POL00114174ds
POL00114174ds
Second Interim Disclosure Statement
18 October 2022
Annex 2 — Approach for responding to Requests No. 12 to No. 23
1. INTRODUCTION
1.4 The purpose of this Annex 2 is to provide an overview of the approach that POL has adopted
for responding to Requests No. 12 to Request No. 23 inclusive. POL's approach in relation
to Requests No. 1 to Request No. 11 is set out in its First Interim Disclosure Statement dated
27 May 2022.
1.2 Insofar has POL has made supplemental productions in relation to Request No. 1 to Request
No. 11 since the date of the First Interim Disclosure Statement, those supplemental
productions (and the approach POL has adopted in relation to the same) is also addressed
in this Annex 2 (at paragraph 14 below).
2. REQUEST NO. 12
24 By its Request No. 12 dated 31 May 2022, the Inquiry requested that POL produce the
minutes of the Horizon Issues Working Group (the "Working Group") together with copies
of all documents referred to in these minutes. This followed HSF's letter of 23 May 2022, by
which it alerted the Inquiry to the existence of the Working Group and requested that the
Inquiry issue a Rule 9 Request should it wish to receive copies of the same. The Inquiry
requested that POL provide its response by no later than 6 June 2022 (Working Group
minutes) and 28 June 2022 (Documents referred to in Working Group minutes).
2.2 In total, POL has produced 212 documents in response to Request No. 12. Relevant
documents were provided to the Inquiry 6 June 2022, 28 June 2022, 12 July 2022 and 26
August 2022.
2.3 Working Group Minutes
24 On 6 June 2022, POL arranged for copies of the (114) Working Group minutes referred to in
HSF's letter of 23 May 2022 (which minutes had been provided to POL by Womble Bond
Dickinson) to be produced to the Inquiry.
25 On 12 August 2022, HSF wrote to the Inquiry (in relation to Request No. 16), explaining that
it had identified eight further sets of Working Group minutes in the period between July and
November 2013 which had not previously been produced to the Inquiry. These documents
were subsequently produced to the Inquiry on 18 August 2022. HSF's letter of 12 August
2022 also confirmed that POL would conduct further targeted searches and produce any
further Working Group minutes identified (or documents referred to within these minutes) by
no later than 26 August 2022.
26 On 26 August 2022, POL produced one further minute of the Working Group. This document
was identified by reference to the following searches, each of which was conducted over the
GLO Database, the Inquiry Database and the HSF Database:
2.6.1 “Horizon Issue*" AND "attendee*" AND "working group"
2.6.2 "Regular Call re Horizon Issues"
2.6.3 “Horizon Weekly Report"
27 Documents referred to in Working Group Minutes
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Second Interim Disclosure Statement
18 October 2022
28 HSF's letter of 6 June 2022 recorded that copies of the documents referred to in the Working
Group minutes disclosed to the Inquiry on 6 June would be produced to the Inquiry by 28
June 2022. By HSF's letter of 20 June 2022, POL subsequently requested a short extension
to (12 July 2022) for producing certain documents in response to Request No. 12.
2.9 On 28 June 2022, POL arranged for an initial tranche of documents referred to in the Working
Group minutes disclosed on 6 June 2022 to be produced to the Inquiry. Supplemental
productions were subsequently made on 12 July 2022 and 26 August 2022 (including in
respect of the additional Working Group minutes identified and produced to the Inquiry on
18 August 2022 and 26 August 2022).
2.10 Asummary of the searches that POL has conducted in order to identify documents referred
to in minutes of the Horizon Issues Working Group is set out below.
No. Date of Meeting icuments Searches
1 19 July 2013 A. Action Points: "Rob to forward I Search A:
statement template and interim R itory: Rob Ki ilb
measure document to Martin I~ Repository: Rob King malibox
Smith." - Search Terms: All emails sent to
B. Action Points: "Generate a list of Martin Smith
past and current cases - Date Range: 19 July 2013 — 31 July
2013
Search B:
- Repository: Jarnail Singh mailbox,
Rodric Williams mailbox
- Search Terms: "List" AND "Case*"
AND "Horizon"
- Date Range: 19 July 2013 - 31
August 2013
2 I 24 July 2013 Jarnail Singh / Legal: "Confirmed I Search A:
thal Rob Wilson fon Royal Mall has I Repository: Jarnail Singh mailbox
a list of pre separation prosecutions s
and will provide this to Jarnail and the I-__ Search Terms: ("Rob" w/S5 "Wilson")
list will be up to date by nextI- Date Range: 24 July 2013 — 31 July
Wednesdays Meeting." 2013
3 I 31 July 2013 A. Dave Posnett/ Security: Report I Search A: Not applicable. Document
prepared following TORCH visit. I previously produced to the Inquiry.
B. pave Pos ety relen Search B: Not applicable. Document
ose completed a report re .
‘system reversals’ on Horizon. previously produced to the Inquiry.
These system reversals are I Search C:
normal and correct, but on fon f
Horizon and Credence logs these I~ _ Repository: Gayle Peacock mailbox,
reversals show up as ‘existing Rod Ismay mailbox
reversals’, implying that the userI___ Search Terms: "TOR" or "Terms of
has performed the reversal." Reference" ar ”
Reference" or "Brand Forum’
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C. Rod Ismay / FSC: "Mentioned
‘Brand Forum’ ; Paula driving,
Gayle is putting TOR together re
support moving forward".
D. Rod Ismay / FSC: "FO/ request
received from FOI desk (to Andy
Winn) re Horizon issues."
E. Action Points: "Gayle to obtain
list of branches via Wincor where
engineer has visited, to establish
if branches have sustained losses
and if the losses have been made
gooa".
18 October 2022
Searches
- Date Range: 31 July 2013 - 31
August 2013
Search D:
- Repository: Rod
Andy Winn mailbox
Ismay mailbox,
- Search Terms: "FOI*" or ("Freedom"
w/5 "Information") or "Request" AND
"Horizon" or "HNG"
- Date Range: 31 July 2013 - 31
August 2013
Search E:
- Repository: Gayle Peacock mailbox
- Search Terms: "Wincor"
- Date Range: 31 July 2013 - 31
August 2013
4 I 7 August 2013
A. Action Points: "Gayle Peacock
to send out TOR re Branch Loss
Board."
B. Action Points: "Dave Posnett to
email Jarnail with details of the 2
contacts with Investigator and cc
Rodric and Renata, with the
heading ‘Subject To Legal
Privilege’.
Search A:
- Repository: Gayle Peacock mailbox
- Search Terms: "TOR" or "Terms of
Reference" or "Branch Loss Board"
- Date Range: 7 August 2013 — 31
August 2013
Search B:
- Repository: Dave Posnett mailbox,
Jarnail Singh mailbox, Rodric
Williams mailbox
- Search Terms: "Investigator" or
"Subject to legal privilege”
- Date Range: 7 August 2013 — 31
August 2013
5 I 14 August 2013
A. Andy Winn / FSC: "Outlined
branch in Burnham, where
£1,600.00 debt was repaid, but as
branch is on the list a letter has
been sent saying we'll be
returning money subject to
outcome of security review."
B. Action Points: "John Scott to
circulate Wincor list of branches
attended by ATM engineer."
Search A:
- Repository: Andy Winn mailbox
- Search Terms: "Burnham"
- Date Range: 1 July 2013 —- 14 August
2013
Search B:
- Repository: John Scott
(Note: GLO Workspace)
- Search Terms: "Wincor" AND "ATM"
mailbox
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Searches
- Date Range: 14 August 2013 - 14
September 2013
6 I 21 August 2013
A. John Scott: "In addition to the
minutes of each meeting a matrix
document is required to bring all
actions and issues on 1 document
to provide a clear line of sight."
B. Rob King — Security: "Terms of
reference re Branch Loss Board —
sent out by Gail 21/08/13."
C. Action Points: “Email
confirmation of issue to be sent to
group by Steve Beddoe."
Search A:
- Repository: Mailboxes of John Scott
(GLO), Gayle Peacock, Rodric
Williams
- Search Terms: "Horizon" wi2
"Issue*") AND "Matrix"
- Date Range: 21 August 2013 — 31
December 2013
Search B:
- Repository: Gayle Peacock mailbox
- Search Terms: "Branch" AND "Loss"
AND "Board"
- Date Range: 20 August 2013 — 22
August 2013
Search C:
- Repository: Steve Beddoe mailbox
- Search Terms: "Bureau" w/5
"Change") AND "Horizon"
- Date Range: 21 August 2013 - 31
August 2013
7 I 28 August 2013
A. Action Points: "A telephone
conference took place between
AP, the Security team and JS1
Singh re action point list.
Confirming that Matrix drafted."
B. Action Points: "E-top up issues —
AW still investigating and stating
that recovery document going out
(which had already been planned)
with suggested wording to cover
the scenario. AW still
uncomfortable with this."
C. ATM Gluing Case: "MS noting
sentencing coming up but had
requested to put on hold for a
month. Look into ATM visitor book
to inspect which engineers looked
at the ATM and when. Agreed to
keep open."
Search A:
- Repository: Jarnail Singh mailbox
- Search Terms: ("Matrix" or ("Action*"
w/5"List’ or “Point*") — or
"Conference")
- Date Range: 1 August 2013 - 28
August 2013
Search B:
- Repository: Andy Winn mailbox,
Gayle Peacock mailbox
- Search Terms: ("Top-Up" or “Top
Up" or "Top-Ups" or "Top Ups")
- Date Range: 1 August 2013 - 30
September 2013
Search C: Not applicable. This is the
same document searched at 5B above.
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No. Date of Meeting Documents Searches
8 14 September I A. Dave Posnett/ Security: Report I Search A: Not applicable. Document
2013 Prepared following TORCH visit. I previously produced to the Inquiry.
B. ATM Gluing: "Call logs to be I search B:
examined to ascertain if there are
any incidents recorded before I- Repository: Gayle Peacock mailbox,
3.2012 and to identify any John Scott mailbox (Note: GLO
branches visited by engineer." Workspace)
Cc. Foe ue = awaiting paste - Search Terms: “ATM" AND
from Steve. Document produce: " - ” “Loa*"
confirming process. GP has sent Engineer AND Log
to Scott in IT&C." - Date Range: 4 September 2013 - 31
October 2013
Search C:
- Repository: Gayle Peacock mailbox,
Steve Beddoe mailbox (Note: GLO
Workspace)
- Search Terms: (Top-Up’
Up™)
- Date Range: 14 August 2013 — 30
September 2013
or "Top
9 I11 SeptemberIBureau Buy’ Back: "Service I Search A:
2013 Improvement Enhancements List" -
following discussions with Fujitsu, 30
improvements were suggested. - Search Terms: "Service
Improvement" AND "Enhancement"
- Repository: Steve Beddoe mailbox
- Date Range: September 2013
10 I 18 September I E-top up: Recovery booklet Search A:
2018 - Repository: Gayle Peacock mailbox
- Search Terms: "Recovery booklet"
AND "E-top up”
- Date Range: September 2013
11 I 25 September I A. Prestbury: 'Disks' from FJ with I Search A:
jard te rt into a potential A f
2013 trowaction failure. 9 @ potenti - Repository: Gayle Peacock mailbox
B. Nelson: Ditto. - Search Terms: "Prestbury" AND
Issue identified by GP: Data
‘Document dated 2012’, unclear I- Date Range: September 2013
what this relates to. Could be in
respect of suspicion about a I Search B:
member of staff, and a policyI- Repository: Gayle Peacock mailbox
drafted by Alison Drake.
- Search Terms: "Nelson" AND "Data"
- Date Range: September 2013
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Searches
Search C:
- Repository: Rodric Williams mailbox,
Alison Drake mailbox.
- Search Terms: "Suspicion" AND
"Policy"
- Date Range: September 2013
12
23 October 2013
Nelson: ARQ reports - in relation to
cash declaration activity, used to
identify staff fraud.
Search A:
- Repository: Gayle Peacock mailbox
- Search Terms: "Nelson" AND "ARQ"
AND "Report"
- Date Range: October 2013
13
21 August 2013
E-top up: ‘Document produced
confirming process' - sent by Gayle
Peacock to ‘Scott’.
Search A:
- Repository: Gayle Peacock mailbox
- Search Terms: AND
“update"
"E-top up"
- Date Range: August 2013
14 I 30 October 2013 I A. Stock reconciliation: Mention of I Search A:
a report regarding Swindon not SSS .
checking pouches due to them I~ Reposiiory: ul Burke malloay,
lacking Horizon numbers to Horizon IT mailbox, Rod Ismay
crosscheck mailbox
B. Carluke Post Office: Mention of I- Search Terms: "Stock". w/5
attempts to retrieve papers, from “reconcil*") AND “pouch*" AND.
context possibly in respect of "Swindon"
criminal proceedings around
2004, but ‘proving difficult’. Dealt
with by Cartwright King.
- Date Range: October 2013
Search B:
- Repository: Cartwright King Files
AND
- Search Terms: "Carluke"
"2004"
- Date Range: N/A
15
6 November
2013
A. Post & Go: “Steve sent report to
Roger, looks to be operational
practices rather than equipment
Search A:
- Repository: Steve Beddoe mailbox
issues." - Search Terms: ("Post & Go" or "Post
B. Stock reconciliation: and Go" or "P&G")
“Weaknesses highlighted in
report. Scoping with Op team for
a 100% check as at the moment
only check 10%. Issue around
how stock audited and not
Horizon. Report matching data
- Date Range: 20 October 2013 - 6
November 2013
Search B:
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No. Date of Meeting Documents
sets, which is a gap that POL
need to close and have been
aware of since 2008."
C. Lake Post Office: “Rodric
Williams in process of looking at
draft letter, which will go out this
week."
D. Action Points: "Horizon desk call
logs — Anne to discuss with Andy
W on info for all cases"
18 October 2022
Searches
- Repository: Jeff Burke mailbox,
Horizon IT mailbox, Rod Ismay
mailbox
- Search Terms: "Stock" w/5
“reconcil*") AND "“pouch*" AND
"Swindon"
- Date Range: October 2013
Search C:
- Repository: Rodric Williams mailbox
- Search Terms: "Lake"
- Date Range: 1 November 2013 — 20
November 2013
Search D:
- Repository: Anne Allaker mailbox,
Andy Winn mailbox
- Search Terms: (("Horizon" or "HNG")
AND “Log*")
- Date Range: 1 November 2013 — 31
November 2013
16
13
2013
November
Post & Go: Mention of a report being
received by Anne Allaker and Gayle
Peacock.
Search A:
Repository: Gayle Peacock mailbox,
Anne Allaker mailbox, Andrew Wise
mailbox
- Search Terms: ("Post & Go" or "Post
and Go") AND “Report”
- Date Range: November 2013
17
27
2013
November
Lake: Mention of a letter being sent to
solicitors and awaiting approval.
Search A
- Repository; Andy Winn mailbox,
Rodric Williams mailbox
- Search Terms: "Lake" AND "ARQ"
AND "Report"
- Date Range: November 2013
Search B:
- Repository: HF Database
- Search Terms: "Lake" AND
"discrepancy" AND "Horizon"
- Date Range: N/A
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No. Date of Meeting Documents Searches
sending a list of affected ATMs to Rod
Williams.
18 I4 December I Blackhall: Mention of seeking I Search A:
2013 clearance to raise ARQ, and a lack Of I Repository: Rod Ismay mailbox
optimism about reports showing
anything. No further information I- Search Terms: "Blackhall" AND
provided. "ARQ" AND "Report"
- Date Range: December 2013
19 I 15 January 2014 I ATM Gluing Case: Gayle Peacock I Search A:
- Repository: Gayle Peacock mailbox,
Rodric Williams mailbox
- Search Terms: "ATM" w/10 "Glu*"
- Date Range: January 2014
20 I 29 January 2014
Fleckney - DVLA transaction:
Mention of ‘details of investigation’
being sent by Rebecca Barker.
Believed to be in association with a
known error raised in March 2010.
Search A:
- Repository: Anne Allaker mailbox,
Rebecca Barker mailbox
- Search Terms: "Fleckney" AND
"DVLA" AND "Transaction"
- Date Range: 15 January 2014 — 10
February 2014
section references report produced by
Andrew Wise, specifically paragraph
21 I 12 February I Money Gram: Mention of a note I Search A:
2014 about next steps being sent by Craig I _ Repository: Rodric Williams mailbox,
to Nick Beal re this scam. Nick Beal mailbox
- Search Terms: ("Money Gram" or
“Moneygram") AND "losses"
- Date Range: February 2014
22 I 19 February I Oaktree and others: Andrew Wise I Search A:
2014 Teviewing ARQ. No further information I_— Renosito : Andy Winn mailbox
provided.
- Search Terms: "Oaktree" AND
"ARQ" AND "Report"
- Date Range: February 2014
23 I 26 February I Post & Go: Mention of a report that I Search A:
2014 has now been produced and ‘tory: es
ae - Repository: Jarnail Singh mailbox
forwarded to Jarnail Singh.
- Search Terms: ("Post & Go" or "Post
and Go") AND "Report"
- Date Range: February 2014
24 I 19 March 2014 I Post & Go: "New issues identified" I Search A:
- Repository: Andrew Wise mailbox
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Searches
headed ‘Nottingham Crown Office’ I- Search Terms: "Nottingham Crown
which refers to a data loss. Office" AND ("Data" w/5 “loss")
- Date Range: March 2014
25 I 26 March 2014 I Parkstone: Mention of data received I Search A:
from Fujitsu. Gayle Peacock and I _ Repository: Gayle Peacock mailbox,
Anne Allaker set to discuss said data. Anne Allaker mailbox
- Search Terms: "Parkstone" AND
"Fujitsu" AND "Data"
- Date Range: March 2014
26 I 2 April 2014 A. Fleckney — DVLA transaction: I Search A:
Mention of a statement being sent R SRE Al Allak il
to SPM _ stating that Horizon I ~ Repository: Anne Allaker mailbox
system is not at fault. - Search Terms: "Fleckney" AND
B. Blackhall: Andy Winn has sent a "DVLA" AND "Transaction"
recommendation to Rod Ismay. = :
Recommendation is said to be to I — Date Range: April 2014
repay balance to the estate. Search B:
C. Parkstone: Information received I- Repository: Andy Winn mailbox, Rod
from FJ (no mention of what this a
_ Ismay mailbox
relates to), set to be reviewed by
Gayle Peacock. - Search Terms: "Blackhall" AND
"Estate"
- Date Range: April 2014
Search C:
- Repository: Gayle Peacock mailbox
- Search Terms: "Parkstone" AND
"Fujitsu"
- Date Range: April 2014
27 =I 16 April 2014 Davies: Audit undertaken, and I Search A:
mention of a report sent to SPM. - Repository: Gayle Peacock mailbox
Report discusses office being run ina
mess, according to notes. - Search Terms: "Audit" AND "Davies"
- Date Range: April 2014
28 I 30 April 2014 Post & Go: Mention of TA file being I Search A:
los but GaAs answered questions _ Repository: Gayle Peacock mailbox
being raised and circulated. Not clear
what this relates to, or what I- Search Terms: ("Post & Go" or "Post
specifically was circulated. and Go")
- Date Range: April 2014
29 I 7 May 2014 Money Gram fraud: Nick Beal has I Search A:
drafted letter to branches, letters tobe I _ Repository: Nick Beal mailbox
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sent out after contract managers
discuss with branches due to difficulty
of conversation.
