SSL0000119 - Transcript of audio provided to the Inquiry by Second Sight Ltd - Telecon IRH RJW and Chris Aujard Belinda Crowe December 5 2013

Evidence on official site

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Telecon IRH RJW and Chris Aujard Belinda Crowe
December 5 2013

(Conference introduction)
RON WARMINGTON: Hello Ian.
IAN HENDERSON: (Unclear).
RON WARMINGTON: Yeah, yeah. Okay, yeah, yeah.
IAN HENDERSON: (Unclear).

RON WARMINGTON: Yeah, I think so. It's the one with
as the participant code.

IAN HENDERSON: Yeah (unclear).

RON WARMINGTON: Yes, yes, and I'm doing what I said I'd
do. Okay?

IAN HENDERSON: Say that again.

RON WARMINGTON: I'm doing what I said I was going to do.
I record it.

IAN HENDERSON: Okay (unclear).
RON WARMINGTON: Okay, right.

(Chris Aujard joins call)
CHRIS AUJARD: Hello?

RON WARMINGTON: Yes, Ron speaking. I think Ian's on as
well.

IAN HENDERSON: Yes, Ian's on.

CHRIS AUJARD: Hi Ron, hi Ian. I take it from that
comment you're not geographically proximate. Is
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that fair comment?

RON WARMINGTON: Yeah, the word "think" would be the
clue, yes.

CHRIS AUJARD: Where are you at the moment?

RON WARMINGTON: Ian's in his office and I'm in mine.
He's in north London and I'm out in the Cotswolds.

CHRIS AUJARD: Right. So neither of you are affected by
the severe weather that's coming in at the moment?

RON WARMINGTON: No, doubt -- doubt it will be. No, we
got -- we're in pretty good shape here.

CHRIS AUJARD: Okay, that's good. You probably heard on
the news this morning there's severe storms forecast
fro all areas, including down towards where I live,

GRO b actually, which is going to be fun, but

RON WARMINGTON: Well, we're getting some really strong
gusts of wind coming past my office here, so I can
feel it coming.

CHRIS AUJARD: Yeah, okay.

Thanks very much for making the time to catch
up. I thought it would be useful following on --
we've had lots of meetings on cases, but I thought
it would be useful to just talk for a moment or two,
hopefully it won't take that long, on the question
of the -- the engagement and, to a lesser extent but
to an important extent, the fee.

The sort of background is that I know there's
been a series of emails around the costs you're
incurring and the resources you're having to deploy
in order to do your job properly, and at the same
time there's been quite a lot of, I think, concern
expressed by Tony around things like data protection
and other matters, and it struck me that now, now
that we've got past the first stage of getting --
getting the applications in, it would be a good time
IAN

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to sit down and put in place a sort of -- well,
I can say, a more formal engagement, but perhaps
just a letter, really, just setting out on -- for

your benefit, and for our benefit, just what
confidentiality issues are around your engagement,
what data protection issues are -- which, just by
way of an aside, I'm particularly sensitive to,
having been in a previous organisation caught out
very badly by the information commissioner. And
indeed, in that bundle, to include a bit more around
how you are charging, which, to be honest, is

a little bit opaque to me at the moment, and also to
clarify for both sides' benefit, I think, just the
scope of the work you're doing, which -- so
basically those are the things I want to kick around
with you.

I think in terms of most of -- and, sorry,
I should add to that that Rod has very helpfully
given me a copy of, I think, a confi(?) agreement
that you've signed a while back, which -- I think
it, sort of, gets us quite a lot of the way there
but not all the way there. So what I was hoping to
do is sort of pick up, you know, the provisions in
that, whack it into a letter, pick up the standard
consultants' Data Protection Act wording, which
Bond Dickinson very helpfully provided to me, put
that in a letter, and then attach a schedule -- two
schedules, so one just dealing with your -- the
scope of your work and then just dealing with the
fee side of things.

So probably the letter itself is -- it's got not
much substance, unless either of you have any
particular sues with data protection or
confidentiality. You know, I don't -- I don't think
you would but, you know, (unclear) the question at
this point.

HENDERSON: Chris, it's Ian here. I think it is
worth revisiting all of this because I'm conscious
that the nature of the engagement has changed.

I don't want to, sort of, go back over ground that,
you know, was covered quite a long time ago but, you
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know, this started off as a quick review by

Second Sight looking at a handful of cases, probably
a maximum of 15, but of course that all changed when
the MPs got more actively involved and we're now,
you know, looking at potentially 147 cases.

So the scope clearly sort of changed very sort
of dramatically. But actually the detailed work has
probably changed quite a lot as well because the
first phase of work was based on the concept of what
became known as spot reviews. We pretty well sort
of parked those --

CHRIS AUJARD: I would agree. And I -- and I think your
point is a very well made one, that the previous
work -- in a sense, I sort of held off on doing any
of this until now, because a lot of the work that
was being done to this stage would have been, to my
way of thinking, slightly hard to describe. You
were doing quite a few different things. Indeed,
one of the things you are doing is just dealing with
people who were, no doubt, getting in touch with you
via your website asking for information. So, you
know, you had quite -- quite -- not a disparate,
that's the wrong word, but quite a diverse range of
activities that you're undertaking, and indeed
historically you're doing the spot reviews. So it
would have been a bit messy, I think, trying to wrap
all of that up at that stage. That was my thinking.

So perhaps we could agree with you that the
focus should be not on saying, "Here's what you have
done", but "Here's what you are now doing and here's
what you will do -- what you are planning to do", or
what, you know, we are thinking to do for the
future. So, the focus on the future is probably the
right way round.

Ian, an issue for me was trying to come up with
a nice, succinct way of describing it. So, being
a very unimaginative person, when it comes to this
sort of thing anyway -- don't take it the wrong way,
I'm quite imaginative other ways -- but I nicked an
email that was flying around. I don't know who
IAN

prepared it, it may have been Angela or Belinda when
the first case review went over, I think, (unclear)
-- yes, it went over to you, and it struck me that
sort of encapsulated very nicely your role and I --
so can I read I out to you and then you can perhaps
leap in and tell me where I've got it wrong or what
it's not covering, but there are a few key things
here but obviously independence, I think, a key
feature, so we need to get that word into the terms
of reference clearly as much for our benefit as your
benefit, and also, you know, so that you can, if
quizzed by MPs, turn round and say: yes -- no, no,
we were acting -- you know, Post Office are paying
but we had an independent brief to do things
independently as we saw fit.

