10)
151/4
services [7] 62/4
62/5 62/6 62/6 71/7
77120 134/12
serving [1] 91/7
set [25] 11/5 18/22
23/23 32/19 37/9 44/1
53/3 55/8 73/9 78/11
80/1 82/5 106/9
108/24 114/9 117/11
122/1 131/6 134/5
152/7 153/4 153/14
154/11 155/13 158/5
setback [1] 130/21
sets [3] 76/9 138/14
138/15
setting [2] 51/1
100/23
settlement [1] 155/2
seven [1] 122/4
Seventh [1] 46/14
several [6] 4/7 22/19
28/11 129/1 139/3
140/9
severe [1] 76/9
severely [2] 6/17
8/13
Sewell [13] 25/14
25/20 28/11 28/15
28/19 30/24 32/9 40/1
40/4 41/9 41/16 46/9
68/15
shabby [1] 127/21
shall [3] 14/8 22/13
7917
share [7] 6/19 17/15
66/12 67/1 78/10
126/14 155/20
shared [9] 5/23 37/17
50/20 58/9 58/11
58/13 58/14 63/4
147/7
shareholder [11]
16/14 126/17 127/4
136/14 139/2 148/21
148/24 149/8 149/13
149/18 150/3
sharing [4] 6/24
62/24 68/19 68/24
sharper [1] 151/18
she [100] 22/8 22/17
23/7 23/9 24/16 24/17
25/5 25/6 25/7 25/11
25/13 25/22 30/25
31/6 31/7 31/11 31/16I
31/18 31/19 33/3 33/5
33/19 33/21 33/21
34/12 34/14 35/1
35/22 36/1 36/19 37/2I
37/5 37/11 37/18 38/1
38/6 39/17 39/18
39/20 39/21 40/2 40/2I
40/3 40/3 42/13 42/14)
42/14 42/19 42/20
43/18 45/6 45/8 46/8
46/8 46/11 46/16
46/18 46/23 46/24
46/24 47/3 47/8 47/12
52/3 53/21 53/23 54/7I
54/14 54/16 55/4
55/24 56/8 56/18
56/18 56/22 57/6 57/8
(66) routinely - she
Ss
she... [23] 57/8 57/10
57/11 57/18 57/19
57/19 57/21 58/3 58/6}
58/7 58/8 58/9 58/11
58/23 105/22 113/1
114/2 116/16 116/22
116/23 143/3 143/12
143/12
she'd [2] 116/18
143/3
sheer [1] 64/4
Sheldon [1] 134/2
shelved [1] 142/16
ShEx [27] 127/4
128/5 128/20 135/8
136/16 136/16 137/9
139/1 139/24 140/17
141/13 141/4 141/14
141/16 141/23 142/24}
143/16 144/17 144/25)
147/7 147/13 147/24
148/3 148/6 148/22
149/20 150/19
ShEx's [3] 127/7
127/9 143/14
ShEx/UKGI [14]
135/8 137/9 139/1
139/24 140/17 142/24)
144/17 144/25 147/13
147/24 148/6 148/22
149/20 150/19
ShEx/UKGI's [1]
148/3
shift [2] 8/8 15/1
shifted [1] 86/25
shirk [2] 66/25
126/14
shocking [3] 50/22
7AI9 80/24
short [12] 21/22
39/14 59/3 59/8 70/12
71/20 79/24 93/5 97/4,
124/4 145/3 145/17
shortcomings [1]
8/12
shortened [1] 133/7
shorter [1] 78/14
shorter-than-some
[1] 78/14
shortfalls [1] 72/17
shortly [6] 14/8 27/8
42/14 45/2 96/16
114/15
should [41] 11/9
11/18 16/1 16/20
16/23 19/16 19/17
19/20 19/22 22/23
25/13 38/2 40/11
47/13 47/16 47/21
48/9 48/11 48/20 51/8
52/14 56/20 78/14
98/8 98/13 98/17
101/14 103/13 107/18)
109/24 110/2 115/12
115/20 132/7 132/19
135/5 138/7 146/5
149/9 155/25 159/9
show [6] 58/18 82/3
83/16 117/13 117/17
123/13
showed [2] 7/6 31/13
shown [4] 10/6 48/12
143/3 160/16
shows [2] 7/13 34/19
shut [3] 1/9 1/10
143/22
Sibbick [1] 132/5
sic [1] 110/17
Sight [41] 7/5 7/14
32/25 33/23 33/24
33/25 34/4 34/11
34/14 34/19 34/24
35/2 35/24 36/2 36/7
37/19 38/5 38/7 38/11
38/12 38/15 38/17
38/22 39/6 39/10
39/11 39/14 41/19
41/22 42/5 43/9 54/14
55/23 87/23 88/18
88/19 88/21 90/4
114/23 123/6 148/12
Sight's [4] 7/8 37/6
38/25 142/10
sighted [1] 71/9
sign [2] 102/16 121/1
signed [2] 41/23
93/12
significance [5] 6/23
31/6 40/7 47/24 50/3
significant [20] 3/11
7/20 12/2 14/11 14/25)
16/17 36/9 45/21
64/25 68/25 70/4
72/25 76/7 76/23
99/18 100/7 104/4
105/22 113/19 130/20)
significantly [2]
17/13 87/21
signing [1] 92/16
signs [1] 157/12
similar [2] 5/18
159/24
similarly [5] 6/19
41/8 69/7 118/1
127/19
Simon [3] 11/20
19/21 43/20
simple [1] 126/19
simply [10] 24/8
24/15 25/10 57/17
84/22 92/3 93/18
95/25 108/12 139/4
sin [1] 146/10
since [10] 8/2 8/8
8/17 9/1 9/4 16/15
42/18 51/5 74/15
77/21
sincere [2] 78/3
128/7
sincerest [1] 20/24
Singh [9] 83/11 94/2
94/13 94/13 98/6
109/10 111/4 111/12
si
single [12] 23/7 69/5
82/17 83/25 85/14
94/8 96/4 96/6 97/12
97/18 100/13 114/1
singled [1] 81/1
sir [128] 1/13 21/15
22/5 22/5 23/20 24/7
24/11 24/23 26/2 28/3
28/22 31/1 31/15
32/15 32/24 34/23
36/18 37/5 37/15
39/19 42/11 43/14
46/22 47/11 51/23
55/2 55/18 57/3 57/17
58/11 58/21 59/7
65/19 66/18 66/24
69/15 69/19 71/10
72/9 74/5 77/25 79/8
79/14 80/4 83/6 83/19)
84/17 85/23 86/11
88/11 88/15 89/19
90/2 90/18 90/23 91/3
93/18 94/7 94/11
94/24 94/25 95/18
96/8 96/10 96/13
96/16 98/15 98/21
99/9 99/11 99/23
100/18 102/17 103/6
103/10 103/12 103/15}
104/5 104/15 104/25
105/4 105/7 106/1
106/4 107/16 108/9
108/14 110/5 110/12
110/18 110/25 112/16
113/15 114/20 114/20
115/18 117/4 118/14
119/1 119/11 119/15
119/15 119/25 122/6
123/15 123/24 124/8
124/11 124/20 129/1
129/23 130/13 132/5
138/2 138/16 139/11
141/2 141/13 141/13
141/14 141/15 143/5
145/22 145/25 148/2
156/20 156/24 159/22
Sir Adrian [2] 129/23
130/13
Sir Alan [2] 141/13
141/15
Sir Alex [1] 138/16
Sir Ed [3] 141/2
141/13 141/14
Sir lan [1] 132/5
