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Interim Disclosure Statement
27 May 2022
THE POST OFFICE HORIZON IT INQUIRY
Interim Disclosure Statement on behalf of Post Office Limited
1. I, Benjamin Andrew Foat of Finsbury Dials, 20 Finsbury St, London EC2Y 9AQ, am
Group General Counsel of Post Office Limited ("POL").
A. INTRODUCTION
2. This interim disclosure statement has been prepared in response to the request
made by the Inquiry in its letter dated 13 May 2022 for the provision of an interim
disclosure statement in relation to all of POL's disclosure to date, in accordance with
paragraph 18 of the Inquiry’s Protocol on the Disclosure of Documents. In that letter,
the Inquiry also requested an explanation for the discrepancy between the number
of documents produced by POL to the Inquiry and the number set out in a statement
made by POL's Chief Executive Officer, Nick Read, in an article that was published
in the Scotsman newspaper on 8 May 2022.
B. THE NUMBER OF DOCUMENTS PRODUCED BY POL
3. Dealing first with the discrepancy, the statement in the article that POL has provided
3 million documents to the Inquiry is incorrect. I am informed by the solicitors
representing POL in the Inquiry, Herbert Smith Freehills ("HSF"), that the
approximate number of documents that has been provided to the Inquiry as at the
date of this statement is 39,000. I am aware from Mr Read that he has written to the
Inquiry to apologise for the discrepancy and to explain the circumstances in which it
arose.
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4. The discrepancy arose in the following circumstances, which have been established
by enquiries made by the POL in-house legal team of Mr Read, the POL
communications team and POL's external communications advisors, TB Cardew. In
advance of the Human Impact Hearings in Glasgow on 11 and 12 May 2022, the
POL communications team obtained an opportunity for Mr Read to explain briefly in
The Scotsman, amongst other things, how POL wishes to assist the work of the
Inquiry. TB Cardew produced a draft article, which was then reviewed by the POL
communications team and by Mr Read. The draft article included the reference to
3 million documents. The number was included by TB Cardew because they had
heard reference to it in a meeting but was not subsequently checked despite Mr
Read asking for it to be. The erroneous number therefore appeared in the article.
5. In the future, I have re-emphasied that any formal communication in the media
relating to the Inquiry will first be checked with POL's in-house legal team and
approved by POL's Inquiry Director, who are familiar with our work in relation to the
Inquiry.
c. OVERVIEW OF INTERIM DISCLOSURE STATEMENT
6. I turn now to the Inquiry's request for a disclosure statement.
7. I am the appropriate person to make the disclosure statement because following the
board's appointment of HSF I am ultimately responsible for instructing HSF in
respect of POL's response to each of the eleven requests made to POL by the
Inquiry under Rule 9 of the Inquiry Rules 2006 ("Rule 9 Requests"), based on the
instructions that I and POL's in-house lawyers under the supervision of POL's Inquiry
Director receive from our colleagues in the business and ultimately the POL board.
8. This statement, including the Annex, constitutes POL's interim disclosure statement
in accordance with paragraph 18 of the Inquiry’s Protocol on the Disclosure of
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Documents. In this statement I set out POL's general approach to searches and
review of documents when responding to Rule 9 Requests received from the Inquiry
to date, including the main repositories, general limitations on searches of which
POL is aware and other relevant background. The Annex sets out POL's searches
and reviews of documents in respect of the requests made by the Inquiry of POL
before the Inquiry was on a statutory footing and each of the Inquiry's eleven Rule
9 Requests.
9. In this statement I address the following topics:
a. The origins and ownership of POL;
b. POL's retention policy and the document preservation holds in place;
c. POL's main repositories of electronic communications;
d. POL's main repositories of electronic documents;
e. POL's main repositories of hardcopy documents;
f. The databases of POL documents hosted on Relativity by KPMG, who are
POL's e-discovery provider;
g. POL's approach to encrypted files and the application of redactions for
privilege;
h. POL's control of documents, and categories of documents that are no longer
within POL's control; and
i. The reasonableness of POL's searches.
10. In this statement I also refer:
a. to steps and/or decisions taken by POL in connection with the Rule 9
Requests including with the assistance of HSF (and POL's other legal
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representatives).
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POL's communications with HSF (and other legal
representatives) were and remain by their nature privileged. For the
avoidance of doubt, any reference to discussions should not be taken as a
waiver of that privilege, whether expressly or impliedly.
b. to steps taken on behalf of POL by HSF and POL's other legal
representatives in connection with the Rule 9 Requests. For the avoidance
of doubt, any reference to steps taken by HSF and POL's other legal
representatives should not be taken as a waiver of privilege, whether
expressly or impliedly.
11. Where I refer to my belief and recollection, these beliefs and recollections are based
on the information provided to me by colleagues at POL, by HSF and by others that
have assisted POL in providing disclosure.
D. DEFINED TERMS
12. In this statement, I have used a number of acronyms and defined terms. I have set
out a definition of each, as I have introduced them. However, for convenience, I also
set out the definitions of these acronyms and definitions below:
EFC
Horizon
HSF
Inquiry
NAS Drive
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E-Filing Cabinet
The Horizon IT System
Herbert Smith Freehills LLP
The Horizon IT Inquiry
Network Attached Storage Drive
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POL Post Office Limited
RMG Royal Mail Group Limited
Rule 9 Request Requests made to POL by the Inquiry under Rule 9 of the
Inquiry Rules 2006
E. ORIGINS OF POST OFFICE LIMITED
13. I set out below a brief explanation of the origins of POL, which are relevant to
understanding how documents are held by POL.
Post Office Limited as a legal entity
14. The Post Office Act 1969 established the Post Office as a statutory corporation,
replacing the General Post Office. In 1986, a restructuring took place in which the
operations of the Post Office were reorganised into three separate businesses:
Royal Mail Letters, Royal Mail Parcels and Post Office Counters. Post Office
Counters was incorporated as a limited company (Post Office Counters Limited) and
subsidiary of the Post Office in 1987.
15. In March 2001, the shareholding of Post Office Counters Limited was transferred to
Consignia plc, a public limited company ultimately owned by the Department of
Trade and Industry (through its holding company Consignia Holdings plc), as part of
restructuring effected under the Postal Services Act 2000. Post Office Counters
Limited was renamed Post Office Limited in October 2001, while Consignia plc was
renamed Royal Mail Group plc in November 2002 (and Consignia Holdings plc was
renamed Royal Mail Holdings plc at the same time). Royal Mail Group plc was
renamed Royal Mail Group Limited ("RMG") in March 2007.
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16. Following the Postal Services Act 2011, POL and RMG formally separated on 1 April
2012 (the "Separation"), with POL's shareholding transferred to Royal Mail Holdings
plc. In September 2013, Royal Mail Holdings plc changed names to Postal Services
Holding Company plc, which became Postal Services Holding Company Limited in
December 2013. In June 2017, the shareholding in POL was transferred to the
Secretary of State for Business, Energy and Industrial Strategy.
F. DOCUMENT PRESERVATION
17. Historically, I understand that POL had a seven year retention policy in relation to
documents and records. In late 2014, data retention instructions were sent to
relevant parts of the business as well as a number of third parties (including
Cartwright King and Fujitsu) in contemplation of litigation. Subsequent document
preservation notices have been issued in connection with the Criminal Appeal
proceedings, malicious prosecution proceedings, the Employment Tribunal
proceedings and the Inquiry once it moved to a statutory footing.
18. In order to ensure that it continued to retain documents and other materials which
were relevant to the Group Litigation, I understand that POL arranged for copies of
the data held on its file servers (totalling approximately 9.5 TB of compressed zip
files) to be copied and placed onto a separate Network Attached Storage ("NAS")
Drive in or around 2017.
G. ELECTRONIC COMMUNICATIONS
19. Prior to 2012, I understand that POL's provider of email servers and software was
Lotus Notes. Following the Separation, POL began to use Microsoft Exchange
instead of Lotus Notes. At the same time, POL began to use an email archiving
system called Proofpoint. Since the beginning of 2016 POL has used Mimecast as
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its email archiving system. The emails that had previously been stored in Proofpoint
were transferred into Mimecast.
20. I understand that there are a number of limitations to the email data that POL
possesses, including:
a. Only those who were identified as being current POL employees at the time
of the Separation (i.e. those employed by POL and who continued to be
employed by POL thereafter) were transferred across to POL. Accordingly,
POL does not hold copies of email data in respect of those employees who
left the business prior to or at the time of the Separation.
b. At the time of the Proofpoint/Mimecast migration, only emails sent to or from
a postoffice.co.uk email account were migrated, despite POL employees
having access to and being able to use royalmail.com email accounts. The
consequence of this is that POL did not receive emails solely between
royalmail.com email accounts, even if those emails involved POL
employees. Furthermore, the migration from Proofpoint to Mimecast will not
have captured any deleted email data.
21. I also understand that there are a number of practical challenges associated with
searching for and exporting email data from Mimecast, including:
a. Mimecast only permits up to five active exports at a particular time. Export
results are divided into 2GB files, each of which needs to be downloaded
separately.
b. Exports only remain available in Mimecast for a period of 15 days, following
which it is necessary to re-run the underlying searches.
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c. The Mimecast search functionality is more limited than the search
functionality available on e-discovery platforms. Accordingly, in order to
conduct meaningful searches across emails archived on Mimecast, it would
first be necessary to export emails onto a separate e-discovery platform.
22. In view of these challenges, POL initially focused on harvesting email data for the
purpose of the Inquiry from custodians who were considered to be most likely to
hold documents relevant to a particular Rule 9 Request. That email data has then
been exported to a "Processing Database". Where it is considered that a
custodian's email data may contain documents responsive to a Rule 9 Request,
searches are then carried out over the mailbox in the Processing Database, with
documents responsive to searches then transferred to POL's "Inquiry Database"
for review (these databases are explained in further detail below). In addition, I
understand that certain email data had already been collated for certain custodians
including in the contexts of the Group Litigation and the Criminal Appeal
proceedings. Where a particular mailbox has been searched for the purposes of
responding to a Rule 9 Request, this has been identified in the Annex.
H. ELECTRONIC DOCUMENTS
SharePoint, Teams and other shared drives
23. Various POL teams (including Company Secretariat, Legal and the Security teams)
have had access to and saved documents on SharePoint or Teams sites and other
shared drives. I understand that these SharePoint and Teams sites were only
introduced following the Separation, although it is possible that historical documents
may have been saved or subsequently transferred onto these drives. Where a
particular SharePoint site or shared drive has been harvested or searched for the
purposes of responding to a Rule 9 Request, this has been identified in the Annex.
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E-Filing Cabinets
24. Prior to the introduction of SharePoint in 2012, I understand that electronic
documents were saved in 'E-Filing Cabinets' ("EFC") within Lotus Notes. Although
an incomplete copy of the EFC is kept on the "GLO Database", POL is currently
working to determine the most complete copy of the EFC to which it has access in
order to ensure that no documents relevant to previous Rule 9 Requests have been
missed and that the most complete copy is used where necessary for future
searches.
Horizon Data
25. Transaction data (recording each transaction processed via Horizon) and event data
(recording Horizon ‘events' such as log-in attempts) is maintained by Fujitsu in
central data centres. Data is normally held for a period of seven years. However, in
October 2014, POL instructed Fujitsu to suspend its document deletion policy. I
understand that Fujitsu therefore holds transaction and event data from October
2007.
Custodian laptops
26. Data from the hard drives and laptops of certain custodians have been harvested,
including for individuals relevant in the context of the Criminal Appeal proceedings.
Contract repositories
27. In 2019, POL introduced a new web-based eProcurement platform for its employees
to manage and store their contracts on. Prior to its introduction, I understand that
third-party contracts were expected to be uploaded onto a system provided by
BravoSolution UK Limited, for which a contract was signed by POL in April 2016. I
am not aware of a central repository of contracts existing at POL prior to the Bravo
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system, although it is possible that historical contracts (including those legacy
contracts that POL obtained from RMG following the Separation) were uploaded to
the Bravo system when it was introduced.
Management tools and databases
28. I POLuses and has used a number of management tools and databases which may
be of relevance to the Inquiry. These include:
a. POLSAP / Core Finance: A database containing financial information and
accounting ledgers, in use since 2005. From September 2014, certain Post
Office teams transferred from POLSAP to Core Finance.
b. Credence: A management information tool providing inter alia the value,
dates and times of Horizon transactions.
c. HORice: A tool used by various POL teams (including the Security Team)
during investigations.
d. Remedy / Dynamics: Software used for logging calls made to the National
Business Support Centre in the period from 2000 — 2014 (Remedy) and 2014
— present (Dynamics).
e. iMAP: A database containing branch information used by the Network
Design and Analysis team.
f. Network Reinvention Database: A database containing the dates of service
of Post Office agents.
I HARD COPY DOCUMENTS
Postal museum
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29. The Postal Museum holds a range of historical POL documents, including (but not
limited to) business and administrative records covering the day-to-day running of
POL, minutes of the meetings of POL's Board which pre-date Separation and hard-
copy branch files. Certain of the documents held in the Postal Museum pre-date the
Separation, and are held by the Postal Museum on behalf of or jointly with RMG.
Oasis
30. Around 70,000 boxes and 30,000 files of archived hardcopy POL documents are
held on behalf of POL by Oasis Group ("Oasis"), an offsite storage provider. POL's
documents are primarily held at Oasis' Winchester site. These boxes comprise a
wide range of documents including (but not limited to) individual branch records, HR
records, audit files, and public consultation documents. Although the vast majority
of the boxes and files are indexed, these indices contain only high level descriptions
of the contents of the boxes and files, and I understand that a number of boxes and
files are misdescribed to a degree. POL is also aware of some branch files which
were believed to have been archived with Oasis but are in fact missing, and may
have been lost in the transfer to Oasis.
31. In addition, POL has recently indexed and scanned around 5,000 boxes and files
that were previously unindexed or not sufficiently indexed for the content to be
identifiable. POL is in the process of arranging for these to be reviewed to consider
whether any of the materials in them are of potential relevance to previous or future
Rule 9 Requests. Any identified as relevant to previous Rule 9 Requests will be
disclosed to the Inquiry. Where POL has carried out searches over the indices
and/or reviewed documents stored at Oasis for the purposes of a particular Rule 9
Request, this is set out in the Annex.
Criminal case files
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32. Various hard copy materials have been identified and collated as part of the reviews
undertaken in the context of the Criminal Appeal proceedings. These include Hard
copy case files consisting predominantly of ‘Green Jackets’ (investigation files of the
POL Security Team, ‘Buff’ files (POL internal prosecution files), ‘Orange’ files derived
from Royal Mail and Cartwright King and ‘Red' files (financial investigation files); as
well as various CDs, tapes and videos, which I understand consist mainly of
recordings of cautioned interviews.
Back office locations
33. During the Group Litigation and Criminal Appeal proceedings, POL identified a
number of administrative offices and sites that contain separate stores of hard copy
documents, and checked these for relevance to those proceedings. Where certain
stores contained documents that may have been relevant to those proceedings, they
were scanned and uploaded to the GLO Database and CCRC Database
respectively (explained in further detail below) for review. POL is considering
whether any of the documents that were not previously scanned may be of relevance
to the Inquiry. However, POL has been unable to locate indices of the remaining
hard copy documents stored at each site. POL is currently in the process of
determining the contents of these hard copy documents and arranging for them to
be reviewed. Any identified as relevant to previous Rule 9 Requests will be disclosed
to the Inquiry.
J. RELATIVITY DATABASES
34. The above categories and repositories of documents have to some extent been
searched and harvested previously for litigation purposes, including in the context
of the Group Litigation, the Criminal Appeals and the Employment Tribunal
proceedings, Baker and Others v Post Office Limited. A number of different
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databases of POL documents collated for various purposes are currently hosted on
a single Relativity platform by KPMG to allow for documents to be more easily
transferred between databases where necessary. These include:
a. The GLO Database: this contains materials collated to allow for searches
and reviews to be conducted for the purposes of disclosure in the Group
Litigation proceedings. I understand that this database was initially hosted
by Consilio on behalf of Womble Bond Dickinson, POL's original legal
advisers in respect of the Group Litigation proceedings, before being
transferred to KPMG. KPMG have carried out a number of checks and
validation steps to provide assurance that the database was successfully
transferred. The GLO Database contains in excess of 20 million documents.
b. The CCRC Database: this contains materials collated to allow for searches
and reviews to be conducted for the purposes of disclosure in the Criminal
Appeals proceedings. This database was initially hosted by Consilio on
behalf of Peters and Peters, POL's legal advisers in respect of the Criminal
Appeals proceedings. KPMG carried out a number of checks and validation
steps to provide assurance that the database was successfully transferred.
The CCRC Database contains in excess of 4 million documents.
c. The Employment Tribunal Database: this contains materials collated to allow
for searches and reviews to be conducted for the purposes of disclosure in
the Employment Tribunal proceedings. This database was initially hosted by
Consilio on behalf of Womble Bond Dickinson, one of POL's legal advisers
in respect of the Employment Tribunal proceedings, before being transferred
to KPMG. KPMG carried out a number of checks and validation steps to
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provide assurance that the database was successfully transferred. The
Employment Tribunal Database contains in excess of 4 million documents.
d. The HSF Database: this contains materials provided to HSF during the
course of separate instructions. It contains almost 500,000 documents,
including agendas, minutes and papers of the POL Board and sub-
committees of the Board, audit reports, emails and laptop copies of certain
custodians, and data extracted from certain SharePoint sites (including those
used by the Legal and Security teams). This database was initially hosted by
HSF before being transferred to KPMG.
e. The Processing Database: a holding database of certain email mailboxes
harvested to allow for searches to be carried out in connection with the
Inquiry. Any documents contained in the Processing Database that are
responsive to particular Inquiry-related searches are transferred to the
Inquiry Database for review. The Processing Database currently contains
over 8 million documents.
f. The Inquiry Database: this contains materials collated to allow for searches
and reviews to be conducted for the purposes of disclosure to the Inquiry.
This includes documents harvested from external sources (including data
harvested and provided by third party law firms, Oasis and the Postal
Museum) and documents identified within the other databases listed above.
POL has sought to consolidate material potentially relevant to previous Rule
9 Requests on this database to improve the efficacy and coverage of its
searches. It currently contains almost 1.5 million documents.
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K. ENCRYPTION, PRIVILEGE AND REDACTIONS
35. Approximately 50,000 documents across the GLO, CCRC, Processing and Inquiry
Databases are subject to password encryption and, at present, cannot be opened.
Accordingly, the contents of such documents would not be caught by keyword
searches. POL is in the process of arranging for software to be used to attempt to
gain access to such documents. To the extent that any documents are accessed
and identified which are responsive to previous Rule 9 Requests, these will be
provided to the Inquiry.
36. When reviewing documents for disclosure to the Inquiry, redactions have been
applied to part privileged material to the extent information falls outside the
parameters of POL's approach to the waiver of privilege set out in its note dated 15
November 2021.
