WITN06160100 Gayle Peacock - Witness Statement

Evidence on official site

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Witness Name: Gayle Peacock
Statement No. WITN06160100

Dated: 31/01/2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF GAYLE PEACOCK

1, Gayle Peacock, will say as follows:

INTRODUCTION

1.

3.

lam a former employee of Post Office Ltd and held various positions of mid to
senior management levels between November 2001 until I left the business in June

2021.

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 4" January 2022
(the “Request’). The information I have provided in this statement is based on
my own personal recollection of events. I did not have access to any
documentation to assist me when answering the questions, with the exception of
the documentation provided to myself by the Inquiry. I have not sought legal

representation in the drafting of this statement.

I would like to make the Inquiry aware that the business re-organised itself

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structurally a number of times during my employment. Whilst I am confident in
the names of the roles I performed, the references I make to specific roles are

from my memory and therefore I may not have the job title 100% correct.

General

4.

7.

I graduated in 1999 and initially had a career in the hospitality industry,

eventually being a Public House Manager before joining the Post Office.

I started working for the Post Office in November 2001 as part of the Graduate
Management Training scheme. This was a 12-month scheme which involved
working for 6 months in a Directly Managed Branch, learning all operational
aspects of working in a Post Office. This was followed by 6 months working in
the Agency Commercial Segment, shadowing an Area Manager responsible for
managing an area of larger postmaster-run branches. On completion of the
secondment, it was my responsibility to find a permanent role within Post Office.
I worked for the Post Office for nearly 20 years and undertook various roles. I
have outlined below the name of the role, the period in which I undertook it, and
a high-level view of my responsibilities. The gaps in the timeline were due to

periods of maternity leave.

Rural Retail Line Manager (Nov 2002 — Jan 2004) — I worked with c.60
postmasters in larger rural branches to help drive improvement in all aspects of

their business.

Network Concept Manager — (Jan 2004 — Oct 2006) — I designed, deployed and

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tested new branch operating models and concepts. This did not involve changing
the use of the Horizon system but developing the operating model of Core and

outreaches.

8. Head of Network Co-ordination — (Oct 2006 — Jan 2010) — I was responsible for

leading a team to provide remote non-sales support for all postmaster operated

branches.

9. Program Manager, Our Best Way Project — (Jan 2010 - Nov 2010) — I led the
Program that tested the deployment of a LEAN tools and techniques in the

Directly Managed Branch network to improve customer service standards.

10.Network Conformance, Standards and Policy Manager — (Oct 2011 — April 2013)
I led a team responsible for providing remote support to branches to help them
achieve the standards required to fulfil regulatory, legal, client and customer

obligations.

11.Head of Branch Support Project — (Apr 2013 — Sept 2014) — I was responsible
for managing the program to review the training and support provided to

postmasters following the Second Sight Review.

12.Business Readiness Lead, Front Office Project — (July 2015 — Nov 2015) — I was
a business Subject Matter Expert (SME) working with other business SMEs and
the potential new supplier IBM who were initially contracted to replace the branch

Horizon system.

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13.Head of Branch and Customer Support — (Nov 2015 — Sep 2018) — I was
responsible for managing the Branch Support Centre (the branch helpline
previously known as the Network Business Support Centre), managing
Customer Care teams, managing the Post Office Executive Correspondence
team, managing the Post Office Model Office in Finsbury Dials HQ, managing

the Network Gateway team and chairing the Branch User Forum.

14. Head of Performance and Support, Supply Chain — (Sept 2018 — Dec 2020) - I
was responsible for managing the Supply Chain change portfolio and providing

performance information to the operational teams.

15.Business Lead, Postmaster Journey Project — (Dec 2020 — June 2021) — I was
the Post Office lead supporting colleagues from Deloitte completing a review
initiated to inform the Group Executive and leadership teams of the extent to
which Post Office had effective change and service plans in place to transform
the culture of Post Office and the relationship with postmasters. The purpose
was to undertake a holistic, independent review of changes to processes, policy,

people and culture following the Group Litigation.

16.1 have been asked to explain when I used the Horizon IT system in the course of
my work and how my roles related to the Horizon IT System between 2000 and
2012. I can confirm that the only period of my career when I used the Horizon
system directly was during the first six months of the Graduate Training Scheme
where I was seconded to Middlesbrough Post Office branch. I was trained in a

Counter Training Office for two weeks before arriving in branch, and then I used
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the system on a daily basis to serve customers and to also complete branch
balancing activities. Following that period my direct use of Horizon was limited. I
was required to work on the counter in Directly Managed Branches during
periods of Industrial Action and attended the refresher training courses before

doing so.

17.1 have been asked to confirm the details of my position in the organization
structure for the delivery of the training of the Horizon IT System. From 2001 until
2006, I was not in the same function as those that were responsible for the
design and delivery of the training. From my recollection, I believe that this was
carried out by a central HR function within Post Office. There was a large-scale
business reorganization in 2006 and the responsibility for training was
transferred from HR into the Network Directorate. This is when I reported into
the Network Support Director and the responsibility for training was transferred
from into this function. The ownership for design and delivery of training sat with

my peers in the team who ran the Network Support Field Teams.

Program(s

18.1 have been asked to provide an overview of the training program(s) with which I
had involvement at the Post Office between 2000 and 2012. Along with this, I
have been asked to provide very specific information regarding the training
content, changes to content etc. As noted above, developing and deploying the
Horizon system training was not my area of responsibility and therefore the

individuals responsible for the Network Support Field Team would be best placed
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to provide that detailed information. What I can provide is a high-level summary

of what training offer was I believed the training offer to be.

19.From 2006, the Heads of Network Support Field Team were responsible to the

design and delivery of the training for postmasters and employees of Post Office.

20. The offer for postmasters was a classroom-based course in one of the regional

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Counter Training Offices. The classroom training would cover a range of
transactions including mails, benefit payments, banking, DVLA if appropriate and
the relevant balancing activities. This was designed as a familiarization of the

system before taking over the Post Office branch.

.When the new postmaster took over their branch, a Network Support Adviser

would attend the transfer. They would then attend the branch and conduct in-
branch training for a period of time. I think this was a week from recollection and
possibly longer for larger branches as they usually conducted a wider range of
transactions such as DVLA, passports, bureau de change etc. The postmaster
would then receive a follow-up visit when they next conducted a branch balance.
A Network Support Adviser would then visit the branch at various intervals up

until about 6 months after the postmaster was appointed.

22.For employees who went to work in Directly Managed Branches, it was the

responsibility of the Branch Manager to complete the induction after the

colleague had attended the classroom training course.

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23.The classroom training and in-branch training was aimed at the postmaster, but it
was not mandatory to attend. The postmaster was responsible for training their
own staff, as noted in the postmaster contract. However, in practice if there were
spaces in the classroom, postmaster spouses, staff or managers could attend as
well. When the Network Support Advisor attended branch, whilst the training was
aimed at the postmaster, in reality, training would be offered to everyone who
was working. This would depend on whether there was a complete change of

staff on branch transfer.

24.Network Support Field Advisors made notes of what was trained out and
postmaster capability following each visit. This information was made available
centrally should a different colleague be scheduled to complete the post-transfer

follow-up visits.

25. Following the completion of the training, postmasters could request further
support regarding training. From 2006, this request was made via the branch
helpline, NBSC, who passed the request to the Network Support Scheduling
Team to respond to the request. Other teams could also make extra training
requests from this team should it be required. This included Contract Managers,
Area Managers, Cash Management, Product and Branch Accounting or
members of my team who when interacting with the branch felt that extra training

was required.

