WITN05210100 Ruth Reid - First Witness Statement

Evidence on official site

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Witness Name: Ruth Reid
Statement No: WITN0521_01

Exhibits: WITN0521_01/1 to WITN0521_01/62

Dated: 13 October 2022

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF RUTH REID

1. I, Ruth Reid, will say as follows:

2. In making this statement I would like to acknowledge the importance of the
Post Office Horizon IT Inquiry and offer my full co-operation to the Inquiry.

3. I would like to express my gratitude to the Inquiry team for the additional time
that they have given to me to provide this statement.

4. I am providing this statement following receipt of a Rule 9 Request dated 29
June 2022 from the Post Office Horizon IT Inquiry asking me to provide a
written statement regarding issues with Horizon. This Request contained 16
questions which the Inquiry asked me to address in my statement. For ease of
reference, I have written out each question with its corresponding question
number.

5. At the outset, I would like the Inquiry to know that I suffer from r

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9. Due to the current state of my mental and physical health I have found it

incredibly difficult to produce this statement and to review the 1,500 pages of

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10. Nevertheless, I have devoted considerable time over the past few weeks to
producing this statement, but undoubtedly my recollection of events has been
impaired by the passage of time and the impact of my medical condition on
my memory.

BACKGROUND

Question 1: Please set out a brief professional background

11. I did an undergraduate degree in Business Studies at Edinburgh University
and graduated in 1985 with an upper second class degree.

12. I joined the Post Office in November 1985 as a graduate entrant based in
Leeds. During the time I worked for the Post Office I was known as Ruth
Holleran.

13. I worked for Royal Mail to start with until around 1988 when I moved out of the
graduate entrant programme.

14. I then worked for Post Office Group in Investigations (Post Office
Investigations Department) as a Systems Manager on the Mail Order
Recordings and Losses System (MORALS system). I was an operational
systems manager not a technical systems manager. I had no IT background.
This was a junior role, at PEC postal executive grade C which was a junior
management entrant level position.

15. At that time, the business was divided into 4 departments, which I recall was
Group HO, Royal Mail, Parcelforce and Post Office Counters Ltd (POCL).

16. I then moved to Chesterfield and I worked for POCL Internal Audit.

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17.

18.

19.

20.

21.

22.

23.

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The role involved auditing head office centralised systems and processes in
POCL. It did not involve audit of the branch processes or cash centres. Much
of my work was focused on identifying process and control improvements in
central systems.

I worked as an auditor initially and I was then promoted to PEB level after 1-2
years. I believe this was sometime in 1991.

The business did a skills analysis and I was graded highly which resulted in
me being promoted to Project Audit Manager in around 1992. This was my
first role as a senior (band 9) manager.

I then followed a band 6 manager who was Peter Dent, Chief Internal Auditor.
Peter asked me to go with him to form a new project team. He was plucked
out to work on the Transaction Information Process (TIP) Project. I think
Peter was working to Roger Tabor, Director of Finance. I was still a band 9 at
this stage. I think this was in approximately 1995. My role was a Business
Requirements Manager (BRM).

I had a team of business analysts working for me at this time. Initially, I was
involved in defining the scope and business requirements of the project. The
scope of TIP was to automate the back end of the processes at POCL head
office in Chesterfield which was still largely manual. Additionally, around this
time I became involved in the Benefit Agency end to end reconciliation
process required for ICL Pathway release 1c.

Horizon was the automation of the front end of the system at branches. It
comprised the BES, EPOSS and APS software components.

I was a BRM for 1-2 years at the most. During my time as a BRM we made a

number of attempts to present business cases to the board regarding the

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24.

25.

26.

27.

28.

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scope and affordability of TIP as a project. At some point a decision was
taken to narrow the scope of TIP to become known as Interim TIP but I can’t
recall whether I was still BRM or had moved on to become a Business
Integrity Manager (BIM) when that decision was taken.

I was promoted to BIM in 1996 or 1997. This was a promotion to band 8
working to David Smith, the Head of the Transformational Management Team
(TMT) in London.

At this time, as well as Interim TIP there was huge business change taking
place, known as ‘shaping for competitive success’. This ran right across all
four businesses within the PO group. The school of process management
was coming to the fore in a big way at this time and this drove much of the
reorganisation. Its aim was to drive efficiency savings in a strategic way.

The operational process being automated by Horizon was owned at the time
by the Head of Transaction Processing. At the time this was Andy Radka and
then later it was Gail Morley.

As BIM I was responsible for ensuring the identification and specification of
the end to end business requirements within TMT. My role was an assurance
role working with relevant business experts to identify what these were, for
example, the business change team (part of Transaction Processing Business
Unit).

I also sat on the Automation Working Group (AWG) which consisted of
managers/stakeholders operating at my level. This was chaired by Elena
Marsh, who also worked to David Smith. The AWG deferred to the

Automation Programme Group (APG), chaired by David Smith, who was my

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boss. The APG was made up of other more senior managers. The AWG and
APG were internal (POCL only) groups.

29. APG and AWG’s meetings were minuted and there was a document review
process within POCL. This document review process was looked after by the
Head of Service Management, who was possibly Don Grey at this time. I
don’t believe I have seen any of these groups’ minutes within the disclosure
provided to me by the Inquiry.

30. ‘I reported into the AWG and it was ultimately the APG which approved the go
live of systems with POCL.

31. In addition to this, Horizon had its own Programme Assurance Team (PAT). It
was staffed by people from the Benefits Agency and POCL and headed up by
John Meagher, who worked directly to the Horizon Programme Manager, who
I think was Bruce McNiven. A lot of the people who were working on the PAT
came from POCL’s business systems and outlet systems group.

32. I remained BIM until around 2000 when I transferred to Chesterfield to
become the Head of Transaction Processing within POCL, taking over from
Gail Morley. I was then Head of Network Support, taking over from Don
Grey. We added the cash centres at some point and I then became the
General Manager of Network Support Services. This was in around 2003. I
remained in this role until I left the business in 2005.

Question 2: Please describe your role in relation to the Pathway Project / the

Horizon IT system.

