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Witness: Rodric David Alun Williams
Statement No.: WITNO8420200
Dated: 2 October 2024
POST OFFICE HORIZON IT INQUIRY
SECOND WITNESS STATEMENT OF
RODRIC DAVID ALUN WILLIAMS
1, RODRIC DAVID ALUN WILLIAMS, will say as follows:
INTRODUCTION
1. This is my second statement to the Post Office Horizon IT Inquiry (“the
Inquiry’). I make this second witness statement in response to a request made
under Rule 9 of the Inquiry Rules 2006 ("the Request”) dated 5 August 2024.
The Request contains questions relevant to Phases 5, 6 and 7 of the Inquiry.
2. On 11 March 2024 I signed my first witness statement (WITN08420100). I
appeared and gave evidence to the Inquiry on 18 and 19 April 2024. This
second statement is supplemental to my first witness statement and my
evidence to the Inquiry. I instructed a firm of solicitors to support me in my
preparation of this witness statement.
3. To assist the Inquiry with the clarifications they are seeking in the Request in
respect of Phases 5 and 6, I have undertaken searches of my POL Outlook, to
which I still have access as a current POL employee. I have carried out these
searches to the best of my ability to try to locate relevant documents. I have not
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had any technical or other assistance with searching or analysing my Outlook.
In the process of reviewing emails, it has become clear that the timestamps of
emails are not consistent,’ which has made the process of reconstructing
chronologies of events from the documents more challenging.
4. Given the time available to respond to the Request, I have limited this statement
to responding to the questions in it, and have not sought to comment on or
address any other evidence before the Inquiry as part of Phases 5 and 6.
BACKGROUND
5. There have been no updates in respect of my position since the submission of
my first witness statement. I remain a Head of Legal at POL but do not currently
have responsibilities within the Remediation Unit. I transferred my
responsibilities to the other lawyers within the unit's legal team so that I would
have the capacity to respond to requests from the Inquiry. Paragraph 15 of my
first witness statement remains accurate.
PHASE 5/6 CLARIFICATION
Email Accompanying Board Briefing of 4 June 2014
6. The Inquiry has shared with me an email from Alwen Lyons to me of 4 June
2014 (POL00029733) and an attached briefing document for the Board
prepared by Deloitte (POL00130618) (the “Board Briefing”). The email from
Alwen Lyons forwards to me an email message that had been sent on behalf of
Chris Aujard and Lesley Sewell to members of the Board, enclosing the Board
‘In this statement, the timestamps of emails are taken from the exhibited documents. I have identified
occasions where these differ from the timestamps of emails I located in my Outlook, but I have not
sought to identify each occasion where such a discrepancy occurs.
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Briefing. I have been asked about my role in drafting the email from Chris Aujard
and Lesley Sewell that accompanied the Board Briefing.
7. As I explained at paragraph 113 of my first witness statement, my recollection
is that the Board Briefing was a document that Chris Aujard asked Deloitte to
prepare for the Board, and that I was involved in discussions with Deloitte about
it. In preparing this statement I have located correspondence describing Lesley
Sewell as “co-sponsoring” the Board Briefing (POL00458682). Sending the
email enclosing the Board Briefing to the Board in Chris Aujard and Lesley
Sewell’s names also suggests that they were the members of the POL
executive team? sponsoring this work.
8. At 17:42 on 4 June 2014, I sent an email to Paula Vennells and Alwen Lyons
with Chris Aujard, Lesley Sewell and Martin Edwards in copy (POL00304766).
In this email, I have written:
“Hi Paula, Alwen — below is the message that Chris and Lesley would
like to send to the Board attaching the final draft of Deloitte’s Briefing on
their review. Alwen — would you be able to send this once you have
Paula’s approval?”
The email then sets out a proposed email to be sent to the Board in Chris
Aujard and Lesley Sewell’s names, which I refer to in my statement below as
the “Proposed Text”. The Proposed Text was used by Alwen Lyons in her
2 The Request refers to the “POL executive team”, which I understand to mean those who were on the
‘ExCo' or 'Group Exec’/'GE’ committee reporting to POL's Board. See paragraph 12 of my first witness
statement.
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email to the Board shared with me by the Inquiry (POL00029733). The Board
Briefing is also attached to my email (POL00130618).
9. Although I have seen emails exchanged during the course of 4 June 2014 with
Chris Aujard and Lesley Sewell concerning the Board Briefing,> I have not been
able to locate any email correspondence with them regarding the Proposed
Text. I cannot now, 10 years later, recall drafting the Proposed Text or any
specific conversations with Lesley Sewell, Chris Aujard, or anyone else about
it. However, I do not believe I would have sent the Proposed Text to Alwen
Lyons without discussing it at some level with Chris Aujard first, and possibly
also with Lesley Sewell, given that it was proposed to be sent to the Board in
their names. The Proposed Text contains information relating to the Sparrow
Sub-Committee that I do not believe would have been within my own knowledge
at that time as I was not a member of that Sub-Committee, and the inclusion of
this information supports my view that it was drafted with at least some input
from Chris Aujard, who I believe was a member of the Sparrow Sub-Committee.