So that was one feature of it.

The other feature that I thought was -- this
email says you were to look at points of common
ground between Post Office -- so in relation to case

questionnaires that are submitted, you're to look at
points of common ground between Post Office and the
department of the postmasters -- subpostmasters,
look at points of disagreement and, where there is
disagreement on, sort of, you know, a fact-based
approach, try to form a view and then to make

a recommendation as to whether the case is suitable
for mediation. That struck me as being the

essence -- I'm sure there's more than that, but that
struck me as being the essence of the work that

you -- the challenge that you're currently faced
with.

So, yeah, I put that out as a way of describing
your activities, but, you know, happy to look at it
and think about it in other terms.

HENDERSON: I think that is right and, of course, the
key document in all of this was the document and the
FAQs that have been sent to all applicants,

including a flow chart describing the whole process.

I think that one additional issue that has

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arisen is we've taken on perhaps more work than was
anticipated originally relating, frankly, to almost
the administration of the scheme, and what we are
trying to do -- and we just got off a call with
Tony, sort of, Hooper --

CHRIS AUJARD: No, no, I was in the call, I didn't say
anything. I was actually in the call (unclear) --

IAN HENDERSON: Well, as you heard, what we're trying to
do is actually push a lot of that back to the
Post Office --

CHRIS AUJARD: Yes.

IAN HENDERSON: -- and we will sort of continue to do
that so, sort of, our added value is more
specifically, if not exclusively, related to the
substance of the matters raised in the CQRs and
obviously the corresponding reports from the
Post Office.

CHRIS AUJARD: I think that's got to be right actually
because, you know, Post Office has many (unclear) --
but what -- one of them is actually there are people
here who can do the administrative work
relatively -- well, one, entirely cost effectively
and -- I think more to the point, my concern is that
the two of you are going to be faced with an
absolute mountain -- or are faced with a mountain of
work and I don't want to have the -- in a sense,
your time -- it sounds wrong but I'll say it anyway,
I don't want you diverted away -- or by dealing
with, as I think you said, lots of interruptions on
the phone because people are picking up asking you
for administrative matters when, frankly, you can do
much more valuable things and possibly meet our
timetable, bearing in mind that we are as under as
much pressure as you are to get this out the way.

RON WARMINGTON: Chris, Ron here, I'm delighted to hear
you say that because, you know, if you've ever done
any investigation work, you probably have, you know
it is pretty cerebral and, you know, getting into

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the flow of some of this stuff, trying to get to the
bottom of really quite complex matters, often badly
expressed, really is "please wrap cold wet towel
round head and call me later" stuff. So the
interrupts are very damaging and costly in that

context.

CHRIS AUJARD: No, no, I agree -- I can see that, because
one of the -- you know, I guess one of my approaches
in reviewing the -- some of the work that Angela has

done is almost to ask the question: well, what would
I say about this if I were Second Sight --

RON WARMINGTON: Good.

CHRIS AUJARD: -- you know, actually? And sometimes it's
hard, you know. It's -- I'm not sure I necessarily
have the answers because -- well, in fact, I don't

RON

IAN

have the answers because it's not my skill-set, not
unless it's a question that I have to ask myself
before things go over to you.

Sorry, I actually agree that point. Sorry,
there's one thing I should say which is slightly on
the admin side. I do think that you have a very
valuable role to play in interacting I think
probably principally with Angela but -- and Belinda
as well, over format and structure of reports that
I'd very much like to -- in other words, if you see
things that are going to make life easier for you or
you see things where you think, "This has got to be
a better -- there's a better way of expressing
this", then I'd want to include that as part of your
terms of reference, as it were, to come back and
say, "You know what, this format could be" -- I
mean, I'm sure you do that anyway but, if you don't
mind, I'd quite like to build that into --

WARMINGTON: Chris, Chris --

HENDERSON: We've already started doing that
because -- and this was experience of -- partly
built up during some of the spot reviews. We
identified quite early on the need to sort of
RON

IAN

RON

streamline the work flow, and what we've got in mind
as far as the mediation reports are concerned, our
report is going to sit on top of both the response
from the applicant, the so-called sort of COR, but
also, sort of, Angela's, sort of, report. It's not
our intention to duplicate material that is
adequately contained within those reports but much
more, as you have indicated, to, sort of, compare
and contrast and really, sort of, pull the issues
together.

That may mean, in some cases, our report is
actually going to be sort of relatively short. You
know, what we've got in mind is that in some cases
it may be as short even just two or three pages.

WARMINGTON: Yes, yes.

HENDERSON: I discussed this briefly with Tony
Hooper. He's got some reservations about that and

I think when we get to that point, and we're only

a few weeks away from that, we probably will need to
sort of sit down and you know and discuss
collectively the best approach.

WARMINGTON: Yeah, I mean, Ian, I think you and

I have been on the same page for months on this.

I would envisage our reports being between 2 and 10
pages, unless there's real exceptional
circumstances, more frequently about the number you
described, and where we are going to refer -- first
of all, you can be sure that the mediators will want
to read that report but also the two other
components that sit underneath it that Ian's
described, and my input is that they will read all
that stuff. So, you know, size isn't everything in
these cases.

CHRIS AUJARD: I would absolutely agree with that.

RON

I think in some ways it's harder to come back with
a two-page report.

WARMINGTON: Much, much.

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CHRIS AUJARD: It's -- sorry, it's going to sound wrong,
but for the right reasons, that -- because in
a two-page report you might say: I've done a lot of
work and I've reviewed this and I actually -- there
are five points where we can agree, there are six
points where we disagree. The most sensible way
forward on this is a mediation and, you know, here's
how I might steer that mediation, sort of, you know,
debate.

And that sort of -- that -- but that -- I know
myself, from having worked an industry where you
sell your goods by the hour, actually people look at
that and say, "What? You know, you've only done
that and you going to charge all that number?" But
actually there's as much work, if not more work, in
writing, coming up to that conclusion, a short
report than a long report, and that -- I think as
you will appreciate.

RON WARMINGTON: Oh, there's plenty of jokes about that,
aren't there? Sorry, you know --

CHRIS AUJARD: (unclear) one of course is the auditors,
you know, a one-page sign off on your financial
statement and that's all they do. You know, their
deliverable is one page.

RON WARMINGTON: Yeah, the old joke is the vicar that,
after a two-hour sermon, says, "I'm sorry I didn't
give you the one-hour sermon but I didn't have time
to prepare that."

