Introduction
WITNO05780100
WITNO5780100
Witness Name: Paul Inwood
Statement No.: WITN05780100
Dated: 15 May 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF PAUL INWOOD
I, Paul Inwood, will say as follows:-
1. lama former employee of Post Office Limited (POL) and held the position
of Contracts and Policy Manager until 2018, when I left POL.
2. 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 25
August 2022 and 6 April 2023 (the “Request’). I have been asked by the
Inquiry to address both R9 requests in a single statement.
Background
3. I have been asked by the Inquiry to set out my roles within Post Office, my
qualifications, what training I received and my career progression within
Post office.
4. In respect of my roles within Post Office, I initially started as a Postal Officer;
serving customers in a Crown Post Office branch. I then became an
Assistant Branch Manager / Branch Manager, responsible for the day-to-
day operation of a Crown Post Office branch. Thereafter I became an Area
Manager (various job titles such as Business Development Manager, Retail
Network Manager). This role entailed supporting Branch Managers and
Sub-postmasters to improving key performance indicators e.g. sales,
customer service, improving retail offer. Some of these roles involved
WITNO05780100
WITNO5780100
Crown Post Offices only, some Sub-postmaster branches, and some were
mixed.
5. Between 2002 to 2004, I held the role, Contracts Manager for the Eastern
side of South East England; managing contractual issues with Sub-
postmasters and appointing Sub-postmasters.
6. Between 2005 to 2007, I held the role, Rural Development Manager /
Concept Design Manager. This role entailed designing pilot concepts for
providing Post Office services in rural areas.
7. Between 2007 to 2010, I held the role, Contracts Development Manager;
developing contracts and contract changes for managing the relationship
with Sub-postmasters.
8. Between 2011 to 2018, I held the role, Contracts and Policy Development
Manager. This role involved developing contracts, contract changes and
policies to support POL teams in managing the relationship with Sub-
postmasters. Note that the scope of this role did not include POLs policy on
prosecutions, as that was owned by legal services, nor did it include every
aspect of POLs relationship with Postmasters
9. The role of Contracts Manager was concerned with appointing Sub-
postmasters, and dealing with contractual issues that arose during a Sub-
postmasters time with POL. The subsequent roles were concerned with the
development of Sub-postmaster contracts and policies designed to assist
people in POL manage some of the issues that arose during a Sun-
postmasters time with POL. Prior to these roles, I cannot provide any
accurate dates and have no means to check.
10.1 confirm, I no longer work for POL, I left in 2018.
11.In respect of my qualifications, I have CSE, O and A levels and BTEC
level 4 management.
12. In respect of what training I have received, I received Health and Safety,
Sub-conscious bias , Horizon system user and Retail skills training.
13.Due to the amount of time that has since elapsed, I have no recollection of the
dates of this training and no means by which to check these. The training events
would have been very short periods of time spread out over a very long period of
time.
14.In respect of my career progression within Post Office, I moved from a
Postal Officer (counter clerk) role to junior management roles within the
WITNO05780100
WITNO5780100
Crown Post Office network. From there I undertook a number of middle
management type roles, including Area Manager roles in the Crown Post
Office and Agency Post Office network, as well as a 2-3 year spell as a
Contracts Manager based in Maidstone. This was part of a team of
Contracts Managers nationally, approximately 14 in number. From there I
obtained my first Senior Manager role at Head Office, working in the rural
strategy programme. After that, I was appointed to a role responsible for
developing Sub-postmaster contracts, and that role was then combined
with one responsible for Sub-postmaster policy i.e. guidance for POL teams
in managing issues and events in a Sub-postmasters life time with POL.
Advice and assistance
15.As an Area Manager, my contact with Sub-postmasters, Managers and
Assistant's working in a Post Office branch was face to face contact,
supporting Sub-postmasters in improving our key performance indicators
such as sales and customer service measures. As a Contracts Manager
my contact was mainly remote , normally where a contractual issue had
arisen, for example in cases of alleged negligence during a robbery or
possible contract breach. I would meet prospective Sub-postmasters for
interview. In subsequent roles, contact would be very limited and
infrequent, and would normally be confined to instances where a Sub-
postmaster had an issue or concern that required my expertise, for
example taxation status, or in cases where I was hearing an appeal against
summary termination of contract.
16.As an Area Manager and Contracts Manager I did provide Sub-
postmasters and Post Office branches with advice and assistance on
normally day to day matters affecting the operation of their business, that
would not be appropriate for referral to the helpline as it required a
particular expertise.
17.The issues would either be resolved by me, or I would ask the Sub-
postmaster to contact the Helpline (as that was the most appropriate way to
remedy the issue), or I would refer the matter to another team in POL who
were best placed to help the Sub-postmaster. In some cases, where
WITNO05780100
WITNO5780100
appropriate, I would notify the NFSP the Sub-postmaster needed their
assistance.
18. Difficulties involving the Horizon system were very rare, and it would be
confined to me hearing that the equipment had some form of catastrophic
failure and had caused the branch to close, for example after a power
spike, or a flood. In these instances, I would escalate matters internally.