33. Please see my response to question 1 above.

TRANSACTION INFORMATION PROCESSING PROJECT

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Question 3: Please consider POL0031246 and POL00031245 (WITN0521_01/1

and WITN0521_01/2).

34.

35.

36.

a. Please describe the purpose and function of the Transaction Information

Processing Project.

The TIP project started out in a nutshell to automate POCL’s back end of
processes in Chesterfield. Horizon was automation of the front end at branch
office outlets. In order to automate the back end the vast majority of
transactions would have needed automation at the point of sale, which wasn’t
the case. Chesterfield used to input the cash count (which was a weekly
summary document), and the supporting documents used to verify the cash
account entries, and they could be anything from summary level to individual
transaction documents themselves. The summary cash count needed
verifying with supporting documents. 700 people were involved in that
process in Chesterfield and in doing so, validated the accounts of outlets and
the financial settlement of business that we were doing on clients’ behalf.

So the purpose of TIP was to explore options for automating the back end.
However, this was a vast undertaking and not something which the business
felt there was a compelling business case for, nor was it affordable to do in
one go. As a result the scope of the original TIP project was narrowed down
in the end to Interim TIP. Interim TIP became an actual project. It took an
electronic feed of cash account and individual transaction data from Horizon
and fed the cash account data into the various legacy systems at Chesterfield.
It was the interface between Horizon and Chesterfield.

Originally conceptualised as being part of TIP was further automation of other

products. Once the scope was narrowed and TIP became Interim TIP, this

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37.

38.

39.

40.

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wider automation was excluded from the scope of Interim TIP. Later, the
Impact Project looked at the whole end to end automation (referenced at

question 13).

. What was the nature of your role in relation to this project?

Peter Dent was the controller of the project. I worked for him in audit and he
took me with him to work on this project, with a promise of an opportunity to
get out of audit and to work on business change of the operation.

We started off with a blank sheet of paper and my role as BRM was to lead a
team of business analysts with a view to defining the scope and business
requirements of the project.

During my time as a BRM we made a number of attempts to present business
cases to the board regarding the scope and affordability of TIP as a project.
At some point a decision was taken to proceed initially with what became
known as Interim TIP.

As BIM my role became wider than Interim TIP, because I was then involved

in the end to end assurance.

. Please explain the relevance of this project to the wider Pathway Project

/ the development of the Horizon IT system.

Interim TIP took an electronic feed of cash account summary data and
individual transactions from Horizon and fed as appropriate into the legacy
systems in Chesterfield. The business benefit of doing this at the time was
very narrow, it just involved avoiding the keying in of the cash account

information manually by the team in Chesterfield.

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42. Document POL00031246 was authored by Paul Uden and Dave Perkins who
worked for the Transaction Process Business Unit at POCL in Chesterfield.
They worked for Andy Radka and then Gail Morley.

43. — Interim TIP was very narrow in scope compared to what was originally
envisaged. I knew how the POCL end to end business operated and that was
why I became involved.

PROJECT REPLAN

Question 4: Please consider POL00039672 (WITN0521_01/3).

a. What did you understand to be the cause(s) of delay to the project in
Spring 1997?

44. I donot specifically recall what was the cause of the delay. I believe there
were a number of things which simply weren't ready in 1997. The brief
passing reference to me in the email from Mena Rego to Min Burdett
(document POL00039672) does not assist my recollection. I do not recall
whether I was asked to input specifically in relation to the concerns raised in
this email. I am not copied in and do not recall seeing this email prior to it
being provided to me by the Inquiry.

b. What (if any) concerns did you have about the accounting integrity of
Horizon at this time?

45. As far as I can recall, the Electronic Point of Sale System (EPOSS) was still
being developed and tested at this stage and therefore I do not recall having
any major concerns regarding the accounting integrity of Horizon at this time.

PiniICL IMPACT ASSESSMENT TEAM

Question 5: Please consider FUJ00078989 (WITN0521_01/4).

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46.

47.

48.

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. What did you understand the purpose of the PinICL Impact Assessment

Team to be?
I wasn’t part of the PiniICL Impact Assessment Team as far as I can recall but I

understand its purpose was as per section 3 of this document.

. Please describe the purpose and function of the Known Problem

Register (“KPR”).

The KPR was a register of problems identified during testing. Issues were
entered onto the KPR if it was considered that they presented a business
impact of going ahead with the release of software. This was circulated to the
business, including me. The business analysts who worked for me would go
through this in detail, as did people working in the Programme Delivery
Authority (PDA), headed up by John Meagher.

Graeme Seedall worked for the PDA and he was an ex POCL Outlet Systems
person. He used to work with colleagues of mine, including Mark Burley, Peter
Jones, Martin Box and several others. The working group would go out and
discuss problems with other business stakeholders right across the business.
In my case this would include the involvement of the Transaction Processing
Unit (TPU) in Chesterfield e.g. Mark Burley would meet with TP business units
and many other from the regional network management structure and their
teams to review the KPR and would RAG rate business impact.

The KPR included workarounds until such times as the problem could have a
permanent fix. Based on those assessments I was one of the sponsors who
would review and approve acceptance of PINICLs for acceptance onto the

KPR.

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50.

51.

52.

53.

54.

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I believe there was some contractual significance to the KPR but I do not

know exactly what this was.

What as the nature of your involvement in relation to the KPR?

I have no specific recollection over and above the detail contained within the
document and the information provided in my response to question 5.b.

above.

. Do you consider that this was an effective system for resolving

technical issues? Please set out the reasons for your answer.

We were not able to be prescriptive about how the software was written, as
far as I was aware, due to the nature of the PFI with ICL Pathway and Fujitsu,
and we did not have access to the code.

As a consequence, the only way we could check our requirements were being
met was via system testing. I recall there was a one to one mapping of the
business requirements to the testing script. There was a service architecture
document which was designed to demonstrate that each of the business
requirements were mapped.