18 October 2022
Searches
- Search Terms: "Money Gram" w/15
“Fraud”
- Date Range: May 2014
30 I 14 May 2014 A. Winsor Road: A response has
been sent to SPM, not clear what
this relates to.
B. Esh: Response written to SPM
"confirming nothing found" — not
clear what this relates to.
C. Roman Road: Reference of an
email re Horizon compensation
being forwarded, possibly to
‘Craig’.
Search A:
- Repository: Gayle Peacock mailbox
- Search Terms: "Winsor Road"
- Date Range: May 2014
Search B:
- Repository: Gayle Peacock mailbox
"Esh”
- Search Terms:
- Date Range: May 2014
Search C:
- Repository: Gayle Peacock mailbox
‘oman Road" AND.
" AND ("Horizon" or
- Search Terms:
"HNG")
- Date Range: May 2014
31 I 21 May 2014 A. ATM Gluing Case: Letters
drafted to affected branches,
being circulated to the group to
determine how much information
to provide.
B. Money Gram fraud: Script
produced for calls with branches,
and authority given to proceed.
C. Parkstone: Disk received from
FJ, full investigation taking place.
D. Roman Road: Gayle Peacock to
send information as to
investigation and compensation
received by customer.
Search A:
- Repository: Gayle Peacock mailbox,
Rodric Williams mailbox, Nick Beal
mailbox
- Search Terms: "ATM" w/10 "Glu*"
- Date Range: May 2014
Search B:
- Repository: Gayle Peacock mailbox
- Search Terms: "Money Gram" AND
"Fraud"
- Date Range: May 2014
Search C:
- Repository: Gayle Peacock mailbox
- Search Terms: "Fujitsu" AND
“Parkstone"
- Date Range: May 2014
Search D:
- Repository: Gayle Peacock mailbox
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Searches
- Search Terms: "Roman Road" AND
“Compensat™"
- Date Range: May 2014
32
11 June 2014
A. Post & Go: Mention of an email
from Dave Posnett to Colin
Middleton, regarding final
balance.
B. Money Gram fraud: Response
sent to husband of assistant,
unclear which branch this relates
to, but believed that assistant has
been sacked.
C. Earls Barton: Mention of an audit
report following an audit on 27
May 2014. Report sent to ‘Anita’.
Search A:
- Repository: Dave Posnett mailbox
- Search Terms: ("Post & Go" or "Post
and Go") AND "Middleton"
- Date Range: June 2014
Search B:
- Repository: Gayle Peacock mailbox
- Search Terms: "Money Gram" AND
"Fraud"
- Date Range: June 2014
Search C:
- Repository: Rodric Williams mailbox,
Nick Beal mailbox
- Search Terms: "Earls Barton" AND
"Audit"
- Date Range: 20 May 2014 — 4 June
2014
33
18 June 2014
A. ATM Gluing Case: Reply
received from Alison Bolsover re
letter contents.
B. Post & Go: Camden branch — e-
mail sent to confirm shortage.
C. Money Gram fraud: Middleton —
SPM has written in, challenging
the 5-year repayment plan.
D. Money Gram fraud: Letter from
MP in Westgate Hill (Shadow
Minister for Information Security),
Angela dealing with responding.
Search A:
- Repository: Alison Bolsover mailbox
- Search Terms: "ATM" w/10 "Glu*"
- Date Range: June 2014
Search B:
- Repository: Gayle Peacock mailbox
- Search Terms: ("Post and Go" or
“Post & Go") AND "Camden" AND
“Short*"
- Date Range: June 2014
Search C:
- Repository: Gayle Peacock mailbox
- Search Terms: ("Money Gram" or
"Moneygram") AND "Middleton"
- Date Range: June 2014
Search D:
- Repository: Gayle Peacock mailbox
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No. Date of Meeting Documents Searches
- Search Term: "Money Gram" or
“Moneygram") AND "Westgate Hill"
- Date Range: June 2014
34 I 16 July 2014 Money Gram fraud: Further letter I Search A:
tecelved jon) Weatdate Hill Me, - Repository: Gayle Peacock mailbox
- Search Terms: ("Money Gram" AND
"Westgate Hill"
- Date Range: July 2014
35 I 30 July 2014 A. Money Gram fraud: Letter I Search A:
received from Gordon Brown re
branch, Gayle Peacock drafting
response. -
- Repository: Gayle Peacock mailbox
estgate Hill" AND
B. Wembley: Anne Allaker has sent
information to 'PB and SH' about
something to do with a potential = Date Renae: ‘ly 2014
equipment issue. No _ further I Search B:
information provided.
" Hon provs - Repository: Shirley —_ Hailstones
mailbox
- Search Terms: "Wembley" AND
("equipment" w/10 "fault" or "issue"
or "problem" or "error")
- Date Range: July 2014
36 I 13 August 2014 I ATM Gluing Case: Hillingdon Heath I Search A:
branch — ‘bespoke’ letter sent to
Branch relating to additional claimed
discrepancy to be __ investigated
separately.
- Repository: Gayle Peacock mailbox
- Search Terms: ("ATM” w/10 "Glu*")
AND "Hillingdon Heath"
- Date Range: August 2014
37 I 24 September I Transfer to ATOS: Anne Allaker has I Search A:
2014 compiled a list of requirements to R q 7
- ‘epository: Anne Allaker mailbox
send to ATOS and IT supply and
management team. Aim is to establish I- I Search Terms: ("List" w/10
a route other than an ARQ request. requirements") AND “ATOS'
- Date Range: September 2014
38 I 22 October 2014 I A. ATM Gluing Case: Andy Winn to I Search A:
send a summary of matters to
Anne Allaker and ‘CT’.
B. Edmonds: Dave Evans has been
sent information re ‘wide scale
issues’ by Dave Posnett.
- Repository: Andy Winn mailbox
- Search Terms: "ATM" w/10 "Glu*"
- Date Range: October 2014
Search B:
- Repository: Dave Posnett mailbox
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Searches
No. Date of Meeting
- Search Terms: "Edmonds" AND
- Date Range: October 2014
39 15 November I Post and Go Berry St Edmonds: I Search A:
2014 Dave Posnett to send details to Anne
Allaker regarding ongoing internal
problems, possibly to do with a
freezing issue. - Search Terms: ("Post and Go" or
“Post & Go") AND "Bury St
Edmunds"
- Date Range: November 2014
- Repository: Dave Posnett mailbox,
Anne Allaker mailbox
40 I 14 January 2015 I Post and Go Berry St Edmonds and I Search A:
City of Bath: Crown office branch
reports purportedly completed in
respect of both branches.
- Repository: Dave Posnett mailbox,
Anne Allaker mailbox
- Search Terms: ("Post and Go" or
"Post & Go") AND ("Bury St
Edmunds" or "Bath")
- Date Range: January 2015
41 I 28 January 2015 I Ferndale: Mention of an e-mail from I Search A:
Ibrahim Kilzildag to ‘Kendra’ as to
- Repository’ Kendra Dickinson
losses, and a process document
A oe mailbox
going back to 2010. This is
presumably a reference to Kendra I~ Search Terms: "Ferndale" AND
"Kilzildag"
- Date Range: January 2015
Dickinson.
42/11 February I Great Missenden: Mention of Andy I Search A:
2015 Winn sending a copy ofa reportto Lin I _ Repository: Andy Winn mailbox
Norbury (contract advisor). Report .
relates to Horizon reports not aligning I- Search Terms: "Great Missenden’
AND "Norbury"
- Date Range: February 2015
with one another.
43 I 8 April 2015 A. AP Mismatches: Anne Allaker I Search A:
has drafted an email
- Repository: Anne Allaker mailbox
B. Springfield: 'DP' has seen file
submitted to 'MS' of Cartwright I- Search Terms: ("AP" w/10
King, regarding son of an SPM mismatch™")
who was making fraudulent postal I- — Date Range: April 2015
orders and cashing them to clear
personal debts. Search B:
C. Accounts not clearing to 0: I- Repository: Cartwright King files
Anne Allaker has emailed Andy
Winn about two branches raised,
neither branch named.
- Search Terms: "Springfield" AND
("Post*" w/5 "Order")
- Date Range: N/A
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Second Interim Disclosure Statement
18 October 2022
No. Date of Meeting Documents Searches
Search C:
- Repository: Anne Allaker mailbox,
Andy Winn mailbox
- Search Terms: "Account" w/10
*clear*”
- Date Range: 1 March 2015 — 10 April
2015
44 I 22 April 2015 AP mismatches: Anne Allaker I Search A:
ae roe Ga confirming - Repository: Anne Allaker mailbox
from ATOS. - Search Terms: "IT" AND "ATOS"
Grimethorpe: Anne Allaker has AND "match"
sent information to several people I- —_ Date Range: April 2015
to review in respect of a query
relating to a gain at this branch, I Search B:
pos related to a system /_ Repository: Anne Allaker mailbox
ze.
= - Search Terms: "Grimethorpe" AND
. Second sight report: Report an ery ”
‘ ("Horizon" or "HNG" or "System’
Received, ROL response sent w/10 "freeze" or “error” or "issue" or
"bug" or “error")
- Date Range: April 2015
Search C: Not applicable. Document
previously produced to the Inquiry.
45 I 1 July 2015 Moss Lane: Update email I Search A:
received by pepect ef priors - Repository: Rodric Williams mailbox,
discontinuing case which Trial
was listed for that Monday. POL
could not provide evidence,
hence CPS decision to close.
Click and Collect: "Wendy' has
received communication due to
go out to branches. Andy Winn to
circulate copy of communication
to those on the call.
Anne Allaker mailbox
- Search Terms: "Moss Lane" AND
("CPS" or "Prosecution" or
“Discontinu*")
- Date Range: 1 June 2015 - 1 July
2015
Search B1:
- Repository: Rodric Williams mailbox,
Nick Beal mailbox
- Search Terms: ("Click" w/5
“Collect") AND "Winn"*
- Date Range: 1 June 2015 - 1 July
2015
Search B2:
- Repository: Andy Winn mailbox,
14/77078306_1
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Second Interim Disclosure Statement
No. Date of Meeting Documents
18 October 2022
Searches
Search Terms:
"Collect")
Date Range: 1 June 2015 - 1 July
2015
46
26 August 2015
AP mismatches / SSKs /
Disconnected sessions: Andy Winn
to send Nick Beal and Anne Allaker an
email re SSK not working properly.
Search A:
Repository: Andy Winn mailbox, Nick
Beal mailbox
Search Terms: "SSK" AND (""Issue"
or "Problem" or "Error" or "Bug")
Date Range: August 2015
47
9 September
2015
Cold Norton: Andy Winn has
forwarded an e-mail to Anne Allaker.
No further information provided.
Search A:
Repository: Andy Winn mailbox
Search Terms: "Cold Norton"
Date Range: September 2015
48 I 23 September I Panorama: Detailed letter sent out I Search A:
2015 addressing issues within programme. I _ Repository: Rodric Williams mailbox
Not clear who this letter was sent to,
perhaps senior editors at BBC. - Search Terms: "Panorama" AND
"Horizon"
- Date Range: September 2015
49 I 21 October 2015] A. AP mismatches / SSKs / I Search A:
Disconnected sessions: Anne
Allaker has a 77-page document
in respect of this. Information from
Yeovil branch is not corroborating
with a report from the security
manager.
B. Panorama: Response received
to letter from makers of
programme.
Repository: Anne Allaker mailbox,
Andy Winn mailbox, Nick Beal
mailbox
Search Terms: ("Mismatch*" or
"SSK" or ("sessions" w/5
“connect*")) AND "Yeovil"
Date Range: October 2015
Search B:
Repository: Rod Williams mailbox
"Panorama" AND
Search Terms
"Horizon"
Date Range: October 2015
50
4 November
2015
Panorama: Rod Williams to circulate
draft of new stage complaint.
Search A:
Repository: Rodric Williams mailbox
"Panorama" AND
Search Terms:
"Complaint"
Date Range: November 2015
14/77078306_1
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No. Date of Meeting Documents Searches
51 I 18 November
2015
A. AP mismatches / SSKs /
Disconnected sessions: Anne
Allaker has received an email
from Andy Wise, stating that an
in-depth look into the 2 branches
is needed. Branches not named.
B. Computer Weekly / Outreach
branch: Anne Allaker stating that
a full report is available in respect
of an investigation. Rod Williams
and Nick Beal requesting a copy.
Search A:
- Repository: Anne Allaker mailbox,
Andy Wise mailbox
- Search Terms: ("Mismatch*" or
"SSK" or ("session" w/5 "connect*"))
AND ("branch*" w/5 "2" or "two")
- Date Range: November 2015
Search B:
- Repository: Nick Beal mailbox,
Rodric Williams mailbox
- Search Terms: ("Computer Weekly"
or "Outreach" or "ATOS") AND
“Report”
- Date Range: November 2015
52 I 13 January 2016
Cold Norton: Andy Winn has
produced a 1-page summary and
recommendation. No further
information provided.
Search A:
- Repository: Rodric Williams mailbox,
Andy Winn mailbox
- Search Terms: "Cold Norton”
- Date Range: 1 January 2016 — 13
January 2016
53 I 10 February
2016
AP mismatches / SSKs /
Disconnected sessions: Anne
Allaker and Andrew Wise have sent
reports to Steve Blandfield. Not clear,
but these appear to relate to
investigations into issues and bugs.
Search A:
- Repository: Andrew Wise mailbox,
Anne Allaker mailbox
- Search Terms: "SSK" or ("Connect*"
AND "Session")
- Date Range: 1 January 2016 - 10
February 2016
54 I 9 March 2016 A. AP mismatches / SSKs / I Search A:
Disconnected sessions: R itory: Rodric Will il
Trowbridge branch — Al Engineer I" Repository: ‘odne Williarne mailbox
sent an e-mail following a site visit I- I Search Terms: "SSK" AND
in which statements were "Trowbridge"
misunderstood by the branch to .
mean that ‘switches' can cause I~ Date Range: 1 February 2016 - 9
losses in the branch. March 2016
B. Panorama: Response from BBC I Search B:
editorial complaints received,
rejecting claim that guidelines
have been breached.
- Repository: Rodric Williams mailbox,
Mel Corfield mailbox
- Search Terms: "Panorama" AND
("Editor*" w/5 "Complaint")
- Date Range: 1 February 2016 - 9
March 2016
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No. Date of Meeting Documents Searches
55/2
2016
November
Critchton Avenue: Letter received in
relation to disputes, mentioning
Moneygram. No further information
provided.
Search A:
- Repository: Rodric Williams mailbox
- Search Terms: "Crichton Avenue"
- Date Range: 1 October 2016 - 2
November 2016
56 I 16
2016
November
Crichton Avenue: Rod Williams to
review an email from ‘SH’.
Search A:
- Repository: Rodric Williams mailbox,
Shirley Hailstones mailbox
- Search Terms: "Crichton Avenue"
- Date Range: 1 November 2016 — 16
November 2016
57 I 30
2016
November
Princetown: Statement drafted by
Melanie Corfield, no further
information given.
Search A:
- Repository: Rod Williams mailbox
- Search Terms: "Princetown"
- Date Range: 1 November 2016 — 14
December 2016
58 I 14 June 2017
Horizon System Issues: 'MG' has a
draft version of a report. Possibly a
report requested from FJ, but not
immediately clear. No further
information provided.
Search A:
- Repository: Rodric Williams mailbox,
Martin Godbold mailbox
- Search Terms: "Barcod*" AND
"Fujitsu" AND ("Horizon" or "HNG")
- Date Range: June 2017
59 I 9 August 2017
A. Freeths:
Claimants
B. Freeths: Defence filed - CMC
19! October
Group Register of
Search A:
- Repository: GLO Trial Bundles
- Search Terms: "Group Register" w/5
"Claimant™
- Date Range: N/A
Search B:
- Repository: GLO Trial Bundles
- Search Terms: "Defence" w/5 "Post
Office Limited’
- Date Range: N/A
60 I6
2017
September
Freeths: Letter sent to Claimants
highlighted for the attention of
claimants working in branch.
Search A1:
- Repository: Rodric Williams mailbox,
GLO Trial Bundles
14/77078306_1
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No. Date of Meeting Documents Searches
- Search Terms
("Claimant*" or "Client*" or "SPM'
or "Postmaster*" w/10 "branch")
- Date Range: 1 July 2017-6
September 2017
Search A2:
- Repository: Inquiry Database
- Search Terms: "Freeths"
("Claimant*" or "Client*" or "SPM""
or "Postmaster*" w/10 "branch")
- Date Range: N/A
- Other: PDF documents only
61 I 5 October 2017 I Branch 260246 Smethwick I Search A:
Installation issues: Shirley I_ Repository: Nick Beal mailbox
Hailstones has sent an email
requesting (among other things) I ~ Search Terms: (‘Smethwick or
details of the root cause. 260246") AND "Instal
- Date Range: 1 September 2017 —
31 October 2017
62 I 14 December I Dines Green: Consent to interview I Search A:
2017 form received, Jim Coney may have
sent it to Shirley Hailstones.