19. Any concerns I raised were dealt with appropriately.
20. There is no one I felt could have done more to assist or make things better
for Sub-postmasters.
Training
21.Whilst managing the contracts of Sub-postmasters, to ensure that
individuals felt confident with using Horizon, I would listen to what the Sub-
postmaster was telling me in the context of the problem we were
discussing, and if there was any red flag re competency or confidence in
using Horizon I'd ask further questions to find out what the cause of the
concern was and react accordingly, for example by contacting the training /
support team.
22. If a Sub-postmaster had flagged up competency and / or confidence as an
issue, I would talk to our training team and seek additional support for the
Sub-postmaster on-site, and also discuss with the field support team.
23.1 do not feel that any improvements could have been made to the training
given to Sub-postmasters.
Resolution of Disputes
24.As a Contracts Manager, and subsequently as an Appeals Manager, I was
involved in disputes between the Post Office and Sub-postmasters
regarding alleged shortfalls of money..
25.The process by which disputes were raised and resolved, in the first
instance, disputes / discrepancies could be challenged with POLs financial
accounts team in Chesterfield, who would conduct an investigation and
where appropriate issue an error notice, amending the initial discrepancy in
whole or part.
WITNO05780100
WITNO5780100
26.In cases where that was not the case, upon receipt of the report from our
audit team and / or security team, I would consider the report in the context
of whether there had been any possible breach of contract by the Sub-
postmaster. In the event where I believed that there was sufficient evidence
to show that there had been a possible breach, I would issue the Sub-
postmaster with the standard letter, explaining the charges, and providing
them with the opportunity to attend for interview, or respond in writing. The
Sub-postmaster would either attend, often accompanied by a friend /
National Federation of Sub-postmasters (NFSP), or provide a written
statement. I would then evaluate the evidence provided by POL and the
Sub-postmaster / NFSP, to determine whether there had been a breach of
contract based on the balance of probability.
27. In the event there had been a breach, I would determine what I adjudged to
be the most appropriate outcome in the case and communicate that to the
Sub-postmaster. .
28.As an Appeals Manager, I would simply re-hear the case, conduct my own
investigation into events and call in any additional evidence required to
determine the case.
29.With regards to specific dispute cases I was involved in, due to the
passage of time I cannot recall specific details of the Sub-postmasters or
POL personnel involved.
30.1 am not aware of any contact or input from Fujitsu in the resolution of
disputes. As far as I can recall, any disputes or discrepancies would be
investigated by POLs Finance team in Chesterfield.
3
.I have been asked to give my view on whether there could have been any
improvement in this process. At the time no but given what I now know is in
the public domain regarding the fallibility of the Horizon system, yes. In
cases of a significant discrepancy the system should be interrogated to rule
out a ‘phantom’ discrepancy before any contractual action is taken. I’m
unsure who would be responsible for implementing this within the current
business structure, or in previous structures.
Appointment of Subpostmasters
WITNO05780100
WITNO5780100
32.1 have been asked to consider various documents in relation to policy,
procedure, recruitment of Sub-postmasters and their contracts
(POL00088903, POL00088900; POL00005671; POL00005670;
POL00005765; POL00005583 and POL00005776).
33. The process for the selection and appointment of new Sub-postmasters, I
believe that vacancies for Post Offices were advertised by POL on an
external portal where interested parties could progress an application.
Vacancies were advertised as either at, near, or at or near the existing
premises. Which of these would depend on the circumstances of the
vacancy e.g. whether the premises were being made available for
continued use as a Post Office.
34.It was normal for Sub-postmasters to advertise their retail business,
including the Post Office, using business transfer agents, or other means.
My recollection is that most of the work in the recruitment process was
undertaken by the agents HR team, and to a lesser extent POLs finance
team. As a Contracts Manager I would have been involved at the interview
stage only, completing an evidence based face to face interview, recording
the evidence and reaching a decision on the application in conjunction with
the Finance teams assessment. Sometimes I would be assisted by an Area
Manager .
35.After the period I was a Contracts Manager, the recruitment process
seemed to change a lot, however as I was no longer directly involved in this
process I wasn’t always aware of the details of such changes. Most of the
impact of these changes appeared to affect HRSC, Finance, and the
contracts team i.e. Contracts Managers and that teams administration. I
am unfamiliar with most of the documents above, except those concerned
with the appointment of temporary Sub-postmasters vacancies during
Network Transformation, and Death in Service. My recollection is that these
documents accurately set out how these issues should be managed within
POL from the dates of the policy issue.
36.The Network Transformation (NT) Programme was designed to enable a
large scale change of Post Office operating model from the traditional sub-
postmaster model to either a Main Post Office or Local Post Office model.
The programme provided for compensation payments for people opting to
leave the network, and payments for moving to one of the new operating
WITNO05780100
WITNO5780100
models. As far as I can recall, it ran for 3 to 4 years up to me leaving POL
in 2018. I was not employed within the Network Transformation
Programme, however I was tasked with producing Sub-postmaster
contracts to enable the roll out of the programme and the new Post Office
operating models.