I copied Chris Aujard and Lesley Sewell into my email to Paula Vennells and
Alwen Lyons at POL00304766, giving them sight of the Proposed Text and
providing them with the opportunity to comment on it if it did not reflect their
position or any instructions received from them. I have no record of receiving
any such comments from them.
10. At 18:06 on 4 June 2014, Paula Vennells responded to my email indicating that
it was for Chris Aujard to approve the Proposed Text (POL00304771). At 18:09
3 See for example email from Chris Aujard to me dated 4 June 2014 at 09:14 (POL00458681);
POL00458682; and my email to Lesley Sewell dated 4 June 2014 at 14:09 (POL00458683).
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11.
12.
on 4 June 2014, Alwen Lyons responded to Paula Vennells’ email asking Chris
Aujard if the Proposed Text and Board Briefing could be sent (POL00108630).
I have not been able to locate a response from Chris Aujard to Alwen Lyons but
it may be that I was not copied in.
I cannot now specifically recall drafting the email that I sent to Paula Vennells
and Alwen Lyons containing the Proposed Text (POL00304766), or the process
I used to draft it. I believe however I would have been trying to introduce and
put into context the Board Briefing, summarise what we understood the key
findings of it to be, signpost key limitations, and identify next steps, so that the
recipients of the email could more easily understand why they had been sent it.
The third paragraph of the Proposed Text states that the Board Briefing is based
on a desktop review of currently available information and “is therefore heavily
caveated”. In the fourth paragraph, before summarising the key findings, it
states that: “Deloitte expressly identify a number of limitations and assumptions
which underpin their findings (see Section 3 “Limitations and Assumptions’).
The briefing must be read in this context.” (emphasis in my original Proposed
Text). Those paragraphs flagged the importance of reading the Board Briefing
in the context of those-limitations. It appears that the emphasis in the Proposed
Text, included in my email to Alwen Lyons (POL00304766), may have been lost
on some subsequent versions of the email (for example at POL00108630).
It was my expectation that the Board Briefing itself would be read by Board
members and they would form their own views on it. It was a document
specifically prepared for the Board by subject matter experts, Deloitte, and
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considerable efforts had been made by Deloitte and POL to make it accessible
to the members of the Board. I believe I would have drafted the Proposed Text
in that context. I would have expected feedback from Chris Aujard if anyone
had found the Proposed Text to be unhelpful. I do not recall receiving any
feedback about the Proposed Text from anyone.
Next Steps in Respect of the Board Briefing
13. I have been asked to set out what steps the POL executive team took to follow
up on the issues raised in the Board Briefing, and the extent of my involvement
in that work. I do not recall attending any Board meetings at which the Board
Briefing or any of Deloitte’s work was discussed. As mentioned at paragraph [7]
above, it is my understanding that the members of the POL executive team
sponsoring the work were Chris Aujard and Lesley Sewell. I am aware that they
continued to be involved in the work that Deloitte were undertaking.* I do not
recall what Chris Aujard and Lesley Sewell’s work entailed, nor working with
them on it.
14. In responding to the Request, I have located in my Outlook emails indicating
that members of POL staff outside of the POL executive team were undertaking
work related to Deloitte's work.5 I do not however know what steps members of
4 See the email from Julie George to Rod Ismay, David Mason and Malcolm Zack sent 17 June 2014
at 09:02 (POL00346958), which was put to me during my evidence of 19 April 2024; the email from
Chris Aujard to me, David Mason, Rod Ismay, Julie George and Malcolm Zack re "FW: Project Zebra”
sent 2 July 2014 at 11:43 (POL00305039), which includes an email from Gareth James to Chris Aujard
and Lesley Sewell dated 10 June 2013 that references meeting with them on 9 June 2019; and the
email from Julie George to Belinda Crowe and others dated 19 August 2014 at 08.26 (POL00458689).
5 See email from Julie George to me dated 5 June 2014 at 08:34 (POL00458684) email from Julie
George to Rod Ismay and others dated 10 June 2014 at 06:34 (POL00458685); email from Julie George
to Gareth James and others dated 18 July 2014 at 09:59 (POL00458686); and POL00458689.