Referenced as a ‘potential trap’ by
POL and WBD - Search Terms: "Dines Green" AND
"Consent to Interview"
- Repository: Rodric Williams mailbox,
Shirley Hailstones mailbox
- Date Range: December 2017
63 I 9 March 2018 A. Yammer: Reference to a post I Search A:
regarding a new tech program, ae .
with somebody writing something I~ Repesitory: Helen Dickinson
about "an engineer had said Post mailbox
Office were not installing new kit
because of new problems with it"
— concerns that the wording is
damning. - Date Range: March 2018
B. Rem Issue Email: Email sent re I Search B:
Rem issue caused by amounts in
suspense. Shirley Hailstones I- Repository: Martin Godbold mailbox
sending details to Martin Godbold
- Search Terms: "Yammer" AND
"Post"
- Search Terms: ("Suspense" or
“Rem*") AND ("Issue" or "Problem")
- Date Range: March 2018
64 I 17 May 2018 Computer Weekly: Mention of article I Search A:
that discusses the system issue
14/77078306_1 18
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No. Date of Meeting Documents
affecting c. 2,000 branches and
referencing the ongoing litigation.
18 October 2022
Searches
Repository: Rodric Williams mailbox,
Horizon IT Mailbox
Search Terms:
AND "Horizon"
Date Range: May 2018
"Computer Weekly"
Search B:
Repository: CCRC Database
Search Terms: "Computer Weekly"
AND "May 2018"
Date Range: N/A
65
24 January 2019
Facebook Survey: Nick Beal to send
a link to this survey, survey appears to
have been made by an ex SPMR and
is asking for people's views on
horizon.
Search A:
Repository: Rodric Williams mailbox,
Nick Beal mailbox
Search Terms: "Survey" AND
("Horizon" or "SPM" or "Postmaster"
or "Facebook")
Date Range: January 2019
66
7 February 2019
End user management — Smart IDs:
Mention of an email just being
received, discussing 26 branches
being affected by some sort of issue
which is being addressed by FJ
through a project manager. Julie
Thomas involved in some capacity.
Search A:
Repository: Rod Williams mailbox,
Alison Bolsover mailbox, Martin
Godbold mailbox,
Search Terms: ("Smart" w/5 "ID")
AND ('26" w/5 "branch")
Date Range: February 2019
67 I 21 February I Data cleanse: Mention of two memos I Search A:
ich wi th
2019 which will be out on 8 March and 15! - Repository: Martin Godbold mailbox,
March 2019 respectively. Information Shirley Hailstones mailbox
has also been recorded on dynamic.
- Search Terms: "Data" AND
"Cleanse" AND ("8" or "15")
- Date Range: March 2019
68 I 8 March 2019 End user management — Smart IDs: I Search A:
Reference to an email that morning of
8 March 2019 confirming that 31
branches were now affected.
Repository: Rodric Williams mailbox,
Alison Bolsover mailbox, Martin
Godbold mailbox
Search Terms: "Smart" AND "ID"
Date Range: 1 March 2019 — 10
March 2019
14/77078306_1
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18 October 2022
3. REQUEST NO. 13
3.4 By its Request No. 13 dated 14 June 2022, the Inquiry requested that POL produce a number
of specific documents of relevance to Phase 2 of the Inquiry's proceedings. The Inquiry
requested that POL provide its response by no later than 8 July 2022.
3.2 In total, POL has produced 45 documents in response to Request No. 13. Relevant
documents were provided to the Inquiry on 8 July 2022 and 5 August 2022. Further
productions containing documents relevant to Request No. 13 and Request No. 15 were
provided to the Inquiry on 29 July 2022 (14 documents) and 12 August 2022 (62 documents).
3.3 We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 13. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege). Please note that the below table does not set out the approach
that POL adopted in relation to its response to Questions 21 and 22 of Request No. 13 (which
sought information relevant to Project Emerald). This is dealt with separately at paragraph
3.9 below.
No locum: Search
1 Any notes or minutes of the Search A:
Stuart Team Meetings to which Repository: (i) Inquiry Database and (ii) GLO
POL00028593 (your reference Database
POL-0025075). * Search Terms: "Sweetman" AND "Meeting" AND
("1997" or "1998")
¢ Date range: N/A
Search B:
e Repository: (i) Inquiry Database and (ii) GLO
Database
Stuart" or "Sweetman") AND
("Team Meeting") AND ("1997" or "1998")
° Date range: N/A
Search C:
e Repository: (i) Postal Museum documents
uploaded to Relativity in August 2022
e Search Terms: "prayer*"
« Date range: N/A
2 Letter of 12th December 1997 Search A:
from John Bennett to Peter
Crahan.
© Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("John" or "Bennett") AND.
("Peter" or "Crahan") AND ("December" w/2
"1997")
e Date Range: N/A
3 Letter of 23rd December 1997 Search A:
14/77078306_1 20
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18 October 2022
No. jocument Search
from Peter Crahan to John e Repository: (i) Inquiry Database and (ii) GLO
Bennett. Database
e Search Terms: ("John" or “Bennett") AND
("Peter" or "Crahan") AND ("December" w/2
"1997")
° Date Range: N/A
4 Any notes or minutes of the Search A:
Horizon Project Review Grou = = = .
Moting on ae MoS ooo te : epentely (i) Inquiry Database and (ii) GLO
which reference is made in jatabase
POL00028639 (your reference ¢ Search Terms: "Horizon" AND "Project" AND
POL-0025121)). "Review" AND ("March" w/2 "1998")
e Date Range: N/A
5 The Notice of Cure issued to ICL I Search A:
Pathway in May 1998. * Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Notice" AND ("ICL" or
"Pathway’) AND ("May" w/2 "1998")
e Date Range: N/A
6 Letter from Paul Rich to Adrian Search A:
Montague concerning the ‘ Fe =
oucene of the Treasury Review I ° See (0 Inqutty Ratabase and (if) GLO
(to which reference is made in elabase
POL00028650 (your reference e Search Terms: ("Paul" or "Rich") AND ("Adrian"
POL-0025132)). or "Montague") AND ("1998" or "1999") AND
("Treasury" w/10 "Review")
¢ Date Range: N/A
7 Letter from Terry Austin to Dave I Search A:
Miller dated 10 September 1998 i ‘
(to which “oforenee i Trade in I* Repository (i) Inquiry Database and (ii) GLO
POL00024582 (your reference jatabase
POL-0021061)). e Search Terms: ("Terry" or "Austin") AND ("Dave"
or “Miller") AND ("September" w/2 "1998")
¢ Date Range: N/A
8 Letter from the Chief Secretary Search A:
of the Treasury dated 23 : * : _
December 1998 (fo which * Repository: (i) Inquiry Database and (il) GLO
reference is made in atabase
POL00028606 (your reference ¢ Search Terms: "Chief Secretary" AND "Treasury"
POL-0025088)). AND ("December" w/2 "1998")
« Date Range: N/A
9 Email from Mena Rego to David I Search A:
Miller dated 30 December 1998
concerning the Project Mentors
report (to which reference is
made in POL00038829 (your
Repository: (i) Inquiry Database and (ii) GLO
Database
Search Terms: ("Mena" or "Rego") AND ("David"
14/77078306_1
24
No. Document
reference POL-0027615)).
POL00114174ds
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Second Interim Disclosure Statement
18 October 2022
Search
or “Miller") AND ("December" w/2 "1998")
e Date Range: N/A
10 ICL Pathway's further proposals
concerning acceptance of the
Horizon system dated 9th
December 1998.
Search A:
« Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("ICL" or "Pathway") AND
"Horizon" AND ("December" w/2 "1998")
e Date Range: N/A
1 Letter from Fujitsu Services
Limited to the Prime Minister
dated 7th April 1999.
Search A:
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Term: ‘ujitsu" AND ("Prime Minister" or
"Tony" or "Blair") AND ("April" w/2 "1999")
e Date Range: N/A
12 I All correspondence between
Stuart Sweetman and Peter
Mathison in April 1999.
Search A:
«Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("Stuart" or "Sweetman") AND
("Peter" or "Mathison") AND (“April" w/2 "1999")
e Date Range: N/A
13 I Hamish Sandison’s Advice on
Live Trial sent to Dave Miller
and copied to Vince Gaskell on
16 April 1999 (to which
reference is made in
POL00028405 (your reference
POL-0024887)).
Search A:
«Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("Hamish" or "Sandison" or "Bird")
AND "Advice" AND ("Live" w/5 "Trial") AND
("April" w/2 "1999")
e Date Range: N/A
14 I Any notes or minutes of the
Counter Automation Steering
Group Meeting on 13 April 1999
(to which reference is made in
POL00028618 (your reference
POL-0025100)).
Search A:
* Repository: (i) Inquiry Database and (ii) GLO
Database
¢ Search Terms: "Counter Automation" AND
"Steering Group" AND ("April" w/2 "1999")
e Date Range: N/A
15 I Minutes of the Post Office Board
Meeting on 27 April 1999 (to
which reference is made in
POL00028618 (your reference
POL-0025100)).
Search A:
© Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Post Office" AND "Board" AND
("Meeting" or "Minute") AND ("April" w/2 "1999")
e Date Range: N/A
16 I Minutes of the Post Office Board
Search A:
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22
No.
jocume!
Meeting on 23 May 1999 (to
which reference is made in
POL00028611 (your reference
POL-0025093)).
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Second Interim Disclosure Statement
18 October 2022
Search
Search B:
Search C:
Search D:
Search E:
Repository: (i) Inquiry Database and (ii) GLO
Database
Search Terms: "Post Office" AND "Board" AND
("Meeting" or "Minute") AND ("May" w/2 "1999")
Date Range: N/A
Repository: HSF Database
Search Terms: "minutes of the meeting" or
"PO99" or "PO!
Date Range: 23 May 1999
Repository: HSF Database
Search Terms: "minutes of the meeting” or
"PO99" or "PO!
Date Range: May 1999
Repository: Inquiry Database
Search Terms: N/A
Date Range: May 1999
Repository: GLO Database
Search Terms: ("minutes of the meeting" AND.
May 1999) or ("PO99" AND “May 1999") or
("POB" AND "May 1999")
Date Range: 23 May 1999
17
Memo prepared by Bob Booth
concerning receipts not
matching payments (to which
reference is made in
POL00029131 (your reference
POL-0025613)).
Search A:
Repository: (i) Inquiry Database and (ii) GLO
Database
Search Terms: ("Bob" or "Booth") AND "Receipt"
AND "Payment" AND "1999"
Date Range: N/A
18
The full update on Horizon
which was sent to Stuart
Sweetman for his briefing with
John Roberts on Monday 13th
September 1999 (to which
reference is made in
POL00028462 (your reference
POL-0024944)).
Search A:
Repository: (i) Inquiry Database and (ii) GLO
Database
Search Ter Update” AND "Horizon" AND
("September" w/2 "1999")
Date Range: N/A
19
The bullet point brief prepared
by Bruce McNiven for John
Robert (to which reference is
Search A:
Repository: (i) Inquiry Database and (ii) GLO
14/77078306_1
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Second Interim Disclosure Statement
18 October 2022
No locument Search
made in POLO0028465 (your Database
reference POL-0024947)). * Search Terms: ("Bruce" or "McNiven") AND.
“Acceptance” AND "Horizon" AND "1999"
« Date Range: N/A
20 I Minutes of all meetings of the Search A:
Counter Automation Steering
Group (which have not
previously been provided).
* Repository: (i) Inquiry Database and (ii) GLO
Database
¢ Search Terms: "Counter Automation" AND
"Steering Group" AND ("Meeting"” or "Minute")
e Date Range: N/A
3.4 For the purpose of responding to Request No. 13 (and identifying and producing to the
Inquiry documents relevant to the same), POL has made specific enquiries in relation to
potentially relevant hard copy documents. In particular, POL has considered the relevance
to Request No. 13 of hard copy documents held at the Oasis archives in Winchester and the
Postal Museum. Further details are set out below.
3.5 Oasis
3.6 Following a review of the index of files / boxes held at the Oasis archives in Winchester, POL
identified the following files / boxes which it anticipated may contain material or information
of relevance to Request No. 13. POL subsequently attended the Oasis archives to review
these hard copy files / boxes and, based upon that review, arranged for those files / boxes
that appeared to contain potentially relevant documents to be scanned and uploaded onto
Relativity. The searches set out in the above table were then conducted across these
materials, and responsive documents were reviewed for relevance to the terms of Request
No. 13.
Reference Box Reference tle
1 I FO0001751370 0001562866 Stuart Sweetman
2 I F00001765447 0001562601 Minutes of Review Group (Range)
3 I F00001756356 0001562680 Treasury Review
4 I F00001749125 0001562735 Counters Automation 5
5 I F00001749126 0001562735 Counters Automation 3
6 I F00001749524 0001562766 Automation: BA/POCL Reports & Receipts Review
— Functional Specification
F00001750152 0001562869 Automation 2
8 I F00001751251 0001562852 Automation
9 I F00001755203 0001562609 Automation BA/POCL 1997
10 I F00001756266 0001562695 Automation Management
11 I F00001756688 0001562730 Counter Automation Roll-Out 1990-1991 (Formerly
Group 0583/1990)
12 I F00001757091 0001562950 D6/1 Counter Automation (includes way ahead):
AH74
13 I F00001757095 0001562942 BA97: Counter Automation Steering Group
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14 I F00001758271 0001562957 Automation
15 I F00001758396 0001562958 Automation Committee
16 I F00001759221 0001562750 Counters Automation 4
17 I F00001759222 0001562750 Counters Automation 2
18 I F00001759531 0001562787 Long Term Automation Strategy -— Counter
Automation: 1331
19 I F00001763654 0001562519 Royal Mail and Automation
20 I F00001765394 0001562598 Automation Transformation Programme
21 =I F00001765402 0001562598 Automation Process Group
22 I F00001766541 0001562354 Counters Automation 1
3.7 Postal Museum
3.8 POL wrote to the Postal Museum on 16 June 2022, enquiring as to whether the Postal
Museum held within its archives documents of potential relevance to Request No. 13. Files
identified by the Postal Museum as potentially containing relevant documents were scanned
by Milinet and uploaded onto Relativity. POL then arranged for each of the searches
contained in the above table to be conducted across these materials and for responsive
documents to be reviewed for relevance to this Request No 13. Relevant documents
identified were produced to the Inquiry on 12 August 2022.
3.9 Approach in relation to Questions 21 and 22 (Project Emerald)
3.10 Question 21 of Request No. 23 sought an explanation in relation to a manuscript reference
to "Project Emerald" included in a document that POL had previously produced to the Inquiry
(POL00028603). Question 22 sought an explanation concerning the relevance of this Project
to the Inquiry's Terms of Reference.
3.11. In order to identify documents concerning Project Emerald (and to confirm the extent to which
this Project was relevant to the Inquiry's Terms of Reference), POL conducted the following
targeted searches, and arranged for the manual review of all responsive documents.
Repository Search Terms
1 I (i) Inquiry Database and (ii) GLO Database I "Project Emerald" AND ("1998" or "1999")
AND "Horizon"
(i) Inquiry Database and (ii) GLO Database I "Emerald"
GLO Database "Project Emerald" AND ("1998" or "1999")
AND "Horizon"
4 I (i) Inquiry Database and (ii) GLO Database I "Project Emerald"
3.12 In addition to the above searches, POL also identified the following files / boxes held at the
Oasis archives in Winchester that it anticipated may contain material or information of
relevance to Project Emerald. These files were reviewed, scanned and uploaded onto
Relativity, and subject to a full manual review.
Reference Box Reference Title
F00001750803 0001562821 Project Emerald
2 I F00001768535 0001562495 Project Emerald Development
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Second Interim Disclosure Statement
18 October 2022
3.13 On 5 August 2022, POL arranged for its response to Questions 21 and 22 to be provided to
the Inquiry. This response included a summary of POL's understanding of Project Emerald
and its relevance to the Inquiry's Terms of Reference, as informed by POL's review of
documents responsive to the searches set out at paragraph 3.11 above and the hard copy
files referred to at paragraph 3.12 above. HSF's letter of 5 August 2022 also enclosed the
complete contents of the Oasis file entitled "Project Emerald Development”, in case of
assistance to the Inquiry.
4. REQUEST NO. 14
44 By its Request No. 14 dated 15 June 2022, the Inquiry sought various documents and
information relevant to Phase 4 of the Inquiry's proceedings. The Inquiry requested that POL
provide its response by no later than 15 July 2022. In particular, the Inquiry sought
documents/information under the following headings/themes:
4.1.4 Contractual Liability for Shortfalls (Questions 1 to 16);
4.1.2 Civil case studies (Question 17);
4.1.3 Private Prosecutions (Question 18 to 41); and
4.1.4 Criminal Case Studies (Question 42).
4.2 The Inquiry requested POL provide responses by 15 July 2022. The Inquiry subsequently
granted the following extensions:
4.2.1 to 29 July 2022 with respect to Question 42;"
4.2.2 to 12 August 2022 with respect to Question 17 to 41; and
4.2.3 to 19 August 2022 with respect to Question 1 to 16.
43 In total, POL has produced 45,560 documents in response to Request No. 14. Relevant
documents were provided to the Inquiry on 28 July 2022, 5 August 2022, 12 August 2022
and 19 August 2022.
44 Contractual Liability for Shortfalls (Questions 1 - 16)
4.5 By Questions 1 to 16 of its Request No. 14, the Inquiry requested information and documents
in respect of the following areas of POL's operation:
4.5.1 policies and guidelines relating to the contractual liability of subpostmasters and
other end users;
4.5.2 audit of branch accounts;
4.5.3 suspension, reinstatement or termination of subpostmasters; and
4.5.4 civil enforcement actions against subpostmasters.
46 POL conducted fact finding sessions with a number of current employees who have been
identified as having potentially relevant information on the operation of these areas within
POL. The information gathered from these sessions were used in forming POL's response
1 The response to Request 42 was provided to the Inquiry on 1 August 2022 due to technical difficulties
experienced on 29 July 2022. Suzanne Palmer's transcripts were provided to the Inquiry on 5 August 2022.