37.1 cannot comment with any certainty with regards to the details of the
appointment process, documentation and decision making for new Sub-
postmasters in the Network Transformation Programme as I was not
directly involved in that process. It was managed by HRSC, contracts
teams and Finance. I am aware that on appointment, it was often the case
that the new contract would be for one of the two new Post Office operating
models ie Local or Main Post Office. I believe that which depended on the
scale of the existing Post Office operation, proximity to other Post Offices,
and according to a set of criteria determined by POL.
Contractual liability of Subpostmasters for shortfalls
38.1 have been asked to consider the various policies and guidelines
regarding recovery of shortfalls and losses, (POL00083939, POL00088904,
POL00086845, POL00088867 POL00030562, POL00088525,
POL00113670, POL00086868, POL00090357 and POL00088312).
39. My understanding of the contractual position as to the recoverability of Sub-
postmasters for shortfalls or losses was that Sub-postmasters were liable
for losses arising from their own carelessness, negligence or error, or for
the same by their assistants, as set out in the relevant contracts.
40. My understanding was that employees working in Crown Post Offices were
not required to make good shortfalls in their till, and that they were not
personally liable for such shortfalls. Instead, they were subject to a
performance management process linked to the amount and frequency of
such shortfalls, and this would be managed by the Crown Post Office team
and HR.
My role and the policies / practices in place relating to error notices,
transaction corrections (TC’s), transaction acknowledgements (TA’s).
branch discrepancies and “corrective action” taken against SPMs
WITNO05780100
WITNO5780100
41.My involvement in policies/practices in place relating to error notices,
transaction corrections, transaction acknowledgements, branch
discrepancies and correction action taken against sub-postmasters was as
follows. During my role as a Contracts Manager, cases where procedural
failings had been identified at audit, which in themselves would not warrant
any suspension, but may necessitate some corrective action, for example
additional training / support, and / or a warning letter reminding the Sub-
postmaster of their contractual obligations. That would be the extent of my
involvement with the issues described above; error notices, transaction
corrections etc would be managed by POLs product and branch accounting
team. I had no involvement or oversight of this.
42.1 have been asked to consider various policy and guidelines in relation to
recovery of loses and gains, debt recovery transaction correction process,
correcting accounts process etc. (POL00083939; POL00088904;
NFSP00000169; = NFSP00000043; POL00085794; POL00030562;
POL00083951; POL00083952; POL00039024; POL00039089;
POL00001642; POL00113670 POLO00086868; POL00090357 and
POL00088312).
43.My role and contribution to the formation of any policies/guidance,
governing error notices, transaction corrections, transaction
acknowledgements and branch discrepancies was extremely limited as
most of these processes were managed elsewhere in POL eg Finance. The
only document above I am familiar with is the 2013 policy document that
deals with in service debt. This policy was authored by me in consultation
with various other parties in POL. Its purpose is clearly set out in the
preface and my recollection is that it was an accurate reflection of POLs
commercial aims at that time.
44.1 am aware that an error notice was a notification to a Sub-postmaster that
would correct an error in their accounts, either a positive or negative impact
on the Post Office balance. A transaction correction was a digital i.e.
Horizon version of an error notice.
45.1 am not able to comment with any authority on circumstances in which
error notices and transaction error were issued, who issued them, what
options were open to Sub-postmsters, the process the Sub-postmaster was
to follow if a deficiency or surplus was discovered etc and any of the other
WITNO05780100
WITNO5780100
matters surrounding error notices and transaction corrections as I was not
directly involved in this area either in the design of the approach or its
implementation.
46.1 have been asked to explain what role the local suspense account played
before its removal. I have been asked to consider various documents in
relation to losses and gains policy, accounting loss policy, liability for losses
policy, security policy and authority to hold losses (WITN03980100,
POL00088904; POL00086845; POLO00088867and NFSP00000169).
47.1 was not involved with suspense accounts or their removal, so cannot
comment with any accuracy what was actually happening in POL, and how
whatever changes were made affected those concerned. I am not aware of
whether any or all of the approaches in the documents were properly
deployed. I believe that suspense accounts enabled Sub-postmasters to
hold discrepancies in suspense until it was clear whether an error notice or
Transaction Correction would be received correcting some or all of the
discrepancy, be that a loss or gain.
48.1 have been asked if by October 2005, as set out in document Debt
Recovery Process Under Branch Trading (POL00085794), the only option
open to sub-postmatsres who received a transaction correction, which they
did not understand or wished to challenge was to call the NBSC helpline. I
cannot accurately comment as this is not an area I was involved in or had
any oversight of.
49.1 have been asked if the sub-postmaster could not provide information at
the time of the call to the helpline to show that the transaction correction
was issued incorrectly the sub-postmaster was required to accept and
settle centrally, whilst further investigations took place. I cannot accurately
comment as this is not an area I was involved in or had any oversight of.
50.1 have been asked if from October 2005 discrepancies identified by a sub-
postmaster which they considered to be caused by a system error the only
option available to them was to call the NBSC helpline and seek agreement
of Product and Branch accounting to settle centrally whilst the matter was
investigated. I cannot accurately comment as this is not an area I was
involved in or had any oversight of.