I was aware that the KPR was just part of the system processes for
identifying, testing and resolving issues. At the time I did consider the KPR to
be effective. It enabled my team to go and work with those who knew the

business, and it meant that issues were appropriately identified to the APG.

. What (if any) role did the KPR have at the time when Horizon was

accepted?
As I have said in my response to question 5.b. above, the KPR has some

contractual significance but I do not know what this was. To the best of my

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recollection the KPR was used throughout the development and delivery of
Horizon.
f. What became of the KPR when Horizon was rolled out to the national

network?

56. I believe it was handed over to POCL Service Management.

ICL PATHWAY RELEASE 1C

Question 6: Please consider POL00028598, POL00028596, POL00028595,

POL00028597, POL00028594, POL00028591, POL00028589, POL00028592,

FUJ00058360, POL00028590 (WITN0521_01/5 to WITNO521_ 01/14).

a. What did you understand about the accounting integrity and robustness
of ICL Pathway Release 1c?

57. I believe that ICL Pathway Release 1c related to the roll out of automation of
the Benefits Agency child benefit system only. I believe that this was a limited
release with the system released to around 200 outlets within the network.

58. The documents provided are all service management reports and one
document detailing the end to end process. My view on the accounting
integrity and robustness were as per the reports, with my main concern being
the lost transactions. It is clear from the reports that this was being given
what I considered to be the necessary priority, and that these issues had been
raised with ICL Pathway.

b. In particular, what understanding did you have about:

i. The nature and severity of PinICLs;
59. I My understanding of the PinICLs was as per the detail provided within the

service reports.

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60.

61.

62.

63.

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ii. The nature, cause and consequences of ‘lost’ or ‘incomplete’
transactions, ‘duplicate payments’, ‘cash account errors’,
‘reconciliation incidents’ and unmatched exceptions;

These issues were all errors identified during routine testing. I was also

aware that this was a limited release and one purpose was to test the

volumes of transactions and to identify errors. I was also aware that branches
were still accounting manually as well trialing the Benefit Encashment System

(BES) software and therefore issues were being identified and reported as

part of the routine test of release 1c.

iii. The fitness for purpose of the software being developed to support
the Horizon system;

Satisfactory, albeit I am unable to comment from a software system coding

perspective.

iv. The design and development of the Electronic Point of Sales
Service (“EPOSS”) and whether it was adequate;

I do not recall any specific concerns regarding EPOSS at that time.

v. The action being taken to rectify these issues and whether it was
adequate.

My recollection is that there were various working parties set up to look at

these issues. All were investigated as per fall back procedures which were in

place and which were proven to be adequate where roll-out was limited. At
the time, having regard to the limited nature of this release, I considered the
action being taken to rectify these issues at this stage of the project was

adequate.

MODEL OFFICE AND END-TO-END TESTING OF NILE RELEASE 2

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Question 7: Please consider POL00028428 and POL00028427(WITN0521_01/15

and (WITN0521_01/16).

a.

64.

65.

66.

67.

68.

What did you understand about the issues identified during the Model
Office and End to End Testing carried out in the autumn of 1998?

Peter Jones and Chris Young were both technical IT experts in systems
testing. Peter was working to Dave Parnell and they worked on the systems
side of Interim TIP. Chris Young worked to Simon Rilot as part of PAT.

At this stage I was BIM.

On reviewing Documents POL00028428 and POL00028427 I am aware that
Peter had a number of concerns regarding issues identified during model

office and end to end testing, which Chris addresses in his response.

. What (if any) concerns did you have about the accounting integrity of

Horizon at this time?

At the time of this correspondence it is prior to systems going live. The
response from Chris Young refers variously to testing and it is my
understanding that he is seeking to provide reassurance that when the testing
takes place, it will investigate the issues Peter has raised. Given that I did not
have a technical background, I was reassured that people with the expertise
of Peter and Chris were aware and discussing such issues and that testing
would be taking place which would interrogate these concerns with a view to
ensuring the accounting integrity of Horizon prior to roll-out.

At some point during the testing phase (and likely during 1999) I did begin to
be concerned once Acceptance Incident No. 376 was identified. I do not now
recall when during the testing phase this incident was first raised. Please see

my answers to question 11 below in relation to Acceptance Incident No. 376.

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Question 8: Please consider FUJ00078674, FUJ00078675, FUJ00078693 and

FUJ00058445 (WITNO521_01/17 to (WITNO521_01/20).

a. What did you understand about the issues identified during the Model
Office and End to End Testing carried out between February and March
1999?

69. I recall that this was the first opportunity to test a POCL release. Prior to this
the only release was a Benefits Agency system only release. This was the
first time we had the EPOS system, for example, in the mix, in the test
(however this was only 9 branches). It was a live test. It was the first time the
interfaces, the back end, were involved, which comprised the reference data
system, Interim TIP, the Host Automated Payment System (HAPS). It was the
first end to end system architecture test. It was a release of software from
Horizon. Essentially the test was the first time we involved POCL back end
processes and systems as well as the first release where we incorporated our
own business requirements (albeit only in 9 outlets).

70. Nile 2.0 was an incremental release. I don’t remember March 1999 standing
out as a major event. As I have said it was limited to 9 branches and it was
during the planned test phase.

71. Oneview of the meeting minutes (Document FUJ00078675) there are no
particularly concerning issues as far as I can see. In terms of the Model Office
Testing Evaluation Report (Document FUJ00058445), this is a write up by the
programme team. I believe the report was a fair, factual report of the testing
and of the issues identified and I cannot add to what is within the report.

72. — It is worth highlighting that whilst I am the only person on distribution list as

being a POCL representative, this is not in fact correct. Lots of the people

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73.

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listed are POCL. For example, Janet Topham was POCL’s Chief Internal

Auditor, and worked for Roger Tabor. She was in POCL Finance, not Horizon.

. What (if any) concerns did you have any the accounting integrity of

Horizon at this time?

I do not have a clear recollection of how I viewed the issues at this stage in
March 1999. I do not recall being aware of any serious accounting concerns
at this stage. However, please see my responses to question 7.b. and 11 in

relation to Acceptance Incident No. 376.