Sir Martin [1] 139/11
sit [2] 51/18 160/19
sitting [2] 1/5 148/11
situation [2] 119/14
138/18
six [2] 16/8 39/12
Sixth [2] 46/6 99/5
size [3] 24/10 40/21
132/7
skilled [1] 18/20
slightest [1] 122/24
slightly [2] 49/14
119/20
slow [2] 8/10 152/23
small [4] 133/19
140/24 144/2 155/11
smiling [1] 119/16
Smith [3] 26/5 94/14
94/17
smooth [1] 130/8
so [65] 1/9 1/10 8/13
10/2 15/19 17/21
17/23 18/22 21/16
21/19 25/5 25/12
29/23 30/4 36/10
41/13 44/3 51/2 58/25)
63/1 71/24 75/3 76/15
78/1 79/10 79/12
79/22 80/25 81/15
86/24 89/5 90/7 90/15)
92/9 92/10 96/10
102/19 105/3 105/18
105/19 108/7 113/25
115/18 121/6 124/25
127/15 127/24 130/15}
130/22 131/18 132/2
135/2 135/20 138/12
140/23 144/11 146/7
150/1 154/4 155/15
160/13 160/21 161/1
161/4 161/10
society [1] 151/9
software [2] 38/21
125/23
sole [2] 16/13 126/16
solely [1] 39/4
solicitor [2] 20/17
53/22
solicitors [1] 151/8
solution [2] 133/21
138/17
solutions [2] 155/5
155/12
solving [1] 91/24
some [40] 1/16 4/8
16/2 16/14 21/25 27/5}
44/10 57/25 61/18
68/24 73/1 73/20 74/1
74/3 76/1 76/6 78/14
78/16 79/4 81/8 88/9
91/10 92/11 93/9
99/10 103/4 103/10
105/5 133/14 134/5
135/18 139/23 142/23
145/18 145/19 146/18
148/22 153/4 153/6
160/20
somebody [1] 55/10
something [4] 48/19
77/14 104/13 107/7
somewhere [2] 21/13)
132/17
sooner [1] 57/16
sophisticated [1]
67/16
sorry [2] 57/22
103/13
sort [13] 86/9 87/6
89/25 91/3 91/24
97/17 98/3 102/23
103/5 111/1 112/10
122/25 143/7
sorts [1] 90/20
sought [19] 3/4 22/6
23/12 66/11 66/15
66/25 84/12 87/24
88/11 88/14 103/19
108/3 108/25 111/20
112/2 115/22 115/25
120/7 143/9
sound [1] 141/18
source [2] 4/15 73/1
sourced [1] 54/6
sources [2] 148/8
148/19
South [1] 160/5
South Wales [1]
160/5
space [1] 146/20
spans [1] 64/2
speak [5] 83/8 90/4
106/3 106/7 115/18
speaking [6] 42/23
42/24 43/5 43/15 52/5
155/8
special [1] 101/7
specialist [4] 34/9
34/18 39/21 149/22
specialists [5] 25/19
39/15 39/22 39/25
68/13
specific [11] 43/9
75/18 99/10 102/6
116/19 117/14 117/2
117/7 117/15 1314/7
134/17
specifically [3] 36/18
86/20 97/9
specification [1]
130/15
specifications [1]
129/17
specificity [1] 130/3
specifics [1] 91/10
specified [1] 67/22
speculate [1] 58/10
speech [2] 17/10
133/18
speed [2] 15/20
(67) she... - speed
Ss
speed... [1] 155/5
spends [1] 9/13
spent [2] 92/9 118/22
spin [1] 126/3
SPMs [2] 104/21
114/17
spoke [2] 112/3
136/23
spoken [1] 108/2
sporadic [1] 92/20
spot [3] 39/4 39/11
39/12
spotted [1] 36/25
spreadsheet [1]
115/9
spreadsheets [1]
108/1
Square [4] 81/19
111/14 122/9 122/22
squarely [1] 80/22
SS [1] 36/9
SSC [3] 81/16 113/25
114/6
staff [12] 11/2 17/7
38/8 61/13 65/4 65/15
71/5 73/21 73/22
125/16 145/11 149/20)
stage [3] 37/1 65/20
132/15
stages [1] 146/18
stake [1] 85/7
stakeholder [1] 24/4
stakeholders [4]
17/8 34/22 131/10
144/6
standard [2] 105/11
106/9
standards [5] 99/2
99/4 145/14 151/11
158/15
standing [1] 15/11
stands [2] 69/21 91/7
stark [1] 91/8
starkly [1] 75/3
start [11] 1/22 7/7
8/17 21/24 60/20
62/22 103/12 117/10
123/25 152/19 154/2
started [2] 80/5
158/8
starting [7] 51/12
120/14 134/9 135/5
135/7 146/9 147/23
startling [1] 72/17
state [6] 65/15 128/2
136/19 136/19 138/10}
159/3
stated [13] 17/9
23/15 32/9 32/16
38/19 39/9 42/12 48/7
48/19 97/7 124/22
130/16 148/9
statement [75] 6/4
8/2 12/19 20/22 25/4
26/19 27/20 33/6 42/3
50/6 53/1 55/9 59/8
61/15 65/3 65/18 77/1
77/13 82/6 83/10
83/14 83/15 85/15
87/16 87/19 89/17
93/5 93/14 93/15
93/15 94/14 98/15
98/20 104/7 104/8
104/12 105/11 106/13)
106/21 107/22 107/24}
108/4 109/14 110/1
110/2 110/5 110/9
113/21 114/21 114/25)
116/5 116/10 116/17
116/23 117/6 117/9
117/14 120/15 120/19)
121/12 121/15 122/13}
123/8 124/8 124/20
128/16 129/4 145/5
146/22 146/25 151/22)
153/3 154/24 156/16
156/17
statements [24] 2/19
7/25 14/17 53/21
53/24 55/3 59/11 61/5)
69/23 74/25 81/11
85/15 86/3 86/5 90/13
95/7 96/10 100/15
106/9 106/19 109/22
109/23 109/25 141/25)
states [1] 54/23
stating [4] 38/3 41/4
45/25 54/17
status [2] 77/17
128/1
statutorily [1] 113/7
statutory [8] 98/18
99/25 100/9 106/6
109/2 145/23 151/19
158/14
Staunton [1] 157/20
Stein's [1] 24/13
step [4] 10/14 101/20
160/8 160/9
Stephen [2] 130/25
148/2
steps [8] 8/8 9/2 15/9
31/3 47/15 85/25 86/2
157/7
stick [1] 89/12
still [9] 2/13 29/22
33/19 36/8 58/2
103/21 111/8 114/18
156/6
stipulating [1] 68/4
stolen [2] 110/11
122/15
stood [1] 46/9
store [1] 111/18
stored [1] 106/10
stories [1] 133/3
story [2] 126/2
126/10
straight [1] 88/22
straightforward [1]
33/5
strange [1] 129/18
strategic [17] 9/6
10/2 13/18 14/3 14/7
15/6 15/9 16/7 16/8
17/1 17/11 17/17
17/20 18/2 18/23 24/4
135/19
strategy [5] 14/24
15/4 19/3 19/4 89/22