26.In respect of what training was in place for members of Post Office in relation to
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the Horizon IT System and wider Post Office activities, I do not know the answer
to the question. Recruitment for employees was the responsibility of HR and
from my experience of recruiting my own team members, it was up to the hiring
manager to develop and complete the induction plan for new colleagues. I did
not believe that a standard induction plan was available. Hiring managers could
have arranged new colleagues to attend the classroom training, but this was not

a mandatory requirement as far as I was aware.

27.1 did not have any involvement in the Training Reviews of 2010.

28.1 did not have any involvement in the 2011 Training Review.

29.1 have assumed the question regarding my involvement in any training
program(s) between 2000 and 2012 to be specifically related to the Horizon IT

system.

30.In terms of wider training programs, I did act as a business SME regarding the
various compliance training modules that were developed in the wider business.
These training programs including modules such as Anti-Money Laundering,
Financial Services Compliance, Information Security, Data Protection etc. This
training did not focus on the Horizon transactional procedures but more about
roles, responsibilities, regulatory and legal obligations and the consequences of

not complying.

31.The content was drafted by the relevant business owner with input from myself
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and other stakeholders. The completion of the training usually required all

postmasters and their assistants to take a test on the Horizon system.

32.In order to help postmasters understand what they needed to do and when, it
was my team when working as Head of Network Co-ordination and then latterly
as Network Conformance, Standards and Policy Manager who would send
reminders to branches of the requirement to complete the training. This was via
the Branch Focus Magazine and via Memoviews on Horizon. It was my team
who were then responsible on behalf of Network for ensuring all branches had

completed the required training.

33.1 have been asked to consider document titled BOMP [POL00032992]. Whilst
there is no date or author on the document, from the title of it identified as
“BOMP’”, I assume this to stand for the Branch Office Management Programme
training. This was the training that was offered by the Network Support Field
teams for the training of Branch Managers who were directly employed by Post

Office.

34.1 believe the contents of the course were developed by the Network Support
Field teams in conjunction with the Directly Managed General Manager and the
respective management teams. The Directly Managed team were responsible for
recruitment and performance of the c.400 branches they were responsible for but
called on the Network Support team to conduct certain elements of training,

including the use of Horizon.

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35.The agenda within the document POL0003992 refers to an “Our Best Way” item.
It indicates that the team were contacting me for information to include. I cannot
recollect what information was provided to them and what ended up being
included within the session. The training courses usually had a supporting
PowerPoint presentation which I don’t have access to in order to refresh my

memory.

36. The “Our Best Way” program was an initiative I was asked to lead in 2010. A
pilot had taken place in two Directly Managed branches with an external LEAN
consultancy who has tested and deployed new branches ways of working with
the aim to improve customer service and colleague engagement. Before rolling
the initiatives out to the whole of the Directly Managed network, the Directly
Managed General Manager want to test whether the tools would be effective in a

larger sample of branches.

37.As a result, I led a small team of internal resources trained in LEAN to train the
25 Branch Managers in the Manchester area in the new ways of working and to

measure the result.

38.The results of the project identified that it was not commercially viable to deploy
the full program. However, there were some learnings and tools that the Directly
Managed management team wanted to incorporate into standard ways of
working, and therefore they were incorporated into the training. I cannot
remember the specific tools that were chosen. However, I can confirm that none

of them required the use of the Horizon system.
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39.1 have been asked to consider Branch Support Programme — Training
Workstream [POL00034746]. The document is a workstream Terms of

Reference that I drafted as part of the Branch Support Program.

40. The overall program had a number of workstreams. The approach of the
program was to complete a gap analysis regarding the training and support
offered to postmasters. The findings of that analysis then informed the creation

of a number of work streams. The Training Work Stream was one of these.

41.It was my role as Program Manager to ensure that the work streams had a clear
scope, budget and had the resources available to deliver the desired outcomes. I
was then responsible for ensuring the work streams were being project managed

correctly.

42. The scope of this work stream was to investigate the development and use of an
on-line learning platform. Whilst Post Office employees had access to a learning
system, postmasters and their assistants did not. This meant that all learning
was undertaken on paper or on tests completed on the Horizon system.
Therefore, all learning had to be done whilst in branch and the Horizon system
couldn’t manage interactive learning content. Developing an on-line learning
platform would improve the quality of the training but also open up the
opportunity to include wider learning content that would support postmasters in

the running of their business.

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43. The colleagues who worked as part of the work stream are named in the
document. They were, Sarah Malone, Ann Miller, Drew McBride, Julie Thomas,
Pam Heap, Julia Marwood, Sue Richardson, Gabriella Driver, Debbie Young and
Claire Langley. These colleagues represented the central Learning and
Development function, Network Support Field Teams, and the Directly Managed

Network.

44.1 have been asked whether I thought this training was adequate. However, this is
an unclear question relating to the document to which I’m referred. It was clear
that the overall training to postmasters needed to be improved and therefore the
work stream was established in order to help remedy that for the reasons

outlined above.

Advice and Assistance

45.1 have been asked to consider various documents [POL00084463,
POL00084464, POL00084465, POL00084768, POL00084769, POL00084770,
POL00084771, POL00084772, POL00084773, POL00084774, POL00084775,
POL00032992, POL00039158, POL0005690 and POL00005939]. The majority
of these documents relate to the Branch Standards booklet and associated
contractual change documentation with the exception of documents

POL00032992 and POL00039158.

46. It was unclear whether the specific sub-questions associated with this question
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wanted an answer regarding these documents specifically or a more general
answer regarding my role in providing postmasters with Branch Support. After
seeking clarification from the Inquiry Team, I have been advised to outline as
much information as possible regarding Branch Support. Therefore, the
approach I have taken is to reference each of my roles in turn and outline my

role in providing postmaster Branch support.

47.During my time as a Rural Retail Line Manager, I was responsible for providing
all different kinds of support to the branches in my area. The Network Business
Support Centre was the first point of call for branches to resolve transactional
queries including help with balancing procedures. My remit for support covered a
wide remit from supporting branches with sales coaching conversations, helping
with requests to undertake additional products and services, supporting after
branches incidents such as robberies and burglaries, resolving customer
complaints, dealing with requests to change opening hours, authorizing
temporary closures, ensuring they were following the correct security
procedures, checking they were completing their cash accounts and providing
general pastoral support. I was usually the point of escalation where the
business process didn’t appear to be working. For example, if there was a
dispute between Cash Management and the branch regarding cash holdings, I
would help resolve the issue. I would find the relevant internal business team to
escalate to. We were not asked to track the types of issues we were resolving for

postmasters.

48.1 tailored my visit program depending on the experience of the postmaster but
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would ensure that each branch was visited at least every quarter at an agreed
time with the postmaster. I visited larger branches on a monthly basis and new
postmasters on a more regular basis. For new postmasters, I would review their
progress and if I felt that they needed extra training, then I would raise a request
for the training team to attend. It was agreed with the postmaster the level of visit
frequency they felt appropriate. They could contact me at any time in between for

any issues or questions they had.

49.One of the responsibilities of the Rural Retail Line Manager was to line manage
a team member. I can’t recall the exact name of the role but seem to think it was
something like Rural Support Advisor. Whilst I was responsible for visiting the
larger branches, these colleagues would undertake a visiting program to ensure
that all of the smaller rural branches received a branch visit at least once a year.
As these branches were so small that they did not have an opportunity to sell
many products due to the low customer footfall, the focus of these visits was to
cover areas such as customer service, branch balancing performance, general
issues, and checking standards etc. If an issue was raised to them, they would

escalate it in the same way I would as a Rural Retail Line Manager.