51.1 have been asked, if settling centrally signified acceptance of the debt
liability as suggested in document, TC/Debt Recovery Review
WITNO05780100
WITNO5780100
(POL00001404). I cannot accurately comment as this is not an area I was
involved in or had any oversight of.
52.1 have been asked, apart from the application of a block on steps being
taken to recover centrally settled debt, was there anything to distinguish a
disputed debt from an undisputed debt. I cannot accurately comment as
this is not an area I was involved in or had any oversight of.
53.1 have been asked to consider if it was satisfactory that Sub-posmasters
were required to settle centrally even where they disputed
discrepancies/TC’s/ TA’s. I cannot accurately comment as this is not an
area I was involved in or had any oversight of.
54.1 have been asked if the process for challenging TC’s, TA/s/ discrepancies
meant that a deficiency or loss was assumed to have been caused by an
error or wrongdoing on the part of a Sub-postmaster, unless they proved
otherwise. I cannot accurately comment as this is not an area I was
involved in or had any oversight of.
Corrective Action taken by Subpostmasters
55.1 have been asked to consider the memo dated 15 February 2006 entitled
“Corrective Action for agents — Process, Timescales and Letters”
(POL00083945).
56.When I held the position, Contracts Manager I have no recollection ofwhat
steps would be taken when account errors which generated transactions
corrections were identified. I had no detailed knowledge or oversight of how
contracts teams were managing these issues in practice as I was not
responsible for managing these teams.
57.1 cannot comment on whether it was assumed that Sub -postmasters who
were receiving frequent transaction corrections were those yet to embrace
the changes and challenges the business faced and what support was
provided to them as I was not involved in the management of these issues.
58.1 have been asked to consider paragraph 3.4, Precautionary Suspension and
Summary termination (POL00005933), in the absence of evidence of
dishonest, what kind of material breach of the contract for services would
justify such action. I cannot comment as I was not involved in the design or
implementation of this approach.
WITNO05780100
WITNO5780100
59.1 did not have any involvement in corrective action against employees in
Crown office branches where accounting error or losses were identified ..
Suspension and termination
60.In my role as a Contracts Manager, up to 2004, I was involved in the
suspension of Sub-postmasters, and involved in dealing with alleged
material and non-material breaches of contract. Subsequent to that role, I
was an Appeals Manager, hearing appeals against summary termination (I
cannot recall the period of time in that role.) As far as I can recall, there
were no significant changes in approach whilst I was in these roles. Further
on, in my role as Contracts and Policy Development Manager, I authored
POLs policy to support contracts teams involved in dealing with alleged
breaches of contract. This change was implemented around 2014. The
policy set out clear guidelines for contracts teams how to manage and
document cases, and provided for a broader array of outcomes than
existing approaches e.g. suspended termination of contract.
6
.I have been asked to consider the various policy and guidance documents
in relation to Subpostmasters contract termination and suspension
(POL00088890; POL00088891; POL00084993; POL00086044;
POL00089004; POL00084002; POL00005856; POL00075610;
POL00086373; POL00088982; POL00005962; POL00086107;
POL00086005; POL00085448; POL00086005; POL00086358;
POL00086081; POL00086828; POL00086704; POL00087258;
POL00087259; POL00005933; POL00086116; POL00086772;
POL00086865; POL00088475; POL00087287; POL00087286;
POL00087287; POL00087291; POL00087292; POL00087288 and
POL00000325).
62.In terms of my involvement in relation to the formulation of any
policies/guidance applicable to suspensions, termination and appeals. I
was either involved in, or responsible for, the development of new
approaches for dealing with alleged breaches of contract, and matters
surrounding the consequences of such breaches, from around 2009
onwards. In some instances I would be asked to comment on related topics
being managed by other teams, and in other cases I would receive
WITNO05780100
WITNO5780100
instructions from more Senior Managers to improve existing approaches in
consultation with other key stakeholders at POL. The appeals policy and
process were not within my remit so I would have had no involvement in
that.
63.Depending on the size and nature of the discrepancy discovered at an
audit, the contracts team would decide whether a suspension was
warranted. At some stage this authority was removed and placed at a
higher level within POL, however I cannot recall the exact timing of that
change. The best estimate would be within the last 5 years of my time
there.
64.The decision to suspend a Sub-postmaster was made by Contracts
Advisor, however that was escalated by one or two tiers of management at
one stage. I cannot recall the timing of that.
65. The decision to suspend was decided on the circumstances as described
to them by the Lead Auditor. At some stage an informal financial threshold
was introduced e.g. shortages of £1k or more, and as I said above at some
point there was an escalation of decision making made.
66. The Sub-postmaster was informed of the suspension by the Lead Auditor
and then in writing by the Contracts Advisor.
67. Sub-postmasters were given the chance to make representation about the
suspension decision and explain the shortage to the Auditor, but beyond
that I wasn’t aware of any further formal opportunity.
68. Sub-postmasters were not remunerated for the period of their suspension.
69.In circumstances where a discrepancy and/or shortfall was identified the
Contracts Advisor was responsible for deciding whether to terminate a Sub
-postmasters contract. I recall some form of escalation of authority, but
cannot recall when.