REVIEW OF POCL AND ICL PATHWAY DEAL

Question 9: Please consider POL00031230 (WITN0521_01/21).

a

74.

75.

76.

What did you understand the purpose of this review to be?
My understanding is that Roger Tabor’s review, carried out in his role as
Director of Finance within POCL, was to review the POCL ICL Pathway deal,

having regarding to POCL’s wider business aims.

. Please describe the nature of your involvement in this review.

I have a vague recollection of speaking with Roger or someone supporting
him with the review but I cannot recall any detail beyond that.

To what extent (if at all) did the view of senior managers as described at
paragraph 2.6 reflect your own views at the time?

Whilst I do not think that the position I occupied within the business in 1999
would have meant that I would have been considered within the group of
people who Roger refers to as senior managers at paragraph 2.6, I did share
some of the concerns which are summarised. In particular, I shared views

and concerns over whether the product would be satisfactory, transparency

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issues in the PFI contract and POCL’s own ability to give it sufficient focus to

enable its success.

. To what extent (if at all) did you support the conclusions reached at

paragraphs 3.4 — 3.6 of the review?

I entirely supported the conclusions reached at 3.4-3.6 of the report.

INCIDENT MANAGEMENT AND RESOLUTION

Question 10: Please consider POL00000758 and POL00000776

(WITN0521_01/22 and WITNO521_ 01/23).

78.

79.

a. Please explain the purpose of these incident management and

resolution procedures.
The purpose was to explain the rectification process for incidents that may
arise throughout the end to end process involved in EPOSS and Automated

Payment System (APS).

. What did you understand about the ‘exceptions’ which had been

identified in EPOSS prior to the operational trial?

The documents provide, at the time of production, a complete and accurate
report and process description for ‘exceptions’ which had been identified in
EPOSS. These documents underwent a number of versions and revisions.
These were authorised by the EPOSS reconciliation panel and ultimately
approved by me as BIM. My role as BIM would have been to ensure that all
relevant business process experts were involved in the drafting and writing of

these process flows, and they were.

What did you understand about the ‘exceptions’ which had been

identified in the Automated Payment Service (“APS”) prior to the

operational trial?

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80. The documents provide, at the time of production, a complete and accurate
report and process description for ‘exceptions’ which had been identified in
APS. These documents underwent a number of versions and revisions.
These were authorised by the APS reconciliation panel and ultimately
approved by me as BIM. My role as BIM would have been to ensure that all
relevant business process experts were involved in the drafting and writing of
these process flows, and they were.

d. What (if any) concerns did you have about the accounting integrity of
Horizon at this time?

81. I do not specifically recall my concerns at this stage but please see my
responses to questions 7.b, 8.b. and 11, in particular in relation to Acceptance
Incident No. 376.

ACCEPTANCE OF THE CORE SYSTEM RELEASE

Question 11: Please consider POL00029137, POL00028357, POL00028367,

POL00028332, POL00030393, POL00028364, POL00028365, POL00028366,

FUJ00079159, POL00028332, POL00029131, POL00030392, POL00028355,

POL00028347, POL00028477, POL00028478, POL00028342, POL00028476,

POL00028474, POL00028475, POL00028471, POL00028472, POL00028470,

POL00028465, POL00028461, FUJ00079176 (WITNO521_01/24 to

WITNO521_ 01/49).

a. Please describe your role in acceptance of the Core System Release
(“CSR”).

82. In my role as BIM I was involved in end to end business assurance, through

stakeholders, of solution fit with the business requirements which had been

identified.

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83.

84.

85.

86.

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b. Did you consider the acceptance timetable (e.g. the core observation

period and the operational trial review period) to be sufficient? Please
give reasons for your answer.

In short, yes. The core observation period covered two accounting period
month ends and 8 branch office account weeks — 8 cycles of producing cash
accounts through the new software. This core observation period duration
was agreed with business stakeholders, head office central finance division
and internal audit. I recall all were satisfied with this duration and on that basis

I considered it sufficient.

. In relation to Acceptance Incident No. 376, please describe and explain:

i. Your understanding of the nature, cause and severity of the
incident;

Acceptance Incident No. 376 was a data integrity issue. It was identified by
the interface testing within Interim TIP not ICL Pathway.
The Interim TIP system demonstrated some differences between the cash
account and the individual transactions data feed. Whilst the front end had
been automated by Horizon this was telling us we couldn't trust the data being
given to the back end of POCL’s systems and ICL Pathway didn’t know this.
It was acknowledged that there was also a reference data issue which was
attributable to POCL and John Meagher of the PAT took responsibility for
resolving this issue prior to acceptance.
Acceptance Incident No. 376 was something I championed and I was very
concerned about it.

ii. How the incident came to be identified;

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88.

89.

90.

91.

92.

93.

94.

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The incident was identified by Interim TIP project team. Dave Parnell and
Peter Jones brought it to the business’ attention.

iii. Your assessment of its business impact;
This was a high severity issue.

iv. What (if any) remedial action you proposed;
In the first instance, I proposed that ICL Pathway introduce the software
change to implement the control which Interim TIP had developed (initially on
a temporary basis) to check the completeness of the data received by Interim
TIP. That software proposal turned out to be too invasive to meet the original
acceptance timescales (August 1999).
An Independent Expert, Peter Copping, was brought in by ICL Pathway under
the contract to work with both parties to agree a way forward, following POCL
not agreeing to acceptance in August 1999. For the avoidance of doubt, my
view was acceptance should be declined in August 1999 and it was.
He recommended, as part of the contract arbitration process, on the basis that
there was a rectification plan to introduce the data capture release in
December 1999 (this was a large piece of work), that acceptance take place
but on a conditional basis, rather than acceptance continue to be declined.
In the main, the condition was that the December 1999 software release was
implemented and that this resolved the issue. In addition, one condition was
that the error levels would need to have reduced to a level defined in the
contract, in order for acceptance to take place.

My preference was for the control to be implemented before acceptance.

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95. Ernst and Young were consulted and they advised the business at a very high
level, that provided that there was a plan for rectification and a control, to
explain the differences, they were satisfied.