50.During my time as Network Concept Manager, I was working directly with pilot
Core sub postmasters in the testing of new branch outreach operating models
including the Partner and Home Service model. I was their direct point of contact
for helping them test the model and was responsible for answering any
operational questions regarding the concept. If I needed to escalate anything,

this would have been to the Rural Strategy Program team. However, I cannot
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recall an instance where I needed to. I did not get involved in the business-as-
usual element of the postmasters running their branch. The Core branches
chosen to operate within the pilot did have Area Managers who we worked
closely with. If there was an issue that the postmaster raised with us regarding
the day to day running of their Core branch, then this would have been flagged to
the Area Manager to help resolve. I cannot recall a time where I ever had to do

this.

.I was appointed to the Head of Network Co-ordination role in 2006. This was

following a large-scale business reorganization. The Post Office had a Sales and
Service structure prior to that time. This was a national team based out of 11
Area Intervention Offices located across the regions within England, Scotland,
Northern Ireland and Wales. I do not know the exact numbers within the team,
but their role was to physically visit branches to support them and resolve any
kind of service issue. The business decision was to remove this structure and I
was asked to set up the Outlet Intervention Team in Maidstone in 2006 to
provide remote telephone intervention support. Further detail of the team and the

support they offered can be found in paragraphs 96,108,109 and 110.

52.As part of this role, my team also consisted of four Network Co-ordination

Managers. They were aligned to the different area of the business to look at
levels of service being provided to branches and look at process improvements,
including the Network Business Support Centre, Cash Management, Product
and Branch Accounting etc. The team would work with the Area Managers and

the Outlet Intervention Teams to understand what issues branches were facing.
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They built relationships across different directorates to understand what they
were doing that would impact branches and implement improvement

opportunities

53.Whilst conducting this role I was also asked to run the Network Efficiency
Program. This involved the establishment of the Branch Standards Team. More
detail about the support provided to postmasters is provided within paragraphs

74 and 80 through to 89.

54.In 2010, I was seconded to run the Our Best Way Program in the Directly
Managed network and therefore did not normally support postmasters. The
exception to this was in the support provided to branches following an incident.
The business process had been set up that managers would be tagged to
branches near to the location where they lived. We were then the first point of
contact to offer support to postmasters both in and out of hours if they were not

part of the Area Managed branch network.

55.1 returned to the Network Conformance, Standards and Policy Manager role in
2011 following a period of maternity leave. There had been a further business re-
structure during my absence, but I maintained responsibility for the Branch
Standards Team. I have explained the structure and the role of the team in

providing support to branches in paragraphs 80 through to 89 below.

56.1 did this role until 2013 when I was asked to lead the Branch Support Program.

As part of this role, I did not support postmasters directly, but one of the tasks of
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my role was to review the support provided to postmasters. Further detail

regarding this role has been explained in paragraphs 90 through to 93.

57.My next role which had direct involvement with supporting postmasters was
when I became the Head of Branch Support in 2015. My remit was the
management of the branch helpline, (which became known as the Branch
Support Centre rather than Network Business Support Centre), the Network
Gateway Team, the Executive Correspondence Team, and the Customer Care
Team. Within this role, I was responsible for colleagues providing immediate

support to branches over the phone, 7 days a week.

58.The requests made to the Branch Support Centre for resolving were varied
ranging from transactional help, balancing help, business process questions,
request to close or change opening hours. Whilst the helpline IVR telephony
system was a one number system for the postmasters to ring, calls regarding
branch incidents were answered by Grapevine, and the IT Service Desk
answered queries regarding IT equipment including Horizon. The Security Team
were responsible for managing the service with Grapevine and the IT team were

responsible for managing the IT Service desk.

59.Calls were categorized by the advisor and the data was available so we could
understand the main drivers for the types of calls. I don’t have access to the
data, but from memory, the types of calls relating to Mails, Stock codes, and

balancing were the main call categories.

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60.One of the issues when I took over the helpline was the quality of the data

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available in order to undertake the analysis. The system they were using did not
enable detailed interrogation. Options for Case Management solutions had been
identified as part of the Branch Support Program and I was able to implement a
Microsoft Dynamics Case Management tool across Branch and Customer
Support and wider back-office teams in 2017. This enabled the provision of
better call categorization to provide better data with regards to what was driving
the calls into the centre. It also provided the ability to keep all communicated
relating to that branch query within one record, regardless of who it was passed

to in the business.

.My remit whilst in this role was the management of the Executive

Correspondence Team. This was the team who managed complaints directed to
the Chief Executive and the Group Executive both from external customers,
stakeholders and also postmasters. It was the role of the team to ensure the
complaint or issue was raised to the relevant senior manager to resolve and

provide support.

62. The types of correspondence raised were varied. Depending on who was raising

the complaint, it could range from complaints from members of the public about
not having a post office branch in their community, poor customer service
standards, allegations of being sold the wrong service or product availability.
Complaints from postmasters were also varied and from memory related to

contractual issues, policy decisions, cash management reducing cash deliveries
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to the branch, Royal Mail issues etc.

63.Each case was logged and tracked regarding who was resolving. This was done
via spreadsheets until the introduction of the Case Management Tool. I do not
have access to the data that confirms the exact numbers and types of cases that
were resolved. The team were involved in formal responses and were informed
about how the issue would be resolved. This depended on the circumstance but
could include arranging someone to visit the branch, having a phone call with
someone senior or apologizing. Where there were learning opportunities to
prevent further occurrences, this would be discussed with the business owner
who would take responsibility for implementing any necessary changes to

process.

64. Cases were discussed on a regular basis, usually weekly. The team would flag
any cases to me in between where they felt they weren’t getting the right support
from the teams who were required to support in the resolution. In these
instances, I would approach the senior management team where it had been

sent and work with them to agree the approach for responding and resolving.

65.1 had indirect involvement with postmasters regarding support during my time in
the role. In 2017 following another business restructure, I took over as chair of
the Branch User Forum. This was a forum established in 2014 as part of the
Branch Support Program that was designed to enable postmasters to have a

better voice within Post Office. Branches from all segments of the network were

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chosen following an application process to participate. This would involve
members of Post Office such as Product Owners and change/project managers
attending the forum to share details of change and ideas and get their input as to
how their project or product could be successfully implemented into the network.
It was also used as an opportunity for branches to raise questions or concerns
that they would like the business to answer. It was the role of my Network
Gateway Manager to work through these actions, issues and questions and

provide responses to those branches.

66.1 have been asked to explain whether I felt the support offered to postmasters
was adequate. I think the changes experienced in 2006 had a massive impact on
some postmasters and for some, the support was not adequate. The changes
were made quickly from the point of business consultation announcements to the
implementation of new structures which did not leave enough time for planning
and preparation. Those teams in place left in place had no central reporting
system to track and monitor who was supporting branches and for what purpose,
leading to a disjointed support model for branches. Replacing physical support
with remote intervention was not enough for some postmasters. This view was

also supported in the review undertaken by Second Sight.

67.1 have been asked to consider the Branch Standards Booklet [POL00084769]. (

68.1 have been asked what my involvement was in drafting the Branch Standards
Booklet. This was part of the Network Efficiency Program which I was project

managing whilst in the role of Head of Network Co-ordination. The Program was
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sponsored by the Network Director. I was responsible for working with members
of the Network Efficiency Program Steerco to agree the areas of focus for
Branch Standards. This group was made up of senior members of the Network,

Finance and Operations directorate.