70.Before a decision was made whether or not to terminate a Sub-
postmasters contract, an analysis of the information provided by the audit
team, the Sub-postmaster, NFSP, and any other relevant information
arising from their examination of the evidence, including any fact finding
obtained from other parties was carried out . A balance sheet of evidence
should have been drawn up to determine the outcome. Once a decision on
culpability was made, the Contracts Advisor should have determined what
WITNO05780100
WITNO5780100
in their opinion was the most appropriate outcome, and explain in their
written summary internally why they had discounted other options.
71. If it was decided not to terminate a contract, arrangements would be made
for the Sub-postmaster to be notified of that, and reinstated. A formal
handover would take place of the Post Office if a temporary Sub-
postmaster had been appointed.
72. In the case of a material breach of the contract proven upon the balance of
probability, that warranted summary termination.
73.1 have been asked what was the policy governing a Sub-postmasters
resignation to avoid summary termination. I cannot recall a generic ‘policy’
that spoke to the resignation in this context.The fact of that would be
recorded in the Postmasters personal papers and at HRSC.
74. Sub-postmasters did not have a right to appeal against the decision to
suspend them..
75. However, they did have the right to appeal against decisions to terminate
their contracts. The appeal would be allocated to a Senior Manager on the
national appeals panel, someone who _ had no prior involvement in the
case. The case would then be reheard by the Appeals Manager with the
appellant having the opportunity for a personal hearing supported by a
friend / NFSP. Sub-postmasters retained their right of appeal during my
time there. Operators of NT contracts did not have a right of appeal.
76.1 have been asked to consider an email dated 2 November 2012 from Alan
Lusher (POL00086048) and email dated 4 January 2013 from Alan Lusher
(POL00086428) and what training was provided to those who conducted
the appeal hearing. As I conducted appeal hearings, my recollection is that
I had some basic training on hearing appeals, re the process and decision
making.
77. When determining an appeal, all of the evidence in the case presented by
POL and the appellant was considered.
78.1 recall that Sub-postmasters had a right to make representations to POL
generally, although I cannot recall any formal trigger for such an
opportunity in the context of appeals.
79.In terms of any changes made to the Network Transformation Programme,
the appeal mechanism did not appear in NT contracts. This is because
there was a view in POL at the time that modern commercial contracts for
WITNO05780100
WITNO5780100
service would not have any such right i.e. appeals were a hallmark of a
contract of service, in other words, employment.
80.As far as I’m aware once an appeal decision was made, it was final,
however there may have been cases where further representations were
made, I am not aware of any.
Recovery of Agent Debt
81.1 have been asked to consider the various documents in relation to policy
and guidelines for recovery of agent debt (POL00083939; POL00105418;
POL00105417; POL00084977 POL00086338; POL00084995;
POL00088897; POL00002086; POL00113670 POL00086868;
POL00090357; POL00088312); POL00087471; POLO0086615 and
POL00043532
82.1 authored the policy in 2013 dealing with debt recovery. Beyond that my
only involvement would have been in responding to ad hoc enquiries
regarding the contractual position in specific cases of debt recovery.
83.1 cannot set out what involvement Contacts Manger/Contracts Advisors
had in decision making relating to agent debt dealt by the Financial
Services Centre (FSC) as I had no oversight of what contracts teams were
doing to manage these issues.
84.1 have been asked to explain the circumstances in which relief could be
granted from accounting losses and / or debt could be written off by the
Post Office. In addressing this, I have been asked to consider the various
documents: (POL00088904; POL00086845; POL00088867;
POL00030562; POL00030563; POL00087251 and POL00087252).
85. My recollection from time to time, Sub-postmasters would write to the Area
Manager, or Contracts Advisor, or others in POL, asking for relief from their
losses, and that such requests would be considered on their merits. The
only occasion where I would have experienced this would be during my
time as a Contracts Manager up until 2004. I cannot recall any specific
cases or explain how they were managed in POL after that time.
86.1 never had access to any data regarding how frequently a Sub-
postmastsers debt was written off so cannot comment.
WITNO05780100
WITNO5780100
Cases against Sub-postmasters
87.1 have been asked what my recollection is of some criminal cases (Nichola
Arch, Susan Hazzleton, Lisa Brennan, David Yates, Carl Page, David Blakey,
Tahir Mahmood, Oyeteju Adedayo, Hughie Thomas, Suzanne Palmer, Janet
Skinner, Jo Hamilton, Pauline Stonehouse, Susan Rudkin, Julian Wilson, Peter
Holmes, Seema Misra, Allison Henderson, Alison Hall, Joan Bailey, Lynette
Hutchings, Grant Allen, Khayyam Ishaq, Andela Sefton and Ann Neild) .I have
no recollection. As a Contracts Manager we were advised that the civil
aspect of a case was entirely separate to any criminal proceedings. It was
extremely rare and unusual to receive any contact from legal services
regarding the civil aspect.
88.In any of my roles within Post Office, I never played any part in criminal
prosecutions. To my knowledge these were managed in legal services /
POLs security team.