37. Where documents are wholly privileged, or where no information relevant to the
Inquiry remains once redactions have been applied to part privileged material, those
documents have not been disclosed.
L. CONTROL
38. POL has only searched for and disclosed those relevant documents within its
control. A large number of documents are held on POL's behalf by its former and
current advisers. POL has asked those advisers who are likely to hold documents
potentially relevant to the Inquiry's terms of reference on behalf of POL to provide
copies of these documents to POL. Where documents have been obtained from an
adviser for the purposes of responding to a particular Rule 9 Request, this is set out
in the Annex.
39. I There are documents in the categories listed below that are no longer in POL's
control:
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a. Original and copy correspondence, memoranda and other documents which
have been lost or destroyed in the ordinary course of business which cannot
now be traced or recovered.
b. Any pre-Separation materials that were not transferred to POL during the
Separation.
M. REASONABLENESS OF SEARCHES.
40. To the best of my knowledge and belief, the searches and reviews that POL has
conducted (or its advisers have conducted on its behalf) to locate and provide the
Inquiry with the information that it has requested in each of its Rule 9 Requests to
date have been reasonable in all the circumstances.
Statement of truth
I believe the content of this statement to be true.
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ANNEX TO INTERIM DISCLOSURE STATEMENT
1. INTRODUCTION
14 The purpose of this Annex is to provide an overview of the steps that POL has taken to
identify and produce to the Inquiry documents responsive to the requests made by the Inquiry
when on a non-statutory footing and each of the eleven Rule 9 Requests issued by the
Inquiry to date, and a description of the documents that have been produced in response to
each request.
1.2 A detailed description of the approach that POL has adopted in responding to the Inquiry's
requests is set out in the following paragraphs.
2. RULE 9 REQuest No. 1 (17 AuGusT 2021) — HSS WITNESS STATEMENT
24 By its Request No. 1, the Inquiry requested that POL produce a witness statement providing
various information in relation to the Historic Shortfall Scheme (the "HSS").
2.2 POL produced a witness statement (provided by Nick Read) in response to this request on
31 August 2021. No additional / supporting documents were requested by (or produced to)
the Inquiry.
3. RULE 9 REQUEST NO. 2 (9 SEPTEMBER 2021) — RE-DISCLOSURE OF DOCUMENTS
3.1 By its Request No. 2, the Inquiry sought, amongst other things, the provision of:
3.1.1 unredacted copies of all documents which POL had previously provided to the
Inquiry in redacted form prior to its conversion onto a statutory footing (request 2).
3.1.2 all documents listed in POL's Artefact Register, to the extent that these documents
have not already been produced to the Inquiry (request 3).
3.2 Prior to its conversion onto a statutory footing, POL arranged for a total of 441 documents to
be produced to the Inquiry. 396 of these documents were produced by POL in response to
five separate "Batch Information Requests" received from the Inquiry, broken down as
follows:
3.2.1 Batch Request 1 (23 October 2020): 275 documents.
3.2.2 Batch Request 2 (20 November 2020): 15 documents
3.2.3 Batch Request 3 (18 December 2020): 26 documents
3.2.4 Batch Request 4 (29 January 2021): 4 documents
3.2.5 Batch Request 5 (26 March 2021): 66 documents
3.2.6 Batch Request 6 (11 June 2021): 10 documents
3.3 POL arranged for a further 11 documents to be produced to the Inquiry in response to the
Call for Evidence on 23 February 2021. A further 34 documents were produced to the Inquiry
in connection with the "Teach-In" sessions held on 29 April 2021.
3.4 In its initial response to Request No. 2 on 30 September 2021, POL produced to the Inquiry:
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3.4.1 unredacted copies of all documents that had previously been provided in redacted
form, save for certain documents for which it considered third party consent would
first be required.
3.4.2 all documents included in the Artefact Register to the extent that these had not
previously been provided to the Inquiry, save for certain documents in respect of
which it considered third party consent would first be required.
3.5 On 29 October 2021, having obtained the third party consents referred to in paragraph 3.4.1
above, POL produced to the Inquiry copies of the documents that had been withheld from
the production on 30 September 2021.
3.6 Certain of the documents contained material that was subject to legal professional privilege
and had accordingly been produced to the Inquiry in redacted form.
4. RULE 9 REQuEsT No. 3 (8 OCTOBER 2021) — GLO TRIAL BUNDLE AND DISCLOSURE LISTS IN
HAMILTON PROCEEDINGS
44 By its Request No. 3, the Inquiry sought production of the following documents:
4.1.1 The full electronic trial bundle in Bates and Ors v Post Office Limited (Case No.
HQ16X01238, hearing dates: 7, 8, 12, 13, 14, 15, 18, 20, 22 and 26 November
2018; 3, 4, 5, and 6 December 2018) (the "Common Issues Trial Bundle");
4.1.2 The full electronic trial bundle in Bates and Ors v Post Office Limited (Case No.
HQ16X01238, HQ17X02637 and HQ17X04248, hearing dates: 11, 12, 13, 14,
18, 19, 20, 21 and 27 March 2019; 3, 9 and 23 April 2019; 4, 5, 6, 7, 11, 13 and
14 June 2019; and 2 July 2019) (the "Horizon Issues Trial Bundle");
4.1.3 A full list of disclosure provided by POL in Bates and Ors v Post Office Limited
group litigation (the "Group Litigation"); and
4.1.4 A full list of disclosure provided by POL in R v Hamilton and Ors [2019] EWCA
Crim 21 and [2019] EWCA Crim 577.
4.2 On 29 October 2021, POL produced to the Inquiry documents responsive to the request,
together with a copy of the production index.
43 POL obtained copies of the Common Issues and Horizon Issues Trial Bundles from Opus 2
International Limited, who provided e-Discovery services in the context of the Group
Litigation and who continue to maintain electronic copies of the bundles.
44 POL obtained a list of the disclosure provided by POL in the Group Litigation from Womble
Bond Dickinson ("WBD"), who represent POL in those proceedings. As explained in HSF's
letters of 18 and 29 October 2021, POL's disclosure in the Group Litigation was provided in
multiple stages and the list provided to the Inquiry was a composite list covering all of the
stages.
45 POL obtained a list of the disclosure provided by POL in the Hamilton proceedings from the
firm of solicitors which acted for POL in those proceedings, Peters & Peters.
5. RULE 9 REQUEST NO. 4 (3 NOVEMBER 2021) — BOARD AND SUB-COMMITTEE MINUTES RELATING
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TO HORIZON
5.1 By its Request No. 4, the Inquiry sought production of all board minutes since 2000 which
relate to the Horizon IT systems, including those which address any of the following matters:
5.1.1 issues relating to and arising from bugs, errors and defects;
5.1.2 the impact of the Horizon IT system on sub-postmasters and sub-postmistresses;
and
5.1.3 the bringing of private prosecutions.
5.2 By its letter of 26 November 2021, the Inquiry confirmed that it considered sub-committee
minutes to be within the scope of Request 4 and requested that POL therefore search for
and provide responsive materials by no later than 3 January 2021.
Board Minutes
5.3 In order to respond to the request, POL sought to collate all minutes of the Post Office board
in the period from 1 January 2000 to date. In this respect:
5.3.1 Minutes from 2012 onwards were obtained from POL's Company Secretary from
the Company Secretary SharePoint.
5.3.2 Pre-2012 minutes were previously obtained from the Postal Museum in the course
of separate instructions that POL had provided to HSF (including, in respect of the
period before regular meetings of the POL Board took place, the board minutes of
the Statutory Corporation and Consignia Plc). In order to identify minutes of the
dedicated POL Board (which started to meet regularly from May 2002), POL
conducted searches across these materials for documents responsive to the
following search: "POLB" AND "Minutes of the meeting" AND ("Post Office Limited"
OR "Post Office Ltd"). POL also sought the assistance of the Postal Museum to
ensure that it had as comprehensive a set of minutes as possible (which helped
identify two further minutes).
54 Having identified and collated a universe of board minutes for the relevant period, POL then
conducted keyword searches using the following terms to identify a narrower pool of
potentially responsive documents for manual review:
5.4.1 Bates
5.4.2 Convict*
5.4.3 FJ
5.4.4 FSL
5.4.5 Fujitsu
5.4.6 GLO
5.4.7 Group Action
5.4.8 Group Litigation
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5.4.9 Horizon
5.4.10 HNG
5.4.11. HZ
6.4.12 ICL
5.4.13 ICRMS
5.4.14 International Computers Limited
5.4.15 IT or Computer w/1 system
5.4.16 Mediation Scheme
5.4.17 POLIT
5.4.18 Postmaster litigation
5.4.19 Prosecut*
5.4.20 Sparrow
5.5 The POL Board met regularly from May 2002. In respect of the period from 2000 to 2002, at
the request of the Inquiry in its letter of 26 November 2021, POL obtained the consent of
RMG to produce minutes of the boards of Post Office Statutory Corporation and Consignia
Pic to the Inquiry.
56 On 1 December 2021, POL produced to the Inquiry Board minutes responsive to Request 4,
together with a copy of the production index. In total, POL disclosed 151 board minutes in
response to this Request 4, including relevant minutes of the Post Office (Statutory
Corporation) and Consignia PLC boards.
Sub-Committee Minutes
57 Sparrow and GLO Sub-committee minutes
5.7.1 POL has maintained complete sets of minutes of the Sparrow and GLO sub-
committees, which are held by the POL Company Secretary. The Sparrow and
GLO sub-committee minutes were manually reviewed in full and those minutes that
are responsive to the request were produced to the Inquiry on 17 December 2021.
5.8 Other sub-committees listed in the Annex to HSF's 23 November letter
5.8.1 The Annex to HSF's letter of 23 November 2021 identified the following, additional
sub-committees:
(A) Audit, Risk and Compliance Committee (formerly, the Risk and
Compliance Committee)
(B) Health and Safety Committee
(C) Nominations Committee
(D) Remuneration Committee
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5.8.2
5.8.3
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(F)
(G)
(H)
()
()
(kK)
(L)
(M)
(N)
(0)
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Annual & Interim Report Sub-Committee, 2011-2016
Eagle Sub-Committee (concerning the sale of Post Office Financial
Services), 2011-2012
Mutualisation Committee, 2012-2013
Pensions Committee, 2012-2013
RMG Sister Company Sub-Committee, 2012
Financial Services Committee, 2014-2015
Sparrow Sub-Committee, 2014-2015
Funding Sub-Committee, 2017
GLO Sub-Committee (also referred to as the Postmaster Litigation Sub-
Committee), 2018-2020
Panther Sub-Committee (concerning the proposed acquisition of a
payments business), 2018
Credit Card Sub-Committee, 2019
All minutes of the above-listed sub-committees held on the Company Secretary
SharePoint were collated and uploaded to KPMG's Relativity platform. Written
resolutions were not considered to be minutes, and were not therefore harvested.
The GLO and CCRC databases were also searched for "POLARC" (a unique
reference which appears in each of the minutes of the meetings of the ARC Sub-
Committee). However, no additional ARC minutes were identified.
POL then conducted keyword searches using the following terms to identify a
narrower pool of potentially responsive documents for manual review.
Bates
Convict*
FSL
FJ
Fujitsu
GLO
Group Action
Group Litigation
Horizon
HNG*
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(Kk) HZ
(L) ICL
(M) ICRMS
(N) International Computers Limited
(O) IT or Computer w/1 system
(P) Mediation Scheme
(Q) POLIT
(R) Prosecut*
(S) Postmaster litigation
(T) Sparrow
5.9 Pre-2012 minutes
5.9.1 Prior to 2012, POL does not appear to have had an Audit, Risk and Compliance
Committee. POL did however have a Risk and Compliance Committee ("RCC"),
which appears to have been a board sub-committee. Searches for pre-2012 RCC
meetings were first carried out on HSF's Relativity platform, with the following
search terms: "Risk and Compliance Committee" AND "Meeting Ref".
5.9.2 POL also wrote to the Postal Museum to ask for assistance with identifying pre-
2012 minutes of the Committees listed above. In its response, the Postal Museum
indicated that it held a small number of copies of Health & Safety Committee
minutes from around 2000 and some Pensions Committee minutes in hard copy.
The Postal Museum indicated that copies of these minutes were not available and
that they would have to be inspected in person. By that stage it had become
apparent that none of the minutes of the Health & Safety Committee and Pensions
Committee that had been located on the Company Secretary SharePoint were
responsive to the request. It was therefore decided not to inspect the Health &
Safety and Pensions Committee minutes held at the Postal Museum on the basis
that they were unlikely relevant. The Postal Museum did not hold any additional
RCC minutes.
5.9.3 In order to identify sub-committee minutes of the Post Office Statutory Corporation
and Consignia Pic for the period from 2000 to May 2002, POL conducted a targeted
search for the term "minutes" across the unified document title HSF's Relativity
platform, with a date filter of 01/01/2000 — 24/05/2002 (the date of the first regular
POL board meeting). Responsive documents were reviewed for relevance. POL
then used text common to each of the minutes identified to try to identify further
Post Office Audit Committee and Consignia Holdings Pic Audit and Risk Committee
minutes. Searches were conducted for "Post Office Audit Committee" across the
HSF, GLO and CCRC databases but no additional minutes were located. POL
conducted a further search for "audit and risk committee" AND "Consignia Holdings
plc" across the HSF, GLO and CCRC databases but, again, these searches did
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not identify any further minutes.
5.10 Board strategy sessions
5.10.1. In the course of responding to this request, POL obtained from the Company
Secretary handwritten notes and action lists of the board's annual strategy
sessions between 2012-2018. Whilst these are not (strictly speaking) Board or
Sub-Committee minutes, POL nonetheless arranged for these materials to be
reviewed for relevance in the absence of formal minutes for these meetings.
5.11. On 22 December 2021, POL produced to the Inquiry 53 relevant sub-committee minutes,
together with a production list identifying the documents that had been provided. Specifically,
POL produced:
5.11.1 39 post-2012 minutes of the Audit Risk and Compliance Committee;
5.11.2 7 pre-2012 minutes of the Risk and Compliance Committee;
5.11.3 1 Post Office (statutory corporation) Audit Committee minutes;
5.11.4 3 minutes of the Remuneration Committee;
5.11.5 1 Annual & Interim Reports Committee minutes; and
5.11.6 2 board strategy session draft minutes.
6. RULE 9 REQUEST No. 5 (26 NOVEMBER 2021) — LEGAL ADVICE
6.1 By Rule 9 Request No. 5, the Inquiry sought the production of various documents / categories
of documents by no later than 17 December 2021. A list of these documents / categories of
documents are set out in Schedule I. In response to this request, POL took the following
steps.
6.2 Document Retention and Disclosure Failures (Requests 1 and 2)
6.2.1 POL located and produced to the Inquiry copies of the advices of Simon Clarke
(the "Clarke Advices") dated 8 July 2013, 15 July 2013, 19 July 2013 and 2 August
2013.
6.2.2 In order to identify materials responsive to Request 2, the following searches were
conducted over the general advice files of Cartwright King and previously
harvested extracts from the mailboxes of the certain former POL employees,
namely Jarnail Singh, Susan Crichton and Alwen Lyons, each of whom appear to
have been centrally involved in communicating with Cartwright King:
(A) Search 1: All emails sent to/from POL domains to/from Cartwright King
domains in the period from 1 July 2013 to 31 August 2013.
(B) Search 2: All emails sent to/from POL domains to/from Cartwright King
domains during the course of 2013, which are responsive to any of the
following search terms: "Disclosure" or "Expert Evidence" or "Fujitsu" or
"Horizon".
(C) Search 3: All emails sent to/from POL domains to/from Cartwright King
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domains, which are responsive to the following search: "Simon" or "Clarke"
wi20 "Advice" or "Advise" or "Opinion" or "Opine".
(D) Search 4: "Simon" or "Clarke" AND "July 2013" or "August 2013".
6.2.3 On 17 December 2021, POL produced to the Inquiry 26 documents in response to
requests 1 and 2, together with a production list. This comprised the four Clarke
Advices described at paragraph 6.2.1 above in response to Request 1, and 23
documents responsive to Request 2.
6.2.4 HSF's letter of 17 December 2021 recorded that POL had been unable to locate
copies of certain documents in response to Request 2, including copies of the
instructions that were prepared in relation to the Clarke Advices and that it
proposed to continue to review potentially relevant materials and conduct further
targeted searches with a view to producing any other responsive documents to the
Inquiry by 14 January 2022. In particular, POL arranged for Search 1 and Search
3 to be conducted across the entire mailboxes of Susan Crichton and Rodric
Williams (with a start date for Search 1 of 1 June 2013 (rather than 1 July 2013)),
with all responsive documents subject to manual review. As explained in HSF's
letter of 14 January 2022, these searches did not reveal any further responsive
documents.
6.3 Post-Conviction Review and Disclosure (Requests 3 and 4)
6.3.1 Peters & Peters have previously collated advices that had been prepared by Brian
Altman QC in the period from 2013 to 2016, and instructions in relation to the same.
These include the following documents, copies of which POL produced to the
Inquiry on 17 December 2021 in response to Requests 3 and 4:
(A) Mr Altman QC's observations on the Original Terms of Reference dated 2
August 2013;'
(B) Mr Altman QC's Interim Review dated 2 August 2013;
(C) A note of the conference held with Mr Altman QC on 9 September 2013;
(D) The Amended Terms of Reference in respect of the Prosecution Review;
(E) The General Review dated 15 October 2013; and
(F) The Review of Post Office Ltd Prosecution Role dated 19 December 2013.
6.3.2 HSF's letter of 17 December 2021 explained that POL had not been able to locate
final versions of (i) the Original Terms of Reference and (ii) the Amended Terms of
‘ As explained in HSF's letter of 17 December 2021, Mr Altman QC was initially instructed by POL to advise
and conduct two separate reviews (as reflected in the Original Terms of Reference): (i) a backward-facing
review of the processes and strategies adopted by Cartwright King and POL (the "Process Review"); and
(ii) a review of POL's role as a prosecutor (the "Prosecution Review"). Following discussions between POL
and Mr Altman QC, and observations that he made on the Original Terms of Reference, it appears that
Amended Terms of Reference were prepared and circulated. Whereas the Original Terms of Reference
had included both of the anticipated reviews, the Amended Terms of Reference were divided into two
separate documents, one for the Process Review and the other for the Prosecution Review. The "General
Review" dated 15 October 2013 set out Mr Altman QC's advice in relation to the Process Review and the
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Reference for the Process Review. However, the text of these Terms of Reference
appears to be quoted in Mr Altman QC's Observations on the Original Terms of
Reference dated 2 August 2013 and the General Review dated 15 October 2013
respectively, copies of which were produced to the Inquiry.