69.Once the draft outline was agreed, I worked with the key contributors outlined in
document POL00084775 (mentioned in paragraph 45 above) to agree the
specific wording for each section. As the areas within the Branch Standards
booklet were owned by various business stakeholders, they had to sign off their
area of content to ensure the information was factually correct. Once the draft
was completed, it went through the process of being re-drafted with internal and
external legal teams and the Communications Team. An external agency was
commissioned by the Communications Team to support with the presentation
and tone of the booklet. Following that exercise I was then responsible for re-
circulating it for sign off and approval before arranging the distribution to

branches.

70.1 have been asked what the Post Office initiative to promote Branch Standards
was. My recollection and interpretation of why Branch Standards was introduced
was to help provide clarity to branches about what it meant to run a good branch.
To my knowledge, what good looked like hadn’t been communicated in this way
before and it was felt that Branch Standards would apply a level of service
consistency regardless of branch size, type or location. There were also different
business teams with different objectives that were trying to improve branch

performance. These teams were working in isolation which not only duplicated
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resource efforts but also made it confusing for branches to understand the
priorities. Therefore, the role of the Network Efficiency Program, of which Branch

Standards was a part, was to help deliver a coordinated approach.

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. The topics identified to include within the booklet were chosen because of the
impact failures in performance were having on customers, the risk of regulatory
and legal sanctions through potential branch compliance breaches, the costs
being incurred by Post Office either in cash holding levels or through service
charges within the various client contracts, and the potential negative impact on

postmasters.

72. The Branch Standards booklet also has to be considered in the context of the
time that it was launched. As mentioned above, the Post Office had made a
decision in 2006 to undertake a large-scale re-organisation of the business which
included the decision to significantly change the focus of support for
postmasters. It was decided that only the large commercial branches who had
the potential to grow their sales income would receive the pro-active support of
an Area Manager. This was c.2000 branches across the country. The remaining
branches were informed they would not have a named individual, and should
they need help, the first point of contact would be the branch helpline, the
Network Business Support Centre. At the time of the re-organisation, a number
of colleagues left the business, and a number of people were recruited with sales

experience to focus on sales within those branches.

73. The impact of this was that it was felt that at the time the Network Efficiency
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Program was launched, the standards within the branch network were not as
they should be and for the reasons mentioned above, they needed to improve.
Re-introducing physical support to branches in the way it had been prior to 2006

was not a commercially viable option.

74. Along with the launch of the Branch Standards booklet, a business case was put
together to introduce a small Branch Standards Team to provide remote support
to help branches meet the standards. The team consisted of c.6 team members
including a team leader, and a data manager. Further detail of the support they
provided is outlined in paragraphs 80 through to 89 below. I believe the
introduction of Branch Standards and the supporting remote interventions made
by the team was seen as the best alternative to driving improvements in

standards in these areas.

75.1 have been asked to consider whether the booklet adequately dealt with the
matters it discussed. The areas within the Branch Standards were not new topics
to postmasters and branches, and it wasn’t designed to replace the operational
instructions that were already available. The purpose was to signpost people to
the key points regarding what was important and why. Branches were given the
opportunity to ask any questions about the initiative and ask for help regarding
any of the content. Processes were put in place with the Network Business
Support Centre who were able to answer the majority of transactional questions,
for example how to process mails transactions correctly. They could also

escalate to the relevant team if there was something they couldn’t answer.

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76.1 have been asked to consider Branch Standards Q&A document
[POL00084774] which is a document associated with Branch Standards. This
was part of the communication collateral that was drafted and coordinated
approval from the relevant stakeholders. This document was part of the
communication that was sent to all branches which included the booklet itself,
the contract variation document, a covering letter and Q&As. It was standard

practice to include Q&As with any change communication of this type.

77.The type of questions to include were identified from direct experience of working
with branches and knowing the types of things that would be asked,
understanding what was usually asked to Area Managers, seeking feedback
from the help-line, working with the Agents Development team who managed
postmaster contractual change, and also getting advice from the legal team and

the Communications team.

78. When drafting a document like this, it is impossible to cover every potential
question that can be asked. I can’t say whether postmasters and branches felt
that it adequately addressed the matters in it as that pro-active feedback was not
sought following the publication of it. As mentioned above, processes were put in
place with the NBSC who were aware that I was the point of escalation regarding
Branch Standards. If a large number of queries were raised, then they would
have come to me to resolve. I cannot recollect having to deal with many queries

as a result of the launch.

79.1 have been asked to consider Branch Support Programme — Terms of
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Reference document [POL00039158] and asked to explain my role (and any

variations to that) of Network Manager. The document is the Branch Support

Program Terms of reference which includes a reference to the business-as-usual

role I was doing at the time when asked to take on the Program. This role was a
variation of the Head of Network Co-ordination role I was doing between 2006
and 2010, which morphed into the role of Network Conformance, Standards and

Policy Manager role I did when returning from maternity leave in 2011.

80.A significant part of my role following the launch of the Branch Standards was to
manage the support and interventions to branches regarding the majority of the
areas within the Branch Standards booklet. The exception to this was the sales
areas. There were various business re-organisations in the time period, with the
Network Gateway Teams and Outlet Intervention Teams moving into other parts

of the Network team.

81.My team when I was the Network Conformance, Standards and Policy Manager
in 2011 consisted of a data team, a team who made outbound telephone
interventions to branches, a National Multiples Manager, and a Mails
Relationship manager. The size of the team making outbound calls had doubled

in size by this time, partly due to the success in helping to improve performance

but also because of the signing of the renewed Mails Distribution Agreement with

Royal Mail which contained a significant number of potential financial service

credits for Post Office if standards weren't achieved.

82. The data team were responsible for receiving the performance data from the
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different parts of the business regarding the areas outlined within Branch
Standards. Some of this information was formulated into a scorecard, which was
sent to branches on a monthly basis via the Branch Focus magazine. Topics
included within the scorecard included whether the branch was making the
relevant cash declarations, whether they were holding the right amount of cash,
if they had processed mails transactions correctly and if the regulatory
compliance training had been completed etc. The data team did not use any data
sourced from the Horizon system. Performance files were received from the

respective business areas and then exported into an excel reporting tool.

83.My role was to agree the intervention approach with the relevant business
stakeholders and the performance data would be used to help prioritise activity
given the resource available. Outbound interventions would be a combination of
activity. If there was a wide scale issue, the normal approach would be to send
communications to branches via Branch Focus. Specific branches could be
targeted, and the data team would identify which branches to include in the
communication. Telephone interventions would also be made to branches.
Things like branches not making accurate cash declarations or not following
bureau de change transaction processes correctly would usually warrant a
phone call, as these areas were often more complex and required the person
making the call to go through the data for the branch and provide more help with

procedures.

84.1 was also responsible for ensuring that the branch network completed the

necessary regulatory compliance training on time. There were approximately
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twelve training modules to complete each year. This usually involved a series of
proactive interventions using a combination of Branch Focus articles,
memoviews being made available on the Horizon system to remind branches the
deadline for completion was coming, memoviews to branches after the deadline
had passed with revised dates to complete, and then a series of phone calls
would be made to ensure the branch had completed the training. Where the
branch still did not complete the training, a request would be made to the
Network Support Scheduling Team to arrange a visit by a Field Support Advisor

to ensure the training was completed.