I mean -- but, Chris, just a quick interjection,
which I hope is not tangential to the main
discussion, the big challenge for POL, which I don't
think is coming across in the first responses we're
getting, is how you deal -- how you prevent me -- or
Ian and I -- from saying something like this, to
say: I don't know why you've bothered to try to get
to the bottom of the individual transactional issues
on 10-year old, 8-year old, 6-year old case now and
why you've put in your text that you've been unable
to defend yourselves, POL, in your report. Because
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the data is no longer available, how that is going
to avoid me saying, in response: Look, you've only
got yourselves to blame. You know, the person
flagged up these issues seven years ago, you didn't
investigate them at the time and now, guess what,
you find you can't investigate them now. How should
that fall in terms of burden of proof o the
shoulders of the appellant in this case?

That's the --

CHRIS AUJARD: Yeah, I know.

RON

IAN

RON

IAN

WARMINGTON: If you're not careful you'll be doing
what they did in the spot reviews, which is, you
know, you will get 600 pages of response to which my
answer will be what I just said.

HENDERSON: The other thing we will be saying is, if
you look at the contractual relationship between the
Post Office and subpostmasters and -- and together
with that you look at what information was available
to the SPMR, often it was impossible in reality --

WARMINGTON: Correct.

HENDERSON: -- for the SPMR to resolve certain sort
of issues if they arose, and what we are now finding
is that POL failed to provide the level of support
that was necessary that would enable the SPMR to
resolve those issues. That, I think, is going to be
a fairly common finding throughout many of these
cases.

WARMINGTON: Yes. The most extreme examples of that
are person raises issues concerning some of the
issues that we know have -- have caused problems for
many, or where people have experienced a lot of
problems, let's say on scratchcards or power
failures or whatever. They then get suspended
without pay. They lose access to their own records,
let alone any of POL's, and that's the end of it.

So they are completely unable, both financially and
in terms of resources and in terms of data
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availability, unable to prove themselves innocent or
to defend against a claim for funds under the
contract, in many cases asserting that they didn't
even see the contract until their lawyer contacted
them, and -- and therefore unable to prove their own
case and POL chose not to either. So --

CHRIS AUJARD: I think the challenge is a good one and
I think that -- well, tending to recap, there's a
challenge in terms of how can we, at this stage in
the process, endeavour to structure things so that
we get both the best possible result for all parties
concerned and do it in the most time efficient
manner or most effective manner. And I think, off
the top of my head, I'm not sure I'd necessarily
have an answer to -- to any of those challenges.
I've had a few thoughts that have been (unclear)
around there. So I suppose, I -- thinking it
through logically there is an approach which could
be taken in all cases along the lines of that, you
know: there's been an assertion one way, there's
been an assertion the other way, the evidence that
you have seen supports either -- supports neither
side nor does it disprove either side.

RON WARMINGTON: Yes.
CHRIS AUJARD: So it's one of those ones.

We, Second Sight, have conducted an
evidence-based review of the facts put before us --
you can make, obviously, other comments about
training or what have you, but -- and, you know, on
the key things, actually, you know, the evidence
there is neither supports nor affirms either way.

This then, and again I'm thinking out loud so
correct if I get this wrong, is then is a case that
should go through to mediation, absolutely, and the
mediator should be made clearly aware of the
limitations that arose on both sides in coming to
a settlement on the facts concerned.

RON WARMINGTON: Yes. That's -- you know, that's -- so
IAN

RON

IAN

in theory, and this is obviously what we're going to
get to in this conversation, we ought to be able to
say -- you would hope we would be able to say
something like, look, provided we get -- in

a typical case, if we get an incoming COR from

a combination of the efforts of the applicant and
his or her adviser, and the second component being

the POL report, we ought to -- you know, we ought to
process that in three man-days, say, for argument,
something like that, and therefore, the cost -- you

know we can work it out. Bom, bom, bom, bom, bom.

Now at the moment, of course, it is -- somebody
used the phrase in the meeting today -- quite
difficult to forecast the future because if we get
into that -- and I was alluding to this in what
I said -- if we get into the sort debates we had
and, frankly, mess that we had on some of the spot
reviews -- you know, in some cases we were 200 pages
into a document before we suddenly realised it was
completely irrelevant. You know, that's terribly
time-wasting and in fact it builds up a level anger
that it's hard for us to dismiss from our minds and
to come back to an objective state.

HENDERSON: Chris, if I can just mention one further
point which I think is causing unnecessary
complication, and you may want to review this, sort
of, internally within the Post Office anyway, is the
whole question of suspension, which seems to happen
pretty much automatically --

WARMINGTON: Yes.

HENDERSON: -- on, you know, any case that has the
potential to be sort of prosecuted. My concern is
that whilst suspension is theoretically a neutral
act designed to protect both the Post Office and the
applicant, because of the way that the

sub-post office is set up, it's anything but
neutral. It usually results in, if they've got

a lottery terminal, that being removed. It usually
results in a loss of a viable sort of business. And
what we are seeing is huge consequential loss

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RON

calculations being performed that are a consequence
of the decision to suspend. And, you know, whilst
this is probably outside the scope of what we are
doing, I am quite concerned about the fact that
suspension seems to be almost the default sort of
position once a case is referred for investigation.

WARMINGTON: Yeah, Ian, on that point, you get

this -- it's not even good use of English -- you get
the investigators arriving and saying, "We're going
to preventive suspend you." I think that's the term
they use. And it just seems to be a natural way of
carrying on, which then -- you know, you get to the
motivation word, Chris. What happens then is the
motivation of the investigation team to reach

a quick conclusion vaporises, that they don't have
any commercial --

CHRIS AUJARD: I can sort of see -- from the way you've

described it I can see the (unclear) that flows
through of the order of events.

RON WARMINGTON: Well, I mean, I was global head of

investigations for two of the world's biggest
companies for two decades. I can count on the
fingers of one hand the number of times we suspended
without pay, and we were handling 3,000 cases a year
or more. So it was unheard of. And to have an
investigation that lasted, you know -- actually, you
know, where a decision was not made in terms of the
culpability of the principal suspect within three
months was also unheard of, you know.