14/77078306_1 26
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Second Interim Disclosure Statement
18 October 2022
to Questions 1 to 16 and informed searches for potentially relevant documents. These
employees and the topic of discussion with each of them are set out below:
4.6.1 Stephen Utting, Michael Keegan and lan Wollon (policies and guidelines relating
to the contractual liability);
4.6.2 Simon Talbot and Paul Humber (audit of branch accounts);
4.6.3 Nick Beal, David Southall, Esra Nadasen and Lisa Marshall (suspension,
reinstatement or termination); and
4.6.4 Michelle Stevens, Kirsty O'Connor, Jenny Smith, Jacqueline Whitham and Zoe
Topham (civil enforcement actions).
47 In the first instance, POL conducted preliminary reviews of certain categories of documents
in order to determine potentially relevant sources of information and documents. These
categories of documents include:
4.7.1 responses to and documents disclosed in previous Calls for Evidence;
4.7.2 documents disclosed in previous Rule 9 Requests;
4.7.3 documents from the trial bundles in the GLO proceedings;
47.4 witness statements filed in the GLO proceedings;
4.7.5 witness statements filed in Mr M Baker & 119 Others v POL;
476 various reports by Second Sight; and
4.7.7 POL response to Second Sight Reports;
48 POL also conducted the following searches in order to identify documents relevant to
Questions 1 — 16 of Request No. 14. Documents responsive to the searches were subject to
manual review, and relevant documents identified were produced to the Inquiry (subject to
privilege).
Question
1 Policies and Search A:
guidelines (applicable
in the four countries
of the United * Search Terms:
edie rotating to Generic Document 6. Information available to POL?
the contractual
liability of Generic Document 8. Shortfalls
subpostmasters and Generic Document 11. Investigations
Generic Document 12. Termination / Suspension
other end users
(such as Crown office . .
Generic Document 929. Guidance to Auditors and
Investigators
« Repository: GLO Database
00000
employees) for
shortfalls shown by
Horizon during the
2 In Stage 2 Disclosure of the GLO proceedings, POL disclosed generic documents relevant to various
issues. These documents can be searched by using the "Generic Document" field in the GLO Database
and selecting the relevant issue.
14/77078306_1 27
No. Question
relevant period.
Search
Search B:
¢ Repository: GLO Database
e Search Terms:
Search C:
« Repository: GLO Database
e Search Terms: Specific searches for the following specific
documents:
POL00114174ds
POL00114174ds
Second Interim Disclosure Statement
18 October 2022
“Losses” AND "SPO" AND "guideline*" AND "negligence"
(and Native type is like Word or Adobe or Outlook)
"Guideline*" w/10 "Responsibilit™ w/10 "Recover*"
("Negligen*" w/10 "Carelessness" w/10 “Error*") AND
“ose*"
“legal advice" AND "losses" AND "recover*" AND
"guide*" AND "88"
((‘Loss*" w/2 "Gain*") w/10 "policy" w/10 "Crown") AND
("2007" or "2006" or "2005" or "2004" or "2002" or "2001"
or "2000" or "1999" or "1998" or "1997" or "1996") AND
NOT "Final Version (Sep 2008)" AND NOT "Version 1
(Sep 2008)" (and Relativity Native Type is ‘like’ Adobe or
Word)
“Liability for Losses Policy (for agency branches)" AND
reatment of cash account losses at agency branches"
"Title" w/10 "Robbery Losses Within the Agency Network"
“In service debt" AND "In order for POL to be modernised
and sustainable it is vital that it works"
“Postmaster Account Support" w/5 "Policy"
"Quick Guide" AND "crown"
Personnel Manual INS 3 PIl
PHQ Circular 90/76 Appendix A
SPSO Discipline Paper No 1A (Jan 1984)
MDCs Guidance to District Managers 9 Aug 86)
Postal Instructions N5 A
Postal Instructions L5 Boo23
Version 2 of Losses policy dated 2006
2 Any formal legal
advice relating to the
policies and
guidelines described
at 1. above.
Search A:
¢ Repository: GLO Database
¢ Search Terms:
Generic Document 6. Information available to POL
Generic Document 8. Shortfalls
Generic Document 11. Investigations
Generic Document 12. Termination / Suspension
Generic Document 929. Guidance to Auditors and
Investigators
14/77078306_1
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18 October 2022
No. Question Search
Search B:
¢ Repository: GLO Database
¢ Search Terms:
- ("Jessica" w/2 "madron") AND Unified Title is like
"personal" or "guarantee*"
- ("Jessica" w/2 "madron") AND ("personal" w/5
"guarantee*") AND "polic*"
- "Personal Guarantees in Company to Company
Relationships"
- "Personal Guarantees" AND ("Company to Company")
AND "version control" AND "policy type"
- "Personal Guarantees" AND "company operator” AND
"version control" AND "policy type" AND "Post Office Ltd
may appoint an individual or a company"
Search C:
¢ Repository: Jessica Madron's inbox
¢ Search Terms:
- — ((("‘make" w/5 "good") or "discrepanc*" or ("Loss*" w/5
"incur*") or ("contractual" w/5 "responsib*") or "shortfal*
or (“liabilt*" w/5 "loss*") or ("responsib*" w/5 "loss*") or
("establish™ w/5 "loss*") or ("establish*’ w/5 "gain*") or
("settle*" w/5 "central*") or ("manage*" w/5
"discrepanc*") or ("recover*" w/5 "loss*") or ("repa*" w/5
ain*”) or ("repa*" w/5 “loss*") or ("disput*" w/5
iscrepanc*") or ("discrepanc*" w/5 "investigat*") or
(“financial*" w/5 "loss*")))
OR
- ("polic*" AND (("postmaster*" or "subpostmaster*" or
"sub-postmaster*" or "SPMR*" or "branch*") w/5
“contract*")) or ((("postmaster*" or "subpostmaster*" or
"sub-postmaster*" or "SPMR*" or "branch*") w/5
“contract*") AND ("shortfall*" or "loss*")) or (“polic*"
AND ("postmaster*" or "subpostmaster*" or "sub-
postmaster*” or "SPMR*" or "branch*") AND "liabi*"
AND ("shortfall*" or "loss*")))
AND
- — (“legal" or ("law" w/5 "firm") or “advice*" or "Cameron" or
“mckenna" or ("bond" w/5 "pearce") or ("Bond" w/5.
"Dickinson") or "Beachcroft*" or "DAC" or ("paula" w/2
"bartlett") or ("Charmian” w/2 "leatt") or ("Graeme" w/2
"Young") or ("Ros" w/2 "Ashcroft")
OR
- — ("paul" w/2 "inwood")
Search D:
e Repository: Documents provided by WBD
¢ Search Terms:
14/77078306_1 29
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Second Interim Disclosure Statement
18 October 2022
No. Question Search
- "Losses" w/5 "polic*"
- "In-Service Debt Policy" or ("In Service" w/5 "Policy")
- ("Losses" w/5 "polic*") AND (("Jessica” w/2 "madron") or
(“paul" w/2 "inwood"))
- ("In-Service Debt Policy” or ("In Service" w/5 "Policy"))
AND (("Jessica” w/2 "madron") or ("paul" w/2 "inwood"))
- ("make" w/5 "good") AND (("Jessica" w/2 "madron") or
("paul" w/2 "inwood"))
- ("Loss*" w/5 “incur*") AND (("Jessica” w/2 "madron") or
(“paul" w/2 "inwood"))
- ("contractual" w/5 "responsib*") AND (("Jessica" w/2
“madron”) or ("paul" w/2 "inwood"))
- "discrepanc*" AND (("Jessica" w/2 "madron") or ("paul"
w/2 "inwood"))
- “shortfal*" AND (("Jessica" w/2 "madron”) or ("paul" w/2
“inwood"))
- ("responsib*" w/5 "loss*") AND (("Jessica" w/2
“madron”) or ("paul" w/2 "inwood"))
- (“establish* w/5 "gain*") AND (("Jessica" w/2 "madron")
or ("paul" w/2 "inwood"))
- (“settle*" w/5 "central*") AND (("Jessica" w/2 "madron")
or ("paul" w/2 "inwood"))
- (“recover*" w/5 "loss*") AND (("Jessica" w/2 "madron")
or ("paul" w/2 "inwood"))
- ("repa*" w/5 "gain*") AND (("Jessica" w/2 "madron") or
("paul" w/2 "inwood"))
- ("repa*" w/5 "loss*") AND (("Jessica" w/2 "madron") or
("paul" w/2 "inwood"))
- (“disput*" w/5 "discrepanc*") AND (("Jessica" w/2
“madron") or ("paul" w/2 “inwood"))
- (“discrepanc*" w/5 "investigat*") AND (("Jessica" w/2
“madron") or ("paul" w/2 "inwood"))
- (“financial*" w/5 "loss*") AND (("Jessica" w/2 "madron")
or ("paul" w/2 "inwood"))
- _ ("polic*" AND ("postmaster*" or "subpostmaster*" or
“sub-postmaster*" or "SPMR*" or "branch*") AND.
“liabl" AND ("shortfall*" or "loss*")) AND (("Jessica" w/2
“madron") or ("paul" w/2 "inwood"))
3 Please confirm which I Narrative response provided to the Inquiry.
department(s) held
responsibility for the
policies and
guidelines described
at 1 above. Who held
responsibility for the
management and
oversight of that
department?
14/77078306_1 30
No. Question
4 Any guidance,
training or instruction
(applicable in the four
countries of the
United Kingdom)
given to those
responsible for
conducting audits of
subpostmasters’
branch accounts.
POL00114174ds
POL00114174ds
Second Interim Disclosure Statement
18 October 2022
Seai
Search A:
« Repository: GLO database
¢ Search Terms:
- Generic Document 6. Information available to POL
- Generic Document 8. Shortfalls
- Generic Document 11. Investigations
- Generic Document 12. Termination / Suspension
- Generic Document 929. Guidance to Auditors and
Investigators
5 Please provide
details of the
experience and
qualifications of those
responsible for
conducting audits of
subpostmasters’
branch accounts.
Search A:
¢ Repository: GLO database
¢ Search Terms:
- Generic Document 6. Information available to POL
- Generic Document 8. Shortfalls
- Generic Document 11. Investigations
- Generic Document 12. Termination / Suspension
- Generic Document 929. Guidance to Auditors and
Investigators
Search B:
¢ Repository: Mailbox of Julia Marwood
* Search Terms:
("job description" AND "job title") or ("JD" or "CV" or
"qualification") AND (“audit*" or "field support" or "training
and audit advisor" or "training & audit advisor" or "agent
debt" or "debt recover*" or "regional network manager" or
("training" AND “audit manager") or “training & audit
manager")
6 Please confirm which
department(s) held
responsibility for
conducting audits of
subpostmasters’
branch accounts
during the relevant
period. Who held
responsibility for the
oversight and
management of that
department?
Narrative response provided to the Inquiry.
7 Any reports, reviews,
formal legal advice or
investigations
(produced by POL or
by an external firm on
POL's behalf) which
address the quality of
Search A:
¢ Repository: GLO database
¢ Search Terms:
- Generic Document 6. Information available to POL
- Generic Document 8. Shortfalls
14/77078306_1
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Second Interim Disclosure Statement
18 October 2022
No. Question Search
the audits conducted - Generic Document 11. Investigations
inrespect of - Generic Document 12. Termination / Suspension
ssubpostmasters’ . . 7
branch accounts. - Generic Document 929. Guidance to Auditors and
Investigators
Search B:
¢ Repository: mailboxes of Julia Marwood and Angela van den
Bogerd
¢ Search Terms:
("report" or "review" or "investigation" or "advice") w/5 "audit"
- excluding documents that are only responsive to “audit
report"
8 Any guidance, Search A:
training or instruction
(applicable in the four
countries of the ¢ Search Terms:
United Kingdom) - Generic Document 6. Information available to POL
given to those
¢ Repository: GLO database
responsible for - Generic Document 8. Shortfalls
making - Generic Document 11. Investigations
determinations in - Generic Document 12. Termination / Suspension
relation to the . ;
- - Generic Document 929. Guidance to Auditors and
Suspension, Investigators
reinstatement or
termination of
subpostmasters and
any consequent
appeals.
9 Please provide Search A:
details of the
experience and
qualifications of those I* Search Terms:
¢ Repository: GLO database
responsible for - Generic Document 6. Information available to POL
making ‘
determinations in - Generic Document 8. Shortfalls
relation to the - Generic Document 11. Investigations
suspension, - Generic Document 12. Termination / Suspension
reinstatement or - .
termination of - Generic Document 929. Guidance to Auditors and
subpostmasters and vestig s
any consequent
dl 4 Search B:
appeals.
* Repository: Mailbox of John Breeden
("job description" AND "job title") or ("JD" or "CV" or
“qualification") AND ("contract* advisor" or "contract*
manager" or "contract* deployment" or "contract*
management")
10 I Please confirm which I Narrative response provided to the Inquiry.
department(s) held
responsibility for
14/77078306_1 32
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Second Interim Disclosure Statement
18 October 2022
No. Question Search
making
determinations in
relation to the
suspension,
reinstatement or
termination of
subpostmasters and
any consequent
appeals. Who held
responsibility for the
management and
oversight of that
department?
11 Any reports, reviews, I Search A:
formal legal advice or I , Stary:
investigations Repository: GLO database
(produced by POL or I* Search Terms:
by an external firm on - Generic Document 6. Information available to POL
POL's behalf) which
address the quality of - Generic Document 8. Shortfalls
the decisions taken in - Generic Document 11. Investigations
relation to the - Generic Document 12. Termination / Suspension
suspension,
- Generic Document 929. Guidance to Auditors and
reinstatement or
Investigators
termination of
subpostmasters and
any consequent Search B:
appeals. e Repository: mailboxes of John Breeden and Angela Van
Den Bogerd
* Search Terms:
("report*" or "review*" or "investigation" or "advice") w/5
("suspend*" or "suspension™ or "terminat*" or "reinstat*")
12 I Any reports, briefings I Search A:
or formal legal advice
relating to the
decisiontoremove I* Search Terms:
the contractual right - Generic Document 6. Information available to POL
of appeal from
subpostmasters. - Generic Document 8. Shortfalls
- Generic Document 11. Investigations
- Generic Document 12. Termination / Suspension
- Generic Document 929. Guidance to Auditors and
Investigators
¢ Repository: GLO database
Search B:
¢ Repository: Inboxes of Jessica Madron, Rod Williams and
Tracy Marshall during 2011-2012
¢ Search Terms:
- (("postmaster* or "subpostmaster*" or "sub-
postmaster*" or "SPMR*" or "branch*") w/10 "contract*")
AND “appeal*"
14/77078306_1 33
No. Question
POL00114174ds
POL00114174ds
Second Interim Disclosure Statement
18 October 2022
Search
- (("postmaster*" or "subpostmaster*" or "sub-
postmaster*" or "SPMR*" or "branch*") AND ("shortfall*"
or "loss*") AND "appeal*"
- "polic* AND ("shortfall*" or “loss*") AND “appeal*"
Search C:
- (("make" w/5 "good") or "discrepanc*" o1
Repository: Jessica Madron's mailbox
Search Terms:
- ((((‘postmaster*" or "subpostmaster*"
postmaster*” or "SPMR*" or "branch*") w/10 "contract*")
AND "appeal*")
- ("postmaster*" or "subpostmaster*" or "sub-postmaster*"
or "SPMR*" or "branch*") AND (("shortfall*" or "loss*")
AND "appeal*"))
= ("polic*” AND ("shortfall*" or "loss*") AND "appeal*")
“Loss*" w/5
“incur*") or ("contractual" w/5 "responsib*") or "shortfal*"
or ("liabilt*" w/5 "loss*") or ("responsib*" w/5 "loss*") or
(“establish* w/5 "loss*") or ("establish*" w/5 "gain*") or
("settle*" w/5 "central*") or ("manage*" w/5 "discrepanc*")
or ("recover*" w/5 "loss*") or ("repa*" w/5 "gain*") or
("repa*" w/5 "loss*") or ("disput*" w/5 "discrepanc*") or
("discrepanc*" w/5 "investigat™) or ("financial w/5
“loss*") AND “appeal*")
- ((‘legal" or ("law" w/5 "firm") or "advice*" or "Cameron" or
“mckenna" or ("bond" w/5 "pearce") or ("Bond" w/5.
Dickinson") or "Beachcroft*" or "DAC" or ("paula" w/2
“bartlett") or ("Charmian” w/2 "Leatt") or ("Graeme" w/2
"Young") or ("Ros" w/2 "Ashcroft")) AND "appeal*")
Search D:
Repository: GLO database
Search Terms:
(i) Wording from the contractual appeal clause which was
removed
- "appeal process review"
- "contractual right of appeal"
- "no right of appeal" and "new model"
- "Local post office contract" and "appeal"
- "Main Post Office Contract" and "appeal"
- "Network Transformation Contact"
- "Network Transformation Contact" and "appeal"
(ii) Wording from template letters:
- "If itis your intention to appeal, you should notify me by
signing and returning to me by";
- “contractually they have 10 working days"
"You may, if you wish, appeal against this decision".