streamlined [3]
14/25 17/21 158/12
strength [1] 57/4
strengthen [2] 17/15
134/13
strengthening [1]
14/12
stress [1] 157/22
stretched [1] 24/3
strict [1] 135/18
strike [1] 89/11
striking [1] 6/8
stripes [1] 142/22
strong [2] 4/24 17/17
stronger [1] 67/12
strongly [2] 105/24
147/23
structural [7] 2/8
3/19 6/15 16/17 18/25
127/7 138/17
structure [8] 5/25
128/4 133/23 134/6
135/25 136/24 137/18}
139/14
structured [2] 42/22
51/16
structures [4] 15/23
128/18 138/12 150/22)
studies [3] 94/11
99/14 100/20
study [3] 97/13 97/18
100/13
stuff [1] 123/1
subject [13] 9/2 18/2
34/2 61/8 65/1 66/13
73/8 88/20 101/7
101/15 101/25 116/5
156/13
submission [6] 24/13
33/5 60/7 65/22 86/12
120/12
submissions [43]
1/12 1/14 1/16 5/20
20/1 22/4 22/5 22/15
22/18 23/23 59/6 59/9)
59/13 60/4 63/19
65/24 66/11 66/19
66/20 66/22 67/2
67/10 68/23 69/12
70/20 70/21 70/24
72/6 76/11 79/11 80/2
92/11 92/14 103/25
104/17 105/3 105/5
108/25 124/7 150/20
152/13 160/11 160/20)
submit [4] 22/10
46/19 58/18 117/9
submits [5] 25/22
39/17 40/3 53/20
55/19
submitted [6] 65/19
69/16 77/2 78/18 87/9
106/1
subordinate [2]
66/15 67/18
subpostmaster [4]
29/10 35/20 40/19
41/2
subpostmasters [21]
27/16 29/4 31/14 32/2
36/22 40/18 53/7 57/4,
57/15 58/20 59/19
59/24 60/2 64/25
70/14 71/8 72/20 78/1
78/4 78/9 102/19
subpostmasters'’ [4]
29/14 31/23 58/5
61/20
subsequent [2]
93/16 114/4
subsequently [2]
50/25 52/7
subsidy [1] 16/21
substance [4] 6/20
6/24 42/10 44/2
substantial [6] 13/8
14/20 23/16 29/15
61/8 147/25
substantive [2] 34/15)
106/12
success [2] 24/6
133/2
successful [1]
133/20
successfully [1]
27/113
succession [1] 15/1
successive [1] 47/18
successor [1] 44/4
successors [1]
142/15
such [21] 4/23 20/10
24/24 36/25 52/11
64/11 64/21 67/19
68/14 69/6 71/4 73/4
73/17 132/20 134/22
137/15 138/4 142/17
145/17 157/10 160/16}
suffering [3] 1/20
60/2 78/9
suffices [1] 118/17
sufficient [2] 5/12
5/15
sufficiently [2] 5/16
7115
suggest [15] 24/13
24/22 36/16 51/14
92/14 110/9 114/5
124/11 141/22 146/10}
146/17 146/22 149/10)
149/23 152/7
suggested [10] 44/8
46/23 69/7 74/1 118/2
149/8 149/16 149/17
154/4 154/21
suggestion [5] 51/7
66/4 66/8 76/18 76/21
suggestions [4]
121/14 145/18 145/20)
154/11
suggestive [1] 103/4
suggests [2] 70/15
105/24
suicide [1] 125/5
suite [1] 65/12
sum [3] 19/20 155/6
159/17
summaries [4] 49/24
50/18 50/22 51/21
summarise [3] 7/24
56/1 134/8
summarised [3]
44/16 45/19 68/23
summary [8] 44/2
51/17 73/11 84/10
118/5 142/10 142/11
142/13
sums [1] 155/17
superficial [1]
125/24
supplement [1] 59/8
suppliers [1] 62/16
supply [1] 145/18
support [37] 7/12
8/21 10/7 10/24 11/2
41/17 12/5 12/24
14/12 24/18 36/13
56/7 56/13 56/17
56/21 65/12 65/15
66/4 66/6 66/7 68/3
69/10 71/2 71/7 71/20}
71/22 71/24 72/5 72/8I
73/4 91/16 91/20
105/22 125/16 131/25)
136/5 158/17
supported [3] 26/24
62/15 79/3
supporting [4] 22/22
61/1 77/22 89/13
supports [2] 42/19
158/3
suppose [1] 66/2
supposed [1] 106/23
sure [3] 10/2 42/5
65/19
surface [1] 140/19
surfaced [1] 54/25
surprise [1] 54/20
(68) speed... - surprise
s
surprised [2] 55/14
76/21
surprising [4] 64/12
80/10 131/13 149/24
survey [4] 13/17
13/17 13/18 20/14
Susan [2] 7/15 38/9
susceptibility [1]
149/14
suspect [2] 51/9
79/11
suspended [1] 35/20
sustainable [2] 17/24)
96/24
sustaining [1] 16/20
swaps [1] 124/11
Swift [1] 142/13
swiftly [1] 103/10
Swinson [7] 23/3
23/6 23/9 142/3 143/1
147/6 149/16
symptomatic [2]
122/24 130/7
symptoms [1] 147/1
system [98] 9/1 10/7
12/10 24/20 27/11
27/25 30/14 31/9
31/22 32/11 32/12
35/1 35/3 35/4 36/15
36/17 37/23 38/18
38/20 39/24 40/8
40/21 41/7 41/12
41/21 42/4 43/13
56/16 56/20 61/11
61/17 61/23 62/3 62/7
62/17 63/13 65/13
65/21 67/23 68/7
68/17 68/19 68/20
69/9 69/18 69/25 70/3,
70/9 70/10 74/7 75/7
75/9 75/12 75/17 77/4
77/7 77/11 77/16
77/16 77/19 87/14
91/23 92/9 97/25
105/1 105/10 105/17
106/4 106/24 107/5
107/6 107/10 107/12
108/12 111/24 112/2
116/1 116/11 120/15
120/19 120/21 120/22)
121/21 121/24 126/21
126/24 128/17 129/11
129/22 130/15 131/3
131/24 136/22 138/3
138/23 140/5 151/6
156/21
system's [2] 27/22
33/12
system-wide [2] 35/3
38/20
systemic [9] 35/14
36/7 37/21 38/3 38/17
38/20 39/10 39/15
141/15,
systems [8] 5/2
31/21 35/18 41/19
60/6 62/11 62/24
133/24
T
tactical [2] 74/4
74/13
tainted [1] 50/5
take [17] 1/17 4/18
20/20 21/10 21/11
21/12 21/16 37/2
47/15 52/3 79/17
94/19 96/18 139/13
148/15 159/20 160/21
taken [20] 4/12 5/10
8/8 9/2 9/18 10/3 15/7
15/9 15/13 31/3 33/16
52/13 56/1 78/15
85/24 86/1 86/2
114/25 116/9 157/7
takes [4] 13/22 13/23
13/25 157/11
taking [5] 25/8 46/3
89/16 112/12 139/9
talk [1] 14/8
tamper [1] 32/4
tarnished [1] 109/18
task [4] 25/10
tasked [2] 34/10 69/1
