POL00366967
POL00366967
Message
From: Simon Henderson
Sent: 30/01/2019 11:23:42
To: Jonathan Gribben Anthony de Garr Robinson
cc: Andrew Parsons j
Subject: RE: Parker 2 [WBD!
Jonny
’'m not sure that I do. We obviously need to make a correction and I think we are already in damage limitation
territory. But it will be hugely embarrassing if we need to make a further correction or corrections. We need to find out
the accurate position as a matter of extreme urgency and if this involves getting senior people from FJ and/or PO to get
involved from on high, my feeling is that is the right approach
Best
Simon
From: Jonathan Gribben
: 30 January 2019 11:17
imon Henderson
Anthony de Garr Robinson (
: Andrew Parsons
Subject: RE: Parker 2 [WBDUK-AC.FID27032497]
Simon,
We need to get to the bottom of which bank accounts did PO support deposit facilities for. We are making enquiries of
Post Office.
FJ didn’t mention savings accounts, ISAs etc. when we put the question to them. I will ask them to confirm the position
now.
I don't think we will get to the bottom of this quickly. In the circumstances, do you agree with our suggested approach?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
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From: Simon Henderson [!
Sent: 30 January 2019 10:53
To: Jonathan Gribben; Anthony de Garr Robinson (¢.
Cc: Andrew Parsons
Subject: RE: Parker 2 [WBDUK-AC.FID27032497]
OK but what other bank accounts did PO support deposit facilities for? If the only account anyone ever used the PO to
make a deposit into was a Giro account, all well and good but is that right? Even if no deposit could be made into 3
party bank accounts (i.e. NatWest etc) the PO (at least today and I imagine at the relevant time) offers all sorts of savings
accounts, ISAs etc. Could FJ have inserted transactions which had the effect of making deposits into (i) 3 party
accounts or (ii) PO accounts? If not, why not?
Best
Simon
From: Jonathan Gribben/ GRO. !
Sent: 30 January 2019 10:48
imon Henderson < GRO Anthony de Garr Robinson
Subject: RE: Parker 2(W
Simon,
Based on FJ's comments this morning, it looks like the statement that a Giro transaction was a type of PO transaction that
was different from any other payment to a bank may not be correct, which is why we are proposing to remove the full
footnote.
Based on FJ's current comments it appears that a SSC user could inject a transaction into a Giro bank account and any
other bank accounts that PO supported deposit facilities, but there would be a paper trail. We need to confirm this with
Post Office and I suspect that will take some time, hence the suggestion to remove the footnote and prepare a paper to
cover off the point.
Let me know if you want to discuss.
Kind regards
Jonny
Jonathan Gribben
Managing Associate
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From: Simon Henderson £ ERO. }
Sent: 30 January 2019 10:38
POL00366967
POL00366967
To: Jonathan Gribben; Anthony de Garr Robinson
Cc: Andrew Parsons
Subject: RE: Parker 2 [WBDUK-AC.FID27032497]
Jonny
This is obviously very concerning. Before we fire off any letter, we need to be absolutely sure we have now got things
right. If it is right that Giro was a standard EPOSS transaction and that FJ could have injected a Giro transaction, doesn’t
it also follow that FJ could have injected a transaction to any bank account? If so, that is a drastic departure from Parker
land 2. The paper trail point may help but it doesn’t solve the fundamental issue. Parker 2 presently says that a Giro
transaction was a type of PO transaction that was different from any other payment to a bank. Is that correct or not?
Best
Simon
From: Jonathan Gribben f~
: 30 January 2019 10:30
nthony de Garr Robinson
: Simon Henderson 4
Subject: Parker 2 [WBDUK-AC.FID27032497]
__>; Andrew Parson:
GRO P
Tony,
Yesterday FJ informed us that a Giro bank is also an AP transaction (like bill payments) - it is the only type of bank
account that is and all other banking deposits go through a totally different path. We included it as a footnote to Steve's
statement (para. 35). FJ have now told us that Giro Bank Transactions are not AP, but standard EPOSS Transactions
and that prior to online banking (introduced in 2003), POL did support some (but not all) other banks with deposit and
cheque cashing facilities which were also EPOSS transactions. They think that there was also a paper trail for those
transactions too (so they would be detectable during Post Office's reconciliation processes) and we will pick this up with
POL to confirm, but the immediate point is that we need to provide a replacement version of Steve's statement with the
footnote referred to above removed. Our suggestion is to send Freeths a version without the footnote by email as follows:
"Dear Sirs,
It has come to our attention that the witness statement we provided yesterday contained a footnote in
error. Please find attached a replacement version.