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the executive team took in connection with this, and any decision to instruct
Deloitte to expand or progress work would, I believe, have been a matter for
the POL executive team and may have required Board input or support. As
mentioned at paragraph 114 of my first witness statement, I appear to have
attended a call with Deloitte, POL IT and Internal Audit colleagues on 2 July
2014. From the notes of that meeting, which Deloitte produced, my primary
concern appears to have been with “balancing transactions”.6 I took steps to
get Deloitte’s work released to Womble Bond Dickinson and Cartwright King so
it could be considered as part of the support they were providing for POL.” As
explained at paragraph 147 of my first witness statement, balancing
transactions was something that Womble Bond Dickinson later discussed
further with Deloitte. Although there is a reference to a draft of the Project Zebra
Report being “with our legal team” in August 2014,8 I do not know what this is a
reference to. It may have been that further feedback from the POL legal team
was expected.
Prosecution and Convictions Section of the Notification to Insurers
15. The Inquiry has shared with me POL00112856 (notification to insurers). I have
been asked about my role in the drafting of the ‘Prosecutions and Convictions’
section of this notification and any issues arising.
® Email from Gareth James to me, Julie George and Rod Ismay dated 2 July 2014 at 23.16
(POL00138459)
7 Email from Gareth James to me dated 21 July 2014 at 11:58 (POL00458687) and my email to Mark
Westbrook dated 15 August 2014 at 15:28 (POL00305703).
® Email from Julie George to Mark Westbrook and others dated 11 August 2014 at 11.05
(POL00458688)
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16. At 16:45 on 6 August 2013 (POL00193243) I received an email from Andrew
Parsons attaching a draft note on D&O risks dated 7 August 2013
(POL00193244) for my review and comments (“the 7 August 2013 Note”). The
7 August 2013 Note was to act as notification to POL’s insurers. It contained a
section entitled “Prosecutions & Convictions” which stated:
“As noted above, in rare circumstances, the Post Office prosecutes
subpostmasters who have acted criminally. The basis of these
prosecutions is often found in the transaction records recorded in Horizon.
As a result of Second Sight's investigation/Interim Report, Post Office is
reviewing all its criminal prosecutions over the last three years to identify
any cases where a conviction may be unsafe.
In particular, the expert evidence of one Post Office witness, Dr Gareth
Jenkins of Fujitsu, may have failed to disclose certain historic problems in
the Horizon system. Under the criminal prosecution guidelines, Post Office
has an obligation to disclose (even retrospectively) this previously
undisclosed information to subpostmasters' defence counsel. Post Office
is required to make these retrospective disclosures where the additional
information (ie Dr Jenkins' knowledge of historic, but now resolved,
problems with Horizon) may have undermined a prosecution case or
assisted with an accused's defence.”
17. At 17:44 on 15 August 2013 (POL00193583), I received an email from Andrew
Parsons attaching an updated version of the Note dated 15 August 2013 (‘the
15 August 2013 Note”) (POL00193585). The email from Andrew Parsons
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18.
19.
records that the 15 August 2013 Note incorporates my “suggestions”, but I do
not recall now, 11 years later, what those were and have not been able to locate
any material beyond the updated note indicating what they might have been. A
comparison of the 7 August 2013 Note and the 15 August 2013 Note shows that
the “Prosecutions & Convictions” section of each are substantially the same
with one amendment: the 15 August 2013 Note states that the Post Office
prosecutes subpostmasters “where circumstances warrant’, whereas the 7
August 2013 Note had stated that Post Office prosecutes subpostmasters “in
rare circumstances’.
At 14:54 on 16 August 2013, I emailed Martin Smith of Cartwright King (cc’ing
Jarnail Singh) a copy of the 15 August 2013 Note that I had received from
Andrew Parsons and requested “any comments on this from a criminal law
perspective...” (POL00298369). Although I do not now recall this specifically, I
believe I will have requested input from Martin Smith because the 15 August
2013 Note, particularly the “Prosecutions & Convictions” section of it, dealt with
criminal law matters which neither Bond Dickinson nor I were expert in, and I
would have wanted the Note to be accurate.
At 12:18 on 26 August 2013, I emailed Andrew Parsons (POL00040025) an
updated version of the Note dated 23 August 2013 (“the 23 August 2013 Note”)
(POL00040026). The 23 August 2013 Note states (changes underlined):
“As noted above, where circumstances warrant, Post Office prosecutes
subpostmasters who have acted criminally. The basis of these
prosecutions is often found in the transaction records recorded in Horizon.
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20.
21.
As a result of Second Sight’s investigation/Interim Report, Post Office is
reviewing all its criminal prosecutions which have had a hearing since 1
January 2010.
Post Office has an obligation to consider whether further discourse [sic]
should be made to defendants. It is of concern to Post Office that the expert
evidence of one prosecution witness, Dr Gareth Jenkins of Fujitsu, may
have failed to disclose certain problems in the Horizon system potentially
relevant to a case.”