85. The data team had mechanisms in place to track the impact after the
interventions were made so we could gauge how effective it had been in terms of
improving performance. The intervention data and the performance data were
used to start helping identify which branches had issues across a variety of
areas, and also to look at where large numbers of branches didn’t meet the
required performance levels. Where there were branches that seemed to be
struggling, the team would liaise with the field teams to see what further training
and support could be given. If this approach didn’t work, then we would work with
the wider Contract Manager team to agree what further action needed to be

taken.

86.Where it appeared that the issues were impacting large numbers of branches,
the approach was often to make contact with branches and ask questions about
what they were finding difficult and if there was anything that could be done to

improve processes etc. Depending on what information came back and if there
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was a common theme, myself and the team worked with the relevant business
teams and also sometimes the client directly to initiate process improvements.
Examples of this included the likes of Mail Redirection Forms where Post Office
was financially penalised for branches not completing the forms correctly. We fed
back and implemented ideas with Royal Mail to reduce the ability for branches to

make mistakes by suggesting changes to the form which were implemented.

87. The telephone intervention team made outbound telephone calls to all
postmaster owned branches, regardless of whether they had an Area Manager
associated with them or not. Where contact was made with a branch who had a
nominated Area Manager, the Area Manager was made aware and involved in
helping to improve performance if appropriate. They were provided with the
performance information. The Directly Managed Branch network Area Managers
were provided with the performance information pulled together by the data
team. They were responsible for acting on the data and agreeing the relevant

approach with their team.

88.The branches that were often not in scope the telephone intervention activity
were those operated by the multiple partners. The Multiples were considered to
be strategic larger partners such as Spar, James Hall, McColls, Co-Op etc. who
had a number of branches and their own structure of area manager support who
were often responsible for the running of the retail and post office branch. The
role of the National Multiples Manager was to ensure that our multiple partners
were provided with the performance data for their branches so they could make

the appropriate interventions with their staff. The National Multiples Manager had
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relationships with named individuals within these organisations, who were the
contact point for sending the information, agreeing the approach and being the

escalation point for support.

89.The Mails Manager role was an addition to the team following the signing of the
Mails Distribution Agreement with Royal Mail. Post Office had a number of
obligations within this contract, including the meeting of standards regarding
mails transactions in branch, but also with regards to how mail was stored in

branches and transferred to the collection drivers etc. There were complaints

from Post Office and Royal Mail respectively that were complex to resolve, and it

was the role of this individual to help resolve these service issues in a way that
was acceptable to Post Office, Royal Mail, the postmaster/branch manager and

customers.

90.1 have been asked to explain how I came to run the Branch Support Program
and what this involved. I was asked to run the Branch Support Program in 2013
by Angela Van-den Bogerd. I was informed that there had been allegations into
the robustness of the Horizon system and that a firm called Second Sight had
been commissioned to complete a review of the system. The messaging that
was given to me by senior management was that there was no indication that
Horizon software was causing discrepancies but that there were a number of
areas of improvement regarding the training and support offered to postmasters
that needed to be implemented. The decision was made to set up the Branch
Support Program to investigate and try to remedy the issues. I was working in

Angela's wider team at the time of being asked to run the Program. I cannot
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speak for her as to the exact reason why she chose me, but I assumed that this

was because I had the skills and knowledge required to do the job.

9

=

.Running the program involved the following activities. The first requirement was
to ensure that branches were made aware of the allegations being made
regarding the Horizon system and to put a process in place for enabling
branches to raise any individual concerns they had and to ensure that the claims
were being passed to the relevant teams to investigate. This involved working
with the Network Business Support Centre, the area support teams, IT, Security,
Product and Branch Accounting, Contracts Managers, the Agents development
team, communications team, the Issue Resolution Team or Mediation Team who
had been put in place to review individual cases, and other business

stakeholders.

92. The approach was then to validate the findings in the Second Sight report and
explore the themes further. A small team of colleagues including myself
conducted interviews and feedback sessions with a range of stakeholders
including postmasters, the National Federation of Sub postmasters, Area
Managers, Network Support Teams who were training branches and conducting
audit, the Network Business Support Centre advisors, Product and Branch
Accounting, the Security and Fraud teams and other business stakeholders who
interacted with branches directly, to identify the list of issues and identify

potential improvement opportunities.

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93. This then involved reviewing the findings and then structuring the work streams
with appropriate resource based on the guidance of the Program Steerco. I can’t
remember the exact names of the work streams, but they included Suspension
Policy, Training, Support, Communications, Data, and IT. The scope of the IT
work stream included identifying where transaction processes could be simplified
on Horizon and also investigating systems that would help back-office teams
support branches more effectively. There may have been others, but these were
the main ones from my memory. It was my role to ensure the scope of the work
streams was agreed, the relevant business stakeholders were involved, manage
progress against deliverables, and flag, manage and escalate risks and issues

where appropriate.

94.1 have been asked whether I felt the support to Branches between 2000 and
2012 was adequate. I did not work in this area between 2000 and 2003 and
therefore I can’t comment on whether this was adequate. However, it is my
personal opinion that the decisions made as part of the 2006 organisation re-
structure and then subsequent changes to the Area Manager network had a
detrimental effect on some postmasters. As mentioned previously, there was a
business decision to remove Area Manager support to all but c.2000 branches
within the network. The model relied on the branch asking for help and would
usually be contacted by Post Office if there was a performance issue to resolve.
The only exception to this was if the branch had experienced a serious incident
such as a robbery or burglary, and therefore it was a priority to request an urgent

visit from the wider Post Office team to provide pastoral support to branches.

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95.This meant that there were some branches who had never been visited during
that time period. There was no central system for Post Office to understand who

visiting branches for what purpose and when.

96. The majority of support to branches therefore from 2006 to 2012 was done ona
remote, reactive basis. Trying to resolve something over the phone had
limitations, but this was the best that could be done given the resources
available. I understood the business rationale for making the changes. However,
on reflection, it appeared that a top-down business decision had been made
regarding how efficiencies could be made without completing a proper
assessment as to whether the remaining teams were ready and capable to offer
the level of support from the launch of the new structure. For example, I was
asked to put in place and run a small Outlet Intervention Team to triage
escalations as the announcements were being made about the new structure to
the network. Roles, responsibilities and processes were still being identified and

people still being recruited.

97.The review of the Second Sight team concluded that the support provided to
Branches between this time period was not adequate, which led to the initiation

of the Branch Support Program.

Resolution of Disputes

98.1 have been asked to consider document Branch Support Programme DRAID

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Log [POL00039217]. Whilst the title of the document is the Branch Support
Program DRAID log (Decisions, Risks, Actions, Issues and Dependencies), it
appears to be the copy of the actions spans across my role as Network
Conformance, Policy and Standards Manager and the wider Network
Performance Team during 2011 and 2012 and then includes actions from the
Branch Support Program in 2014. This would have been the type of document
that I would have completed, inputted to and managed in both roles but I don’t
know why the two have been merged and the context of which is relates to the
subsequent questions relating to audit and disputes regarding alleged shortfalls

of money.

99.1 have been asked to set out what involvement I had in the audit process. The
Network Support Field team were responsible for carrying out two types of
branch audit; a compliance audit and a financial audit. These audits were not

often carried out together.

100. The compliance audit focused on regulatory, legal and procedural
compliance. It included areas such as making sure the postmaster had
registered all members of staff with HR, checking whether the regulatory
compliance training to comply with Anti-Money laundering regulations had been
completed, whether the branch was displaying out of date promotional materials
which were in breach of Financial Services Authority requirements, checking that
there was no evidence of Horizon passwords being shared, ensuring the branch
were not keeping Post Office Card Account cards and PINS in the branch on

behalf of customers, and making sure that the branch were not breaching the
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Mails Integrity rules and regulations etc.