89.1 have been asked if I have any recollection of civil action against Sub-
postmansters (Asiam Ramtoola,' ‘evin Palmer, Rachel
Williams, Frank Holt, Susan McKnight, Tracey Etheridge, Katherine
McAlerney, Keith Macaldowie, Lee Castleton and Julie Wolstenholme). I
have no recollection of these civil cases.
90.1 have been asked if there were any civil matters I had involvement in which
are relevant to the matters being investigated by the inquiry (in particular
bugs, error and defects in the Horizon system. If the reported systemic
problems within the Horizon system were present in my position as a
Contracts Manager and then later as an Appeals Manager, then it is quite
possible that some or most of the cases of alleged breach of contract that I
had heard as a Contracts Manager were affected by these bugs etc. Most
of the cases of alleged breach resulted from audit shortages.
9
.I have been asked if I have any concerns about any civil cases in which I
was involved in, yes I do, for the reasons stated above. It is quite possible
that I made unsafe decisions as a Contracts Manager based on flawed /
incomplete evidence. I think that would apply to every Contracts Manager /
Advisor during the period of time. At the time I had to make decisions
based on the evidence before me, and there was no evidence that I had
sight of that the Horizon system was flawed.
WITNO05780100
WITNO5780100
Policy of Family Transfers
92.1 have been asked to consider the following documents, Agency Changes
Communiqué — Family Transfers (POLO00005769) and Family Transfers
dated 30 October 2017 (POL00005840).
93.1 authored the family transfer policy in 2017 in consultation with business
stakeholders.
94.It was necessary to set out , “If a Postmaster has had their contract
terminated by POL; or the Postmaster has resigned to avoid summary
termination, or they have served notice to terminate due to contractual
action being taken by POL, then the Family Transfer request should be
rejected”, because the family transfer policy was a concession that POL had
intended to be a supportive gesture to Sub-postmasters suffering some
difficulty, for example ill health. It was not a contractual entitlement. It was
not felt that termination or resignation to avoid that fell into that description.
95.1 have been asked if the policy documents influenced by the transfer of
contract at Post Office branch, The Grange from Suzanna Palmer (see
paragraph 91 above) to Kevin Palmer (see paragraph 64 above). No it was
not. I have no memory of these cases and I did not consider them or any
other cases when formulating the 2017 policy document.
Knowledge of bugs, errors and defects in the Horizon System
96.1 was not aware of any issues or problems with the Horizon system, except
for rare catastrophic failures in the hardware, where a swap out would be
required. In my role as a Contract Manager and as an Appeals Manager in
all of the cases I managed where there were discrepancies in Sub-
postmasters accounts, , I cannot recall one case where the Sub-postmaster
had attributed the problem to Horizon
97.Where I was aware that there had been some catastrophic failure of the
system, and there had then been some discrepancy at the branch that
necessitated contractual action, I would have referred the matter to an
internal team for further investigation.
98.During the final year of my service I had heard that it was possible for
Fujitsu engineers to gain ‘back door’ access into the system without the
WITNO05780100
WITNO5780100
knowledge of Sub-postmasters. That did give me some cause for concern
as I had previously heard a rebuttal to this internally. That aside I was not
aware of any concerns regarding the robustness of the Horizon system. I
had used the system myself on occasions, over a long period of time, and it
appeared to work well. I had not seen any evidence that it was not working
well. I had heard of a campaign by the Justice for Sub-postmasters group,
however we were assured internally that the system was sound.
99.1 have been asked to consider email from John Breeden to Angela Van-
Den-Bogerd, Sue Huggins and Others dated 05/12/2010 (POL00091384)
and asked how I became aware of this issue. I had heard a rumour
internally that POL had a problem in this regard to the GLO, specifically
that Fujitsu engineers could gain access remotely.
The Post Office Response to Second Sight
100. I have been asked to consider the following documents f POL00022167 and
POL00040235 and explain my involvement in relation to the post offices
response to the reports producted by Second Sight.To my recollection, I had
no involvement in the reports produced by Second Sight
Other Matters
101. There are no other matters which I wish to bring to the attention of the Chair to
the Inquiry.
Statement of Truth
I believe the content of this statement to be true.
