WITN00370100 Calum Greenhow - Witness Statement

Evidence on official site

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Witness Name: Calum Brian
Greenhow

Statement No.: WITN00370100
Dated: 4" September 2024

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF Calum Brian Greenhow

I, Calum Brian Greenhow, will say as follows...

INTRODUCTION

1.

I am a former Postmaster at West Linton Post Office, which I still own with
my wife. I am currently the Chief Executive Officer of the National Federation

of Subpostmasters (NFSP). I have been in this role since June 2018.

This witness statement is made to assist the Post Office Horizon IT Inquiry
(the Inquiry) with the matters set out in the Rule 9 Request dated 23 July
2024 (the Request). I have had the advice of the NFSP’s solicitors in

preparing this witness statement.

I wish to thank the Chair, the Inquiry and the Inquiry team for all the work it
has done and is continuing to do. The NFSP came into this Inquiry to engage
with it as fully as possible and to assist the Inquiry in any way we could. I
also wanted to find out more about what had taken place over the years,
when and why, including about the NFSP’s own role in it all. There is much
that I have seen and heard at the Inquiry over the last two years that I did not

know, including about the NFSP.

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4. The Inquiry, its work and the recent push for full and proper financial redress
is a testament to the tenacity, dignity, courage and determination of the
victims of the Horizon scandal. I want to say at the outset that the NFSP.
acknowledges publicly that more could and should have been done by it to
recognise that the issues being raised by Sir Alan Bates, in the media such
as Computer Weekly, in documentaries such as Panorama needed to be
taken seriously, and the Post Office line that Horizon was ‘robust’ should not
have been accepted as often as it was or repeated as regularly as it was. I
understand why former members of the NFSP felt let down by the responses
they received at the time when seeking help from us or to raise questions
about Horizon. On behalf of the NFSP and as the current Chief Executive
Officer, I want to say that we are truly sorry for these failures of the past. I
hope that in providing this witness statement, the information given will assist
the Inquiry as to the work of the NFSP and its role. I also provide information
in this witness statement on the NFSP’s proposals for the future of the
network, the Post Office and the bodies and organisations who represent the

various employees and members.

5. By way of background to my own involvement in the Post Office network, my
wife and I purchased our Post Office in West Linton in 1995 prior to our
wedding the following year. As such, we have worked together our whole
married life. With financial help from my parents, we were able to buy our
business which hosts the local Post Office. This is not a decision I regret for
a moment as the Post Office has enabled my wife and I to live in a wonderful
community, in which we have brought up our two daughters. Having a

contract with the Post Office has provided us with a home, as we live above

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the Post Office, clothes on our backs and food on our kitchen table. As such,

I have a lot to be thankful and grateful for.

6. I remember our Post Office being broken into overnight in August 2008. The
break-in was not a pleasant experience. We turned to the NFSP for help, and
I am grateful to those who supported us at that time. I recognise, however,
that while this may be my experience, sadly the experience of members who
were Horizon victims was very different. My hope is that the members and
former members of the NFSP who became Horizon victims will be willing to

accept my apologies.

7. In terms of the part postmasters play in their local community, we are no
different from many others in their communities across the UK and those the
Inquiry has heard about. My wife and I have spent the years since taking
over the position of Postmaster and moving to the village of West Linton in
various roles within the community. I've been treasurer of the local tourist
group, a school governor at the local primary school, a Community
Councillor, the Returning Officer for the Community Council, a Church Elder,
a Retained Crew Manager at the local Fire Station. We've also helped
organise the local fireworks display for the last 29 years and the village
Christmas Lights. My wife was a leader in the Girl Guides at local, regional
and national levels, receiving the Chief Guide medal in 2021. She is the
current West Linton Citizen of the Year. Over the years we have supported
micro businesses in the community by providing space within our shop and

have been the drop-off point for local charities.
8. When my wife and I took over our Post Office in 1995, the Post Office
operated what was known as the Appointment Abatement Scheme. This was

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where they reclaimed 25% of the Postmaster’s income within the first year.
Post Office claimed it was to “reflect uncertainty and risk”. To us it seemed
arbitrary and unjustified. Fraser LJ mentioned this in his Common Issues

judgement (POL00113269) at paragraph 78 where he stated: “the rationale

or economic justification for this is not entirely clear...”

9. Sadly, due to the Network Transformation programme, which was
established in 2012, we had to make the difficult decision in 2015 that we
would not convert to the proposed Local model as it would not make financial
sense. We have been part of what is known as the Hard to Place (HtP) since
April 2018 as no Potential New Postmaster (PNP) has come forward to take
on the post office. In February 2023, Post Office unilaterally changed the
terms of the agreement in place since 2015 for 130 Postmasters and unless
a PNP was in place by March 2025, these offices would be closed. The
reason being is Post Office did not wish to go through the cost of installing
the proposed Horizon replacement, known as NBit, and then to also take the
HtP colleagues through the training process for it. Whilst initially a PNP came
forward for our Post Office before the March 2024 cut-off, they pulled out in
April this year. As such our Post Office is due to close on the 11" of October
this year without any provision, at the time of writing this witness statement,
being in place for the local community. There are around 30 other
Postmasters who are in the same situation. This decision of the Post Office
Board will result in an average loss to each of these 30 Postmasters of

around £43,000.
BACKGROUND

10.1 am asked to provide a summary of my career and qualifications prior

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to joining the NFSP.

1

.I left college with an National Certificate in Accounts and Information Studies.
I had several roles prior to taking over our Post Office in August 1995. These
include working as a trainee assistant manager for H Samuel Jewellers, a
fresh produce salesman for Caledonian Produce and as Sales Manager for
Scotland for Gordon Fraser Cards, which was a division of Hallmark Cards. It
was while I was working for Gordon Fraser that I met my wife. The Post
Office in West Linton was one of my Gordon Fraser customers and as we

had decided to run our own business, this fitted our needs.

12.1 was also a Retained Fire Fighter for the Scottish Fire and Rescue Service
(SFRS) from 2000 - 2017, retiring on the 31st of December 2017 as a Crew
Manager. During my service for SFRS, I was an Emergency Fire Appliance
Driver, a qualified Incident Commander and gained qualifications from the

Institution of Occupational Safety and Health (IOSH).

13.In 2003 I began working part-time for a Solicitor & Estate Agent covering the
Scottish Borders and Lothians. In order to add to my understanding of the
industry, in 2004 I gained the Certificate in Mortgage Advice and Practice

through the Chartered Institute of Insurers of Scotland.

14.1 have always had a keen interest in the earth sciences and so in 2015 I
began studying through the Open University for a degree in Earth Science.
Given the time I had available, I studied one module per academic year,
although becoming Chief Executive of the NFSP in 2018 meant that I had to
abandon those studies. However, I was able to complete modules in
Exploring Science (S104), Maths for Science (S151) and Communication

Skills for Business and Management (LB170).

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15.1 am asked to describe the roles I held at the NFSP prior to my appointment
as Chief Executive. Although I became a Postmaster in 1995, I did not
become a member of the NFSP, which was a trade union at the time, until
2001. I am not a traditional trade unionist. However, there was continuous
change going on in the network and I decided to join the NFSP. After two
network reorganisations through Network Urban Reinvention in 2003 and
Network Change in 2007, my wife and I believed that a third network
reorganisation was most likely on its way. To protect our investment, we
purchased our second Post Office in nearby Biggar in 2008. It was not until
2008 that I started attending meetings of what was the South of Scotland
Branch of the NFSP and became more involved in the local branch. As part
of the Network Transformation Programme we left the Biggar Post Office in

2013 when someone else took on that business.

16.Having become more involved in the local NFSP branch, in 2010 I was asked
to stand for the role of President of the South of Scotland Branch of the
NFSP. I was elected in 2010 and attended my first National Conference that
year. In 2012 it was proposed that I stand for the position of Branch
Secretary for the South of Scotland. After being elected for that, in 2013, I
was elected by the Scotland Region to become the Scotland representative
on the NFSP’s Standing Orders Committee. This was the committee which,
in traditional trade union terms, dealt with the motions from the branches
which would go to the annual conference. In 2016 as the Regional Non-
Executive Director was retiring, the Scotland Region asked me to stand for
election to the Board of the NFSP as the Scotland Regional Non-Executive

Director. After being elected, I attended my first Board meeting in June 2016.

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Later, following the retirement of George Thomson, I was appointed as the

CEO in June 2018. This is an employed position and not an elected position.

17.1 am asked about the background to my appointment as Chief Executive and
the responsibilities of that role. In early 2017 George Thomson approached
me to say he would be stepping down as Chief Executive. At that time, he
said he thought I had had shown an aptitude to take on the role. It was no
secret in the Scottish Region that George and I had had public
disagreements. In 2013 I had produced a paper that said Network
Transformation was potentially not what it was being sold as and rather than
sailing to a promised land it was a sea of icebergs. I was strongly criticised
for taking that view. I previously had challenged him on the Articles of
Association and Memorandum of Understanding as I felt these were a result
of Network Transformation turning out not to be what it was said to be. I was
surprised when he said he was going to stand down and hadn't even thought
I would be someone he would consider. Others said to me it would be an
opportunity to bring the NFSP back to the organisation it should be, bring it
back together and be more inclusive, more representative of the members
rather than what had become more of a toxic environment under George. It
has been interesting to read the Post Office Group Executive Agenda and
Associated Documents dated 14 September 2017 (POL00027276) and what
is said by Post Office about my appointment. I note that Nick Beale said that
Post Office had wanted someone from outside the postmaster community
and not only had this view been shared with George Thomson, but it had
been advocated by him. Also, that the decision of the NFSP to appoint me

as the Chief Executive was “somewhat disappointing” and I came with

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“unknowns”. None of which I knew, but it is of no surprise to me given my
experience of how Post Office work as an organisation and their internal
culture, and also shows George was saying one thing to me and something

else to the Post Office.

18.From that initial mention by George, the possibility of the role was discussed
with the then Chair of the NFSP, Jim Nott and the Negotiating Committee
Facilitator, lan Park who were supportive of me taking on the role before it

was put to the full Board, who agreed.

19.1 should say that I would not have taken the role without the full support of my
wife and family. I therefore began the role in June 2018. As a result, this
meant I stepped down as the Postmaster for West Linton on the 31st of May
2018 after 23 years of service to my community. My wife then became the

Postmaster and still is today.

20. The role of Chief Executive of the NFSP is a dual role. There is the day-to-
day management of a business with employees and there is the
representative role. The NFSP is the representative body for self-employed
Postmasters and to quote one of our founding fathers back in 1897, the
NFSP seeks to work collaboratively and constructively with Post Office Ltd
“to improve the conditions under which Subpostmasters labour, and to
undertake the advancement of our cause by all legitimate and honourable

means” (see NFSP Centenary book page 17, WITN00370130).

2

. The role requires me to be the voice of Postmasters and those who operate
their post offices. As such I regularly meet with politicians, Government

officials, other external stakeholders and also those within Post Office.

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22. Being involved in a network of over 11,500 Post Office outlets, brings its
challenges and understandably, Postmasters look to me in relation to issues
they have. I manage a small team who deal with such situations on behalf of
Postmasters. Later in this witness statement I go into more detail as to how

those issues present themselves.
THE NFSP’S ACTIVITIES

23.1.am asked to provide a brief summary of the purpose(s) and activities

of the NFSP.

24.The NFSP is the representative body of self-employed businesspeople who,
as Postmasters, hold a contract for services to and on behalf of Post Office
Ltd as their agents. As agents, these self-employed business people invest
financially into the Post Office network by providing premises and staff etc to
enable services of general public interest to be provided in their community.
We negotiate rates of pay and conditions of service, we consult on conditions
of service, opening hours, assist members with matters such as contractual
disputes. We assist members who need help when shortfalls arise, although
prosecutions are not what usually happens these days the Post Office may
still seek recovery under the contract. When asked by our members to
assist, we ask the Post Office to prove that it was not negligence,
carelessness or error as those are the only ways in which a Postmaster is

liable under the contract.

25.The aim of the NFSP is to ensure that the relationship that exists between
Postmasters and Post Office is as collaborative and constructive as possible.
As seen in the following documents, (the Subpostmaster Handbook 1995 at

page 6 NFSP00000899; the Memorandum and Articles of Association of the

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NFSP as revised 9 May 2021 at page 6 NFSP00001051; the NFSP Rules
dated 2009 at page 1 NFSP00001067; and the NFSP Rules dated 2014 at
page 1 NFSP00001072), throughout the years the objects of the NFSP has
included regulating relations between Postmasters and Post Office, including
by negotiating rates of pay and conditions, of service and variations of
postmaster contracts on behalf of postmasters. Also participating in any form
of consultation or negotiation relating to conditions of service for
postmasters. Endeavouring to settle collective or individual disputes between
members and Post Office and promoting such settlement through joint
participation, conciliation or arbitration. This is not an easy goal to achieve as
the relationship is seen by Government and Post Office Ltd as one of “parent
to child”, with Post Office Ltd being dominant and Postmasters being

subservient.

26. Over the last 25 years successive Government decisions have ultimately
been detrimental to the viability of the network via Network Urban
Reinvention (2003), Network Change (2007) and Network Transformation
(2012). Each of those restructures reduced the viability of the network and
Postmasters and therefore the security of the Postmasters investment as
well as their ability to generate a return on their investment. The role of the
NFSP during these times was to ensure the impact on the Postmaster was
fully known by Government and Post Office and keep Postmasters as
informed as possible and bringing their voice into any discussions with

Government and Post Office.

27.The NFSP provides support to members in terms of on/off boarding i.e.

leaving or joining the network, support with mail products, retail support, free

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access to human resources services and holiday cover via HR4UK,
insurance cover such as tax and VAT investigation insurance, personal ID
theft cover, access to business legal advice (first 30mins free) and a

Benevolent Fund.

28.The NFSP also supports its members via campaigns and awareness in
matters relating to the network such as the recent DVLA campaign to prevent
Government from removing the ability for DVLA services to be accessed over
a Post Office counter (as discussed further later in this witness statement).
We meet monthly with the Department of Business and Trade and also UKGI
to discuss matters relating to the network. There are also three meetings per
year with the Postal Affairs Minister of the day, again to discuss high level

aspects of matters relating to Post Office and its network.

29.On a monthly basis, our Negotiating and Engagement Team meet with
various departments and individuals within Post Office to discuss
remuneration, performance and any other aspect that may affect the

network.

30.We have and continue to develop our Advocacy Representative role. I
recognised when I came into post that there wasn’t a central register of
issues or overall knowledge of what was going on, no training for anyone
dealing with a postmaster where a discrepancy arose and felt that was
wrong. I later heard that in the early part of the 2000s that was there, but not
subsequently. I wanted to make this more professional and ensure that
across branch secretaries there was a knowledge of issues that were going
on. An Advocacy Representative is someone trained in Post Office

contracts, such as the Mains Contract, the Local Contract etc. If a postmaster

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32.

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has a suspension or potential termination then it is an Advocacy
Representative who will represent them and they have been specifically
trained to do that. Two of the Advocacy Representatives are NFSP
employees and four are Postmasters from different regions. We advertised
the role and said we were looking for people in these geographical areas. We
therefore now have six trained representatives who have a knowledge pf the
different kinds of Postmaster contracts and also Post Office policies that
impact Postmasters. The aim of this work is to ensure that there is
consistency across Post Office Ltd when it comes to how Postmasters are
treated in relation to any kind of contractual dispute. This has been one of a
number of key changes in the representation of postmasters which has
changed and developed from the Horizon Scandal time. The roles are
evolving and developing on an ongoing basis. We are working with ACAS to
find out if mediation training which they offer can also assist in the Advocacy
Representative role. We are committed to making sure the Post Office is not
the judge, jury and executioner in cases against Postmasters and that the
right questions, the right evidence and the right steps are taken in the

present.

.I am asked to provide an overview of the organisational structure and

funding structure of the NFSP. Where this changed over time, I am

asked to provide details.

The National Federation of Subpostmasters was formed on Easter Monday
1897, where 90 Postmasters met in the Music Saloon, Wood Street,
Wakefield. I have the NFSP Centenary book (WITN00370130) and I can see

from page 17 that the reasons for the formation of the NFSP bear similar

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hallmarks to the cultural attitudes the Inquiry is considering today. It reports
that The Wakefield Express said on the 24" of April 1897 “The reason for the
general movement is the dissatisfaction felt as to the result of Lord
Tweedmouth’s Committee on the Post Office Establishment, whereby the
grievances of Subpostmasters were referred to the Postal Department,
although, it is alleged, that Department has long known of their just claims,

and has hitherto totally disregarded them.”

33. The NFSP was a Trade Union until January 2014, when the Certification
Officer made the ruling that the organisation as a representative body of self-
employed individuals did not meet Section 1 of the Trade Union Act 1992.
This is seen in the Letter (with enclosure) from David Taylor to G Thomson
re: Trade Union and Labour Relations (Consolidation) Act 1992, Removal of
Nation Federation of Sub-Postmasters from the list of trade unions
(NFSP00001464). At the special conference in June 2015 (see Transcript of
the NFSP Special Conference dated 18 - 19 June 2015, NFSP00000957)
members at Branch, Regional and National level had mandated their
representatives to vote on the proposals, which were a merger with either the
CWU or the National Federation of Retail Newsagents (NFRN) or the
Memorandum of Understanding/Grant Funding Agreement. I was there as a
branch secretary for the South of Scotland branch and had been mandated
by the branch members to vote for the Memorandum of Understanding. I
personally did have questions about the MoU. That said, I was also not
wanting to be part of a large trade union such as the CWU as I saw
Postmasters such as myself as small businesses rather than being

employees, and the MoU allowed the NFSP to remain as a stand-alone

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34.

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organisation to represent its members, funded by Post Office Ltd under the
Grant Framework Agreement (NFSP00001075) instead of by union
subscriptions. Since September 2015, the NFSP has been a company limited
by guarantee with no share capital (see Memorandum and Articles of

Association of the NFSP, NFSP00001051).

Its structure today is that each member is associated to a Branch, with each
Branch associated with a Region and with each Region having a Non-
Executive Director to the Board. The Board members are therefore those
who own and operate Post Offices. There are others who attend the Board
but are not Board members. These include Operations Director, the
Commercial Director, Public Affairs Manager, Communications Manager,
Network Operations Officer/Negotiating & Engagement Facilitator and
Compliance & Network Support Adviser. The non-Board members will
provide updates on the network and other issues they are working on within
their roles. I encourage the non-Board members to contribute to the meeting
and for the meeting to have a more collaborative approach. I have sought to
encourage team working in the organisation rather than the autocratic
approach taken by the previous General Secretary/Chief Executive, George
Thomson. The Chief Executive is delegated to manage the day-to-day
running of the business and report to the Board of Directors. Earlier
documents such as (the NFSP Rules 2009, NFSP00001067; the NFSP
Rules 2014 NFSP00001072; the NFSP Organigram dated 2015,
NFSP00001086; and the NFSP Organigram dated 2019 NFSP00001094)
outline the previous structures prior to my time on the Board and later as

Chief Executive. These show there were differences in names of roles, but

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largely the language and structure is similar as the organisation changed
over from a trade union to a trade association. For example, we don’t talk

about motions at conference but do have debates on key topics.

35. Until 2015/2016, the NFSP as a trade union was funded predominately by its

members. That funding structure was before my time on the Board, therefore

I cannot comment from a position of knowledge.

36. Today, most of the funds available come from the Post Office under the GFA

with a small amount generated by some commercial activity. When we
changed from a trade union to a trade association the members were
automatically transferred over. Any new Postmasters coming into the
network were written to, I think by the NFSP, to ask if they did not want to

join the organisation. If nothing further was heard from them, then they

would become members but under the GFA they did not pay subscriptions to

the NFSP and the NFSP did not get any more money via the GFA as a
result. Nowadays, the NFSP writes to new Postmasters asking if they want
to join rather than if they don’t want to join. I am not certain when this came

in but it was before my time as Chief Executive.

37.The NFSP is made up of mostly volunteers from within the Postmaster
community. The NFSP is divided into 53 Branches and 10 Regions. Each
Branch has a Branch Secretary and Chair, who have a duty to engage and
support members in that locality. Each Branch is connected to one of the 10
Regions, who have a Regional Chair, Secretary and Treasurer with the
Branch Secretaries forming the remainder of the Regional Council. Each
Region has a Non-Executive Director to represent the interests of all the

members within that Region on the Board of Directors of the NFSP. All of

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these positions are elected by the members.

38.1 am asked to provide an overview of the methods the NFSP adopted to

represent its members’ interests between 2000 and 2019 (inclusive).

39. Issues in relation to which the NFSP represented its members’ interests

during this period include:
a) Horizon introduction/roll-out back in 1999;

b) Automated Credit Transfer which was the removal of the benefits

books going electronic,
c) the Post Office card account in 2003;

d) Network Urban Reinvention in 2003 (this was an early closure
programme which resulted in 3000 post offices closing);

e) The Green Girocheques issue in 2005/2006 (further explained later in
this witness statement);

f) Post Office Card Account campaign in 2006 (to keep the card

account, partially successful in the sense it was kept, the Benefits

Agency increased their activity into the banks);

Network Change in 2007 (where another 3000 post offices were

@

closed. This was huge and dominated everything the NFSP was
doing, the work then was to get the best possible deal for those who
were having to leave the network and the way in which offices who
were to remain open. Some wanted to stay open but were having to
close and some who were to stay open wanted to close due to the
compensation the NFSP negotiated);

h) PostBank (was a proposal in 2009 for a bank owned by Post Office

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as discussed later in this statement);

i) Postal Services Bill in 2011, mutualisation and Network

Transformation;

j) the Trade Union Certification Officer 2013/2014 and the change from
trade union to trade association leading to the GFA and the way in

which the organisation could be kept going;

k) ‘White Space’ in 2018 - this is about New Network Locations, which
threatened to undermine the viability of neighbouring offices by
opening a new Post Office within close proximity which Post Office

knew about but the seller of the Post Office did not know;

I) Hard to Place - ongoing since 2018 (those offices that have not
transferred under Network Transformation are being closed down by
March 2026, we are campaigning to get full and fair compensation for

those members from the Post Office);

m) DVLA campaign (to keep DVLA services over Post Office Counters

as discussed further later in this witness statement);

n) Simplification 1 and 2 (Post Office doing upgrades of the Horizon
system which they stated made transactions quicker and so they
would reduce the transaction fee paid to postmasters for that
transaction/per transaction), Simplification 1 was introduced but 2

was scrapped.