Tatford [8] 96/9
109/9 109/13 109/15
110/18 111/4 111/12
122/12
Tatford's [3] 85/18
108/21 110/6
team [29] 6/22 16/8
18/20 25/21 25/25
26/22 26/22 29/8
29/18 39/15 40/4 52/9
54/10 55/13 57/19
58/4 81/13 91/16
120/23 136/9 136/10
136/14 139/22 139/25)
141/23 149/18 150/15)
160/23 160/25
teams [8] 9/14 20/17
34/18 34/25 64/1 69/1
125/17 136/6
tech [1] 133/20
technical [19] 25/18
40/16 60/13 61/7 66/6
67/23 68/22 71/5 72/2
77/9 78/8 85/12 89/9
89/14 89/14 112/23
115/22 131/10 131/16)
technically [3] 66/17
130/13 130/19
technician's [2]
113/2 123/19
technicians [2]
105/13 106/23
technological [3]
19/1 78/24 91/25
technology [4] 5/15
11/20 27/15 89/10
teeth [1] 151/18
tell [8] 82/7 82/11
83/1 83/10 83/12
103/8 109/3 138/5
telling [1] 22/1
tellingly [1] 66/18
tells [14] 117/22
tended [1] 149/23
tendency [1] 153/23
term [5] 15/2 17/3
105/1 106/5 106/5
terms [8] 3/5 35/4
85/19 89/13 91/23
115/17 118/10 119/2
terrible [1] 19/11
terribly [1] 104/4
test [5] 26/16 87/14
111/23 133/19 154/3
tested [2] 27/4 27/22
tester [1] 42/1
testimony [2] 3/24
126/8
testing [4] 41/19
41/21 42/4 69/1
text [1] 32/15
than [32] 2/6 6/25
8/14 21/13 24/1 24/3
30/4 37/18 51/15
54/18 60/23 60/25
61/3 66/5 70/17 72/4
77/11 78/14 85/1
95/13 107/4 107/6
110/11 122/15 130/3
139/7 140/21 144/2
154/1 155/22 161/4
161/8
thank [18] 20/15 21/8}
21/17 22/5 58/24 79/8
79/9 79/21 80/3 99/11
123/23 123/24 160/3
160/15 160/17 160/21
160/23 161/10
thanks [2] 20/11 59/7
that [949]
that's [10] 49/13
49/13 66/22 71/11
79/15 95/12 115/18
133/10 149/22 161/8
theft [2] 32/19 123/3
their [75] 1/21 2/19
3/20 10/13 11/2 11/17
13/24 17/15 17/23
20/17 28/16 29/17
29/21 38/23 39/23
40/6 40/11 43/14
44/23 45/2 47/5 47/10
50/12 50/16 50/19
53/23 56/25 58/5
59/19 59/25 60/3
63/22 65/16 71/15
78/1 78/4 78/10 80/15
82/21 94/10 100/8
102/12 103/1 104/17
105/25 109/11 118/12)
125/21 128/10 131/15)
135/21 137/11 137/12}
137/17 137/20 137/21
138/19 142/24 143/6
143/19 143/24 144/19
144/20 144/21 147/14]
147/15 148/24 148/24}
152/9 152/24 154/11
154/23 156/8 159/3
160/18
theirs [1] 104/20
them [38] 9/14 19/11
22/20 37/8 45/18 58/6
58/8 79/13 79/14
79/16 80/12 84/13
87/13 87/15 91/2 94/6
100/12 102/16 102/20}
103/9 105/19 106/3
106/13 108/3 112/4
114/19 123/7 135/12
135/17 137/13 137/19}
137/20 139/14 140/22}
142/24 144/3 160/12
160/20
theme [3] 75/15
147/11 147/13
themes [3] 5/18 49/9
153/6
themselves [4] 23/1
105/16 137/18 144/8
then [22] 6/22 20/9
21/12 21/19 26/5 26/6)
29/1 33/14 37/5 49/16
76/5 81/2 81/6 84/12
94/14 100/16 108/14
114/20 120/11 131/23}
137/19 140/5
theoretical [2] 63/9
104/11
theories [1] 120/2
there [112] 5/20 5/24
6/9 6/13 6/19 10/18
10/20 12/23 14/10
14/18 17/21 19/10
19/22 22/22 27/4
27/14 27/25 28/1
29/16 29/25 30/14
31/18 32/3 35/10
36/16 36/23 37/4 38/3
40/12 41/19 41/24
41/24 42/3 49/5 51/7
51/9 53/1 53/5 53/18
54/9 56/16 58/18
61/16 66/2 66/3 66/7
67/5 69/9 75/18 76/18)
81/9 81/16 81/25
82/14 84/21 85/20
87/4 87/10 87/13
88/17 89/2 89/22 90/9
95/9 96/4 100/25
104/9 109/11 110/4
110/21 110/24 111/6
112/12 113/16 113/20)
113/22 113/24 114/20)
1417/1 120/8 120/9
121/2 121/10 121/23
122/19 123/11 129/15)
132/21 134/25 135/21
137/1 138/19 138/21
141/5 1414/7 141/7
141/9 142/1 142/6
142/7 144/24 145/6
148/5 148/23 153/11
154/24 156/6 157/24
157/25 158/10 160/7
160/7
there'd [1] 141/8
there's [9] 21/25 37/3}
77/18 114/3 114/4
152/22 153/23 154/3
160/8
thereabouts [1]
21/11
thereafter [1] 136/16
thereby [2] 16/11
150/18
therefore [6] 38/13
41/24 50/23 63/6
127/6 150/5
these [46] 11/7 11/10
13/19 19/11 29/17
34/17 38/1 40/14
43/14 45/17 53/24
61/9 61/13 62/24
66/19 73/21 76/24
78/23 81/4 82/2 89/19
91/22 94/5 96/6 96/25
97/11 98/1 99/18
101/14 105/10 105/24}
107/24 108/4 115/7
118/5 128/9 131/12
132/3 133/8 136/24
141/23 141/25 144/18)
147/5 155/11 155/17
they [96] 2/22 5/14
TIT 1119 16/12 17/23
22/2 28/8 28/15 28/17,
29/14 29/21 29/23
36/15 37/7 37/12
38/14 38/23 39/6 40/9I
41/22 42/10 45/19
49/2 49/25 62/25 64/9)
65/15 84/23 85/10
85/11 88/8 91/1 94/1
95/25 96/7 97/21 99/6I
99/7 100/21 101/8
101/14 101/15 102/7
102/12 102/13 103/1
103/8 103/9 103/22
105/12 105/16 105/20}
106/8 106/23 107/3
107/4 107/5 107/17
107/19 109/9 109/24
1411/7 115/23 118/6
(69) surprised - they
T
they... [31] 119/7
119/8 119/9 125/9
126/1 131/2 131/4
131/6 135/12 135/13
135/15 135/20 135/22)
136/7 137/15 143/6
143/8 143/14 143/16
143/19 143/22 144/1
144/13 145/4 148/4
148/7 148/15 148/16
150/4 151/1 155/11
they'd [2] 69/8
130/25
they've [1] 1/10
thin [1] 68/11
thing [1] 56/3
things [12] 49/16
62/5 81/25 82/3 89/10
89/14 91/1 108/17
108/22 133/9 133/13
155/11
think [14] 1/8 21/12
21/24 30/25 80/1