6.3.3 Mr Altman QC's advice of 19 December 2013 refers to three separate conferences
/ teleconferences, held on 9 September 2013, 4 October 2013 and 17 October
2013. HSF's letter of 17 December 2021 recorded that POL had located (and
produced to the Inquiry) a note prepared in relation to the 9 September conference
and that POL proposed to continue to review potentially relevant materials and
conduct further targeted searches with a view to identifying any notes that were
prepared in relation to the 4 October and 17 October teleconferences. The
supplemental searches conducted by POL are set out below, each of which were
conducted across the mailboxes of Rodric Williams and Susan Crichton. As
recorded in HSF's letter of 14 January 2022, these searches did not identify any
additional relevant documents. It is conceivable that notes of these teleconferences
were not prepared and/or shared with POL.
(A) Search A: Documents responsive to the following search terms, in the
period from 1 October 2013 to 31 October 2013: "Altman" and
"Conference" or "Note" or "Call" or "4 October" or "4th October".
(B) Search B: Documents responsive to the following search terms, in the
period from 1 October 2013 to 31 October 2013: "Altman" and
"Conference" or "Note" or "Call" or"17 October" or "17th October".
6.4 Second Sight Advice (Request 5)
6.4.1 In order to identify potentially responsive materials, POL initially conducted a
manual review of certain emails and advices in the possession of POL, WBD and
HSF. Documents identified through this exercise were then subject to a manual
review to confirm their responsiveness to Request 5 and, as explained in POL's
letter to the Inquiry of that date, were produced to the Inquiry as appropriate on 17
December 2021.
Targeted Searches
6.4.2 As explained in HSF's letter to the Inquiry dated 14 January 2022, POL focused its
searches in the time available on the repositories most likely to hold responsive
documents. Following the initial production of documents in response to Request
5 on 17 December 2021 referred to above, POL conducted targeted electronic
searches over a broader range of documents in order to identify responsive
material, which are explained below. In parallel, potentially responsive documents
provided by Linklaters were manually reviewed and also produced to the Inquiry
as appropriate on 14 January 2022.
6.4.3 Documents that were responsive to the searches outlined below were manually
reviewed to assess their responsiveness to the request. POL then produced those
“Review of Post Office Ltd Prosecution Role" dated 19 December 2013 contains his advice in relation to
the Prosecution Review.
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documents that were responsive to the request and also any non-responsive family
documents.
Second Sight Advice (Request 5) - Search Terms
Search 1
e Repositories searched: Client files held and identified as potentially relevant
by WBD and DAC Beachcroft, as well as client files provided to POL by
Cartwright King.
* Date Range: 1 January 2013 to 31 December 2015
* Custodians:
1. In relation to WBD documents, emails from and to POL addressees
to which Andrew Parsons or Gavin Matthews (the relevant WBD
partners / managing associates in relation to WBD's involvement in
the engagement of Second Sight) are a recipient, a sender, copied
or blind copied.
¢ Search terms:
1. ("lan" or "Henderson" or "Ron" or "Second Sight" or "Warmington")
AND
("Briefing" w/10 "Report'); or
("Draft' w/10 "Report"); or
("Initial w/10 "Complaint'), or
("Interim" w/10 "Report’); or
"Destroy" or "Engage" or "Instruct or "Terminate"; or
"ICRMS" or "Mediation" or "Part 1" or "Part One" or “Part 2" or "Part
2" or "Sparrow’; or
8. "8 July" or "8/7/13" or "08/07/2013" or "25 July" or "25/7/13" or
"25/07/2013" or "21 August’ or "21/8/14" or "21/08/2014" or "9 April"
or "9/4/15" or "09/04/2015" or "10 March" or "10/3/15" or
"10/03/2015"
Nog - 8 WN
Search 2
e Repositories searched: The mailboxes of Susan Crichton and Chris Aujard,
who held the position of General Counsel at POL for the period 2012-2013
and 2013-2015 respectively.
e Date Range: 1 July 2013 to 30 June 2014
*° Search Terms: Those set out in respect of Search 1 above.
Search 3
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Second Sight Advice (Request 5) — Search Terms
* Repositories searched: Emails previously harvested by HSF from the
mailboxes of Jane MacLeod, Chris Aujard and Alwen Lyons.?
e Search terms: Those set out in respect of Search 1 above.
Search 4
e Repositories searched: The mailboxes of Chris Aujard, Jane MacLeod and
Rodric Williams.
e Date Range: 1 January 2014 to 1 June 2015.
* Search terms:
1. “terminat" w/10 "engagement'
2. "terminat*" w/10 "Second Sight"
3. “terminat" wi10 "SS"
Search 5
e Repositories searched: The mailboxes of Chris Aujard, Jane MacLeod and
Rodric Williams.
e Date Range: 1 February 2015 to 1 June 2015
e Search terms:
1. “destr" wi5 "document"
2. “return*" wi5 "document"
6.4.4 Following this production, as HSF explained in a letter to the Inquiry dated 5 April
2022, it became apparent that, due to a technical issue with the documents that
were provided by WBD to KPMG (POL's e-Discovery provider), the date range
searches that were carried out in relation to Second Sight materials did not provide
accurate results with regard to a certain type of data. This issue has since been
resolved and the search terms that POL initially applied in respect of Second Sight
(set out in Search 1 above) were re-run. POL is in a position to produce additional
responsive documents to the Inquiry once it has been provided with a Quatrix link.
6.4.5 Across the various productions that include documents responsive to this request,
POL has produced a total of 1,121 documents.
6.5 Group Litigation Advice (Request 6)
6.5.1 As with Request 5 above, POL identified documents responsive to Request 6 by a
combination of (i) reviewing an initial set of potentially responsive materials that
were identified from documents provided by POL and its external legal advisors
The search parameters applied when conducting this harvest were: Date Range: 1 July 2014 to 31 August
2016; Search Terms: "Second Sight*" or "SS" or "Warmington" or "Henderson" or "Parsons" or "Brooks"
or "Brookes" or "Loraine".
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(including WBD and Norton Rose Fulbright ("NRF")), and (ii) conducting targeted
searches across various repositories and manually reviewing responsive results.
Potentially responsive materials
6.5.2 In order to produce a list of potentially responsive materials, a manual review was
conducted of documents and emails: (a) provided by POL to HSF from the time of
HSF's engagement by POL in 2019 in relation to the GLO; (b) in relation to legal
advices provided by HSF to POL; (c) provided by NRF in relation to its involvement
in the GLO; and (d) identified by WBD as potentially responsive to Request 6
following WBD's own manual review. Manual reviews of these documents were
then conducted to determine which particular documents were responsive to
Request 6. In addition to the above, POL conducted a review of:
(A) Papers that were prepared for regular meetings of a Steering Committee
("SteerCo") that was established by POL in 2016 to co-ordinate its
approach and response to the Group Litigation.
(B) The minutes of SteerCo (or similar) meetings in 2019 identified and
provided by POL to HSF.
(C) Papers that were prepared for the sub-committee of POL's board (the
"GLO board sub-committee") that was established by POL in around
March 2018 in order for the Board to receive legal advice in relation to
POL's defence of the Group Litigation and held regular meetings from 26
March 2018 to 10 December 2019.
(D) The minutes of the GLO board sub-committee identified and provided by
POL to HSF.
(E) Papers that were prepared for POL's board in relation to the conduct of
POL's defence of the Group Litigation identified and provided by POL to
HSF; and
(F) Proofs of evidence and notes from witness proofing meetings in relation to
the Common Issues trial and Horizon Issues trial, identified and provided
to POL by WBD.
Targeted Searches
6.5.3 Following the initial production of documents in response to Request 6, POL
conducted targeted electronic searches over a broader range of documents —
principally documents held by WBD - in order to identify responsive material. A
summary of these searches is set out below, including a description of the search
terms that were applied and the repositories across which these searches were
applied.
6.5.4 Documents that were responsive to the searches outlined below were manually
reviewed to assess their responsiveness to the request. POL then produced those
documents that were responsive to the request and also any non-responsive family
documents.
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GLO Advice (Request 6) - Search Terms
Search 1
« Repositories searched: Electronic client files held and identified as
potentially relevant by WBD. These consisted principally of the Group
Litigation matter files themselves, which comprised emails and attachments
that had been filed in relation to those matters. However, to the extent that
searches were run over other WBD files (such as those relating to the claims.
of individual claimants, the contents of which related to the Group Litigation),
the following search terms were applied:
1. “Bates”
2. “Freeths"
3. "GLO"
4. "Group Litigation"
¢ Date Range: N/A
* Custodians:
1. Emails from and to Paula Vennells, Al Cameron, Tom Moran or
Jane Macleod to which Andrew Parsons or Gavin Matthews are a
recipient, a sender, copied or blind copied.
2. Emails from and to POL addressees to which David Cavender QC,
Anthony de Garr Robinson QC, Lord Grabiner QC and the Rt Hon.
Lord Neuberger of Abbotsbury are a recipient, a sender, copied or
blind copied.
* Search terms:
1. “advi*"
"counsel"
“Instruct™
“opin*"
“Option*"
“Recommend™"
"Strat"
"PH PON
Search 2,
* Repositories searched: See Search 1 above.
* Date Range: 1 January 2017 to 31 May 2017.
¢ Custodians:
1. Emails from and to POL addressees to which Andrew Parsons or
Gavin Matthews are a recipient, a sender, copied or blind copied.
* Search terms:
41. “advit"
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GLO Advice (Request 6) - Search Terms
2. “counsel”
3. "Instruct"
4. “opin*"
5. “Option*"
6. "Recommend"
7. “Strat”
Search 3
¢ Repositories searched: See Search 1 above.
e Date Range: 1 January 2019 to 31 December 2019.
* Custodians:
1. Emails from and to POL addressees to which Andrew Parsons, Tom
Beezer or Gavin Matthews are a recipient, a sender, copied or blind
copied.
° Search terms:
1. "Grabiner"
2. “Neuberger”
3. "Recus*"
Search 4
¢ Repositories searched: See Search 1 above.
* Date Range: 1 January 2015 onwards.
* Custodians:
1. Emails from and to Paula Vennells, Al Cameron, Tom Moran or
Jane Macleod to which Andrew Parsons or Gavin Matthews are a
recipient, a sender, copied or blind copied; and
2. Emails from and to POL addressees to which David Cavender QC,
Anthony de Garr Robinson QC, Lord Grabiner QC and the Rt Hon.
Lord Neuberger of Abbotsbury are a recipient, a sender, copied or
blind copied.
* Search terms:
1. “advi" or "counsef" or "Disclos*" or "Instruct*" or “opin*" or "Option*"
or "Recommend™" or "Strat"
AND
2. "Jenkins" or "KEL" or "Known Error Log" or "Log"
6.5.5 Following these productions, as POL informed the Inquiry in its letter dated 5 April
2022, in the course of reviewing documents for the purpose of the Inquiry's Rule 9
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request of 28 February 2022, POL identified an email from Rodric Williams which
POL considered to be responsive to Request 6. POL produced the email to the
Inquiry. In view of that email, POL conducted a targeted review of email
correspondence between Mr Williams and WBD to identify any further documents
that may be responsive to Request 6.° POL is in a position to produce these
additional responsive documents to the Inquiry once it has been provided with a
Quatrix link.
6.5.6 Across the various productions that include documents responsive to this request,
POL has produced a total of 4,298 documents.
6.5.7 As explained in HSF's letter to the Inquiry dated 14 January 2022, in order to
identify documents responsive to this request, POL sought to focus its searches in
the time available on the repositories most likely to hold responsive documents.
POL noted that whilst further searches could theoretically have been carried out to
identify other potentially responsive documents, it appeared to POL that any such
documents may only have limited probative value.
6.6 Board Minutes (Request 7)
6.6.1 POL had already responded to this aspect of the Rule 9 Request (as part of its
response to the Request No. 4). Accordingly, no further action was taken in respect
of this Request 7.
7. RULE 9 REQUEST NO. 6 (3 DECEMBER 2021) — INFORMATION AND DOCUMENTS CONCERNING
PROSECUTIONS
71 By its Request No. 6, the Inquiry requested that POL provide the following explanation and
documents by no later than 17 December 2021:
7.14 Prosecution Statistics: Confirmation of the number of prosecutions that POL
brought (in total) between 2000 and 2015 and the number of those prosecutions
that resulted in a conviction.
7.1.2 Prosecution Files: All of POL's prosecution files relating to any conviction (of an
SPM, assistant or employee) which took place in the years 2001 and 2011.
7.2 POL's response to the Inquiry's request for "Prosecution Statistics" was provided on 15
December 2021, with the requested "Prosecution Files" produced on 17 December 2021. As
explained in HSF's letter of 15 December 2021, POL adopted the following approach in
identifying these materials and producing the requested information to the Inquiry.
7.3 Prosecution Statistics
7.3.1 The information provided by POL in its letter of 15 December 2021 related to
private prosecutions brought by POL (or, pre-separation, RMG), and which were
brought (entirely or in part) on the basis of evidence from the Horizon IT system. It
3 Search Terms: "Strat*" or “Option*" or "Recommend*" or “Instruct*" or “advi
“disclo*"; Date Range: 1 January 2015 to 31 December 2019.
or "counsel" or “Opin*" or
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did not include cases brought in Northern Ireland or Scotland, on the basis that
such cases were conducted by public authorities.
7.3.2 The principal source of information relied upon to produce this information was
contemporaneous casework spreadsheets that were manually created and
maintained at the time of the investigations / prosecutions by the POL Security
Team. In the course of collating and analysing this information, Peters & Peters
identified instances of incomplete, incorrect or inconsistent data, some of which
they were unable to reconcile. Where Peters & Peters were unable to verify
information, it was assumed that the prosecutions fell within the Post-Conviction
Disclosure Exercise ("PCDE"). Peters & Peters confirmed that to date they have
not identified any prosecutions that were within scope of the PCDE and which had
not been reflected in the casework spreadsheets.
74 Prosecution Case Files
7.41 POL produced to the Inquiry documents located in each of the following document
repositories, to the extent that these documents had been identified by Peters &
Peters as part of the PCDE as relating to any individuals who were convicted in
2001 or 2011:
(A) The electronic Security team SharePoint system;
(B) The hard copy Security team folders;
(C) The hard copy RMG 'Buff Files', which were created and maintained by
RMG's criminal law team (and, post-separation, by POL's criminal law
team);
(D) The defence case files, consisting of documents identified for disclosure to
convicted individuals by Peters & Peters as part of the PCDE; and
(E) Disclosable to Appellant, consisting of documents identified by Peters &
Peters as meeting the test for disclosure to a convicted individual under
the Criminal Procedure and Investigations Act.
75 POL has produced a total of 14,586 documents (29 documents in relation to convictions
secured in 2001, and 14,557 documents in relation to convictions secured in 2011). As
explained in HSF's letter of 15 December 2021, only very limited materials were available in
respect of convictions secured in 2001, in part as a result of the application of a ‘business as
usual’ document retention policies, under which POL/RMG would destroy documents after
six years.
8. RULE 9 REQuEST No. 7 (13 DECEMBER 2021) — HORIZON ROLL-OuT MATERIALS
8.1 By its Request No. 7, the Inquiry requested that POL produce to the Inquiry by 29 December
2021:
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8.1.1 three named Reports referred to in the Trade and Industry Select Committee 11%
Report of September 1999;
8.1.2 minutes of the Horizon Working Group; and
8.1.3 reports of the Horizon Working Group.
8.2 In an effort to locate documents responsive to this request, POL (i) conducted targeted
searches for relevant electronic documents and (ii) reviewed hard copy materials held at the
Postal Museum and Oasis archives.
8.3 Initial searches were carried out for the specific documents sought by running appropriate
key word searches over the electronic documents held in Relativity. In particular, POL
conducted the following searches across each of the HSF, GLO and CCRC Databases. As
explained in HSF's letter of 23 December 2021, these searches did not identify any
responsive documents.
8.3.1 Search 1: Documents responsive to the following search terms, in the period from
4 January 1997 — 1 January 1999:
(A)
"Adrian Montague"
"Benefits Payment Card" AND "Report"
"Consulting Group" AND "Report"
"Corbett" AND "Report"
"Graham Corbett"
"Montague" AND "Report"
"PA Consulting Group"
“Report' AND ("October 1997" or "July 1998" or "October 1998")
8.3.2 Search 2: Documents responsive to the following search terms:
(F)
(G)
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"Horizon Working Group"
"HWG"
"Horizon" AND "Working Group"
("Horizon Working Group" AND ("Minutes" or "Meeting"))
(("Horizon Working Group" or "HWG" or ("Horizon" AND "Working Group"))
AND (“John Roberts" or "Jerry Cope" or "Stuart Sweetman")
("Horizon Working Group" or "HWG" or ("Horizon" AND "Working Group"))
AND "lan McCartney"
("Horizon Working Group" or "HWG" or ("Horizon" AND "Working Group"))
AND "Alan Johnson".
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8.3.3 Search 3: Documents responsive to the following search terms:
(A) "Horizon Working Group" AND "Report"
(B) ("Horizon Working Group" or "HWG*" or ("Horizon" AND "Working Group"))
AND "Cabinet Office" AND ("December 1999" OR "1999").
8.4 POL also searched hard copy documents held at the Oasis archives in Winchester and the
Postal Museum for responsiveness to this request. These searches were undertaken at the
same time as searches for the documents requested by the Inquiry under Request No. 9,
and full details are set out below at paragraph 10 below.*
8.5 Files that were identified during onsite hard copy reviews as being potentially responsive to
Request No. 7 were scanned and uploaded to Relativity and each document contained within
those files was then manually reviewed.
8.6 POL provided the responsive documents to the Inquiry on 11 February 2022. This comprised
copies of the (three) individual Reports sought, and a number of documents relating to the
Horizon Working Group. In total, nine documents were produced to the Inquiry in response
to this request.
87 It is possible that further documents may be located in other hard copy repositories which
are being searched. However, this is uncertain due to the date of creation of the documents
requested. Applying POL's seven-year retention of documents policy, and even assuming
that the documents would have been within scope of the litigation stop notice issued in 2014,
many of the documents which existed in hard copy from this period are likely to have been
lost or destroyed in the usual course of business prior to the notice being issued.
Furthermore, in as far as the documents requested were ever held electronically, then it is
unlikely that they were migrated to POL following its separation from RMG in 2012 as many
employees who had been involved in creating and handling these documents were likely to
have left POL's employment and therefore not be caught in the harvesting of POL documents
described in the main body of this statement.
9. RULE 9 REQUEST No. 8 (17 DECEMBER 2021) — TEACH-IN WITNESS STATEMENTS.
9.1 By its Request No. 8, the Inquiry requested (i) draft witness statements, and (ii) any related
documents, from the appropriate persons within POL in relation to a series of teach-in
sessions with POL employees held between April and June 2021, prior to the conversion of
the Inquiry into a statutory Inquiry from 1 June 2021.