40.The NFSP went about this by lobbying the Postal Affairs Minister (by meeting
them, writing to them); discussions with MPs generally and other

stakeholders, such as OFCOM and Citizens Advice; and trying to bring

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others on board, e.g. Association of Convenience Stores. As an example,
this is why the NFSP has a Public Affairs Manager (Ruth Buckley-Salmon) as
the work with Parliament, MPs, Ministers is vital. There is the All-Party
Political Group (APPG) which the NFSP was part of getting off the ground
and regular meetings took place at Portcullis House. The benefit of the
APPG was about informing parliamentarians of the plight of Postmasters

investing in the network.

4

.lt is difficult to summarise all of the work done by the NFSP over two
decades and the many different ways in which it has organised and run
campaigns but this is my recollection of the key events from my perspective
as a member, then branch official, then Board member and onto Chief

Executive in 2018.

42.In June 2018, when I took over as Chief Executive, I reviewed the then
practices, or lack thereof. When I became a Branch Secretary in 2012 there
was no formal training provided to those who were supporting Postmasters

where there was a contractual dispute with Post Office Ltd,

43.A Branch Secretary's Guide was produced in 2011 and I still have the copy I
received in 2012 (NFSP00001034). In the foreword by the then President
Kym Ledgar, she states “By accepting the role of Branch Secretary, you have
undertaken one of the most valuable roles in the organisation. Members will
seek your advice and guidance on a multiplicity of topics. To the majority of
our members, you will be the face and voice of the Federation.” Contained
within the guide were the roles at the time of President (Chair), Vice
President, Membership Secretary, Assistant Secretary, Minute Secretary,

Benevolent Fund Officer and Social Secretary. These individuals would

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normally form the Branch or Regional Committee, which also included a

Regional Treasurer.

44.As a minimum, there would be two Branch meetings per year and also two
Regional meetings per year. One of those meetings would be an AGM to
elect the Branch or Regional Officials. The Branch & Regional Secretaries,
should work collaboratively and in conjunction with others covering areas
where members raise issues. This could cover remuneration, holidays or
sickness substitution, opening hours, complaints from customers or
resignations due to the closure or transfer/sale of the office. Regional Non-
Executive Directors are elected by the region on a 3 year cycle and are ex
officio of the Regional Council. They can re-stand at the end of their 3 year

cycle.

45. Guidance on how to deal with Reason to Urge (RTU’s) interviews was also
provided. The aim was to ensure the member received a fair hearing and

achieve the best outcome for the member.

46.This Branch Secretaries Guide was updated and sent to all Non-Executive
Directors, along with Branch and Regional Secretaries in May 2022 (see
Branch Secretaries Guide final, NFSP00001033).

47.Listening to Postmasters during Branch or Regional meetings, there could be
an inconsistency in the level of support provided. Added to this, there was no
register of issues being kept centrally to have a fuller understanding or

broader picture of issues that Postmasters in the network were experiencing.

48.With this in mind, I along with my colleague, Nilesh Joshi, the Non-Executive

Director for London began working on what would become the Advocacy

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Representative project where consistent training would be provided to
Postmasters and a central record of all issues would be kept and analysed

for patterns or anomalies.

49.Prior to 2019, the NFSP representative would have access only to the same
information that the Postmaster could access. This was due to the Post
Office having a bureaucratic, dictatorial and hierarchal culture inherent
across the operational, tactical and strategic levels of the business. The
NFSP as Postmasters are not seen any differently by Post Office as a whole.
This has now improved with Postmasters and the NFSP, on behalf of the
Postmaster, can have access to information that Post Office use to identify

how the discrepancy arose. This is referred to later in this witness statement.

50.1 am asked to summarise the nature and extent of the legal services
that the NFSP would provide to its members between 2000 and 2019
(inclusive).

51. The NFSP does not have, and to my knowledge has not had, its own legal
service, either inhouse or funded external solicitors to cover contractual
disputes of the type which occurred during the Horizon period, such as

criminal prosecutions and civil recovery actions for shortfalls.

52. The NFSP has a commercial arrangement with an organisation called
Parliament Hill, which is a benefit management specialist. We pay a fee to
them and they provide a range of benefits to our members, which include a
free consultation with a law firm and this covers property law, personal
accident and inheritance planning. The NFSP also has an insurance policy

which allows members to access tax and VAT advice.

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53. If the dispute is a contractual matter, for instance a complaint from a member
of the public, or about opening hours, or an audit finds some procedural
irregularities, the Postmaster can get in touch with the NFSP for assistance.
This would involve the branch or regional secretary becoming involved to
assist the Postmaster. However, where the issue is or becomes a criminal
prosecution or involves civil court proceedings, that would be outside what
the NFSP representatives could do and the member would have to obtain

their own legal advice from a criminal or civil court solicitor.

54. Today we will work alongside the solicitors of any member involved in a
contractual dispute of whatever type with Post Office to assist with as full a

defence as possible.

55.1 am asked to provide an overview of the types of Post Office
employees, workers or contractors that the NFSP represented between
2000 and 2019 (inclusive), limited to those who used the Horizon IT

System.

56.1 can only comment from June 2018 with any certainty. The NFSP to my
knowledge has provided representation to NFSP members and, when we
were a trade union, Associate Members. An Associate Member could be a
family member of the Postmaster. Employees of the Postmaster would not
be members of the NFSP. For provisions regarding membership see Article
8.1 of the Articles of Association (NFSP00001051) and also previous NFSP
Rules from 2009 NFSP00001067, and 2014 NFSP00001072 which set this
out also. As mentioned, as a membership organisation of those with their
own businesses and, often, with employees, this is the reason the

Certification Officer deemed the NFSP sat outside section 1 of the Trade

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Union Act 1992. I am not aware of the NFSP ever supporting a Crown
employee of Post Office as that is the exclusive remit of the CWU or, ifa

Manager, then likely the CMA (now Unite).

57. lam asked to provide an overview of the processes by which SPM’s
concerns and grievances were reported, recorded and monitored by the
NFSP between 2000 and 2019 (inclusive). Where this changed over

time, I am asked to provide details.

58.1 cannot answer with any certainty prior to June 2018 but from my own
experience as a Branch Secretary from 2012, it did not appear that there was
a central recording facility. However, if a Postmaster had a concern or a
grievance, they could come to their local Branch Secretary or Chair, their
Regional official or their Executive Officer prior to September 2016 and Non-

Executive Director from October 2016.

59. If they had a concern this could be raised at a Branch or Regional meetings
or through the Standing Orders Committee which decided which motions
should be included at the Annual Conference, as was the usual way of doing
things in a trade union. This is seen in the Branch Secretary Guide 2012
(NFSP00001034) which sets out the way in which members would put
forward motions, ask questions, debate and discuss matters at the annual
conference. They were also able to write to the National President/National
Chair who is the most senior representative of the members. The person in
this role would change annually. They would bring matters raised with them

to the Executive Council or Board of Directors.

60.As a result of participating in this Inquiry we have recognised a much greater

and real need for the ability for members to raise concerns they may have

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about the NFSP. With this in mind we have developed both a complaints and
whistleblowing policy for members. These are being discussed by the Board
on Monday 2™ September, and will be communicated to the members and

provided to the Inquiry thereafter.

6

Although the branch system meant that often issues did not come up to HQ,
in 2018 I began a system of collating issues which were coming up across
branch and regional secretaries and analysing them for themes, patterns and
anomalies. A report is then presented to the Board at each quarterly Board
meeting. This is discussed further at paragraphs 265 — 266. The most
recent of these reports is NFSP Public Affairs Manager Report to NFSP
Board re issues affecting Postmasters March 2024 (WITN00370109). We
would usually have had a report in June, however our Public Affairs Manager
was not able to compile this due to the work she has been doing on this
Inquiry. As described later, if any issue is identified it is taken to and
discussed with the Post Office. We also have the 10 regional WhatsApp
Groups and a Facebook page and we pick things up from there also. This
process was not previously in place during the Horizon era and social media
is now more to the fore. While social media has been very useful in hearing
directly from Postmasters about issues they are having, it does come with
some negative impacts when it is used to troll the organisation or its local
representatives with occasions of personal abuse which has left some

Postmasters unwilling or afraid to provide comments on issues.
KNOWLEDGE OF HORIZON
62. I am asked to describe the nature and extent of my knowledge of the
integrity of the Horizon IT System from 2000 to 2019 (inclusive),

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including (a) the existence of bugs, errors or defects and (b) the ability
of Fujitsu staff to alter transaction data or data in branch accounts

without the knowledge or consent of SPMs (‘remote access’).

63. I can’t recall where or when I started to become aware of the issues being
raised that Horizon was faulty. I can only say it is my recollection that it was
getting towards 2015 before I become aware of issues around the Horizon
system being faulty and the prosecutions based on it. I’m conscious that it
probably sounds strange that I personally did not know of bugs, errors and
defects during this time. I think this comes down to being a Postmaster in a
small village, later becoming a local branch representative. In my own
experience as a Postmaster in my Post Office and in the branch role, I didn’t
come into contact with anyone raising Horizon being faulty or the cause of
losses as an issue. The issues I mainly heard about were the kind of things
I've described as the NFSP being involved in. Although I can’t recall just
when this was something I did become more aware of, I can see that in
emails with Helen Baker in around June 2015 I was saying that if over 150
MPs say there is a case for the Post Office to answer then it seems rather
odd that the SLT (Senior Leadership Team) of the NFSP don’t look into it
(see Email from Calum Greenhow to Helen Baker re: ace up the sleeve,
NFSP00001460). I can’t recall where I got the information about 150 MPs,
but it does seem that I knew of something that was being said by them. I
think the first time I became aware of the nature of Horizon issues on losses
and prosecutions was watching the Panorama programme in August 2015.
When I watched the Panorama programme and saw Hughie Thomas, Jo

Hamilton and Seema Misra, I just couldn't see them as people who had

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stolen money. I saw the programme and then saw George Thomson's
branch circular (see Branch Secretaries’ Circular dated 18 August 2015,
(WITN00370126) and thought these things didn’t add up and which resulted
in me emailing him to question this (see Email chain from Angela Van-Den-
Bogerd to Mark Davies RE: Panorama - Trouble at the Post Office,
POL00162628). Although there is reference to bugs in the Second Sight
Interim Report of 2013, I don’t remember reading this report until later
although I can’t say when that was. I can see that George Thomson issued a
branch circular on 27" August 2013 (Branch Secretaries Circular from
George Thomson re press release and information pack, NFSP00000976) in
which he encloses the press release and information pack issued by Post

Office about the mediation scheme.

64. From what I can recall, I first became aware of the Fujitsu ability to access
postmaster accounts on Horizon and alter data was when the GLO took
place and the judgement was issued in December 2019. I was aware that
remote access was something that was being spoken about, for instance, it
was raised at the BEIS Select Committee in 2015 at which George Thomson
and Andy Furey of the CWU appeared, but it was being denied by the Post

Office and they consistently denied it and continued to deny it.

65.1 remember that I had a call with Tim McCormack, a postmaster member of
the CWU who had a post office in the South of Scotland Region in August
2016. He contacted me by email in August 2016 (see Emails between
Calum Greenhow and Tim McCormack re Dalmellington dated 9 August
2016, WITN00370129) and through that I became aware of what is known as

the Dalmellington bug.

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66.In paragraph 448 of Fraser LJ’s Horizon Issues Judgment (UKGI00018137),
he states that between 2010 and 2015, 112 occurrences of the Dalmellington
Bug, affecting 88 different branches, took place. I had no knowledge to the

extent of the bug prior to Fraser LJ’s ruling of 2019.

67.1 am asked to what extent did I discuss the integrity of the Horizon IT
System from 2000 to 2019 (inclusive), including (a) the existence of

bugs, errors or defects and (b) remote access with others at the NFSP?

68.As has mentioned earlier in my statement, in 2015 after watching the
Panorama programme, I wrote to George Thomson (see Email chain from
Angela Van-Den-Bogerd, POL00162628), the then General Secretary of the
NFSP highlighting my concerns. In the June of 2016 I joined the Board of the
NFSP with Peter Montgomery, who also joined at the same time.
Independently of each other, at the first Board meeting I attended, we each
challenged the Board and especially George Thomson on the stance taken
by the NFSP in relation to the integrity of Horizon (see NFSP report of a
meeting of the Council on 13-15 June 2016, NFSP00000500), however I can
see this was not recorded in the Minutes. I can remember saying the
computer system cannot be 100% correct, a 100% of the time. I think George
was repeating the no systemic issues line, but I was saying that did not mean
it couldn't have local faults. George effectively shut it down and states, as
seen in those Minutes, that we were ‘reminded’ of ‘collective cabinet
responsibility’. In raising this at the first Board, I was conscious that I wanted
to try and build some momentum that could challenge George, I felt if I had
gone at him all guns blazing he would have shut me down, as he had done

others, and this would effectively prevent any challenge or change.

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69.As I describe later in my witness statement at paragraph 99, I had a case
involving a Postmaster who was having issues at their branch. At the reason
to urge interview with this Postmaster, I challenged the Post Office Contracts
Manager for Scotland, Brian Trotter, about the Dalmellington bug which Tim
McCormack had told me of in earlier in 2016. Brian Trotter told me that the
Dalmellington bug had been fixed, but did not elaborate as to when. He only

said it was not connected to the case. I do not have minutes of this meeting.

70.1 emailed Mervyn Jones in June 2015 primarily around the GFA but I was
also raising concerns that although the Second Sight Interim Report
indicated no systemic fault with Horizon, there was enough for the NFSP to
be challenging the Post Office on how they were dealing with members (see
Email from George Thomson to Mervyn Jones re: Yesterday's Branch
Meeting, NFSP00001465). This email was brushed off. I did send Mervyn’s
reply and my email on to others who were at that time on the Standing

Orders Committee so that they could see the issues I was raising.

7

.Iam asked to summarise any steps I or the NFSP took in order to
develop a better understanding of the integrity of the Horizon IT System
from 2000 to 2019 (inclusive), including (a) the existence of bugs, errors

or defects and (b) remote access between 2000 and 2019.

72.1 am asked what the NFSP did to better understand the issue of bugs, errors
and defects. As I have mentioned, this was not something I had any real
awareness of until around 2015. From looking back at records that the NFSP
has supplied to the Inquiry which appears to relate to such queries, examples

include:

a) National Executive Council Circulation with Memo from George

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Thomson to Executive officer re Lee Castleton - Horizon (Lee
Castleton case study), NFSP00000888; George Thomson asked
Executive Officers to notify him of cases where the member believed
Horizon was the problem and gave an undertaking he would raise the

case with the Post Office at the highest level.

Email from Martin Rolfe to Michael Rudkin others cc'd re: Bracknell
Visit, POL00021699; this confirms Michael Rudkin did go to Bracknell
as has been reported although it appears we don’t have further

details on this.

Motions for conference as agreed at the Midland Regional Council
meeting on February 2010, NFSP00001037; in preparation for
Conference potential motions were discussed, including ones about
Post Office retaining Horizon data on failures in software for a 12

month period, as they were doing it only for six months.

Report on Motion, NFSP00001044; this shows NFSP members via
motions at Conference trying to mandate the Executive Council to

challenge Post Office on Horizon generated shortfalls.

Horizon Next Generation Release Authorisation Board (Internal)
Recommence Pilot Activities: Meeting no 10, Post Office (Internal
RAB Meeting of 04 May 2010) NFSP00000725; there were a large
number of outages and freezes relating to Horizon Online rollout
which the NFSP repeatedly challenged Post Office about. Marilyn
Stoddart was invited to join the Release Authorisation Board and as
can be seen was asking about information on issues such as the live

service log and recovery process.

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f) Letter to Dave Hulbert from Marilyn Stoddart re Semilong Post Office
Mrs Jane Brewer, NFSP00000806; this is an example of the NFSP
challenging the Post Office to carry out an investigation into

shortages that may have been caused by Horizon.

g) Email chain from Marilyn Stoddart to Andrew Craddock, Keith
Richards re workshop agenda for Bracknell 22 Jan, NFSP00000671
and Email from Dave Hulbert to Marilyn Stoddart Re: Issues around
the recovery process following Horizon outage, NFSP00001332);
there had been frequent outages and freezes, the NFSP identified an
issue with the recovery process and what the helpline was telling
Postmasters about this. Issues with the recovery process was
causing shortages, in that if it was not dealt with correctly
transactions would not go through properly, causing an issue with the
accounts. The NFSP escalated this issue to Post Office which
culminated in an NFSP visit to Bracknell on 22 Jan 2013, in which
Fujitsu were to explain to the NFSP why recovery happens and hints

and tips for successful recovery.

h) Agenda and Briefing for Paula Vennell's meeting with George
Thomson on 13 March 2013, POL00142870; this agenda shows
concerns about Horizon reliability and outages and capacity to handle
peak volume periods.

73.Earlier in this witness statement I have set out steps I took to try to
understand these issues of bugs, errors and defects, including my email to
George Thomson after the Panorama programme (POL00162628), although
I can’t remember now if the programme specifically mentioned bugs, errors

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and defects. Once I took over the role of Chief Executive in June 2018 and
in relation to the steps I took to develop a better understanding, I met with
Andy Furey, Assistant Secretary of the CWU in October 2018 during which
Horizon was discussed and I refer to that later in this witness statement at
paragraph 131. I met with Lord Arbuthnot in July 2019 to try and understand
more of the background to the GLO trial which had been taking place and I
refer to that later in my witness statement at paragraph 141. When I came
into post as Chief Executive, the trial date had been set and was happening
a few months later. I felt it at that time the correct course was to allow the
court process to take place to determine the extent of the Horizon issue and
provide a ruling. As the NFSP was not a party in the proceedings, it was not
until after Fraser LJ’s Common Issues judgement in March 2019 that we
began to understand the full extent of actions of Post Office over the years,

which I discuss further later in this witness statement.

74. After the Common Issues judgement, the NFSP appointed Nilesh Joshi to
the role of Legal & Regulatory. The purpose of this role was to collate and
collect all members contract issues along with any anomalies or
inconsistencies that show up. As mentioned earlier, a training programme
would be developed to provide representatives of the NFSP the knowledge

to support Postmasters at interviews held with Post Office.

POST OFFICE INVESTIGATIONS, CRIMINAL PROSECUTIONS AND CIVIL
PROCEEDINGS
75. 1am asked to summarise how I understood POL to conduct branch
audits or investigations into alleged shortfalls in branch accounts
whilst I have been a member of the NFSP. I am asked to summarise any

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changes in practice I noticed.

76. There were two types of audit Post Office conducted, those routinely on a

three-year cycle or those where a suspected cash shortage may be present.

77.As I never had an audit where a concerning shortfall was a factor, I cannot
comment on this at a personal level. However, where the audit may be due
to a suspected discrepancy, my understanding is that either a Postmaster
would submit a Trading Period balance that showed a significant loss (I
cannot state a minimum figure but I remember I was always concerned about
the size of the losses prior to the Post Office doing an audit) or there would
be a concern about the Overnight Cash Holdings (ONCH) in relation to the

amount of cash that the office went through.

78.When an audit took place, it was unannounced. For us at our Post Office,
there would be a knock on our flat door usually about 8am and two auditors
would be present. We would take their ID and check with Post Office that
they had authorisation to be present and then allow them access to the safe,
where a check of our cash and stock against the Horizon derived figures
would be conducted. If there was a slight discrepancy, it would be noted and
then a discussion against Post Office processes would take place. This
usually centered around security and whether we had the telephone number
for Grapevine and the security manual to hand. A week or so later, a full
report would arrive outlining the audit and any recommendations that were

suggested.

79.Personally, I found the Auditors officious but diligent in doing their job. There
was one occasion where I did take exception, and that was where they put a

notice on our outside door stating that the Post Office was closed for financial

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checks to be undertaken. I refused to allow them to put it up as I felt it
suggested to the community that there may be financial irregularities behind
the checks. The auditors agreed and carried on with their audit, which found

no irregularities.

80. The only change I noticed was that the routine three-year cycle stopped and
now you only receive a Branch Assurance visit, if there is a concern. Today,

these visits tend to be announced in advanced.

8

. If a Postmaster was short in their balance, there is a common acceptance
that they are responsible for these discrepancies as per their contract,
Section 12 of the SPSO contract (NFSP00000761 or POL00075132) and
clause 4 in the Mains & Local contracts (POL00003870 and POL00372920

respectively).

82.Whilst Postmasters took on the responsibility for the safe keeping of Post
Office stock and cash, Post Office had a duty to provide a system that was fit
for purpose and investigate any discrepancies fairly and thoroughly. Both of
these sides of the contract should have been complied with “in good faith”.
However, I can see from documents provided by the NFSP to the Inquiry and
from my own experience that the Post Office attitude to losses became
harsher after the introduction of Horizon (see Open Debate resume losses

audit suspension, NFSP00001041).

83. Iam asked to consider and comment on UKG1I00025299 (Email from
Tom Aldred to Beth White, William Wilson, Post Office Team and others
re BEIS/NFSP/UKGI meeting 26/11/19 - read out), in particular the
following extract from William Wilson’s email dated 2 December 2019:

“They (sic) key point for Calum is that, following an audit, there should

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be much more transparency when POL investigates claims. He finds
POL ways of dealing with (potential) losses still rather cack-handed and

not in good faith.”

84. This email was written prior to the Post Office providing and issuing internal
policies that cover audits in which I go into more detail later in this witness
statement at paragraphs 323 - 329. The email appears to be someone's
interpretation of what I have said, I don’t recognise the phrase ‘cack-handed’

as one I would use.

85. I am asked to describe the nature and extent of any support the NFSP
offered to SPMs in relation to (a) raising concerns about the Horizon IT
System or related training and support services, (b) the conduct of
branch audits, (c) investigations into alleged shortfalls in branch
accounts, or (d) civil or criminal proceedings against SPMs arising from
alleged shortfalls in branch accounts, between 2000 and 2019

(inclusive). 1am asked how was that support organised by the NFSP.

86.As I was not in a position of leadership for the majority of this period, I can
only give my understanding as a Postmaster during the time period in

question.