101. As the areas covered within the audit were the same types of areas covered
within the Branch Standards booklet mentioned earlier. I put a process in place
to ensure that the results of the audits were shared with the data team and the
telephone intervention members of the team made follow-up calls to the branch
to identify progress the postmaster was making in closing any gaps identified.
This was because the audits were taking place and no follow-up activity had

been taking place previously.

102. As part of the Branch Support Program, I was involved in a review of the
compliance audit content to ensure that the content of the audit was focused on

the areas that could only be checked during a physical visit.

103. With regards to a financial audit, this was the audit that was undertaken by a
member of the Network Support Field Team to verify the cash and stock holdings
within the branch. I was not involved in agreeing the approach, the content of the
actual audit itself. My experience of an actual financial branch audit was when I
shadowed members of the team for my own personal development. When I was
a Rural Retail Line Manager, I would always attend a branch transfer audit to

thank the outgoing postmaster and welcome the new postmaster.

104. The Branch Standards Team were not involved in following up after the
completion of a financial audit. If a discrepancy was identified, the Network

Support Field team would liaise directly with the Contracts Managers to discuss
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discrepancies and the next course of action to be taken.

105. My team had some initial administrative involvement in the process following
a suspension as part of the new business structure created in 2006. If the
decision had been made to close the branch following a suspension, it was my
team that completed some of the business paperwork to notify relevant business
teams of the closure, to help source temporary postmasters and to facilitate
branch transfers and re-openings — i.e. making sure there was someone
available to reopen the branch and cash and stock could be delivered on the
days required etc. I managed this for a short period of time before this element of

support moved into the Contracts Manager team.

106. Ihave been asked to explain if I was involved in or party to any disputes
between the Post Office and postmasters regarding any alleged shortfalls of
money. In my days as a Rural Retail Line Manager, I would discuss the results of
the branch balances during my visits and any shortages or surpluses. If a branch
had a discrepancy, they were unclear about how it had occurred, I would help
them by contacting the Product and Branch Accounting teams in Chesterfield to
understand if the branch were due to receive any error notices back which would
explain the discrepancy. My recollection was that more often than not, a mistake
had been made and the team were in the process of generating an error notice

to correct the branch account.

107. If a postmaster had a financial shortfall which they disputed, they had the

opportunity to request the amount be written off. They could raise a request with
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me, and I would then have to request approval via my Head of Area who had
prescribed authority levels. To my recollection, I did not receive any request
which required me to follow this process. None of the postmasters I was every
responsible for had to be suspended or have their contract terminated due to
financial discrepancies. None of my postmasters I visited expressed a concern to

me about the Horizon system.

108. When I began my role as Head of Network Co-ordination, I was responsible
for setting up the Outlet Intervention Team. This team would help triage requests
from the business and administer certain service processes for the postmaster
network. This would include escalations from the Network Business Support
Centre if the branch had got a discrepancy or they wished to dispute

discrepancies.

109. The NBSC would try to resolve the query as much as possible. If they didn’t
do this to the postmaster’s satisfaction, the escalation would come to the Outlet
Intervention Team. They would make contact with the postmaster and identify if
there was anything further that could be done to help. Depending on the
outcome of the conversation, the team would request a face-to-face support from
the training team, liaise with the Product and Branch Accounting team if the
branch was requesting more information, or put a contact request through to the
Contracts Manager if the request was to discuss about resolving the loss. Any
request to either write-off shortages or initiate the hardship process was the

responsibility of the Contracts Advisors to resolve. I would get involved in the

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process if the teams who the Outlet Intervention Team were trying to get support
from were not being responsive to the requests, and they needed me to escalate

to their line managers to resolve.

110. In terms of resolving disputes regarding shortfalls of money that were as a
consequence of an error notice/transaction correction, the agreed business
process was that the query would be raised with the Product and Branch
Account Team who would provide further evidence to branch and review the
case. If there was a further dispute, then there was a specific role within that
function that reviewed the individual cases. I can’t remember the name of the
role, but it was undertaken by Andy Winn who was in Rod Ismay’s team. If on
review they still held the belief that the shortfall was correct to pay, then this was
flagged to the Contracts Manager to resolve. The times I would get involved is if
any cases flagged to me hadn't followed this process, and I would help escalate

to ensure it was being reviewed as part of the agreed process.

111. As part of my status of senior manager within Network, I was required to be
an Appeals Manager for both postmasters and employees. With the exception of
when postmaster appeals were conducted by a specified person for a period of
time (possibly around 2009), I was a designated appeals managers to undertake
appeals from postmasters regarding having their postmaster contracted

terminated.

112. In the majority of cases I heard, a financial discrepancy identified at audit was

the contributing factor to the decision to terminate the contract. As an appeals
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manager, it was my role to undertake a review of the case and provide the
postmaster with an opportunity to provide evidence as to why it was not
appropriate to terminate the contract. It was also my role to ensure that the
correct processes had been followed and then to make a judgement as to

whether it was correct to terminate the contract.

113. As part of the case papers I received, it was typical to have any relevant
Horizon data that the Contract Manager had used in making the decision. This
could include things like the transaction logs from the branch which would have
been provided by the auditor, cash declarations and copies of Cash Accounts or
Trading statements etc. Depending on the case, copies of remittance notes of
cash and stock could be included if relevant. If the Security and Investigations
team had been involved and used any key-stroke data provided by Fujitsu this

was also included in the pack.

114. If after conducting the appeals meeting with the postmaster to understand
their version of events, I sometimes did request additional branch data to verify
the information being told. The data I typically asked for was any data that was
accessible via the Product and Branch Accounting Team, Cash Management,

Security and Investigations or information from the National Stock Team.

115. Following the review of the case, as an appeals manager I made the decision
whether the appeal was successful or not. Those decisions were made against
the contract under with the postmaster operated. It was not within my remit to

agree whether and how any financial shortfalls would be repaid.
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116. As part of running the Branch Support Program, I became aware of specific
dispute cases between the Post Office and specific branches. This is because I
had set up the process to ensure branches had a mechanism for raising
concerns about the system, I attended the weekly business calls to discuss
specific cases, and I used the findings from reviews to suggest business process

improvements. I have expanded on this in paragraphs 130 through to 135.

117. The other times I was party to disputes between the alleged shortfalls of
money was within my role as Head of Branch and Customer Support. I became
responsible for the helpline in 2015, which became known as the Branch Support
Centre rather than the Network Business Support Centre. If a branch suffered a
shortage which was felt to be as a result of incorrect advice provided by an
advisor or incorrect action taken to resolve the issue, then I would review the
complaint. In these instances, of which there are only a couple I can recollect
from my time doing the role, I would review the case listening to the calls and
reviewing call scripts etc. If it was found that incorrect advice was given, or the
correct process wasn’t followed then I would request the shortfall to be written off

against my cost centre code.

118. I have been asked to outline my awareness of the contact or input from
Fujitsu in the resolution of these disputes. I was aware that as part of the
contract with Fujitsu, there was an agreed number of ARQ files that could be

requested free of charge. I can’t remember what the anacronym stood for, but it

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was branch data that related to all the keystrokes on the system that somebody
in branch had undertaken. This would provide more detailed information
regarding which users were doing what on the system and when. The data
available in the ARQ process was also available for a larger date range than the

teams in Product and Branch Accounting Team had add access to.