My email to Andrew Parsons stated that the Note had been updated “with input
from Cartwright King on the criminal law risks”, and the version of the Note
attached to that email had been saved under the _ title
“Insurance_Risks_(with_CK_amendments)_22.08.13.docx” (POL00040026). I
believe this shows that the amendments made to the 23 August 2013 Note
reflected input from Cartwright King, as I would not have said that otherwise. I
assume this will have come from Martin Smith, either in person or by telephone,
given I sent my email request for input to him, but have not been able to locate
an email in reply. I believe this section was seeking to reflect the “Sift Review”
Cartwright King was undertaking for POL to determine the specific prosecutions
where further disclosure was required, and it would not have been in POL’s
interest to misstate that in a notification to insurers.
In my email to Andrew Parsons of 26 August 2013, I asked him to check that
the Note would still serve the purpose of notifying insurers of the grounds for
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potential claims. At 13:49 on 26 August 2013, he replied enclosing the 23
August 2013 Note and stating (in part) “The note and email look good”
(POL00458680). At 16:19 on 28 August 2013, I sent the cover email
(POL00242854) and text of the 23 August 2013 Note (POL00242856) to Miller
Insurance.
Briefing Note for Paula Vennells
Overview
22. I have been asked by the Inquiry to consider POL00145089. This contains the
text of a briefing note for Paula Vennells for a meeting with James Arbuthnot,
which is also referred to in contemporaneous correspondence as a ‘speaking
note’. I have been asked to set out: (1) my role in the drafting of the Current
Prosecutions and Historical Prosecutions section of this note and (2) the issues
concerning the note that I produced, referred to by Susan Crichton in the
covering email.
23. In this statement I will refer to the briefing note prepared for the meeting with
James Arbuthnot as the “Speaking Note”, to distinguish it from a separate
“Briefing Note” I was drafting at the same time. The Briefing Note was a
document which, as I set out at paragraph 58 of my first witness statement, I
was co-ordinating. The Speaking Note appears to have been drafted at the
same time by others who worked more closely with Paula Vennells and were
more familiar with the public affairs context in which the notes were being
prepared. I was aware by being copied into emails that the Speaking Note was
being drafted, and that it covered similar subject matter to the Briefing Note, but
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I do not recall considering the contents of the Speaking Note in detail. My focus
would have been on the Briefing Note, for which I was ‘holding the pen’. I set
out below a summary of my understanding of how the Briefing Note and
Speaking Note were created and developed, based on documents I have
reviewed whilst preparing this statement.
Briefing Note
24. I set out in paragraph 58 of my first witness statement that on 2 July 2013 I was
asked by Hugh Flemington and Susan Crichton to co-ordinate revisions to a
draft briefing note he had prepared for Paula Vennells,? so as to provide a
consolidated overview of the background to and issues arising out of the draft
Second Sight interim Report.’? Following receipt of the Request, I have
undertaken a further review of my Outlook to try to understand whether I had
any input into the Speaking Note. As set out below, I have located emails which
show that I first became involved in the drafting of the Briefing Note on Thursday
27 June 2013, a few days earlier than Tuesday 2 July 2013 as stated in my first
statement.
25. On 27 June 2013, I instructed Andrew Parsons by email to prepare a response
document to Second Sight’s Interim Report which was due to be published
imminently (POL00189184). At 17:13 that day, Andrew Parsons emailed me
(POL00189205) attaching the draft response document (POL00189206). At
® This is the document that I refer to as the Briefing Note in this statement.
10 Email from Rodric Williams to Lesley Sewell and others dated 2 July 2013 at 14.19 (POL00115918);
and ‘Internal Briefing Note to Paula Vennells: Second Sight review into Horizon — Implications of Interim
Report’ dated 2 July 2013 (POL00115919)
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17:54, I emailed the draft response document to Lesley Sewell, Hugh
Flemington and Alwen Lyons (POL00296725). In my cover email, I stated that
this could also act as a briefing note for Alice Perkins. Over the following days
a number of iterations of the draft were circulated and revisions were suggested
by a number of individuals at POL. Jarnail Singh’s input was sought on a
number of occasions in relation to criminal law matters as he was POL’s in-
house criminal lawyer. As I was ‘holding the pen’ in respect of the Briefing Note,
I would have sought to reflect the amendments and comments received into
updated drafts, which I would re-circulate."*
Speaking Note for Meeting with James Arbuthnot
26. On 2 July 2013 at 19:33 Susan Crichton circulated what I now believe to be the
first iteration of the Speaking Note. I was not copied into that email from Susan
Crichton, but Hugh Flemington forwarded it to me and Jarnail Singh on 2 July