CHRIS AUJARD: I think in relation to those bigger macro

issues, you know, I would -- I would -- you know,
I'm new at the Post Office, but I've certainly --
the Post Office is cognisant of macro learnings

from -- you know, from this exercise and, you know,
I'm sure factors such as the one you've mentioned
about -- you know, the analogy of suspension without
pay is a good one actually to bear in our minds

as -- well, as the Post Office goes through that
exercise.

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So that's -- I don't -- I think you can --
I think they are useful observations. They're
probably ones that affect, to my way of thinking
(unclear) our way, it's just it's outside the scope
of this project, because the project, as
I understand it, having come into this -- into
the -- very, very late in the day, now -- what -- is
now very focused on a process, and the process is to
make sure that those people who have put in
applications and submitted their case questionnaires
have the right thing done by them, which I think is
going to take that through to the mediation stage,
and therefore my -- my -- I'm very, very focused on
taking -- making sure that people get through to
mediation, that investigations are done to the right
standard, and that you -- you collectively are
placed in a position where you can actually do what
is required to move it on to the next stage. And
I don't -- sorry, that sounds like an unduly
narrowly focused on --

RON WARMINGTON: No.

CHRIS AUJARD: I'm very conscious that for a lot of
people time is important, so have entered this
process so they (unclear) very little (unclear) and
I don't want to be in a position where we end up in
July next year and there's still people who are
dangling around.

RON WARMINGTON: Well, Chris --

CHRIS AUJARD: My current focus is on moving it forward.
But I think the points you have made are ones, you
know, which actually I absolutely will relay on to
the right people.

RON WARMINGTON: Yeah, I mean, to some degree the amount
of -- you could think -- it could be easily thought
that the amount of time we will take in responding
to POL's reports will be somewhat directly
proportional to the degree of defensiveness in POL's
stance, which to date has been more defensive than
any company I've ever come across in my life. It
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has been totally -- total denial that there was
anything wrong at any point, not just with the POL
software but with any of the surrounding operational
processes, people, practices or whatever.

By the way I used the term "preventive
suspension", the term is "precautionary suspend".
"We're going to precautionary suspend you." It's
used multiply in language.

But coming back to the point, if POL is
defensive to the point of, sort of, producing vast
reams of paper without pointing out why any of these
documents are submitted, I'm duty-bound to review
them, which is going to chew up time, but at the end
the degree of defensiveness is probably not going to
have an effect. The quantity of paper is but, you
know, would it make a difference if POL said
something like: yeah, actually, although we never
committed to carry out any investigations and it was
never funded to do that, we can see that, you know,
there have been investigation -- investigative work
that perhaps should have been carried out wasn't.
Had that happened we might have discovered system
improvements, process improvements, found out the
root route cause of some of the shortfalls, not
actually taken people to court for the losses, and
we -- you know, we could see that point.

Of course, the ramifications of that are
enormous. The cost of that decision is enormous.
But, on the other hand, fighting it if it's true
will get us into a lot of cost -- get POL into a lot
of cost, will drag things out, and actually might
backfire much more seriously than would some early
concessions.

You know --
CHRIS AUJARD: I'm not sure that -- I can understand what
you're saying but for the fact that the standing

instructions in the investigation team --

RON WARMINGTON: Yes.
CHRIS AUJARD: -- is to produce a document with facts in
it.

RON WARMINGTON: Yes.

CHRIS AUJARD: And the reason it's done that way is,
firstly, it was agreed by the working group that
that's what they do, so that seems sensible. It's
also to stress to them that they had to be
independent in their approach, you know. You know,
obviously they all have -- they have to be
independent in their approach.

RON WARMINGTON: Are you talking about us? Are we
talking about us, Chris, or the --

CHRIS AUJARD: No, I'm talking about our internal
investigation team.

RON WARMINGTON: Oh, yeah, yeah, right, okay, yeah.

CHRIS AUJARD: That's the bare, very strong standing
orders, if you like. Therefore, they are producing
a document which has in it a series of facts. The
reason it's done that way is that, as I've
understood it anyway, and I think I've taken my
leave really from what was here when I came in, the
refrain, the next stage in the process is to say,
on -- in these facts that have been produced -- by
both sides, so both the subpostmaster and by the
Post Office -- is there -- is it something which is
amenable or suitable for the mediation process,
bearing in mind this is not a court process where
one party is arguing one way, the other party is
arguing the other way. The purpose of the mediation
process is to get an agreement between the parts and
some form of closure or settlement or whatever you
like to describe it.

So to your point about being defensive, in
a sense that's a slightly -- that's not the --
that's not the -- it's the reason for which people
are -- (unclear) that's neither -- you know, it just

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represents the facts and that's, in a sense,
defensive and offensive -- or defensive and whatever
the opposite is in the --

RON WARMINGTON: Yeah, yeah, Chris, I'm absolutely on

board with what you say, I don't have an issue with
it, other than -- first off, one of the core --
there are some core issues here which have -- have
infused everything.

The first of the two top core issues are -- the
first is risk acceptance decisions have been made by
POL where POL accrues the benefit but the risks fall
on the shoulders of the SPMRs, and they don't even
know they've got those risks. Okay? That is a --
that is a business model which is so deeply flawed
it should have been picked up years ago, okay.

I can elaborate on that if you wish but when POL
decides what controls and preventions it's going to
put in place on foreign currency dealings, on ATMs,
on various processes that are deployed, it can
willy-nilly take the decision to roll something out
which is going to put the SPMRs at risk in the safe
knowledge that it will receive the benefits of the
shortcut and the subpostmasters will carry the can
on it. And that has happened.

Now, that itself has led to the situation where
the investigation function, the POL security team or
the audit team or whatever they were called, has
never been held to respond -- it's never one of its
triggers to respond to pleas for help from the
subpostmasters. It's written out of the contract.
The contract says the only time the investigation
team will be deployed is where it suspects crime.

So unlike all big companies -- all other big
companies in dealing with their staff, where the
staff would have a call on the investigation
function, that has not been the case.

Now, that has carried forward to when those
first interviews take place in the branch and the
person saying, "Oh, I've been telling the Helpdesk
for the last six months that I've got this bloody
difference -- these differences arising, I think
it's down to the scratchcard problem."

And all that's been happening is the
investigation team has been saying, "So what did you
do in that six months?"

"Well, I carried it forward because the Helpdesk
said the problem would go away, it would sort itself
out."

"Well, exactly how did you carry it forward?"

"Well, I pretended I'd got the cash in the
till."

"Ah, so you've committed false accounting,
right, thank you, closed."

