POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Re: Seema Misra
4" Interim Technical expert’s report to the Court prepared by
Charles Alastair McLachlan, a Director of Amsphere Consulting
Ltd.
90 Fenchurch Street
London EC3M 4BY
England
This report contains 10 pages
POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Contents
1 REVIEW OF EVIDENCE AVAILABLE AS OF 12™ FEBRUARY 2010....1
2 APPENDIX 1 — INSTRUCTIONS ETC..........cessssssssssessesessesessseesseseseanes 5
3 APPENDIX 2 - MY DUTIES TO THE COURT.........:essssssssesssesssssseeeeeseees 7
Charles McLachlan
1
POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
1 Review of evidence available as of 12" February 2010
Introduction
This report has been updated to reflect the witness statements provided by Gareth
Jenkins and the telephone interview conducted with him on 12° February 2010.
Gareth Jenkins was asked to comment on the West Byfleet and the requests in
st
relation to Callender Place, Falkirk for the first time in the week commencing I
February 2010.
1.1 Hypothesis: The User Interface gives rise to incorrect data entry
1.1.1. Source of problem — training and support: full and complete training
materials and training records have yet to be provided. In addition a log
of calls and response to the NBSC would provide further evidence as to the
understanding of the users at the West Byfleet branch.
Additionally: Gareth Jenkins during a telephone interview conducted on 12
February confirmed his response in the witness statement dated 2" February
relating to my 2™ interim report at 2.1.3.10 “It is the responsibility of the clerk
to ensure that the Debit Card payment was successfully authorised by the MA
and to check the response received. Should they not do so and assume it was
processed and touch “Fast Cash” to clear the basket without looking at the
screen, then indeed the system might record a Cash Transaction. (bold
added).
1.1.2 Source of problem — user interface: there has not been an opportunity to
conduct a usability review to date; in addition, the logs included in Andy Dunk
2™! witness statement refer to problems with the touch screen which require
the screen to be calibrated. It has not been possible to test whether this
could give rise to incorrectly captured user actions.
Additionally: Gareth Jenkins during a telephone interview conducted on 12"
February confirmed that if the touch screen requires calibration it is possible
that the user could touch the screen to activate one button and a different
button would be activated. Gareth Jenkins asserted that the size of the buttons
makes such an event unlikely.
1.2 Hypothesis: The Horizon system fails to properly process transactions
Charles McLachlan
1
POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
1.2.1 Source of problem — End to end EPOSS transaction flow: the equipment
failure user guide provided identifies at subsection 14 a process for identifying
lost EPOSS transactions. The implication is that EPOSS transactions can be
lost due to equipment failures. Without access to the sub post office data
records and the intermediate data records in the end to end process it will
not be possible to identify the extent to which this may explain the accounting
discrepancies.
Additionally: Gareth Jenkins, during a telephone interview conducted on 12"
February confirmed: that copies for the sub post office data records are
maintained by means of an message audit log for 7 years in the Fujitsu data
archive; that no request has been received by Fujitsu for any of the records
relating to West Byfleet; that such requests are routine and a Fujitsu employee
is engaged full-time in servicing such requests; that Fujitsu have an established
process for delivering the messages in the audit log into a readily interpretable
form accessible in an Excel spreadsheet. Further, Gareth Jenkins explained that
Fujitsu use an ORACLE database to load the messages and output both
consolidated branch data at the stock item level and raw data at the transaction
level that is sent to the Post Office Limited SAP accounting system and MIS
systems respectively. He explained that one of the functions of the SAP system
is to identify transaction errors. Gareth Jenkins advised that the Post Office
Product Branch Accounting department would be best placed to comment on
transaction corrections and ‘rems’ (remittances of stock to or from branches).
1.2.2 Source of problem — Poor integration: the helpdesk reports provided in Andy
Dunks 2™ statement identify a series of problems with the network, printer
and the pin terminal. It has not been possible to test whether this could give
rise to inconsistent data capture and transmission at the sub post office.
Additionally: Gareth Jenkins confirmed, in a telephone interview conducted
on 12" February, that if the printer failed to produce a readable document
because of ink or cylinder problems, then branch terminal would consider the
document to have been printed and if the operator acknowledged the printing
without examining the receipt then it was possible that the receipt could be a
“decline” or “refer” document for a card transaction which the operator then
over looked. Consistent use of the [Fast Cash] button to clear the stack
would then result in the declined card transaction being treated as a cash
Charles McLachlan
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POL00054126
POL00054126
Amsphere Confidential and Privileged
1.2.3
1.3.
On instruction of Comber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
receipt. It is noted that such problems were reported in Andy Dunks 2™
statement.
Source of problem -— systems issues causing incomplete/inconsistent
processing of transactions between sub post office and central systems: the
reports provided in Andy Dunks 2™ statement identify a number of cases in
which the user was required to ‘re-boot’ the terminal. It has not been
possible to test whether this could give rise to inconsistent data records in the
sub post office.
Additionally: Gareth Jenkins asserted, in a telephone interview conducted on
12 February, that the treatment of messages would always ensure that there
was a matching set of credit and debit transactions maintained both at the
branch and centrally. However, he pointed out that the replication between the
branch and the centre relied on a 35 day retry cycle and, in the event of a flood
or other prolonged break down in branch access, inconsistencies between the
branch records and the central records could arise and would then have to be
resolved manually. Further, he explained that the audit log archive maintained
by Fujitsu would record when a terminal ‘re-boot’ occurred and it would be
possible to determine if this had given rise to any pattern of transaction
discrepancies.