2013 at 20:56'2 (POL00458679). I believe Hugh Flemington forwarded this and
another email chain regarding the Speaking Note (see below at paragraph [28])
"' See in particular email from me to Alwen Lyons (with Hugh Flemington copied in) at 21:59 on 27 June
2013, attaching an updated version of the briefing note (POL00189436); email from me to Jarnail Singh
at 06:39 on 28 June 2013 asking him questions about pre-separation prosecutions (POL00296754);
email from Jarnail Singh to me at 09:44 on 28 June 2013 in response to my questions and my response
(POL00296787); email from me to Jarnail Singh at 17:09 on 28 June 2013 with a copy of the current
version of the Briefing Note at his request (POL00189534); email from Jarnail Singh to me at 17:12 on
30 June 2013 providing further information on the prosecutions part of the draft Briefing Note
(POL00296855); email from me to Lesley Sewell, Alwen Lyons and Hugh Flemington with Simon Baker,
Gina Gould, Martin Edwards, Jarnail Singh and Mark Davies in copy at 01:06 on 1 July 2013 circulating
an updated draft of the Briefing Note (POL00296858); email from Hugh Flemington to me, Alwen Lyons
and Martin Edwards on 1 July at 12:14 (POL00144948); email from Alwen Lyons to me at 20:07 on 1
July 2013 (POL00380977); email from Simon Baker to Rodric Williams at 20:30 on 1 July 2013
(POL00296942) with attached draft (POL00296943); and email from me to Lesley Sewell, Susan
Crichton, Mark Davies, Alwen Lyons, Martin Edwards and Simon Baker with Hugh Flemington and
Jarnail Singh in copy at 13:18 on 2 July 2013, circulating updated version of the draft Briefing Note
dated 2 July 2013 (POL00296960 and POL00296963). .
‘2 There is a discrepancy between timestamps in the email I can see in my Outlook (20:56) and the
email that has been disclosed to the Inquiry (19:56).
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to me so that I could see the work being undertaken on the Speaking Note in
parallel to the Briefing Note.
27. At 21:43 on 2 July 2013," Martin Edwards emailed me, Lesley Sewell, Susan
Crichton, Alwen Lyons and Simon Baker with Hugh Flemington, Mark Davies
and Jarnail Singh in copy asking if there had been any updates to the latest
draft of the Briefing Note which I had circulated earlier that day. In this email,
Martin Edwards stated: “Would be good to send Paula and Alice the latest
version alongside the speaking note.” (POL00368546). I replied to this at 23:07
stating “/’m just updating it now — I will resend shortly, adding Nina and Ruth.”
(POL00368548).
28. At 22:30 on 2 July 2013, Hugh Flemington forwarded to me with “Fyi” an email
exchange between Martin Edwards and Susan Crichton concerning the
prosecutions section of the Speaking Note (POL00368552).
29. At22:38 on 2 July 2013, I emailed Mark Davies and Martin Edwards with Lesley
Sewell, Susan Crichton, Alwen Lyons, Simon Baker, Hugh Flemington, Jarnail
Singh, Nina Arnott and Ruth Barker in copy (POL00297032) with the updated
draft of the Briefing Note (POL00297033).
30. I now understand from evidence before the Inquiry that during the evening of 2
July 2013, Martin Edwards and Mark Davies exchanged emails making
amendments to the Speaking Note (POL00297040). I do not appear-to have
3 The document I am exhibiting, which has been disclosed to the Inquiry, shows this email to have
been sent at ‘21:43’. When I view the email in my POL Outlook it shows it as being sent at 22:43.
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been copied in to those exchanges and do not have any recollection of them.
At 23.44 on 2 July 2013, Mark Davies responded to my email circulating the
latest draft of the Briefing Note (see paragraph [29] above) seeking a
clarification in relation to a particular prosecution. I responded at 23.55
indicating that we had limited information regarding this prosecution and that
we should know more tomorrow (POL00297081).
31. At 00:16 on 3 July 2013, I emailed Martin Edwards informing him that there was
one amendment (which concerned the “62 Branch Exception”) to the draft
Briefing Note which I had just circulated (and was attached POL00368557) that
“should track across into the one Susan prepared” (POL- POL00368556). The
“one Susan prepared” is I believe a reference to the Speaking Note. At 00:16
on 3 July 2013, Martin Edwards replied to say he would make this amendment
(POL00368555).
32. At 02:04 on 3 July 2013, Martin Edwards circulated a version of the Speaking
Note to Alice Perkins and Paula Vennells, copying Susan Crichton, Alwen
Lyons, Mark Davies, Hugh Flemington, Simon Baker and me. Martin Edwards’
email is the first email in the chain at POL00145089. I do not recall reading the
Speaking Note before the meeting with James Arbuthnot took place, and may
not have done so given my understanding of who was involved in preparing it,
my focus on the Briefing Note, and the timing of this email (the lateness of the
hour and its proximity to the meeting with James Arbuthnot). If I did, I do not
believe I would have commented on the Current Prosecutions and Historical
Prosecutions section (or indeed any other section) given that the Speaking Note
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had been drafted by colleagues who had the latest draft of the Briefing Note
and a better understanding of what the Speaking Note was required to address.