Literally you can hear the book being slammed
shut and that's the end of it.

Now, that is ever so serious, because the
investigation teams did not -- I have to tell you,
I've listen to so many recordings and transcripts,
I know that what I'm saying is truce. What that
meant is that either POL proceeded to civil asset
recovery or, worse, to criminal prosecution without
the underlying factors having been investigated.

Now, that is bloody serious, because it would be
a criminal offence to not yield up to the defence
evidence that might undermine the prosecution. It
is a moot point as to whether failing to investigate
in the first place constitutes a similar offence.

And the fact that POL has carried out its own
prosecutions meant that the safety net of having an
independent body such as the CPS review the adequacy
of the investigation that went into -- leading to
the charge has meant that POL has acted basically in
a way that -- where it could be accused of having

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misled the courts.
It's as serious as that, Chris.

CHRIS AUJARD: There's a lot -- you've put forward a lot
of --

RON WARMINGTON: Well, I've put all this in a report by
the way. I don't know if Susan shared it with you,
but she asked me --

CHRIS AUJARD: No, no, I'm sure you shared it with
Susan Crichton in the past and -- you know, how it
is. Those -- those issues, whatever they may be,
and whether --

RON WARMINGTON: Well, it is fundamental to -- almost
every case is impacted by that point.

Ian, you have come to this later than I have in
the sense of -- I think I reached this position
probably three or four months before you --

CHRIS AUJARD: Ina sense, that's good for your purposes --

RON WARMINGTON: Yeah.

CHRIS AUJARD: -- that background knowledge that you may
have formed in connection with other (unclear) --

RON WARMINGTON: Yeah.

CHRIS AUJARD: -- my focus, as I said about -- a few
minutes ago, is really now on taking it --

RON WARMINGTON: Yeah.

CHRIS AUJARD: I'm dealing with the -- each case as it
comes through.

RON WARMINGTON: Yeah.

CHRIS AUJARD: So the macro -- macro issues are another
pot. They're not in my pot, they belong to other

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parts of the organisation, and I can see through
some of those spots on this call into that pot or
pick up your thematics sheet and use that as a piece
of -- you know, an input to it, maybe, but the pot

I am charged with looking after, and I think the pot
that the working group is charged with
administering, collectively, is to deal with the
proper processing of the applications as they come
through.

So, in a sense -- you know, I don't want to
sound rude, but maybe it does sound a bit rude, is
actually I'm very, very focused on the -- on each
individual case as it comes through and what each
individual case is doing, and to make sure that --
to the extent possible, that the facts relating to
each individual case are unearthed internally --

RON WARMINGTON: Yeah.

CHRIS AUJARD: -- and then -- in a -- what I hope is
a sort of neutral manner, not, you know -- not
(unclear) another side there, with a view to
answering the principal question which I think needs
to be answered, which is: is there stuff here that

is going to take us -- it makes it suitable for
mediation? And during that mediation process itself
one suspects -- but I don't know for sure, one
suspects -- that a lot of these other issues will
follow up in the room, because people will, you
know, have (unclear). And they might not have all

the views that you have, by the way. They might
have different views or different angles on things
or what have you, but that's their -- that's the
purpose of getting them together.

So I'm not -- don't get me wrong, I'm not
(unclear) -- talking to you and hearing what your
views are on various things, that is definitely --
you know, that's helps us to know that you have been
through this process and that you have yourself
formed views. What I'm saying is, for this purpose,
I'm -- really want to make sure that we do -- we do
justice by the people we're putting into the scheme
and make sure that we deal with the applications on
the basis of the facts that they're putting forward.

RON WARMINGTON: Yeah, just one quick --
CHRIS AUJARD: (Unclear) actually (unclear) a last bit --
RON WARMINGTON: No, no, no, no, that's not -- I

didn't -- look, we're big boys and tough boys, we've

IAN

dealt with lots and lots of really tough situations
over the years, so this isn't tough at all.

What I'm interested in Ian's comment on is the
blue chart, the famous flow chart, says that what
we're trying to do is to produce a case review and
a recommendation of whether the case is suitable for
mediation.

Now, what Tony Hooper was looking for -- Ian,
correct me if I'm wrong, because you were quite keen
to learn what his expectations were in respect of
our reports -- he's indicated that what he's looking
for, I think -- you fill in the gaps -- was
something which was much more opinionated than we
were expecting it to be in terms of who's got the
better case here.

What did you get from the -- not today's meeting
but the prior meeting where this came up?

HENDERSON: Yeah, and Chris, just a bit of
background, Tony Hooper, sort of, phoned me probably
about ten days ago and spent probably 20 minutes
explaining, you know, how he saw the mediation, sort
of, scheme working, and emphasising the importance
of Second Sight's report, and he described it as
being akin to a judicial finding.

You know, clearly it's going to be
evidence-based and so on but I think he wants us,
within those reports, to very clearly, sort of, come
down, you know, one way or the other, and that
clearly has the potential to be very significant in
terms of how the mediator then deals with that.

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RON WARMINGTON: Yeah, otherwise, Ian, we would have
a one --

CHRIS AUJARD: (Unclear) your work and the mediation
effort, both process -- both parts of the process,

RON

isn't it, because clearly, you know, forming a view,
an evidence-based view, whether it's suitable for
mediation, identifying points of common ground,

et cetera, it requires quite a lot of work actually,
but to go and actually produce a judicial -- a
quasi judicial opinion on something is -- well,
there's a liability issue as well, obviously, you
know, which is -- it he's (unclear) an expert
witness, you know, he was standing up there saying,
"I believe this to be the case." I wonder --

I hadn't picked that up, sorry, I picked that up
from Tony, and I'll -- it may be that I should give
him a call at some point in the next few days and
say, "Tony, we're about to embark on a very
substantive exercise" -- it's a very substantive
exercise, let's not kid ourselves --

WARMINGTON: Yeah, yeah.

CHRIS AUJARD: -- "on both sides, and -- but we need to

IAN

be really clear about the end game and have
a separate specially called working group meeting if
needs be."

HENDERSON: Chris, what I've already suggested is,
you know, rather than just deliver a Second Sight
report to the working group, as we get close to that
point we want to actually put our draft report
probably for the working group or a sub-set of the
working group and actually use that as very much

a sort of a learning opportunity --

CHRIS AUJARD: Yeah, yeah.