87.All Branch Secretaries, Regional Secretaries, Executive Officers or Non-
Executive Directors of the NFSP along with the previous Assistant General
Secretary and the General Secretary/Chief Executive would have been able
to offer support to any Postmasters who raised concerns about a branch
discrepancy, including when the Postmaster believed it was as a result of

Horizon.

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88. There is evidence of times where the NFSP were raising concerns to Post
Office about the quality of training, for example in the National Federation of
Subpostmasters Report of a Meeting of the National Executive Council on
15-17 June 2009, NFSP00000511, where the Council were trying to ensure
that Postmasters were properly trained to minimise the risk of shortages; and
in the Spreadsheet concerning terminals and Post Office Horizon software
transactions (mails closed actions; branch support and compatibility report) -
last updated was 12 February 2019, NFSP00001352, where there are entries
under both open and closed Negotiating Committee actions detailing the

NFSP challenging Post Office about the quality of training.

89.In 2000, the NFSP introduced training for Branch Secretary who would be
involved in Reason to Urge (RTU) interviews, where a Postmaster was being
questioned about an alleged shortfall (see NFSP Branch Secretaries’
Training Representing Members RTUs and Appeals, NFSP00000848; and
Publicity and Development Committee: Branch Secretaries Training reasons
to urge and appeals interviews recruitment, NFSP00000822). It seems that
training was discontinued at some point. As I have said earlier, it was not
offered to me when I became a Branch Secretary in 2012. Guidance is
available within the Branch Secretaries Guide, as discussed earlier in this

statement.

90. Although before my time on the Board or as Chief Executive of the NFSP,
from the evidence available to the Inquiry, I can see that before I became
Chief Executive, a key concern that the NFSP had regarding the Horizon IT
System, as reported to them by members, was the repeated and prolonged

outages, and their effect on their businesses being able to operate. I can see

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9

92.

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that the NFSP repeatedly challenged the Post Office regarding the outages
and tried to obtain goodwill/compensation payments from the Post Office for
Postmasters as a result of these concerns (see, for example, the entries
regarding outages and goodwill payments in the Spreadsheet concerning

terminals and Post Office Horizon software transactions, NFSP00001352).

.I can see there is evidence which has been made available to the Inquiry of

NFSP officials challenging shortages, asking for investigations into shortages
which may have been caused by an issue with Horizon, and asking that the
debt recovery process against Postmasters be blocked. For example, in the
Email from David Milner to Anita Turner, Marilyn Stoddard, George Thomson
and others - Re: National Savings Payment Advice, NFSP00001291, Dave
Milner challenges the Post Office where a Post Office suffered a £4,000
shortage because Horizon had recognised a £2,000 withdrawal as a £2,000
deposit. He asks for confirmation that the business has addressed this issue,
and for assurance that all payment advice transactions over this period will

be investigated to ensure that no Postmaster suffered a shortage.

I can see there is another example where Marilyn Stoddart is asking for the
Post Office to block the debt recovery process in relation to a shortfall
caused by the recovery process failing, as seen in Email from Andrew Winn
to Marilyn Stoddart and Branch Support Team re: Balance discrepancy,
Queen's Ferry Post Office, NFSP00001305. As discussed earlier in this
statement at paragraph 72(g), as Postmasters continued to have issues with
the recovery process and inform the NFSP about these, I can see the NFSP
later visited Fujitsu for an explanation of this issue (see Email chain from

Marilyn Stoddart to Andrew Craddock, Keith Richards re workshop agenda

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for Bracknell 22 Jan, NFSP00000671).

93.When it came to the Post Office deciding to prosecute and take the matter
into the civil or criminal courts, as discussed in my witness statement, the
NFSP did not have inhouse legal services or externally funded legal support
for criminal prosecutions. This situation is the same or similar to other
organisations, such as the CWU, and Tony Kearns of the CWU also referred
to this situation when he gave his evidence to the Inquiry in June this year.
This meant that members had to obtain their own solicitors for such cases. I
know I have met with solicitors to answer any questions or guide them on
how the Post Office and Horizon worked so that they could build as strong a
defence as possible. I cannot state if in every case that the NFSP was

contacted by the defence solicitor to request our assistance.

94.My understanding of the past is that the NFSP believed that the Postmaster
had the right to choose whether they asked for the help of the NFSP, or
whether they decided to deal with their case themselves. Our preference
today would be that all Postmasters seek the help of the NFSP and that no

Postmaster should suffer in silence.

95.When we were a Trade Union, we could only help those who were already a
member. However, after we became a Trade Association, currently funded
via the Grant Framework Agreement, any Postmaster, whether they were a

member or not would receive the same support.

96. 1am asked to summarise my knowledge of or involvement with
case(s) in which the NFSP provided support or representation to an
SPM who was (a) accused of misconduct or incompetence in relation to

a shortfall in a branch account and (b) the SPM could not explain the

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cause of the shortfall or alleged that it was caused by the Horizon IT

System, between 2000 and 2019 inclusive.

97. There is a lack of a central record keeping process historically during the
time period which means the NFSP does not have the evidence to show the
extent of support that a Regional Official would have or did provide in
individual cases. This is something we have sought to rectify via the central
recording keeping of support provided at a Branch or Regional level.
However, the NFSP has been able to provide evidence to the Inquiry that
shows the NFSP helping Postmasters where a discrepancy was present. An
example would be the issues at Semilong Post Office, as referred to
previously. Here Marilyn Stoddart wrote the Post Office to request a full
investigation as the result of significant shortages which may have been

caused by the Horizon system (NFSP00000806).

98.During my time representing Postmasters as a Branch Secretary or Non-
Executive Director for Scotland between 2012 -2018, I had only a small
number of cases where there was a discrepancy at audit. As it happened, all

but two of the Postmasters admitted to taking money.

99.1 had a case where there was a Postmaster who had been in post only for a
short period of time but was being questioned over a £39,000 discrepancy in
their branch accounts. The Postmaster operated a core and outreach office,
with Post Office suggesting that there was a misbalance between what cash
and stock was being transferred between the core and outreach offices. The
Postmaster was insisting that he was having trouble with the transferring of
cash and stock due to the barcodes that were being used to transfer between

the core and outreach offices. I challenged Post Office on whether it could be

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the Dalmellington Bug, based on the information Tim McCormack provided
(as discussed earlier in this statement), but was told that the bug was fixed
prior to the events taking place so could not be involved. I continued to push
the Contracts Manager during the meeting for information covering the period
that the discrepancy was supposed to have occurred. However, the response
I received was that as Post Office did not have the information themselves,
they would have to request the information from Fujitsu which would incur a
cost. My response was that given we are talking about the integrity of a

Postmaster, cost should not be a factor.

100. On leaving the meeting, there were two action points. The first was for
Post Office to retrieve the information requested from Fujitsu (which was
never supplied). The second was for the Postmaster to write a letter to the
Contracts Manager outlining the losses they had incurred along with the lack
of training and support from Post Office they had received. I contacted the
Postmaster having not heard anything from them for a few weeks to be told
that the case was before John Breedon, Head of Postmaster Contracts. A
few weeks later, I spoke with the Postmaster as Post Office was requesting
further information from them. Unfortunately, in the December 2016 the
Postmaster received a letter from the Contracts Manager terminating their
contract but there had not been a criminal charge. I kept in contact with the
Postmaster trying to support them afterwards but was not able to encourage
Post Office to reconsider as there was no longer an appeals process.
However, when Fraser LJ’s ruling was handed down, I contacted the
Postmaster to see how they were and let them know that there was a

Historical Shortfall Scheme being set up. It was then that I discovered they

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became part of the GLO and will hopefully, finally receive the financial
redress they fully deserve.
RESPONDING TO THE EMERGING SCANDAL
101. lam asked to consider:
a) POL00041564 (Computer Weekly article dated 11 May 2009);
b) NFSP00000500 (NFSP council meeting minutes dated 13 - 15
June 2016);
c) POL00162628 (the email exchange dated 19 August 2015).
102. lam asked to describe when I first became aware of the creation

of the Justice for Subpostmasters Alliance (“JFSA”) and the allegations

made in the 11 May 2009 Computer Weekly Article.

103. As per my email to George Thomson of August 2015 (POL00162628),
I first became aware of a group of Postmasters, who I subsequently came to
understand as Justice for SubPostmasters Alliance at my first Annual
Conference in Torquay in May 2010.

104. I cannot state specifically when I became aware of the allegations
made in the May 2009 Computer Weekly article but clearly, by August 2015 I
was beginning to question the line that Post Office and George Thomson
were promoting.

105. 1am asked to consider POL00162628 (Email chain from Angela
Van-Den-Bogerd).

106. lam asked to explain why I sent the email of 19 August 2015 to

George Thomson.

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107. Like a lot of Postmasters and also members of the general public, I
watched the Panorama programme and received the Branch Secretaries
Circular (BSC) that was issued by George Thomson on the 18th of August
(see Branch Secretaries’ Circular dated 18 August 2015, WITN00370126). I
felt that the NFSP had to start thinking a different way and challenge Post
Office. Despite the Post Office and the BSC claiming there were no systemic
issues, that did not mean it was impossible for the computer system to add

2+2 and get 3 or 5.

108. I am asked to what extent I discussed the matters raised in this

email with others at the NFSP.

109. I contacted both the Scotland Executive Officer and Regional Secretary
for the issue to be placed upon the next Regional meeting, which was due to
take place in October (see Emails between Calum Greenhow (as Branch
Secretary), Donald Ramsay (Scottish Executive Officer) and Paul McBain
(Scottish Non-Executive Director) after Panorama Programme 18 August
2015, WITN00370102; and Emails between Calum Greenhow (as Branch
Secretary), Donald Ramsay (Scottish Executive Officer) and Paul McBain
(Scottish Non-Executive Director) after Panorama Programme 19 August

2015, WITN00370103).

110. Following these emails, the NFSP Scottish Regional Council Minutes
dated 2 October 2015 (WITN00370131) record the following from the
Scotland Executive Officer: “BSC 24 under the spotlight with regards to the
Horizon system and what it does or does not do. National President agreed
that the Post Office did a lot wrong in the early years but there is no evidence

that the systems were at fault. The National President also explained that the

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system was checked annually for its robustness and no issues were found by
these outsourced companies of which Price Waterhouse was one. The
agreement with the delegates was to accept the response but believe that

the issue would return due to MP signing an Early Day motion.”

111. I am asked to describe the actions I took (if any) following George

Thomson’s response to this email.

112. I cannot remember whether I did anything further after the October
Regional meeting. I would say that around this time, my wife and I were
having to make a decision in relation Network Transformation and whether
we would convert to a Local or leave the network. This would have a
significant impact on our future, whether we could afford to remain in our
home or would have to move and so I think there were many other significant
aspects taking place around that time which I was dealing with.

113. I am asked to provide an account of any steps I or the NFSP took
between 2000 and 2019 (inclusive) in raising any concerns regarding
the integrity of the Horizon IT System with POL, the Government, the
Shareholder Executive/UK Government Investments (‘UKGI’), MPs and
peers or journalists.

114. My dealings with Post Office, Government, the Shareholder
Executive/UKGI, MPs and peers or journalists only began after I took over as
Chief Executive in 2018.

115. In December 2019 I wrote a Branch Secretaries Circular to all
members (see NFSP - Branch Secretaries Circular vol. 31, NFSP00000292),

where I call on Government to ensure that Horizon is monitored and reported

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on transparently. I further called on Post Office to provide effective training,
engagement and relationship building with a clear and easy process for
flagging and escalating problems. If losses are identified, the focus should be
on resolution, not prosecution. I concluded by directing any Postmaster who

had suffered losses to contact the Complex Case Team.

116. Looking into the past, Colin Baker in his correspondence with Sir Alan
Bates says “In relation to errors which members considered were due to
Horizon problems, the Executive Council set up a joint Federation/Post Office
Ltd group who visited the Horizon helpline site to discuss and resolve issues.
It is my understanding that Post Office Ltd can trace the nature of any error
including telephone calls relating to the same when the Horizon System is in
question and, therefore, should be able to produce evidence that all is, in
fact, correct from their side” (see Letter chain from Colin Baker to Alan Bates

RE: Horizon System; NFSP00001058).

117. In August 2008, Michael Rudkin, the NFSP Chair of the Negotiating
Committee (NC), visited Fujitsu’s headquarters in Bracknell due to concerns
about the Horizon system. We have not been able to find a report on this
visit, nor is it mentioned in either the Negotiating Committee or Executive
Council minutes from the time period, but have located confirmation of his
attendance (see Email from Martin Rolfe to Michael Rudkin others cc'd re:

Bracknell Visit, POL00021699).

118. As discussed earlier in this statement, where there have been
significant issues in relation to outages of the Horizon system resulting in
Postmasters being unable to trade, the NFSP negotiated goodwill payments
to Postmasters.

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119. In February 2010, there is evidence that the NFSP ensured that the
roll-out of Horizon Online was paused due to concerns about how it was
working. This also included some form of compensation for these offices
affected (see, for example, Branch Secretaries’ Circular - February 2010 -
Volume 9, NFSP00001014; and Letter on Horizon Online Pilot Review from
Marilyn Stoddart with email attachment of feedback from Mark Burley,

NFSP00000061).

120. 1am asked to describe my working relationship with Paula
Vennells and the senior management team at POL and provide details
of any meetings I had with the senior management team at POL in

respect of concerns or allegations regarding the Horizon IT system.

121. I took over my role in June 2018 and (as Ms Vennells indicated in her
evidence to the Inquiry) she had taken a back seat by Christmas 2018. As
such, there was very little cross-over. I do remember not long after I had
taken over my role, being invited to a meeting by Tim Parker, the then Chair
of Post Office (see Summary of meeting with Tim Parker and Paula Vennells
on 29 May 2018, NFSP00000040). At the meeting Ms Vennells was present
and I found the interaction strange. Having been part of a disciplined service
such as the Fire Brigade, I had learned from that there was a way that senior
officers acted in relation to junior officers and vice versa. No junior officer
would interrupt or speak over a senior officer, but a senior officer will interrupt
or speak over the junior officer, who will then immediately go silent. This
attitude appeared to be present from Tim Parker to Ms Vennells, where on a
few occasions Ms Vennells would be talking and then Mr Parker would

interrupt and talk over her. On these occasions, Ms Vennells immediately

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went quiet.

122. I had cause to write to Paula Vennells in September 2018, requesting
the scrapping of Simplification given Post Office’s profits had increased that
year but Postmasters income had declined (see Email to Paula Vennells over
Post Office's Annual Report & Accounts 14 September 2018,
WITN003700132). Simplification was split in two parts. Simplification part 1

was implemented but Simplification part 2 was not.

123. As the Chief Executive of the NFSP, I was invited to Ms Vennells’
leaving do at Finsbury Dials on the 30" of April 2019. My recollection of it
was one of “for she’s a jolly good fellow and so say all of us” being led by Tim
Parker and Al Cameron. Given the outcome of the GLO, this whole thing did

not sit with me and so I left.

124. lam asked to describe the NFSP’s relationship with the

Communications and Workers Union (‘CWU’).

125. The NFSP and the CWU have in the past been able to work
collaboratively where our interests align, for example, in relation to the
PostBank proposal in 2009, as presented to the All Party Parliamentary
Group (APPG). PostBank was a proposal in 2009 for a bank owned by Post
Office and a rival in the banking system as a new entrant and would have
enabled us to encourage our POCA customers to bank with us. This was
done in France and other countries, which is keeping their Post Offices viable
but government did not want to do this due to the cost of a banking licence,
which is why we currently have the banking framework. The CWU and
NFSP’s interests aligned in relation to this proposal, and we advocated for

this at the APPG together (see CWU Research: Post Bank Campaign

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Briefing, NFSP00001110; NFSP Briefing — Postbank: All Party Parliamentary
Group for Post Offices, NFSP00001116; and All Party Parliamentary Group

for Post Offices- Agenda for AGM/Meeting on Postbank, NFSP00001105).

126. As I discuss later in this witness statement, the CWU is a trade union
representing, among others, Crown Post Office employees. The NFSP
represents individual Postmasters who are self-employed small business
owners and are not employees, although they may well be an employer. Our
respective interests are therefore quite different. As George Thomson said in
his oral evidence regarding the vote on the Memorandum of Understanding
or merging with, for example, the CWU, the NFSP membership was not
naturally inclined to want to be part of a large trade union. The vast majority
of the CWU’s membership is within Royal Mail and as both Royal Mail and
Post Office are two separate organisations with different owners and

shareholders, then the needs of our membership do not match.

127. The relationship between the NFSP and CWU has not been good
since the NFSP announced their support for the Postal Services Bill in 2011.
However, as this would mean the sell-off of Royal Mail, it was something that
the CWU was very much against. This was also around the time that two
Executive Officers of the NFSP, Mark Baker & Nippy Singh formed the
Postmaster Branch of the CWU. I think it is fair to say that by then George
and Mark did not have a good relationship and saw things differently on the
Bill and also on Horizon, and this may well have led to the departures and

bad feeling at the time.

128. In 2013 as Network Transformation completed its first full year, there

were 373 Crown offices and 4511 Crown office employees according to Post

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Office’s annual accounts. By 2023, this had declined to 114 Crown offices
and 1269 Crown office employees. Therefore some 70% of the number of

Crown offices and Crown employees had been lost.

129. lam asked to what extent did you or the NFSP liaise or
communicate with the CWU and/or the JFSA in relation to the integrity

of the Horizon IT System?

130. I cannot say what conversations the NFSP of the past had with either
the CWU or JFSA in relation to the integrity of the Horizon IT system. I am
aware via the Inquiry and the documents that the NFSP have identified and
supplied to the Inquiry that there was a Working Group back in 1999 on
which were the NFSP, the CMA (now Unite) and the CWU. I do not know if
there were any discussions at that point in the development and roll out of
Horizon. I am aware that there was correspondence between Sir Alan Bates
and Colin Baker, former General Secretary of the NFSP in late 2003 and
early 2004 (see Letter chain from Colin Baker to Alan Bates RE: Horizon

System; NFSP00001058).

131. I can say that I have had a meeting with Andy Furey, Assistant
secretary of the CWU on 30th September 2018 where many topics were
discussed. One topic was the impact of the Horizon on Postmasters and I
said that my view was different to George Thomson's. Mr Furey did not offer

any insight beyond what he stated in the 2015 BEIS Select Committee.

132. I totally understand, given the history, that there would be a reluctance
for members of the JFSA to have involvement with the NFSP. To try to repair
that, over the last couple of years, I have reached out to the JFSA via their

website on four occasions, although have not heard back on this. I recently

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asked one of the members of the JFSA if they might speak with Sir Alan
Bates about the possibility of my meeting with him. My hope is that Sir Alan
would understand that I am trying to help and have been changing the

organisation which failed him and others in the past.

133. lam asked to summarise the nature and extent of any involvement
the NFSP had, or the support or representation it provided, in relation

to the following matters:

a) efforts by SPMs convicted of theft, fraud offences or false
accounting to overturn their convictions; and

b) POL’s Initial Complaint Review and Mediation Scheme.

134. In relation to efforts by Postmasters convicted of theft, fraud offences
or false accounting to overturn their convictions, whilst we can tell from the
June 2016 Executive Council minutes (NFSP00000500) that my predecessor
thought that Freeths “were ambulance chasers’, I can say that from ad hoc
conversations I had with people, there were branch and regional secretaries
as well as other individual members of the NFSP who encouraged
Postmasters to engage with Freeths and the GLO. I can’t recall names of

individuals or what documents exist to show this.

135. The legal process was under way with court dates set when I took on
the Chief Executive role in June 2018, and the NFSP was not a party in the
GLO case. Therefore, I determined that it was right to allow the due legal
process to take place and allow the courts to determine once and for all what
the answer to the Horizon issue was. Added, as someone not experienced or
practiced in the legal process, I did not think we could get involved at that

late stage. I certainly had no idea that the NFSP would be a significant focus

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of the GLO proceedings.

136. After the GLO rulings were handed down, I did not feel it right for the
NFSP to try and “muscle in” on discussions. Rather I felt it was better for the
NFSP to add its voice to the calls for full redress to be provided, as I was
aware that due to the legal costs involved, many of the GLO claimants were
still at a financial detriment (as discussed later in my statement). I did have a
meeting with Postal Affairs Minister Paul Scully MP and Nick Read, where I
called on Post Office to begin legal proceedings against Fujitsu for financial
redress and for any sums to be passed on to the victims. I remember
describing the situation as similar to an individual buying a car. On leaving
the car garage, something terrible happens. As a result of that something
terrible, the car owner is charged and prosecuted. However, later it transpires
that both the car garage and the manufacturer knew about the fault in the car
that caused the something terrible. It would then be a requirement for both
the car garage and the manufacturer to be held to account and provide
financial redress. As both Government and Post Office have provided the
financial redress so far, I felt that it was imperative that Fujitsu should also
provide financial redress. I have written many columns, given radio or TV
interviews and have been quoted on many occasions calling for the victims to
have their convictions quashed and for all of their losses, including

consequential losses, to be refunded without delay.

137. In relation to POL’s Initial Complaint Review and Mediation Scheme,
this all happened prior to my role as Chief Executive Officer so I cannot
comment on any personal activity. The NFSP has provided evidence to the

Inquiry in relation to the NFSP and the Complaints & Mediation Scheme,

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including:

a) Letter (Branch Secretaries Circular) from George Thomson to
unnamed colleague re Horizon Mediation Scheme, NFSP00000263,
which shows that George Thomson circulated the information pack
on the mediation scheme to members through a Branch Secretaries’

Circular;

b) Email from George Thomson to Paul Hook CC'd George Thomson,
Annabel Barnett RE;POL Horizon mediation scheme,
NFSP00000699, which shows that the public line proposed regarding
the mediation scheme was that the NFSP was welcoming the
announcement of the establishment of the scheme, and was happy
that the Post Office was saying that it would improve training and
support;

c) Meeting 29/8/13 148 Old St. Gayle Peacock, Stefani Ulgiati, Ann
Analka, Andrew Gilhooly, Marilyn Stoddart, lan Park,
NFSP00000695, in contrast to the public line proposed above, this
shows that George was not in fact supportive of the establishment of
the Mediation Scheme, as the Inquiry heard through his oral

evidence.

GROUP LITIGATION PROCEEDINGS

138. lam asked to describe any involvement I had in respect of the

GLO proceedings.