14/77078306_1
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No. Question Search
Search E:
e Repository: Documents provided by WBD
¢ Search Terms:
- "right" w/2 "appeal*"
- "contractual right of appeal"
- ("polic*" AND ("shortfall*" or "loss*") AND “appeal*")
- _((‘make" w/5 "good") AND "appeal*")
- “discrepanc*" AND "appeal*"
- (("Loss*" w/5 “incur*") AND "appeal*")
- (("contractual" w/5 "responsib*") AND "appeal*")
- "shortfal*" AND “appeal™
- ((“liabilit*™ w/5 "loss*") AND "appeal*")
- (("responsib*" w/5 "loss*") AND “appeal*")
- (("settle*" w/5 "central*") AND "appeal*")
- (("recover*" w/5 "loss*") AND "appeal*")
- _ (("repa*" w/5 "gain*") AND “appeal*")
- (("repa*" w/5 "loss*") AND "appeal*")
- (("disput*" w/5 "discrepanc*") AND "appeal*")
- (("financial*" w/5 "loss*") AND "appeal*")
- (("postmaster*" or "subpostmaster*" or "sub-
postmaster*" or "SPMR*" or "branch*") AND
(("shortfall*" or "loss*") AND "appeal*"))
- ((("postmaster*" or "subpostmaster*" or "sub-
postmaster*" or "SPMR*" or "branch*") w/10 "contract*")
AND "appeal*")
13 I Any guidance, Search A:
training or instruction
(applicable in the four
countries of the * Search Terms:
United Kingdom) - Generic Document 6. Information available to POL
given to those
responsible for taking
« Repository: GLO database
- Generic Document 8. Shortfalls
civil enforcement - Generic Document 11. Investigations
action to recover . oe :
shortfalls shown by - Generic Document 12. Termination / Suspension
Horizon. - Generic Document 929. Guidance to Auditors and
Investigators
Search B:
e Repository: mailboxes of Alison Bolsover and Michelle
Stevens
e Date Range: January 2000 to December 2019
* Search Terms:
- “train*" or "guidance" or "policy" or "procedure" or
“instruction” or "workshop" or “manual” or "process" AND
14/77078306_1 36
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POL00114174ds
Second Interim Disclosure Statement
18 October 2022
No. Question Search
"debt" w/10 ourt" or "solicitor" or "judgment" or
"judgement" or "action" or "enforce*" or "committal" or
“proceedings” or "pursue" or "claim" or "LBA" or "letter
before action" or "recovery letter" or "CCJ" or “county
court")
- "In Service debt Policy" AND “recover debt incurred in
service" or "debt recovery" or "write off"
- “legal proceedings will be issued against you" AND
("insert" or "XX") or ("standard letter I" or "standard letter
J" or "standard letter K" w/10 "debt")
- "Write off Policy" w/10 "debt"
- ("Criteria discussed and agreed" w/10 "debt") or "Criteria
used to pursue debt"
- "Victoria Brooks" AND ("criteria" or "feasible" or "guidance"
or "policy" or "procedure") AND ("pursue" or "debt" or
"threshold" or "write off" or "LBA" or “letter before action"
or "CCJ" or "bankrupt")
- "Process Former Agent Debt"
- "Former Agent's Debt Process Text"
- “Former Subpostmaster End to End Debt Review"
14 I Please provide Search A:
details of the Ss
experience and ¢ Repository: GLO database
qualifications of those I * Search Terms:
spore for taking - Generic Document 6. Information available to POL
civil enforcement :
actin fo TacOver - Generic Document 8. Shortfalls
shortfalls shown by - Generic Document 11. Investigations
Horizon. - Generic Document 12. Termination / Suspension
- Generic Document 929. Guidance to Auditors and
Investigators
Search B:
¢ Repository: Mailbox of Alison Bolsover
¢ Date Range: January 2000 to December 2019
¢ Search Term:
- "job description" or "job title" or "JD" or "CV" AND "former
agent debt" or "FAD" or "current agent debt" or "CAD" or
“agent debt" or "debt recover*"
- "michelle" AND "stevens" AND "CV"
Search C:
¢ Repository: Mailbox of Michelle Stevens
¢ Date Range: January 2000 to December 2019
¢ Search Terms:
- "job description" or "job title" or "JD" or "CV" AND "former
agent debt" or "FAD" or "current agent debt" or "CAD" or
14/77078306_1 36
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Second Interim Disclosure Statement
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No. Question Seai
“agent debt" or "debt recover*"
- "CV" AND "current agent debt" or "debt recovery"
Search D:
¢ Repository: Mailbox of Rod Ismay
« Date Range: January 2000 to December 2019
¢ Search Terms:
- _ "job description" or "job title" or "JD" or "CV" AND "former
agent debt" or "FAD" or "current agent debt" or "CAD" or
"agent debt" or "debt recover*"
"CV" AND "Bolsover"
- "michelle" AND "stevens" AND "CV"
15 I Please confirm which I Narrative response provided to the Inquiry.
department(s) held
responsibility for
making
determinations in
relation to the
bringing of civil
enforcement action
against
subpostmasters to
recover shortfalls
shown by the
Horizon. Who was
responsible for the
management and
oversight of that
department?
16 I Any reports, reviews, I Search A:
formal legal advice or I , Repository: GLO database
investigations
(produced by POL or I* Search Terms:
by an external firm on - Generic Document 6. Information available to POL
Foe eon wn - Generic Document 8. Shortfalls
and/or - Generic Document 11. Investigations
aperopratoness of = Generic Document 12. Termination / Suspension
ae action - Generic Document 929. Guidance to Auditors and
against Investigators
subpostmasters to :
recover shortfalls Search B:
shown by Horizon. e Repository: mailboxes of Rod Ismay, Rodric Williams, Alison
Bolsover and Michelle Stevens
e Date Range: January 2000 to December 2019
("report” or "review" or "investigation" or "legal advice") w/10
("debt" or "recovery" or "civil enforcement" or "enforcement
action" or "civil action" or "civil recovery action" or "civil
14/77078306_1 37
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Second Interim Disclosure Statement
18 October 2022
No. Question Search
proceedings" or "civil litigation" or "pursue" or “letter before
action" or "LBA" or "debt recovery letter")
49 Civil Case Studies (Question 17)
4.10 By Question 17 of Request No. 14 the Inquiry asked for all records relating to the conduct of
branch audits, civil interviews, decisions on suspension, reinstatement, termination and
appeal, as well as the threat, instigation and pursuit of civil enforcement action in respect of
nine individuals:
4.10.1 Aslam Ramtoola, subpostmaster between 1988 — 2000, Rochdale, England.
4.10.2 Katherine McAlerney, subpostmistress between 2000 — 2008, County Down,
Northern Ireland.
4.10.3 Lee Castleton, subpostmaster between 2003 — 2004, Marine Drive, Bridlington,
England.
4.10.4 Susan McKnight, subpostmistress between 2005 — 2009, Wigan, England.
4.10.5 Rachel Williams, subpostmistress 2006 — 2008, Somerset, England.
4.10.6 Keith Macaldowie, subpostmaster 2006 — 2011, Greenock, Scotland.
4.10.7 Tracey Etheridge, subpostmistress between 2008 — 2011, Gurnos Estate Post
Office, Merthyr Tydfil, Wales.
4.10.8 Kevin Palmer, subpostmaster between 2007 — 2016, Essex, England.
4.10.9 Frank Holt, subpostmaster 2008 — 2017, Invernessshire, Scotland.
4.11 Allnine individuals were claimants in the GLO. The Schedules of Information that were filed
as part of the GLO litigation of these individuals were used as a starting point in order to
determine potentially relevant information and devise appropriate search terms across
various repositories. The Schedules of Information filed by each of the nine individuals have
been disclosed to the Inquiry. Where applicable, evidence given in the Human Impact
Hearings, including any witness statements filed in support were also reviewed for this
purpose.?
4.12 Electronic client matter files held and identified as potentially relevant by WBD were collated.
These consisted principally of the ICRMS or civil investigations files for each individual. No
search terms were applied to these files, and these were manually reviewed, and, where
relevant, produced to the Inquiry. Set out below are the names of each of the matter client
files:4
4.12.1 364065.01064 - M105 - Katherine McAlerney (row 597);
4.12.2 364065.00960 - M001 - Lee Castleton (row 493);
3 It is noted that the majority of evidence given at the Human Impact Hearings mirror that of the Schedules
of Information.
4 The files are named by reference to each individual's GLO claimant number.
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4.12.3 364065.00559 - Mrs Tracey Elizabeth Etheridge (row 380);
4.12.4 364065.01039 - M080 - Gareth & Tracey Etheridge (row 572);
4.12.5 364065.01352 - Dispute with Kevin Palmer (row 727);
4.12.6 364065.00992 - M033 - Rachel Anne Williams (row 525); and
4.12.7 348035.00134 - Mr Lee Castleton (RMG row 400).5
4.13 Napier and Sons held electronic client matter files on the case of Katherine McAlerney.
These files were obtained and manually reviewed without applying any search terms, and,
where relevant, produced to the Inquiry.
4.14 POL identified security files relating to each individual that were held by Peters & Peters.
Due to the nature of these files being in relation to investigations that arose from discovery
of branch audit shortfalls, all of the security files, barring Lee Castleton,® were manually
reviewed, and, where relevant, produced to the Inquiry.
4.15 Further searches were carried out using the data obtained from the Schedules of Information
by applying search terms by reference to each individual and to the areas of interest cited in
Question 17 of Request No. 14. In some cases, additional terms specific to the fact scenario
of each individual's case (drawn from the analysis of the Schedules of information and
Human Impact Witness Statements) were included as part of narrowing the number of
responsive document hits. Excel documents were excluded from the searches due to the
number of false positives in the results. All documents that were responsive to these
searches were then manually reviewed and, where relevant, produced to the Inquiry. The
production also included family documents, including those that may be non-responsive to
Question 17 of Request No. 14. A summary of the searches carried out is set out below.
Search
A_ I Aslam Ramtoola Search A:
¢ Repository: GLO Database
* Search Terms:
- ("Aslam" w/5 "Ramtoola") AND ("audit*" or "suspen*"
or "terminat*" or "resign*" or “interview*" or "reinstat*"
or "appeal" or "sue*" or "suing" or “pursu*" or "claim"
or "court" or "recover*" or "civil" or "proceeding*" or
“enforce*" or “litigat*" or "letter before action" or "LBA"
or "debt recovery letter" or "settl*" or "abandon*")
Search B:
* Repository: HSF Database
¢ Search Terms:
- ("Aslam" w/5 "Ramtoola") AND ("audit*" or "suspen*" or
“"terminat*" or "resign*" or "interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or "pursu*" or "claim" or
6 Lee Castleton matter files from WBD were produced in full.
6 Due to the large number of documents that relate to Lee Castleton, a 25% sample of his documents from
the security files were reviewed, all of which relate to POL's pursuit of civil proceedings and are relevant
to Question 17 of Request No. 14. POL's decision was to disclose his files to the Inquiry in full.
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"court" or "recover*" or "civil" or "proceeding*" or
"enforce*" or “litigat*" or "letter before action" or "LBA"
or "debt recovery letter" or "settl*" or "abandon*")
B_ I Katherine McAlerney I Search A:
¢ Repository: GLO Database
¢ Search Terms:
("Katherine" w/5 "McAlerney") AND (“audit*" or
“suspen*" or "terminat*" or "resign*" or "interview*" or
"reinstat*" or "appeal" or "sue*" or "suing" or "pursu*"
or "claim" or "court" or "recover*" or "civil" or
"proceeding*" or "enforce*" or “litigat*" or "letter before
action" or "LBA" or "debt recovery letter" or "settl*" or
"charg*" or "freedom of information" or "FOIA")
Search B:
¢ Repository: HSF Database
¢ Search Terms:
("Katherine" w/5 "McAlerney") AND (“audit*" or "suspen*"
or "terminat*" or "resign*" or "interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or "pursu*" or "claim" or
"court" or "recover*" or “civil" or "“proceeding*" or
“enforce*" or “litigat*" or "letter before action" or "LBA" or
“debt recovery letter" or "settl*" or "charg*" or "freedom of
information" or "FOIA") AND NOT ("HQ16X0123" or
"10th March 2015” or "DSAR")
c Lee Castleton Search A:
« Repository: GLO Database
¢ Search Terms:
- ("Lee" w/5 "Castleton") AND (“audit*" or "suspen*" or
“"terminat*" or "resign*" or "interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or “pursu*" or "claim" or
"court" or "recover*" or "civil" or "proceeding*" or
"enforce*" or "litigat*" or "letter before action" or "LBA"
or "debt recovery letter" or "settl*" or "judgment" or
"counter*" or "bankrupt*")
Search B:
* Repository: HSF Database
¢ Search Terms:
- ("Lee" w/5 "Castleton") AND ("audit*" or "suspen*" or
“"terminat*" or "resign*" or "interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or "pursu*" or "claim" or
"court" or “"recover*" or "civil" or "proceeding*" or
"enforce*" or "litigat*" or "letter before action" or "LBA" or
"debt recovery letter" or "settl*" or "judgment" or
“counter*" or “bankrupt*" or "Pearce") AND NOT
("DSAR")
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No. Claiman
D Susan McKnight
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Search
Search A:
¢ Repository: GLO Database
¢ Search Terms:
= ("Susan" w/5 "McKnight") AND (“audit*" or "suspen*"
or “terminat*" or "resign*" or "interview*" or "reinstat*"
or "appeal" or "sue*" or "suing" or "pursu*" or "claim"
or "court" or "recover*" or "civil" or “proceeding*" or
“enforce*" or "litigat*” or “letter before action” or "LBA"
or "debt recovery letter” or "settl*" or "charg* or
"repay*" or "judgment")
Search B:
¢ Repository: HSF Database
¢ Search Terms:
= ("Susan" w/5 "McKnight") AND (“audit*" or "suspen*" or
“terminat*" or "resign*" or “interview*" or "reinstat*" or
"appeal" or "sue*" or “suing” or "pursu*” or "claim" or
"court" or "recover*" or "civil" or “proceeding*” or
“enforce*" or "litigat*" or "letter before action” or "LBA" or
"debt recovery letter" or "settI*" or "charg*" or "repay*" or
“judgment")
E I Rachel Williams
Search A:
¢ Repository: GLO Database
¢ Search Terms:
- ("Rachel" w/2 "Williams") AND ("audit*" or "suspen*"
or "terminat*" or "resign*" or "interview*" or "reinstat*"
or “appeal” or "sue*" or "suing" or “pursu*" or "claim"
or "court" or "recover*" or "civil" or "proceeding*" or
“enforce*" or "litigat*" or "letter before action" or "LBA"
or “debt recovery letter" or "settl*")
Search B:
e Repository: HSF Database
¢ Search Terms:
- ("Rachel" w/2 "Williams") AND ("audit*" or "suspen*" or
"terminat*” or “resign*" or "interview*" or "reinstat*" or
“appeal” or "sue*" or “suing” or "pursu*" or "claim" or
"court" or "recover*" or "civil" or "proceeding*" or
"enforce*" or “litigat*" or "letter before action" or "LBA" or
"debt recovery letter" or "settl*") AND NOT
("Rachel.Kamm" or "Rachel Scott" or "DSAR" or "Rachel
Harwood" or "Media Coverage")
F Keith Macaldowie
Search A:
« Repository: GLO Database
e Search Terms:
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No. Claiman Search
- ("Keith" w/5 "Macaldowie") AND ("audit*" or "suspen*"
or "terminat*" or "resign*" or “interview*" or "reinstat*"
or "appeal" or "sue*" or "suing" or “pursu*" or "claim"
or "court" or "recover*" or "civil" or "proceeding*" or
“enforce*" or "litigat*" or “letter before action" or "LBA"
or “debt recovery letter" or "settl*")
Search B:
¢ Repository: HSF Database
¢ Search Terms:
("Keith" w/5 "Macaldowie") AND (“audit*" or "suspen*" or
“terminat*" or “resign*" or "interview*" or “reinstat*" or
"appeal" or "sue*” or "suing" or "“pursu*" or "claim" or
"court" or "recover*" or “civil" or "proceeding*" or
"enforce*" or "litigat*" or "letter before action" or "LBA" or
“debt recovery letter" or "setti*")
G Tracey Etheridge Search A:
¢ Repository: GLO Database
¢ Search Terms:
- ((‘Tracey" or "“Gareth") w/5 "Etheridge")) AND
("audit*" or "suspen*" or "terminat*" or "resign*" or
"interview* or "reinstat*" or "appeal" or "sue*" or
"suing" or "pursu*" or "claim" or "court" or "recover*"
or "civil" or "proceeding*" or "enforce*" or "litigat*" or
"letter before action” or "LBA" or "debt recovery letter”
or "settl*" or "charg*" or "judgment")
Search B:
« Repository: HSF Database
¢ Search Terms:
- (("Tracey" or “Gareth") w/5 "Etheridge")) AND
("audit*" or “suspen*" or “terminat*" or "resign*" OR
“interview*" or "reinstat*" or "appeal" or "sue*" or
"suing" or "pursu™” an
or "claim" or "court" or "recover’
or "civil" or "proceeding*" or "enforce*" or "litigat*" or
"letter before action" or "LBA" or "debt recovery letter"
or "settl*" or "charg*" or "judgment") AND NOT
("DSAR" or "Assemble Data" or “Conditions of
Appointment List" or "Type 1 Thematic Issues")
H Kevin Palmer Search A:
« Repository: GLO Database
¢ Search Terms:
- — ("Kevin" w/5 "Palmer") AND (“audit*" or "suspen*" or
“terminat*" or "resign*" or “interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or "pursu*" or "claim" or
"court" or "recover*" or "civil" or "proceeding*" or
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No. Claiman Search
"enforce*" o1 igat*" or "letter before action" or "LBA"
or “debt recovery letter" or "settl*" or "release")
Search B:
¢ Repository: HSF Database
¢ Search Terms:
- ("Kevin" w/5 "Palmer") AND ("audit*" or "suspen*" or
"terminat*" or "resign*" or "interview*" or "reinstat*" or
"appeal" or “sue*" or "suing" or "pursu*" or "claim" or
"court" or "recover*" or "civil" or "proceeding*" or
“enforce*" or "litigat*" or "letter before action” or "LBA" or
“debt recovery letter" or "settl*" or "release") AND NOT
("DSAR" or "Assemble Data" or "Conditions of
Appointment List" or "Brendan Palmer" or "Appraisal" or
"SIP Report" or "Panther")
1 Frank Holt Search A:
¢ Repository: GLO Database
¢ Search Terms:
- ("Frank" w/5 "Holt") AND ("audit*" or "suspen*" or
"terminat*" or "resign*" or “interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or “pursu*" or "claim" or
"court" or "recover*" or "civil" or "proceeding* or
“enforce*" or "litigat*" or "letter before action" or "LBA"
or “debt recovery letter" or "settl*" or "investigation" or
"Findlay" or "request* information")
Search B:
¢ Repository: HSF Database
¢ Search Terms:
- ("Frank" w/5 "Holt") AND ("audit*" or "suspen*" or
"terminat*" or "resign*" or "interview*" or "reinstat*" or
“appeal” or "sue*" or "suing" or "pursu*" or "claim" or
"court" or “recover” or "civil" or "proceeding*" or
"enforce*" or “litigat*" or "letter before action" or "LBA" or
"debt recovery letter" or "settl*" or "investigation" or
"Findlay" or "request* information") AND NOT
("Assemble Data” or "Conditions of Appointment List")
4.16 Prosecutions (Questions 18 - 41)
4.17 Peters & Peters collated the information responsive to Question 18 to 41 by utilising the work
undertaken in relation to the PCDE to the fullest extent possible. The PCDE covers cases
where (a) the individual was convicted of a criminal offence; (b) POL (or RMG for
prosecutions relating to POL that took place pre-separation) was the prosecutor; (c) the
prosecution was based wholly or partly on data derived from the Horizon IT system; and (d)
the prosecution was undertaken between 2000 and 2013. In the PCDE, Peters & Peters
identified relevant documents by conducting a substantial search across multiple
repositories. Peters & Peters approach is recorded in a Disclosure Management Document
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and Addendum that was disclosed in the course of the criminal appeal proceedings and
provided to the Court of Appeal, Criminal Division. Although the PCDE (and in particular, any
search terms that were applied) would not (and could not) have specifically taken into
account the Requests (or the relevant Completed List of Issues), the extensive overlap
between the PCDE and the Rule 9 Requests provides a sound basis for utilising the PCDE
related work in this way.