9.2 In particular, the Request sought "the same or similar information that was received" during
the teach-in sessions and set out a series of 53 more specific requests for information to be
covered by the witness statements requested. The Request also sought copies of all
documents in POL's possession that were referred to during, or otherwise provided in relation
to, the teach-in sessions.
9.3 POL identified three individuals who were able to provide the witness statements requested.
As part of the preparation of these witness statements, POL sought to identify, and exhibit
4 Request No. 9 and Request No. 7 had multiple common factors. Both requests focused on the earliest
documents relevant to the Horizon IT system, dating back to 1994, Further, both requests sought a
combination of specific documents and classes or types of documents.
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to each witness statement, any documents that were relevant to the issues covered by that
statement.
9.4 POL had maintained a record of the documents provided to the Inquiry as part of the teach-
in sessions and subsequently in response to the Inquiry's Batch 6 information request (issued
prior to its conversion to a statutory Inquiry) regarding additional materials referenced during
the sessions. Using this record, POL was able to identify the responsive documents. For
other documents, POL conducted targeted searches.
9.5 POL provided the draft witness statements requested to the Inquiry by way of email on 8
February 2022. On the same day, POL also produced exhibits to these statements, together
with documents responsive to Part 54 of the Request, which together represented 128
documents.
10. RULE 9 REQuEsT No. 9 (17 DECEMBER 2021) — FURTHER HORIZON ROLL-OuT MATERIALS
10.1 By its Request No. 9, the Inquiry sought specific documents and certain broader categories
of documents relating to the adoption and design of the Horizon IT system, and also the pilot
and roll-out of the system. Responsive documents were identified by a manual review of
hard-copy documents stored at the Oasis archives in Winchester and the Postal Museum,
as well as by targeted searches for electronic documents.
Oasis archive (Winchester)
10.2 The Oasis archive comprises over 70,000 boxes and some 30,000 files. These boxes and
files consist of a wide range of documents including (but not limited to) individual branch
records, HR records, audit files, public consultation documents, and the working papers of
individuals. Descriptions of the majority of these boxes and files are set out in two indices
(the "Oasis indices"), one for boxes and one for files. There were also many boxes and files
— be around 5,000 — which were unindexed. POL has recently indexed and scanned these
files and boxes and is in the process of arranging for these to be manually reviewed. Any
documents identified as relevant to this or other Rule 9 requests will be disclosed to the
Inquiry.
10.3. POL conducted keyword searches across the Oasis indices in order to identify files and
boxes which appeared from their descriptions to contain potentially responsive material to
Request No. 7 and Request No. 9. These include the following: "Horizon"; or "ICL"; or
"Pathway", or "CAPS"; or "Treasury"; or "Consulting"; or “Corbett'; or "Montague"; or
"Roberts" or "Johnson" or "DSS" or "Benefit' or "Benefits" or "DTI" or "Select" or "Cabinet’
or "HWG" or “Working Group" or "Payment" or "Consultancy".
10.4 The descriptions of the boxes and files that were responsive to these search terms, as well
as the dates on which they were archived, were considered on a line-by-line basis to filter
out any that appeared on manual review to be irrelevant. Where there was uncertainty as to
whether a particular file or box was likely to be relevant, POL erred on the side of inclusion,
so as to minimise the risk of responsive documents being missed. A further manual review
of the indices was then undertaken to identify any additional files or boxes whose
descriptions in the indices were not responsive to keyword searches but which had been
archived by particular individuals, or which appeared from their names to relate to projects
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which could have related to Horizon.°
10.5 These searches produced lists of:
10.5.1 18 files that were reviewed for relevance to Request No. 7; and
10.5.2 In excess of 480 files (across approximately 125 boxes) that were reviewed for
relevance to Request No. 9.
10.6 Any files which were identified as containing responsive material were scanned and
uploaded to Relativity, and subject to a manual review.
Postal Museum
10.7 POL provided a list of documents (described in the same terms as in the relevant requests)
to the archivists at the Postal Museum. The archivists then undertook searches of the
materials that they hold based on keyword searches that they believed were most likely to
identify the material. POL then attended the Postal Museum in January 2022 to review in
hard copy the files and documents which were responsive to the archivists' searches and
which POL considered may be relevant to the requests.
10.8 Once relevant files had been identified, document processing specialists attended in January
and February 2022 to undertake on-site scanning, as removal of the documents from the
Postal Museum is not permitted. The documents were then uploaded to Relativity and
manually reviewed, and the documents that were responsive to the requests were provided
to the Inquiry.
Electronic documents
10.9 POL also conducted searches across the electronic documents held in Relativity (in
particular, over documents hosted on the GLO Database), save that where copies of specific
documents requested in the Request No. 9 had already been located in the hard copy
repositories, no further searches were undertaken.
10.10 POL used iterative searches to locate documents in response to each item requested under
Request No. 9, refining the searches depending on information gathered from previous
searches, such as likely date ranges, relevant names of authors or recipients, document
titles, terms or footer references. Where categories of document were sought, rather than
individual documents, a similar approach was adopted searching for the particular category
of documents. A full list of keyword searches is set out below.
10.11 Documents responsive to targeted searches across the GLO Database were reviewed and,
to the extent responsive, were produced to the Inquiry. As part of this review, a number of
documents were identified as responsive but subject to joint legal privilege held by POL and
other entities such as Fujitsu, the Department of Work and Pensions, HM Treasury and BEIS.
These documents were therefore withheld from production until POL had obtained the
6 For example, POL considered on a line-by-line basis the descriptions of each of the files which had been
archived by the Horizon Director, the Horizon Commercial Manager, the Horizon Change Control Manager
and certain secretarial / support staff who appeared to have filed materials relating to Horizon around the
time of the roll-out.
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consent of the relevant privilege holder to produce copies to the Inquiry. Once this consent
was obtained, all documents identified as relevant were produced to the Inquiry.
Request No. 9 — Search Terms
Repositories Searched: GLO Database
Date Range: 1995 — 2000. Please note that, due to the limited metadata available, it was
not always possible to refine searches by reference to the date field in Relativity.
Search Terms:
« Request 1: Document located in hard copy — no electronic searches conducted.
e Request 2: Document located in hard copy — no electronic searches conducted.
« Request 3: Document located in hard copy — no electronic searches conducted.
« Requests 4 and 5:
1. (“risk" wi2 “register') AND ("/CL" wi2 “path*") AND ("procurement" wl2
“authority") AND "horizon"
(“risk" wi2 "register’) AND ("ICL" w/2 "path*")
“risk" w/2 "register") AND ("pathway" w/2 "proposal")
"ECCO" wi5 ("RISK" wi2 "REGISTER")
"path*" wi5 ("risk" wi2 "manager')
isk management database"
"risk" AND ("register or "report" or "proposal") AND "1996"
N Oar wn
« Request 6: Document located in hard copy — no electronic searches conducted.
« Request 7:
1. ("ICL" wi2 “Pathway") AND ("respon*" w/3 "tender’) AND "horizon"
("invitation to tender’) AND ("/CL" w/2 “Pathway")
"Dick" AND "horizon" AND "tender"
"DICK" AND ("respon*" w/3 "tender’)
"Service provider solutions document"
Document Title:
"Solution Summary"
"DICK" AND "BID" AND "PRICE"
"Service provider" AND "dick" AND NOT ("dick" w/2 "long")
9. "DSS/POCL procurement opportunity" AND "1996"
10. "Dicks" AND "bia"
11. "pathway response to OJEC notice 94/s 165-58937/EN"
12. "94/s 165-58937/EN"
13. "pathway response" AND "1996"
PNOAAE OWN
« Request 8:
1. "Procurement Authority"
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Request No. 9 — Search Terms
2. “Procurement! wi2 "Authority"
3. "PDA" AND "Pat Kelsey"
4. ("Procurement' w/1 "Authority") AND “project board"
« Request 9:
1. "Project Management Board" AND ("1995" or "1996")
2. "Project Management Board"
« Request 10:
1. "authorities agreement"
2. "DSS VERSION 5.0"
3. "POCL SERVICE ENVIRONMENT"
4. "DSS Agreement" AND "Schedule" AND ("Restricted" w/3 "Contracts")
5. "POCL Agreement" AND "Schedule" AND (""Restrictea" w/3 "Contracts") AND
"Ko?"
6. “authorities agreement’ AND ("15 May" or "15/05" or "15.05" or "15th May")
("15 May" or "15/05" or "15.05" or "15th May") AND "/CL" AND ("POCL" or
"Post Office Counters Limited") AND ("DSS" or "Department for Social
Security") AND ("agreement" or "contract') AND (Document is not responsive
to Search 2 above")
8. "Authorities' Agreement’ AND "Schedule" AND "restricted - contracts"
9. "Authorities Version" AND "15 May 1996"
10. "Authorities Version" AND "Volume Two"
11. "DSS Version" AND "15 May 1996"
12. "Authorities' Agreement’ AND “schedule 1"
13. "Authorities' Agreement’ AND “service environment’ AND "schedule"
14. "Authorities' Agreement’ AND “service environment" AND "schedule"
15. "authorities' agreement’ AND "schedule" wi2 "assumptions"
16. "CR/POL/002"
17. "Service Infrastructure Acceptance Criteria"
18. "Authorities' agreement’ AND "schedule C"
19. "schedule C" AND "operational AND "trial"
e Request 11: See search terms applied for Requests 3 and 4 above
° Request 12:
1. ("horizon" w/10 "replan") AND "February 1997"
"horizon" wi10 "repian"
“no fault" AND "replan" AND "horizon"
("change" w/5 "request') AND ("February" w/10 "1997")
"no-fault" AND “re-plan"
aR en
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Request No. 9 —- Search Terms
6. "no-fault"
7. "re-plan" AND "defer" AND "1997"
8. “re-plan" AND "1997"
9. "ICL pathway re-plan proposal"
10. "CCN 105"
11. "re-plan" AND "February 1997"
12. "re-plan" AND "agreement"
° Requests 13 and 14:
1. (“ICL" wi2 "pathway’) AND ("notice" w/2 "default")
("notice" wi2 "default’)
("ICL" wi2 "pathway") AND "notice" AND "Bennett'
("ICL" wi2 "pathway") AND ("authorities" wi2 "agreement')
("ICL" wi2 "pathway") AND ("authorities" w/2 "agreement') AND "Christou"
("authorities" w/2 “agreement') AND "Bennett"
("pathway’ wi2 "group") AND "Bennett' AND "notice"
("pathway" w/2 "group") AND "Bennett' AND "notice" AND ("live" w/2 "trial")
9. ("clause" w/2 "603")
10. "CCN" AND ("Bennett' or "Christou")
11. ("breach" wi2 "contract')
12. ("breach" wi2 "contract') AND ("letter" or "notice")
13. ("breach" w/2 "contract') AND "notice" AND "Bennett'
14. ("breach" wi2 "contract') AND "notice" AND ("November" w/2 "1997") AND
"Bennett"
15. ("breach" wi2 "contract') AND "notice" AND ("November" wi2 "1997")
16. "21 November 1997"
17. "21 November 1997" AND ("Bennett" or "breach")
18. ("benefits agency" or “default' or "breach") AND "December 1997" AND
"pathway" AND "November 1997"
19. "pathway" AND "PDA" AND "December 1997"
20. "pathway" AND "PDA" AND "December 1997" AND "benefits agency" AND
“trial”
21. "PDA" AND "benefits agency" AND “post office counters" AND "pathway"
AND "live trial" AND "1997"
22. "PDA" AND "benefits agency" AND "post office counters" AND "pathway"
AND "live trial" AND "May 1998" AND "default’
23. “authorities agreement’ AND ("breach" or "default') AND "1997"
24. “authorities agreement’ AND "default" AND "November 1997"
25. "trial" AND "default' AND "November 1997"
26. "trial" AND "default' AND "November 1997" AND “authorities agreement’
OP NAAR HON
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Request No. 9 —- Search Terms
« Request 15:
1. ("Brief or "Report*") AND ("Delivery Authority" or"PDA") AND "Management
Boara"
2. ("Brief" or “Report™") AND ("Delivery Authority’ or "PDA") AND "Project
Director" AND (Document not responsive to Search 1 above)
3. ("Brief" or "Report*") AND ("Delivery Authority’ or "PDA") AND "Steering
Committee" AND (Document not responsive to Searches 1 or 2 above)
4. ("Brief" or “Report*") AND ("Delivery Authority" or "PDA") AND "Project
Board" AND (Document is not responsive to Searches 1, 2 or 3 above)
5. ("Delivery Authority’ or "PDA") AND "Nile" AND (Document is not responsive
to Searches 1, 2, 3 or 4 above)
6. ("Delivery Authority’ or "PDA") AND "Crahan" AND (Document is not
responsive to Searches 1, 2 or 3 above)
« Request 16:
1. "project board" AND ("minutes" w/5 "“meeting") AND ("May" w/3 "1996")
2. "project board" AND ("minutes" w/3 "meeting") AND "June 1996"
3. "project board" AND ("minutes" wi3 "meeting") AND ("1996" or "1997" or
"1998")
4. "project steering committee" AND ("minutes" w/3 "meeting") AND ("1996" or
"1997" or "1998")
"BIIP SteerCo" AND "minutes"
6. "SteerCo" AND "minutes" AND ("1996" or "1997" or "1998")
"Miller' AND "Sweetman" AND "committee" AND "minutes" AND ("1996" or
"1997" or "1998") AND "steer*"
« Request 17:
1. "Minutes" AND "Project Board"
"Post office project board"
“horizon project board"
"board" AND "minutes"
“Programme Board” AND "Minutes"
("Dave Miller" or "Stuart Sweetman") AND "board"
AaPon
« Request 18:
1. "Project Manager" AND ("Customer Accounting and Payment Systems" or
"CAPS")
2. "Report*" AND ("Customer Accounting and Payment System" w/3 "Board") or
("CAPS" wi3 "Board") AND (Document is not responsive to Search 1 above)
3. ("Customer Accounting and Payment System" w/3 "Board") or ("CAPS" wi3
"Board") AND (Document is not responsive to Searches 1 or 2 above)
4. "Project Manager’ AND ("POCL" or "Post Office") AND ("BA" or "Benefits
Agency" or "DSS" or "Department') wi3 "Board" AND ("report*" or "brie" or
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Request No. 9 - Search Terms
“paper or "memorand*") AND (Document is not responsive to Searches 1
or 2 above)
5. ("POCL" or "Post Office") AND ("BA" or "Benefits Agency" or "DSS" or
"Department') wi3 "Board" AND ("report" or "brief" or “paper or
"memorand*") AND (Document is not responsive to Searches 1, 2, 3 or 4
above)
6. ("CAPS Programme Executive team") AND ("report*" or "brief" or "paper" or
"memorand*") AND (Document is not responsive to Searches 1, 2, 3 or 4
above)
« Request 19:
1. "horizon project team"
“horizon project team" w/10 "testing"
"implementation" wi5 "horizon system"
"Horizon" w/10 "live trial"
"Horizon" w/10 "testing"
"David Miller’ w/10 “live trial"
"David Miller’ w/10 "trial"
“Horizon Testing Manager"
"Simon Rilot"
Pp OB NBA WN
« Request 20:
1. "icl pathway proposal"
"icl pathway proposal" AND variation*
"strictly private’ AND “confidential AND "pathway"
"strictly private’ AND "confidential AND "pathway" AND "proposal"
“commercial and contractual proposals"
("acceptance" w/3 "proposal") AND "pathway"
NOP wn
“pathway funding paper"
e Request 21:
1. "24 May 1999" AND ("withdraw*" or "terminat*" or "cancel*")
"24 May 1999" AND ("cance/*" or "terminaf*") AND "sociaf'
"24 May 1999" AND (terminaf*" or "cance! or “withdraw*) AND "DSS"
("DSS agreement" or "authorities agreement’) AND ("May" wi4 "1999")
"DSS agreement’ AND ("May" w/4"1999") AND ("24" wi4 "May")
("24" wi4 "May’) AND "DSS" AND "1997" AND ("withdraw*" or “cancel or
“terminat") AND "agreement' AND "DSS agreement"
Pa Pen
« Request 22:
1. "Heads of Agreement’ AND "1999"
2. "Letter Agreement" AND "Heads of Agreement’ AND "1999"
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Request No. 9 - Search Terms
3. "Letter Agreement" AND "Heads of Agreement’
« Request 23:
1. ("post' w/5 "limited") AND ("/CL" wi2 "pathway") AND ("July" w/2 "1999")
2. ("codified' wi2 "agreement') AND ("July" w/2 "1999")
3. "Under the Letter Agreement Post Office Counters Ltd and ICL Pathway
Limited agreed, inter alia, to replace the Post Office Agreement and the
Authorities Agreement (each as amended under change control procedures)
with a single agreement (the "Codified Agreement") codifying the changes to
those agreements agreed in the Letter Agreement"
"This Codified Agreement is made the 28th day of July, 1999"
"Paul Lam-Po-Tang"
"Gavrelle House"
"Sweetman" AND ("Codified' w/2 "Agreement')
"J Cook" AND ("Codified" w/2 "Agreement")
9. "CA991520"
10. "CA99" AND “schedule”
11. "Schedule A5"
12. "Schedule A6" AND "approach to remedies"
13. "Schedule A&"
14. "Schedule A9" AND "asset transfer"
15. "Schedule 1" AND "POCL Service Environment"
16. "Schedule A2" AND "policies and standards"
17. "Schedule A3" AND "Audit"
18. "Schedule A4" AND "contract management’
« Request 24(a):
1. "variation*" AND "acceptance criteria" AND ("/CL" or “Pathway")
2. "acceptance" AND "variation" AND ("slaughter" or "Bird" or "masons" or
"Christou") AND ("/CL" or "Pathway")
3. "acceptance" AND ("slaughter or "Bird" or "masons" or "Christou") AND
("ICL" or "Pathway") AND (Document is not responsive to Searches 1 or 2
above)
PN
4. ("variation*" or “change*" or "modification*") and "acceptance" AND ("/CL" or
“Pathway") AND ("1998" or "98") or ("1999" or "99")) AND (Document is not
responsive to Searches 1, 2 or 3 above)
« Request 24(b):
1. ("DSS" or "Department of Social Security’) AND ("agreement" or "contract")
AND "terms" AND ("terminat" or "withdraw*") AND (("99" or "1999") or ("98"
or "1998")) AND "Benefits Payment"
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Request No. 9 - Search Terms
2. ("DSS" or "Department of Social Security") AND ("terminat*" or "withdraw*")
AND "terms" AND "DSS Agreement’ AND (Document is not responsive to
Search 1 above)
« Request 24(c) and (d):
1. "privilege*" AND ("June" w/3 "1999") AND ("slaughter" wi2 "may") or "bird" or
"masons"
2. "privilege*" AND ("July" w/3 "1999") AND ("slaughter" w/2 "may") or "bird" or
"masons"
"legal advice" AND ("May 1999" or "June 1999" or "July 1999) AND "privil*"
4. "post office counters" AND “pathway” AND ("May w/2 "1999") AND "advice"
AND "privil*"
“post office counters" AND "pathway" AND "letter agreement" AND "advice"
6. "post office counters" AND "pathway" AND "letter agreement’ AND "advice"
AND "privil*"
7. "post office counters" AND "pathway" AND “letter agreement' AND
("slaughter or "bird")
8. ("non" wi2 “binding") AND "advice" AND "agreement AND ("privil*™ or
"pathway" or "post office")
9. "report' AND "pathway" AND "post office" AND "1999" AND "May" AND
"advice" AND "privil* AND "agreement' AND "legal" AND “execuf*" AND
"fixed payment’
10. "briefing" AND "pathway" AND "post office" AND "1999" AND ("May" or
"June" or "July") AND "advice" AND "privil*"
11. "fixed payment’ AND "post office" AND "pathway" AND ("letter agreement’
or "heads of agreement’)
12. "post office" AND "pathway" AND "heads of agreement"
13. "codified agreement’ AND (("May" wi2 "1999") or ("June" wi2 "1999") or
("July" wi2"1999")) AND "privit™"
14. "codified agreement" AND ("July" wi2 "1999") AND "privil*" AND "advice"
15. "privilege*" AND "delay*" AND "acceptance" AND "advice" AND "si/aughter’
AND "horizon" AND "confidential"
Productions
10.12 An initial set of responsive documents was produced to the Inquiry on 11 February 2022,
with supplemental productions on 18 February 2022 (relating to requests 15 — 19 and 24), 4
March 2022 (Fujitsu joint privilege documents), 8 April 2022 (BEIS and DWP documents)
and 5 May 2022 (Treasury documents). Further responsive documents were also produced
on 6 May 2022.