96. As aconsequence, acceptance took place in September 1999 on a
conditional basis. These conditions were defined by the respective
commercial teams and embodied within the contract.

97. Meanwhile, there was a vast group of people working to investigate, explain
and rectify this issue.

98. All of these incidents were being reviewed by the APG (my boss Dave Smith
and the heads of departments).

v. Your assessment of ICL Pathway’s proposed rectification plans

99. We wanted ICL Pathway to recognize this problem, and to recognise the need
as an outsource supplier, for them to investigate and fix this problem. ICL
Pathway took this seriously, not least in part because they could see this was
a serious issue for us.

100. Right up to November 1999 I was involved in saying this was a major
problem. I was involved, as was my boss, David Smith. There were lots of
people involved. It was a hot topic. The key people were the Chief Internal
Auditor, Dermot Toberty and Hilary Stewart, and external auditors. As above,
I recall that Ernst and Young had some involvement with this as well.

101. Meanwhile, a workaround continued to be developed by Transaction
Processing in Chesterfield, ICL Pathway and other relevant parties for any
residual errors.

vi. How (if at all) your assessment of ICL’s Pathway’s proposed

rectification plans changed over time.

Page 21 of 42
102.

103.

104.

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WITNO5210100

We were receiving daily reports. They were fixing all the time where issues
were attributable to their own software and notifying us where the issue was
attributable to the reference data. The EPOSS working party continued to
work on the residual errors.

I believe ICL Pathway were acting in good faith with a view to rectifying the

issues and delivering a system which we could accept and subject to the

criteria defined (including for example specific criteria regard the error levels).

. In relation to Acceptance Incident No. 298, please describe and explain:

i. Your understanding of the nature, cause and severity of the
incident;
ii. How the incident came to be identified;
iii. Your assessment of its business impact;
iv. What (if any) remedial action you proposed;
v. Your assessment of ICL Pathway’s proposed rectification plans;
vi. How (if at all) your assessment of ICL Pathway’s proposed
rectification plans changed over time.
I do not recall being heavily involved in Acceptance Incident No. 298. There
were sub groups of people involved in investigating all of the Acceptance
Incidents. I recall that 298 was championed by Jeremy Folkes. This was a
technical screen locking/freezing issue which is all that I feel that I can say in
relation to questions 11 d. i.- vi above.
In relation to Acceptance Incident No. 218, please describe and explain:
i. Your understanding of the nature, cause and severity of the
incident;

ii. How the incident came to be identified;

Page 22 of 42
105.

106.

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WITNO5210100

iii. Your assessment of its business impact;
iv. What (if any) remedial action you proposed;
v. Your assessment of ICL Pathway’s proposed rectification plans;
vi. How (if at all) your assessment of ICL Pathway’s proposed
rectification plans changed over time.
I do not recall being heavily involved in Acceptance Incident No. 218. There
were sub groups of people involved in investigating all of the Acceptance
Incidents. I recall that 218 was a training issue, with one issue in particular
being the quality of the training scripts. Bruce McNiven was the lead on 218.
I was aware of it in high level overview terms. Bruce was the Head of the
Implementation Programme and was a very senior manager within POCL.
This is all that I can say in relation to questions 11 e. i.-vi above.
In relation to Acceptance Incident No. 408, please describe and explain:
1. Your understanding of the nature, cause and severity of the
incident;
Il. How the incident came to be identified;
I. Your assessment of its business impact;
IV. What (if any) remedial action you proposed;
V. Your assessment of ICL Pathway’s proposed rectification plans;
VI. How (if at all) your assessment of ICL Pathway’s proposed
rectification plans changed over time.
I do not recall being heavily involved in Acceptance Incident No. 408. There
were sub groups of people involved in investigating all of the Acceptance
Incidents. 408 was to do with The Horizon System Helpdesk. Part of the

service bought from ICL Pathway was a first tier support helpdesk resourced

Page 23 of 42
107.

108.

109.

110.

WITNO05210100
WITNO5210100

by ICL Pathway and this would prove branches/outlets with support. Adele
Henderson led on 408. Adele worked for our own business support /
helpdesk. Andy Radka was the head of this (as Head of Services
Management) by this time and he was involved in this. This is all that I can
say in relation to questions 11 f. i.-vi.

Which (if any) of these acceptance incidents remained outstanding as at
the date of acceptance of the CSR?

I am certainly aware that Acceptance Incident No. 376 remained outstanding
at the date of Acceptance in September 1999.

I am not sure about the other Acceptance Incidents.

What (if any) pressure was brought to bear on you to downgrade these
acceptance incidents in order to achieve acceptance of the CSR? By
whom was such pressure exerted?

There was pressure generally and we were working almost around the clock
getting things right having declined acceptance in August 1999 and the
subsequent involvement of the external expert, Peter Copping. But there was
no direct pressure whatsoever on me to downgrade acceptance incidents or
pressure on me generally. Dave Smith and Dave Miller (Operations Director)
were very supportive of the position I took around this time regarding
Acceptance Incident No. 376.

What (if any) concerns did you have about the accounting integrity of
Horizon at the point at which CSR was accepted?

As explained above, I was sufficiently concerned, in particular in relation to
Acceptance Incident No. 376, and supportive of the business decision to

decline acceptance in August 1999. At the point of conditional acceptance in

Page 24 of 42
111.

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September 1999 I remained concerned about ICL Pathway’s ability to deliver
the software release, but understood the decision regard recommencing roll-
out would only be taken in January 2000 following ICL Pathway’s software
release.

Please describe and explain the conditions on which the CSR was

accepted by the Post Office.

These were contractual conditions and I am unable to assist over and above the
details set out within the documents. As I have summarised above, in respect of
Acceptance Incident No. 376 in particular, the conditions included a further software

release and a reduction in the errors to within agreed limits.