IAN

HENDERSON: You know, to -- is this addressing issues
and expectations? You know, does it need more, sort
of, detail? Is it helpful to the mediator? And so
on.
CHRIS AUJARD: Yeah, no, yeah, and I think that would be

IAN

a useful -- a very, very useful exercise actually.

I think -- there's no point at this stage -- we're
frankly, you know, all up against it in terms of the
sheer wall of work that's coming our way but we just
can't afford to waste --

HENDERSON: Can I just mention one other thing? I
mean, the overall objective is to reach closure, you
know, relating to as many cases as possible.
However, so far, nobody has really identified the
most significant risk factor that could well prevent
closure occurring, and that is, when we get to
mediation, and I think the majority of applications
that have come in, you know, will head in that
direction -- you know, there's clearly some that
will be resolved before that and we've had some
early successes, you know, with Angela's team and so
on, and there may be some other, you know, small
number items, you know, where the financial amounts,
sort of, being claimed, you know, can be resolved in
other ways, but the vast majority of cases I expect
we will recommend that arbitration is appropriate.

What nobody can anticipate, however, is how, for
want of a better word, generous or otherwise the
Post Office will be during the mediation sort of
process, and that, to my mind, is the biggest risk
in all of this. There is a very clear expectation
by many applicants for -- the outcome that they are
looking for is financial compensation. What we
haven't sort of highlighted so far are the magnitude
of some of those numbers. But, you know, you have
got the applications. I think the largest number
that I've seen is in the order of £5 million. But
I am very concerned at the potential expectation gap
between the applicant and, at the end of the day,
what Post Office may be prepared to do in order to
achieve closure.

CHRIS AUJARD: I think that's a very helpful comment

because that's -- I mean, that's clearly something
that, you know, the Post Office -- the Post Office

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IAN

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itself has to look into. You know, at the end of
the day it's our money and our risk but that does --
you know, it's useful that you'll pick that up as
well.

HENDERSON: I'd go even further than that, and this
is not a discussion that we need to be sort of part
of, but I would strongly suggest that Post Office
maybe on a worst case scenario, you know, does look
at the numbers involved and perhaps internally, you
know, makes some sort of, you know, board level
decision as to how it may respond, and if at the end
of the day there is going to be a huge gap between
what applicants are look for and what Post Office
has got to offer, frankly we almost need to sort of
question whether this whole process is the best way
to move forward, bearing in mind the overall
objective, which is to achieve closure.

You know, the worst outcome for everyone is for,
you know, all of us to chew up a lot of time, cost
and energy and effort and at the end of the day fail
to reach a satisfactory conclusion by way of
mediation. If we're not going to achieve that, you
know, maybe the best thing is just to pack this all
in and allow, you know, litigation, you know, to
proceed, bearing in mind --

CHRIS AUJARD: I think I'm going to surprise you, as

IAN

a lawyer I'm never in favour of litigation.

HENDERSON: Very wise.

CHRIS AUJARD: Never in favour of litigation. My very

strong sense, actually, is, you know -- I think what
you're saying to me is proceed with care for some
very tough discussions in the mediation process and
also be prepared for the fact that actually you
won't get there on some of them, and, you know,
that's sort of useful.

RON WARMINGTON: Yeah. I mean, although he's far too

astute to hold the pistol to anybody's head, Alan's
made it pretty clear that he's got his finger
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hovering over the big red button that says, you
know, neutron bomb and, you know, if the first few
mediation hearings after all this work turn out to

be completely -- you know, they get stonewalled and
nothing -- no satisfaction to, you know, the
applicants or him, I think he will be -- find it

very difficult to resist slamming his finger down on
the button. And that would involve a walk-out and
the whole process would evolve into an acrimonious
mess, which POL would be -- wish it had never
started. I suspect.

So, Ian -- I'm glad Ian's raised that point. It
is the elephant in the room.

CHRIS AUJARD: It's useful to have those -- as you know,
useful to have those discussions now rather than
actually get halfway through the process and have
them. So, you know, I think what you have flagged
up to me, which again I -- I take it this is your --
as external consultants, you are looking at this,
you're saying, "Chris, just be aware of the
expectation gap and be aware that, you know, you get
into those mediation sessions, when you're sitting
around having the mediation, that there is
a bigger -- a wider implication beyond each
individual mediation", and that's, you know, that's
actually -- you know, that's those thoughts.

I wouldn't have said -- and from where I sit
there's absolutely every single reason, now, to go
on and continue full steam ahead with the mediation.
And, you know, one of the ways I think of dealing
with some of the issues you have identified is -- is
to make sure (a) we do our investigative report
properly and thoroughly, and (b) we sort focus in on
the facts.

Because my concern is around each individual
case and to make sure -- I will consider the job
well done if I can say in each individual case we
gave it our best shot, you know? We did what we
could, we reviewed it the best we could, we weren't
agreed in all cases but that -- so we know that to
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be the case, but -- and -- and as -- Second Sight
can facilitate that process by making sure that, you
know, when it gets in front of the mediation at
least we can say -- give the facts -- you know,
"Here are the facts, here are the (unclear), here is
what the views of the various parties are"; at least
that gets people into a room and gives the
possibility of closure.

RON WARMINGTON: Yeah, I mean, Chris --

CHRIS AUJARD: You (unclear) points are really well
taken --

RON WARMINGTON: Chris, what -- you know, at the risk of
upsetting people of a certain origin, I used to use
the expression, I'm not allowed to anymore but I'll
use it now, you know, I used to say to my
investigators, and there were 110 of them round the
world, you say, you know, "I want this to be
understandable in ten years' time by an Australian
truck driver."

You know?

CHRIS AUJARD: Pretty much, I'm

RON WARMINGTON: And preferably after he's had ten pints
of Fosters. In other words, a sort of judge or
mediator that is going to be an audience for this
stuff is really not going to be very generous,

I think, to documentation which has them -- his or
her dancing all over the shop saying, "Well, what
the bloody hell is the relevance of that? I mean,
I've just read through 100 pages and it's completely
bloody irrelevant."

So our reports will be designed that way, as our
interim report was. You know, we've had a lot of
people say, "Gosh, this is the first investigation
report we've ever seen coming out of Government that
we can understand on one reading without going back
over it again."
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That's how the stuff has got to be, and some of
the quality of the reports coming in from the
external advisers, the professional advisers, are up
to that standard, sadly not all of them, and if
POL's stuff isn't, it's going to not be very helpful
to POL's position.