10.13 Across the various productions that include documents responsive to this request, POL
produced a total of 1,033 documents.
10.14 It is possible that further documents may be located in other hard copy repositories which
are being searched. However, this is uncertain due to the date of creation of the documents
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requested. Applying POL's seven-year retention of documents policy, and even assuming
that the documents would have been within scope of the litigation stop notice issued in 2014,
many of the documents which existed in hard copy from this period are likely to have been
lost or destroyed in the usual course of business prior to the notice being issued.
Furthermore, in as far as the documents requested were ever held electronically, then it is
unlikely that they were migrated to POL following its separation from RMG in 2012 as many
employees who had been involved in creating and handling these documents were likely to
have left POL's employment and therefore not be caught in the harvesting of POL documents.
described in the main body of this statement.
11. RULE 9 REQUEST No. 10 (18 FEBRUARY 2022) — DOCUMENTS AND INFORMATION RELEVANT TO
PHASES 2 AND 3
11.1 By its Request No. 10, the Inquiry sought various documents and information relevant to
Phases 2 and 3 of the Inquiry's proceedings. In particular, the Inquiry sought documents /
information under the following headings / themes:
11.1.1. Horizon Implementation (Requests 1 to 4);
11.1.2 Modifications (Requests 5 to 11);
11.1.3 Training (Requests 12 to 15);
11.1.4 Advice and Assistance (Requests 16 to 20);
11.1.5 Resolving Disputes (Requests 21 to 24);
11.1.6 Recording, Reporting and Fixing Bugs, Errors and Defects (Requests 25 to 26);
11.1.7 Privileged Access Rights (Requests 27 to 28); and
11.1.8 I Assurance (Request 29).
11.2 The Inquiry requested that POL provide a response in respect of Requests 1 - 4 and
Requests 25 — 29 by 18 March 2022, with a response due in respect of the balance of the
requests by 15 April 2022.
Requests with a deadline of 18 March 2022
11.3. POL sought to identify documents responsive to this request by a combination of (i) reviewing
known documents (including liaising with Peters & Peters and WBD in relation to the same)
with a view to identifying an initial list of potentially responsive materials and (ii) devising and
conducting targeted searches across various repositories and manually reviewing
documents that were responsive to those searches.
11.4 In order to identify an initial list of potentially responsive materials, and on the basis that the
issues captured by the Request No. 10 were also the subject of disclosure in the Group
Litigation, POL reviewed each of the Horizon Issues and Common Issues Trial Bundles, as
well as each of the witness statements and expert reports prepared in those proceedings,
both to identify whether the documents were responsive and should be disclosed to the
Inquiry and to identify further materials of potential relevance referred to within those
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documents. POL has produced to the Inquiry all relevant documents identified through this
process.
11.5 A summary of the targeted searches that POL has conducted to identify documents
responsive to Requests 1 — 4 and Requests 25 — 29 is set out below, in each case including
a description of the keyword search terms that were applied and the repositories across
which these searches were conducted. In large part, due the specific nature of the requests
and challenges with identifying individuals at POL who would be likely to hold key responsive
materials, the searches were conducted over the entirety of or significant portions of the
GLO, CCRC and Inquiry Workspaces, rather than being focused on the mailboxes of specific
individuals. All documents that were responsive to these searches were then manually
reviewed and, where relevant, produced to the Inquiry (subject to privilege).
11.6 Certain of the documents contained material that was subject to legal professional privilege
and had accordingly been produced to the Inquiry in redacted form.
No. I Request Approach
HORIZON IMPLEMENTATION
1 All minutes of the Major Project I « Repositories searched: (i) GLO Database (ii) Postal
Expenditure Committee in museum documents and (iii) Oasis documents®
which Horizon / the Pathway
Date R : N/A
Project are mentioned. * Bale Range
° Search terms:
1. "Major Project Expenditure Committee" wi10
"Horizon" or "Pathway"
2. "Major Project Expenditure Committee" AND
"Minute" or "Meeting"
3. "MaPEC" w/10 "Horizon" or "Pathway"
4. "MaPEC" AND "Minute" or "Meeting"
5. "Counters Major Project Expenditure
Committee" w/10 "Horizon" or "Pathway"
6. "Counters Major Project Expenditure
Committee" AND "Minute" or "Meeting"
7. "“ComPEC" wi10 "Horizon" or "Pathway"
8. "ComPEC" AND "Minute" or "Meeting"
2 All minutes of the Horizon Post I * Repositories searched: (i) GLO Database (ii) Postal
Implementation Review museum Documents (iii) Oasis Documents’
Committee.
6 In addition to conducting this Search 1 over the GLO Database and the materials collated from Oasis and
the Postal Museum archives, POL also arranged for these searches to be conducted over a CD provided
by a member of the POL IT Team, containing various historic POL data and records.
7 As above in the case of Request 1 - Search 1, this search was also conducted over the data stored on the
CD provided by the POL IT Team.
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No. I Request
Approach
Search 2
Date range: 1999 — 20218
Search terms:
o “Horizon Post
Committee"
o ="HPIRC"
o "PIR" AND "1999"
o "PIR" AND "2000"
o "PIR" AND "2001"
Implementation Review
° "Horizon" AND "Review Committee"
Repositories searched: GLO Database
Date Range: N/A
Search terms:
o = “HPIRC” AND "Minute"
o “HPIRC” AND "Meeting"
o ="PIR’ AND “1999” AND "Minute"
o “PIR” AND “2000” AND "Minute"
o “PIR” AND “2007” AND "Minute"
Other search parameters: Search limited to Microsoft
Word and PDF documents only.
3 The Post Office Business
Impact Analysis of Horizon
conducted in August 1999.
Repositories searched: (i) GLO Database, (ii) Postal
Museum Documents, (ili) Oasis Documents
Date range: August 1999 —- December 1999
Search terms:
o “Business Impact Analysis" AND "Horizon"
o “Impact Analysis" AND "Horizon"
4 Any internal audit reports on
Horizon during the period 1999
— 2002.
Repositories searched: (i) GLO Database (ii) Postal
museum Documents and (iii) Oasis Documents °
Date range: 1999 — 2002
Search terms:
Due to the limited metadata available for hard copy documents located at the Oasis and Postal Museum
archives, it was not possible to search these materials by reference to a specific date range. Accordingly,
this search was conducted across the entire suite of Oasis and Postal museum documents, rather than
simply those falling within the relevant date range.
As above in the case of Request 1 — Search 1 and Request 2 - Search 1, this search has also been
conducted over the data stored on the CD provided by the POL IT Team.
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No. I Request Approach
o “audit report" w/10 "Horizon"
o "Audit" w/10 "Horizon"
o “review" w/10 "Horizon"
o “report' w/10 "Horizon"
o "analysis" w/10 "Horizon"
o “assessment' w/10 "Horizon"
o “assurance" w/10 "Horizon"
RECORDING, REPORTING AND FIXING
Bucs, ERRORS AND DEFECTS
produced by POL, Fujitsu or a
third party) relating to ... th
Calendar Square Bug.
e
25A I Any reports, records or I Search 1
investigations (whether e Repositories searched: (i) CCRC Database and (ii)
produced by POL, Fujitsu or a Inquiry Database
third party) relating to ... the
Receipts and Payments Mis-I* Date range: N/A
match Bug. * Search terms:
o "PC0204263" or "PC0204765" or
"PC0203864"
Search 2
e Repositories searched: (i) GLO Database
° Date range: N/A
* Search terms:
o "PC0204263" or "PC0204765" or
"PC0203864"
25B I Any reports, records or I Search1
investigations (whether
Repositories searched: (i) CCRC Database and (ii)
Inquiry Database
Date range: N/A
Search terms:
"PC0126042" or "PCO126376" or
"PC0103864" or "PCO116670" or
"PC0075892" or "PC0083101" or
"PC0086212" or "PC0193012"
°
Search 2
Repositories searched: (i) GLO Database
Date range: N/A
Search terms:
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No. I Request Approach
o ="PC0126042" or "PC0126376" or
"PC0103864" or "PCO116670" or
"PC0075892" or "PC0083101" or
"PC008621 2" or "PC0193012"
25C I Any reports, records or I Search1
esas p (whether * Repositories searched: (i) CCRC Database and (ii)
Produced’ by POL Fullisy or a Inquiry Database
third party) relating to ... the
Suspense Account Bug. e Date range: N/A
° Search terms:
o "PC0223870"
Search 2
e Repositories searched: (i) GLO Database
° Date range: N/A
* Search terms:
o "PC0223870"
25D I Any reports, records or I Search 1
investigations p (whether I, Repositories searched: (i) CCRC Database and (ii)
produced by OL, ‘ujitsu or a Inquiry Database
third party) relating to ... the
Daimellington Bug. ° Date range: N/A
* Search terms:
o "PC0246949" or "PC0247207"
Search 2
e Repositories searched: (i) GLO Database
° Date range: N/A
o "PC0246949" or "PC0247207"
25E I Any reports, records or I Search1
investigations (whether
produced by POL, Fujitsu or a
third party) relating to ... the
Data__Tree Build __ Failure
discrepancies.
e Repositories searched: (i) CCRC Database and (ii)
Inquiry Database
* Date range: N/A
* Search terms:
o ="PC0033128" or "PC0132133" or
"PC0144386" or "PCO121925" or
"PC0123319" or "PC0046811" or
"PC0055964" or "PC0058161"
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No. I Request Approach
Search 2
e Repositories searched: (i) GLO Database
° Date range: N/A
e Search terms:
o ="PC0033128" or "PCO132133" or
"PC0144386" or "PCO121925" or
"PC0123319" or "PC0046811" or
"PC0055964" or "PC0058161"
25F I Any reports, records or I Search1
investigations (whether I, Repositories searched: (i) CCRC Database and (ii)
produced by POL, Fujitsu or a
. . Inquiry Database
third party) relating to
Phantom Transactions. * Date range: N/A
* Search terms:
o "PC0065021" or "PC0065021" or
"PC0052025"
Search 2
* Repositories searched: (i) GLO Database
e Date range: N/A
* Search terms:
o "PC0065021" or "PC0065021" or
"PC0052025"
26 Any reports, records or reviews I See above — "Search 1 for Request 25A to 25F". These
(whether produced by POL, I searches were also conducted over the entire GLO
Fujitsu or a third party) relating I Database, and responsive documents were manually
to the rectification of the bugs, I reviewed.
errors or defects identified at
Question 25.
PRIVILEGED ACCESS RIGHTS
27 I Any reports, records orIe Repositories searched: (i) CCRC Database, (ii)
investigations which address Inquiry Database and (iii) GLO Database
the extent of permissions or * Date range: N/A
privileged access rights Sale range:
granted to Fujitsu personnel. ° Search terms:
o ("permission*" or "access right" or
"privileged user" or "access privilege"
or "remote access") AND ("balancing
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No. I Request Approach
transaction" or "BT") AND ("software
support centre" or "SSC") AND "99.12"
0 ("access right" or "privileged user" or
“access privilege" or "remote access")
AND "BRDB" AND ("session data" or
"transaction data")
28 I Any briefings, reports or other Ie Repositories searched: (i) CCRC Database, (ii)
records relating to changes Inquiry Database and (iii) GLO Database
which were made to the © Date range: N/A
permissions or _ privileged Pate range:
access rights granted to Fujitsu I * Search terms:
personnel as a result of or in co "PC0208119"
connection with PEAK
PC0208119. o "PEAK" wi10 "0208119"
o "208119"
ASSURANCE
29A I Any audit or assurance reports I Search 1,
produced after the adoption of I, Renositories searched: (i) CCRC Database, (ii)
Horizon which addressed ... Inquiry Database, (iii) GLO Database
the existence _and_extent_of
bugs, errors and defects _inI* Date range: N/A
Horizon. * Search terms:
29B I Any audit or assurance reports o ("Audit Report" or "Assurance Report’)
produced after the adoption of w/10 ("Horizon" or "HNG*")
Horizon which addressed ... I. Other search parameters: Search limited to
the ability of bugs, errors and Microsoft Word, PDF and Powerpoint documents.
defects to cause shortfalls and
discrepancies _in___branch I Search 2
accounts. —
~~ e Repositories searched: (i) CCRC Database, (ii)
29C I Any audit or assurance reports Inquiry Database and (ili) GLO Database
produced after the adoption of I, Date range: N/A
Horizon which addressed ...
the extent to which shortfalls I* Search terms:
were caused by bugs, errors o "Internal Audit and Risk Management’
and defects in Horizon. w/10 "report" or "audit or "review" or
“executive summary" or "investigation"
29D I Any audit or assurance reports or "briefing" or "presentation")
produced after the adoption of
Horizon which addressed ...I* Other search parameters: Search limited to
the ability of errors in data entry Microsoft Word, PDF and Powerpoint documents.
and branch accounting
procedures, in data transfer Search 3
and_processing, in_reference
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No. I Request Approach
data and in third party data to I* Repositories searched: GLO Database —
cause discrepancies in branch Custodians: (i) Lesley Sewell, (ii) Mike Young and
accounts. (iii) Rob Houghton 1°
29E I Any audit or assurance reports I* Date range: N/A
produced after the adoption of Ie Search terms:
Horizon which addressed ~ o ("Report" or "Audit" or "Assurance" or
the extent to which such errors " cw Lion a
ey dierramnannine in Investigation") w/10 ("Horizon" or
caused discrepancies in " e
'HNG*")
branch accounts.
29F I Any audit or assurance reports Search 4
produced after the adoption of Ie Mailbox searched: Simon Oldnall
Horizon which addressed ...
Date range: January 2020 to Present
the limited extent of the reports ° y
and transactions data available I * I Search terms:
in branch to SPMs, managers o ("Report" or "Audit" or "Assurance" or
and assistants. "Investigation") w/10 ("Horizon" or
"HING*
29G I Any audit or assurance reports )
produced after the adoption of Search 5
Horizon which addressed ...
the inability of _SPMs, I* Mailbox searched: Horizon IT Team
managers _and_assistants to]. Date range: N/A
access transactions _and_to
identify the causes of shortfalls I* Search terms:
and discrepancies. o ("Report" or "Audit" or "Assurance" or
"Investigation") w/10 ("Horizon" or
29H I Any audit or assurance reports
produced after the adoption of
Horizon which addressed ...
the reliability or robustness of
Horizon and / or the integrity of
its data.
"HNG*")
Search 6
* Mailbox searched: Andrew Perkins "'
° Date range: N/A
° Search terms:
co ("Report' or "Audit" or "Assurance" or
"Investigation") w/10 ("Horizon" or
“HNG*")
10 The GLO Database is filterable by reference to the data that had been harvested in respect of certain
custodians or from certain repositories. For the purpose of conducting this Request 29 - Search 3, POL
arranged for all of the materials that were harvested from each of Lesley Sewell, Mike Young and Rob
Houghton (all former POL Chief Information Officers) in the context of the GLO to be collated and then
arranged for the above search to be conducted across these materials only (rather than the entirety of the
GLO Database).
11 full mailbox harvest has not yet been conducted in respect of Andrew Perkins. However, POL has
harvested a number of documents for which Mr Perkins was the custodian. For completeness, POL has
arranged for this Request 29 — Search 6 to be conducted across these materials.
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Supplemental Reviews
11.7 Following production to the Inquiry on 18 March 2022, POL conducted the following further
search and review exercises in respect of this request.
11.7.1. Postal Museum and Oasis documents: As explained in HSF's letter of 18 March
2022, further searches were conducted at the Oasis and Postal Museum archives,
which POL considered may hold documents relevant to this request. Documents
that were identified as being potentially responsive from a review of and searches
across the relevant indices were scanned and uploaded to Relativity.
11.7.2 For the avoidance of doubt, POL conducted a full manual review of each of the
documents recently collated from the Oasis archives and uploaded onto Relativity
for responsiveness to Request No. 10. To the extent that any of the searches listed
in the above table were conducted over documents collated from the Postal
Museum archives prior to these supplemental materials being uploaded to
Relativity, these searches have been repeated over the more comprehensive set
of Postal Museum documents. All documents that were responsive to the search
terms were manually reviewed, and documents identified as responsive were
produced to the Inquiry.
11.7.3 Technology Assisted Review: In HSF's letter of 18 March 2022, POL explained
that it was considering deploying Technology / Computer Assisted Review in order
to identify any further documents that were responsive to this request (and, in
particular, documents responsive to Requests 25 — 29).
11.7.4. The approach adopted by POL was to identify a core population of key responsive
documents for each of Requests 25 — 29 from the documents produced by POL to
the Inquiry on 18 March 2022. From that core population of documents, POL
deployed functionality within Relativity to identify "clusters" of conceptually similar
documents, over which POL then conducted searches. Documents which were
identified by Relativity as being highly likely to be of a similar type to the core
population of documents were manually reviewed and responsive documents were
produced to the Inquiry.
11.7.5 Documents held by Third Party Advisers: HSF's letter of 18 March 2022
explained that POL had written to each of Deloitte, KPMG and Ernst & Young (each
of which had previously been engaged by POL in various capacities) to request
11174749700_13 53
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that they provide a complete record of the materials prepared during the course of
their respective engagements for POL, as well as copies of the same.