139. There was no hand over from my predecessor, George Thomson, in

relation to the GLO. I do remember prior to taking on the Chief Executive role

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asking him why he was leaving at that point and was there anything coming
down the line that I was not aware of that was encouraging him to leave at
that point? His response that there was not anything that was specifically
making him leave but he could see that things were going to get much

harder.

140. In terms of my understanding from June 2018, neither I nor the NFSP
had any involvement in the GLO proceedings, although we were aware of it
taking place. However, when the case was running my team and I did follow
Nick Wallis’ live blog on the court proceedings which was very helpful and
enlightening. As such I researched what documents that NFSP had in
relation to the whole issue such as the Second Sight reports. It was through
this that I learned Sir Alan Bates had been corresponding with the former
General Secretary, Colin Baker and also Stephen Timms, the former Postal
Affairs Minister about his situation (NFSP00001058). It is in the reply from
Stephen Timms to Sir Alan’s MP Betty Williams where the “arms length”
position of Government in Post Office matters was described. Also, in the
reply there is personal handwriting that states “I am trying to find out what the
dispute is here.” I have not been able to find any evidence to say who the
Minister asked in 2003 and what, if anything, he found out. However, I do
wonder if the Government had taken a different view at that time, could this

situation have been prevented?

141. After the Common Issues judgement, I met with Lord Arbuthnot in July
2019 and am grateful for his time and hospitality within Westminster and the
helpful way in which he explained the events of the Horizon scandal. This

provided me with a different view to what I had heard within the Post Office

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world, which was “that there were no systemic issues” or that “Horizon was

robust”.

142. In my role as the new Chief Executive of the NFSP I felt it was
important to show I was not anti the GLO in the way that George Thomson
had been. I therefore attended the first day of the trial. I remember being on
my own in the court reception area and saw Sir Alan came out of the court. I
wanted to go and introduce myself, shake his hand and thank him for his

courage but unfortunately, there was not the opportunity in that brief moment.

143. lam asked to consider NFSP00000707 (Email from Calum
Greenhow To: Keith Richards, Sharon Merryweather, Lynda Willoughby

re FW: RE: Branch Refresh).

144. lam asked to comment on the following extract from my email
dated 24 April 2018: “Add to this that there have now been 4 system
faults over the last month, which have caused nationwide access
problems thus I am concerned that we are handing Freeths a stronger
case to bring to court in November as “the present is a guide to the

past” is a strong argument.”

145. In order to understand this comment, at the time I was dealing with a
rollout of updated hardware and software of Horizon. As we know now, it was
only through the court proceedings of later in 2018/2019, that Post Office
finally admitted that there were known bugs, errors and defects in the
Horizon system and that remote access was possible. At this point in April
2018, Post Office were still maintaining the robustness of the Horizon
system. Now, during the rollout of this new HNG-A hardware, there were

Postmasters who were having very major issues with it, including occasions

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where the network had gone down. This was causing significant frustration,
resulting in Postmasters being unable to trade and therefore generate an

income.

146. What I was trying to do here in saying those words was to push Post
Office to do better and be more understanding about how these issues were
impacting Postmasters. Therefore, I have to say, I was using the events in
the GLO to make Post Office sit up and listen for the betterment of the
affected Postmasters. I was saying to the Post Office “do something” or they
would be ending up with this new issue becoming part of the court case. I
was trying to get them to sit up and take notice or they would have to face

the consequences of not doing so.

147. lam also asked to comment on the following extract from my
email dated 24 April 2018: “I believe also that it is important for both the
Post Office and NFSP to work together to restore confidence in the
computer system agents use as matter of course. The retail world is a
difficult place at present with competition rife and therefore it is
important for the business to keep its agents very much on side for it to
maintain its network size as well as grow and thrive within a

challenging market place.”

148. In 2013, Postmasters total income was £478m. If we take inflation into
account from April 2013, that income would be worth £648m at March 2024.
However, Postmasters’ income to March 2024 was £398m, some £250m of a
difference. That's the equivalent of nearly £22,000 per office. In 2005,
income to Post Office Ltd for Government services was £576m. By 2010, that
had declined to £167m. Today it is around £30m. In the financial year ending

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March 2024, my own office earned just £113 from Government services.
That is how the impact of decisions within Government and Post Office are

affecting my Postmaster colleagues today.

149. When I took over my role, I recognised that the relationship between
the Postmasters and Post Office was broken. Culturally, Post Office
considered themselves to be the dominant party within the relationship. I was
and remain hopeful of repairing that relationship and ensuring it is one of
equal partners. Central to that relationship is Postmasters confidence in the
computer system we use. That confidence was being eroded due to the
events surrounding the GLO and specifically in April 2018, due the
hardware/software issues I have described above which Postmasters were
experiencing. It was these issues that I was highlighting to Post Office in my

email to Rob Houghton who was the Post Office’s Chief Information Officer.

150. It is my role to bring the concerns of Postmasters to those within the
Post Office to work with them to identify and implement solutions. As
Postmasters income is variable depending on the number of transactions, if
Horizon is not working or a product is not available, that has an immediate
and direct impact on their income. I have to remind Post Office employees
that whether Horizon is working, or a product is available or not, has no
impact on their earnings. Therefore, I was trying to motivate Post Office to go
that extra mile in support of Postmasters.

151. lam asked to consider NFSP00000710 (Email form Jon Follenfant
to The Subpostmaster, Jim Nott, Kevin Whitlock and others RE: Articles

for the Magazine).

152. lam asked to explain why the NFSP adopted the approach as

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discussed in this email chain dated 14 November 2018 regarding the
extent to which the GLO proceedings would be reported on in the

Subpostmaster magazine.

153. Simply put, those of us in the email chain were not a party in the court
case. Nor were we privy to the detail of the information that the court would
be considering over a fairly lengthy period. However, I had faith (I am sure
the others in the email chain felt the same) in the due legal process and that
it was for Fraser LJ, who had the authority to compel the Post Office and the
claimants to lay all evidence before him to enable him, to come to a
conclusion. I felt it was not for the NFSP, at that time, to be making any
comments other than presenting the facts to the network via The
Subpostmaster magazine. In the BSC entitled Letter from Calum Greenhow
to Colleague re Group Litigation Bates v Post Office, (NFSP00000870) I was
saying there are important issues affecting those in the GLO group and that
the full legal process should take place without interference from the NFSP

and we would comment after the judgement.

154. lam asked to consider NFSP00000779 (Email chain from Lynne
Eccles RE: NFSP piece), in particular the following extract from Lynn
Eccles’ email dated 16 November 2018 : “Nick will criticise us for hiding
behind court process but given that we are no longer firmly coming
down on one side or the other I think that’s the best we can do for

now.”

155. lam asked to explain why the NFSP’s position was that they were
“no longer firmly coming down on one side or the other” during the
GLO proceedings. Where the NFSP’s position changed on this point

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over time, I am asked to provide details.

156. It is clear what George Thomson's view on Horizon was and the way
in which he led the organisation. However, I hope the Inquiry accepts that my
view and actions have been different. I believe that my approach to
managing the NFSP, which is more collaborative and encouraging of
different views, allowed my colleagues at the NFSP and our members
express a core belief that Post Office may well be in the wrong here. This
was due the number of people involved, as per my email to George Thomson
in August 2015 and our experience of Post Office’s fervent cultural stance

which historically has been detrimental to Postmasters.

157. Therefore, Lynn was rightly expressing a different stance on the court
proceedings. This view is explained further in our later email to Nick Wallis
(Email chain from Peter Hall to Nick Wallis RE:Book, NFSP00000777) in
which we say that the NFSP, under new management, felt it appropriate to

observe and make decisions based on the outcome of the GLO.

158. lam asked to consider NFSP00000774 (Email from Calum
Greenhow to Calum Greenhow re: FW: Press and other enquiries RE
Post Office trial), in particular the following extract from Peter Hall’s
email dated 21 March 2019: “... where the judgement has found issues
with Post Office Ltd’s approach to dealing with subpostmasters where
a shortage has been identified — the NFSP has challenged PO on many
of these same issues in the past. Broadly speaking, we wouldn’t

necessarily disagree with many of the criticisms levelled at PO.”

159. lam asked to provide an account of the occasions where the

NFSP challenged POL on their approach to dealing with SPMs where a

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shortage had been identified.

160. In his email, Peter was referring to Fraser LJ’s reference in his Horizon
Issues Judgment of December 2019 (UKGI00018137), at paragraph 232
where he said “and the NFSP had privately expressed its concern to the Post
Office about Horizon.” Examples of those concerns can be seen in the
Marilyn Stoddart emails discussed earlier.

161. One example of the work which the NFSP has done to challenge the
Post Office when they have held members liable for shortages relates to
what is known as the Green Girocheques issue.

162. An outline of this issue can be seen in the NFSP Report to Calum
Greenhow on Girocheques Issue by Andrew Gilhooly (former National
President and NED for Scotland of the NFSP) (undated) (WITN00370101).
This outlines how in around — 2005/2006 the Post Office was holding
Postmasters liable for the losses arising from accepting cheques that were
excellent forgeries and could only be identified as forgeries by the DHSS by
checking their serial numbers. The NFSP argued that the losses being
experienced by the Postmasters were due to them unknowingly accepting
fraudulent cheques which were part of organised crime. Therefore, the
Postmasters should not have been held liable. The Executive Council took
advice from Counsel and solicitors, who considered that the NFSP had an
excellent case against the Post Office’s position. It is understood that at the
time, George Thomson advised the Post Office that the NFSP was intending
to take legal action. The Post Office conceded that Postmasters were not
liable for such losses two days later. The Post Office then set up a board to

scrutinise the counterfeit cheques and 95% of Postmasters (i.e. those who

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met the security regulations for encashment) received a refund of funds that
Post Office had recovered from them in relation to these losses.

163. The Girocheques issue showed that there were occasions when data
was being fed up through the branch network chain that was consistent
across a range of sub-post offices and appeared to be about organised
crime. As a result of that the NFSP at the time were able to collate data from
a number of sub-post offices and challenge the Post Office on the basis of
this data. It also shows that Post Office were not willing to negotiate until
threatened with legal action. It is an example of an issue where the NFSP
was able to take a collective position based on the consistency of evidence
coming through from branches which showed the same thing was happening
in different offices in different places.

164. Itis a real regret that a consistency of issues and reports from
branches were not coming through about Horizon in the way in which an
organised crime issue such as the Green Girocheques was. I understand
from what I have seen and heard at the Inquiry that due to George
Thomson's consistent position on: (i) the requirement for; and (ii) the entire
network's reliance on Horizon that he did not put information coming through
to him, such as the letter from Lee Castleton in 2009 (NFSP00000888) and

the email from Alan Bates in 2012 (POL00296010), in the same category.

165. The NFSP has supplied hundreds of documents to the Inquiry showing
how we supported members across a myriad of issues, throughout the
relevant time period, and further examples of these have been provided
elsewhere in this statement, including where I provide an overview of the

methods the NFSP adopted to represent its members’ interests between

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2000 and 2019 above.
166. I am asked to consider:

a) NFSP00000558 (NFSP council meeting minutes dated 25 and 26

March 2019);

b) NFSP00000712 (the email dated 15 March 2019); NFSP00000774

(the email exchange date 21 March 2019).

167. lam asked to describe the NFSP’s response to the criticisms
raised in the Common Issues Judgment (POL00113269) in respect of

the NFSP.

168. Not being legally trained, nor having any experience of such
circumstances before nor having been involved in the court case, we were
surprised to feature so prominently in Fraser LJ’s ruling. It is also an
important factor for us that the ruling was being used to attack the NFSP, and
to undermine and cause division within the network. Therefore, at the
immediate time of the judgement being issued, the NFSP felt it was
necessary to make a statement on what had been said about it. On reflection
I can see that this was a knee-jerk reaction. Once I'd had time to read and
understand the full impact of the judgement and the effect of what the Post
Office had done and how the GLO members had suffered, I began to take
steps to acknowledge the NFSP'’s failures. I initiated the efforts to make
changes to the GFA (described later in this witness statement), to reach out
to others to better understand the situation, such as Lord Arbuthnot, and to
engage with the efforts which had begun regarding redress (also described

later in this witness statement).

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169. One matter which remained outstanding for us, however, is in
paragraph 589 of the judgement where Fraser LJ comments that he found
“behaviour highly suspicious” about changes which were made to our
website and where the GFA could be found (POL00113269). If we had been
asked, we could have easily explained the reason for the changes. As part of
the process of improving the NFSP, we were working on our Mission, Vision
and Values statements along with the tone of voice and the look and feel of
our website. As part of that, our Communications Director was making those
changes and had taken the GFA down from the website, as her plans were
for there to be a specific location for it because it was felt that the “About Us”
section was not the right location. As she was doing this work and while
following Nick Wallis’ blog, she realised that the court proceedings began
discussing the GFA so she felt it would be important to put it back on the
website in case anyone following the case went to look for it. I can confirm
that there was no attempt to act in a suspicious manner. The reason no-one
from the Post Office could answer the court's questions was because these
changes were being made on our website which was independent of the
Post Office.

170. I am asked to consider:

a) NFSP00001387 (Email chain from Calum Greenhow to Calum
Greenhow RE: FW: Revised column - Column for April magazine
NFSP); and

b) NFSP00001234 (Email from Sharon Merryweather to Douglas
Kemp and Calum Greenhow - Re: FW: Message Via Contact
Form on Website).

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171. lam asked to what extent did the NFSP provide support to SPMs
(both those who were a party to the GLO proceedings or otherwise)
who had experienced a historic shortfall which may have been due to
the Horizon System, following the handing down of the Common Issues

Judgment.

172. The NFSP is not aware of all of the individuals who were involved in
the GLO. However, via the Subpostmaster magazine, newsletters, radio and
TV interviews, I and my colleagues have promoted the Historical Shortfall
Schemes and support a number of Postmasters who have come forward for
help. To date, between the original historical shortfall scheme and the late

claimants scheme, 650 Postmasters have sought the help of the NFSP.

173. We have met regularly with Simon Racaldin of the Post Office to
encourage as broad and as swift a response as possible. We keep a central
register of who we have supported. The NFSP has met with Government

Ministers and civil servants urging broad and swift redress.

174. We have publicly supported and called for the victims to have their
convictions quashed so that the unjust stain is removed. When there was the
change of law announced this year that initially excluded those in Northern
Ireland and Scotland we wrote to the Justice Minister and Attorney General
of Northern Ireland, who very graciously met with the NFSP in support of
changes in the English & Wales legislation to enable victims in Northern
Ireland to be included. Despite several attempts to meet with the Justice
Minister and Lord Advocate in Scotland, we have not yet been offered the
same opportunity. However, we do note the Post Office (Horizon System)

Offences (Scotland) Act which came into law in June 2024.

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175. In relation to Mr Kemp (see NFSP00001234), as this was before the
Historical Shortfall Scheme had been established, we directed him to Freeths
who were the solicitors we knew were involved in the GLO and therefore had

the background to help him.

176. 1am asked to comment on NFSP00000715 (Email from Peter Hall
to Calum Greenhow. RE: Elephant in the room section of the magazine
article on your conference speech), in particular the following extract
from Peter Hall’s email dated 1 May 2019: “Calum stated that Justice
Fraser allowed the court to be embroiled in a conspiracy theory
perpetrated by those who seek to occupy the space the NFSP does as

the representative body for subpostmasters.”

177. I've described above the issue of the way in which the GFA on the
NFSP’s website was described in the judgement. The ruling says that in
relation to the moving of the GFA on the website, the second sentence on
the website (i.e. the wording about where people could find information about
how the NFSP was established as a trade association and linking to the
GFA) must have been added to bolster the Post Officer's position regarding
transparency (see the Common Issues Judgment at paragraph 594,
POL00113269). It is the way in which others with an interest in undermining
the NFSP have used this part of the ruling. In truth, what took place was
innocuous and wholly unrelated to the Post Office. It was this which caused
me to make the comments recorded by Peter. Through the Inquiry, I do wish
to clarify and confirm that the NFSP did not make any changes to its website

to bolster the position of the Post Office.

178. Itis clear, however, that the full wording of the email shows that my

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focus was not primarily on the reputation of the NFSP but on the needs of
Postmasters through the creation of the Legal & Regulatory role with the
purpose of challenging Post Office to ensure that nothing like the Horizon

scandal could happen again.

179. lam asked to consider POL00393126 (Email from Calum
Greenhow to Mark R Davies RE: Support to Sustain our Post Office)
and UKGI00017689 (Email from Joshua Scott (UKGI) to Tom Cooper,

Tom Aldred, Oluwatosin Adegun and others Re: POL Biweekly Comms

Catch up).
180. lam asked to describe my working relationship with Mark Davies.
181. Mark Davies and I met occasionally, rather than regularly. Therefore, I

cannot comment on the extent of our relationship other than I found him

professional when we met.

182. lam asked to explain why POL was kept informed in relation to

the NFSP’s media statements.

183. Postmasters as investors in the business see themselves as de facto
business partners of Post Office. In general, they do not want a bone-on-
bone adversarial relationship with the business. We need to work together
with Post Office to drive improvements and encourage growth in our

remuneration.

184. When it comes to communications either internally or externally, the
relationship is and should be two-way. Post Office informs the NFSP on what
they will be putting out and the NFSP informs Post Office what we will be

putting out. Sometimes, it will be similar, whilst other times it will be from a

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different perspective.

185. Given the importance of the Horizon judgement, I considered it was

part of that relationship to inform Post Office what we intended to release.

186. lam asked to consider: POL00291032 (the email exchange dated
18 December 2019); POL00291026 (NFSP’s draft statement on the
Horizon Issues Judgment); NFSP00000292 (NFSP’s statement on the
Horizon Issues Judgment); NFSP00001321 (the email exchange dated

20 December 2019).
187. lam asked to describe my working relationship with Nick Beal.

188. Mr Beal was the liaison contact between Post Office and the NFSP
therefore we would talk or meet on a fairly regular basis to cover a wide
range of issues pertinent to Postmasters such as remuneration or network
changes etc. In my view it was professional throughout. Mr Beal moved in

2021 to become involved with the Horizon replacement, NBit.

189. lam asked to explain why POL was asked to comment on the

NFSP’s draft correspondence with SPMs.

190. I am unable to recall the reasons why I was informing Post Office about
our statement on the GLO verdict. However, I think it was simply part of the
relationship I have described above in providing Post Office with notice as to
what the NFSP were going to say and also how we felt about the whole
situation. The tone and content of my email to Nick Beal and Patrick Bourke
makes my view point very clear, in that I believed that Post Office had

mislead the NFSP in relation to Horizon.

191. I am aware that the Post Office sent us a copy of their response to the

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GLO verdict to the NFSP on the 16'" of December 2019 (see Email from Nick
Beal to Calum Greenhow, Peter Hall re: Media statement - concerning Post

Office Response to Group Litigation Judgment, NFSP00000718).

192. From memory, I have no recollection being informed of the content of
Melanie Corfield’s email. To my knowledge, she is not someone I know or

have dealt with.

193. 1am asked to provide an overview of the comments provided by
POL (if any) in respect of the NFSP’s draft statement on the Horizon
Issues Judgment and describe the extent to which POL’s comments
influenced the final version of the NFSP statement which was circulated

to SPMs.

194. The statement was drafted by the NFSP and sent to the Post Office in
terms of the relationship I have described above. The draft NFSP statement
reflected that the Post Office prided itself on being the UK’s most trusted
brand, but the three trials exposed the reality of their culture and attitude
towards Postmasters, assistants and Crown office employees. Given Post
Office had always maintained to the NFSP that the system was robust, and
that remote access was not possible, the three verdicts showed that Post
Office had misled everyone, including the NFSP, on these important points.
The NFSP also wanted to draw attention to the need for the relationship
between Postmasters and the Post Office to be repaired. Having reflected on
the draft, the tone was adjusted in the final version as issued, to provide a

more pragmatic and considered view rather than a reactive one.

195. In relation to the emails between Melanie Corfield and Patrick Bourke, I

was not aware of those emails or what was said in them, and I have no

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recollection of anybody from the Post Office ever bringing these issues to my
attention. Therefore, I do not believe that they affected the tone or content of

the statement that was issued.

196. In relation to the Email from Amanda Cox to Mr Andrew B Summers cc,
Calum Greenhow RE: Horizon trial judgement FAD: 200647 Post Office:
Orleton PO, NFSP00001321, Mr Summers emailed the NFSP on the 20th of
December, 2019 asking why the NFSP was directing Postmasters to the
Complex Case Team in the Branch Secretaries Circular. I replied to explain
why. The NFSP is a small organisation dealing with many issues affecting
Postmasters, not just the outcome of the GLO. As Post Office, under the
auspices of Government, had set up a specific team, it was right for us to
make it clear where past and present members could go for help. If they had
issues, they could always come to the NFSP for additional support, as many

have (as discussed later in this statement).

THE GRANT FRAMEWORK AGREEMENT.

197. 1am asked to consider:

a) NFSP00001079 (a note from a meeting about the Grant

Framework Agreement);

b) NFSP00000766 (the email exchange requesting legal advice

dated 15 November 2016);

c) NFSP00001390 (the email which contains a note from a meeting

with legal advisors dated 24 November 2016);

d) NFSP00000727 (the email exchange requesting legal advice

dated 19 December 2016);

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e) NFSP00000534 (NFSP council meeting minutes dated 19 and 20

June 2017 - in particular page 12);

f) POL00027276 (POL Group Executive Agenda dated 14

September 2017 - in particular pages 39 to 44);
g) NFSP00000710 (the email exchange dated 14 November 2018).

198. lam asked to explain what the Grant Framework Agreement was

and how it operated in practice.

199. As a result of the delisting of the NFSP as a trade union due to the
decision of the Certification Officer (Letter (with enclosure) from David Taylor
to G Thomson re: Trade Union and Labour Relations (Consolidation) Act
1992, Removal of Nation Federation of Sub-Postmasters from the list of
trade unions, NFSP00001464), the NFSP in consultation with its members
looked at what options were available to it. These included a merger with the
CWU, a merger with the National Federation of Retail Newsagents or the
Memorandum of Understanding (MOU)/Grant Framework Agreement (GFA)
with the Post Office. A two-day Special Conference took place in June 2015,
where members of the NFSP voted for the MOU/GFA rather than a merger
with either the CWU or the NFRN. At every level of the NFSP; Branch and
Regional as well as National, the members voted for the MOU/GFA (see
Transcript of the Special Conference, NFSP00000957). I discuss how I was

mandated to vote by my Branch members earlier in my statement.

