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From: Rodric Williams +
To:
Ce:
Subject: RE: Private & Confidential re: Post Office Group Litigation - Request for Documents -
SUBJECT TO LEGAL PRIVILEGE [WBDUK-AC.FID27032497]
Date: Mon, 12 Nov 2018 23:31:18 +0000
Importance: Normal
Inline-Images: image001.png; image003.png; image004.png; image005.png
Thanks Lucy — I'll send to RM, cc’ing Johan Appel, and fwd you a copy once sent. Please liaise with Johan
(who may want to update our CoSec) tomorrow to keep this moving.
Thanks again, Rod
To: Rodric Williams
Ce: Jonathan Gribben <j,
Subject: RE: Private & Confidential re: roup Litigation - Request for
TO LEGAL PRIVILEGE [WBDUK-AC.FID27032497]
Rod,
Thanks for this. I have made some minor amends, as follows:
I have amended the words "2011 audit report" to read "2011 management letter" in line with the description on the
front of the 2011 E&Y document; and
I have added "and that further work would be carried out on this" at bullet point four, in line with what it says in the
management comments in the 2011 E&Y document.
Kind regards,
Lucy
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Lucy Bremner
Associate
Womble Bond Dickinson (UK) LLP
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From: Rodric Williams [_
Sent: 12 November 2018 23:03
To: Lucy Bremner
Cc: Jonathan Gribben; Andrew Parsons
Subject: Private & Confidential re: Post Office Group Litigation - Request for Documents - SUBJECT TO LEGAL
PRIVILEGE
Lucy — please see my proposed email to Royal Mail below and let me know if any changes need to be made
to reflect properly the requests for documents.
Thanks, Rod
Privat nfidential - JECT TO LEGAL PRIVILEGE - Sent in Connection with the Post
Office Group Litigation
Luke,
Following our telephone call on Friday, Post Office Ltd is trying to locate:
a 2010 Ernst & Young management letter; and/or
Royal Mail Group Audit Committee or Audit, Risk & Compliance Committee (ARC) minutes for
2010/2011.
These audit-related documents are sought to assist our preparations for the Post Office Group Litigation
“Horizon Issues” trial. That trial will take place in March 2019 to determine (primarily on expert evidence)
technical issues concerning the Horizon IT system used to record transactions in Post Office branches.
By way of context:
¢ In his report filed on 16 October 2018, the Claimants' expert Jason Coyne refers to issues with
Credence (a back office accounting system which uses Horizon data) to support his conclusion that
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Horizon may not be reliable.
¢ The Credence issues are mentioned in EY’s 2011 management letter (disclosed in the Group
Litigation) and concern weak change controls and a lack of documentation to approve fixes and
patches.
* To address the Credence issues, EY recommended that Post Office require its IT provider Logica to
segregate the roles of developer and implementer, maintain complete and accurate records of any
changes, and periodically audit the achievement of service level agreements.
¢ EY’s 2011 management letter notes that in 2010 Post Office management stated that Logica had been
asked to comply with EY’s recommendations and ensure appropriate role separation and that further
work would be carried out on this, hence our request for the 2010 Ernst & Young management letter.
¢ The 2011 audit report did not however comment on whether the issues had been fully addressed as this
particular issue was not within scope.
¢ Weare therefore trying to determine whether any other audit-related documents disclose whether these
issues were addressed and if so how, hence our request for Royal Mail Group Audit Committee or
Audit, Risk & Compliance Committee (ARC) minutes for 2010/2011 which may address this issue.
I hope that clarifies our request. Please let me know if not.
We are unfortunately running on a very tight timetable, so any prompt attention you could provide to this
would be very much appreciated so that if appropriate, disclosure can be made as soon as possible this.
week. I do of course apologise for the short notice.
With thanks and kind regards,
° Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
2017 Winner of the Global
Postal Award for Customer
Experience
JSS ISIS ICIS ICI CIOS I SSI CIOS CIOS ICI CIO SIC AISI OSIRIA III IIA
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