(A) Deloitte: Deloitte provided copies of the documents requested in advance
of the 18 March 2022 deadline, which POL manually reviewed. Responsive
documents were produced to the Inquiry on 18 March 2022.
(B) KPMG: KPMG provided copies of the documents requested on 6 May
2022, which POL manually reviewed. Responsive documents were
produced to the Inquiry on 12 May 2022.
(C) Emst & Young: As explained in HSF's letter dated 12 May 2022, Ernst &
Young has declined to provide the requested information and documents.
11.7.6 Repeated CCRC Searches: As explained in HSF's letter of 14 April 2022, it
became apparent that a substantial volume of materials stored in the CCRC
Database were missing extracted text (with the impact that these documents would
not have been caught by any of the targeted searches that had been conducted
across the CCRC Database). This issue was rectified and all searches previously
conducted over the entire CCRC Database were repeated, and responsive
documents were manually reviewed. Responsive documents were produced to the
Inquiry on 14 April 2022.
In response to a number of the requests listed below (in particular, requests 5, 7, 12, 13, 14,
16, 17, 18, 20, 21, 22 and 23), POL provided a narrative response to the Inquiry, in a number
of cases together with supporting documents. POL has not set out in the below table the
steps that it followed to identify and collate the documents that informed and were produced
with those narrative responses. Please let us know if the Inquiry would be assisted receiving
this information. Where the request was for the provision of documents (specifically, requests
6, 8, 9, 10, 11, 15, 19 and 24), POL sets out the approach it adopted to identify and produce
these materials to the Inquiry.
No.
Request
Approach
MODIFICATIONS
5
Who was responsible for decision-
making in relation to the 2005
IMPACT Programme (“IMPACT”)
Narrative response provided to the Inquiry, together
with supporting documents. Supporting documents
(and documents that informed this narrative response)
were identified as follows:
* Conducting a keyword search for "IMPACT", or
"Impact Programme" or "Improved Accounting"
across the board minutes stored on the Inquiry
Database, and manually reviewing responsive
documents created in or around 2004-2006.
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No. I Request Approach
e Conducting a search for "IMPACT" within the
Horizon Issues Trial Bundle, and manually
reviewing responsive documents.
* Conducting a keyword search for ("IMPACT" AND
"Improved Accounting") across the Inquiry
Database, and manually reviewing a sample of
responsive documents.
e Conducting a keyword search for ("Design
Authority’ AND “IMPACT") across the Inquiry
Database, and manually reviewing responsive
documents.
e Conducting keyword searches for ("Saunder
Narayan" AND “IMPACT") or ("Torstein
Godeseth" AND "IMPACT") across the Inquiry
Database, and manually reviewing responsive
documents.
* Conducting an interview with Andrew Perkins
(POL).
6A IThe following documents of I Repositories searched: (i) Inquiry Database, (ii) GLO
relevance to IMPACT: Database
Any reports or _ briefings I Search terms:
vaio the rationale for I, “mMPACT" wi2 "Programme" AND "report" AND
’ “business case" AND "2005"
* — ("IMPACT" wi2"Programme") AND "Corbett"
6B I Any notes or records of the I Repositories searched: (i) Inquiry Database, (ii) GLO
collaborative workshops between I Database
POL, Fujitsu and the Prism Search terms:
Alliance;
« = "IMPACT" AND "workshop" AND "Prism Alliance"
AND "Fujitsu"
6C IThe Conceptual Design I Repositories searched: (i) Inquiry Database, (ii) GLO
documents; Database
Search terms:
¢ ("IMPACT' wi2"Programme") AND "conceptual
design"
6D I Any written consultation or other I Repositories searched: (i) Inquiry Database, (ii) GLO
input obtained from stakeholder
organisations and _ individuals,
such as the NFSP and SPMs;
Database
Search terms:
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No.
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e = ("IMPACT' wi2"Programme") AND "consultation"
AND "NFSP"
e = ("IMPACT" wi2"Programme") AND "consultation"
AND "SPMs"
6E
Any reviews or assessments of the
anticipated or actual effect of
IMPACT upon SPMs;
Repositories searched: (i) Inquiry Database, (ii) GLO
Database
Search terms:
* "IMPACT" AND ("effect' w/5 "SPM")
6F
Any testing completion reports and
/ or post implementation reviews;
Repositories searched: (i) Inquiry Database, (ii) GLO
Database
Search terms:
© "IMPACT" wi2"Programme") AND "completion
report"
¢ — ("IMPACT" wi2 "Programme") AND "post
implementation review"
6G
Any notifications, guidance or
instructions given to SPMs
following the implementation of
IMPACT.
Repositories searched: (i) Inquiry Database, (ii) GLO
Database
Search terms:
© ("IMPACT" wi2"Programme") AND "guidance"
AND "2005"
Who was responsible for decision-
making in relation to the migration
to Horizon Online in 2010.
Narrative response provided to the Inquiry, together
with supporting documents. Supporting documents
(and documents that informed this narrative response)
were identified as follows:
e Conducting a search for "Horizon Online" across
the Horizon Issues Judgment and Horizon Issues
Trial bundle.
* Conducting the following keyword searches
across the Inquiry Database, and manually
reviewing responsive documents:
o “HNG-X Application" w/8 “roll out" (limited to
documents dated 2009 — 2010)
o “joint release authorisation board" AND
“HNG-X" (limited to documents from 2010)
o “Perkins"" AND “Horizon Online" AND
“Acceptance Manager’ AND "2010"
o “HNG-X Acceptance Gateway 4"
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No. I Request Approach
o "HNG-X Programme Manager’ (limited to
documents from 2010)
o “HNG-X Design Authority" (limited to
documents from 2010)
o "POL Acceptance Manager" (limited to
documents from 2010)
o “Post Office Account HNG-X
Reviewers/Approvers Role Matrix"
o “HNG-X Operational Test Plan — Joint
Working Document"
o "HNG-X Capacity Management and
Business Volumes"
o "HNG-X Testing Strategy"
o “HNG-X Release Management Procedure"
o "“HNG-X Generic Acceptance Process"
8 Please provide any reports, notes I Repositories searched: (i) Inquiry Database, (ii) GLO
or briefings addressing: Database
a. the rationale for migration to I Search Terms: See below.
Horizon Online;
b. the problems identified during
the pilot of Horizon Online;
c. the decision to suspend the
high volume pilot of Horizon
Online;
d. the decision to accept and to
roll out Horizon Online.
8A IThe rationale for migration to I Search terms:
Horizon Online. * ("Horizon Online" wi10 "migration") AND
("reduction" wi4 "costs")
* ("Horizon Online" wi10 "migration") AND
“business case"
8B_ I The problems identified during the I Search terms:
pilot of Horizon Online. * “Horizon Online" AND "pilot' AND "red alert"
8C_ I The decision to suspend the high I Search terms:
volume pilot of Horizon Online. © “Horizon Online" AND
AND ("April" w/3 "2010")
ilot' AND "suspen*"
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No. I Request
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8D I The decision to accept and to roll
out Horizon Online.
Search terms:
* "Horizon Online" AND "Release Authorisation
Board" AND "roll out"
9 Any records of consultations or
other input obtained — from
stakeholder organisations and
individuals, such as the NFSP and
SPMs in relation to the migration to
Horizon Online.
Search terms:
* ("Horizon Online" wi10 "migration") AND
“consultation” AND "NFSP"
¢ ("Horizon Online" wi10 "migration") AND
“consultation” AND "SPM"
10 I Any reviews or assessments of the
anticipated or actual effect upon
SPMs of the migration to Horizon
Online.
Search terms:
* ("Horizon Online" wi10 "migration") AND
“assessment' AND "SPM"
¢ ("Horizon Online" wi10 "migration") AND
“review' AND "SPM"
11 Any notifications, guidance or
instructions given to SPMs
following the implementation of
Horizon Online.
Search terms:
* = ("Horizon Online" wi10 "guidance") AND "2010"
* "Horizon Online" AND ("instructions" w/4 "SPM")
* = “Horizon Online" AND "user manual AND
"2010"
TRAINING
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No.
Request
Approach
12
Details of the training given to
SPMs, managers and assistants in
relation to the use and operation of
Horizon since the commencement
of the national roll out. This was
requested to include the following
details:
a. Where, when and by whom
the training was provided;
b. The form, content and duration
of the training;
c. What (if any) provision was
made for additional training if
requested;
d. What (if any) provision was.
made for additional training
when significant changes or
modifications were made to
Horizon;
e. Any changes or improvements.
made in
training.
the provision of
Narrative response provided to the Inquiry, together
with supporting documents.
Documents and Repositories:
POL has conducted a manual review of each of the
following documents:
Mailboxes
The following keyword searches were run over the
mailboxes of the below individuals for Word, PDF,
PowerPoint and Excel documents:
Documents saved on POL's Training SharePoint
Site (Current and Archive);
Documents embedded in POL's Training Library
document;
GLO documents tagged by WBD as responsive to
"Training" and containing the term "Horizon";
GLO documents tagged by WBD as responsive to
"Information available to SPMR" and containing
the term "Horizon";
Documents identified as being potentially relevant
to training in the GLO bundles following a review
of the GLO bundle indices;
Documents relating to training which were
disclosed in the Baker and others v Post Office
Limited (as identified by WBD);
4x CD Roms and hardcopy documents held and
identified by POL employee Andrew Perkins;
Documents provided by POL's Internal Audit team
following a manual review of their index of internal
audits; and
Documents held in the Oasis archives which were
identified following a manual review of the indices.
Alina Lingard
Maree Young
Tracy Marshall
Pam Heap
Anita Turner
Amanda Jones
11174749700_13
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POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No.
Request
Approach
e "Branch Compliance" shared mailbox
e "Land Design Team" shared mailbox
« "Ops Training Design" shared mailbox
1 I (‘job description" or "JD") AND ("QALT" or
"FSA" or "Trainer" or "Adviser’)
2 I ("Horizon" AND "Trainer*") wi/10
“qualification
3 I ("Horizon" AND "Trainer*) w/10 “experience”
4 I "Horizon" AND "Session Brief
5 I "Horizon" AND "Trainer Brief"
6 I "Horizon" AND "Counter Skills Training"
7 I "Horizon" AND "Trainer Pack"
8 I "Horizon" AND "Classroom Trainer Notes"
9 I “Balancing with Horizon"
10 I "National Roll Out" AND "Train*"
11 I "Horizon" w/5 "Operations Manual"
12. I "Horizon" w/10 "Training"
13 I "Horizon" wi10 "Trainer"
13
Details of any guidance, training or
instructions given to those
responsible for delivering training.
Narrative response provided to the Inquiry, together
with supporting documents. Please see the searches
described at Q12 above.
14
Details of the experience and
qualifications of those responsible
for delivering training.
Narrative response provided to the Inquiry, together
with supporting documents. Please see the searches
described at Q12 above.
15
Any reports, reviews or
investigations (produced by POL
or by an external firm on POL’s
behalf) which address the quality
of the training provided to SPMs,
managers and assistants in
Documents and Repositories:
POL manually reviewed each of the following
categories of documents:
e Documents saved on POL's Training SharePoint
Site (Current and Archive)
11174749700_13
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POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Request Approach
relation to the use and operation of GLO documents tagged by WBD as responsive to
Horizon. "Training" and containing the term "Horizon";
« GLO documents tagged by WBD as responsive to
"Information available to SPMR" and containing
the term "Horizon";
Mailboxes
The following keyword searches were conducted over
the mailboxes of each of the following individuals for
Word, Pdf, PowerPoint and Excel documents:
e Alina Lingard
« Maree Young
«Tracy Marshall
« Pam Heap
«Anita Turner
« Amanda Jones
e "Branch Compliance" shared mailbox
* "Land Design Team" shared mailbox
e "Ops Training Design" shared mailbox
1 I "Horizon" AND "Train*" AND "Restructure"
2 I "Horizon" AND "Train*" AND "Review"
3 I "Horizon" AND "Train*" AND "Report"
4 I "Horizon" AND "Train*" AND "Investigation"
5 I "Horizon" AND "Train*" and "Audit"
Keyword searches 1 to 4 resulted in a very large
number of responsive documents. In order to reduce
this number so that the documents could be manually
reviewed, the following further keyword searches
were conducted and only the documents that were
responsive to those searches were manually
reviewed: "Train*" w/10 ("Report' or "Review" or
Investigation").
ADVICE AND ASSISTANCE
11174749700_13 61
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POL00114170ds
Interim Disclosure Statement
27 May 2022
No.
Request
Approach
16
Details of any guidance, training or
instructions given to those
responsible for operating the
Network Business Support
Helpline (“Helpline”) since the
commencement of the national roll
out.
Narrative response provided to the Inquiry, together
with supporting documents.
Current training materials were obtained from the BSC.
training manager (Nigel Davies). Available training
materials from the pre-Separation period were
obtained from Kendra Dickinson and consent was
obtained from RMG for their disclosure to the Inquiry.
The customer service training materials referred to in
the response were obtained from Jo Milton.
To identify Knowledge Base Articles ("KBAs"), as well
as other guidance and_ instruction documents,
searches were carried out over documents disclosed
in the Group Litigation proceedings with the tags
"“NBSC" or "KBAs". POL conducted a keyword search
for "Horizon" or “discrepanc*" or "shortfalf’ and all
keyword responsive documents were manually
reviewed.
A SharePoint site called "NBSC KBA", referred to in
the Annex to POL's letter of 14 April 2022, was also
harvested. POL conducted a keyword search for
“Horizon” or "discrepanc*" or "shortfall" or "transaction
correction", with a date range filter of 01 August 2019
— 01 June 2021. All documents responsive to this
search were manually reviewed.
The text of the current KBAs stored on Dynamics was
exported into an excel spreadsheet. Keyword
searches for "Horizon" or "discrepancy" or "shortfall"
or "transaction correction" were conucted, and the text
of all keyword responsive KBAs was manually
reviewed.
17
Details of the experience and
qualifications of those responsible
for operating the Helpline.
Narrative response provided to the Inquiry, together
with supporting documents.
POL conducted the following keyword searches over
the mailboxes of Kendra Dickinson, Mel Fischer and
Angela van den Bogerd:
* "helpline" w/10 "experience"
= “helpline” wi10 "qualification"
e = "helpline" wl10 "job description"
* = "helpline" wi10 "JD"
e "BSC" w/10 "experience"
© = "BSC" w/10 "qualification"
11174749700_13
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POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Request Approach
e "BSC" w/10 "job description"
© = "BSC" w/10 "JD"
All keyword responsive documents were manually
reviewed.
18 Who has been responsible for I Narrative response provided to the Inquiry, together
producing and reviewing the I with supporting documents.
contents of the Horizon Help tool POL conducted the following keyword searches over
since its Introduction and provide the mailbox of Alina Lingard:
details of their experience and
qualifications. * "Horizon Online Help" AND "responsib*" AND
"experience"
"Horizon Online Help" AND "responsib*" AND
“qualification”
e "Horizon Online Help" AND "responsib*" AND
“job description"
* "Horizon Online Help" AND "responsib*" AND
"yp"
« "Horizon Help" AND "responsib*" AND
"experience"
* "Horizon Help" AND "“responsib*" AND
"qualification"
* "Horizon Help" AND "responsib*" AND "job
description"
* = "Horizon Help" AND "responsib*" AND "JD"
All keyword responsive documents were manually
reviewed.
19 Any reports, reviews or I In relation to the Helpline, POL conducted the
investigations (produced by POL
or by an external firm on POL’s
behalf) which address the quality
of the advice and assistance
provided via the Helpline and / or
the Horizon Help tool.
following keyword searches over the mailboxes of Mel
Fischer, Jo Milton and Angela Van Den Bogerd:
° = "helpline" w/10 "review"
¢ "helpline" w/10 "report"
e = "helpline" w/10 "investigation"
"helpline" w/10 "audit"
* "helpline" w/10 "Barclay partnership"
* "helpline" w/10 "McKinsey"
* "helpline" w/10 "Deloitte"
«© "helpline" w/10 "Brand Biology"
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POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Request Approach
* = "helpline" w/10 "First Friday"
© = "BSC" w/10 "review"
© = "BSC" w/10 "qualification"
* = "BSC" w/10 "investigation"
© = "BSC" w/10 "audit"
e = ="BSC"w/10 "Barclay partnership"
e ="BSC"w/10 "McKinsey"
* "BSC" w/10 "Deloitte"
* "BSC" w/10 "Brand Biology"
© = "BSC" w/10 "First Friday"
All responsive documents were manually reviewed.
The searches were also repeated over the mailbox of
Kendra Dickinson, albeit within five words (w/5) rather
than within 10 words (w/10). All responsive documents
were manually reviewed.
In relation to the Horizon Help tool, POL conducted the
following keyword searches across the mailboxes of
Alina Lingard, Jo Milton and Angela Van Den Bogerd:
e "Horizon Online Help" w/10 "review"
e = "Horizon Online Help" w/10 "report"
e "Horizon Online Help" w/10 "investigation"
* "Horizon Online Help" w/10 "audit"
e = "Horizon Help" w/10 "review"
* "Horizon Help" w/10 "report"
e = "Horizon Help" w/10 "investigation"
* = "Horizon Help" w/10 "audit"
« "Enhanced User Help Support" (Note: This search
was carried out over Angela van den Bogerd's
mailbox only, on the basis that Ms van den Bogerd
had sponsored this discontinued initiative to
update the Horizon Help function).
All keyword responsive documents were manually
reviewed, and responsive documents were produced
to the Inquiry.
20 Details of any other sources of I Narrative response provided to the Inquiry.
advice and assistance available to
SPMs, managers and assistants
11174749700_13 64
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POL00114170ds
Interim Disclosure Statement
27 May 2022
No.
Request
Approach
on the use and operation of
Horizon since the commencement
of the national roll out.
RESOLVING DISPUTES
21A I Who_was responsible, from the I Narrative response provided to the Inquiry.
commencement of the national roll
out, for:
responding to concerns or
complaints about discrepancies
and shortfalls which were reported
to the Helpline;
21B I investigating discrepancies _ or I Narrative response provided to the Inquiry.
shortfalls which could not be
resolved by the Helpline;
21C I undertaking enquiries into I Narrative response provided to the Inquiry.
disputed error notices or
transactions corrections.
22 I Details of their experience and I Narrative response provided to the Inquiry, together
qualifications (to the extent not I with supporting documents.
already covered by Q.17 above). e Repositories: Mailboxes of Alison Clark, Tracy
Marshall and Rod Ismay.
* Search Terms:
"CV" AND (financial service* centre" or
"FSC" or "P&BA" or "product* and branch
account*" or "product* & branch account*")
- "job description" AND (‘financial service*
centre" or "FSC" or "P&BA" or "product*) and
(branch account*" or "product* & branch
account*")
- "JD" AND ("financial service* centre" or "FSC"
or "P&BA" or "product*) AND (branch
account*" or "product* & branch account*")
All keyword responsive documents were manually
reviewed.