200. The Grant Framework Agreement (NFSP00000758) is an agreement
between the NFSP and Post Office to provide funding from the Post Office to

enable the NFSP to offer support to Postmasters. It was designed so that this

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support was free at point of use to all Postmasters.

201. The NFSP is provided with an Annual Grant for £1.5m inclusive of VAT
to cover the general provision of negotiating with Post Office aspects relating
to Postmasters as described in clause 1.3 of a Postmaster’s contract (see,
for example the contract for Mains Offices, POL00003870), which says the
NFSP is the only body which Post Office Limited will seek to discuss and
consult on matters affecting operators subject to any legal, regulatory or
political obligations. We also represent Postmasters if there has been a
perceived breach of contract. Added, we challenge, review and comment on
Post Office policies on behalf and for the benefit of Postmasters. The Annual
Grant is there to provide welfare and support to Postmasters in relation to the
entirety of the Postmasters business. The Annual Grant also provides an
honorarium to Regional Secretaries (£1200), Regional Treasurers (£1200)
and Branch Secretaries (£600) to offer help and support to Postmasters
within the Regions and Branches. Costs for meetings are also covered, along
with travel expenses, hotel accommodation and substitution cost for those

members attending our Annual Conference.

202. In addition, there is £1m available to the NFSP to provide project
specific help and support. We have utilised this funding to provide Mail
Segregation support that has returned £16.1m for Postmasters at a project
specific cost of £3.2m since 2017. That is for every £1 spent, Postmasters

have received £5.
203. Rightly, the NFSP prepares an annual plan or project specific plan

detailing how the funds will be used in the year or over the length of the

project. Understandably, Post Office check that the NFSP are using the

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funds as intended.

204. lam asked to explain the extent to which (if any) the restrictions
on the NFSP under the terms of the Grant Framework Agreement
impacted the support and/or representation provided to SPMs by the

NFSP.

205. There are two specific areas of the Grant Framework agreement that
are an issue. They are clause 5.3, which has a broad range of restrictions
regarding the activities of the NFSP. For example, under the GFA the NFSP-
could not undertake any public activity which may prevent Post Office from
implementing any of its initiatives, policies or strategies. In the event of the
NFSP carrying out activities contained within 5.3, then Post Office could
invoke aspects of clause 17 — Withholding, Suspending and Repayment of

Grant via event clawback.

206. I cannot comment completely on the GFA as I was not involved in the
discussions that led to the GFA. Due to the timing of the GFA being in 2015,
I don’t believe the GFA and the restrictions in clause 5.3 cover the majority of
the time period the Inquiry is considering as the GFA was not in place until
the vote of the membership in 2015. I do appreciate and understand the
reference made about the GFA by Fraser LJ in the Common Issues
judgement of 2019 (POL00113269), however, that does not appear to cover
the period which the GLO cases were concerned with. While there are
questions as to how George Thomson and the NFSP dealt with the Horizon
issues, the NFSP was a trade union until 2014 and throughout the majority of
the time of the Post Office prosecutions and recoveries. The GFA was not in

place during that time.

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207. Colin Baker’s stance on Horizon in relation to Sir Alan Bates in 2003,
did not have anything to do with the GFA. George Thomson's views in
relation to Lee Castleton in 2009 similarly would not have had anything to do
with the GFA. Having seen the evidence of George Thomson, I do not
believe the GFA restricted his actions in relation to Horizon, not only because
of its timing but because it is clear he believed and still believes that Horizon

was ‘robust’.

208. In terms of the period post-2015 and in respect of the period since I
have been Chief Executive, I do not consider it is the GFA that makes things
difficult for the NFSP in terms of representation of Postmasters. It is the Post
Office and its culture. It is trying to work with the Post Office to engage with
what’s needed on behalf of the members, such as negotiations trying to get
the renumeration necessary for Postmasters to operate. I have used what
Fraser LJ said about the GFA (see the Common Issues Judgment,
POL00113269, at section F) in meetings of the Grant Committee with the
Post Office because I have felt the Post Office are not providing the

necessary funding for Postmasters to run their retail business.

209. I can say from my own position as Chief Executive that the GFA has
not prevented me from publicly criticising, questioning and making
statements about the Post Office, including at this Inquiry, about this Inquiry
and about matters such as Hard to Place, Postmaster remuneration and the
way in which the Post Office does not appear to consider Postmasters as
investors in their business. I recognise that my public criticisms may have an
effect on how the Post Office regard and treat the NFSP by, for instance,

dealing with other organisations and not always including the NFSP in

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discussions. However, I believe it is important to publicly speak out where
the decisions and actions of the Post Office have the potential adverse effect
on Postmasters and their businesses. I discuss the revisions to the GFA
which the NFSP has been promoting and working on since Fraser LJ’s
Common Issues judgement and also the future of the NFSP without a GFA

later in this statement.

210. On reflection, the GFA really comes about because of the decision of
the Certification Officer that the NFSP could not continue as a trade union. If
that had not happened, I do sometimes wonder what the future of the NFSP.
would have been, and for instance, if mutualisation of the Post Office had
happened and the NFSP had then changed to accommodate that type of

business structure.

211. In 2019, as a result of Fraser LU’s Common Issues Judgment
(POL00113269), the NFSP recognised the criticisms of the GFA and what it

said about the relationship between the Post Office and the NFSP.

212. From then, with the help of our solicitors, we have negotiated with Post
Office to revise the GFA to ensure it is less restrictive. This should be signed
shortly, and we will provide this to the Inquiry when available. It has not been
easy. For instance, trying to get the words that the parties would always act
‘in good faith’, even where it was not sought to make that legally binding,
proved impossible to achieve. Some of the changes in the revised GFA
under the annual grant funding purpose of the NFSP include: (i) negotiating
changes to remuneration on behalf of and for the benefit of Postmasters; (ii)
challenging, reviewing and commenting on new or updated Post Office

proposed policies or proposals on behalf of and for the benefit of

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Postmasters; (iii) representing its members including in relation to disputes
with Post Office; (iv) providing welfare and support to Postmasters in each
case in relation to Postmasters, operation of Post Office branches and all
business carried on by Postmasters on their own account from Post Office
branch premises in accordance with their contract for the operation of the

Post Office branch.

213. In the past it was clause 5.3 that everyone pointed to, the updated GFA
removes those restrictive clauses which previously gave the Post Office the
ability to use the GFA to effectively control the activities of the NFSP. One of
the things we couldn’t do was bring legal action against the Post Office and
now we can. I think it also makes it clearer what the core purpose is of the
NFSP is in terms of negotiating, representing, challenging and providing

welfare.

214. The protracted nature of those negotiations (as discussed later in this
statement) shows, in my view, that the “leopard has not changed its spots”
and regardless of who they are negotiating with, the Post Office has to be in

a position of control at all times.

215. The financing of the NFSP is not the real issue, as in the past grants to
undertake specific projects and fund specific roles for those and the provision
of facilities were provided by Post Office. It was the ability for the NFSP to be
free to challenge the Post Office and be able to be the representative body
that Postmasters need which was the issue. The updated GFA should enable
the NFSP to defend the interests of Postmasters within a constructive and
collaborative relationship with Post Office. As described elsewhere in this
witness statement, the NFSP is providing examples of how that relationship

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can develop, change and improve for the benefit of Postmasters.

216. I am asked to consider the NFSP report of a meeting of the

Council held on 19 & 20 June 2017, NFSP00000534,

217. I had been on the Board for about a year in 2017. I don’t recall any
discussions prior to this meeting about the “express instructions” being
referred to. It does show how the Post Office operated the restrictions that
were within the GFA in place at the time, and how those restrictions at the
period from 2015 until Fraser LU’s Common Issues judgement, were
implemented. This is combined with George Thomson, on his evidence, of
being supportive of Horizon and unsupportive of the JFSA and GLO and

therefore not supporting or wanting to be seen to support those groups.

218. lam asked to consider NFSP00000728 (Email from Calum
Greenhow to Calum Greenhow re: FW: Grant Agreement - to be

published on the ‘about us’ page on the website).

219. lam asked to explain why there was a delay between the
execution of the Grant Framework Agreement and the publication of

that document on the NFSP’s website.

220. As this was before my time, I cannot comment specifically on what the
Inquiry is asking for other that it would appear Post Office in December 2016
were in agreement for the GFA to be published. This could be in relation to a
requirement under clause 23 that neither parties (Post Office & NFSP) shall

make public statements without prior written agreement of the other party.

221. I am asked to explain why approval from POL was required before

the Grant Framework Agreement could be published on the NFSP’s

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website.

222. As this was before my time as Chief Executive, I cannot comment on
whether the NFSP specifically required agreement from Post Office to

publish the GFA. This again could be in relation to clause 23.
FINANCIAL REDRESS
223. lam asked to consider:

a) NFSP00000905 (NFSP Branch Secretaries circular dated 11

December 2019);

b) NFSP00000492 (NFSP council meeting minutes dated 16 June

2020);
c) UKGI00030616 (the email exchange dated 2 July 2020);
d) NFSP00000778 (the letter from Nick Read dated 16 July 2020).

224. lam asked to provide an overview of the methods the NFSP
adopted between 2019 and the present date to support SPMs and
represent their interests in relation to compensation and financial
redress for losses suffered as a result of the Horizon IT system. Where

this changed over time, I am asked to provide details.

225. In addition to the documents I have been to consider, I would also refer
to the Letter to Nick Read (Group CEO, POL) from the NFSP re further
compensation of GLO claimants 9 July 2020 (WITN00370105). One of the
methods the NFSP adopted between 2019 and the present date to support
Postmasters and represent their interests in relation to compensation and
financial redress for losses suffered as a result of the Horizon IT system was
writing to Post Office to ask them to include the GLO Claimants in the

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Historic Shortfall Scheme (HSS) and ask Fujitsu to contribute to

compensation.

226. Once the GLO was settled, it came to the NFSP’s attention through
various discussions with UKGI, Post Office etc. that much of the settlement
sum had been used up by legal and other fees, meaning that the actual sum
received by the claimants was not significant. The NFSP felt that this was
unfair, not least because the HSS was only made possible by the GLO. It
seemed unfair that a Postmaster applying to the HSS could be reimbursed to
the full value of their losses, but the GLO Claimants could not apply, having
received a sum less than the amount that Post Office took from them. I
therefore outlined this in a letter to Nick Read dated 9 July 2020
(WITN00370105). The NFSP made continued efforts to ensure the GLO
claimants were included in the HSS, including discussion with the Post
Office, DBT and UKGI, along with communications to members, letters to

ministers, etc.

227. The NFSP has continued to receive queries from Postmasters about
the HSS and are working to ensure that the members can be given the
appropriate legal advice and support in order to ensure their claim is properly

dealt with.

228. The NFSP has helped around 650 Postmasters who have approached
us for help in relation to compensation and financial redress. The original
HSS was open from May 2020 and was set to close in August 2020. The
NFSP was putting pressure on the Post Office to extend that date, and I
believe that others representing claimants and potential claimants would
have been doing the same. In the end, the scheme remained open until

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November 2020. During that time between August and November 2020,
approximately 120 Postmasters approached the NFSP for advice and help in
understanding what the scheme was, how it worked and whether they were
eligible to claim. From the outset of the scheme and following each
individual’s permission, we retained a spreadsheet of every Postmaster who
came to us with details of their claim, so that we could help them if their claim

was stalling.

229. Following closure of this original scheme, many more Postmasters
came forward to the NFSP. They were told by Post Office that they were too
late to make a claim. However, we retained a list of everyone who came to
us for advice. This was extremely useful when, in 2022, the Government
agreed to allow late claims to be processed. Although this was widely
publicised, we were able to contact those that had come to us to advise that
a similar scheme to the HSS was now open to all late claims. Applications
for this new scheme were opened in October 2022 when a new claim form
was produced by the HSS. We were (and still are) able to send the form to
anyone who came to us to check whether they were eligible to claim. In
reference to the new scheme, to date the NFSP have helped approximately
500 different Postmasters, both past and present, to advise on their
individual situation and supply them with an application form to complete and
submit. Follow up advice has been sought by many individuals before
submitting their claim to ensure their application is correct. This advice has
been given to both members and non-members, past Postmasters who have
left the business many years ago, family of those past members and family of

Postmasters who have sadly passed away.

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230. We have also been available for follow up advice when a Postmaster
has had an offer letter from the HSS and is unsure whether to accept it or
not. We will talk them through the options they have to allow them to make
an informed decision themselves as to whether the offer is right for them or
to go back and challenge the amount. However, we will not make that
decision for them. We do offer Postmasters the option of seeking legal

advice on their claim if they would prefer that option.

231. We have also lobbied Government and the Department for Business
and Trade along with its previous iterations for a wider scope of involvement

for those Postmasters impacted and their ability to access redress.

232. We have continued to work on this through to the present day and will
continue to do so. An example of this is that NFSP is able to use its
relationship with the Postal Affairs Minister, other MPs, and key stakeholders
to support Postmasters and represent their interests in relation to
compensation and financial redress for losses suffered as a result of the
Horizon IT system, as well as wider issues. An example of this is the letter
written from the NFSP to Kevin Hollinrake MP on 8 January 2024 in the wake
of the ITV drama Mr Bates vs the Post Office (WITN00370106). This shows
that the NFSP was concerned that it was nearly five years since Fraser LJ’s
Common Issues judgement, but victims had still not received compensation,
and it took the TV drama and its aftermath for the government to take speedy
action on the compensation issue.

233. The NFSP wanted the Government to ensure that there was an
external audit of Horizon with a published report to ensure that Horizon users

of today could have confidence in the Horizon IT system, given that it had

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been nearly five years since Fraser LJ had concluded it was not robust. We
also brought the NFSP’s concerns about the governance of the Post Office to
the Postal Minister's attention. The NFSP has proposed an Oversight
Committee to address this, which is discussed later in this witness statement.
In relation to the monies paid to Post Office by victims, the NFSP called for a
full investigation into debt recovery by the relevant authorities to determine

where this money went.
WHISTLEBLOWING

234. lam asked to describe any practice, policy or procedure adopted
by the NFSP between 2000 and 2019 (inclusive) to enable members or
officials to report wrongdoing in so far as it related to the matters to

which this inquiry relates.

235. There was no formal whistleblowing policy in place for members to use.
It became clear as a result of hearing the evidence of George Thomson at
the Inquiry that this was a gap in our procedures and there was a need to
address how complaints about NFSP officials and senior leaders could be
made and how whistleblowing could be facilitated. These have now been
drafted and will be discussed with the Board at its meeting on 2% September
before being signed off and put onto the NFSP website. This will be provided

to the Inquiry.

236. Prior to the introduction of formal policies for members to use,
members could contact either the General Secretary/Chief Executive Officer
or National President/Chair to raise a concern about an issue that would
affect them or an official of the NFSP. Their concern or complaint could also

be raised with their Branch or Regional Officials including their Executive

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Officer or Non-Executive Director.

237. When the NFSP was a trade union, complaints could also be raised
with the Certification Officer, if members felt that the NFSP had not handled
the complaint correctly or treated it seriously enough. The process of raising
a complaint can be found on the Certification Officers website. There are
examples of where complaints by members about the NFSP were raised with
the Certification Officer and these can be found on the Certification Officer's
website.

238. lam asked to describe any practice, policy or procedure that the
NFSP currently has in place to enable members or officials to report
wrongdoing in so far as it relates to the matters which are relevant to
this inquiry.

239. As discussed above, the NFSP is introducing both a complaints
procedure and whistleblowing policy for members to use. We will submit
those policies to the Inquiry.

CURRENT MATTERS

240. lam asked to provide an overview of the current membership of
the NFSP and the way in which the NFSP represents its members’
interests as at the present day.

241. There are approximately 11,500 sub-post offices across the UK (this
excludes Crown Post Offices). These offices are operated by approximately
7,100 independent Postmasters, some of whom will have more than one

Post Office, and also strategic business partners (e.g. WH Smith). The

NFSP currently has 6,800 individual members who operate around 8,500

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sub-post offices.

242. There has been a forest of issues that have impacted Postmasters
during the period the Inquiry is considering. One such tree within that forest

has been Horizon.

243. Today, Postmasters are extremely concerned about the security of
their investment and their ability to generate a viable income from it. They do

not see their income growing in line with inflation nor their costs.

244. However, reflecting on the whole period of the past, governance of the
Post Office by Government and by the Post Office Board or Royal Mail Board
is where the issue lies. Postmasters have simply not been treated as equals
nor their investment respected. This has to change going forward and this is
why the NFSP is proposing an Oversight Committee, discussed later in this
statement, which would include Government, Post Office, representative
bodies such as Unite, the CWU and NFSP along with consumer champions
such as Citizens Advice, Age UK and Rural Services Network as examples.
The whole point would be a body working alongside the Board ensuring the

social purpose of the Post Office is being maintained.

245. The NFSP represents its members’ interests by regularly writing to
relevant MPs to outline the various issues affecting Postmasters and flagged
to us as concerns by our members. An example of this is the letter to an MP
on 12 December 2022 (see Letter to House of Commons from the NFSP re
Current Network Issues 12 December 2022, WITN00370125) outlining
various issues affecting the network, and therefore Postmasters, together

with the NFSP proposed solutions where available. Key issues include:

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a) Business Rates: The NFSP’s statistical analysis of our member
surveys, renumeration surveys, and monitoring of the calls received
from Postmasters indicate that business rates are a significant issue
for Postmasters, with 70% of our members earning the equivalent of
the National Minimum Wage or less. Feedback from our membership
has shown that this is a significant and ongoing issue for
Postmasters, as whist they are providing a public service, they
cannot afford to make a living. The NFSP had and continues to
consistently flag this as an issue, as shown in various letters written
to minsters such as this one, in DBT Working Group meetings (as
outlined later in my statement), and through other avenues.

b) Relationship with the Post Office: despite Post Office claims that
they are keen to reset the relationship with Postmasters, our
members reported that they did not feel listened to by Post Office in
our membership survey (see NFSP Member Survey Results 2021,
WITN00370113). The NFSP considers that Post Office need to be
more aware of the issues affecting the network on the ground, in

order to rebuild relationships with Postmasters.

c) Hard to Place: the NFSP has written to the Inquiry previously
outlining the issue regarding Hard to Place Offices. After the closure
of the Network Transformation programme in 2018, if a Postmaster
wanted to leave the network but a potential new postmaster cannot
be located, Post Office places them on a Hard to Place register. If a
potential new postmaster is found, the exiting Postmaster will get a

leavers’ payment. However, if a Postmaster has to close their office

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due to ill health, age other reason before a potential new postmaster
is found, they forfeit their leaver's payment. The NFSP considered
that Post Office should pay the exiting Postmaster compensation in
such circumstances. As demonstrated in later letters, whilst 26
months’ compensation was offered initially by Post Office, this is no
longer the case. We are therefore concerned that Postmasters are
either forced to leave the network without a potential new postmaster
in place, forfeiting their investment, or forced to remain open despite
age, ill health, or running a Post Office that is no longer profitable.
Added to the above, Post Office without agreement with the NFSP
has withdrawn any funding that would have been available for any
new PNP who may wish to take over one of the HtP offices and now
expect the incoming PNP to fund £16,000 - £17,000 for a new post
office counter making the proposition less attractive. This may make
it more difficult for those communities to have a full-time, full service

post office provision going forward.

d) Working Group: the NFSP is part of a tripartite Working Group with
Post Office and DBT, which is also a strategy that the NFSP uses to
build relationships with key external stakeholders and represent the
interests of its members. At this point, a key concern was that Post
Office had not provided the NFSP with its future strategy so we can
communicate this to our members. As our members are investors in
the network it is important that they are informed about the Post

Office’s strategy, as this may affect their investment.

246. A more up to date example of the NFSP writing to MPs to inform them

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about the issues affecting Postmasters is the Letter to Gareth Thomas MP
(Minister of State for the Department of Business and Trade) with NFSP.
introductions and outline of key SPM issues 11 July 2024 (WITN00370119).
Recently, Gareth Thomas MP was appointed as the Minister of State in the
Department of Business and Trade. We wrote this letter to him outlining some
of the key issues affecting Postmasters at this time. As above, low
renumeration rates continue to be a considerable concern for members and
cause them financial hardship. As explained in the letter, Postmasters are
continuing on despite this financial hardship, as they are aware of the service
they provide to the community. This is to their own detriment but to the benefit
of the Post Office. The NFSP is calling for an urgent comprehensive
renumeration review to address this. The NFSP continues to ask key
stakeholders to consider and implement its Oversight Committee proposal in
order to address issues with Post Office Governance (as further discussed
later in my statement). As demonstrated in this letter, the NFSP is seeking to
ensure that key stakeholders are aware of the issues reported to us by our
members both through writing to and in seeking to meet and discuss these

issues with them.

247. In relation to MPs, the NFSP now provides members with draft letters for
them to send to their own MPs. The NFSP notes individual constituency MPs
were influential in bringing the Horizon scandal to wider attention, and so has
adopted this as a method by which issues affecting Postmasters are brought
to the attention of a larger number of MPs. The NFSP is therefore using this
as a method to make more MPs aware of issues affecting Postmasters. One

example is the NFSP’s Proposed Draft Letter from Members to their MP re

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renumeration and Horizon Inquiry July 2024 (WITN00370122) where the
issues are Postmaster renumeration and the Horizon Inquiry. Through doing
this they will hopefully engage with the Government as a key stakeholder that
way. Providing such letters may enable members to learn about the issue and
make their concerns regarding issues commonly affecting Postmasters heard

without having to figure out what to do by themselves.

248. The NFSP also used this method as part of our campaign regarding
DVLA, as shown by the NFSP’s Proposed Draft Letter from Members to their
MP re DVLA and other issues July 2023 (WITN00370112). The termination of
the DVLA contract was planned to happen in March 2024. This would have
meant that over 6 million DVLA transactions, and the renumeration associated
with that, would no longer be available to Postmasters. This is part of a larger
pattern of the Government withdrawing face-to-face services, causing a barrier
to people who have issues accessing online services, and decreasing
Postmaster income from Government services to 5% of what it was in 2005.
The NFSP campaigned against the proposed end of the DVLA contract. This
campaign included writing to various MPs, including asking our members to
write to their own MPs as demonstrated by this draft letter circulated to our
members. The NFSP handed over the signed petitions at Downing Street
regarding the campaign and brought along two Postmasters so they could ask
questions and be part of discussions regarding this issue. As a result, the
contract was extended to March 2025, and renumeration in relation to these

transactions was increased.