Yours faithfully"
We will then produce a paper to bottom out the above points.
Please let me know if you agree with this approach.
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
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From: Gareth Jenkins’
Sent: 30 January 2
To: pete.newsome’
Cc: Andrew Parsons; Dave.Ibbett:
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
“} Christopher Jay } Jonathan Gribben
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
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Hi Jonny,
Sorry, but you didn’t send me the actual question until I’d gone off line around 4ish yesterday, so other than the phone
call I had from Pete, I didn’t see the emails until late last night.
A further clarification:
POL00366967
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1. The Giro Bank Transactions are not AP, but standard EPOSS Transactions. I don’t know how info on them got to
Giro Bank — it may well be that Giro Bank worked off the paper trail and then sent summaries to POL which they
then reconciled with the Horizon feed. POL would need to provide the details.
2. Prior to online banking (introduced in 2003), POL did support some (but not all) other banks with deposit and
cheque cashing facilities. Again these were EPOSS (not AP) transactions. I assume that there was also a paper
trail here and it would work in a similar way to Giro Bank. Again it is POL that need to define the process. All
Horizon did was provide the buttons to record the electronic part of the transaction.
Is there any point in me re-reading Steve’s statement? I’m out this morning, but could do so this afternoon.
Hope this helps.
Best wishes
Gareth
From: pete.newsome@ GRO
: 29 January 2019 19:45
jonathan.gribben¢
gi.jenkins@~ )
use - effective software fixes
Cc: andrew.parsons@ 1; Dave. Ibbett@.
Subject: RE: SP Second Witness Statement: Possi
Jonny
I read out the questions and then interpreted Gareth's answers into my own words.
Pete
Sent from my Android phone using Symantec TouchDown (www.symantec.com)
From: Jonathan Gribben;
Received: Tuesday, 29 Jan 201
To: Newsome, Pete!
jay, Christopher
(Chris Jay,) GRO
; Ibbett, Dave _ I; Gareth Jenkins
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
Pete,
Thanks. When you say you have had to interpret, do you mean interpret my email and/or what Gareth has said, or do you
mean you passed on my email and Gareth confirmed that it is correct?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
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From: pete.newsome@ GRO
Sent: 29 January 2019 17:22
To: Jonathan Gribben; Christopher. Jay@
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
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Jonny
I talked to Gareth and the answer is below. I have had to interpret as Gareth was not able to send a response.
Pete
Pete Newsome
Account Manager
DHL,and.PRost_Office. Account, Fujitsu UK&l
Fujitsu named as :
Responsible Business sae
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From: Jonathan Gribben
Sent: Tuesday, January 29, 2019 5:04 PM
lewsome, Pete { >; Jay, Christopher’
ndrew Parson: ; Ibbett, Dave <!
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Yes it has been sent to Gareth, but it is:
How is it possible for SSC to inject a GIRO bank transfer into a set of branch accounts but it isn't possible to inject
another bank deposit? Gareth's answer Giro Bank paying in was possible into accounts by AP as it was
introduced before on line banking so you needed was the account number and detailed knowledge of the system
so theoretically it was possible. But there was a paper work trail to back this up that the sub-postmaster had to
send in to POL which should then reconcile to the AP transaction file from Horizon. (Post Office would understand
how it worked). A report was produced daily to reconcile against the Horizon feed, any discrepancy Post Office
may find where the paper work was not present would be discussed with the branch at the time. Post Office can
describe what would happen if the paperwork was not available.
Steve thinks the answer is:
I think the answer is that Giro bank is also an AP transaction (like bill payments). It is the only type of bank
account that is. All other banking deposits go through a totally different path. There may have been other banks
who had similar facilities before on line banking was introduced in 2004? but you would have to ask Post Office as
they were AP transactions.
