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Witness name: Nick Read
Statement No: WITN00760400
Dated: 24 September 2024
THE POST OFFICE HORIZON IT INQUIRY
Fourth Witness Statement of Nick Read
on behalf of Post Office Limited in the Post Office Horizon IT Inquiry
1. 1, Nick Read, of 100 Wood Street, London, EC2V 7ER, will say as follows:
A. Introduction
2. I am Nick Read, Group Chief Executive Officer (“CEO”) at Post Office Limited
(‘Post Office”). This is my Fourth Witness Statement to the Inquiry. I am giving
this witness statement in a corporate capacity on behalf of Post Office, in response
to Question 45 of the Rule 9 request dated 2 July 2024 (the "Rule 9(58) Request").
I am aware of the steps Post Office has taken to respond to this section of the Rule
9(58) Request; as such, I am the appropriate person to give this witness statement
on behalf of Post Office.
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3. I have aimed to include within this witness statement evidence relating to Question
45 of the Rule 9(58) Request insofar as the relevant facts are within my own
knowledge. The facts in this Fourth Witness Statement are true, complete and
accurate to the best of my knowledge and belief. Where my knowledge and belief,
as set out in this Fourth Witness Statement, has been informed by another person
or by documents that I have reviewed, I acknowledge that person or those
documents. I have been assisted in preparing this witness statement by Burges
Salmon LLP and Fieldfisher LLP (together "BSFf"), who act on behalf of Post
Office in the Post Office Horizon IT Inquiry (the "Inquiry").
B. Post Office's process to identify the information shared between Post Office
and the Shareholder during the period specified
4. I have been asked to consider section 12.1 of the Post Office Limited Shareholder
Relationship Framework Document [POL00362299] and provide a summary of all
information relevant to the matters being investigated by the Inquiry that has been
proactively shared by Post Office with the government as Shareholder, and details
of all requests made by the Shareholder to Post Office for information since 1
January 2023. Further, for each request, to confirm when Post Office responded
to each request for information from the Shareholder, and whether all, part or none
of the information requested was provided and why.
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5. I have not personally been involved in the process of searching, harvesting or
reviewing of documents in order to answer Question 45 of the R9(58) Request, but
have been informed of this process by Post Office's legal team and BSFf.
6. As set out at paragraph 27 of Rachel Scarrabelotti's Second Witness Statement
[WITN11120200], Section 12.1 of the Framework Document [POL00362299]
confirms the Shareholder's right to information, as follows:
12. Shareholder’s right to information
12.1 POL will proactively endeavour to share information on key strategic or policy
issues with the Shareholder. Under the Articles (Articles 9.1 and 9.2), the
Shareholder may “request such information in relation to the affairs of the group ...
as it may consider necessary or desirable. The company shall use its reasonable
endeavours to comply promptly ... but only in so far as the company has such
information within its possession or such information can reasonably be obtained
by it” and may meet with “such specified or other relevant directors and senior
managers of the company ... to discuss the affairs of the group”. The Shareholder
may make such requests itself or via the Shareholder’s Representative or Policy
Sponsor. The Shareholder, Shareholder’s Representative and Policy Sponsor may
use the information as necessary to properly exercise the shareholder function on
the understanding that due care will be taken in handling POL’s information, as set
out in paragraph 13 below. The appointment letter for the Shareholder NED
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contains further provisions specifically on the sharing of confidential information
between POL and the Shareholder NED.
. The sharing of information between Post Office and the Shareholder happens on
a regular basis. It takes place across a number of different levels and teams
throughout the organisation and covers a range of issues. As CEO, I am not
involved in the majority of the day-to-day communication and as such, it is not
within my direct knowledge.