249. The NFSP’s Written Submission to Business, Energy and Industrial

Strategy Committee re Post Office Network Inquiry 2020 (POL00392930) is

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also an example of how the NFSP supports our members’ interests. The
NFSP brought in the response from the 2019 member survey (which I
discuss later in this witness statement) into these submissions, so that it
could accurately represent what members were concerned about in an
informed way. Again, key issues include renumeration, concerns of
Postmasters that they will have to close their Post Offices, asking for more
services to be provided within branches for them to be sustainable, and
changing the attitude of Government and other stakeholders to Postmasters.
Many of the issues mentioned here have not been rectified, but the NFSP

continues to bring these to stakeholders’ attention.

250. We also represent our members’ interests through the DBT Working
Group. The Working Group is a tripartite meeting between the NFSP, Post
Office and DBT. We use these meetings to discuss high level strategic
issues and raise issues with Post Office and DBT that members have raised
with us, where these fall within the category of high level strategic issues. At
one meeting on 29 March 2023 (see Working Group Minutes between the
Department of Business and Trade, POL and NFSP 29 March 2023,
WITN00370107), we discussed concerns about declining footfall and the
need to diversify services provided at post offices. These are common
themes identified as issues affecting the network by the NFSP in our analysis
of Postmaster concerns. There are occasions upon which we raise an issue
and are told that this is for discussion on different occasions (e.g. in this
meeting, in relation to Tim Boothman, Chair of the NFSP, raising concerns
about the restrictive policies on Postmasters regarding what they can offer in

comparison with other retailers). These are the meeting notes prepared by

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DBT and shared with us after the meeting. These minutes outline the
purpose of the Working Group in looking at high level issues and working

together to identify problems and potential solutions.

251. It should be noted that in these minutes, Martin Roberts, Group Chief
Retail Officer of the Post Office, informed the NFPS and DBT that the Post
Office Board has signed off the joint Grant Framework Agreement between
Post Office and the NFSP. To clarify, the amended Grant Framework
Agreement was not signed by Post Office at this point, and at the point of

writing is still yet to be signed.

252. In advance of the DBT Working Group Meeting on 12 July 2023, the
NFSP asked members what concerns they would like us to raise at the
Working Group meeting via our Facebook group. Responses included that
the Post Office’s non-disclosure of documents and the effect of that on this
Inquiry, were of concern. I therefore raised this as an issue within this
meeting and asked the Government to take a more active role as
shareholder in holding Post Office to account (see Working Group Minutes
between the Department of Business and Trade, POL and NFSP 12 July
2023, WITN00370108). The NFSP and its members are concerned that the
culture of the Post Office has not changed adequately, and therefore we use

meetings such as this to flag this to both Post Office and DBT.

253. Added to the support we are providing today is our Advocacy
Representatives as described earlier in this statement. These trained
individuals are present to support Postmasters where there is a potential
breach of contract that could cause a suspension or termination of the
Postmasters contract. The NFSP have also been calling for a Mediation or

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Arbitration facility.

254. We are currently supporting Postmasters who believe they are victims
of mis-selling by Post Office of the Network Transformation programme and
has led to their financial detriment. At present 262 Postmasters have come
forward on this and we are currently exploring the legal options on this issue
and ultimately it is hoped this can result in full investigation into the activities
of the Post Office during Network Transformation Programme and if this had
a detrimental effect on Postmasters and the financial viability of their

businesses.

255. As mentioned above, another important body of work we have been
supporting Postmasters with is for those who are classed as Hard to Place.
These are Postmasters who had the option to convert to one of the new
models or leave the network under Network Transformation but for whom no
Potential New Postmaster has come forward. In February of 2023, the Post
Office without consultation imposed a change to their existing contract that
was in our view and importantly, the view of the Postmasters, to their
detriment. Post Office announced that these individuals would have their
contracts terminated but only receive 12 months compensation rather than
the 26 months they had been promised. In 2014, Postal Affairs Minister Jo
Swinson MP announced to Parliament that £640m would be available to
complete Network Transformation. Postmasters affected by this rightly asked
where the money had gone. A freedom of information request was submitted
on behalf of the NFSP via our solicitors to both Government and Post Office.
This FOI was refused on grounds of cost and we have therefore been unable

to establish how Post Office spent the £640m. At present, around 30

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Postmasters will exit the business having each lost on average £43,000 in
compensation. When we take into account the age of the individuals and the
health issues some experience and how the Post Office have acted in
respect of this group, we have an understandable question as whether this
has been done in the arbitrary, irrational and capricious manner, of the type
referenced by Fraser LJ in his Common Issues Judgment (POL00113269,

e.g. at para 756).

256. Our understanding is that the decision not to provide 26 months worth
of a leaving payment was made at Board level. We do not know how much
involvement the two Non-Executive Postmaster Directors (NEDs) had in the
decision but I did write to them on behalf of affected Postmasters. Although I
received a holding response from Elliot Jacobs, I did not receive any further
correspondence from either of the Postmaster NEDs (see Emails between
Calum Greenhow and Postmaster NEDs Re_ Hard to Place dated 8

December 2023, WITN00370128).

257. lam asked to summarise the nature and extent of the legal
services or support (if any) that the NFSP provides to its members as at
the present day.

258. As described, above, via the Parliament Hill benefit management
services business, free consultations with a law firm, covering property law,
personal accident and inheritance planning is available to all members.

259. Today, as described earlier in the witness statement, we work
alongside the solicitors of any Postmaster involved in a contractual dispute

with Post Office to enable as sound a defence as possible.

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260. We are aware that through a Postmaster’s own public liability or

business insurance, they may also have access to legal support of various

kinds.

261. As mentioned earlier in the witness statement, the NFSP does not
have and has never had an inhouse legal team or external solicitors
contracted to provide legal services for members in respect of criminal
prosecutions or civil court actions. Today, we would refer members to
appropriate firms of solicitors where they have not been able to obtain cover

through the free legal advice scheme or via their insurers.

262. 1 am asked to provide an overview of the processes by which
SPM’s concerns and grievances are reported, recorded and monitored

by the NFSP as at the present day.

263. As discussed earlier in this witness statement, there are new policies
and procedures coming into place regarding complaints and whistleblowing.

I set out the way in which these issues were dealt with in paragraphs 234 -

237.

264. As discussed earlier in this witness statement, in light of Fraser LU’s
judgment in 2019, the NFSP conducted a review of its structure and
processes, and identified that issues reported by members at a branch level
were not necessarily being escalated, collated and thematically analysed by
HQ. Therefore, if there were trends in issues arising, HQ may not previously

have had an accurate view of these.

265. To address this issue with information flow, the NFSP has put in place

a process by which representatives monitor are report back to HQ regarding

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the issues that are raised with them by members. The NFSP asks all Branch
Secretaries, Regional Secretaries and Regional Non-Executive Directors to
send in information on a weekly basis detailing issues which Postmasters
have raised with them or sought support on. This is collated and we discuss
each case recorded in the month and if there are any patterns or anomalies,
we would take that to Post Office to be discussed. The NFSP’s Public Affairs
Manager collates this information into a spreadsheet such as the NFSP
Public Affairs Manager Spreadsheet with Monthly Overview of SPM issues to
June 2024 (WITN003701 24), which shows what issues are being raised
most frequently, how this changes over time, how the type of office or source
of report correlates with the type of issue reported etc. This spreadsheet is
the Monthly Overview, or Directors Log for this year. This year, the most
common issue that the NFSP has been contacted about is the HSS, however

the number of calls regarding this per month have been decreasing.

266. We then use this data in a presentation to the NFSP Board, for
example NFSP Public Affairs Manager Report to NFSP Board re issues
affecting Postmasters March 2024 (WITN00370109). This is so that the
Board are aware of the common issues being reported by our members. This
also includes information gathered in our renumeration survey of members,
from HR4UK and members survey when these are carried out. The
presentation shows the NFSP’s relationships with key stakeholders and
political efforts, and the different methods the NFSP uses to support
members and how the NFSP is developing and managing relationships with
key stakeholders through meetings, such as discussions about the Oversight

Committee, attending debates, and providing briefing notes to MPs.

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267. Data collected is also reported back to our members through a graphic
in the Subpostmaster Magazine (an example of this has been provided to the
Inquiry — see Subpostmaster Magazine Graphic re results of member survey
April 24, WITN00370123). We think it’s important that Postmasters have an
understanding of the common themes and issues affecting other members
and reported to the NFSP, so they are better informed about these. The
graphic provided to the Inquiry shows that Horizon, Post Office governance
and Network Transformation continue to be issues about which Postmasters
feel strongly. In particular, it is important to note that 99% of Postmasters
responding to our January and February members survey, when asked
“Regarding a change in Post Office governance via the NFSP’s proposed
Oversight Committee, do you agree there is a need for change in PO
governance” answered yes. 98% felt there was a need for a change in

culture of Post Office and the way it deals with Postmasters and the network.

268. Examples of areas we have addressed as a result of the collation of

this information include:

a) Covid — During Covid, the NFSP led from the front during this time of
crisis, hosting Teams meetings 7 days a week providing Postmasters
with the latest information on furloughing staff, Government grants,
social distancing guidelines and access to masks and hand gels.
Thousands of Postmasters joined our Regional and national calls
providing them with updates.

b) Miskeys — this was a problem over long period affecting many
Postmasters which they regularly raised with us. Post Office saw
miskeying as falling into the category of error by the Postmaster in

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terms of the contract. We raised this with the Post Office and pushed
them to add another step into the Horizon process which has
changed the colour of the deposit icon so that there was a clear
differential between that of a withdrawal, which was a common
miskey issue arising. This has saved Postmasters’ significant losses

as a result.

Flip-top Tills — Postmasters regularly raised this issue with us. These
were installed during the Network Transformation programme, when
offices became more open plan. The till was incorporated into the
courter with a secure lid. The flip top till is coming to the end of its life
and Postmasters were being charged a great deal of money for
repairs. We worked to have this changed so that these costs are now

incurred by Post Office.

New Network Locations (White Space) — Despite the majority of
Postmasters having to convert to one of the Mains or Local models,
Post Office then began in 2017, a programme of extending their
network. This placed financial pressure on the neighboring offices.
The NFSP lobbied for a joint panel where these new outlets would be
located and were successful in ensuring that around a third were not
opened as they would have a detrimental impact on a neighboring
office.

Onboard/Offboarding — This is when there is a change in the
Postmaster. For anyone taking on a Post Office, the process is
lengthy and time-consuming with some Potential New Postmasters
deciding against partnering with the Post Office during this process

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f)

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as a result. This team was consistently under resourced. However,
after much lobbying by the NFSP, Post Office have increased the

staff levels and the process seems to be running smoother

Membership Survey — we considered that it was necessary for the
NFSP to survey our members to help inform us about the issues
affecting the members, to ensure that we were aware of and properly
representing members in relation to issues affecting them. We
therefore carried out a previous survey in 2019 (as discussed in the
NFSP Report of Meeting of the Council on 17 and 18 June 2019,
NFSP00000464), and a survey in 2021. 1,001 Postmasters
responded to the latter. The results of this (see NFSP Member
Survey Results 2021, WITN00370113) have informed and been used
in our approach to raising issues with key stakeholders as evidence
of widespread concerns about various issues. In 2019, we found that
22% of Postmasters thought they were going to close/ downsize
within the next year, which dropped to 12% in 2021. Slide 6
demonstrates how Postmasters felt about the issues regarding the
relationship between them and Post Office, and their concerns about
the current reliability of Horizon. The NFSP then took these issues
forward, as shown in the various letters referred to, the Minutes of the
Working Group, and various discussions with key stakeholders. The
NFSP also used this survey to understand what the members want
from the NFSP, so support and representation to our membership

can be better focused and tailored, as shown by slide 15.

g) Annual Conference - The NFSP annual conference is method by

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which the NFSP both informs its members and is informed by its
members. It is an opportunity for members to attend the NFSP
Annual General Meeting, attend exhibitions about relevant matters
and, importantly, ask questions and raise concerns. The NFSP
Conference Programme 11 — 13 May 2024 (WITN00370116) shows
that this year, I, Kevin Hollinrake MP (the Postal Affairs Minister) and
Nick Read (the CEO of POL) were part of a panel discussion at which
they were asked questions from Postmasters. The NFSP considers it
important to provide our members with the opportunity and forum to
ask such questions and get answers directly from high-ranking

members of the NFSP, Post Office and government.

269. lam asked to describe the nature and extent of any support the
NFSP offers to SPMs in relation to (a) raising concerns about the
Horizon IT System or related training and support services, (b) the
conduct of branch audits, (c) investigations into alleged shortfalls in
branch accounts, or (d) civil or criminal proceedings against SPMs
arising from alleged shortfalls in branch accounts, as at the present

day. I am asked how is that support organised by the NFSP.

270. As discussed earlier in this witness statement, we now have the
Advocacy Representatives who have received particular training on
representing Postmasters facing these issues. Also as discussed earlier,
there is the free legal advice service available through the Parliament Hill
benefit management services contract. As mentioned, where there are
criminal prosecutions and/or civil recovery actions, we will refer the affected

Postmaster to solicitors’ firms who may be able to assist or recommend they

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contact their own solicitors. The NFSP does not provide direct or paid for

legal services to members.

271. Additionally, Postmasters can raise issues in relation to Horizon directly
with the NFSP, through their Regional representatives or through our social
media channels. An example of this was in January of 2021 where
Postmasters had issues in relation to the revaluation of their postage stamps
due to the price increase. Postmasters went onto the NFSP social media
groups and highlighted they had an issue. This was picked up by the NFSP,

collated and taken to Post Office for a resolution.

272. The NFSP receives information from Post Office on a monthly basis
under Service & Support. This report provides an anonymised account of the
number of transaction corrections, percentage of offices carrying out their
Overnight Cash Holdings (ONCH) and also how many risk based audits took
place. For example in 2023/2024 there were 340 risk-based audits across
the network with an average discrepancy of £93.3k. However, of those 340,
only 31 came to the NFSP for help via the Advocacy Representatives. My
concern is that the Postmasters who have not come to the NFSP may not be
receiving the help they could, nor do we have full insight into the quality of

these Branch Assurance visits.

273. Where the NFSP is asked for help, our goal is to ensure that Post
Office is respectful, helpful in terms of providing full access to any
information, carries out a full and thorough investigation and is understanding
in terms of any conclusion. In terms of an investigation, Post Office must
answer the three questions of

a) Is it computer error?

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b) Has someone made a mistake and why?

c) Have the funds of the Post Office been used in the manner they are

not intended and by whom?

274. If Post Office cannot answer these questions factually, then the
Postmaster should not be held to account. Some of these cases are very

complex and are being dealt with by the relevant Police authorities.

275. Where there are any criminal prosecutions and civil actions, the NFSP.
will support the Postmaster and their solicitors in the legal defence of the
case by providing information and guidance on how Horizon works or Post
Offices polices and processes. We are aware of four cases that have taken
place where the NFSP has provided support to these Postmasters. One has
concluded with the successful exoneration of the Postmaster in court and

three are ongoing at present.

276. lam asked to describe my working relationship with the current
POL Executive Team and others in POL with whom you have a
relationship. In answering this question, I am asked to set out the
frequency of any meetings and the way in which I consider them to be

approached.

277. I would say the relationship between Post Office and the NFSP is very
strained at this moment. An example of just how the leadership of Post Office
are treating Postmasters, including the NFSP, can be summed up in a recent
meeting on the 29th of May this year. In this meeting was the CEO, the
Deputy CEO, Chief Retail Officer, Chief People Officer and the Chief

Technology Officer, where the NFSP were asking about NBit (Horizon’s

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proposed replacement) and we were provided with an update. However, the
following day Computer Weekly broke the story that NBit was unachievable.
Whilst we knew it was running late and over budget, at no point in the
meeting of the previous day were we told it lacked quality according to
auditors for the Department of Business & Trade or that Post Office had
asked for nearly £1bn in cash to fund the project or that the Infrastructure
and Projects Authority were now involved or that the project had been
brought into the Government Major Projects Portfolio. There is still a
significant lack of transparency and openness. Trust in the senior
management and the Board of Post Office still does not exist from the

Postmaster or the NFSP’s view point.

278. Another example is from earlier this year. In January, the NFSP met
with Postal Affairs Minister Kevin Hollinrake MP and Post Office via the
Department of Business and Trade (DBT) Working Group. At the meeting the
NFSP were putting forward the Oversight Committee as a way of improving
the governance of the Post Office. The Minister asked both the NFSP and
Post Office to go away, discuss and come back with a workable proposal. At
the subsequent meeting which took place in the February, the former Chief
Retail Officer for the Post Office, Martin Roberts, made it very clear in his
opening words that Post Office was not interested in any changes to its
governance structure. I had to remind the former Chief Retail Officer, that as
an employee, it was not their place to go against the wishes of the Minister. I
have to say that discussions about the governance of the Post Office are
now taking place. I do believe that before any decision is made, Postmasters

and employees of Post Office need to be consulted.

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279. However, it is important to note that there are those within Post Office
who do have an open and transparent mindset. We have been greatly
encouraged by those within Branch Technology team. There are others
within the Audit/Branch Assurance teams who are looking to be more
collaborative. We are disappointed that the Security Team has been
renamed as Network Crime & Risk Support Team as it suggests an optical
blindness within Post Office given everything that has occurred it looks like

there is a focus on crime within the network.

280. On a day to day basis, I would engage most with Shaun Kerrison, who
is Head of Post Office Engagement. I would also engage with Tracy Marshall
(Network Development Director) and Martin Edwards (Network Strategy &
Development Director) at least on a monthly basis and ad hoc as required to
deal with matters pertaining to the network and remuneration. I would meet
with Martin Roberts (Chief Retail Officer) on a quarterly basis and Nick Read

(CEO) once or twice a year.

281. At this moment it rather looks like the ship is rudderless. The CEO,
Nick Read, is not dealing with day to day issues as he is concentrating on the
Inquiry, the Deputy CEO, Owen Woodley, is leaving at the end of August, the
Chief Retail Officer, Martin Roberts, has left the business suddenly, the
Group General Counsel, Ben Foat, is absent during a significant legal crisis
for the business, the Chief Financial Officer, Alisdair Cameron, has left the
business with a £1.2m settlement and the previous Chair, Henry Staunton,
was sacked. Added to this, anyone new coming in as part of the leadership
team has the title of “Interim” at this point. Therefore, from a stability and

continuity perspective, it does not look good. Postmasters are rightly

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concerned about the direction of the business and how this may impact the

security of their investment.

282. I am asked to describe the culture of the NFSP and set out your
reflections as to the ways in which the culture has or has not changed
following the findings of Fraser LJ in the Common Issues Judgment

and/or the evidence arising in the Inquiry.

283. The NFSP is made up of two parts. There is the employed staff based
in Shoreham-by-Sea and then there is the membership, which includes the
volunteering Branch & Regional officials. As the Chief Executive, I am
responsible for the workplace culture and the way in which the organisation
treats and deals with its employees. Distinct from the employer/employee
relationship, there is the wider membership of over 6,800 members. While
the NFSP cannot dictate how each individual postmaster behaves, what the
Chief Executive and the Chair of the Board have is a responsibility for is the
culture in the way in which members will be dealt with and the way in which

the NFSP will represent the interests of its members.

284. When I came in as Chief Executive I wanted to change the way in
which the previous leadership had operated. For myself, I wanted to be
more collaborative and operate as a team. I felt it was important to look at

how challenge could be made and dealt with.

285. In seeking to improve the culture of the NFSP for and with its members

from 2018 onwards, we have introduced the following Mission Statement:

a) Our Vision - The collective voice of post office operators offering

members representation, support and solutions to realise the full

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potential of their businesses.

b) Our Mission — to be a membership led organisation, supporting
members to operate post office and retail outlets. We represent their
interests at every level of policy and decision making. We offer an
opportunity to belong to, and take part in, a community working

together for a more successful future.

c) Our Values - Member-focused, Trusted, Knowledgeable, Respectful

and Supportive.
286. Examples of initiatives we have introduced since 2018 include:

a) Culture Committee — At this year’s Annual Conference (see this
year’s Conference Programme, WITN00370116), the NFSP
welcomed Darren Burns from Timpson's who outlined the culture
within the Timpson's Group. One such aspect Timpson's operate is a
Culture Committee of employees to help the management ensure
that Postmasters are treated with respect and that the business is
deemed to be a good place to work. The NFSP has just launched the
recruitment process for our own Culture Committee from within the
network, as seen in the NFSP Newsletter to Members 15 August
2024 (WITN00370111). Any member can apply and the aim will be to
have 10 Regional members of the Committee. Members from within
those Regions will vote for who they want to be the Regional
Representative. Once the Committee is decided, we will sit down and
decide what key areas it will focus on to begin with. We expect an
employee of the NFSP will also be on the Culture Committee so that

there is unity across the whole organisation. I don’t want to be

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prescriptive about what this Culture Committee looks like, or dictate
what it is going to say and do, I want to work with the Committee on

the issues which it determines is its key focus.

Part of last year’s and this year’s annual plan is to link NFSP Board
Directors with Product Directors and Managers within Post Office.
Connected with the NFSP Directors will be a small group of
Postmasters who along with the NED Director work with Post Office
to improve an understanding of how these products actually work on
counter. This brings greater transparency and involvement to the
Postmaster network something the NFSP have advocated for some

time.

We have developed regional WhatsApp groups and a Facebook
page to enable two-way discussions and peer to peer support. There
is now weekly newsletters sent to over 4000 members who subscribe
to that service. After each Board meeting, I hold a national call to
update Postmasters on what is discussed so that they can feed in
their thoughts and ask questions. Each month, we conduct a
remuneration survey and ask Postmasters for their views on a variety
of topics relevant to the network. The results are fed back to
members via The Subpostmaster magazine or the weekly
newsletters.