SUSPENSION OF ROLL OUT

Question 12: Please consider POL00028565, POL00028564, POL00028563,
POL00028561, POL00028559, POL00028558, POL00028556, POL00028542,
POL00028509 (WITN0521_01/50 to WITNO521_ 01/58).

a. Please describe your role in monitoring ICL Pathway’s compliance with

112.

113.

114.

the conditions imposed upon acceptance of the CSR.

My role was to receive the daily and weekly reports, to review and check on
progress and to report that to my boss Dave Smith.

I focused on 376 because it was such a big issue and I knew that others were
taking responsibility for the other issues.

These reports were being received by scores of people, including my boss
Dave Smith. I had daily meetings with Martin Box of Interim TIP, Graeme
Seedall of PAT, Mark Burley and others. There must have been 8 different
people. It included finance, in particular Dave Stephenson. He worked for
Sean Delaney. He was a head office finance expert and knew client

settlement inside out. He was all about financial probity. These people were

Page 25 of 42
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WITNO5210100

either technical or financial. I was working in combination between
Chesterfield and London. Sue Harding was also in these meetings. She was
in Chesterfield and had responsibility for the back end of the system including
error processing. She was the Head of Development in Chesterfield’s
Transaction Business Unit.

115. We monitored the incidence of errors via the data integrity report, prior to,
during and following conditional acceptance of CSR. It was a two pronged
approach. The first being the software update which put the onus on ICL
Pathway to understand the problem in their data and to introduce a fix and the
second element was the reporting on the error levels.

b. To what extent did ICL Pathway meet the conditions / criteria for
proceeding with roll out of the system in January 2000?

116. I have no direct recollection of any January 2000 updates. I may have been
absent or on annual leave and I note that I was not at the 14.01.20 meeting.
None of the documents assist me.

117. I have seen one traffic light report dated 15.11.99. The errors against
Acceptance Incident No. 376 are red. I have not seen any other reports to
prompt my memory of how this progressed between November 1999 and
January 2000.

118. There will have been other daily reports up to and after 15.11.99. I think I was
at the checkpoint meeting in November 1999 but I do not remember it and I
have seen no minutes of it. However, I am aware that this was prior to the
December 1999 software release.

c. Please describe the checks which were put in place to monitor the data

integrity and help desk issues which had emerged.

Page 26 of 42
119.

120.

121.

122.

123.

WITNO05210100
WITNO5210100

Daily and weekly reports were produced, covering the criteria and the checks.
There was also a traffic light system to help identify issues which had
emerged.

Acceptance Incident Nos. 376 and 408 were also covered in the daily and
weekly reports which were produced.

There were various formal and informal daily meetings as well as formal
meetings with ICL Pathway. The formal meetings are set out in Document
POL00028565. I believe that it is an accurate record of the steps taken to

resolve these issues.

. Did you consider these checks to be satisfactory? Please provide

reasons for your answer.

Yes. There was a process and a programme of regular meetings, where
everyone understood the inputs and outputs and I considered these checks to
be satisfactory.

What (if any) concerns did you have about the accounting integrity of
Horizon when roll out recommenced in January 2000?

Whilst I was not at the 14.01.20 meeting, I knew from working closely with
Dave Smith and Graeme Seedall that they were as concerned about
Acceptance Incident No. 376 as I was. I believe they would not have been
content with agreeing to the recommenced roll out in January 2000 unless the
criteria had been met. Against that background, whilst I have no direct
recollection of the events of January 2000, I believe that I must have been
satisfied regarding the position and the process for any residual exceptions

was defined.

Page 27 of 42
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WITNO5210100

f. What (if any) action did you take to report such concerns to others
within or outside Post Office Counters Limited?

124. I have explained above the concerns that I had regarding acceptance. I was
in constant dialogue with all stakeholders regarding accounting integrity
issues during late 1999 through the AWG and APG (both formally and
informally) and all concerns were shared and addressed with all relevant
persons both within and outside POCL. Additionally, I have referred above to
the role Peter Copping played in finessing the conditional acceptance
decision.

IMPACT PROGRAMME

Question 13: Please consider POL00038867, POL00038878, POL00038885,

POL00039624 and FUJ00090148 (WITN0521_01/59 to WITN0521_ 01/62).

a. Please describe and explain the principal business drivers for the
IMPACT programme.

125. The purpose of IMPACT was to define a wider scope of automated solutions
for the back end of POCL’s business, including new systems for reference
data, data integrity, training, helpdesks. It was similar in scope to what TIP
might have been before the decision was taken to proceed with Interim TIP. I
recall that it was a well-resourced project.

b. What was the nature of your involvement in the programme?

126. At this time, my role was an operational one and I was therefore involved as a
business stakeholder.

127. I was the General Manager of Network Support Services where I had
responsibility for cash centres and network support. I was issued with the

documents and reports which came out of the project teams because I was

Page 28 of 42
WITNO05210100
WITNO5210100

one of the business stakeholders. By this time Impact had a Programme

Manager which was Sue Harding.

c. What did you understand about the change(s) made to the use and
operation of branch suspense accounts?
128. Given my role at the time did not involve branches I am not in a position to
answer.
d. Please explain the rationale for such changes.
129. As above.
e. What effect did these changes have upon end users?
130. As above.
f. To what extent (if at all) were the views of end users taken into account
when these changes were made?
131. As above.
GENERAL

Question 14: Looking back, do you consider that POCL effectively scrutinized

the testing, trial and acceptance of the Horizon system?

132.

I have given this question my detailed consideration. On balance, I do feel
that POCL effectively scrutinised the testing, trial and acceptance of the
Horizon system. The system was rigorously tested which ensured that issues
were identified and appropriate plans put in place to rectify. This was made
more difficult by the nature of the PFI contract which meant that POCL’s
testers and IT teams did not have access to the system architecture and code
but this was understood at the time and testing and trialing was designed and

carried out with this in mind.

Page 29 of 42
WITNO05210100
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Question 15: Looking back, do you consider that the Horizon system was fit
for purpose at the point at which it was rolled out? If not, why do you consider
that the system was accepted and rolled out?