23 Details of any guidance, training or I Narrative response provided to the Inquiry, together
instructions they were given. This.
request includes (but is not limited
to) any guidance, training or
instruction concerning:
with supporting documents.
Search 1
« Repositories: Documents disclosed in the GLO
and tagged by WBD for "10. NBSC" or "26. KBAs".
11174749700_13
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POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Request Approach
a. the length and scope of the I Search Terms: "Horizon" or "discrepanc*" or
investigations or enquiries “Shortfall”
which ought to be undertaken; I Search 2
b. the circumstances in which an I « Repositories: Documents disclosed in the GLO
ARQ request for audit data and tagged by WBD for "08. Shortfalls".
ought to be made; * Search Terms: No search terms applied. All
c. the circumstances in which a documents reviewed.
disputed shortfall or I Search 3
discrepancy ought to be! , Repositories: Documents disclosed in the GLO
placed into the central and tagged by WBD for "07.Transaction
suspense account pending Corrections" and "18. Transaction Corrections".
investigation. * Search Terms: No search terms applied. All
documents reviewed.
Search 4
« Repositories: Documents disclosed in the GLO
and tagged by WBD for "13. Suspense Accounts".
* Search Terms: No search terms applied. All
documents reviewed.
Search 5
e Repositories: Mailboxes of Alison Clark, Tracy
Marshall and Rod Ismay
° Search Terms:
- — "train*" w/10 ("shortfall" or "discrepanc*" or
"transaction correction" or "TC" or "error
notice” or "financial service* centre" or "FSC")
- "workshop" w/10 ("shortfall" or "discrepanc*"
or "transaction correction" or "TC" or "error
notice" or "financial service* centre" or "FSC")
- "manual" w/10 ("shortfall" or "discrepanc*" or
"transaction correction" or "TC" or "error
notice" or "financial service* centre" or "FSC")
- "policy" w/10 ("shortfall" or "discrepanc*" or
"transaction correction" or "TC" or "error
notice" or "financial service* centre" or "FSC")
All keyword responsive documents were manually
reviewed.
24 =I Any reports, reviews or I Search1
investigations (produced by POL
or by an external firm on POL’s
behalf) which address the quality
of the investigations undertaken I* Search Terms: "Horizon" or “discrepanc*" or
into dispute shortfalls, “Shortfall
« Repositories: Documents disclosed in the GLO
and tagged by WBD for "10. NBSC" or "26. KBAs".
11174749700_13 66
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POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Request Approach
dist ancit and _ transacti
i creps icles in INSi ion Search 2
corrections. TT
+ Repositories: Documents disclosed in the GLO
and tagged by WBD for "08. Shortfalls".
e Search Terms: No search terms applied. All
documents reviewed.
Search 3
« Repositories: Documents disclosed in the GLO
and tagged by WBD for “07.Transaction
Corrections" and "18. Transaction Corrections".
* Search Terms: No search terms applied. All
documents reviewed.
Search 4
+ Repositories: GLO Database, Mailboxes of Alison
Clark, Tracy Marshall, Rod Ismay and Jessica
Madron.
* Search Terms:
- (“investigation" or "report" or "review") w/10
“relationship manager"
- ("investigation" or "report" or "review") w/10
"FSC"
- ("investigation" or "report" or "review") w/10
"P&BA"
- (“investigation or "report" or "review") w/10
"transaction correction"
- ("investigation" or "report" or "review") w/10
“Business Support"
- ("investigation" or "report" or "review") w/10
"financ* service* centre"
- (“investigation" or "report" or "review") w/10
"SSRT"
- (“investigation" or "report" or "review") w/10
“product* and branch account*"
- ("investigation" or "report" or "review") w/10
("dispute" w/10 ("discrepanc*" or "shortfall"))
All keyword responsive documents were manually
reviewed and documents responsive to the request
were produced to the Inquiry.
11174749700_13 67
POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
Productions
11.9 Documents responsive to Request 10 were originally produced to the Inquiry on 18 March
2022. Supplemental productions in respect of Request No. 10 were provided to the Inquiry
on 14 April 2022, 29 April 2022, 6 May 2022 and 12 May 2022. Across these productions,
POL has produced a total of 10,284 relevant documents.
12. RULE 9 REQUEST NO. 11 (28 FEBRUARY 2022) — DOCUMENTS REFERRED TO IN BOARD / SuB-
COMMITTEE MINUTES
12.1. By its Request No. 11, the Inquiry sought various documents and information referred to in
the minutes of the POL Board and the Audit, Risk and Compliance Sub-Committee which
were previously produced to the Inquiry. The Inquiry requested that POL provide a
response by 31 March 2022.
12.2 POL has located and produced to the Inquiry the majority of documents responsive to the
request. In some cases, these documents were identified without needing to conduct broad
search and review exercises (including, for example, where documents were located on the
Company Secretary SharePoint). Where POL was unable easily to locate the requested
document or where the request was for multiple documents and initial enquiries /
investigations did not appear to have identified a comprehensive set of responsive materials,
supplemental searches were devised and conducted to address these gaps.
12.3. The below table provides an overview of the supplemental searches that POL conducted
and the repositories over which the searches were conducted. Where POL produced the
requested document to the Inquiry, the relevant production ID is set out below.
No. I Relevant Meeting I Request Approach
1 1 September 2004 I Horizon IT Roadmap Document produced to the Inquiry
POL Board (POL- 0027041)
2 I 23 February 2005 A. Presentation concerning I A. Document produced to the
POL Board the “Next Generation of Inquiry (POL- 0027042)
Retzon B. In order to identify a copy of the
B. Business case that would "Business case" presented at
be presented at the April the April board meeting, POL
board meeting conducted the following
searches across the materials
that have to date been collected
from Postal Museum and Oasis
archives:
- Search Terms: "Horizon"
AND "Next Generation"
AND ("business case" or
"update" or strategy")
- Date Range: N/A
11174749700_13 68
POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Relevant Meeting
Request
Approach
Responsive documents were
manually reviewed and no
responsive documents were
identified.
3 I 19 October 2005
POL Board
Strategy Paper for noting at
the RMG Board meeting in
December 2005
In order to identify and locate a copy
of the "Strategy Paper" for noting at
the RMG Board meeting held in
December 2005, POL conducted
the following searches across all of
the materials that have to date been
collected from the Postal Museum
and Oasis archives:
- Search Terms: "Horizon"
AND ("strategy w/20
("paper" or "update"))
- Date Range: N/A
Responsive documents were
manually reviewed and no
responsive documents. were
identified.
4 I 22 March 2006
POL Risk and
Compliance
Committee
Cotemporaneous documents
which formed the basis of the
update that was provided to
the Committee in relation to
“high value branch losses"
POL produced to the Inquiry a
number of documents in response to
this request. In order to identify
potentially relevant materials, POL
conducted the following searches
across all of the materials that have
to date been collected from the
Postal Museum and Oasis archives:
"Horizon"
wi20
- Search Terms:
AND "strategy"
("paper’ or "update"))
- Date Range: N/A
All responsive documents were
manually reviewed.
As set out in Annex I to HSF's letter
to the Inquiry dated 31 March 2022,
given the limits on the pre-2012
documents to which POL continues
to have access, it seems unlikely
that these documents represent a
complete set of the relevant
documents.
11174749700_13
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POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Relevant Meeting I Request Approach
5 I 20 April 2006 Paper presented to Board I Document produced to the Inquiry
POL Board which would be taken to RMG (POL-0027014).
Board meeting on 27 April
2006
6 I 6September 2006 I A. Contemporaneous A. In order to identify copies of
POL Risk and docuimelits which formed Gentemporaneous documents
Compliance the basis of the update which formed the basis for the
Committee that was provided to the update that was provided to the
Committee in relation to POL Risk and Compliance
"branch audit committee in relation to "branch
diagnostics" audit diagnostics", POL
conducted the following
searches across the materials
that have to date been collected
from the Postal Museum and
Oasis archives:
B. Documents created to
“ascertain if there are any
common profiles"
- Search Terms: ("branch"
w/10 “audit') AND
("diagnostics" or "update")
- Date Range: N/A
Responsive documents were
manually reviewed and no
responsive documents were
identified.
B. In order to identify copies of any
documents created to ascertain
if there are any “common
profiles", POL conducted the
following searches across the
materials that have to date been
collected from the Postal
Museum and Oasis archives:
- Search Terms: ("branch"
w/20 "audit') AND
("financial irregularity" or
"losses" or “common")
- Date Range: N/A
Responsive documents were
manually reviewed and no
responsive documents were
identified.
11174749700_13 70
POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Relevant Meeting I Request Approach
7 I 26 March 2008 Scoping documents prepared I In order to identify and locate copies
POL Risk and in relation to the splitting of I of the requested ‘scoping
Compliance types of former I documents" referred to in the
Committee Subpostmaster losses to I minutes of the 26 March 2008
provide greater clarity I meeting of the POL Risk and
between fraud losses and I Compliance Committee, POL has
other losses. conducted the following search
across the materials that had at that
time been harvested from the Postal
Museum and Oasis archives:
- Search Terms: "postmaster"
AND "losses" AND "fraud"
- Date Range: N/A
Responsive documents were
manually reviewed. One relevant
document was identified and
produced to the Inquiry (POL-
0027833).
As set out in Annex I to HSF's letter
to the Inquiry dated 31 March 2022,
given the limits on the pre-2012
documents to which POL continues.
to have access, it seems unlikely
that this document represents a
complete set of the relevant
documents.
8 I 22 September 2011 I Paper addressing a I Documents produced to the Inquiry
POL Board Technology Update including (POL-0027072 and POL-0027073).
tactical and strategic
relationship with Fujitsu
9 15 March 2012 Paper _ entitled "Horizon I Document produced to the Inquiry
POL Board Update’ (POL-0027074).
10 I 23 May 2012 Noting paper on the Fujitsu I Document produced to the Inquiry
POL Board Services Review of Horizon I (POL-0027075 and POL-0027081).
Online
11 I 21 May 2013 Update on the Horizon I Document produced to the Inquiry
POL Board position with the Second I (POL-0027150).
Sight Review
12 I 25 September 2013 I Horizon Progress Report POL considers that it has located
11174749700_13
nm
POL00114170ds
POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Relevant Meeting I Request Approach
POL Board (and produced to the Inquiry) a copy
of the Horizon Progress Report
(POL-0027548). The search
parameters that were applied in
order to identify this document are
set out below:
- Mailboxes: Susan Crichton
and Chris Aujard
"HNG") AND ("Progress" or
“Report' or "Update")
- Date Range: 15 September
2013 to 25 September 2013
All responsive documents were
manually reviewed.
13 I 19 November 2013 I Notes prepared for or I POL produced to the Inquiry various
resulting from GC update re I documents responsive to this
approach to prosecutions request. In order to identify these
materials, POL conducted the
following searches across the entire
mailbox of Chris Aujard (POL's
General Counsel in November
2013):
ARC Committee
- Search Terms:
“Prosecution” AND
("Policy" or "Approach")
- Date Range: 1 November
2013 - 21 January 2014
All responsive documents were
manually reviewed.
As set out in Annex I to HSF's letter
to the Inquiry dated 31 March 2022,
in some cases, it is not immediately
clear whether these documents are
in fact notes specifically prepared for
or resulting from the update
provided by Mr Aujard, but POL has
nonetheless produced copies of
these documents to the Inquiry.
14 I 27 November 2013 I Progress Report on Project I Document produced to the Inquiry
POL Board Sparrow (POL-0027180).
11174749700_13 72
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POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Relevant Meeting I Request Approach
15 I 11 February 2014 A. Report which outlined the I A. Document produced to the
proposed changes to the Inquiry (POL-0027375).
prosecution policy
ARC Committee
B. Document produced to the
B. Paper explaining the Inquiry (POL-0027193).
most appropriate ways to C. POL produced approximately
communicate . the 400 documents in response to
prosecutions policy the Inquiry's request for all
C. All iterations of the iterations of the prosecution
prosecution policy from policy from 1999 to date. In
1999 (to the extent in order to identify these materials,
POL's custody and the following search was
control) conducted over all of the
materials which POL had at that
time harvested from the Postal
Museum and Oasis archives:
- Search Terms: "Policy"
AND ("Investigat*" — or
“Prosecut™ or “Whistle")
- Date Range: N/A
In addition to conducting
searches across the materials
collated from the Postal
Museum and Oasis archives,
POL also arranged for the
following search to be
conducted across the entire
POHIT and CCRC databases.
- Search Terms:
("Investigat" or
“Prosecut™) w/10 ("Policy")
- Date Range: N/A
- Other parameters: Review
limited to Microsoft Word
and PDF documents only.
All responsive documents were
manually reviewed.
As set out in Annex I to HSF's
letter to the Inquiry dated 31
March 2022, POL is unable to
confirm that it has located all
versions of the prosecution
policy. POL provided in Annex I
11174749700_13 73
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POL00114170ds
Interim Disclosure Statement
27 May 2022
Relevant Meeting
Request
Approach
to HSF's letter to the Inquiry
dated 31 March 2022 a
complete list of the dated
versions of the prosecution
policy which POL has produced
to the Inquiry. POL also
produced a number of draft and
undated policies, as well as
certain other documents which
relate to the prosecution
policies.
16
26 February 2014
POL Board
Report on the challenges
facing the ICRMS
Document produced to the Inquiry
(POL-0027196).
17
26 March 2014
POL Board
A. "Legal
Board
report" to the
B. One page "lessons
learned" document
A. Document produced to the
Inquiry (POL- 0027203).
B. POL considers that it has
located (and produced to the
Inquiry) a copy of the "lessons
learned" document referred to in
the minutes of the POL Board
Meeting held on 26 March 2014
(POL-0027210). The search
parameters that were applied in
order to identify this document
are set out below:
- Mailbox: Belinda Crowe
- Search Terms: "lesson"
AND "learned"
- Date Range: 26 March 2014
— 30 April 2014
All responsive documents were
manually reviewed.
18
30 April 2014
POL Board
Draft Report / Review from
Deloitte (and final version of
the same, to the extent not
produced)
Document produced to the Inquiry
(POL-0027216). This document
was also produced to the Inquiry in
response to Request No. 10.
19
10 June 2014
POL Board
Update on the Sparrow Sub-
Committee
Document produced to the Inquiry
(POL-0027215).
11174749700_13
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POL00114170ds
Interim Disclosure Statement
27 May 2022
No. I Relevant Meeting I Request Approach
20 I 25 June 2014 Update on the ICRMS Document produced to the Inquiry
POL Bosra (POL-0027202).
21 =I 2 July 2015 Paper on the Fujitsu contract I Document produced to the Inquiry
POL Board extension (POL-0027237).
22 =I 15 July 2015 Briefing on Project Sparrow I Document produced to the Inquiry
POL Board for the Chairman (POL-0027239).
23 =I 9 February 2016 Paper addressing the I Document located and produced to
POL Board extension of the Horizon I the Inquiry (POL-0027436).
contract
24 I 19 May 2016 Minutes of a discussion with I Document produced to the Inquiry
ARC Committee external auditors (shown in I (POL-0027288).
separate appendix)
25 I 24 May 2016 Report on the Postmaster I Document produced to the Inquiry
POL Board litigation (POL-0027370).
26 =I 28 March 2017 Project Sparrow Report As set out in HSF's letter to the
POL Board Inquiry dated 31 March 2022, ne
written report was prepared in
advance of the 28 March 2017
meeting of the POL Board in relation
to Project Sparrow, with only a
verbal update provided.
27 =I 18 May 2017 Note circulated by GC I POL considers that it has located
ARC Committee
updating the ARC on the
funding of the Postmasters'
action
and produced to the Inquiry a copy
of the note prepared by the POL
General Counsel (Jane MacLeod) in
relation to the funding of the
Postmaster's action, as referred to
in the minutes of the meeting of the
ARC Committee held on 18 May
2017 (POL-0027300). The search
parameters that were applied in
order to identify this document are
set out below:
- Mailbox: Jane MacLeod
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- Search Terms:
"Postmaster" AND
"Funding" AND "Litigation"
- Date Range: 18 May 2017
— 25 September 2017
All responsive documents were
manually reviewed.
28 I 31 July 2018 Continency planning paper I Document produced to the Inquiry
POL Board Telating to the postmaster I (POL-0027379).
litigation
29 I 20 March 2019 A. Paper setting out the I A. Document produced to the
POL Board
background to recusal
and other issues
B. A phased plan covering
operational, financial and
reputational issues
Cc. A summary of previous
investigations into
Horizon
D. The "critical analysis"
document
Inquiry (POL-0027397).
B. POL has located and produced
to the Inquiry copies of various
documents in response to its
request for a copy of the
“phased plan covering
operation, financial and
reputational issues" (POL-
0027351, POL-0027353 and
POL-0027355). In order to
identify these materials, POL
conducted the following
searches across the entire
mailboxes of (i) Al Cameron
(POL Chief Financial Officer),
(ii) Tim Parker (POL Chairman)
and (iii) Jane MacLeod (POL
General Counsel in March
2019):
- Search Terms: ("phase"
w/10 "plan") or ("operation*"
AND "finance" AND
“reputation*")
- Date Range: 15 March 2019
to 30 March 2019
All responsive documents were
manually reviewed.
C. POL considers that it has
located and produced to the
Inquiry a copy of the note
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summarising the previous
investigations into Horizon, as
referred to in the minutes of the
meeting of the POL Board held
on 20 March 2019 (POL-
0027349). The search
parameters that were applied in
order to identify these materials
are set out below:
- Mailboxes: Jane MacLeod
- Search Terms: ("Summary"
or "Report’ or "Update")
AND "Horizon". AND
("Investigat or "audit' or
“review")
- Date Range: 15 March 2019
to 15 April 2019
All responsive documents were.
manually reviewed.
D. POL has not located a copy the
“critical analysis" document
referred to in the minutes of the
meeting of the POL Board held
on 20 March 2019. In order to
attempt to locate this document,
the following search was
conducted across the entire
mailbox of Jane MacLeod
(POL's General Counsel at the
relevant times and the individual
that was tasked with preparing
the update):
- Search Terms: ("Analysis"
or "Review" or “Improv*")
AND "Postmaster AND
"Horizon"
- Date Range: 20 March 2019
to 1 September 2019
All responsive documents were
manually reviewed.
POL notes that the minutes of
the POL Board meeting held on
20 March 2019 refer to the
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“critical analysis" in the following
terms (at Section 5, Point 6):
“We need to carry out a critical
analysis for ourselves. For
example, what did we need to
do to be the right partner for
Postmasters" [emphasis
added]. It is not clear from this
description whether the “critical
analysis" was in fact prepared.
On the basis that the item was
marked for the attention of Jane
MacLeod (JM), it is likely that a
copy of this document (to the
extent prepared) will have been
sent to or from Jane MacLeod.