Wellbeing Overview — in May 2019 the NFSP signed MIND’s Time to
Change Pledge committing us to focus on the mental health of our
employees and members. As part of this we have regular meetings

with Post Office as the NFSP is trying to work with Post Office (with

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Postmaster input) to try to improve the culture of the wider network,
which includes the Post Office employees. This is to provide
wellbeing support to Postmasters and trying to develop the
relationship with Post Office so that they also are contributing to the
improvement of network culture and are treating Postmasters with
respect. As demonstrated by the NFSP and POL Wellbeing Overview
Spreadsheet 24 July 2024 (WITN00370117), since 2019 the NFSP
through its specially trained personnel have been training and
promoting Mental Health Champions and First Aiders, along with
providing a Mental Health helpline, providing Advocacy
Representation, providing confidential support through HR4UK and
other initiatives to assist employees and Postmasters with their
wellbeing and provide them with support. We are working with Post
Office to promote World Mental Health Day on Thursday 10 October
this year. The NFSP has worked hard on this particular initiative
because we recognise the pressure of running your own small
business can have, where isolation, financial concerns and

relationships with the Post Office can all take their toll.

287. The NFSP firmly believes that when it comes to any changes or
developments within Post Office that impact the network, Postmasters should
be fully consulted. The difficulty arises because we find the Post Office
cannot bring themselves to lose that level of control over any changes. The
NFSP seeks a protocol that would enable us to engage with the Postmaster
network, explain the change and how that impacts Postmasters, gather the

feedback so as to proactively negotiate with Post Office to ensure that a

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pragmatic consensus can be agreed.

288. lam asked to summarise my understanding of the actions the
NFSP has taken to change the culture of the organisation following the
findings of Fraser LJ and/or the evidence arising in the Inquiry. I am
asked to set out my reflections on how effective these changes have

been.

289. It is difficult to evaluate how effective all these measures have been as
some are fairly new or are at the inception stage. In addition, during the time
I have been in the Chief Executive role, there has been the impact of Covid
and the ongoing efforts in dealing with the Post Office on a day to day basis.
Even where we have or are managing to develop our own culture, it is
difficult having to deal on a day to day basis with an organisation — the Post
Office - whose own culture needs to change, and despite everything that has

come out at this Inquiry, we don’t find any real change in culture to date.

290. In order to develop an understanding of this, as the Inquiry has
progressed, I have encouraged my fellow Board members and my employed
colleagues to attend the Inquiry so that they could experience for themselves
the true implications of what the Inquiry is covering. My hope is that the
experience of what they see, hear and learn will never leave them and
influence positively my desire to change the overall culture of the NFSP so
that the totalitarian culture of the past, does not and cannot exist in the

present or tomorrow.

291. When the BEIS Select Committee that took place in 2020 was looking
into the Horizon issue, I felt it was important for the victims to hear a different

message from the NFSP than before, and so I said sorry to them at that

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Committee. Since then, the NFSP has continued to be public in its apologies
to those victims who did not receive the support they required. We recognise
that improvements need to be made in how Post Office listen to
representative bodies and in a far more open and transparent manner.
However, it is important that all the representative bodies involved, take a

look at themselves as well to see where they need to improve.

292. lam asked does the culture at the NFSP support the building and

maintaining of trust between the NFSP and SPMs?

293. I am asked about the culture of the NFSP in supporting the building
and maintaining of trust between the NFSP and its members. From the
NFSP perspective of today, our main focus is on encouraging unity as there
are serious threats to the viability of the Post Office network looming and if
we are divided, then it will ultimately be to the detriment of Postmasters and
the communities we serve.

294. As discussed earlier in this witness statement, we have set up Regional
WhatsApp groups and a Facebook group to provide peer to peer support.
While we have worked hard on the culture of the organisation and to ensure
the relationship with and for the members, sadly, I am regularly contacted by
Postmasters who tell me that they do not engage with the WhatsApp group
due a toxic or negative environment which has been created by a small
number of members and former members who feel the NFSP has not done
enough for them. There are also examples of some of our Postmaster and
employee colleagues being pursued with relentless requests for evidence,
often when this has been provided and it has become a form of harassment

which causes stress. I understand this type of trolling is termed ‘sealioning’. I

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can understand that there are and will be members who feel that the issues of
their declining income and reduction in value of their investment cause upset
and anger, however, posts which cause the wider membership not to engage
with our social media does have an effect on the culture, as they feel this tone
does not reflect them and they can end up feeling intimated. The NFSP is
working every day on issues of remuneration although this will not always be
enough to keep all of the membership happy all of the time. When we have
tried to ensure that posts are done in a kind and courteous manner and also
during reasonable working hours, there are calls that the NFSP is trying to shut
down freedom of speech. This social media issue is having a mental health
impact on both employees and membership and in my role as Chief Executive
I have a duty to the well-being of the NFSP’s employees, members and
elected/voluntary officials. I am conscious that the NFSP is not the only
organisation facing this kind of social media problem and the effect on well-
being of others who receive, read or are part of WhatsApp groups, for instance,
MPs have faced a huge increase in negative social media and many decided
to stand down at the last election because it was too much for them and their
families.

295. I have been asked separate questions about membership of the NFSP
and these include describing the process by which applications for
membership with the NFSP are assessed, including who is involved in
reviewing any such applications and how a final decision is communicated to
the applicant; the criteria used to assess an application for membership with
the NFSP; where an application is refused what processes exist for the

applicant to appeal such a decision and if such a process does not exist, why

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that is; and have any applications for membership with the NFSP been refused
since the beginning of this calendar year, how many applications have been
refused and the reasons for any such refusals.

296. We have a Membership Officer who processes applications that are
submitted to the NFSP. In terms of new incoming Postmasters to the network,
as mentioned earlier in my statement, these Postmasters are written to by the
NFSP to ask if they wish to join. If they do, then these applications are
processed by the Membership Officer and accepted with a Welcome Pack
being sent out which sets out the membership benefits. There are instances
of Postmasters leaving the network and as a result they are removed from the
membership list. There are also some instances where a Postmaster feels they
no longer wish to be a member of the NFSP and they will communicate this,
rescinding their membership and they are then removed from the membership
roll. On occasion, a member who has left the organisation may later apply to
rejoin.

297. In answering these questions, I have included them in this section about
culture as we have refused one application for membership in this calendar
year and that relates to the issues I have been discussing above. The starting
point for membership assessment is in accordance with Article 8.1 of the
Articles of Association (NFSP00001051) which says that anyone who holds a
contract to operate as a Postmaster may be a member. This means that you
must be a Postmaster to be a member but membership is not compulsory or
automatic if you are one.

298. If there is to be a refusal of membership that is done under Article 9.3 of

the Articles of Association which say the Council (the Board) may in its

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reasonable discretion decline to accept any person as a member and need not
provide its reasons for doing so. There is no process of appeal for an applicant
whose application is refused under Article 9.3. This is because there is nothing
in the Articles of Association which allows for this.

299. In this calendar year, one application was refused. This is the only
application I am aware of being refused since I came into post as Chief
Executive. This application came from someone who had previously been a
member of the NFSP. I have highlighted above the behaviour of some on
social media, whether by members or former members, and the mental health
impact of that on our employees and Postmaster members. Based on the
application of a former member, the Board took the difficult decision as per
Article 9.3 to refuse the application. By way of example, the administrator of
the relevant Facebook group and also one of our employed officials contacted
me about the impact some social media posts had had on them, feeling they
could not look at posts due to that impact. The application which came used
what we understand to be pseudonym, in other words not the actual full name
of the applicant. The Board, taking this kind of information into account and
taking account of its duty of care to existing employees and members, made
the very difficult decision to refuse membership (see Email from Lisa
Harmsworth to Calum Greenhow re denied membership request dated 13

March 2024, WITN00370127).

300. In terms of other matters relating to the effect of cultural change, with
the plans we have in place in linking NFSP Directors with groups of
Postmasters, promoting specialisation in product areas and engaging with

Product Directors of Post Office, we believe this will enable more

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Postmasters to understand the challenges and complexities of running a
business the size of the Post Office. Importantly, it will enable Postmasters

thinking to be involved at every level within Post Office.

301. Later in this witness statement I discuss the NFSP’s proposal for an
Oversight Committee which brings Government, Post Office and consumer
champions together we can work collectively together for the good of the
business and the communities we serve. We believe such an Oversight
Committee would have a positive effect overall on the culture of the whole

network.

302. 1am asked to summarise my understanding and experience of the
board’s relationship with other key relevant external stakeholders, such
as the CWU, UKGI and the Department for Business and Trade (‘DBT’)

and any way in which this affects the NFSP.

303. The Inquiry is asking about three distinct groups and I will answer in

relation to each below

a) The CWU — The CWU is the recognised representative body of Post
Office employees in Crown offices, Cash Van in Transit, Auditors and
Contracts Managers. This the NFSP respects and is supportive of.
The interests of employees such as those in Crown offices which the
CWU represent are quite different from those of self-employed small
business owners and retail operators who are almost always
employers themselves, and it’s possible for a Postmaster’s
employee/s to be members of the CWU. This inevitably means that
while interests of our two organisations will align on some aspects of

the wider Post Office network, this will not always be the case. The

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NFSP takes the view that where those interests align, we should be
working together for the benefit of our respective members in holding
Post Office to account. This can and should be in a collaborative
manner, such as the 2009 proposal regarding PostBank, rather than
being in opposition to each other and debates on social media over

which organisation is the better one.

UKGI/DBT — Whilst I meet with UKGI on a monthly basis and the
DBT Working Group three times a year, I would prefer a more two-
way discourse, looking at resolving the issues that affect the network.
The “arm's length body” aspect of the past provided Post Office with
the ability to deflect and misinform, and this has to change. This also
has to apply to the Department of Business and Trade. Its way of
working has also allowed politicians to have the “get out” of plausible
deniability and thereby absolve themselves of accountability. From
the Inquiry evidence, we have heard much about behind the scenes
discussions on the Post Office and its network, where decisions are
being made which impact the viability of a post office without proper
input from the Postmaster network. In our view, Government and its
officials need to have at the forefront of their minds that Postmasters
invest their own money into the network to ensure there is a service
available in communities across the country. Without the investment
of Postmasters, there would not be a network as large as it is. At
present, it feels too often like a tick box exercise than a real interest
in aspects that affect Postmasters. There should be agreed protocols

put in place between the NFSP, UKGI and DBT to ensure that the

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owner (Government) and their de facto business partners

(Postmasters) can work collaboratively and constructively.

c) Royal Mail — though not referred to in the question asked of me by
the Inquiry, another key stakeholder that the NFSP has regular
engagement with to support our members and represent their
interests is Royal Mail. The Letter to Simon Thompson (CEO of Royal
Mail) and Keith Williams (Chair of Royal Mail) from NFSP re
renumeration 22 July 2024 (WITN00370118) is an example of this.
This shows how the NFSP is trying to engage with Royal Mail as a
key stakeholder to try to ensure that Postmaster renumerations
(which has been flagged by members consistently as a key issue

affecting Postmasters) do not decrease.

304. This is why the NFSP is proposing the Oversight Committee as it will
be a way for the CWU, Unite, the NFSP, Government, Post Office and
consumer champions to work together to ensure that services of general
public interest (SGPI) are maintained and available in communities across

the country via the Post Office network.

305. My concern is that decades of decisions at Government level and
within Post Office has diminished the network. Of the futures I can see, one
that looms large is another network restructure, where there will be around
4000 outlets that we would recognise as a Post Office and over 20,000 Drop
& Collect outlets. This would save Post Office significantly in terms of license
fees and hardware costs for NBit plus it would reduce the costs in stock and

cash held in branch.

306. lam asked to consider the Times article dated 19 February 2024

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(News article from The Times titled 'Postmasters on Post Office board

‘ignored and unwanted’, RLIT0000201).

307. 1am asked to set out in detail my understanding (if any) of the
matters raised in this article, including the relevant background,
chronology and actions of any individuals involved. I am asked to

describe my working relationship with Elliot Jacobs and Saf Ismail.

308. Sadly, it did not come as a surprise at all that the article describes the
attitude embedded in the Post Office towards Postmasters as one of being
guilty and on the take. What is disturbing though is to find that even after all
this time and the Inquiry hearing so much evidence from the past about the
attitude of investigators, auditors and others within Post Office that this is still
the attitude today. There is also the point raised about the present Chief
Executive describing some employees as being ‘untouchables’, and I have to

wonder what exactly this means.

309. The article describes a feeling of being “ignored and unwanted” or
“seen as an annoyance”. This is in reference to today, not the past. This I
can very much relate to, along with the level of obfuscation there is when you
try to deal with Post Office. What I take from this article and in my
experience, regardless of the Postmaster NEDs being on the Board, it just
feels very much as if Post Office is working to undermine any threat to their
dominance and maintain control rather than truly resetting the relationship
with Postmasters. This is very much what the NFSP has found is the way we
are treated whenever we challenge Post Office.

310. Prior to the Inquiry asking for my witness statement, I had been

reflecting on the last three years that Saf Ismail & Elliot Jacobs have been

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Postmaster Non-Executive Directors on the Post Office Board. Whilst I do
believe we want the same things, the NFSP has a concern there has not
been a proper process put in place for the two Postmaster NED’s and the
NFSP to meet and discuss matters affecting Postmasters. The way in which
this has been set up by Post Office does not feel collaborative. I therefore
placed an official request in June this year to Post Office for that process to

be set up. That is not in place yet.

311. I do have concerns about a current Postmaster being a Non-Executive
Director of the Board due to potential conflicts of interest under the
Companies Act 2006. The Directors of the Post Office Board have a duty to
act in a way they consider, in good faith, would be most likely to promote the
success of the company for the benefit of its members as a whole. However,
Postmaster NEDs will have the same duty in relation to their own companies
and those two interests could conflict, for example, remuneration where I
understand the Postmaster NEDs will register their interest and abstain from
voting.

312. As well as the conflict of interest question, Post Office itself recognises
that the Postmaster NEDs are not independent members of the Board and, if
for example there was to be an increase in the number of Postmaster NEDs
on the Board, then the number of Board members would have to increase in
order for Post Office to comply with their Articles of Association that the
majority of Board members are independent. This was why the NFSP in
October 2020, decided that no existing NFSP Board member should apply to

be a Postmaster NED on the Post Office Board.
313. To be clear, this is not calling into question the integrity of the individual

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Postmaster NEDs, rather it is to highlight the issues that can arise from this
particular decision to create these positions on the Board. These issues also
highlight why the Oversight Committee which we are proposing is, in our

view, the better solution.
314. lam asked to consider:

a) NFSP00000713 (the email requesting legal advice dated 28

March 2019);

b) NFSP00000464 (NFSP council meeting minutes dated 17 and 18

June 2019 - in particular page 26);

c) NFSP00000497 (NFSP council meeting minutes dated 14 and 15

October 2019 - in particular page 19);
d) NFSP00000716 (the email exchange dated 28 November 2019).

315. lam asked to provide an overview of any discussions between
NFSP and POL in relation to proposed amendments to the Grant
Framework Agreement following the handing down of the Common
Issues Judgment. I am asked to provide details of any amendments that
were under consideration and clarify whether any such amendments

have now been implemented.

316. As discussed earlier in my witness statement, the NFSP recognised
that this was an opportunity in light of Fraser LJ’s ruling to seek the removal
of clauses within the Grant Framework Agreement that were preventative in
us helping Postmasters in the ways they needed. We therefore asked our
solicitors to review the GFA and Fraser LJ’s ruling and for their legal advice

on what changes should be made in the light of the ruling.

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317. Post Office provided the NFSP with a note of novation. The legal
advice we received said this did not address the specific clauses which were
raised by Fraser LJ at paras 590 and 596 of the Common Issues Judgment
(POL00113269). These related to clauses 5, 17 and 26. The advice we
received is that the GFA would require significant alteration to comply with
the Common Issues judgement.

318. The amended note of novation (see Draft deed of variation of grant
framework agreement, NFSP00001082) prepared by our solicitors was
presented to the October 2019 NFSP Board and approved prior to it being
sent to Post Office for consideration. It has taken the best part of five years to
get the Post Office to the point of agreeing some of the changes we were
proposing. In December 2019 Nick Beal informed us that the revised
changes proposed by our solicitors was still in the hands of the Post Office
legal team. Almost a year later in November 2020 things had not moved on
and the GFA was still sitting within the Post Office legal team. Thereafter,
things do not appear to move forward until October 2021 when it becomes
clear there is a blockage in the Post Office. From discussion with Shaun
Kerrison in October 2021 he explained to me that Post Office couldn't move
forward with the GFA amendments until both parties had agreed the core
purpose and metrics. The core purpose being negotiate, challenge, represent
and support, as explained earlier in this witness statement. To get Post
Office to agree to this was protracted, as they did not want the NFSP to
support Postmasters in the whole of their business where Post Office
services were being provided. As mentioned earlier, nor were they willing to

have the term “good faith”. We felt, in light of PO’s actions over the GLO, it

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was imperative going forward that in all their dealings with Postmasters, good
faith was central.

319. The issue of good faith was a central tenet of Fraser LJ’s Common
Issues Judgement (POL00113269). It was therefore important that, given the
NFSP is run by Postmasters for Postmasters, the Post Office was willing to
act in good faith when dealing with the NFSP. We proposed that the term
‘good faith’ be placed in the recitals section, but this was also rejected by
Post Office. The reality of the Post Office refusing all attempts to include this
tenet in the GFA gives voice to concerns that, culturally, Post Office has not
changed and that there is an unwillingness by the Post Office to act in good
faith towards the NFSP and therefore our Postmaster members.

320. By August of 2023, we finally reached a place where we could agree
the GFA and so I presented the revised GFA to the Board of the NFSP, who
approved it and confirmed with the Post Office that NFSP were willing to
proceed. The GFA, then slipped into the black hole that the Post Office have
and despite several emails to Tracy Marshall asking where the Post Office
was with it, I did not receive a satisfactory response. Therefore, on March the
15'" this year, I emailed Shaun Kerrison to invoke clause 31 and escalated
the process to try and bring about a finality to the revision of the GFA. As I
write this witness statement, the GFA has not been signed but is about to be.
This is more than 5 years since the Common Issues ruling and a third of the
period that the GFA covers.

321. Although we have now managed to achieve an updated GFA, as
discussed earlier in my witness statement this has taken several years and

there is now only five years of the GFA contract left. The NFSP has

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therefore taken the necessary step, following discussions at Board level and
presentations to the membership, to instruct Grant Thornton to look at the
future of the NFSP beyond the GFA and what possible commercial strategy
alternatives are open to the NFSP, as demonstrated by the Letter of
Engagement between NFSP and Grant Thornton 4 July 2024
(WITN00370120). This is to ensure that the NFSP has the best commercial
strategy possible in order to support its members. The scope of the work
instructed is at Appendix A of this letter. The work commenced on 12 August
2024 and is estimated to take 12 weeks. The views of the Post Office will be
sought as part of this exercise as they are de facto business partners of
Postmasters, however, the views of Post Office are not determinative in this
exercise. It will also be an important part of this process to hold interviews
and discussions with stakeholders, such as Postmasters in order to inform
which options are aligned with their interests.

322. I reflected on all of this, having been present at a John Lewis Council
meeting on July the 4", 2024, I witnessed a Board, Group Executive and
representative body working together for the common good of the business. I
firmly believe that with the right culture present within Post Office, the NFSP
and the Postmasters network, we can have a productive and collaborative

working relationship for the common good of all concerned.
323. I am asked to consider:

a) POL00088885 (the email from POL to the NFSP attaching

internal SPM support policies dated 26 May 2021);

b) POL00088886 (POL internal SPM support policy - Post Office
Audit Opening Script); POL00088887 (POL internal SPM support

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policy — A Short Guide to the Audit Reporting Tool);

c) POL00088888 (POL internal SPM support policy — Audit Closing
Script);

d) POL00088889 (POL internal SPM support policy — Postmaster
Contract Suspension Policy);

e) POL00088890 (POL internal SPM support policy — Postmaster
Contract Termination Policy);

f) POL00088892 (POL internal SPM support policy — Postmaster
Termination Decision Review Policy);

g) POL00088893 (POL internal SPM support policy — Network
Monitoring and Audit Support Policy);

h) POL00088894 (POL internal SPM support policy — Postmaster
Account Support Policy);

i) POL00088895 (POL internal SPM support policy — Postmaster
Contract Performance Policy);

j) POL00088891 (POL guidance for SPMs - Postmaster Guide to
Policies);

k) POL00088896 (POL responses to NFSP questions on SPM
support policies).

324. lam asked to provide an overview of any further discussions

between the NFSP and POL about POL’s internal SPM support policies.

325. These polices are a huge step in the right direction as this was not in

place prior to the court case. The Audit Reporting Tool (ART) and the Audit

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Rational Document (ARD) are very important documents that Post Office will

make available on request. This is something they would not do in the past.

326. However, we have raised concerns about the Audit Reporting Script,
we did suggest an alternative script which the Postmaster or OIC would be
required to sign with a copy retained by the Postmaster. Part of the opening
script informed the Postmaster or OIC, that the NFSP was available for help
and support. Additionally, we suggested a checklist for the Postmaster and
OIC to follow given the potential stressful situation that may be being dealt
with. This would enable notes to be taken for reflection afterwards. Sadly,

this was rejected by the Post Office on a number of occasions.

327. In relation the termination policy, we raised our concerns about the
Decision Review Panel as we were concerned that Post Office were bringing
current or former Postmasters into a position where they were deciding on
the potential future of their colleague or former colleague. This we felt was
potentially placing these individuals in a place of undue accountability.
Added, the panel would consist of 2 senior Post Office employees, a non-
voting Chair (also a Post Office employee) and one Postmaster, where the
majority decision would take precedence. We felt that it was unlikely that two
senior Post Office employees would go against the decision of another Post
Office employee. The view of the NFSP is that a proper mediation process
via CEDR or ACAS should be used in such circumstances where Post Office
bring their evidence and rationale and the Postmaster has the opportunity to
offer their defence, without Post Office acting as judge, jury and executioner,

in other words, Post Office having complete control over the situation.

328. lam asked to set out any other comments, reflections or concerns

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(if any) I may have about POL’s internal SPM support policies.

329. To Post Office’s credit, they are now providing these documents on an
annual basis for the NFSP to review. These are checked with our HR
specialist legal team and responded to. Whilst Post Office have not always
taken on board every point we have made, they are discussed. Added, the
ownership of these documents is at a very high level within Post Office and
sits under the Audit & Risk Committee. As to whether there is a Key

Performance Indicator, this is not known by the NFSP.

GENERAL

330. lam asked to set out my reflections on the extent to which the
support and representation available to SPMs alleged to be responsible
for shortfalls shown by the Horizon IT System was adequate or

inadequate between 2000 and 2019 (inclusive).