91/23 94/11 98/21
115/15 119/9 124/1
124/14 133/15 144/1
thinking [1] 109/16
third [15] 11/19 40/8
44/22 49/17 62/11
62/16 66/14 83/25
96/13 96/16 97/14
100/5 100/7 149/10
154/8
third-party [3] 62/11
62/16 100/5
this [251]
Thomas [8] 105/12
105/13 105/19 105/21
106/7 107/23 108/2
159/2
Thomas' [10] 91/16
92/22 94/12 105/1
105/4 107/1 108/5
108/9 120/16 120/19
Thornton [5] 14/21
15/4 15/8 18/10 158/9)
Thornton's [1] 14/23
thorough [2] 20/17
78/6
thoroughly [1]
126/23
those [66] 1/15 2/1
2/1 3/13 3/14 3/23
4/17 5/14 5/17 5/20
6/13 11/24 13/5 13/12
16/17 19/7 35/4 50/12)
56/24 57/5 57/9 59/13,
59/21 59/23 60/8
61/18 63/14 68/24
69/10 69/12 70/17
70/23 71/22 71/24
72/5 72/10 73/22
74/12 75/1 78/10
78/16 90/7 91/8 95/25)
98/12 99/4 99/12
101/8 108/22 113/7
1417/8 117/17 119/5
120/12 120/17 125/4
125/11 125/25 134/7
141/21 151/13 152/25)
154/18 159/14 160/10)
160/17
though [11] 1/9 31/5
35/19 44/13 87/2
92/12 102/8 133/10
134/3 143/18 143/22
thought [16] 64/12
90/2 94/18 108/4
108/5 109/18 109/24
109/25 110/2 112/4
113/16 113/20 115/12)
119/9 122/2 135/16
thousands [2] 3/25
56/23
three [8] 10/21 45/10
76/6 91/11 91/11
108/17 108/22 129/18)
three-way [1] 129/18
through [26] 10/25
11/22 16/8 17/14
17/18 40/4 42/21
43/10 44/9 53/11 79/4
85/24 86/1 105/4
106/18 109/1 131/9
134/13 136/7 136/21
137/23 139/14 148/13)
151/19 156/1 160/19
throughout [11] 6/1
51/23 58/15 58/16
60/25 61/21 65/10
68/25 85/20 109/18
160/1
thrown [1] 125/4
thrust [1] 56/5
tier [3] 10/21 137/8
140/18
tiers [6] 136/8 136/22
137/13 138/1 139/5
139/8
Tim [2] 142/10
142/14
time [46] 13/25 21/18
22/13 23/7 25/8 27/17
31/11 38/3 40/1 44/8
47/13 48/8 50/14 54/6
65/7 67/25 75/20
92/15 92/15 92/18
93/18 93/19 93/21
93/21 103/17 104/4
108/22 118/14 119/18)
119/24 130/12 130/23)
132/16 132/19 134/20)
137/21 138/7 140/12
143/4 143/11 143/12
143/21 148/5 153/5
157/11 158/16
timekeeper [1]
119/20
timely [1] 138/6
times [11] 68/12
68/25 92/18 105/23
138/24 143/2 146/17
149/7 149/13 150/16
154/24
timetable [1] 114/11
tiny [1] 144/10
today [7] 2/11 22/13
57/23 62/13 70/24
118/18 156/15
together [5] 16/5
32/8 34/5 58/12 157/6
told [50] 27/9 31/7
31/16 31/19 31/19
32/3 33/22 36/1 36/18
36/19 37/5 37/11
37/20 38/14 39/14
39/18 40/3 40/14
40/20 42/14 45/6 45/8
46/8 46/11 47/3 48/17
54/7 56/15 57/24 80/7
83/2 84/9 84/19 87/11
87/13 87/15 98/1
108/19 112/4 112/22
116/22 116/23 117/5
117/15 118/5 140/22
142/17 143/12 144/17!
148/4
tolerated [1] 146/12
tone [3] 52/6 52/11
158/5
too [6] 8/10 145/11
146/19 146/20 152/23
156/9
took [9] 4/21 42/2
52/16 55/8 56/18
79/18 86/20 123/19
132/24
tools [2] 65/12
123/16
top [4] 24/23 69/17
135/24 158/5
topic [2] 55/7 98/14
topics [1] 22/19
total [3] 17/13 92/1
144/10
totality [1] 39/5
totally [1] 144/1
touched [1] 78/16
tough [1] 54/18
towards [7] 8/17
14/14 15/2 77/7 123/6
135/24 158/4
trace [2] 113/25
114/7
tracking [1] 120/23
Tracy [2] 10/8 11/21
Trade [2] 124/9
124/21
tragedy [1] 128/13
tragic [1] 125/5
tragically [2] 78/2
152/25
trail [2] 114/1 114/7
training [18] 7/11
11/1 12/5 12/24 13/7
13/8 13/10 56/7 56/13}
56/17 56/21 91/17
91/17 94/21 125/24
141/7 150/4 150/9
transaction [3] 10/20
26/17 54/5
transactions [9]
27/13 30/21 41/12
57/2 92/23 108/1
108/10 111/8 121/12
transform [1] 19/5
transformation [6]
18/20 18/25 128/23
147/12 156/25 157/9
transparent [1] 40/18)
transposed [1] 33/14
trashed [1] 125/1
Treasury [1] 155/14
treat [2] 96/17 135/9
treated [5] 88/8
96/15 97/1 97/20
109/14
treating [1] 98/25
treatment [2] 7/10
7/18
trends [1] 49/9
trial [9] 52/7 81/21
110/4 113/13 118/19
118/23 119/25 122/18}
1341/5
trials [1] 8/4
tribute [1] 160/9
trickle [1] 144/9
true [1] 58/12
truly [1] 124/24
trust [11] 8/12 12/22
13/1 13/4 14/6 25/13
93/25 94/1 128/19
135/14 138/4
trusted [4] 33/2
46/24 57/19 159/20
trusts [1] 58/11
trustworthy [1]
159/20
truth [7] 57/11 84/18
126/19 138/5 139/19
140/10 146/12
truthful [4] 137/23
137/25 140/7 150/24
truths [2] 83/20
126/4
try [2] 57/10 119/5
trying [3] 118/23
124/18 143/22
Tuesday [1] 1/1
turn [16] 5/9 6/17
23/20 24/11 61/14
102/4 108/14 114/20
116/4 118/18 128/16
128/24 133/23 137/8
146/1 152/17
turned [1] 116/4
turning [4] 30/6
39/19 42/11 43/19
twice [1] 28/6
two [29] 3/9 9/8 9/13
23/3 26/11 28/5 29/14
29/19 36/11 36/12
36/14 37/24 38/7
39/25 40/25 41/3
44/20 46/7 54/16
76/16 84/21 87/4
110/4 128/21 137/1
148/20 149/7 149/11
149/12
two-hatted [5]
128/21 148/20 149/7
149/11 149/12
type [2] 92/1 154/6
types [1] 65/7
typical [1] 136/1
typing [1] 108/7
Uo
UCL [1] 133/18
UKGI [26] 127/9
127/16 128/5 135/8
136/16 136/17 137/6
137/9 138/8 139/1
139/24 140/3 140/17
142/24 144/17 144/24)
144/25 147/13 147/19)
147/24 148/6 148/22