Issues referred to by Susan Crichton in her email (POL00145089)
33. I have been asked by the Inquiry to comment on “the issues concerning the
note” that I produced, referred to by Susan Crichton in her email of 3 July 2013
at 07:13 (POL00145089). I understand “the note” to be a reference to the
Briefing Note described at paragraphs [24], [25], [29] and [31] above.
34. I We were working in a very fast paced environment at the time the Briefing Note
was being prepared, and had received a great deal of information concerning
the matters traversed in it in a short period of time, meaning the Briefing Note
needed to be updated constantly. In her email Susan Crichton considered the
Briefing Note required some “updating”, but I do not know which part or parts
of the Briefing Note she was referring to, and I do not recall her communicating
to me any specific issues she may have had with the Briefing Note. Susan
Crichton had been copied in to two emails prior to this that indicated that the
Briefing Note would need to be updated, so it may be that she was referring to
these parts of the Briefing Note.'4
‘4 See emails from Mark Davies sent at 23:44 on 2 July 2012 and Lesley Sewell sent at 07:06 on 3 July
2013 raising issues with the “Merthyr Dyfan case” and “Rudkin Spot Review’ respectively
(POL00297081). Please'note that there is a timestamp discrepancy between the document disclosed
to the Inquiry and the document in my Outlook in respect of the email from Lesley Sewell. My Outlook
indicates that it was sent at 08.06, which would be after Susan Crichton had sent her email at
POL00145089.
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LESSONS LEARNED
35. I have been asked by the Inquiry to set out any conversations that I have had
with the current executive team or Board of POL regarding my involvement in
the matters being investigated by the Inquiry and their response to the same. I
do not recall any specific discussion with the current executive team or POL
Board regarding my involvement in the matters being investigated by the
Inquiry. When the scope of the Inquiry was expanded in Spring 2021 to include
matters in which I may have been personally involved, I emailed the General
Counsel Ben Foat and Historical Matters Director Declan Salter concerning the
conflict or potential conflict of interest this could create between POL and me
around POL’s participation in the Inquiry, following which I ceased providing
legal support to POL with respect to its participation in the Inquiry.
- 36. _ I have been asked by the Inquiry to set out any internal investigations, inquiries
or lessons learned exercises that have taken place into my involvement in the
matters being investigated by the Inquiry and their findings. I am not aware of
any internal investigations or inquiries that have taken place into my
involvement in the matters being investigated by the Inquiry. I am however
aware that shortly after the conclusion of the Group Litigation, POL’s Board
commissioned a review of events that led to that litigation. I did not have any
involvement in that review, but it is possible that it considered matters being
investigated by the Inquiry and my involvement in them. I understand that POL
maintains and retains privilege over the instruction, communications and output
regarding this review. “
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37.
38.
I have been asked by the Inquiry to set out any changes within POL that have
been implemented as a result of my involvement in the matters being
investigated by the Inquiry (if any). Since the handing down of the judgments in
the Group Litigation, I know that across POL a great deal of work has been
undertaken to try to remedy the issues raised in the various legal judgments
and observations made as part of them, for example so that POL engages with
serving postmasters consistently with the postmaster contracts as construed by
the Group Litigation’s Common Issues Judgment, to establish and fund
compensation schemes, and to consider claims made to them. As set out at
paragraph 20 of my first witness statement, my primary role at POL has been
to manage POL'’s legal risks and facilitate the provision of appropriate legal
support and advice to the business. My role therefore has been to support
rather than lead these activities, and I believe others are better placed to speak
to the detail of them.
I have sought to provide this support cognisant of the criticisms that have been
made against POL, and of POL’s desire to address and not repeat them. I have
done so because that is consistent with the legal judgments and observations
which have been made, and because it is clearly the right thing to do given the
profound personal impact these matters have had on the people affected. I
would therefore like to reiterate what I said at the conclusion of my first witness
statement, that I hope that a resolution to these matters is achieved soon for all
those who might have been affected.
18
WITNO08420200
WITNO08420200
39. 1am happy to assist the Inquiry further if required.
STATEMENT OF TRUTH
I believe the cantent.of this statement to be true.
GRO
RODRIC DAVID ALUN WILLIAMS.