331. In terms of reflection, I can say that I and the NFSP’s current
leadership have no doubt that more could and should have been done to
challenge the Post Office privately and in public and to prevent affected
Postmaster from falling victim to this extended miscarriage of justice. This
includes the repeated failure to take seriously or properly understand the
importance of what was being said by some members and former members
that Horizon was faulty and causing their shortfalls, George Thomson not
taking the correspondence which he received from Sir Alan Bates seriously,
and not only accepting the Post Office when they said that Horizon was
‘robust’ but George Thomson's promotion of that line, which impeded the
ability of the organisation to assist its members who were seeking help. We

are aware from the evidence that there are victims of the Horizon scandal

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who were members of the NFSP who have cited disappointment and
frustration with the actions of the NFSP and the representation they received.
This is a source of deep regret and, on behalf of the NFSP I am genuinely
sorry.

332. I would also reflect that while the Inquiry has heard evidence from
many different sources that challenges to the ‘Horizon is robust’ line (whether
from Second Sight, Sir Alan Bates over many years, Lord Arbuthnot, over
100 MPs and the JFSA) and it is clear Post Office could not be forced
publicly to admit what they knew, this does not absolve the NFSP from failure

to push Post Office much more seriously in the Horizon issues era.

333. I am asked if there is anything further that is relevant to the Terms

of Reference of which I think the Chair ought to be aware?

334. “It took a long time for things to go so far. It came about because
things that should have been stopped were not stopped soon enough.” — I

Ching, or Book of Changes

335. The big question that Postmasters would like answered is what next,
when the Inquiry is complete? Whilst change is required, it should not be
rushed. My own view is that sensible and pragmatic discussions need to take
place, and it is important that egos are removed. Otherwise, Postmasters will
suffer as a result. This is our one opportunity to showcase the Post Office as
it can be for the benefit of communities across the country. As our Chair, Tim
Boothman says “Postmasters have not enjoyed the Post Office their
investment deserves.”

336. We find that most Postmasters are disinterested in the noise or politics

that exist around the Post Office and network. Postmasters are not looking to

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be millionaires, they are looking to get up in the morning, open their Post
Offices, serve their communities, pay their bills, provide for their families
before closing their offices in the evening and living their lives.

337. Too many communities are losing their Post Office because it is no
longer viable for the Postmaster to operate the service. Being apolitical,
decisions by respective Governments over the last 30 years have resulted in
the decline of “the most trusted brand in the UK.”

338. This whole sorry scandal comes down to three words: Power, Authority
& Influence. Post Office had all of the power, authority and influence and
used it to the detriment of the victims. Given the historical evidence that
shows Post Office acting in such a detrimental manner towards Postmasters,
they should not be in a position to determine nor dictate the future viability of
a Postmasters investment.

339. In terms of the NFSP’s proposal for the way forward, and recognising
that while mutualisation is the ultimate goal, as discussed earlier in this
witness statement, the NFSP considers that in order for the relationship
between Postmasters and Post Office to be repaired and for Postmasters to
be treated fairly by Post Office, an Oversight Committee is what is required in
order properly to hold Post Office to account. This document (NFSP Proposal
for Oversight Committee January 2024, WITN00370110) is the NFSP’s draft
proposal for such an Oversight Committee. This has been discussed by the
Board of the NFSP at various points, the first of which being 18 months ago.
It has since been discussed with members and presented on our national
calls, local and regional meetings and conference, Post Office, DBT, MPs

(including Kevin Hollinrake MP and Gareth Thomas MP, and Rt Hon Kemi

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Badenoch MP - see Letter to Gareth Thomas MP (Minister of State for the
Department of Business and Trade) from NFSP re governance suggestions
26 July 2024, WITN00370114, and Letter from NFSP to Rt Hon Kemi
Badenoch MP (Secretary of State for Business and Trade) re Oversight
Committee proposal 30 January 2024, WITN00370121).

340. As discussed previously, the NFSP has identified through the member
surveys that Postmasters are concerned about their relationship with Post
Office. The NFSP’s view is that an Oversight Committee would be the option
most likely to ensure that something like the Horizon scandal could not
happen again, ensuring that Post Office still have a level of scrutiny after the
current Inquiry is finished. The NFSP considers that the Inquiry has heard
evidence that the Horizon scandal was effectively enabled by the “arms’
length” relationship between Post Office and the Government, its sole
shareholder. It is clear to us that this “arms’ length” relationship and lack of
Government oversight still exists today.

341. In the Oversight Committee proposal, the Committee would consist of a
member of Government, members from membership bodies, such as the
NFSP, the CWU and Unite, external legal representation, representative
bodies for people who especially rely upon the Network, such as older
people, people with disabilities, and people from rural areas, as well as a
temporary role for individuals with relevant expertise on specific issues on
the agenda. The Committee would have the ability to challenge the strategy
of Post Office and provide scrutiny to decisions, improving transparency and
corporate accountability. The NFSP hopes that this will assist with the early

identification of issues and concerns within the network and rebuild both trust

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in Post Office and the relationships between Post Office and other
stakeholders, including the Postmasters. The NFSP’s suggested scope for
such a Committee is on page 6 of the draft proposal.

342. An example of why an Oversight Committee is required can be seen
through the case study on page 9 of the draft proposal. We understand the
Inquiry is aware of what we call “Bonusgate” (the award of bonuses to senior
leaders for apparently complying with the Inquiry). This case study outlines
how an Oversight Committee could have prevented this from happening, as
well as how the Oversight Committee could work in practice in holding Post
Office to account and the early identification and rectification of issues.

343. The NFSP is aware that franchising has been proposed as another
way forward for Post Office. We believe this would cause a movement of risk
from Post Office to Postmasters. Under the franchising proposal,
Postmasters would have to pay Post Office to provide Post Office services
within their branch. They would also have to lease the IT equipment from
Post Office. If there was an issue with the IT equipment causing a loss to the
Postmaster, the Postmaster rather than Post Office would automatically carry
the loss unless and until they could prove that the fault was with Post Office’s
IT system. They would then have to pursue Post Office for the loss. The
NFSP is therefore of the view that franchising would not prevent an issue
such as the Horizon scandal from arising again, as it seems that this would
just put further onus on Postmasters in relation to losses.

344. In addition, Post Office branches run by Postmasters are small
businesses that are providing a service, and without their retail side most

would be a complete loss. Whilst franchising seems like a good proposal on

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the surface, we believe this would not work for the vast majority of
Postmasters who are providing a service alongside their retail business, as
the number of branches where you could actually earn a living from a Post
Office alone is small. The NFSP has concerns that Post Office are looking for
solutions which look good on the surface but would not be beneficial to
Postmasters in practice.

345. The NFSP considers that an Oversight Committee would be more
beneficial to members and protect their interests, in trying to ensure that their
business partner, Post Office, no longer treats them as subservient.

346. All of that said, I do, however, believe that all is not lost. Postmasters
have a contract with Government, via the Post Office, as it owns the Post
Office. It is imperative that there is a change in focus from within Government
and Post Office to see Postmasters as business partners due to their
investment. We need to change the entirety of the relationship framework
between Government and Post Office, which requires to be rewritten to
provide greater significance to the investment of Postmasters. We need to
work together to rebuild this business for the good of communities and the
people within Post Office who serve them.

347. If the Post Office past was wrong and we want to make the Post Office
tomorrow right, then we must grasp the opportunity of today to change the

way Government and Post Office interact with Postmasters.

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Statement of Truth

I believe the content of this statement to be true.

Signed:

Dated: 4" September 2024

Page 124 of 133
Index to First Witness Statement of Calum Brian Greenhow

Rw

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12
13
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15
16

17

18

19

URN
POL00113269

POL00027276
WITN00370130

NFSP00000899
NFSP00001051

NFSP00001067
NFSP00001072

NFSP00001464

NFSP00000957
NFSP00001075

NFSP00001086
NFSP00001094
NFSP00001034
NFSP00001033
WITNO0370109
NFSP00001460
WITNO0370126

NFSP00000976

POL00162628

Document Description
Common Issues Judgment

Post Office Group Executive Agenda
14/9/2017 and associated
documents

NFSP Centenary book page 17
Report Federation matters
MEMORANDUM OF ASSOCIATION
OF NATIONAL FEDERATION OF
SUBPOSTMASTERS, Bates Wells &
Braithwaite London LLP, revised 9th
May 2021

National Federation of Postmasters -
Rules

National Federation of
Subpostmasters - Rules

Letter (with enclosure) from David
Taylor to G Thomson re: Trade
Union and Labour Relations
(Consolidation) Act 1992, Removal
of Nation Federation of Sub-
Postmasters from the list of trade
unions

Special Conference

Grant framework agreement Post
Office Limited and National
Federation of sub-postmasters
NFSP Organisation structure

NFSP organisation structure diagram
NFSP Branch Secretaries Guide
2012

Branch Secretaries Guide final
NFSP Public Affairs Manager Report
to NFSP Board re issues affecting
SPMs March 2024

Email from Calum Greenhow to
Helen Baker re: ace up the sleeve?
Branch Secretaries’ Circular dated
18 August 2015

Branch Secretaries Circular from
George Thomson re press release
and information pack

Email chain from Angela Van-Den-
Bogerd to Mark Davies RE:

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Control Number_
POL-

0110651)
POL-0023917

WITN00370130
VIS00013795
VIS00013947

VIS00013963
VIS00013968

NFSP00001464

VIS00013853
VIS00013971

VIS00013982
VIS00013990
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VIS00013929
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NFSP00001460
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NFSP00000976

POL-0151030
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21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

WITNO0370129

UKGI00018137

NFSP00000500

NFSP00001465

NFSP00000888

POL00021699

NFSP00001037

NFSP00001044

NFSP00000725

NFSP00000806

NFSP00000671

NFSP00001332

POL00142870

NFSP00000761

POL00075132

POL00003870

POL00372920

Panorama - Trouble at the Post
Office

Emails between Calum Greenhow
and Tim McCormack re
Dalmellington dated 9 August 2016
Horizon Issues Judgment

NFSP report of a meeting of the
Council on 13-15 June 2016

Email from George Thomson to
Mervyn Jones re: Yesterday's
Branch Meeting

National Executive Council
Circulation with Memo from George
Thomson to Executive officer re Lee
Castleton - Horizon (Lee Castleton
case study)

Email from Martin Rolfe to Michael
Rudkin others cc'd re: Bracknell Visit
Motions for conference as agreed at
the MRC meeting on February 2010
Motions for conference as agreed at
the MRC meeting on February 2010
Horizon Next Generation Release
Authorisation Board (Internal)
Recommence Pilot Activities :
Meeting no 10, Post Office (Internal
RAB Meeting of 04 May 2010)
Letter to Dave Hulbert from Marilyn
Stoddart re Semilong Post Office
Mrs Jane Brewer

Email chain from Marilyn Stoddart to
Andrew Craddock, Keith Richards re
workshop agenda for Bracknell 22
Jan

Email from Dave Hulbert to Marilyn
Stoddart Re: Issues around the
recovery process following Horizon
outage

Agenda and Briefing for Paula
Vennell's meeting with George
Thomson on 13 March 2013

Post Office Ltd Section 1 Operators
Contract and Status
Subpostmasters' contract

BM20 - Preface and Standard
Conditions for the Operation of a
Main Post Office

POL Standard Conditions on Site
Commercial Transfer - Local Post

WITNO0370100
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WITNO00370129

UKGI028144-001
VISO0008958

NFSP00001465

VIS00013784

POL-0018178

VIS00013933

VIS00013933

VIS00013621

VIS00013702

VIS00013567

NFSP00001332

POL-BSFF-
0002035

VIS00013657
POL-0071695
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POL-BSFF-
0200313
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41

42

43

44

45

46

47

NFSP00001041

UKGI00025299

NFSP00000511

NFSP00001352

NFSP00000848

NFSP00000822

NFSP00001291

NFSP00001305

POL00041564

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WITNO0370103

Office Branch (POL Cash)
Agreement Existing Premises, New
Operator
Open Debate resume losses audit
suspension
Email from Tom Aldred to Beth
White, William Wilson, Post Office
Team and others re
BEIS/NFSP/UKGI meeting 26/11/19
- read out
National Federation of
Subpostmasters Report of a Meeting
of the National Executive Council on
15-17 June 2009
Spreadsheet concerning terminals
and Post office Horizon software
transactions (mails closed actions;
branch support and compatibility
report) - last updated was 12
February 2019
NFSP Branch Secretaries' Training
Representing Members RTUs ad
Appeals

Publicity and Development
Committee: Branch Secretaries
Training reasons to urge and
appeals interviews recruitment
Email from David Milner to Anita
Turner, Marilyn Stoddard, George
Thomson and others - Re: National
Savings Payment Advice
Email from Andrew Winn to Marilyn
Stoddart and Branch Support Team
re: Balance discrepancy, Queen's
Ferry Post Office.
Bankruptcy, prosecution and
disrupted livelihoods - Postmasters
tell their story; reported by Rebecca
Thomson - Article
Emails between Calum Greenhow
(as Branch Secretary), Donald
Ramsay (Scottish Executive Officer)
and Paul McBain (Scottish Non-
Executive Director) after Panorama
Programme 18 August 2015
Donald Ramsay (Scottish Executive
Officer) and Paul McBain (Scottish
Non-Executive Director) after
Panorama Programme 19 August
2015

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VIS00013937

UKGI034194-001

VISO0008969

NFSP00001352

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NFSP00000061

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NFSP00001116

NFSP00001105

NFSP00000263

NFSP00000699

NFSP0OO000695

NFSP00000707

NFSP00000710

NFSP00000870

NFSP00000779

NFSP Scottish Regional Council
Minutes dated 2 October 2015
NFSP - Branch Secretaries Circular
vol. 31

Letter chain from Colin Baker
to Alan Bates RE: Horizon System
Branch Secretaries’ Circular -
February 2010 - Volume 9
Letter on Horizon Online Pilot
Review from Marilyn Stoddart with
email attachment of feedback from
Mark Burley
Summary of meeting with Tim Parker
and Paula Vennells on 29 May 2018
Email to Paula Vennells over Post
Office's Annual Report & Accounts
14 September 2018
CWU Research: Post Bank
Campaign Briefing
NFSP Briefing — Postbank: All Party
Parliamentary Group for Post Offices
All Party Parliamentary Group for
Post Offices- Agenda for
AGM/Meeting on Postbank
Letter (Branch Secretaries Circular)
from George Thomson to unnamed
colleague re Horizon Mediation
Scheme
Email from George Thomson to Paul
Hook CC'd George Thomson,
Annabel Barnett RE;POL Horizon
mediation scheme
Meeting 29/8/13 148 Old St.
Gayle Peacock, Stefani Ulgiati, Ann
Analka? ,Andrew Gilhooly, Marilyn
Stoddart, lan Park
Email from Calum Greenhow To:
Keith Richards, Sharon
Merryweather, Lynda Willoughby re
FW: RE: Branch Refresh
Email form Jon Follenfant to The
Subpostmaster, Jim Nott, Kevin
Whitlock and others RE: Articles for
the Magazine?
Letter from Calum Greenhow to
Colleague re Group Litigation Bates
v Post Office
Email chain from Lynne Eccles RE:
NFSP piece

WITNO0370131

VIS00008740

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VIS00013910

VIS00007509

VIS00007488

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NFSP00001116

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NFSP00000712

NFSP00000774

NFSP00001387

NFSP00001234

NFSP00000715

POL00393126

UKGI00017689

POL00291032

POL00291026

NFSP00000292

Email chain from Peter Hall to Nick
Wallis RE:Book

Email from Calum Greenhow to
Calum Greenhow re: FW: Press and
other enquiries RE Post Office trial
NFSP Report to Calum Greenhow
on Girocheques Issue by Andrew
Gilhooly (former National President
and NED for Scotland of the NFSP)
(undated)

Email from George Thomson to Nick
Beal, cc'd Kevin Gililand and Paula
Vennells re PRINTED Fwd: Horizon
Investigation

NFSP report of a meeting of the
council on 25 - 26 March 2019
Email from Sharon Merryweather to
David Sanghera and others. CC ing
Calum Greenhow and others. RE:
Court Case

Email from Calum Greenhow to
Calum Greenhow re: FW: Press and
other enquiries RE Post Office trial
Email chain from Calum Greenhow
to Calum Greenhow RE: FW:
Revised column - Column for April
magazine NFSP

Email from Sharon Merryweather to
Douglas Kemp and Calum
Greenhow - Re: FW: Message Via
Contact Form on Website

Email from Peter Hall to Calum
Greenhow. RE: Elephant in the room
section of the magazine article on
your conference speech

Email from Calum Greenhow to Mark
R Davies RE: Support to Sustain our
Post Office

Email from Joshua Scott (UKGI) to
Tom Cooper, Tom Aldred,
Oluwatosin Adegun and others Re:
POL Biweekly Comms Catch up
Email from Melanie Corfield to
Patrick Bourke re: RE: Horizon
verdict v3

Horizon Verdict V3

NFSP - Branch Secretaries Circular
vol. 31

WITNO0370100
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VIS00013673

VIS00013670

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POL-BSFF-

0134060

VIS00009016

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NFSP00001234

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0220013

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NFSP00000727

NFSP00000534

NFSP00000710

NFSP00000758

NFSP00000728

NFSP00000905

NFSP00000492

UKGI00030616

NFSP00000778

WITNO0370105

Email from Amanda Cox to Mr
Andrew B Summers cc, Calum
Greenhow RE: Horizon trial
judgement FAD: 200647 Post Office:
Orleton PO

Email from Nick Beal to Calum
Greenhow, Peter Hall re: Media
statement - concerning Post Office
Response to Group Litigation
Judgment

Grant framework agreement meeting
Email from Calum Greenhow to
Calum Greenhow re: FW: Advice in
relation to potential Post Office
actions

Email from lan Park to Jenna
Khalfan cc George Thomson, Philip
Bloor RE: threats

Email from Calum Greenhow to
Calum Greenhow re: FW: NFSP
follow up

NFSP report of a meeting of the
Council held on 19 & 20 June 2017
Email form Jon Follenfant to The
Subpostmaster, Jim Nott, Kevin
Whitlock and others RE: Articles for
the Magazine?

Grant Framework Agreement: Post
Office and National Federation of
SPM

Email from Calum Greenhow to
Calum Greenhow re: FW: Grant
Agreement - to be published on the
‘about us’ page on the website
Branch Secretaries Circular -
Guidance for NFSP members re
historic losses

NFSP report of a virtual meeting of
the Council on 16 June 2020 and
slides from presentation on HSS
NFSP Support

Email from Brooks White to Wilson
William, Cecilia Vandini, Joshua
Scott and others

RE: Tomorrow's Catch Up

Letter from Nick Read RE: Options
to explore on further compensation
of GLO Claimants

Letter to Nick Read (Group CEO,
POL) from the NFSP re further

NFSP00001321

VIS00013614

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VIS00013674

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107 NFSP00000464
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111 WITN00370127

compensation of GLO claimants 9
July 2020

Letter to Kevin Hollinrake MP (Postal
Affairs Minister) after ITV drama 8
January 2024

see Letter to House of Commons
from the NFSP re Current Network
Issues 12 December 2022

NFSP Member Survey Results 2021
Letter to Gareth Thomas MP.
(Minister of State for the Department
of Business and Trade) with NFSP
introductions and outline of key SPM
issues 11 July 2024

NFSP’s Proposed Draft Letter from
Members to their MP re
renumeration and Horizon Inquiry
July 2024

NFSP'’s Proposed Draft Letter from
Members to their MP re DVLA and
other issues July 2023

NFSP’s Written Submission to
Business, Energy and Industrial
Strategy Committee re Post Office
Network Inquiry 2020

Working Group Minutes between the
Department of Business and Trade,
POL and NFSP 29 March 2023
Working Group Minutes between the
Department of Business and Trade,
POL and NFSP 12 July 2023

Emails between Calum Greenhow
and Postmaster NEDs Re_ Hard to
Place dated 8 December 2023
NFSP Public Affairs Manager
Spreadsheet with Monthly Overview
of SPM issues to June 2024
Subpostmaster Magazine Graphic re
results of member survey April 24
NFSP Report of Meeting of the
Council on 17 and 18 June 2019
NFSP Conference Programme 11 —
13 May 2024

NFSP Newsletter to Members 15
August 2024

NFSP and POL Wellbeing Overview
Spreadsheet 24 July 2024

Email from Lisa Harmsworth to
Calum Greenhow re denied

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128 POL00088895

129 POL00088891

membership request dated 13 March
2024

Letter to Simon Thompson (CEO of
Royal Mail) and Keith Williams
(Chair of Royal Mail) from NFSP re
renumeration 22 July 2024

News article from The Times titled
‘Postmasters on Post Office board
‘ignored and unwanted

Email from Sharon Merryweather to
Audrey Cameron CC ing Calum
Greenhow. RE: FW: Grant Fund
Agreement

Report of a Meeting of the Council
held on 14 and 15 October 2019
Email from Calum.Greenhow to
Sharon Merryweather. RE: Grant
Framework Agreement

Draft deed of variation of grant
framework agreement

Letter of Engagement between
NFSP and Grant Thornton 4 July
2024

Email chain from Jo Milton to Keith
Richards re: Policies (postmaster
support policies & Postmaster Guide
to Policies)

Post Office Audit Opening Script

A short guide to the Audit Reporting
Tool (ART)

Audit Closing Script

Postmaster Contract Suspension
Policy v3.0

Postmaster Contract Termination
Policy V3.0

Postmaster Termination Decision
Review Policy V2.3

Postmaster Support Policies:
Network Monitoring and Audit
Support Policy (v.V1.5)

Postmaster Support Policies:
Postmaster Account Support Policy -
Version V1.5

Postmaster Support Policies:
Postmaster Contract Performance
Policy (v.V3.0)

Postmaster Guide to Policies
Version — V1.2 (undated)

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Responses to NFSP questions on
Postmaster Support policies

NFSP Proposal for Oversight
Committee January 2024

Letter to Gareth Thomas MP.
(Minister of State for the Department
of Business and Trade) from NFSP
re governance suggestions 26 July
2024

Letter from NFSP to Rt Hon Kemi
Badenoch MP (Secretary of State for
Business and Trade) re Oversight
Committee proposal 30 January
2024

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