Thanks
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
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From: pete.newsom i
Sent: 29 January 7019 16:55
To: Jonathan Gribben; Christopher.Jay; GRO
Cc: Andrew Parsons; Dave.Ibbett:
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Hi
What is the question? Has it been sent to Gareth already?
Pete
Pete Newsome
Account Manager
DHL_and Post Office Account, Fujitsu UK&l
E-Mai,
Web: hitp://uk.fujitsu.com
Web: uk.fujitsu.com
My normal working week is Monday to Thursday
Fujitsu named as
Responsible Business
of the Year
Fujitsu is proud to partner with Action for Children
CIO: Global Intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
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From: Jonathan Gribben <jonathan.gribbeni
Sent: Tuesday, January 29, 2019 4:58 PM
To: Newsome, Pete <pete.newsome_ >
Cc: Andrew Parsons <andrew.parsons¢
Subject: RE: SP Second Witness Statem
AC.FID27032497]
Pete,
Jay, Christopher <Christopher.Jay
amples to use - effective software fixes [WBDUK-
Steve has signed his statement and we are holding it subject to one point that Gareth Jenkins needs to check. Can you
make contact with Gareth and ask him to do that ASAP please?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
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Sent: 29 January 2019 16:49
To: Jonathan Gribben; Christopher.Jay¢
Cc: Andrew Parsons
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Jonny
Is available for a call now. Try his mobile. 5.30 is when he needs to stop.....
Pete
Pete Newsome
Account Manager
DHL and Post Office Account, Fujitsu UK&l
Web: uk. fujitsu.com
My normal working week is Monday to Thursday
Fujitsu named as
- . wie
Responsible Business —waumr
of the Year ‘
Fujitsu is proud to partner with Action for Children
CIO: Global intelligence for the ClO. Fujitsu's online resource for ICT leaders
Sponsors of the 2015 Rugby World Cup
&é Please consider the environment - do you really need to print this email?
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From: Jonathan Gribber
Sent: Tuesday, Janua
To: Jay, Christopher
Ce: Andrew Parsons ¢
; Newsome, Pete +
POL00366967
POL00366967
Subject: FW: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Chris, Pete,
We are close to finalising Steve's statement and it really needs to go today, but he is saying he isn't available after
5:30. Would you be able to speak to him to explain the importance of this please?
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
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Sent: 29 January 2019 16:27
To: Jonathan Gribben
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
No, can’t be available after 5:30
From: Jonathan Gribben <
Sent: Tuesday, January 29, 2019 4:21 PM
To: Parker, Steve < GRO. >
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes
Steve,
I should have said, we really do need to get this out today. Are you available this evening?
Thanks
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP
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From: Jonathan Gribben
Sent: 29 Janu:
To: 'ParkerSP)_
Cc: Matthew.L
Parsons
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Lucy Bremner; John.Simpkins¢ Andrew
Steve,
Thank you for this. Updated version attached. We are down to one point to bottom out, which is the GIRO bank theory in
para. 35. The bit we are struggling with is that it if it is possible to deposit money in a Giro bank account, how is it not
possible to deposit money in a normal account. Why is a paper slip necessary for this type of account?
It might be worth having a quick call on this. Are you free?
Kind regards
Jonny
From: ParkerSP(_ ~
Sent: 29 January 2019 14:47
To: Jonathan Gribben
Cc: Matthew.Lentoné GRO _;; Dave. Ibbett¢ } Lucy Bremner; John.Simpkins
Parsons ~
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Andrew
Latest comments / change marked
Steve
From: Jonathan Gribben
Sent: Tuesday, January 29, 2019 12:07 PM
To: Parker, Steve <_~
Cc: Lenton, Matthew; “jucy Bremner
Ibbett, Dave
“n>; Andrew Parsons
Simpkins, Joh
Subject: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Importance: High
Steve,
Please see attached the updated version of your statement and a comparison showing the changes made.
Can we discuss the comments at 2:00pm please?