CHRIS AUJARD: And we'll make sure that the, you know --

RON WARMINGTON: By the way, lest you consider that this
is in any way undermining Angela, Angela is the best
person that we've had to deal with at POL, bar none.
She is truly knowledgeable about the process. She
has a sense of what -- right and wrong, she deals
with people very well, she's a good manager. I
mean, she's a very class act. But, you know, she's
POL through and through and has been brought up in
the defence of the mothership and is bound to be --
particularly if she is being charged with being one
of the principal defenders of the faith, she is
going to be rather hampered in what she writes by
her sense of loyalty to the corporation and her
sense of trying to, kind of, fend off everything.

CHRIS AUJARD: My standing orders to her and the standing
orders to the whole team are, you know, this has got
to be independent and thorough. You know, you've
got to get to the facts.

RON WARMINGTON: Good.

CHRIS AUJARD: There's no point in doing the exercise if
you don't get to the facts and, you know, it's --
just put them out as you -- don't spin anything in
one way, the other way, just put the facts down --

RON WARMINGTON: You see, when we get to -- I'll tell you
a good case to look out for. When you Alison Hall
case, which has got the indomitable, powerful
Mike Wood MP behind it, firi ll lind
sharp as a tack that guy, [

when that case comes in, ey

question is going to be: why did the investigation
team proceed to a prosecution for false accounting

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when the underlying cause for that, without much
doubt, was that she got in a complete mess over
scratchcards, when POL knew that there was a huge
problem with reconciliation of scratchcards, and yet
it doesn't seem that either the investigation team
and the prosecution team knew that, or if they knew
about it they didn't cut her any slack because of
it. That's what my report's going to have to
address. And it's really serious because it's
potentially an unsafe conviction.

IAN HENDERSON: Just building on that, Chris, the other
feature that is going to be in a number of our
reports, I expect, is the failure to identify the
root cause of the various sort of deficiencies. We
are consistently seeing prosecutions that are
focused on the false accounting sort of issue with
no regard for actually identifying what has caused
the deficiency in the first place --

RON WARMINGTON: And often backed, Ian --

IAN HENDERSON: Just one further point -- and what we are
seeing is the information that would enable an
investigator to do that lies exclusively in many
cases with POL, and the failure to do that at the
appropriate time has actually, you know, made
matters far worse than it should have been.

RON WARMINGTON: And Chris, just to pile on the agony,
and this is unproven, but some of the stories that
are coming in are unbelievable. I mean, hopefully
they are unbelievable.

CHRIS AUJARD: No, no, it's undoubtedly the case that
there is a lot of individual distress associated
with --

RON WARMINGTON: Yes, in many --

CHRIS AUJARD: (unclear) because I don't know --

RON WARMINGTON: Well, in many cases there was the threat
of a theft charge which was lifted as part of
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a deal -- a sort of courtroom steps deal, where the
condition was: we won't proceed with the theft
charge (by the way, we wouldn't have had the
information, the evidence to win anyway) as long as
you plead guilty to the false accounting and as long
as you refrain from saying anything in your defence,
particularly anything to do with a criticism of

Horizon.

Now, that -- and in one case a Legal Aid
barrister that was -- completely fabricated a story
and trotted it out in court that wasn't true, as to
the woman stealing -- which she hadn't -- in order
to support her cancer-stricken mother. So, you
know, there are some -- potentially horrible stuff
that will be coming out here. And, you know, our
role in that -- don't for a moment think, Chris, we
haven't -- you know, we're immersed in this, totally

immersed in this. And, you know, the good news is
that we have, now, encyclopaedic knowledge of all --
not only each of these cases but -- but all of the
cases collectively, because each builds on -- many
build on and some undermine the case of another, but
it's a tough situation for crying out loud.

CHRIS AUJARD: Which brings me back, I think, to --

RON WARMINGTON: The main topic. Yes, I understand.
Sorry.

CHRIS AUJARD: The focus has got to be on the facts of
each case and --

RON WARMINGTON: Yeah.

CHRIS AUJARD: -- there will be hard cases, there's no
doubt that, but there are also -- you know, there
will also be cases where actually they should be
relatively quick and uncomplicated.

RON WARMINGTON: Yeah, we actually want --

CHRIS AUJARD: I sincerely hope that to be the case.
I know you are painting a very black picture --
RON WARMINGTON: No, no, but there are some chancers. We
recognise some of those.

CHRIS AUJARD: You know, the key -- the key is that, you
know, all you can do and all we can do is do our job
professionally and make sure that we look at the
facts as they are presented and then report on them
and go into the mediation process with an open --
all sides -- mind --

RON WARMINGTON: But at the risk of you being really
irritated with me, and I appreciate you would be,
some of the facts are not going to be ascertainable.
You know, if somebody has had a £30,000 shortfall
that's built up over the case of a year and a half
and they have no idea how it came about but they
have, on reflection, sort of realised that they were
having problems with some of the areas where others
have had problems, you're not really dealing with
facts now, you're dealing with an impossibility to
distinguish between what might have been a theft by
a member of staff, or even by the person that's
pretending they didn't steal -- it's going to be
very difficult to get to the underlying facts.

If somebody's wife dipped her hand into the till
while he was having his sandwiches and took 30 grand
out of it, that would be a mysterious difference
that would look exactly the same as somebody having
come in to draw money out on their debit card and it
was processed as a credit instead of a debit.

CHRIS AUJARD: No, I agree, your point is --

RON WARMINGTON: So, you know, let's not kid ourselves
that we're all --

CHRIS AUJARD: There will be -- in circumstances in which
we -- on the known facts we can only say so much.

RON WARMINGTON: Exactly, exactly.

CHRIS AUJARD: I think that is right though, I think that

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is the spirit of mediation, if I haven't
misunderstood what's been explained to me
painstakingly to me as if I was a 5-year old child,
because I've had no experience of mediation in prior
lives, that this is the point of mediation. The
point of mediation that has been rammed into me, if
you like, almost, is -- is you get kind of
intimate(?) with the ascertainable facts.

RON WARMINGTON: Yes.

CHRIS AUJARD: There might be pressure on both sides -- on
both sides -- in opposite directions, but the
mediator's job is to keep on bringing them back down to
the factual base, which -- I think it's more important
for your work to keep that focus on the facts, though I
do hear -- and it's been a very useful conversation to
hear, you know, first-hand, if you like, the other
issues that you think are swilling around out there,
that somehow, you know, Post Office needs to
accommodate and to address. I don't have -- I'm afraid
I don't have an answer for you on any of those at the
moment because my focus is very much just on this
mediation and getting us through from where we are
today to where we are at the end of it.