4.18 As detailed in HSF's letter to the Inquiry dated 6 July 2022 and further to the Inquiry's email
response dated 14 July 2022, POL took the following approach:
4.18.1 In relation to Questions 22, 23, 26, 27, 30, 31, 34, 35, 38, and 39 of the Request,
POL provided information in relation to the individuals at POL that were
"responsible" for specified areas (and not any third parties);
4.18.2 POL identified which (if any) external legal advisers were instructed to provide
advice and assistance in response to the Inquiry's email response to HSF dated
14 July 2022; and
4.18.3 In relation to Questions 22 to 41, POL provided its responses by providing
information and documents (where available) by reference to the following cases,
and the individuals involved in those cases (to the extent known):
(A) the 23 case studies listed in Question 42; and
(B) the 88 case studies that were reviewed by Peters & Peters as set out in
HSF's letter to the Inquiry dated 4 March 2022.
4.19 As explained in HSF's letter to the Inquiry dated 12 August 2022, there are certain caveats
in relation to the data and information provided in response to Questions 18 to 41:
4.19.1 During the course of the PCDE, it became apparent to Peters & Peters that some
data is no longer available or complete, apparently having been lost during the
passage of time, by the application of the retention of document policy or as part
of the RMG/POL separation.
4.19.2 As part of the RMG/POL separation, there was a wholesale change to the email
servers used. Most of the archived email data pre-dating 2012 was retained by
RMG and no longer exists, including communications between Security and/or the
Criminal Law Team custodians. Peters & Peters asked RMG to provide any
archived email data relating to Security/Legal custodians including the back-up of
the archive. Peters & Peters were informed that it had been deleted in line with
RMG's data retention policies. POL conducted a search across its IT system for
any archived pre-2012 email data files saved on its system (however, this was
limited to data for individuals whose employment was transferred to POL in 2012).
In particular, data limitations arose out of the limited availability of records
(particularly in respect of lawyers from the Criminal Law team who are not
employed at POL) and the passage of time that has elapsed since POL ceased
private prosecutions; and
4.19.3 HR files were not collected for all POL individuals responsible for, or materially
involved in, the investigation and prosecutions, as part of the PCDE. Peters &
Peters sought to collect HR material relating to additional Security team custodians
that have since been identified. The search for HR files for a small number of
individuals is ongoing. Much of the material is in hard copy and requires on-site
review and collation at various sites. There is a possibility that some material,
responsive to the Rule 9 Requests relating to training/qualifications, may therefore
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be identified at a later stage. Any such material will be disclosed to the Inquiry as
soon as possible.
4.20 In addition to the material collated as part of the PCDE, Peters & Peters conducted specific
searches on the 2020 version of POL's Sharepoint site (de-duplicated for the 2015 version
of that repository) to identify any further relevant material. They also conducted several
targeted searches, in particular in relation to Request 19.
4.21 Peters & Peters also conducted interviews with several Security Managers (both former and
current) to better understand the nature and form of any training that they had received and
the qualifications of the Security Team. Following these interviews, certain Security
Managers provided Peters & Peters with materials that were referred to and discussed during
the sessions.
4.22 Peters & Peters was also provided with any (potentially) relevant materials by HSF and POL
as part of their separate Inquiry-related work. This included (but was not limited to) material
relevant to Requests 18-20, 22, 26, 30, 34 and 38.
4.23 Inresponse to these requests, POL has produced:
4.23.1 477 documents;
4.23.2 written responses;
4.23.3 a spreadsheet that set out the available information relating to the individuals
responsible for, or materially involved with, the investigations and prosecutions;
and
4.23.4 a spreadsheet identifying the training and qualifications of the relevant teams.
4.24 Criminal case studies (Question 42)
4.25 As explained in HSF's letter to the Inquiry dated 6 July 2022, POL took the approach of
providing the Inquiry with all materials identified as relevant for the specified individuals in
Question 42 during the course of the PCDE and Peters & Peters’ Inquiry-related work.
4.26 POL has produced a total of 25,245 documents in response to this request.
5. REQUEST NO. 15
5.1 By its Request No. 15 dated 1 July 2022, the Inquiry requested that POL produce a number
of further specific documents of relevance to Phase 2 of the Inquiry's proceedings. The
Inquiry requested that POL provide its response by no later than 22 July 2022.
5.2 In total, POL has produced 192 documents in response to Request No. 15. Relevant
documents were provided to the Inquiry on 22 July 2022 and 15 August 2022. Further
productions containing documents relevant to Request No. 13 and Request No. 15 were
provided to the Inquiry on 29 July 2022 (14 documents) and 12 August 2022 (62 documents).
5.3 We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 15. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege).
No. Document Search
1 Minutes of all meetings of the Search A:
Automation Steering Group
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Search
Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("Steering Group" w/2
“Automation") AND ("Meeting" or "Minute")
° Date range: N/A
2 The First, Second and Third
Supplemental Agreements to.
the Codified Agreement
Search A:
* Repository: (i) Inquiry Database and (ii) GLO
Database
* Search Terms: "Codified Agreement" AND
"Supplement*" AND ("First" or "Second" or
"Third")
« Date range: N/A
3 Ruth Holleran’s paper prepared
for the Acceptance Workshop on
17th September 1999
addressing conditions for
acceptance
Search A:
Repository: (i) Inquiry Database and (ii) GLO
Database
¢ Search Terms: ("Acceptance" w/5 "Workshop")
AND ("September" w/2 "1999")
° Date range: N/A
Search B:
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Holleran" AND "September"
AND "1999"
e Date range: N/A
4 Post Office Christmas Research
Report originally circulated by
email on 7 January 2000 (to
which reference is made at
POL00028441 (your document
reference POL-0024923))
Search A:
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("Christmas" AND "Research"
AND (“January" w/2 "2000")
e Date range: N/A
5 Any reports or briefings relating
to the downgrading and / or the
closure of the following
acceptance incidents: Al 211, Al
218, Al 376, Al 378, Al 408
Search A:
Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("Acceptance" w/5 "Incident" or
“Report" or "Register") AND ("211" or "218" or
"376" or "378" or "408"
e Date range: N/A
6 Any reports or briefings relating
to the “integrity controls”
mentioned in POL00028509
(your document reference POL-
0024991):
Search A:
e Repository: (i) Inquiry Database and (ii) GLO
Database
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Search
e Search Term: lorizon" AND ("Roll" w/2 "Out")
AND ("Integrity" w/5 "Control") AND ("1999" or
"2000")
+ Date range: N/A
7 I CCD entitled TPS Reconciliation I Search A:
and Incident Management
negotiated / concluded in or
around January 2000.
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "TPS" AND ("Reconciliation w/5
"Incident Management") AND ("January" w/2
"2000")
° Date range: N/A
54 For the purpose of responding to Request No. 15 (and identifying and producing to the
Inquiry documents relevant to the same), POL has made enquiries in relation to potentially
relevant hard copy documents. In particular, POL has considered the relevance to Request
No. 15 of hard copy documents held at the Oasis archives in Winchester and the Postal
Museum. Further details are set out below.
5.5 Oasis
5.6 Following a review of the index of files / boxes held at the Oasis archives in Winchester, POL
identified the following files / boxes which it anticipated may contain material or information
of relevance to Request No. 15.” POL subsequently attended the Oasis archives to review
these hard copy files / boxes and, based upon that review, arranged for those files / boxes
that appeared to contain potentially relevant documents to be scanned and uploaded onto
Relativity. The searches set out in the above table were then conducted across these
materials, and responsive documents were reviewed for relevance to the terms of Request
No. 15.
Files
No. File Reference Box Reference Description
F00001749125 0001562735 Counters Automation 5
2 I F00001749126 0001562735 Counters Automation 3
3 I F00001749524 0001562766 Automation: BA/POCL Reports & Receipts
Review — Functional Specification
4 I F00001750152 0001562869 Automation 2
5 I F00001751251 0001562852 Automation
6 I F00001755203 0001562609 Automation BA/POCL 1997
7 I F00001756266 0001562695 Automation Management
8 I F00001756688 0001562730 Counter Automation Roll-Out 1990-1991
(Formerly Group 0583/1990)
9 I FO0001757091 0001562950 D6/1 Counter Automation (includes way ahead):
AH74
7 There is some overlap between the Oasis files that were identified as potentially containing documents
relevant to Request No. 13 and Request No. 15 respectively.
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10 I F00001757095 0001562942 BA9Q7: Counter Automation Steering Group
11 I F00001758271 0001562957 Automation
12 I F00001758396 0001562958 Automation Committee
13 I F00001759221 0001562750 Counters Automation 4
14 I F00001759222 0001562750 Counters Automation 2
15 I F00001759531 0001562787 Long Term Automation Strategy - Counter
Automation: 1331
16 I F00001763654 0001562519 Royal Mail and Automation
17 I F00001765394 0001562598 Automation Transformation Programme
18 I F00001765402 0001562598 Automation Process Group
19 I F00001766541 0001562354 Counters Automation 1
20 I F00001749874 0001562829 Change Request / Change Control Notes 326
21 =I FO0001750871 0001562842 Change Request / Change Control Notes
221/325
22 I FO0001750920 0001562841 Change Control
23 I F00001759205 0001562747 Change Request / Change Control Notes 71-110
24 I FO0001765813 0001562912 Accountancy & Reconciliation - Change Control
25 I F00001768467 0001562491 Integration Change Control Manager
26 I FO0001750280 0001562877 CCN'S 510-530
27 =I F00001749066 0001562736 Acceptance Comments
28 I FO0001750710 0001562816 Acceptance Misc. 1
29 I F00001750715 0001562816 Acceptance Misc. 2
30 I F00001750913 0001562841 Acceptance
34 I F00001759215 0001562750 Acceptance
32 I F00001766637 0001562893 Acceptance of Operational Trial
33 I F00001767288 0001562392 Acceptance Criteria - Update
34 I F00001767290 0001562392 Acceptance Criteria
Boxes
No. Item Code SKP Number Title
1 0001601153 472183542 Change Control Notes Supporting
Correspondence and Hard Copies
2 I 0001611115 377518268 Horizon Contract CCNS 431-745
3 I 0001611090 377518269 Horizon Contract CCNS 747-972
4 I 0001611120 377518267 Horizon Contract CCNS 1-430
5.7 Postal Museum
5.8 POL has also written to the Postal Museum, enquiring as to whether the Postal Museum held
within its archives documents of potential relevance to Request No. 15. Files identified by
the Postal Museum as potentially containing relevant documents were scanned by Millnet
and uploaded onto Relativity. POL then arranged for each of the searches contained in the
above table to be conducted across these materials and for responsive documents to be
14/77078306_1 48
6.1
6.2
6.3
POL00114174ds
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reviewed for relevance to this Request No 15. Relevant documents identified were produced
to the Inquiry on 12 August 2022.
REQUEST NO. 16
By its Request No. 16 dated 5 July 2022, the Inquiry requested that POL produce a number
of organograms / structure charts in relation to POL's senior leadership team and other
individuals in key posts concerning Horizon. The Inquiry requested that POL provide its
response by no later than 2 August 2022.
In total, POL has produced 10 documents in response to Request No. 16. Relevant
documents were provided to the Inquiry on 2 August 2022.
During the course of the Inquiry, POL has identified and collated approximately 80
organisation / structure charts and has arranged for these documents to be uploaded onto
its e-Discovery platform. These structure charts were obtained from various internal POL
sources. A small number of further structure charts were also identified and provided to POL
by Womble Bond Dickinson. In order to ensure (insofar as possible) the comprehensiveness
of the organisation / structure charts obtained to date, POL arranged for the manual review
of all documents located on the Inquiry Database that Relativity assessed as having a
similarity ranking of +90% to the structure charts / organograms provided to date. In addition,
POL ran the following keyword searches across the indices of the GLO Trial Bundles:
6.3.1 “organogram"
6.3.2 “organisational chart"
6.3.3 “organisation chart"
6.3.4 “org chart"
6.3.5 “org_chart"
6.3.6 “org charts"
6.3.7 “org_charts"
6.3.8 “network structure"
6.3.9 “network_structure"
6.3.10 "team profiles"
6.3.11 "team_profiles"
6.3.12 "structure"
6.3.13 "structure chart"
6.3.14 "structure_chart"
6.3.15 "profiles"
6.3.16 "structure chart and profiles”
14/77078306_1 49
6.4
7.2
7.3
8.41
8.2
8.3
No. Docu
1
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POL arranged for a full manual review of all of the organisation / structure charts identified
for relevance to Request No. 16. All documents that were identified as relevant were
produced to the Inquiry on 2 August 2022, together with copies of further documents which,
whilst not strictly responsive to Request No. 16, POL anticipated would nonetheless be of
interest and assistance to the Inquiry. In addition to these materials, POL also arranged for
the following documents to be prepared and provided to the Inquiry:
6.4.1 List of POL Board members: This document contained the names and dates of
service of all POL Board members, as ascertained from Companies House.
6.4.2 List of meeting attendees: This document set out a full list of attendees of the
following committees / working groups: (i) the Project Sparrow Sub-Committee, (ii)
the GLO / Postmaster Litigation Sub-Committee, (iii) the Mediation Scheme
Working Group and (iv) the Horizon Issues Working Group. Updated versions of
this list were subsequently provided to the Inquiry on 12 August 2022 and 26
August 2022, including certain additional attendees of the Horizon Issues Working
Group.
REQUEST NO. 17
By its Request No. 17 dated 17 August 2022, the Inquiry sought various documents and
information relevant to the overturned conviction of Mr Grant Allen by 26 August 2022.
As explained in HSF's letter to the Inquiry dated 26 August 2022, POL took a similar
approach in relation to Request No. 17 as it did for the criminal case studies requested as.
part of Request 42 of Rule 9 Request No. 14 (see further at Section 4 above).
POL has produced a total of 673 documents in response to this request.
REQUEST NO. 18
By its Request No. 18 dated 23 August 2022, the Inquiry requested that POL produce a
series of further board documents. The Inquiry requested that POL provide its response by
no later than 7 September 2022.
In total, POL has produced 62 documents in response to Request No. 18. Relevant
documents were provided to the Inquiry on 7 September 2022.
We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 18. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege).
Search
If written, a letter from the Chief I Search A:
Executive to the Post Office’s
Minister, lan McCartney,
highlighting the Post Office's
concerns about Horizon as e Search terms: ("McCartney") AND "Horizon" AND
referenced at p.11 of 16 of the ("1999" w/10 "May" or "June" or "July")
Board Minutes of 20 July 1999, Dat NIA
document POL00000352. . ate range:
e Repository: (i) Inquiry Database and (ii) GLO
Database
If carried out and recorded in a Search A:
document, a review of the
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No locument Search
decision to continue with the e Repository: (i) Inquiry Database and (ii) GLO
limited rollout of Horizon to 900 Database
pit eftces 6s cereronced oy Search terms: ("Sweetman") AND "Horizon" AND
On Be (Roll wi2 "Out") or "Pilot") AND ("1999" or
Minutes made on 14 September "2000"
1999, document POL00000353. )
« Date range: N/A
3 Any documents presented to the I Search A:
board detailing issues with rollout I , R tone (i : -
" epository: (i) Inquiry Database, (ii) GLO
with Project Horizon. Database and (iii) HSF Database
e Search: "Board" AND "Minute" AND "Meeting"
AND “Attend*" AND ("1998" or "1999" or "2000" or
"2001")
e Date range: To the extent responsive documents
had metadata, all documents that were dated after
2002 were excluded from this search.
Search B:
e Repository: All Board minutes currently held on
Relativity (including any additional Board minutes
identified following Search A above)
¢ Search: "Horizon"
e Date range: To the extent responsive documents
had metadata, all documents that were dated after
2002 were excluded from this search.
Search C:
* Repository: (i) Inquiry Database and (ii) GLO
Database
° Search: "Board" AND "Meeting" AND ("Paper*" or
“Report*" or "Brief*") AND "Horizon" AND ("1998"
or "1999" or "2000" or "2001")
e Date range: To the extent responsive documents
have metadata, please exclude all documents that
are dated after 2002.
4 Business Board Minutes I Search A:
between January 2000 and June
2001.
Repository: (i) Inquiry Database, (ii) GLO
Database and (iii) HSF Database
* Search: "Board" AND "Minute" AND "Meeting"
AND "Attend" AND ("1998" or "1999" or "2000" or
"2001")
« Date range: To the extent responsive documents
had metadata, all documents that were dated after
2002 were excluded from this search.
Search B:
e Repository: (i) Inquiry Database and (ii) GLO
Database
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"Business Board" AND "Minute*" AND
("2000" or "2001")
e Date range: N/A
The White Paper referenced at
p.2 of 16 of the Board Minutes
made on 20 July 1999,
document POL00000352.
Search A:
Repository: (i) Inquiry Database and (ii) GLO
Database
¢ Search terms: "White Paper" AND "1999"
e Date range: To the extent responsive documents
have metadata, please exclude all documents that
are dated after 2002.
Report and presentation made
by Duncan Hine as referenced at
p.9 in the Board Minutes made
on 14 September 1999,
document POL00000353.