Kind regards
POL00366967
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Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
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From: ParkerSP:
Sent: 29 January 2019 1
To: Jonathan Gribben
Subject: RE: SP Second Witness Statement: Possible examples to use - effective software fixes [WBDUK-
AC.FID27032497]
Yes, will do
From: Jonathan Gribben
Sent: Tuesday, January 29, 2019 10:40 AM
To: Parker, Steve _
Cc: Lenton, Matthew
‘n>; Ibbett, Dav
i
ftware fixes [WBDUK-
AC.FID27032497]
Steve,
Thank you for this.
I'm working on the statement now — next (and hopefully final version) will be with you within 30 minutes. We need to get it
out today, so please can you review on receipt? I'll send you a comparison so you can easily see the changes made.
Kind regards
Jonny
Jonathan Gribben
Managing Associate
Womble Bond Dickinson (UK) LLP.
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From: ParkerSP@
Sent: 29 January 2019 09:10
To: Jonathan Gribben
Cc: Matthew.Lenton: “Lucy Bremner; John. Simpkins¢~
Jenkins <gi.jenkinsG@
Subject: SP Second Witness Shtement: Possible examples ‘to use - effective software fixes
Ibbett¢™ —
IMPORTANT - This email or attached documents contains legal advice (or relates to litigation or anticipated litigation) and is being provided in
circumstances for which Legal Privilege may be claimed. Do not copy or forward this document without permission.
Jonny, we’ve been looking at some potential examples to use within the witness statement. Suggest WBD have a look
and decide if it is useful to add them as examples?
Effective Software Fixes
Pc0089918: PSteed2847N - reverse a rem, but when this has been reversed it is doubling up ona
balance
+ve: Already mentioned in statement but still shows a quick software error turn round
28/04/03: SSC (Paul Steed) identified error
28/04/03: Paul Steed updated and sent to MSU to handle discrepancy with FAD & POL
30/04/03: Development identify error
01/05/03: Work Package generated: PWY_WP_16353 B3S30R
07/05/03: Tested on LST. Fix released.
09/05/03: I have spoken to the PM to say that the software fix was sent down and became active on 07-May-2003 and
so there should be no recurrences of the original problem.
PC0123699: 28/07/05 ...payments and receipts are mismatched...PM states he was balancing on node 2
but there was discrepancies...
-ve: Initial SSC response was erroneous, to send back to Helpdesk.
+ve: Fast fix to live for financial issue
+ve: Demonstrates passing to MSU to tie up financial impact with POL
+ve: Example of looking at more than one site, diligence identifying other sites with issue
+ve: Shows how an initial R&P error is seen by PM and support are subsequently able to identify other events that tie it
in to other sites
28/07/05: Incorrectly sent back by SSC ...Balancing problems should be dealt with initially by NBSC...
28/07/05: ...Have spoken with the PM and advised...All that remains now is for us to try and identify the root cause of
the discrepancy which may take a while. As per usual we will forward our findings on to the MSU who will advise POL
accordingly...
29/07/05 With development. Work Package PWY_WP_22602 generated
01/08/05: BI3S80R_WP22602 is now ready for test
02/08/05: Release PinICL PCO123865
08/08/05: This has passed testing in LST and is being returned to RM for live pilot.
09/08/05: sent out to the Pilot 100 successfully
05/09/05: Applied to all live outlets and now in the live Generic Prodlists roll-outs using both $70 and S80 spares
POL00366967
POL00366967
When the PM went to produce a trail balance a discrepancy was shown but at the bottom the receipts and payment
totals did not match.
The £170 discrepancy was down to an APS txn message that had no product number and no primary or secondary
mappings. There was a critical event raised on 21st Jul on counter 9 which helped to identify this (Event Id:4 with the
text "Error Message: Failed to generate EPOSSCore transaction grammar").
As the txn message was incomplete it was omitted from the rollover 'calculations' and thus caused the discrepancy
reported.
When I checked the tivoli event archives yesterday I found that 216 of these events had been logged in the past 7 days
at different offices/counters
Looks like whenever the event is raised it is either down to a cancelled quantum txn
Have checked out a sample of 40 to 50 sites and they're all at S80 so its probably safe to assume its an S80 problem.
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