RON WARMINGTON: Well, we -- you raised resources --

CHRIS AUJARD: We agree -- don't get it the wrong way
round, actually, even though you -- you've raised
some -- I think more to the point you've alerted me

to one or two potential bear traps, which is always
much appreciated.

RON WARMINGTON: Yeah, well, you know, on --

IAN HENDERSON: At the beginning, Chris, you said that
you wanted to discuss some other matters with us.
You know, data protection, confidentiality --

CHRIS AUJARD: I think, Ian, you know, it's just the
standard data protection wording which I've whipped
from a document that's been sent to me by my good
friend at Bond Dickinson, and also some -- which is
just standard wording. The only other thing that is
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of -- I think it's relatively straightforward --
I'll tart it up and send it over to you or get it
tarted up and send it over to you. The only thing
that I think is sort of material is your workload.
So my challenge to you is, you know, we are relying
on you -- everybody is relying on you to process
cases as expeditiously as possible, and -- that's
the first point.

The second point is actually the charging
structure. And I've got to say, I wasn't a party to
any discussions you had, obviously, with Susan
Crichton, but I believe that you put an hourly rate
to her. My challenge, certainly at this stage, is
for you to think about how you can best start this
up internally and best come up with a fee structure
that's going to mean that we don't spend, you know,
£400,000 on getting reports prepared, which frankly
would be, you know, I think, just a waste of time,
actually. It -- I would rather, as I said -- so --
so my challenge to you currently is I haven't myself
come to a landing on -- on what the best way to do
it is, because I'm not close to it. You will have
done that. I think -- you know, I did hear
a suggestion that you are thinking of putting in
someone who is more junior that could be charged

out -- charged at a lower rate. Can I leave that
with you and I will therefore leave that schedule of
the --

RON WARMINGTON: Sure. I mean, as it happens --

CHRIS AUJARD: I do want it done properly but I do want
it done as cost effectively as we possibly can in
all the circumstances.

RON WARMINGTON: Well, just a quick coverage of a couple
of those points, we'll deal with them in more
detail.

Ian and I., our normal charge-out rate is much
higher than we've charged POL, because we recognise
that this is a big slug of work. So we actually
reduced our fee rate in order to kind of share the
pain, but we are charging £150 an hour. Now that's
the same -- that's the rate of a junior lawyer and
it's the rate that we're paying the -- pretty well
the rate that we're paying these professional
advisers. I have been turning down not only

a full-time senior assignment but much higher paid
fee rates. I'm an ex-trader, ex-investigator
accountant who is an ex-derivatives trader, so you
won't be surprised that I was approached to do one
or two of the big current trading-related
investigations at very fat fee rates. Obviously
we're turning down everything in order to stick to
this case. So I'm not going to be reducing my fee
rate any more on an hourly basis. As it happens,
both Ian and I cap the amount that we charge in

a day, even though on this, covering admin of the
scheme, several days we were working, like, 12-hour

days. I've never, ever charged that much. We don't

charge for travel time or charge half rate if we're

working on travel. I've got this guy called Pandit,

who's will cost me all of £25 an hour and to whom
I'm going to delegate some of the work. He came

recommended by Alan, he's a competent guy. Angela
thought it wasn't necessary because she's got her

own people, but I do need somebody independent and I

think it's wise to get him involved and take work
load off Ian and I at, you know, a much lower fee
rate.

We've also got another investigator, another
top, top guy, available in our company, but -- and
we're prepared to have him read in to the file, but

more in the nature of backup to us. It literally is

going to take too long to get anybody else up the
curve to help on this exercise but he could help us
with the report writing and so on. It's a guy
called Chris Holyoak, he's on our website, he's an
ex main board director of European Bank, qualified
accountant, absolutely top notch guy. But I would
be -- I mean, he'd be charged out at the same rate
as Ian and myself, so it would only displace time.

But I would be prepared to get him to read in to the

files, if you give permission for us to allow him
access, free. I wouldn't charge for any of that

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time.

CHRIS AUJARD: Why don't you ping me over your thoughts
on how you can most effectively do that, so rather
than do it over the phone. That's probably the way
to go, I think.

RON WARMINGTON: Yeah.

CHRIS AUJARD: I appreciate this will take time. I also
know I am - as you'd expect from every organisation,
every big organisation, I'm constantly pressed on
time, when am I going to deliver, and I'm constantly
pressed on budget. That's just the way it goes.

You know, I've got no -- you know -- but that said,
I know how much work this takes, so -- I don't want
rush you, I'd rather you thought about things
sensibly and you came up with a structure

(unclear) --

RON WARMINGTON: Yeah.

CHRIS AUJARD: -- and that work is split out sensibly to
the, you know, cheapest person and what have you,
rather than rushing into it. So perhaps I shall
just leave that with you for the moment and, you
know, then either pick up the phone or ping me an
email --

RON WARMINGTON: Yeah, the sad news is that we've been
through that big admin bubble where Ian and I have
not really been doing work as investigators, but --

CHRIS AUJARD: I'm very keen that your time is not
distracted, you're not distracted.

RON WARMINGTON: Well, it has been, but on the other hand
it's hard to see how that would be done very much
differently, but it could have been done more
cheaply.

CHRIS AUJARD: There we are, you know, I can't --

RON WARMINGTON: Okay.
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CHRIS AUJARD: Thank you very much. I'm, as you might

RON

expect, rather overdue for a --

WARMINGTON: Yes, I got that.

CHRIS AUJARD: But that -- I think that was a useful

RON

discussion. For my part, as I say, you know, I'm
keen on getting this process through to the end.

I will take an action at some point, certainly pick
up the phone to Tony to -- just to clarify that,
because, you know, people soon start to matter quite
a lot, what his expectations are as regards the
report, and it's good I think we ought to be aligned
sooner rather than later as to what that is.

My -- and I think I made a note of all the other
things you said as well. So that's a very fulsome
discussion.

WARMINGTON: Well done, Chris, thank you very much,
sir.

CHRIS AUJARD: Okay, thank you. I'll catch up in due

RON

course, no doubt.

WARMINGTON: Very good.

IAN HENDERSON: Thanks, Chris.

CHRIS AUJARD: Okay, bye.

(Recording ends)