119. I believe this process and the request for the data was managed by the
Security and Investigations Team. I was aware that if the Post Office exceeded
the request for ARQ data above the agreed allocation, then this was a charge to
the Post Office. I can’t remember the exact amount but understand it was in the
region of £400 per request. If a request needed to be made, this had to be done
via the Security Team and therefore I didn’t have any dealings with Fujitsu as

part of this process.

120. I have been asked whether there were any improvements that could have
been made to this process. In my role as Head of Network Co-ordination, there
were process improvements that were identified and discussed with Product and
Branch Accounting. One of these was the consistency with which supporting

evidence was provided when Transaction Corrections issued to branches.

121. Another issue which was raised with the team was the timing of the issuing
of the Transaction Correction and the length of time branches had to resolve the
dispute. Part of the Horizon balancing process was that all Transaction
Corrections had to be accepted and processed before the branch completed its

balance, otherwise the branch could not complete the required procedures to roll
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the branch into the next accounting period. Feedback via the Outlet Intervention
Team was that Transaction Corrections were being sent to branches on the day
they were due to balance which forced them to accept the Transaction
Correction and resolve the discrepancy, leaving them to dispute it afterwards.
This was raised to the Product and Branch Accounting Teams in Chesterfield to
put processes in place that prevented this from happening in order to give the

branch longer to complete their own investigations before accepting it.

122. There were improvements to the process which were identified and
implemented as part of the Branch Support Program. The first was the
workstream that reviewed the suspension policy, which changed the approach of
suspending a postmaster and then investigating to one where the postmaster
was able to continue running the branch whilst the financial discrepancies

identified at audit were investigated fully.

123. The second was the work that was undertaken to improve the accessibility
to more detailed Horizon data. As part of the Program, I worked with colleagues
in Fujitsu to understand how it would be possible to provide Post Office
colleagues with access to a tool known as HORICe, which stood for the Horizon
Information Centre. The data within this tool was all of the information generated
by branch and had the level of granularity that was available as part of the ARQ
process. Three months’ worth of data could be accessed, and it worked on the
basis of permission-based roles where a number of defined users could access

the system at one time. The tool could also be used to run specific reports as

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requested by the business, such as branches not logging on for a period of time,
branches where connectivity had been lost and large numbers of reversals being

made etc.

124. In 20141 worked with Pete Newsome and Steve Parker from Fujitsu to
implement this system. This was a licensed based system, and the licenses and
the tool were implemented across identified users in the branch help line,
Product and Branch Team, Cash Management, the Security Team and other
functions. By having this system available in the likes of the helpline, trained
advisors could now see all of the data relating to the branch to try and help the
branch resolve what had happened. For example, they could help pinpoint
possible causes of discrepancies, such as a postmaster may have entered too
many 00s when entering the amount for a bill or processing a banking
transaction as a withdrawal rather than a deposit. Depending on what they
identified, they could then escalate the issue to the relevant resolving team more
quickly or advise the postmaster what steps needed to be taken in branch to

resolve the discrepancy.

125. The processes followed and improvements that I identified were based on
the assumption that the Horizon system could not cause discrepancies and cash
shortfalls. Had I known then about the issues with the system and the impact it
could have had, then this would have completely changed my approach to the

processes I was involved with.

126. I have been asked to consider various documents [POL00039244,
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POL00043369, POL00043370, POL00043371 and POL00043372]. All of the
documents with the exception of POL00039244 appear to be copies of the
regular meetings that were held to discuss any new issues being raised

regarding the use of Horizon. I have never seen this type of document before.

127. I have been asked to explain whether I was aware of any issues or problems
with the Horizon system. Prior to the Second Sight review, I had not been made
aware of claims that branch discrepancies were caused by the actual system
itself.

128. Up until that point, the issues or problems that I was aware of with the
Horizon system relating to cash discrepancies were associated with how the
system was operated. This included things like a branch not accounting for the
stock correctly onto the system when they received it from the stock centre; not
processing transfers correctly between stock units in branch; miss-counting cash
and stock; making mistakes declaring transactions correctly from other branch
equipment such as the paystation or ATM; serving in the wrong stock units; not
reversing things correctly; not following the correct procedures for recovering a
transaction when the system went off-line, miss-keying incorrect amounts, or
processing banking transactions as deposits rather than withdrawals but giving

the customer the money.

129. Even when the claims about Horizon started to be known within the
business, the messaging coming from the business was that the system was not
capable of impacting the accounts. I made the assumption that the business had

undertaken the relevant due diligence to ensure this was the case. I did not have
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the technical knowledge to understand how this would be possible and therefore
had to trust the information from the business as I had no evidence or knowledge

to suggest otherwise.

130. I started attending the weekly calls with the range of business stakeholders
when I ran the Branch Support Program. The purpose of the call was to discuss
and share the details of branches who had concerns with the Horizon system.
There were a number of teams present on the call who undertook various roles
to support the investigations. It was agreed as part of the call who was taking
ownership to investigate the cases and share up-dates. As the documents
outline, representatives from Legal Services, Network, Communications, IT,
Security, the Finance Service Centre (previously known as Product and Branch
Accounting) and the Network Business Support Centre regularly attended the

calls.

131. I The person responsible for resolving would vary depending on the issue and
the status of the claim. If this was a completely new branch for example, the
Security and Investigations Team would look at retrieving all of the branch data
and this would then be passed to the Case Resolution Team or the Mediation
Team as it was known. With the likes of the case where concerns had been
raised regarding ATM shortages, the investigation with the Bank of Ireland
concluded that the losses were likely as a result of potential criminal behavior by
a Wincor engineer. In this instance, the case was progress with the Product
Team who managed the relationship with the Bank of Ireland to recover the

branch losses.
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132. My role within the team was to ensure that there was a mechanism in place
to identify the branches that were having issues and to agree with the key
stakeholders who would take the action and ensure that someone was owning
the case to conclusion. In most cases the information collated by the different
stakeholders on the calls and passed to the Case Resolution Team or Mediation
Team to review. They would complete a review of the case and then try to
identify the possible causes of the error. The Case Resolution Team or
Mediation Team had a process to follow on the review of the case, but I cannot

remember the details of what that was.

133. Whilst the common theme from the cases I was made aware of appeared to
be caused by human error or a failure to follow the correct procedures, it was
important that each case been considered independently on the evidence
presented. Just because previous cases gave the impression that this was the
case, it was important not to assume that there wouldn't be something within a

new claim that would point to evidence.

134. As part of the Branch Support Program, the themes were being incorporated
into the overall work streams. For example, the cases confirmed that there was a
lack of understanding regarding what would cause discrepancies. The focus for
training appeared to be on how to do something correctly and didn’t cover what
to do when something went wrong. As a result, the training team started to

develop a module to address this.

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135. If there was an opportunity to improve the transaction process on Horizon,
then this was reported to the Product Owner, and it was agreed what could be
done to improve it and remove errors. An example of this was an issue raised in
processing of bureau de change transactions. The process required the printing
of two receipts to record evidence of personal identification, with the second
being required should the transaction turn out to be fraudulent. This wasn’t
automatically printed and therefore required the branch colleague to remember
to print it. There were instances of the customer transactions being fraudulent
and branches being required to stand the loss as they couldn’t produce the
second receipt. The project team worked with the Product Manager, the Finance
Service Centre and Fujitsu to implement the change on Horizon to auto-generate

two receipts to prevent mistakes from happening.