Index to First Witness Statement of Paul Inwood
WITNO05780100
WITNO5780100
URN
Document Description
Control Number
POL00088903
Brief summary of certain sections of
the Subpostmasters contract dated17
December 2004
POL-0085961
POL00088900
Template ‘invitation to interview’
letter with extract from SPM contract
POL-0085958
POL00005671
Agency Changes Communiqué —
Subpostmaster Seminar Project — Pilot
Activities dated 26 October 2005
POL00005671
POL00005670
Agency Recruitment Policy - version
0.2 dated October 2008
V1S00006738
POL00005765
Appointment of Temporary Postmaster
Policy - final version , dated 2 February
2014
VIS00006833
POL00005583
Policy Document - Advertising
Vacancies During Network
Transformation dated 19 April 2015
VISO00006651
POL00005776
Death in Service dated 13 January
2016
ViS00006844
POL00083939
Losses at SPSO's: Guidelines on
responsibilities and recovery
arrangements”
POL-0080997
POL00088904
Losses and gains policy within the
POCL agency network - version 1
dated 20 November 1998
POL-0085962
10
POL00086845
Post Office Ltd — Security Policy:
Accounting losses policy for agency
branches - Version 1, dated February
POL-0083903
WITNO05780100
WITNO5780100
2003
1
POL00088867
“Post Office Ltd — Security Policy:
Liability for losses policy (for agency
branches0 - version 1 dated 7,
September 2003
POL-0085925
12
POL00030562
Post Office Ltd Losses policy —
overarching (branches)” (version 9,
effective date April 2006)
POL-0027044
13
POL00088525
Presentation on losses and gains
policy dated 20 January 2011
POL-0085583
14
POL00113670
Operators' In Service Debt -
Operators’ Lifecycle Issue - Policy
issue 8 dated 18 September 2013
POL-0112554
15
POLO0086868
Operators' In Service Debt - Operators’
Lifecycle Issue - Policy issue 8 dated
22 October 2013
POL-0083926
16
POL00090357
Policy document - postmasters'
lifecycle issue, policy issue 8,
version 2.0 dated 4 December 2014
POL-0087326
17
POL00088312
Policy document - postmasters'
lifecycle issue, policy issue 8,
version 3.0 dated April 2017
POL-0085370
18
NFSP00000169
Letter circulated to the National
Executive Council enclosing
correspondence regarding debt
recovery process dated 17
December 2004
VIS00007617
19
NFSP00000043
The draft policy “Debt recovery —
Horizon related errors” dated 18
November 2004,
VIS00007491
20
POL00085794
Debt Recovery Processes under
POL-0082852
WITNO05780100
WITNO5780100
Branch Trading” (October 2005)
21
POL00083951
Process for awaiting TC (Transaction
Correction) — Multiples Version 1 dated
15 December 2005
POL-0027044
22
POL00083952
Process for awaiting TC (Transaction
Correction) — Singletons Version 1
dated 15 December 2005
POL-0081009
23
POL00039024
Transaction Corrections Process
Review for Agency Branches - version
6b (draft, October 2007)
POL00083952
24
POL00039089
Operating Level Agreement: Product &
Branch Accounting, Network and
Service Delivery - version 1.0 dated 29
March 2009
POL-0035506
25
POL00001642
Review of the Creation and
Management of Transaction
Corrections in POLFS to Correct
Accounting Errors in Horizon - version
1.0 dated 10 February 2010
POL-0035571
26
WITNO3980100
Witness statement of Susan Harding
dated 4 October 2022
VIS00002656
27
POL00001404
TC/Debt Recovery Review — Key
Feedback issues
WITN03980100
28
POL00083945
Agency Changes Communique memo
- Corrective Action for agents —
Process, Timescales and Letters dated
15 February 2006
V1S00002418
29
POL00088890
Postmaster Contract Termination
Policy - version 3.0.
POL-0081003
30
POL00088891
Postmaster Guide to Policies - version
1.2
POL-0085948
WITNO05780100
WITNO5780100
31
POL00084993
Contract Advisor Process - Audit
Discrepancy
POL-0085949
32
POL00086044
“Subpostmaster suspension
POL-0082051
33
POL00089004
Managing Agents Contracts - version 3
dated 1 January 2001
POL-0083102
POL00084002
Outlet Support — Audit Contact Points -
version 2 dated September 2006
POL-0080965
35
POL00005856
Post Office Limited: Appeals
Handbook dated 19 June 2008
POL-0081060
36
POL00075610
Agency Changes Communiqué —
Deployment of Post office operating
models in cases of summary
termination and resignation to avoid
summary termination dated 11
December 2009.
VIS00006924
37
POL00086373
The email dated 21 December 2009 re
ACC 12/2009 deployment of Post
Office
POL-0072173
38
POL00088982
Draft wording - Dealing with proven
serious contract breaches: guidance
for Contracts Advisors and Appeals
Managers
POL00086373
39
POL00005962
Sub-postmaster Appeals Panel
Process - version 1 dated 23 March
2011
POL-0080943
40
POL00086107
SOMR Appeals Process Flowchart V1
— dated 23 March 2011
VIS00007030
41
POL00086005
Agency Changes Communiqué —
Policy and Process Amendments to
POL-0083165
WITNO05780100
WITNO5780100
ACC 12/2009 (Deployment of Post
Office operating models in cases of
summary termination and resignation
to avoid summary termination) dated 6
June 2011)
42
POL00085448
Agency Changes Communiqué ACC -
Company Operated Post Office
branches: dealing with resignation of
and applications from existing
Operators dated 20 May 2011
POL-0083063
43
POL00086005
Agency Changes Communiqué ACC -
Policy and Process Amendments to
ACC 12/2009 (Deployment of Post
Office operating models in cases of
summary termination and resignation
to avoid summary termination) dated
16 June 2011)
POL-0082506
44
POL00086358
Managing shortages at Audit:
Process and Policy guidelines
POL-0083063
45
POL00086081
Flowchart - Managing Shortages at
Audit:
POL-0083416
46
POL00086828
Subpostmaster Appeal Panel Process
Review dated March 2012
POL-0083139
47
POL00086704
Agency Changes Communique (ACC)
- Guidance to Post Office Ltd
personnel dealing with requests from
Post Office Ltd Operators to be
accompanied by a friend at interview
dated 25 June 2012.