133. Looking back, my view is that Horizon was not perfect but I do consider that
the Horizon system was fit for purpose at the point of roll out. As far as I can
recall the APG accepted the system, on the basis there were measures in
place to ensure there were suitable workarounds and further system
developments designed to remove the known issues at the time of
acceptance.

Question 16. Are there any other matters that you consider will assist the

Chair?

134. 1am not aware of any other matters which I consider will assist the Chair.

Statement of Truth

I believe the content of this statement to be true.

Page 30 of 42
Signed:

Dated:13-10-22

Index to First Witness Statement of Ruth Reid

WITN05210100
WITNO5210100

No.

Exhibit number

Document
Description

Control
Number

URN

WITNO521_01/1

Report: TIP
Project: Working
Papers for the
Interim TIP case

POL-0028148

POL00031246

WITNO0521_01/1

Report: Progress
Report for
October 1996

POL-0028147

POL00031245

WITN0521_01/3

Email from Min
Burdett to Tim
O'Leary and
others® Re:
Stage 2 review
meeting 24/4/97

POL-0036230

POL00039672

WITN0521_01/4

PINICL Impact
Assessment Team
(PIAT) Process
Description (V.1),
17 Sept 1997

POINQ006857
7F

FUJ00078989

Page 31 of 42
WITN05210100
WITNO5210100

WITN0521_01/5

BA/POCL
Programme
Congo 4 (ICL
Pathway Release
1c), Full Business
Continuity Status
Report (The Full
Monty), No.1, Nov
1997, by Phil
Turnock

POL-0025080

POL00028598

WITN0521_01/6

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.1, Dec 1997,
by Phil Turnock

POL-0025078

POL00028596

WITN0521_01/7

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.2, Jan 1998,
by Phil Turnock

POL-0025077

POL00028595

WITN0521_01/8

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.3, Feb 1998,
by Phil Turnock

POL-0025079

POL00028597

WITN0521_01/9

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.4, March 1998,
by Dennis Wong

POL-0025076

POL00028594

Page 32 of 42
WITN05210100
WITNO5210100

10

WITN0521_01/10

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.6, May 1998,
by Dennis Wong

POL-0025073

POL00028591

11

WITNO521_01/11

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.7, June 1998,
by Phil Turnock

POL-0025071

POL00028589

12

WITN0521_01/12

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.8, July 1998,
by Dennis Wong

POL-0025074

POL00028592

13

WITN0521_ 01/13

Benefit Payment
End to End
Reconciliation
Process For ICL
Pathway Release
1c- PART 2
(Resolution)
(version 2.0).

POINQ006453
1F

FUJ00058360

14

WITN0521_01/14

Horizon
Programme
Congo 4 (ICL
Pathway Release
1c), Horizon
Service Report
No.10, Sept 1998,
by Dennis Wong

POL-0025072

POL00028590

Page 33 of 42
WITN05210100
WITNO5210100

15

WITN0521_01/15

Letter from Peter
Jones to Simon
Rilot re MO & E2E
Testing Issues

POL-0024910

POL00028428

16

WITN0521_01/16

Letter from Chris
Young, Horizon
Model Office Test
Manager to Peter
Jones re MO &
E2E Testing
Issues

POL-0024909

POL00028427

17

WITN0521_01/17

Email from Chris
Young toa
number of
individuals,
including, Peter
Jeram, Dave
Miller and Andrew
Simpkins, re
Minutes of Weekly
MOT/E2E
Progress Meeting,
19 March 1999

POINQ006826
2F

FUJ00078674

18

WITNO0521_01/18

Minutes of Weekly
MOT/E2E

Progress Meeting
45 18 March 1999

POINQ006826
3F

FUJ00078675

19

WITN0521_01/19

Email from James
Brett to a number
of individuals,
including, Peter
Jeram, Dave
Miller, John
Meagher, and
Andrew Simpkins,
re Issued MOT
Evaluation Report

POINQ006828
1F

FUJ00078693

20

WITN0521_01/20

Model Office
Testing Report for
Nile Release 2.0

POINQ006461
6F

FUJ00058445

Page 34 of 42
WITN05210100
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21

WITN0521_01/21

Review of the
POCLI/ICL
Pathway Deal by
Roger Tabor,
Finance Director
POCL (January
1999)

POL-0028132

POL00031230

22

WITN0521_01/22

EPOSS End-to-
End
Reconciliation
Process for
Release NR2 -
Incident
Management and
Resolution

VIS00001772

POL00000758

23

WITN0521_ 01/23

Automated
Payment End-to-
End
Reconciliation
Process for
Release NR2 -
Incident
Management &
Resolution 16
June 1999

V1IS00001790

POL00000776

24

WITNO0521_01/24

Horizon Plan for
Acceptance
During the ICL
Pathway
Operational Trial
(Version 2)

POL-0025619

POL00029137

25

WITNO0521_01/25

Collection of
Acceptance
Incident Forms for
various incidents
(various dates in
1999)

POL-0024839

POL00028357

Page 35 of 42
WITN05210100
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26

WITN0521_01/26

Acceptance
Board, Fourth
Meeting Minutes,
8 July 1999;
Acceptance Board
Terms of
Reference;
Acceptance
Guidelines for
Core System
Release dated 21
July 1999

POL-0024849

POL00028367

27

WITN0521_01/27

Horizon
Programme,
Management
Resolution
Meeting Minutes
(sent to PA
Consulting)

POL-0024814

POL00028332

28

WITNO0521_01/28

Electronic
memorandum by
the Post Office on
acceptance and
business impact.