Search A:
* Repository: (i) Inquiry Database and (ii) GLO
Database
e Search terms: ("Duncan” w/5 "Hine") AND
"Horizon" AND ("1999" w/10 "August" or
"September" or "October")
e Date range: To the extent responsive documents
have metadata, please exclude all documents that
are dated after 2002.
Search B: ®
e Repository: Inquiry Database
¢ Search terms:
PO/007'
"POB(00)4"
“Duncan Hine" AND "Report"
"Duncan Hine" AND "Presentation"
"Hine" AND ("Report" or "Presentation")
AND "11 January 2000"
o “Hine” AND ("Report" or "Presentation")
AND "January 2000"
o "Technology" AND "Information System*"
AND "Duncan Hine"
20000
e Date range: N/A
Chief Executive's Report
CB(01)19 as reference in p.3 of 9
of the Board Minutes dated 12
June 2001, document
POL00021476.
Search A:
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search terms: ("John" w/5 "Roberts") AND
"Report" AND "2001"
There is no reference to the Duncan Hine presentation or report in the 14 September 1999 minutes.
Duncan Hine was not in attendance at that meeting. There is, however, a reference to the report and
presentation of Duncan Hide in the minutes of the meeting held on 11 January 2000 (POL0000001).
14/77078306_1
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Sear
e Date range: To the extent responsive documents
have metadata, please exclude all documents that
are dated after 2002.
Search B:
° Repository: HSF Database
° Search terms:
o "CB(01)19"
o ="CB01/31"
o ("Chief Executive*" AND "Report" AND
“June 2001")
¢ Date range: N/A
8 All Audit Committee minutes Search A:
from 1998 to 2001 (inclusive)
and any substantive papers
produced for the purpose of the Ratebace
Audit Committee insofar as they Ie Search: ("Audit" w/2 "Committee") AND "Minute*"
are relevant to the development, AND "Horizon" AND ("1998" or "1999" or "2000"
acceptance, roll out and or "2001")
subsequent monitoring of the
Horizon IT system. «Date range: WA
Search B:
e Repository: (i) Inquiry Database and (ii) GLO
¢ Repository: (i) Inquiry Database and (ii) GLO
Database
¢ Search: ("Audit" w/2 "Committee") AND ("Paper*"
or “Report*" or "Brief*" or "Document*”) AND
"Horizon" AND ("1998" or "1999" or "2000" or
"2001")
e Date range: N/A
9 Any documents that were Search A:
produced for the purpose of the
Post Office / Consignia Board
from 1998 to 2001 (inclusive)
insofar as they are relevant to e Search:
the development, acceptance, AND
roll out and subsequent 2001")
monitoring of the Horizon IT
system.
¢ Repository: (i) Inquiry Database, (ii) GLO
Database and (iii) HSF Database
"Board" AND "Minute" AND "Meeting"
‘ttend*" AND ("1998" or "1999" or "2000" or
e Date range: To the extent responsive documents
had metadata, all documents that were dated after
2002 were excluded from this search.
Search B:
e Repository: All Board minutes currently held on
Relativity (including any additional Board minutes
identified following Search A above)
* Search: "Horizon"
e Date range: To the extent responsive documents
had metadata, all documents that were dated after
2002 were excluded from this search.
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Document Search
Search C:
e Repository: (i) Inquiry Database and
Database
° Search: "Board" AND "Meeting" AND ("Paper*" or
“Report or "Brief*") AND "Horizon" AND ("1998"
or "1999" or "2000" or "2001")
i) GLO
e Date range: To the extent responsive documents
have metadata, please exclude all documents that
are dated after 2002.
8.4 For the purpose of responding to Request No. 18 (and identifying and producing to the
Inquiry documents relevant to the same), POL has made enquiries in relation to potentially
relevant hard copy documents. In particular, POL has considered the relevance to Request
No. 15 of hard copy documents held at the Postal Museum.
8.5 POL wrote to the Postal Museum on 30 August 2022, enquiring as to whether the Postal
Museum held within its archives documents of potential relevance to Request No. 18 (and,
in particular, documents relevant to the Inquiry's Questions 3, 4, 8 and 9). The Postal
Museum archivists identified a total of eight (8) files of potential relevance to these matters,
five (5) of which had previously been requested, scanned and uploaded onto Relativity. The
additional three (3) files identified by the Postal Museum as potentially containing relevant
documents were scanned by Millnet and uploaded onto Relativity. POL then arranged for
each of the searches contained in the above table to be conducted across these materials
and for responsive documents to be reviewed for relevance to this Request No 18. Relevant
documents identified were produced to the Inquiry on 16 September 2022.
9. REQUEST NO. 19
94 By its Request No. 19 dated 26 August 2022, the Inquiry requested that POL produce a
series of further documents relevant to Phases 2 and 3 of the Inquiry's proceedings. The
Inquiry requested that POL provide its response by no later than 5 September 2022.
9.2 In total, POL has produced 7 documents in response to Request No. 19. Relevant documents
were provided to the Inquiry on 5 September 2022.
9.3 We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 19. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege).
Document Search
1 Document POL00028323 Search A:
includes at page 21 the minutes . . . 7”
of the Automation e Repository: (i) Inquiry Database and (ii) GLO
Transformation Steering Group Database
Undertemaitrefer oa I* SeaishTems: "Woolley" AND “EPOSS' AND
presentation given by Stephen 1998)
Woolley, and states that slides e Date range: N/A
are attached to the minutes.
Please provide copies of these
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No Search
v4 Document POL00043668 (POL- I Search A:
0040171) refers at Action No. 4 < . . =
(page 7) to a paper being ¢ Repository: (i) Inquiry Database and (ii) GLO
prepared by Ruth Holleran and Database
Darren Bosco relating tourgent I I Search Terms: "EPOSS™ AND ("Holleran” or
issues such as testing and "Bosco") AND " AND "1998"
EPOSS. Please provide this /
these paper(s). e Date range: N/A
3 Any other written reports or Search A:
slideshows prepared by Darren . . a
Bosco relating to the EPOSS * Repository: (i) Inquiry Database and (ii) GLO
application. Database
e¢ Search Terms: "EPOSS" AND ("Bosco") AND
("1998" or "1999")
« Date range: N/A
4 Documents referred to in bullet points in document POL00039783, consisting of the
following:
4A I Horizon database key Search A:
information (from John
Meagher) ¢ Repository: (i) Inquiry Database and (ii) GLO
Database
* Search Terms: "Meagher" AND ("Horizon" w/5
"database") AND ("1998" or "1999")
¢ Date Range: N/A
4B I Regular reports on potential risks I Search A:
which a training solution could
avert, from: (i) Horizon service
reports, (ii) BA/Pathway/PoCL
joint meetings, (iii) Before and
After procedures group
* Repository: (i) Inquiry Database and (ii) GLO
Database
° Search Terms:
o ("Horizon" w/5 "Service") AND "Report"
AND "training solution" AND ("1998" or
"4999")
o (("BA" or "Benefits Agency") AND
("Pathway" or "ICL") AND ("PoCL" or
“Post Office")) AND ("Joint" wi/5
“Meeting") AND ("1998" or "1999")
e Date range: N/A
Search B:
e Repository: Inquiry Database
e Search Terms: "Horizon Service Report"
* Date Range: N/A
Search C:
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No Search
¢ Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Horizon Service Report"
e Date Range: To the extent responsive documents
had metadata, all documents that were dated after
2000 were excluded from this search.
4C_ I Progress reports on roll-out (e.g. I Search A:
number of people being trained) s = : =
Dara Forde to supply Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Term: orde" AND "progress" AND "roll-
out" AND ("1998" or 1999")
e Date range: To the extent responsive documents
had metadata, all documents that were dated after
2000 were excluded from this search.
4D I Clare's conformance report and I Search A:
CEC paper . . A -
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Dryhurst" AND ("conformance" or
"CEC") AND ("1998" or "1999")
¢ Date range: N/A
4E I Research services reports: Search A:
assessment of product < ~ :
association for counter clerks, * Repository: (i) Inquiry Database and (ii) GLO
Horizon Database
e Search Terms: ("research services") AND ("1998"
or"1999")
« Date range: N/A
4F Right First Time report (HEB) Search A:
e Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: ("right first time") AND ("1998 or
"1999")
e Date range: N/A
4G I AnnGreen's report on Ic offices I Search A:
e Repository: (i) Inquiry Database and (ii) GLO
Database
wi5 "“office")
e Search Terms: "Green" AND ("
AND ("1998" or "1999")
e Date range: N/A
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No locum: Search
4H I Kate Doyle to provide reporton I Search A:
what we've learned from
regional helplines and e Repository: (i) Inquiry Database and (ii) GLO
systemline that could help us Database
identify common problems * Search Terms: "Doyle" AND ("helpline™ or
“systemline*") AND "1999"
e Date range: To the extent responsive documents
had metadata, all documents that were dated after
2000 were excluded from this search.
41 I Trevor Rollason's report to Search A:
Bruce McNiven
e Repository: (i) Inquiry Database and (ii) GLO
Database
¢ Search Terms: "Rollason" AND "McNiven" AND
"Report" AND ("1998" or "1999")
« Date range: N/A
4J I Report on ECCO and manual Search A:
offices, from Sue Smith .
* Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Smith" AND "ECCO" AND
("manual" w/5 "office*") AND ("1998" or "1999")
« Date range: N/A
4K I Kevin Lenihan's early report on Search A:
risk to transaction processin:
. S Ie Repository: (i) Inquiry Database and (ii) GLO
Database
e Search Terms: "Lenihan" AND ("risk" I w/10
“transaction") AND ("1998" or "1999")
e Date range: N/A
9.4 For the purpose of responding to Request No. 19 (and identifying and producing to the
Inquiry documents relevant to the same), POL has made enquiries in relation to potentially
relevant hard copy documents. In particular, POL has considered the relevance to Request
No. 19 of hard copy documents held at the Postal Museum.
9.5 POL wrote to the Postal Museum on 30 August 2022, enquiring as to whether the Postal
Museum held within its archives documents of potential relevance to Request No. 19. The
Postal Museum archivists confirmed that they do not hold any files or boxes that they
consider may contain documents of relevance to Request No. 19, beyond the files / boxes
that had previously been scanned and uploaded to Relativity.
10. REQUEST NO. 20
10.1. By its Request No. 20 dated 26 August 2022, the Inquiry requested that POL produce a
picture, diagram or print-out of what data / information sub-postmasters could typically see
on the Horizon terminal at the point of balancing their accounts. The Inquiry made clear that
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this was a request in relation to Legacy Horizon, and that documents produced in response
to the same should include any major changes in the period from 2000 to 2010. The Inquiry
requested that POL provide its response to Request No. 20 by no later than 2 September
2022.
10.2 In total, POL has produced 12 documents in response to Request No. 20. Relevant
documents were provided to the Inquiry on 2 September 2022.
10.3 We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 20. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege).
Repository Search Terms
1 I GLO Trial Bundles “balanc*"
2 I HSF Database “horizon system user guide" AND "balancing"
AND "2000"
3. I HSF Database “weekly balance period rollover"
4 I HSF Database "Horizon printout” AND "balancing"
5 I HSF Database “Horizon printout" AND "mediation"
6 I HSF Database "mediation" AND "balancing" AND "screenshot"
7 I HSF Database "Branch Trading: balancing booklet"
8 I HSF Database “operations manual" AND "balancing" AND
"4999 or 2000"
9 I HSF Database “Monthly Trading Period Rollover" AND
"balance"
10 I HSF Database "Branch Trading Statement" AND "balance"
10.4 In addition to the above targeted searches, POL also conducted the following reviews for
documents relevant to Request No. 20:
10.4.1
10.4.2
10.4.3
10.4.4
14/77078306_1
a full review of the materials held on the "POL Training Library Archive" SharePoint
site;
a full review of all operations manuals in use as at February 2009 (as provided to
HSF by Mark Horne of POL);
a review of two hard copy operations manuals identified from the pool of hard copy
documents collated from the Leeds archives; and
a full review of all of the hard copy documents that had been identified, scanned
and uploaded to Relativity following the site visit to the Chesterfield archives on 3
August 2022.
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11. REQUEST NO. 21
11.1 By its Request No. 21 dated 12 September 2022, the Inquiry requested that POL produce a
number of further documents relevant to Phase 2 of the Inquiry's proceedings. The Inquiry
requested that POL provide its response to Request No. 21 by no later than 26 September
2022.
11.2 In total, POL has produced 51 documents in response to Request No. 21. Relevant
documents were provided to the Inquiry on 26 September 2022, 30 September 2022 and 14
October 2022.
11.3. We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 21. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege).
No. Documen Se
1 Any risk registers produced by Search A:
POCL in relation to Horizon in "
. _ e Repository: (i) Inquiry Database, (ii) GLO
the period 1998 — 2001 Database and (iii) HSF Database
° Search Terms:
o “risk register" AND ("1998" or "1999" or
"2000" or "2001") AND ("POCL" or "Post
Office Counters Limited") AND "Horizon"
o “The rating of the risks"
o "RISKS TO BE REPORTED TO" AND
"Register"
o ("Service provider risk register" or
“programme risk register") AND ("1998"
or "1999" or "2000" or "2001")
¢ Date Range: N/A
2 Any reports produced by POCL I Search A:
Business Service Management R itorv: Inquiry Datab
relating to the performance of ° Repository: Inquiry Database
Horizon in the period 1999 — ¢ Search Terms:
200! o ("Business Service" or "Service
Management") AND "Horizon" AND
"performance"
o “BSM" AND “Acceptance Incident" AND
("1999" or "2000" or "2001")
e Date Range: 1 January 1999 — 31 December
2001
Search B:
¢ Repository: Inquiry Database
* Search Terms:
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o ("Business Service" or "Service
Management") AND "Horizon" AND
(1999" or "2000" or "2001")
0 "Radka" AND "Horizon" AND ("1999" or
"2000" or "2001")
o "BSM" AND "Horizon" AND ("1999" or
"2000" or "2001")
e Date range: N/A
Search C:
« Repository: HSF Database
¢ Search Terms:
o ("Business Service" or "Service
Management") AND "Horizon" AND
"performance" AND ("1999" or "2000" or
"2001")
o ("Business Service" or "Service
Management") AND "Horizon" AND
("1999" or "2000" or "2001")
o ("Radka or “Dave Miller" or "Dave
McLaughlin") AND "Horizon" AND
("1999" or "2000" or "2001")
o "BSM" AND "Horizon" AND ("1999" or
"2000" or "2001")
o “BSM" AND "Acceptance Incident” AND
("1999" or "2000" or "2001")
e Date Range: N/A
3 Acomplete copy of the Business.
Service Management Report
produced on 29 January 1999
(POL-0036334)
Not applicable. Relevant document identified manually
from Oasis documents scanned and uploaded to
Relativity in April 2022.
4 The “short update” authored by
Professor Andrew Davies of
Project Mentors Ltd to which
reference is made in the Memo
dated 8th December 1998 at
page 3 of POL00038829
(Control Number: POL-0027615)
Search A:
e Repository: Inquiry Database
e Search Terms: "Andrew Davies" AND "1998"
AND "update"
e Date Range: N/A
5 Any documents (including
“problem statements”, “proposed
solutions” or “assessment”
documents) that were prepared
in response to and/or following
on from paragraph 4 of David
Millers letter to Stuart Sweetman,
dated 16 November 1998
(Paragraph 4 of POL00028421
(Control Number: POL-0024903)
Search A:
e Repository: Inquiry Database
° Search Terms:
o “problem statements”
co “proposed solutions”
o “assessment’"
o "Sweetman"
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Sear
e Date range: 16 November 1998 to 31 December
1999
Search B:
* Repository: Inquiry Database
¢ Search Terms:
o "98" AND ("testing" or "milestone*") AND
“Horizon release management"
o "98" AND ("testing" or "milestone*") AND
“Horizon release management"
¢ Date range: Where metadata was available, all
documents dated after 31 December 1999 were
excluded.
Search C:
e Repository: Inquiry Database
* Search Terms:
o (“problem statement*” or “proposed
solution*” or “assessment*") AND
("Sweetman" or "Millers") AND ("1998" or
"1999")
o “problem statements” or “proposed
solutions” or “assessment” AND
"Sweetman" AND "1998"
e Date range: N/A
6 A copy of Vince Gaskell’s letter
dated 07 April 1999, as referred
to in the first paragraph of Dave
Millers letter dated 08 April 1999
(POLO0028406 _— Control
Number: POL-0024888);
Search A:
¢ Repository: (i) Inquiry Database, (ii) GLO
Database and (iii) HSF Database
¢ Search Terms:
o “gaskell" AND "April 1999"
o "Dave Miller" AND "Vince Gaskell"
o — ("vinc*" or "gask*") AND ("dave” or
“miller") AND "Apr*" AND "1999"
o ("vinc*" or "gask*") AND ("dave" or
“miller") AND ("7" w/3 (“April" or "99"))
o ("vinc* or "gask*") AND "Benton" AND
"April"
« Date Range: N/A
7 A copy of document
POL00028590 (Control Number:
POL-0025080), including page
26. The copy of this document
previously disclosed to the
Inquiry by the Post Office only
contained 25 of 26 pages;
Search A:
e Repository: Inquiry Database
e Search Terms: "This report is produced by the
POCL Service Management team and provides a
high level"
* Date Range: N/A
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18 October 2022
No. locum: Search
8 A copy of the letter from Dave Search A:
Miller to George McCorkell R tory: Inquiry Datab
referenced at paragraph 3 of © < Repesitony naully watepase
document POL00028657 ¢ Search Terms: "Dave Miller" AND "McCorkell"
(Control Number: POL-0025139) AND "Programme Lawyer's advice”
in which it was suggested that Date R NIA
there should be constraints on ao ea
the advice sought from the
Programme Lawyer;
9 A copy of the Memorandum Search A:
dated 09 February 1999, as * Repository: (i) Inquiry Database, (ii) GLO
referred to in paragraph 1 of ee
document POL00031109 Database and (iii) HSF Database
(Control Number: POL- e Search Terms:
0027593), © "1999" AND "Memorandum" AND "dave
miller" AND "Kelsey"
o "1999" AND "dave miller" AND "Kelsey"
o “What are the Target Dates?"