POL-0083886
48
POL00087258
Email from Nigel Allen to Anita
Bravata, Craig Tuthill and others re:
FW: Horizon Challenge Cases -
Process to be adopted - Take 2.
POL-0083762
49
POL00087259
Horizon Challenge Process
Attachment dated 29 August 2012
POL-0084316
WITNO05780100
WITNO5780100
50
POL00005933
Precautionary Suspension Policy
dated 7 October 2012
POL-0084317
51
POL00086116
“Guiding Principles for Suspension
dated 2 November 2012
ViS00007001
52
POL00086772
Proposed Approach To Dealing With
Subpostmaster Breaches - draft 1
dated 21 August 2013
POL-0083174
53
POLO0086865
Policy Document - Contract Breach
dated 4 February 2014.
POL-0083830
POL00088475
Policy Document — Contract Breach
dated 7 April 2014
POL-0083923
55
POL00087287
Conduct Management New Model
Agreements: Process and Policy
Guidelines - version 3.56 dated 29
May 2014
POL-0085533
56
POL00087286
Email from Robert Findlay to John
Breeden and others re: New
Agreement Conduct Process.
POL-0084345
57
POL00087287
Conduct Management New Model
Agreements: Process and Policy
Guidelines”
POL-0084344
58
POL00087291
Managing shortages at Audit
(Traditional Branches/NT Converters):
Process and Policy Guidelines
POL-0084345
59
POL00087292
Traditional Conduct Process
POL-0084349
60
POL00087288
New Model Agreement
Conduct/Performance
POL-0084350
WITNO05780100
WITNO5780100
61
POL00000325
Postmaster Support Policies:
Termination Decision Review Policy -
version 2.3 dated 30 March 2021
POL-0084346
62
POL00086048
Email dated 2 November 2012 from
Alan Lusher to Laura Tarling, Mark
Lawrence, Mark Right, Paul Inwood
& Others — re ‘Appeals Panel
Refresher Training - Monday 26
November 2012'
VviIS00001299
63
POL00086428
Email dated 4 January 2013 from
Alan Lusher to Mark Wright, Paul
Inwood, Sheila Mccann and others -
re: Appeals Panel Refresher
Training - Thursday 31st January -
11:00 to 16:30
POL-0083106
64
POL00083939
Losses at SPSO’s: Guidelines on
responsibilities and recovery
arrangements issued 1998
POL-0083486
65
POL00105418
Email dated 6 November 2007 from
Gayle Laverick to Lynn Hobbs, John
Breeden re. Network Efficiencies
POL-0080997
66
POL00105417
Summary of discussion on
Compliance, Conformance, Losses
and Debt
POL-0104526
67
POL00084977
Former Subpostmaster End to End
Debt Review - version 0.5 dated
December 2009
POL-0104525
68
POL00086338
Presentation on “Former Agents Debt
by Alison Bolsover
POL-0082035
69
POL00084995
Back Office Efficiency Programme:
Debt Review Workshop Output -
version 1.0, 13 October 2009
POL-0083396
70
POL00088897
Working agreement — “Finance Service
POL-0082053
WITNO05780100
WITNO5780100
Centre and Networt
71
POL00002086
Fraud & Conformance Team Handover
Document dated 3 March 2012,
revised July 2012
POL-0085955
72
POL00087471
Former Agents Debt Management -
version 1.0 dated 4 December 2014
VIS00003100
73
POL00086615
Email 2013 Email exchange dated 5
April 2013 between Jessica
Madron, Jacqueline Witham, Paul
Inwood, Ravi Chauhan regarding
recovering SPM' debt.
POL-0084529
74
POL00043532
Email dated 12 February 2014 from
Craig Tuthill to Angela Van-Den-
Bogerd, Nick Bea! and John
Breeden re: MoneyGram Fraud
POL-0083673
75
POL00030563
appendix 5 “Process for seeking relief
on losses — singletons”
POL-0040035
76
POL00087251
Email dated 12 Febryuaray 2014
from Craig Tuthill to Angela Van-
Den-Bogerd, Nick Beal and John
Breeden re: MoneyGram Fraud
POL-0040035
77
POL00087252
Branch Write Off Process dated 5
December 2013
POL-0084310
78
POL00005769
“Agency Changes Communiqué” —
“Family Transfers January 2011
V1S00006837
79
POL00005840
Family Transfers dated 30 October
2017
VIS00006908
80
POL00091384
Email chain dated 5 December 2010
between John Bredeen, Angela
Van-Den-Bogerd, Sue Higgins and
others RE: Follow up to BIS meeting
POL-0090406
WITNO05780100
WITNO5780100
on JFSA
81
POL00022167
Second Sight Mediation Briefing
Report. Draft (V2) 30 July 2014:
Reactive comments regarding
subpostmaster contract
POL-0018646
82
POL00040235
Email dated 21 August 2014 from
Belinda Crowe to Paul Inwood,
Craig Tuthill RE: Fwd Part 2 Report
POL-0036717