149/20 150/6 150/19
157/6
UKGI's [4] 128/20
147/21 148/3 158/19
ultimate [3] 13/22
127/12 128/6
ultimately [8] 19/2
85/18 95/12 126/18
127/1 127/14 136/9
155/3
unable [1] 143/17
unambiguous [2]
27/20 41/8
unauthorised [3]
30/19 30/20 31/17
unaware [2] 90/1
94/21
unblemished [1]
72/24
uncertainty [1]
132/21
unchecked [2] 3/20
125/23
unclear [3] 50/7
115/11 130/19
unconnected [1]
115/14
uncooperative [1]
76/20
uncover [1] 57/11
(70) they... - uncover
U
uncovered [2]
112/19 139/23
uncritically [1] 24/16
under [8] 8/19 11/11
15/21 52/23 100/9
108/18 157/22 158/1
underlying [2] 40/16
129/13
undermined [3]
70/22 111/21 130/7
underpin [1] 16/24
underpinning [1]
14/13
understand [13] 3/5
29/22 33/19 36/6
50/21 53/16 60/17
99/7 99/20 101/14
103/3 107/11 143/24
understandable [3]
56/18 129/14 149/22
understandably [1]
147/16
understanding [11]
4/11 5/13 6/5 31/25
38/4 39/19 102/17
107/1 107/9 120/16
148/14
understands [2] 57/3
57/8
understated [1]
119/2
understood [16]
31/11 39/3 39/9 47/24
99/24 101/4 102/16
103/22 105/8 105/15
105/16 105/20 115/23
117/20 135/15 147/17
undertake [4] 97/3
98/11 118/9 122/1
undertaken [1]
101/20
undiscovered [1]
75/10
uneducated [1] 99/4
unequipped [1]
93/21
unequivocal [2] 33/6
63/22
unequivocally [1]
128/3
unfair [1] 96/25
unfairly [1] 64/15
unfairness [1] 98/24
unhappy [1] 135/13
uniformly [1] 63/1
unifying [2] 14/24
15/3
uninstructed [1] 99/3
unintelligent [1]
146/18
unions [1] 141/6
unit [3] 72/22 72/23
138/25
unitary [1] 139/9
United [1] 62/13
universal [1] 134/25
universally [1] 129/8
unknown [3] 63/14
75/10 75/22
unless [1] 121/2
unlikely [1] 31/10
unrealised [1] 125/2
unrealistic [1] 144/1
unresolved [3] 63/14
75/11 156/2
Unrestricted [1]
30/18
unsafe [5] 43/10
46/15 47/24 53/19
142/7
unstructured [1]
44/14
unsubstantiated [1]
141/20
unsupported [1]
66/20
unsurprising [1]
66/22
unsurprisingly [1]
68/21
unsustainable [1]
120/13
untenable [1] 50/6
unthinkable [1]
106/19
until [19] 9/10 19/9
21/19 23/18 26/2
28/13 45/2 45/5 58/25
65/8 82/22 91/1 92/24
93/7 93/14 109/13
127/4 132/3 136/12
untouchables [1]
157/17
untrained [1] 93/22
untrue [2] 141/12
141/25
untruthful [1] 141/1
untruths [1] 126/3
unused [4] 100/11
100/16 102/10 111/9
unusual [2] 101/18
120/2
unvarnished [2]
25/14 142/25
unwilling [2] 143/15
143/17
unwillingness [1]
120/25
up [22] 1/17 11/8
28/5 36/20 88/16 89/2
103/8 108/7 118/18
119/17 121/1 126/7
131/6 136/8 137/23
140/7 145/24 151/20
153/8 153/14 154/11
155/5
update [5] 7/15 19/25]
35/24 44/17 53/12
updates [5] 20/2 20/4
20/8 34/20 156/19
upon [14] 23/9 43/18
59/14 63/16 69/3
80/12 81/10 85/10
86/12 91/7 92/8 101/2
113/19 147/17
upwards [2] 5/9 14/5
urges [1] 159/14
us [4] 22/13 43/9
54/19 137/16
use [25] 11/3 32/4
42/24 43/6 51/24
61/12 62/8 62/12 66/8
74/6 81/14 82/21
87/17 90/21 93/23
99/19 102/18 105/1
106/4 116/14 116/22
120/15 120/17 135/12
153/5
used [15] 1/4 2/2
13/21 31/17 33/11
46/15 66/5 73/20
83/15 87/8 90/10
96/23 117/6 118/7
120/22
user [1] 4/24
using [2] 109/9
117/14
usual [5] 68/18 85/5
119/2 144/21 154/23
usually [2] 92/2
101/19
Vv
vacuum [2] 150/22
151/1
vague [1] 69/13
value [1] 52/15
values [1] 71/20
van [4] 28/25 29/11
29/20 34/9
varied [1] 92/20
variety [1] 144/6
various [4] 22/8
62/16 65/6 138/8
variously [1] 61/21
vast [5] 3/9 68/20
80/6 116/8 144/4
vastly [1] 17/14
veneer [1] 87/2
Vennells [103] 22/7
22/16 22/22 23/2 23/4
23/11 23/15 23/18
23/25 24/12 24/15
25/3 25/5 25/16 25/22
26/6 26/25 27/17
27/24 28/12 28/16
29/6 29/22 30/22
30/25 31/5 31/10
31/15 32/3 32/22 33/1
33/13 33/15 33/18
34/1 34/11 34/19
34/23 36/18 37/16
37/17 37/20 37/22
38/1 38/8 39/9 39/14
39/17 39/20 39/25
40/1 40/14 40/20
40/24 41/9 41/16 42/7)
42/11 42/18 42/24
43/6 43/16 44/11
44/13 45/6 45/24 46/6
46/14 46/20 46/22
47/11 47/18 47/23
48/3 49/19 50/14
51/23 52/2 52/5 52/12,
52/17 53/9 53/16
53/20 54/2 54/6 54/11
54/13 54/23 55/2
55/15 55/19 55/21
56/12 56/15 57/3
57/14 57/17 58/2
58/19 58/19 58/22
142/3
Vennells' [8] 22/12
23/20 27/2 33/4 39/19)
58/15 147/8 152/11
ventriloquist [1] 82/3
verbatim [1] 43/15
verify [1] 33/21
version [1] 110/23
vertically [1] 5/24
very [26] 3/11 22/25
31/1 32/22 56/1 57/22,
67/20 82/2 85/2 88/17)
90/13 92/1 92/8 93/17
94/15 99/12 101/17
119/11 119/18 126/12)
130/19 132/24 134/8
144/11 152/20 160/22,
vested [1] 85/7
vi [1] 50/10
via [4] 13/16 17/23
65/6 144/16
viable [1] 130/13
victims [1] 152/22
view [21] 15/25 16/19]
19/15 19/19 19/22
44/8 49/5 50/4 54/8
55/8 56/1 69/15
117/11 135/7 137/5
138/22 143/6 143/16
146/15 150/11 156/4
views [6] 8/19 9/3 9/5)
9/17 10/2 159/12
visibility [1] 34/24
vision [1] 158/6
vocal [1] 131/21
vocally [1] 142/23
voice [4] 9/20 14/13