. Post Office prepared its response to Question 45 of the Rule 9(58) Request in
conjunction with Question 44(f) of the Rule 9(58) Request, which asked for
information about all meetings between Post Office and the Shareholder. Both
questions required material to be searched and harvested. I understand that the
primary mode of sharing information between Post Office and UK Government
Investments ("UKGI") / Department for Business and Trade ("DBT") is via email
(as opposed to letters sent only in the post). As such, Post Office identified UKGI
and DBT domain names, and this identified around c. 282,000 emails passing
between Post Office and UKGI/DBT in the period 1 January 2023 to 1 July 2024.
In addition, Post Office identified individuals within Post Office who met with the
Shareholder during the course of their work and during the relevant period, and
harvested potentially relevant files from their mailboxes where necessary. Further
documents were also located in, and where potentially relevant, harvested from
certain folders in SharePoint and OneDrive in Post Office’s IT systems.
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9. Further, I understand that some requests for documents are made and sent via a
secure file sharing platform called Quatrix. I understand that although it is possible
to obtain a list of communications between users and file names which were
shared, it is not possible to reconstruct the message. KPMG produced a report
which extracted over 1000 file paths (containing the file names) of documents
shared between Post Office and the Shareholder, but the underlying documents
are not retained on Quatrix. I understand that due to the complexity of the file paths
it was difficult to extract the file names in a searchable format and assess relevancy
from the report alone. In the time available it has not been possible to attempt to
use the file paths to try to locate the underlying documents in the material that had
been harvested or cross-check the file names in the chronology of communications
in the spreadsheet.
10.Search terms relevant to the Inquiry's Terms of Reference were applied to the
harvested documents. Post Office has kept a detailed record of these searches,
but in summary they were designed to identify communications pertaining to
matters relevant to the Inquiry:
a. the operation of Horizon;
b. Strategic Platform Modernisation Programme ("SPMP") / New Branch IT
system ("NBIT");
c. Postmasters;
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d. governance;
e. culture;
f. investigations; and
g. Speak Up / Whistleblowing.
11. This narrowed the pool to c.11,600 documents. Once potentially relevant family
documents, which were not responsive to the search terms, had been added to
this pool, a total of 14,895 documents were then individually reviewed for relevance
to Question 44(f) and Question 45 of the R9(58) Request. Key documents relevant
to Question 44f were addressed in my First Witness Statement [WITN00760100]
and produced as exhibits. Where a communication was relevant to Question 45,
a summary of the communication was entered into the spreadsheet exhibited to
this statement (‘Summary of Information Sharing between Post Office and
Shareholder’, referred to in this statement as "the spreadsheet") [POL00460562].
12. The spreadsheet includes a summary of all relevant communications that were
identified as part of this review. I understand that duplicative documents, or
documents that were assessed as wholly legally privileged, have not been
produced, and that wholly privileged documents have not been summarised in the
spreadsheet. The documents produced totals 205 (not including family
documents). The summaries in the spreadsheet seek to make clear the nature of
the response from Post Office. Where Post Office has not been able to identify a
response to a request for information from the Shareholder, additional searches
have been run to try to locate it; however, in the time available it has not been
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possible to conclude whether there was in fact no response from Post Office, or
instead whether there was a response from Post Office, but it has not been located
using the search terms applied.
13.1 have not considered the underlying documents myself. There has not been time
to do so, and as stated above I am not involved in every communication sent
between individuals working for the Shareholder and Post Office. I have however
reviewed the spreadsheet that has been prepared by Post Office, which I exhibit
to this statement.
Statement of Truth
I believe the content of this statement to be true.
GRO
Signature:
Date: 24 September 2024
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Index to the Fourth Witness Statement of Nick Read
No. URN Document Description Control Number
1. I POL00362299 I Post Office Limited Shareholder POL-BSFF-
Relationship Framework 0190809
Document
2. I WITN11120200 I Rachel Scarrabelotti's Second WITN11120200
Witness Statement
3. I WITNOO760100 I Nick Read's First Witness WITNOO0760100
Statement
4. I POL00460562 I Summary of Information POL00460562
Sharing between Post Office
and Shareholder (spreadsheet
exhibited to Nick Read's Fourth
Witness Statement)
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