Dated: 2 October 2024
19
WITNO08420200
WITNO08420200
Index to Second Witness Statement of Rodric David Alun Williams
URN
Document Description
Control Number
WITN08420100
First witness statement of Rodric
David Alun Williams
WITN08420100
POL00029733
Email from Alwen Lyons to Rodric
Williams dated 4 June 2014 at
18:27
POL-0026215
POL00130618
Deloitte Draft Board Briefing
document further to report on
Horizon desktop review of
assurance sources and key control
features dated 4 June 2014
POL-0120670
POL00458682
Email from Rodric Williams to
Gareth James dated 4 June 2014 at
09:25
POL-BSFF-WITN-
052-0000007
POL00304766
Email from Rodric Williams to Paula
Vennells and Alwen Lyons, with
Chris Aujard, Lesley Sewell and
Martin Edwards in copy dated 4
June 2014 at 17:42
POL-BSFF-0142816
POL00458681
Email from Chris Aujard to Rodric
Williams dated 4 June 2014 at
09:14
POL-BSFF-WITN-
052-0000006
POL00458683
Email from Rodric Williams to
Lesley Sewell dated 4 June 2014 at
14:09
POL-BSFF-WITN-
052-0000008
POL00304771
Email from Paula Vennells to Chris
Aujard, Alwen Lyons and others
dated 4 June 2014 at 18:06
POL-BSFF-0142821
POL00108630
Email from Alwen Lyons to Paula
Vennells, Chris Aujard and others
dated 4 June 2014 at 18:09
POL-0106722
10.
POL00346958
Email from Julie George to Rod
Ismay and others dated 17 June
2014 at 09:02
POL-BSFF-0172679
11.
POL00305039
Email from Chris Aujard to David
Mason and others dated 2 July
2014 at 11:43
POL-BSFF-0143089
12.
POL00458689
Email from Julie George to Belinda
Crowe and others dated 19 August
2014 at 08:26
POL-BSFF-WITN-
052-0000016
13.
POL00458684
Email from Julie George to Rodric
Williams dated 5 June 2014 at
08:34
POL-BSFF-WITN-
052-0000011
14.
POL00458685
Email from Julie George to Rod
Ismay and others dated 10 June
2014 at 06:34
POL-BSFF-WITN-
052-0000012
15.
POL00458686
Email from Julie George to Gareth
James and others dated 18 July
2014 at 09:59
POL-BSFF-WITN-
052-0000013
16.
POL00138459
Email from Gareth James to Rodric
Williams and others dated 2 July
2014 at 23:16
POL-BSFF-0000683
20
WITNO08420200
WITNO08420200
17.
POL00458687
Email from Gareth James to Rodric
Williams dated 21 July 2014 at
11:58
POL-BSFF-WITN-
052-0000014
18.
POL00305703
Email from Rodric Williams to Mark
Westbrook dated 15 August 2014 at
15:28
POL-BSFF-0143753
19.
POL00458688
Email from Julie George to Mark
Westbrook and others dated 11
August 2014 at 11:05
POL-BSFF-WITN-
052-0000015
20.
POL00112856
Email from Stuart Corney to DO
Claims dated 9 September 2013 at
15:34
POL-0110268
21.
POL00193243
Email from Andrew Parsons to
Rodric Williams dated 6 August
2013 at 16:45
POL-BSFF-0031306
22.
POL00193244
Draft Note on “Horizon Risks” (“the
7 August 2013 Note”) dated 7
August 2013
POL-BSFF-0031307
23.
POL00193583
Email from Andrew Parsons to
Rodric Williams dated 15 August
2013 at 17:44
POL-BSFF-0031646
24.
POL00193585
Updated Draft Note on “Horizon
Risks’ (“the 15 August 2013
Note”) dated 15 August 2013
POL-BSFF-0031648
25.
POL00298369
Email from Rodric Williams to
Martin Smith and Jarnail Singh
dated 16 August 2013 at_14:54
POL-BSFF-0136419
26.
POL00040025
Email from Rodric Williams to
Andrew Parsons and Simon
Gildener dated 26 August 2013 at
12:18
POL-0036507
27.
POL00040026
Updated Draft Note on “Horizon
Risks” (“the 23 August 2013
Note”) dated 23 August 2013
Note that this document has been
saved under the title: “Insurance_
Risks_(with_CK_amendments)_.
22.08.13.docx”
POL-0036508
28.
POL00458680
Email from Andrew Parsons to
Rodric Williams dated 26 August
2013 at 13:49
POL-BSFF-WITN-
052-0000004
29.
POL00242854
Email from Rodric Williams to Miller
Insurance dated 28 August 2013 at
16:19
POL-BSFF-0080917
30.
POL00242856
Note on “Horizon Risks” dated 23
August 2013 attached to Rodric
Williams’ email to Miller Insurance
dated 28 August 2013 at 16:19
POL-BSFF-0080919
31.
POL00145089
Email from Susan Crichton to
Martin Edwards and Hugh
Flemington dated 3 July 2013 at
07:13
POL-BSFF-0004216
21
WITNO08420200
WITNO08420200
32.
POL00115918
Email from Rodric Williams to
Lesley Sewell others dated 2 July
2013 at 14:19
POL-0116920
33.