As explained above, the
searches that POL conducted
over Jane MacLeod's mailbox
did not result in the identification
of this document.
30
28 May 2019
POL Board
Group litigation update
Document produced to the Inquiry
(POL-0027369).
34
22 September 2020
ARC Committee
“Law and trends" paper
As explained in HSF's letter to the
Inquiry dated 6 April 2022, this
document (POL-0027427) was
subject to legal professional
privilege and had been produced to
the Inquiry in error. That letter
requested that the Inquiry delete this
document from its Relativity platform
and confirmed that POL did not
consider the document to be
relevant to the Inquiry's Terms of
Reference.
32
23 September 2019
POL Board
Paper on the Group litigation
Document produced to the Inquiry
(POL-0027368).
33
29 October 2019
POL Board
Paper on the Group litigation
Document produced to the Inquiry
(POL-0027367). HSF's letter of 6
April 2022 explained that an
updated version of this document
was produced to the Inquiry on 6
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Request
Approach
April 2022, with additional
redactions applied (POL-0027564).
HSF's letter of 6 April 2022
requested that the Inquiry arrange
for the version of this document
provided on 31 March 2022 to be
deleted from its Relativity platform.
34 I 26 November 2019
POL Board
Paper that was before the
Board concerning a group
litigation update
Document produced to the Inquiry
(POL-0027366).
35 I 8 April 2020
POL Board
A. Paper on the post-GLO
Implementation plan
B. Table of criticisms
A. POL located a copy of the post-
GLO implementation plan
referred to in the minutes of the
meeting of the POL Board held
on 8 April 2020. As explained in
HSF's letter to the Inquiry dated
31 March 2022, this document
was authored jointly by Herbert
Smith Freehills and Peters &
Peters, and is subject to legal
professional privilege. This
document has not therefore
been produced to the Inquiry.
B. POL produced to the Inquiry
copies of various documents in
response to its request for a
copy of the “table of criticisms"
referred to in the minutes of the
meeting of the POL Board held
on 8 April 2020. In order to
identify these and other
potentially relevant materials,
POL conducted the following
searches across the entire
POHIT Database:
Search Terms:
- "criticism" AND
"improvement" AND
"lifecycle" AND "agent"
AND "HIJ" AND "CiJ"
- "Adverse comments" AND
“Common Issues
Judgment’
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- “Fraser J" AND "Criticism"
AND "CiJ"
- "Table of criticisms"
"Cls")
AND
AND
"Julie
- ("HiJ" or
"Criticism"
Thomas"
- ("Table" w/5 "Criticism")
Date Range: N/A
The following
conducted across
Database:
search
the
was
HSF
"table"
"Julie"
AND
AND
Search Terms:
riticism" AND
"Thomas"
Date Range: N/a
All responsive documents were
manually reviewed.
36
21 May 2020
POL Board
Correspondence between
Tim Parker and the Minister
Document produced to the Inquiry
(POL-0027586). As explained in
HSF's letter of 6 April 2022, this
document contains redactions for
legal professional privilege.
37
25 June 2020
POL Board
A. Paper on Contracts
Approach
B. Paper on KELS which
was presented to the
Group Executive
A.
. Documents produced to the
Document produced to the
Inquiry (POL-0027380). As
explained in HSF's letter of 6
April 2022, an updated version
of this document was produced
to the Inquiry on 6 April 2022,
with additional ~—_ redactions
applied (POL-0027565). HSF's
letter of 6 April 2022 requested
that the Inquiry arrange for the
version of this document
provided on 31 March to be
deleted from its Relativity
platform.
Inquiry (POL-0027566).
38
30 June 2020
POL Board
A. Paper on
Contract/SPM -
Fujitsu
A.
Document produced to the
Inquiry (POL-0027430).
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B. Paper on Post GLOIB. Document produced to the
Settlement Programme Inquiry (POL-0027430).
Update
39 I 28 July 2020 Paper on post-GLO I Document produced to the Inquiry
POL Board
implementation plan
(POL-0027431).
40 I 27 August 2020
POL Board
Costs Paper relation to the
GLO action
Document produced to the Inquiry
(POL-0027386).
41 I 22 September 2020
POL Board
Post-GLO implementation
plan and _ historical matters
business unit report
Documents produced to the Inquiry
(POL-0027236 and POL-0027238).
42 I 1 October 2020
POL Board
Various papers presented to
the Board
POL has located copies of the
papers that were presented to the
POL Board at the meeting held on 1
October 2020. As explained in
HSF's letter to the Inquiry dated 31
March 2022, these papers were
authored jointly by Herbert Smith
Freehills and Peters & Peters, and
are subject to legal professional
privilege. They have not therefore
been produced to the Inquiry.
43 I 8 October 2020 Paper on de minimis I Document produced to the Inquiry
POL Board payments (POL-0027400).
44 I 19 November 2020 I Business case that was I Document produced to the Inquiry
POL Board provided to BEIS (POL-0027013).
45 I 24 November 2020 I A. Paper concerning I A. POL considers that it has
ARC Committee
suspense accounts
B. All drafts of the KPMG
report referred to in the
minutes which —_ were
shared with POL
produced to the Inquiry a copy
of the paper concerning
“suspense accounts" and
referred to at the meeting of the
ARC Committee held on 24
November 2020 (POL-
0027389). The search
parameters that were applied in
order to identify these materials
are set out below:
- Mailbox: Mark Underwood
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- Search Terms: "suspense"
AND "account" AND
"KPMG"
- Date Range: 10 November
2020 to 24 November 2020
All responsive documents were
manually reviewed.
B. POL produced to the Inquiry the
final version of the KPMG report
referred to in the minutes of the
meeting of the ARC Committee
held on 24 November 2020
(POL-0027391). Whilst POL
has located earlier drafts of this
Report, these drafts are marked
as privileged and have not
therefore been produced to the
Inquiry. The search parameters
that were applied in order to
identify these materials are set
out below:
- Mailbox: Mark Underwood
- Search Terms: ("Suspense
Account Review" AND
"KPMG" AND "Project King"
and "Draft") or ("Statement
of Work" AND "16 October
2020")
- Date Range: 16 October
2020 to 31 January 2021
All responsive documents were
manually reviewed.
46 I 26 January 2021 A. Copy of POL I A. POL produced approximately
ARC Committee Investigations : Policy 260 documents in response to
(together with all the Inquiry's request for all
iterations of the same iterations of the investigations
since 1999 that are within policy from 1999 to date. In
POL's custody and order to identify these materials,
control) the following search was
conducted over all of the
materials which POL had at that
time harvested from the Postal
Museum and Oasis archives:
B. Paper on branch losses
and balances on
Postmaster accounts
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C. Paper on Postmaster - Search Terms: "Policy"
Policies (concerning the AND ("Investigator
policies that had been "Prosecut*" or "Whistle")
proposed to address
points arising from ClJ) - Date Range: N/A
All responsive documents were
manually reviewed.
In addition to conducting
searches across the materials
collated from the Postal
Museum and Oasis archives,
POL also arranged for the
following search to be
conducted across the entire
POHIT and CCRC databases.
- Search Terms:
("Investigat™ or
"Prosecut*") w/10 ("Policy")
- Date Range: N/A
- Other parameters: Review
limited to Microsoft Word
and PDF documents only.
All responsive documents were
manually reviewed.
As set out in Annex I to HSF's
letter to the Inquiry dated 31
March 2022, POL is unable to
confirm whether it has located
all versions of the investigations
policy. For completeness, and in
case of assistance to the
Inquiry, POL also produced a
number of draft and undated
policies, as well as certain other
documents which relate to the
investigation policies.
B. Document produced to the
Inquiry (POL-0027395).
C. Document produced to the
Inquiry (POL-0027570).
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47 I 25 February 2021 A. Letter received from the I A. Document produced to the
POL Board Sook on 23 February Inquiry (POL-0027477).
B. Document produced to the
B. Correspondence sent in Inquiry (POL-0027478).
reply to 23 February 2021
letter
48 I 30 March 2021 A. Paper on Postmaster I A. Document produced to the
ARC Committee policies Inquiry (POL-0027432).
B. Paper on Law & Trends B. Document produced to the
C. Postmaster Complaints ingulry (OE 0027973),
Handling Policy C. Document produced to the
D. Network Transaction ngeipy (POE-002 7406). “
Corrections Policy explained in HSF's letter to the
Inquiry dated 31 March 2022,
E. Network Cash and Stock this is an internal policy which
Management Policy was introduced in 2020/21, such
F. Postmaster Termination that historic versions will not be
Decision Review Policy available.
G. Postmaster Onboarding D. Document Produced to the
Policy Inquiry (POL-0027405). As
explained in HSF's letter of 31
H. Postmaster Training March 2022, this policy was
Policy introduced in 2020/21, such that
lL. Guide to Policy historic versions will not be
Standards for available. In case of assistance
Postmasters to the Inquiry, POL also
: : produced certain related
J. The Whistleblowing documents, including a copy of
Policy the "Transaction Correction
K. All previous version of the Process Overview" (POL-
above policies since 2000 0027503), which provides a
summary of the process for
dealing with Transaction
Corrections prior to the
introduction of the Network
Transaction Corrections Policy,
a copy of the "Overarching
Losses Policy" (POL-0027044),
which was effective from April
2006, along with 7 other
peripherally relevant
documents.
E. Document produced to the
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Inquiry (POL-0027404). As
explained in HSF's letter to the
Inquiry dated 31 March 2022,
this policy was introduced in
2020/21, such that historic
versions will not be available.
F. Document produced to the
Inquiry (POL-0027572). As
explained in HSF's letter to the
Inquiry dated 31 March 2022,
this policy was introduced in
2020/21, such that historic
versions will not be available.
G. Document produced to the
Inquiry (POL-0027407). As
explained in HSF's letter to the
Inquiry dated 31 March 2022,
this policy was introduced in
2020/21, such that historic
versions will not be available.
H. Document produced to the
Inquiry (POL-0027408). As
explained in HSF's letter to the
Inquiry dated 31 March 2022,
this policy was introduced in
2020/21, such that historic
versions will not be available.
1. Document produced to the
Inquiry (POL-0027403). As
explained in HSF's letter of 31
March 2022, POL has also
produced a copy of the
approved version of this
document (POL-0027497).
J. Document produced to the
Inquiry (POL-0027472).
K. POL produced approximately
45 documents in response to
the Inquiry's request for all
iterations of the whistleblowing
policy from 2000 to date,
including a number of policy
documents that had previously
been collated by POL. In order
to identify additional policy
materials from the pre-
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No. I Relevant Meeting
Request
Approach
separation period, the following
search was conducted over all
of the materials which POL had
at that time harvested from the
Postal Museum and Oasis
archives:
- Search Terms: "Policy"
AND ("Investigaf"" or
"Prosecut*" or "Whistle")
- Date Range: N/A
All responsive documents were
manually reviewed.
49 I 18 May 2021
ARC Committee
A. Paper on _ Postmaster
Policies
B. Any update from Tim
Perkins to the Committee
on how the policies were
working in practice
C. Postmaster Contractual
Performance Policy
D. Postmaster Contract
Suspension Policy
E. Postmaster Contract
Termination Policy
F. Accounting Dispute
Resolution Policy
(Revised)
G. All previous versions of
the above policies since
2000
. Document
. POL considers that
. Document
produced to the
Inquiry (POL-0027421).
it has
located (and produced to the
Inquiry) a copy of the update
regarding how the policies were
working in practice, as referred
to at the meeting of the ARC
Committee held on 18 May
2021 (POL-0027448). The
search parameters that were
applied in order to identify these
materials are set out below:
- Mailbox: Tim Perkins
- Search Terms:
“Postmaster” AND "Polic*"
AND ("ARC" or "Audit" or
"Committee")
- Date Range: 18 May 2021
to Present
All responsive documents were
manually reviewed.
produced to the
Inquiry (POL-0027414). As
explained in HSF's letter of 31
March 2022, POL also
produced the previous version
of this policy which was
introduced in the course of 2020
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(POL-0027498).
D. Document produced to the
Inquiry (POL-POL-0027416).
As explained in HSF's letter of
31 March 2022, POL also
produced the previous version
of this policy which was
introduced in the course of 2020
(POL-0027499). In case of
assistance to the Inquiry, POL
also produced a copy of the
Precautionary Suspension
Policy dated 12 October 2012
(POL-0027528).
—. Document produced to the
Inquiry (POL- 0027417). As
explained in HSF's letter of 31
March 2022, POL also
produced the previous version
of this policy which was
introduced in the course of 2020
(POL-0027496). In case of
assistance to the Inquiry, POL
also produced certain related
documents, including —_ the
Resignation to Avoid Summary
Termination Policy dated 17
October 2012 (POL-0027529).
F. Document produced to the
Inquiry (POL-0027415). As
explained in HSF's letter of 31
March 2022, POL also
produced the previous version
of this policy which was
introduced in the course of 2020
(POL-0027500).
G. As explained above (and in
HSF's letter of 31 March 2022),
the above policies were
introduced in 2020/21 such that
no historic versions will be
available.
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Supplemental Searches and Productions
12.4 Following the productions to the Inquiry on 31 March 2022 and 6 April 2022, POL continued
to conduct certain further search and review exercises in respect of the request. A brief
description in relation to these supplemental reviews is set out below.
12.4.1 Postal Museum and Oasis Documents: As explained above in the context of
POL's response to Request No. 10, POL arranged for supplemental visits to be
scheduled to these archives during the course of March 2022 with a view to
identifying further hard copy documents which may be responsive to this request.
12.4.2 All documents identified following the supplemental visits to the Oasis and Postal
Museum archives were scanned and uploaded onto POL's e-Discovery platform.
(A) To the extent that any of the above searches were conducted over
documents collated from the Postal Museum archives, these searches
were repeated over the more comprehensive set of Postal Museum
documents. All responsive documents were manually reviewed, and
documents identified as responsive to the request were produced to the
Inquiry.
(B) POL conducted a full manual review of each of the documents recently
collated from the Oasis archives for responsiveness to Request No. 11.
12.4.3 CCRC Documents: As explained in HSF's letter of 14 April 2022, it became
apparent that a substantial volume of materials stored in the CCRC Database were
missing extracted text (as a result of which these documents would not have been
caught by any of the targeted searches that had been conducted across the CCRC
Database). This issue was rectified and all searches previously conducted over the
entire CCRC Database were repeated, and responsive documents were manually
reviewed. Responsive documents were produced to the Inquiry on 14 April 2022.
12.4.4 On 13 May 2022 KPMG confirmed that, when re-running keyword searches over
the CCRC database following the resolution of the extracted text issue,
approximately 2,000 documents responsive to one of the searches were missed
due to a technical error. POL manually reviewed each of these documents and is
in a position to produce responsive documents to the Inquiry, once it has been
provided with a Quatrix link.
12.4.5 Additional Policy Documents: In HSF's letter of 31 March 2022, POL explained
that, in the case of certain of the policy documents requested under sub-request
48, updated versions of these policy documents had been provided to the Audit,
Risk and Compliance Sub-Committee for approval on 29 March 2022 and that POL
would provide copies once they had been formally approved. POL produced to the
Inquiry copies of each of these newly approved policies on 14 April 2022. POL
separately produced an updated version of the Postmaster Guide to Policies (as
well as the updated Postmaster Support Guide) on 6 May 2022.
Productions
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12.5 Documents were initially produced to the Inquiry on 31 March 2022. Further responsive
documents were produced on 6 April 2022, 14 April 2022, and 6 May 2022. Across these
productions, POL has produced a total of 978 relevant documents.
13. OTHER PRODUCTIONS
13.1 In addition to the disclosures that POL has made in response to Rule 9 requests, POL has
also produced to the Inquiry copies of the documents that have to date been provided by
POL to Paula Vennells via her legal representatives Mishcon de Reya.
13.2 To date, 1,422 documents have been provided to Mishcon de Reya and therefore to the
Inquiry. In large part, the documents that POL has provided in response to requests received
from Mishcon de Reya have been limited to documents which relate to the period of Ms
Vennells' tenure at POL and, in some cases, were identified following targeted searches
across various electronic repositories (including, for example, the mailbox of Paula Vennells).
13.3 As explained in HSF's letter of 23 May 2022, POL has identified a series of meeting minutes
of a Working Group that was established in around 2013 for the purpose of discussing
"Horizon Issues" and anticipates that the content of these minutes will be of interest to the
Inquiry. HSF's letter of 23 May 2022 explained that POL would produce these documents to
the Inquiry following it issuing a Rule 9 request for production of the same.
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SCHEDULE
Rule 9 Request of 26 November 2021
Document Retention and Disclosure Failures
1. Please provide copies of the Advices (in July and August 2013) provided by Simon Clarke to
POL on the subject of POL’s document retention and disclosure failures (‘the Clarke
Advices”).
2. Please provide copies of all communications passing between POL and Cartwright King LLP
relating to the Clarke Advices, including a copy of the instructions to the firm to provide advice
and any correspondence between the firm and POL’s Board of Directors.
Post-Conviction Review and Disclosure
3. Please provide copies of the review and advice on disclosure performed by Brian Altman QC
in October 2013 (“the Altman Review").
4. Please provide copies of any instructions given to Brian Altman QC in his preparation of the
Altman Review. If any instructions were provided in conference, please explain what took
place at these conferences and provide copies of any notes made.
Second Sight
5. Please provide copies of any formal written external legal advice (i.e. from counsel or
solicitors outside) or instructions concerning:
a. The findings of the Interim Report dated 8 July 2013
b. The findings of the Briefing Report Part One dated 25 July 2014;
c. The findings of the Briefing Report Part Two version 1 dated 21 August 2014;
d. The findings of the Briefing Report Part Two version 2 dated 9 April 2015;
e. The decision by POL to terminate the Second Sight investigation; and
f. The decision by POL to request that Second Sight destroy all of the paperwork in their
investigation.
The Group Litigation
6. Please provide copies of any formal written external legal advice (i.e. from counsel or
solicitors outside of POL) or instructions on the strategy for defending the group litigation in
Bates and others v Post Office Limited. In particular, please provide any external advice
given:
a. Atthe time that the litigation was first in contemplation in 2015 or 2016;
b. At the time the Group Litigation Order was made in March 2017;
c. On the approach to be taken and the preparation for the Common Issues trial, including
notes of any conferences with witnesses;
d. On the legal professional privilege asserted in the Common Issues trial;
e. On the application for Mr Justice Fraser to recuse himself;
f. On the approach to be taken and the preparation for the Horizon Issues trial, including
notes of any conferences with witnesses; and
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g. Onthe relevance and POL's control of the Known Error Log.
Board Minutes
7. In the Rule 9 request of 3 November 2021 we requested “all board minutes which relate to
the Horizon IT system”. Please ensure that your response now includes any minutes which
relate to the conduct of litigation (if and to the extent that it did not already do so).
11174749700_13 4