136. I have been asked how this knowledge impacted on how I interacted with
postmasters or Post Office managers working in branch. This question is a bit
ambiguous, and I have made the assumption that “this knowledge” refers to what
my understanding was regarding what was causing the balancing errors to be.
My knowledge was based on the assumption that Horizon could not cause these

issues and therefore were down to operator error.

137. The impact this had on my interaction was to try and understand what could
be done to prevent these issues happening in the first place, and how to get
branch colleagues involved in change earlier on in the process to make it easier

to complete transactions.

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138. I have been asked what concerns I had in relation to specific areas of the
Post Office system including Mails, Camelot, DVLA, Banking etc. One of the
concerns I had was that where there was a piece of technology in the branch
that didn’t have a direct feed from it to Horizon and relied on postmasters and
branch staff to manually transfer the transactions onto Horizon, this generated
the opportunity for error. This included the likes of the paystation terminals, Post

and Go, ATMs, Camelot etc.

139. All of these processes appeared to have been designed in isolation with the
client and were constrained by the change constraints on the Horizon system.
My interpretation was that the Horizon system wasn't defective, but that the
process design and user experience for certain transactions was. As the optimal
technical solution wasn’t available for go-live for whatever reason, this had the

potential to increase the operational burden into the branch.

140. When Transaction Acknowledgements were introduced in 2011 for products
such as Paystation and Camelot, whilst this generated an automatic feed of the
sales into the Horizon system, there was still an onus on the branch to set up
correct stock units to accept the TA, process it correctly and then physically
transfer the takings to the Post Office cash if for example the Lottery terminal

was located on the retail side of the business.

141. I have been asked whether I had any concerns in relation to the in-branch
technology and that it may be responsible for some of the errors. As mentioned

above, I had no evidence to suggest this to be the case or have the technical
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knowledge of the equipment used.

142. I have been asked with the benefit of hindsight whether the training to
postmasters was sufficient between 2000 and 2012. As mentioned above, this
was one of the focus areas of the Branch Support Program which confirmed that
there were many areas of improvement, and the training wasn’t sufficient. Whilst
there were postmasters who ran their branches with few or no problems at all, I
don't think there is data available to identify the role that the training played in
that.

143. I have been asked in hindsight whether better support could have been
offered to postmasters. My previous responses indicate that I don’t believe that
the support model offered was right. Also, had it been understood and
communicated that there were potential defects with the system that could
contribute to discrepancies, this would have been considered in how branches

were supported to help resolve errors.

144. Had this been known on a personal level, this would have potentially
changed the processes I managed and the decisions I made. On reflection, my
knowledge and assumptions were not the full picture. If I had known about the
potential problems, I would have sought to understand and include the possibility
of a system errors in processes I was developing and implementing, or

investigations I was completing.

145. I have been asked who and/or what do I think is responsible for the Post

Office Scandal. I have not been party to all of the evidence presented and
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therefore don’t feel that I can comment on this with any level of authority. Any
answer given would be opinion only and I don’t think my opinion will provide any

comfort to the postmasters who suffered as a result of the Post Office Scandal.

146. My experience of working in the Post Office was that it operated within a
strict risk control framework and there were processes in place for making
decisions. Any change to policy, approach, request for funding etc. had to be
signed off at the highest level, sometimes including the shareholder, and it did
not appear that individuals could make decisions in isolation or outside of their
remit. Before the separation of Post Office from Royal Mail Group, there were
internal processes for approvals and then this would go to Royal Mail Boards for
further approval. Once decisions had been made and strategies agreed, this
then filtered down into individual objectives at every level in the organization. It

wasn't an environment where you could just do what you wanted if you felt like it.

147. Contributing factors to the Post Office Scandal goes beyond the Post Office
as an organsation. Undertaking Prosecutions against postmasters was an
agreed business policy and I assumed, as probably did others, that this would
have gone through the relevant due diligence to get to the point of preparing the
case for submission. You also had faith in the justice system in that people are
innocent until proven guilty, and if the cases were unsafe then a verdict of not
guilty would be reached. The very fact that this was happening, and the justice
system was accepting the evidence provided, this added to the narrative and
beliefs that it couldn't possibly be the Horizon system that was causing branch

discrepancies. If a Court of Law believed it, then on what basis did any of us
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have to challenge this not to be true? We now know that those convictions were

a miss-carriage of justice.

148. From some of the decisions being made about how the network would be
managed and the policies implemented, the personal impression I got was that
the primary driver was cost and reducing the funding burden on government
funding. I am not sure how much the impact on postmasters was considered and
whether if they had a stronger voice in the making of those decisions and

policies, then perhaps different decisions would have been made.

149. I have been asked whether there are any further matters I consider the Chair
of the Inquiry to be aware of. I can confirm that there are no further matters I

think need to be considered.

Statement of Truth

I believe the content of this statement to be true.

Dated: 31/01/2023

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Index to First Witness Statement of Gayle Peacock

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URN

Document Description

Control Number

POL00032992

Training Agenda
(BOMP)

POL-0029927

POL00034746

Branch Support
Programme — Training
Workstream

POL-0031618

POL00084463

Letter from Gayle
Peacock - Subject
‘Branch Standards and
Financial
Consequences for
Franchisees' 29 March
2010

POL-0081521

POL00084464

Letter to SPMs
including a copy of the
Post Office Branch
Standards Booklet

POL-0081522

POL00084465

Branch Standards
note on recovering
money from
Franchisees

POL-0081523

POL00084768

Letter from Gayle
Peacock subject
‘Branch Standards and
Financial
Consequences' March
2010

POL-0081826

POL00084769

Branch Standards
Booklet 2010

POL-0081827

POL00084770

Template Letter to
SPM on Branch
Standards

POL-0081828

POL00084771

Branch Standards
Conformance with
Branch Standards
Compliance Training,
Cash Declarations and
Looking after MVL
discs document

POL-0081829

10

POL00084772

letter template on
Branch Standards to
PO Managers

POL-0081830

11

POL00084773

Template letter for
SPMs with numerous
branches on Branch

POL-0081831

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Standards

12

POL00084774

Branch Standards -
Q&A Document

POL-0081832

13

POL00084775

Branch Standards Key
Contributors

POL-0081833

14

POL00039158

Branch Support
Programme —- TOR
v.3 In confidence
Gayle Peacock

POL-0035640

15

POL00005690

AAC Email from Gayle
Peacock re ‘Branch
Standards and
Financial
Consequences for
Franchisee

VIS00006758

16

POL00005939

ACC Team Email
subject 'Branch
Standards and
Financial
Consequences’

VIS00007007

17

POL00084769

Branch Standards
Booklet 2010

POL-0081827

18

POL00084774

Branch Standards -
Q&A Document

POL-0081832

19

POL00039158

Branch Support
Programme —- TOR
v.3 In confidence
Gayle Peacock

POL-0035640

20

POL00039217

Branch support
programme DRAID
Log (dependencies,
Risks, Actions, Issues
Database

POL-0035699

21

POL00039244

Initial Complaint
Review and Mediation
Scheme - Post Office
Investigation Report
for Branch 207320-
Case number M060

POL-0035726

22

POL00043369

POL Meeting Minutes
to discuss Horizon
Issues of 2 Oct 2013

POL-0039851

23

POL00043370

POL Meeting Minutes
to discuss Horizon
Issues of 9 Oct 2013

POL-0039852

24

POL00043371

POL Meeting Minutes
to discuss Horizon
Issues of 16 Oct 2013

POL-0039853

25

POL00043372

POL Meeting Minutes
to discuss Horizon
Issues of 23 Oct 2013

POL-0039854

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