52/11 131/8
vulnerable [1] 56/22
Wo
wait [1] 156/8
waiting [1] 19/1
wake [1] 150/7
Wales [1] 160/5
want [2] 86/11
123/21
wanted [4] 23/11
58/19 91/10 99/10
Ward [3] 94/12 105/2
120/17
warehouses [1]
60/21
warmly [1] 150/6
Warwick [2] 85/18
96/9
was [498]
wasn't [27] 37/5 49/6
57/24 81/9 81/12
81/13 81/18 81/20
81/22 83/2 83/14
84/20 86/4 86/24
88/25 92/3 92/4 92/5
92/6 102/21 110/24
112/13 113/4 113/13
116/14 116/20 148/15)
waters [1] 157/24
way [37] 2/13 10/6
12/7 15/21 24/7 27/5
27/18 37/13 43/15
44/10 44/14 45/20
50/20 56/2 58/23
63/18 64/7 68/4 79/4
81/7 87/7 99/9 110/20
113/25 115/22 123/2
125/10 125/21 128/13)
129/15 129/18 133/2
135/11 143/15 150/23}
154/25 161/9
ways [2] 65/6 94/9
we [56] 22/6 22/10
22/13 22/18 23/23
24/19 24/20 24/25
25/9 27/15 27/21
32/25 35/8 35/19 36/6
36/14 36/16 36/24
37/6 37/8 37/13 38/20I
41/5 41/18 42/1 42/1
46/19 54/20 56/1
58/17 58/25 67/12
67/21 68/1 68/5 79/17
79/18 90/7 94/20
104/25 105/7 114/11
134/3 141/22 143/14
145/5 146/10 146/22
146/25 147/23 150/20)
154/22 158/22 160/7
160/7 161/10
we'll [7] 21/12 21/16
21/19 21/19 58/25
79/22 123/25
we're [4] 1/8 21/24
80/1 139/12
we've [2] 95/5 95/8
weak [1] 146/18
weakened [1] 125/3
weakness [1] 30/16
(71) uncovered - weakness
Ww
weaknesses [1] 30/9
web [1] 20/2
week [3] 9/13 52/9
133/18
Weekly [3] 26/23
27/8 27/10
weight [2] 23/8
151/25
Weir [1] 27/2
welcome [6] 56/4
133/22 145/20 152/14
156/4 156/20
welcomes [3] 18/12
19/23 150/6
well [23] 3/10 3/14
21/10 51/16 63/8
63/13 63/25 79/22
83/22 100/24 108/8
111/12 112/20 113/5
115/18 119/3 132/11
132/14 140/20 140/23}
155/12 155/23 160/6
well-researched [1]
140/20
well-worn [1] 155/12
went [5] 3/6 63/8
109/21 118/6 143/21
were [144] 3/11 4/23
5/2 5/11 5/16 6/10
7/12 14/18 26/8 26/15)
29/1 29/14 32/21
32/21 34/10 34/17
36/20 37/4 37/24 38/3
38/22 40/9 40/12
40/20 41/1 41/21
44/12 45/19 49/25
50/11 50/15 50/16
50/22 52/11 53/1
53/24 55/6 56/16
57/16 60/13 60/21
60/21 60/23 62/21
62/25 62/25 64/5 64/9
66/5 67/5 68/5 69/12
70/14 70/16 71/14
78/1 78/21 78/23 81/4
81/16 81/17 81/25
83/21 85/10 86/2
87/13 94/1 94/5 95/24
95/25 97/24 98/12
98/23 99/14 99/16
101/8 102/6 102/7
104/9 105/9 105/11
105/13 106/23 107/3
107/22 109/5 109/9
110/21 111/6 111/12
112/19 115/4 115/13
117/14 120/10 121/23)
125/25 126/1 126/12
127/9 129/7 129/14
129/15 131/12 132/4
135/9 135/12 135/12
135/20 135/22 136/3
136/7 136/10 136/19
136/25 140/9 140/25
141/5 141/7 141/19
142/7 142/17 142/22
143/5 143/6 143/8
143/14 143/15 143/17)
143/22 144/20 144/24)
146/7 146/8 147/5
147/9 147/24 149/25
150/4 150/22 154/5
155/6 155/11 155/11
weren't [3] 36/23
36/24 130/24
West [1] 122/25
what [94] 3/2 3/3 3/6
3/7 18/5 18/24 21/6
21/6 22/7 22/8 24/25
24/25 29/24 31/5
33/14 33/21 34/13
36/18 37/2 37/20
38/14 39/18 40/2
40/22 43/5 47/16
47/21 49/13 51/17
52/24 52/24 54/7 57/6)
57/23 60/17 64/9 69/3
73/22 83/6 83/16
83/19 84/8 84/18 86/9
86/21 88/2 88/5 94/5
96/1 96/2 97/10 97/24
98/1 101/8 101/22
102/10 102/24 104/14)
105/20 108/3 108/15
109/5 109/6 109/10
109/15 110/13 110/15)
110/18 111/14 112/4
117/4 117/17 117/19
117/23 118/7 118/8
119/1 119/6 119/7
119/12 120/11 122/2
123/8 123/13 130/25
135/13 140/22 143/12)
146/7 148/14 148/14
148/15 148/17 161/1
what's [2] 21/18
130/25
whatever [1] 103/5
whatsoever [2] 76/18
91/17
wheel [1] 153/16
when [40] 1/10 6/8
19/20 22/20 23/5 26/2
26/22 27/7 28/17 30/2
42/24 46/14 49/11
50/23 54/12 58/25
67/9 77/12 81/14
83/14 88/23 89/5 99/3
99/6 102/7 103/9
104/2 105/12 107/25
109/22 110/7 111/5
114/2 117/13 129/23
131/23 139/11 143/2
158/25 161/2
whenever [1] 135/15
where [13] 10/16
15/8 56/15 60/6 76/11
81/18 100/21 107/3
118/20 133/13 137/20
139/24 140/25
wherever [1] 128/3
whether [18] 19/3
19/4 34/24 37/4 40/12
44/6 48/25 49/11 50/7
55/10 64/9 75/18
111/6 121/10 122/23
123/2 127/7 132/18
which [202]
while [5] 44/4 56/20
64/14 64/16 143/9
whilst [9] 19/1 57/11
62/23 65/25 128/8
133/1 153/17 154/20
157/11
whitewash [1] 36/10
Whittam [4] 59/1
59/5 59/6 79/9
who [42] 1/24 2/2 2/4
3/11 4/6 5/12 9/12
18/20 20/12 20/24
29/15 41/11 42/1 51/5)
53/18 64/5 67/22 68/1
68/15 71/22 71/25
78/1 80/24 81/10
81/15 81/16 82/17
90/25 91/8 94/2 96/7
98/18 111/16 122/7
126/12 136/23 140/3
152/8 152/25 160/10
160/15 160/17
whole [6] 13/2 17/4
39/2 131/18 148/12
155/1
wholesale [1] 15/21
wholly [3] 111/21
115/11 115/13
whom [7] 19/7 25/6
47/17 57/19 57/19
63/21 94/8
whose [3] 25/20
99/12 140/17
why [31] 25/3 25/12
29/22 30/2 31/19
33/19 47/12 56/18
57/25 58/2 58/10
58/13 64/22 73/24
82/24 83/1 85/8 86/5
88/8 94/18 102/21
109/22 112/13 115/12]
120/17 145/17 146/4
146/7 147/20 151/14
159/10
wide [7] 12/3 35/3
38/20 70/21 137/10
144/6 159/5