Hypothesis: Errors in operator data entry are not properly reconciled by
the Post Office finance function or by the Horizon system: without access
to the system files it is not possible to determine whether this is the case.
Source of problem — lack of reconciliation of EPOSS transactions end to end:
without access to the system data files it is not possible to determine
whether this is the case.
Additionally: Gareth Jenkins, in a telephone interview conducted on 12"
February, explained that these reconciliation processes are conducted by the
Post Office Product Branch Accounting function and the system data files
would have to be provided by this function. Fujitsu are not aware of any
request to provide this information.
1.3.2 Source of problem — lack of reconciliation of other transactions end to end:
without access to the system data files it is not possible to determine
whether this is the case.
Charles McLachlan
3
POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Comber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Additionally: Gareth Jenkins, in a telephone interview conducted on 12”
February, explained that these reconciliation processes are conducted by the
Post Office Product Branch Accounting function and the system data files
would have to be provided by this function. Fujitsu are not aware of any
request to provide this information.
Charles McLachlan
4
POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2 Appendix 1 — Instructions etc.
2.1 Instructions
2.1.1 Tam Charles Alastair McLachlan, a Director of Amsphere Consulting Limited,
London, England specialising in information technology consulting. I have
been instructed in this matter by Coomber Rich Solicitors, on behalf of their
client, Seema Misra, (“the Defendant”) to assist the court in this matter of
alleged fraudulent accounting in providing expert evidence on the questions
posed at 1.1.3 hereunder.
2.1.2 [have been instructed to review the disclosures provided in electronic format
by the prosecution up to 1* February 2010 and consider to what extent they
will enable me to provide an opinion in relation to the alternate hypotheses for
the discrepancies that have given rise to charges of fraudulent accounting.
2.2 My qualifications have been itemised in the previous two interim reports.
2.3 Confidentiality
2.3.1 This report is strictly private and confidential and has been prepared at the
request of Coomber Rich Solicitors on behalf of their client, for the Court.
2.4 Legal and factual issues
2.4.1 This report should not be read as expressing any opinion on factual matters
which depend on disputed testimony of the witnesses of fact, or legal issues.
It, however, inevitably reflects my understanding of the position.
2.5 Sources of information
Charles McLachlan
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POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Comber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
2.5.1 In preparing my report, I have considered the documents used for my previous
reports and in addition:
a. The ‘Further Disclosure Request’ submitted by the Defence
b. The responses by e-mail from Marilyn Benjamin, Royal Mail 29" January
2010
c. Horizon System User Guide - Equipment information and system failure
Version 8.0 August 1999
d. The 2™ Witness statement of Andrew Paul Dunks 29" January 2010
e. The Audit of Post Office ® West Byfleet branch, Excel Workbook
2.6 The scope of my work
2.6.1 I report as an expert witness, not as a witness of fact. I have reviewed the
documentation provided to me.
2.7 Independence
2.1.1 Ihave prepared an independent and objective report addressed to the Court. I
have had no previous involvement with the Defendant. I have no previous
involvement with Coomber Rich Solicitors.
2.1.2 Amsphere’s fees in this case are not dependent on the result of the
proceedings in this matter.
Charles McLachlan
6
POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3 Appendix 2 - My duties to the Court
3.1 IT understand that my overriding duty is to the Court, both in preparing reports
and in giving oral evidence. I have complied and will continue to comply with
that duty.
3.2 I have set out in my report what I understand from those instructing me to be
the questions in respect of which my opinions as an expert are required.
3.3. I have done my best, in preparing this report, to be accurate and complete. I
have mentioned all matters that I regard as relevant to the opinions I have
expressed. All of the matters on which I have expressed an opinion lie within
my field of expertise.
3.4 I have drawn to the attention of the Court to all matters, of which I am aware,
which might adversely affect my opinion.
3.5 Wherever I have no personal knowledge, I have indicated the source of factual
information.
3.6 I have not included anything in this report that has been suggested to me by
anyone, including the lawyers instructing me, without forming my own
independent view of the matter.
3.7 Where in my view, there is a range of reasonable opinion, I have indicated the
extent of that range in the report.
3.8 At the time of signing the report I consider it to be complete and accurate. I will
notify those instructing me if, for any reason, I subsequently consider that the
report requires any correction or qualification.
Charles McLachlan
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POL00054126
POL00054126
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
3.9 I understand that this report will be the evidence that I will give under oath,
subject to any correction or qualification I may make before swearing to its
veracity.
3.10 I have included in this report a statement setting out the substance of all facts
and instructions given to me, which are material to the opinions expressed in
this report or upon which those opinions are based.
3.11 I confirm that insofar as the facts stated in my report are within my own
knowledge I have made clear which they are, and I believe them to be true, and
the opinions that I have expressed represent my true and complete professional
opinion.
Charles McLachlan
Amsphere Consulting Ltd
90 Fenchurch Street
London, EC3M 4BY
England
Friday, 12 February 2010
Charles McLachlan
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