POL00115919
Draft “Internal Briefing Note to
Paula Vennells: Second Sight
review into Horizon — Implications
of Interim Report” dated 2 July 2013
POL-0116921
POL00189184
Email from Rodric Williams to
Andrew Parsons with Hugh
Flemington in copy dated 27 June
2013 at 13:14
POL-BSFF-0027247
35.
POL00189205
Email from Andrew Parsons to
Rodric Williams with Hugh
Flemington in copy dated 27 June
2013 at 16:12
POL-BSFF-0027268
36.
POL00189206
Draft Response to Second Sight
Interim Report (undated)
POL-BSFF-0027269
37.
POL00296725
Email from Rodric William to Leley
Sewell, Hugh Flemington and
Alwen Lyons dated 27June 2013 at
17:54
POL-BSFF-0134775
38.
POL00189436
Email from Rodric Williams to
Alwen Lyons and Hugh Flemington
dated 27 June 2013 at 21:59
POL-BSFF-0027499
39.
POL00296754
Email from Rodric Williams to
Jarnail Singh with Hugh Flemington
in copy dated 28 June 2013 at
06:39
POL-BSFF-0134804
40.
POL00296787
Email from Jarnail Singh to Rodric
Williams dated 28 June 2013 at
10:44
POL-BSFF-0134837
4.
POL00189534
Email from Rodric Williams to
Jarnail Singh dated 28 June 2013
at 17:09
POL-BSFF-0027597
42.
POL00296855
Email from Jarnail Singh to Rodric
Williams with Hugh Flemington in
copy dated 30 June 2013 at 17:12
POL-BSFF-0134905
43,
POL00296858
Email from Rodric Williams to
Lesley Sewell, Alwen Lyons, Hugh
Flemington and others dated 1 July
2013 at 01:06
POL-BSFF-0134908
POL00144948
Email from Hugh Flemington to
Alwen Lyons, Martin Edwards,
Rodric Williams and others dated
01 July 2013 at 12:15
POL-BSFF-0004075
45.
POL00380977
Email from Alwen Lyons to Rodric
Williams, Susan Crichton and Hugh
Flemington dated 1 July 2013 at
20:07
POL-BSFF-0207864
46.
POL00296942
Email from Simon Baker to Rodric
Williams and others dated 1 July
2013 at 20:30
POL-BSFF-0134992
47.
POL00296943
Draft “Internal Briefing Note to
Paula Vennells: Second Sight
investigation into Horizon -
POL-BSFF-0134993
WITNO08420200
WITN08420200
Implications of Interim Report”
dated 1 July 2013 with Simon
Baker's amendments
48.
POL00296960
Email from Rodric Williams to
Lesley Sewell, Susan Crichton,
Mark Davies, Alwen Lyons, Martin
Edwards and Simon Baker with
Hugh Flemington and Jarnail Singh
in copy at 13:18 on 2 July 2013,
circulating updated version of the
draft Briefing Note dated 2 July
2013
POL-BSFF-0135010
49.
POL00296963
Draft “Internal Briefing Note to
Paula Vennells: Second Sight
review into Horizon - Implications of
Interim Report’ dated 2 July 2013
POL-BSFF-0135013
50.
POL00458679
Email from Hugh Flemington to
Rodric Williams dated 2 July 2013
at 19:56
POL-BSFF-WITN-
052-0000002
51.
POL00368546
Email from Martin Edwards to
Rodric Williams and others dated 2
July 2013 at 21:43
POL-BSFF-0191963
52.
POL00368548
Email from Rodric Williams to Mark
Davies and others dated 2 July
2013 at 22:06
POL-BSFF-0191965
53.
POL00368552
Email from Hugh Flemington to
Rodric Williams dated 2 July 2013
at 22:30
POL-BSFF-0191969
54.
POL00297032
Email from Rodric Williams to Mark
Davies and others dated 2 July
2013 at 22:38
POL-BSFF-0135082
55.
POL00297033
Draft “Internal Briefing Note to
Paula Vennells: Second Sight
review into Horizon - Implications of
Interim Report’ dated 2 July 2013
POL-BSFF-0135083
56.
POL00297040
Email from Mark Davies to Martin
Edwards and others dated 2 July
2013 at 11:19
POL00297040
57.
POL00297081
Email from Rodric Williams to Mark
Davies and others dated 2 July
2013 at 23:55
POL-BSFF-0135131
58.
POL00368556
Email from Rodric Williams to
Martin Edwards with Hugh
Flemington in copy dated 2 July at
23:16
POL-BSFF-0191973
59.
POL00368557
Draft “Internal Briefing Note to
Paula Vennells: Second Sight
review into Horizon - Implications of
Interim Report’ dated 2 July 2013
POL-BSFF-0191974
60.
POL00368555
Email from Martin Edwards to
Rodric Williams with Hugh
Flemington in copy dated 2 July at
23:16
POL-BSFF-0191972
23