wider [2] 36/13 40/22
widespread [3] 2/6
5/4 36/17
wilfully [1] 46/22
will [67] 1/17 2/10
2/17 2/24 3/1 3/16 8/6
8/18 9/9 9/19 9/24
11/10 11/13 11/17
14/10 16/4 16/5 16/10)
17/2 17/13 17/17
18/15 19/4 20/9 20/18}
20/20 21/5 23/1 35/9
35/10 36/4 42/6 57/9
58/12 58/22 58/25
61/24 64/13 65/1
69/20 74/17 74/20
74/23 83/6 96/9 98/13
119/20 128/13 132/17I
145/16 145/18 146/15)
152/14 154/16 156/9
156/20 157/24 158/15)
158/18 159/12 159/24}
160/1 160/13 161/2
161/3 161/4 161/10
Williams [1] 43/23
willing [4] 73/3 89/5
122/1 123/12
willingness [4] 41/25
89/3 90/3 104/25
Winn [1] 28/25
wish [2] 105/4
132/17
wishes [4] 20/15
77/23 128/2 159/4
withheld [2] 48/5
98/4
withhold [2] 89/23
111/20
withholding [2]
54/19 87/7
within [26] 4/18 5/16
5/24 11/6 12/25 38/17,
53/19 61/17 63/8
63/20 64/19 69/17
72/16 75/22 81/13
102/25 112/4 113/6
115/13 127/5 127/20
128/3 137/11 139/25
150/12 153/12
without [17] 22/22
29/3 29/9 29/13 31/11
31/14 32/1 65/17
69/18 75/12 85/24
99/24 104/13 123/16
157/14 160/12 161/7
withstand [1] 23/8
witness [46] 26/19
42/3 44/24 46/10
46/16 47/24 48/17
48/23 50/5 55/9 55/11
55/16 71/25 74/25
80/9 80/13 80/23
81/11 82/6 83/2 83/3
84/14 85/12 85/15
86/9 86/15 90/13 91/3
91/18 92/4 92/12
94/23 97/2 97/6 98/21
98/22 99/3 100/15
101/12 104/3 104/6
109/15 116/4 119/4
119/4 122/13
witnesses [22] 3/11
3/24 4/6 22/21 23/1
55/4 61/4 62/2 64/7
69/7 81/9 90/25 120/2I
120/3 120/4 129/2
135/1 136/23 137/7
138/8 139/4 153/9
woefully [1] 98/7
Wolstenholme [1]
142/20
Womble [1] 87/20
won [1] 33/10
won't [3] 22/2 105/3
153/5
Woodley [1] 76/14
word [2] 1/3 46/7
wording [1] 27/1
words [19] 8/14
31/24 43/14 66/7
75/24 80/21 85/21
96/18 99/23 100/10
106/12 107/2 108/21
109/17 112/6 114/25
115/9 120/18 133/24
work [35] 2/2 2/20
8/2 8/11 9/19 9/22
12/2 13/1 16/5 18/6
18/8 18/10 38/13 39/5}
46/2 47/10 54/5 61/2
64/7 71/3 71/5 78/7
79/4 94/19 97/3 99/12I
101/24 102/13 131/3
137/13 140/3 142/15
149/22 156/7 156/10
worked [3] 11/22
116/1 152/20
Workflow [1] 52/24
working [17] 13/12
13/24 34/3 34/12 38/6I
58/4 58/7 62/2 63/25
92/9 106/24 124/16
131/7 131/17 131/19
138/25 158/11
workings [2] 4/2
143/1
workstations [1]
107/3
world [4] 72/23 91/13
93/21 123/15
worn [1] 155/12
worry [1] 28/2
worse [1] 110/19
worsen [1] 16/18
worst [2] 23/11
140/11
worth [1] 159/18
would [77] 1/22
16/24 20/3 20/5 20/7
20/11 21/15 25/11
26/17 27/15 29/23
31/11 33/20 34/13
37/13 37/23 39/2 43/2
(72) weaknesses - would
Ww
would... [59] 43/3
43/5 43/9 51/21 55/12)
67/13 68/18 79/10
79/12 79/14 79/16
82/1 87/23 90/11
90/17 93/22 95/8
95/14 96/24 96/25
97/6 97/14 99/1 99/5
100/17 103/21 103/23)
104/2 104/6 104/11
105/15 105/16 106/21
108/2 108/11 112/5
113/14 113/15 113/18)
116/20 117/6 118/9
120/8 130/20 131/3
133/21 141/21 144/7
145/10 145/19 148/11
148/11 148/13 150/16
156/4 156/18 156/19
160/15 160/17
wouldn't [2] 104/3
108/12
write [1] 76/16
writing [4] 44/1 50/25)
78/11 142/4
written [53] 1/13 4/20)
5/20 6/3 7/25 11/21
12/6 14/17 20/1 20/4
20/8 22/5 22/14 22/18
23/22 29/25 34/20
39/8 45/10 58/15 59/9)
59/11 60/4 61/4 63/19
66/10 66/20 67/10
69/22 70/20 72/6
73/10 76/10 78/14
92/14 95/4 95/19
95/21 103/25 104/17
105/3 108/24 129/2
129/4 145/5 146/22
146/25 150/20 151/21
153/3 154/23 156/16
160/10
wrong [10] 3/6 27/25
49/17 60/7 94/6 133/1
133/9 133/14 135/9
148/14
wrongdoing [1]
74/22
wrongful [3] 7/21
57/5 59/17
wrongfully [1] 70/14
wrongly [2] 35/20
66/13
wrongs [2] 8/6 13/15
wrote [4] 42/19 43/7
54/16 105/22
Wylie [2] 87/16
113/22
Wylie's [1] 123/9
Yo
year [5] 30/8 35/13
76/5 153/11 159/12
years [16] 3/2 3/9 4/4
4/8 16/14 21/6 37/25
60/25 63/11 91/15
92/9 103/24 122/4
131/22 133/9 141/19
yes [9] 1/7 21/14
49/16 79/12 79/20
89/7 95/17 121/11
124/18
yesterday [4] 49/20
57/7 88/15 134/2
yet [4] 1/9 37/7 98/2
112/12
you [72] 1/8 1/10
1/10 21/8 21/9 21/13
21/17 22/3 22/5 49/14
49/16 54/20 57/21
58/11 58/24 59/7
59/10 66/18 67/13
79/8 79/9 79/10 79/12
79/16 79/21 80/3 83/4
83/6 89/17 91/4 91/9
94/11 94/12 95/8
95/15 96/7 97/22
98/14 98/21 101/13
103/5 103/8 106/25
106/25 107/11 110/12)
115/15 116/25 118/17)
119/1 119/16 119/22
119/24 122/6 123/23
123/24 124/16 138/19)
139/11 139/12 139/16)
145/22 148/17 148/18)
148/18 148/18 148/19)
156/19 160/3 160/14
160/21 161/10
you'd [1] 21/14
you'll [7] 65/19 66/24
103/14 110/18 129/1
141/2 152/11
you're [7] 21/9 21/11
83/3 97/22 119/15
139/15 161/8
you've [1] 115/19
YouGov [2] 20/14
157/15
Young [12] 25/14
25/19 26/3 26/6 26/11
26/24 28/9 28/15
28/18 30/6 32/5 32/15
Young's [2] 27/6
31/20
your [14] 58/12 58/23)
79/11 83/6 89/17
117/1 119/20 124/10
139/17 160/22 161/41
yourself [1] 1/11
zero [3] 92/22 108/1
108/10
(73) would... - zero