« Date Range: N/A
10 I Acopy of the contract Search A:
assurance report (“PWKP4-40") R itorv: Inquiry Datab
referred to in paragraph 1.12 *° Repository: (nauiry Database
(page 2) of document e Search Terms: "PWKP4-40"
POL00028152 (Control Number: Date R: NIA
POL-0024634); . eee
11 I Acopy of the value factor report I Search A:
(“PWKP4-41") referred to in R tory: Inquiry Datab:
paragraph 1.12 (page 2) of * Repository: inquiry Database
document POL00028152 e Search Terms: "PWKP4-41”
(Control Number: POL-0024634) .
« Date Range: N/A
12 I Acopy of the Formal Response I Search A:
to Review of Horizon R I iry Datab
Performance and Problem &\\ Repesitory duly eataneee
Managing Report issued e Search Terms: "Horizon Performance" AND
February 2000, and any other "Report" AND "2000" AND "review"
documentation dealing with how Date R NIA
the issues raised in report were Pale Range:
addressed.
11.4 For the purpose of responding to Request No. 21 (and identifying and producing to the
Inquiry documents relevant to the same), POL has made enquiries in relation to potentially
relevant hard copy documents. In particular, POL has considered the relevance to Request
No. 21 of hard copy documents held at the Oasis archives in Winchester and the Postal
Museum. Further details are set out below.
11.5 Oasis
11.6 Following a review of the index of files / boxes held at the Oasis archives in Winchester, POL
identified the following files / boxes which it anticipated may contain material or information
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Second Interim Disclosure Statement
18 October 2022
of relevance to Request No. 21 (and, in particular, to Questions 1 and 2). On 20 September
2022, POL arranged for these files / boxes to be scanned in their entirety and uploaded onto
Relativity. The searches set out in the above table were then conducted across these
materials, and responsive documents were reviewed for relevance to the terms of Request
No. 21.
Files
No. File Reference Box Reference Description
1 I F00001750706 0001562816 DSS Reporting & Online Service
2 I F00001750962 0001562840 ICL: Implementation Supplier Reporting
Requirements
3 I F00001755450 0001562628 Certificate of Internal Controls
4 I F00001755912 0001562649 Horizon: Security
5 I F00001755913 0001562649 Horizon: Service Report
6 I F00001759495 0001562789 Horizon Reports and Receipt
7 I F00001759501 0001562789 Migration of Post Offices to Horizon post National
Rollout
8 I F00001766813 0001562373 BA/ POCL Consultancy — Pathway 1993
9 I F00001769478 0001562887 Horizon: Service Reports
10 I F00001755343 0001562641 Counters Reports 97/98
11 I F00001765370 0001562597 CAPS 27: CAPS Programme Volumetrics Report
12 I F00001769059 0001562525 CAPS 14: Technical Implementation
13 I F00001769061 0001562525 CAPS IT 11: PAS Exceptions
14 I F00001769063 0001562525 CAPS IT 11: Personal Issue of PUN's
15 I F00001755886 0001562653 Risk Management
16 I F00001755890 0001562653 Counters Risk Management Committee (CRMC)
17 I F00001766820 0001562373 ICL Pathway — Fraud Risk Management
18 I F00001769479 0001562887 Horizon: Fraud Risk Management — General
Correspondence
19 I F00001755328 0001562627 Business Unit Performance Review (BUPR)
20 I F00001758304 0001562963 Horizon: Performance & Service Levels
21 =I FO0001755888 0001562653 Service Management
22 =I FO0001768546 0001562498 Horizon Commercial: Workload Brief
Boxes
No. File Barcode le Number Description
1 I F00001750706 0001562816 DSS Reporting & Online Service
2 I F00001750962 0001562840 ICL: Implementation Supplier Reporting
Requirements
3 I F00001755450 0001562628 Certificate of Internal Controls
4 I F00001755912 0001562649 Horizon: Security
5 I F00001755913 0001562649 Horizon: Service Report
6 I F00001759495 0001562789 Horizon Reports and Receipt
7 I F00001759501 0001562789 Migration of Post Offices to Horizon post National
Rollout
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8 I F00001766813 0001562373 BA/ POCL Consultancy — Pathway 1993
9 I FO0001769478 0001562887 Horizon: Service Reports
10 I F00001755343 0001562641 Counters Reports 97/98
11 I F00001765370 0001562597 CAPS 27: CAPS Programme Volumetrics Report
12 I F00001769059 0001562525 CAPS 14: Technical Implementation
11.7. Postal Museum
11.8 I POLwrote to the Postal Museum on 14 September 2022, enquiring as to whether the Postal
Museum held within its archives documents of potential relevance to Request No. 21. The
Postal Museum archivists confirmed that they do not hold any files or boxes that they
consider may contain documents of relevance to Request No. 21, beyond the files / boxes.
that had previously been scanned and uploaded to Relativity.
11.9 The Inquiry's letter of 10 October 2022
11.10 By its letter of 10 October 2022, the Inquiry sought certain clarifications in relation to POL's
response to Request No. 21. The Inquiry also requested that POL produce a copy of one
further document: a copy of Vince Gaskell’s letter dated 26 March 1999, as referred to in the
first paragraph of Dave Miller's letter dated 01 April 1999 (POL00028407 — Control Number:
POL-0024889). The Inquiry requested that POL provide its response by no later than 14
October 2022.
11.11 POL provided its response to the Inquiry's letter of 10 October 2022 on 14 October 2022.
11.11.1 The Inquiry requested that POL confirm that its searches for "fajny reports
produced by POCL Business Service Management relating to the performance of
Horizon in the period 1999 — 2001" included all 'CONGO' reports for the period
1999 — 2001. HSF's letter of 14 October 2022 confirmed that, in searching for
documents relevant to Question 2 of Request No. 21, specific searches had not
been carried out for the purpose of identifying ‘CONGO’ reports. HSF explained
that POL had accordingly conducted further searches and enclosed with its letter
of 14 October 2022 copies of relevant documents identified. For reference, the
further searches conducted by POL are set out below.
(A) Repository: (i) Inquiry Database, (ii) GLO Database and (iii) HSF
Database
(B) Search Terms: "Congo" AND "Report" AND ("1999" or "2000" or "2001")
(C) Date Range: N/A
11.11.2 HSF's letter of 14 October 2022 explained that POL had conducted further
searches for the Vince Gaskell’s letter dated 26 March 1999 and enclosed the
document that POL considered to be responsive to this request. For reference, the
searches conducted to identify this document are set out below:
(A) Repository: Inquiry Database
(B) Search Terms:
(1) "Vince Gaskell" AND "26 March 1999"
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12.
12.1
12.3
POL00114174ds
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Second Interim Disclosure Statement
18 October 2022
(2) "26" AND "March" AND "1999"
(C) Date Range: N/A
REQUEST NO. 22
By its Request No. 22 dated 15 September 2022, the Inquiry sought various documents and
information relevant to the overturned conviction of Ms Alison Lorraine Hall by 29 September
2022.
Pursuant to Request No. 6, POL had previously disclosed certain documents related to Ms.
Hall's prosecution on 3 December 2021. Request No. 22 sought any further documents
concerning Ms Hall's prosecution.
As explained in HSF's letter to the Inquiry dated 29 September 2022, POL took a similar
approach in relation to Request No. 22 as it did for the criminal case studies requested as
part of Request 42 of Rule 9 Request No. 14 and Request No. 17 (see further at Section 4
and 7 above). POL excluded the documents that had previously been disclosed under
Request No. 6 from this production.
POL has produced a total of 537 documents in response to this request.
REQUEST NO. 23
By its Request No. 23 dated 4 October 2022, the Inquiry requested that POL produce a
number of further board minutes and schedules. The Inquiry requested that POL provide its
response to Request No. 23 by no later than 7 October 2022.
We set out below a summary of the searches that POL conducted in order to identify
documents relevant to Request No. 23. Documents responsive to the following searches
were subject to manual review, and relevant documents identified were produced to the
Inquiry (subject to privilege).
No. Documen Search
1 The Minutes of the Acceptance I Search A:
Board which recommended eee . ae
acceptance of the Core Systems . Repository ® ate ease (ii) GLO
Release in late September atabase and (iil) atabase
1999; ¢ Search Terms:
o ("Acceptance" w/3 "Board") AND
“minute AND (("Sep*" w/3 ("99" or
"4999")) or "9/99" or "9/1999")
* Date Range: N/A
2 The Minutes of the Release Search A:
Authorisation Board which
authorised the acceptance of the
Core Systems Release in late
September 1999.
* Repository: (i) Inquiry Database, (ii) GLO
Database and (iii) HSF Database
¢ Search Terms:
0 ("Release" w/3 "Authorisation" w/3
“Board") AND "minute*" AND (("Sep*"
w/3 ("99" or "1999")) or "9/99" or
"9/1999")
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Second Interim Disclosure Statement
18 October 2022
Search
e Date Range: N/A
3 A ccomplete copy of Schedule Not applicable. The discrepancy on the page
A07 to the Authorities numbering is as a result of the way the Relativity
Agreement dated 24 May 1996. I software displays the original native document in the
POL00028163 (your reference Relativity native viewer.
POL-0024645) contains only 5
of 6 pages — page 6 of 6
appears to be missing.
13.3. For the purpose of responding to Request No. 23 (and identifying and producing to the
Inquiry documents relevant to the same), POL has made enquiries in relation to potentially
relevant hard copy documents. In particular, POL has considered the relevance to Request
No. 23 of hard copy documents held at the Oasis archives in Winchester and the Postal
Museum. Further details are set out below.
13.4 Oasis
13.5 Following a review of the index of files / boxes held at the Oasis archives in Winchester, POL
identified the following files / boxes which it anticipated may contain material or information
of relevance to Request No. 23 (and, in particular, to Questions 1 and 2). On 7 October 2022,
Oasis confirmed that each of these files had previously been scanned and uploaded to
Relativity save for the file entitled "RAB Matrix". POL subsequently arranged for the full
contents of this file to be scanned, uploaded to Relativity and reviewed for relevance to
Request No. 23. HSF's letter of 12 October 2022 confirmed that this review had completed
and that no further documents of relevance to Request No. 23 had been identified.
ID Barcode Des:
1 I FO0001765683 0001562544 Minutes of Project Team Meetings
2 I F00001755134 BUK_F6181 Pathway — Release 1c Authorisation Vol 1 & 2
3 I F00001767327 BUK_F6181 Pathway — Release 2 Authorisations
4 I F00001767327 BUK_F6181 Pathway — Release 2 Authorisations
5 I F00001751063 BUK_F6181 Release Authorisation
6 I F00001755134 BUK_F6181 Pathway — Release 1c Authorisation Vol 1 & 2
7 I F00001767327 BUK_F6181 Pathway — Release 2 Authorisations
8 I F00001750708 BUK_F6181 RAB Matrix
13.6 Postal Museum
13.7. POL wrote to the Postal Museum on 4 October 2022, enquiring as to whether the Postal
Museum held within its archives documents of potential relevance to Request No. 23. The
Postal Museum archivists confirmed that they do not hold any files or boxes that they
consider may contain documents of relevance to Request No. 23, beyond the files / boxes.
that had previously been scanned and uploaded to Relativity.
14. SUPPLEMENTAL PRODUCTIONS
14.1 Since the date of the First Interim Disclosure Statement, POL has also produced further
tranches of documents in response to certain of the Rule 9 Requests addressed in that
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statement. Further details in respect of these supplemental productions, and the steps that
POL took to identify these documents, are set out below.
14.2 Request No. 4
14.2.1
14.2.2
14.2.3
By its Request No. 4 dated 3 November 2021 and 26 November 2021, the Inquiry
requested that POL produce copies of all board (and sub-committee) minutes since
2000 which relate to the Horizon IT System.
HSF's letter of 16 September 2022 explained that, during the course of conducting
searches for documents relevant to Request No. 18, POL had identified a small
number of pre-2000 board minutes which discussed Horizon-related issues.
Further to the Inquiry's letter of 22 September 2022, POL arranged for copies of
these pre-2000 board minutes to be produced to the Inquiry on 27 September
2022.
By its letter dated 14 October 2022, the Inquiry requested that POL confirm whether
it holds any Post Office Counters Limited ("POCL") board minutes in the period
from 1 January 1996 to 31 December 2001. In response to this request, POL
conducted the following searches and arranged for the manual review of
responsive documents for relevance:
Search A
(A) Repository: HSF Database
(B) Search Terms:
(1) "Post Office Counters" AND "Minute" AND "Meeting"
(2) "Post Office Counters" w/6 "Minutes of a meeting”
(C) Date Range: N/A
Search B
(A) Repository: Inquiry Database
(B) Search Terms:
(1) "Post Office Counters" AND "Minute" AND "Meeting"?
(2) "Post Office Counters" w/6 "Minutes of a meeting"
(3) ("Post Office Counters" w/10 "Minute") AND "Meeting"
(4) "Post Office Counters" AND "Minutes of the meeting"
(C) Date Range: N/A
Search C
(A) Repository: GLO Database
(B) Search Terms:
% Sort Date: Value not set or prior to 1 January 2002.
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Second Interim Disclosure Statement
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(1) "Post Office Counters" w/10 "Minutes of the meeting"
(2) "Post Office Counters" AND "Minutes of the meeting"
(3) "Post Office Counters" AND "Minute" AND "Meeting"’?
(C) Date Range: N/A
14.2.4 HSF's letter of 17 October 2022 confirmed that POL had identified one minute of
the POCL board in the period requested by the Inquiry and enclosed a copy of the
same. HSF's 17 October 2022 letter also recorded that POL had made enquiries
with the Postal Museum in respect of this request and that the Postal Museum had
confirmed that it did not hold any relevant documents.
14.3 Request No. 5
14.3.1 By its Request No. 5 dated 26 November 2021, the Inquiry requested that POL
produce copies of various legally privileged materials, including copies of formal
written external legal advice concerning the Group Litigation and Second Sight.
14.3.2 HSF's letter of 5 April 2022 noted the following:
(A) in relation to Question 5 of the Request No. 5 (Second Sight), POL
proposed to carry out a further targeted review of email correspondence
between Mr Rodric Williams (of POL) and WBD."*
(B) in relation to Question 6 of Request No. 5 (Group Litigation), there was a
technical issue with respect to the date range searches that were applied
to documents provided by Womble Bond Dickinson ("WBD") which meant
additional keyword responsive documents would need to be reviewed.
14.3.3. HSF's letter of 30 May 2022 explained that each of the reviews described at
paragraph 14.3.2 above had completed and enclosed documents identified as
relevant to Request No. 5. That letter also explained that certain documents subject
to Without Prejudice privilege had been withheld from this production pending the
provision of consent from Freeths (the law firm that represented the Claimants in
the Group Litigation). These documents were subsequently produced to the Inquiry
‘on 20 June 2022.
14.4 Request No. 10
14.4.1 By its Request No. 10 dated 18 February 2022, the Inquiry requested that POL
produce various documents of relevance to Phases 2 and 3 of the Inquiry's
proceedings, including (at Question 27) “any reports, records or investigations
which address the extent of permissions or privileged access rights granted to
Fujitsu personnel’.
14.4.2 HSF's letter of 15 August 2022 explained that POL was in the course of arranging
for all hard copy documents that had been collected from various hard copy
archives to be reviewed for responsiveness to any of the Rule 9 Requests and that
it anticipated shortly being in a position to produce the first tranche of relevant
10 Document Type: Word or PDF.
‘1 Search Terms: "Strat*" or "Option*" or "Recommend™" or “Instruct* or "advi*" or "counsef" or "Opin*" or
“disclo*"; Date Range: 1 January 2015 to 31 December 2019.
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documents identified. HSF's letter of 15 August 2022 also recorded that, in
conducting this hard copy review, POL had identified an internal POL email chain
that was responsive to Question 27 of Request No. 10 and that POL proposed to
conduct further searches over the mailboxes of the individuals involved in this email
chain and would produce any relevant documents identified to the Inquiry as soon
as possible.
14.4.3 The supplemental searches that POL conducted are set out below — all documents.
responsive to these searches were reviewed in full for relevance to Question 27 of
Request No. 5. In total, POL identified a further 78 documents which it arranged to
be produced to the Inquiry on 29 September 2022.
Search A:
(A) Repositories: Rod Ismay mailbox, John Breeden mailbox, Angela van den
Bogerd mailbox
(B) Search Terms: (("Remote" or "Privilege*") w/2 "Access") AND "Fujitsu"
(C) Date Range: N/A
Search B:
(A) Repositories: Mailbox data harvested in respect of Mike Granville and Lynn
Hobbs in the Group Litigation
(B) Search Terms: (("Remote" or "Privilege*") w/2 "Access") AND "Fujitsu"
(C) Date Range: N/A
14.5 Request No. 11
14.5.1 By its Request No. 11 dated 28 February 2022, the Inquiry requested that POL
produce copies of various documents that had been referred to in Board and Sub-
Committee minutes that POL had previously produced to the Inquiry (in response
to Request No. 4).
CCRC Documents
14.5.2 HSF's letter of 14 April 2022 explained that POL had become aware that a
substantial volume of documents stored on the CCRC Database had been
uploaded onto Relativity without any extracted text, with the result that these
documents would not have been captured by any of the targeted searches that had
been conducted for the purpose of responding to Request No. 11. That letter also
explained that POL had resolved this issue and, having repeated its Request No.
11 searches, had identified a further tranche of relevant documents. These
documents were produced to the Inquiry on 14 April 2022.
14.5.3 HSF's letter of 30 May 2022 explained that, on 13 May 2022, POL discovered that
approximately 2,000 documents responsive to one of the Request No. 11
searches"? had been omitted due to a technical error. HSF's letter of 30 May 2022
explained that these documents had been manually reviewed for responsiveness.
12 ("Investigat™ or "Prosecut*") w/10 ("Policy")
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18 October 2022
to Request No. 11 (in particular, to Questions 15 and 46A) and enclosed copies of
further relevant documents identified.
Whistleblowing Policy
14.5.4 HSF's letter of 6 September 2022 explained that POL had previously produced (on
31 March 2022) various versions of the Whistleblowing Policy in response to
Request No. 11 (and, in particular, Question 48), including the version in force at
the time (Version 6.1). HSF's letter of 6 September 2022 also explained that POL
had since approved a new version of the Whistleblowing Policy (Version 7) and
enclosed a copy of the same.
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