POL-0026875

POL00030393

29

WITN0521_ 01/29

Output from
Tranche 3
Acceptance
Incident
Workshop, 10
August 1999

POL-0024846

POL00028364

Page 36 of 42
WITN05210100
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30

WITN0521_01/30

Letter to John
Dicks, Director of
Customer
Enquiries at ICL
Pathway from
Bruce McNiven,
Director of
Horizon
Programme re
Review of
Acceptance
Incident 218 -
Training - and
analysis of
evaluation against
business impact

POL-0024847

POL00028365

31

WITN0521_01/31

Email to Andy
Radka at POCL
from Keith Baines
at POCL re
system freezes
and response to
ICL

POL-0024848

POL00028366

32

WITNO0521_01/32

Letter from John
Dicks to Bruce
McNiven (cc Chris
French, Ruth
Holleran, John
Meagher and
Mike Coombs), 11
August 1999, re
outstanding
issues raised by
POCL

POINQ006874
7F

FUJ00079159

33

WITN0521_01/33

Horizon
Programme,
Management
Resolution
Meeting Minutes
(sent to PA
Consulting)

POL-0024814

POL00028332

Page 37 of 42
WITN05210100
WITNO5210100

34

WITN0521_ 01/34

POCL Meeting
Output:
Acceptance
Incidents
Discussed at
Meeting on 11th
August 1999

POL-0025613

POL00029131

35

WITN0521_01/35

Report Summary
on incidents
between POCL
and ICL Pathway

POL-0026874

POL00030392

36

WITN0521_ 01/36

Acceptance
Incident Hotlist
sent by email from
Tony Houghton

POL-0024837

POL00028355

37

WITNO0521_01/37

Email to John
Dicks at ICL
Pathway from
John Meagher at
POCL re Incident
Rectification Plans

POL-0024829

POL00028347

38

WITN0521_01/38

Follow on from
Acceptance
Update Meeting 2,
Agreed Output
and Actions, 24
August 1999

POL-0024959

POL00028477

39

WITN0521_01/39

Email from Jeff
Austin to POCL
employees, re
Continued
Acceptance
Incident
Monitoring and
Acceptance
Incident
Workshop, 25/26
August 1999
(emails, agenda
and Incident List)

POL-0024960

POL00028478

Page 38 of 42
WITN05210100
WITNO5210100

40

WITN0521_01/40

Memo from Post
Office re
Acceptance
Workshop Roles

POL-0024824

POL00028342

4

WITN0521_01/41

Acceptance
Update Meeting 3,
Agreed Output
and Actions, 27
August 1999

POL-0024958

POL00028476

42

WITNO0521_01/42

Email from Ruth
Holleran, POCL,
to Jeremy Folkes
& John Meagher,
POCL re Incident
298 (System
Stability) Target
Levels

POL-0024956

POL00028474

43

WITN0521_01/43

Internal POCL
email from Ruth
Holleran, re
Incident 218 (The
Training
Experience)
Success Criteria

POL-0024957

POL00028475

44

WITNO0521_01/44

Emails between
Keith Baines,
Ruth Holleran and
David Smith, all
POCL, re High Al
Re-classification
Tactics

POL-0024953

POL00028471

45

WITN0521_01/45

Horizon
Acceptance
Dispute
Workshop, Outline
Agenda and
accompanying
reports, 2
September 1999

POL-0024954

POL00028472

46

WITNO0521_01/46

Acceptance
Workshop (3)
Action Points, 2
Sept 1999 (draft)

POL-0024952

POL00028470

Page 39 of 42
WITN05210100
WITNO5210100

47

WITN0521_01/47

Email from Dave
Miller to Stuart
Sweetman,
POCL, re Horizon
Acceptance
Progress

POL-0024947

POL00028465

48

WITN0521_01/48

Email from
Andrew Simpkins
to POCL re 1999
Rollout

POL-0024943

POL00028461

49

WITN0521_01/49

Acceptance
Workshop (7) -
Action Points, 17
Sept 1999

POINQ006876
4F

FUJ00079176

50

WITN0521_01/50

Email from John
Meagher to Chris
French and Keith
Baines re
Acceptance
Decision Process
for 24 Nov 1999

POL-0025047

POL00028565

51

WITN0521_01/51

Email from John
Meagher to Chris
French re
Reference Data,
28 Oct 1999

POL-0025046

POL00028564

52

WITN0521_01/52

Email to Ruth
Holleran from
Keith Baines re
Conformance to
help desk scripts

POL-0025045

POL00028563

Page 40 of 42
WITN05210100
WITNO5210100

53

WITN0521_ 01/53

Letter from John
Dicks, Director of
Customer
Requirements at
ICL Pathway, to
John Meagher,
POCL re
acceptance
criteria and issues
with AI376 (Lack
of Data Integrity
on the Data
Stream Across the
TIP Interface), 5
Nov 1999

POL-0025043

POL00028561

54

WITN0521_01/54

Rollout 2000 Pre-
Checkpoint
Meeting Agenda
and Rollout 2000
Criteria -
Monitoring Report,
15 Nov 1999

POL-0025041

POL00028559

55

WITN0521_01/55

Emails between
Min Burdett,
Graeme Seedall,
Ruth Holleran,
Martin Box and
Keith Baines (all
POCL) re
Requirements for
continuing with
rollout

POL-0025040

POL00028558

56

WITN0521_01/56

Email from Min
Burdett, POCL to
other POCL
employees re
Rollout 2000
Decision- Actions
for the next 10
days (up to 3rd
December)

POL-0025024

POL00028542

Page 41 of 42
WITN05210100
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57

WITN0521_01/57

Horizon/Pathway
Delivery Meeting:
Special Meeting
Notes, 14 Jan
2000, sent by Dick
Brazear, Head of
Programme Office
for Post Office
Network to POCL
and ICL
employees

POL-0024991

POL00028509

58

WITN0521_01/58

Accounting &
Cash
Management
Programme,
Conceptual
Design (V. 3.1)

POL-0035349

POL00038867

59

WITN0521_01/59

Branch Trading
Reporting,
Management and
Control and
Transaction
Management,
Conceptual
Design (version
1.0)

POL-0035360

POL00038878

60

WITN0521_01/60

PO Ltd Financial
Systems Release
3 Conceptual
Design (V0.4)

POL-0035367

POL00038885

61

WITN0521_01/61

Communications
Plan Release S60
(v.0.1)

POL-0036108

POL00039624

62

WITN0521_01/62

PO Ltd Financial
Systems Release
3 Conceptual
Design (V1.0)

POINQ009631
OF

FUJ00090148

Page 42 of 42