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18 April 2024
Witness Name: Martin Anthony Edwards
Statement No.:WITN09760100
Dated: 18 April 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF MARTIN ANTHONY EDWARDS
I, Martin Anthony Edwards, will say as follows:
INTRODUCTION
1. This witness statement is made to assist the Post Office Horizon IT
Inquiry (the “Inquiry”) with the matters set out in the request for information
pursuant to Rule 9 of the Inquiry Rules 2006, dated 12 March 2024 (the
“Request’). My retained lawyers, Kingsley Napley LLP, have assisted me
in preparing this statement, but the content is instructed by me.
2. The principal headings within the Request are referenced in capitals, with
sub-headings being added to this statement to assist with answering the
Request'’s questions in a structured manner.
BACKGROUND
Career history
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I have been asked to provide a summary of my career and qualifications prior
to joining Post Office Limited (“POL”). I obtained an English Literature (MA)
degree from the University of Edinburgh in 2001. Following graduation, I
spent 11 years in the UK Civil Service, working at HM Treasury, UK Financial
Investments, the Home Office and the Scottish Government. I worked on a
broad range of policy development roles during this period, including tax and
welfare reform, public spending control, the Government's response to the
2007-08 financial crisis and international police co-operation.
I left the Civil Service and moved to POL in September 2012, initially in the
role of Chief of Staff. This was a newly-formed role which was created to
assist the then Chief Executive Officer (“CEO”) of POL, Paula Vennells
(“PV”). At that time, POL had recently separated from Royal Mail Plc and
was establishing itself as a stand-alone entity and undergoing a major
transformation programme to move towards financial sustainability. The
purpose of the role was broadly defined, providing support and co-
ordination across a wide range of strategy projects and day-to-day issues.
I was not the subject matter expert (“SME”) on any particular issue and
did not have any specific decision-making accountabilities. A major part of
the role involved co-ordinating and editing numerous briefings, reports
and correspondence either going to PV (for example to prepare her for
meetings) or being issued from her, such as letters to external
stakeholders or updates to the POL Board. The substance and technical
detail for these documents would typically come from the relevant SMEs
for the topic in question, and my role was to edit this information to ensure
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the end product was suitably clear and succinct for the target audience.
5. The Chief of Staff role was positioned as a time-limited development role, as
a precursor to other positions within the organisation.
6. In October 2014 I moved to become the Group Strategy Director at POL. This
involved co-ordinating the business’ Three-Year Strategic Plan, managing
funding negotiations with the Government and managing a team which
provided an internal consultancy function for POL across a broad range of
strategy projects. As explained later in this statement, this and my
subsequent roles at POL had very limited involvement with the matters being
examined by the Inquiry.
7. In January 2018 I moved to become Managing Director, Identity and
Government Services at POL. Within that role I had commercial responsibility
for POL’s portfolio of Government and identity services, including bringing
new products to market and renegotiating client contracts.
8. Since October 2020 I have worked for POL as Network Strategy and Delivery
Director. In this role I am responsible for setting the strategic direction for
POL’s branch network and developing our commercial relationship with
postmasters and franchise partners.
THE HORIZON IT SYSTEM (“HORIZON”)
Knowledge of Horizon IT issues
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9. I have been asked to consider a Computer Weekly article dated 11 May
2009 [POL00041564]. This article was published more than three years
before I joined POL. I do not recall reading this specific article before it was
provided to me along with the Request. In my initial months at POL I
became generally aware that Computer Weekly was investigating concerns
around this article, but I was not involved in specific internal discussions
around Horizon.
10. I have been asked to consider the Rod Ismay Report dated 2 August 2010
[POL00026572]. I was not involved in the production of this report, which
was issued two years before I joined POL. I do not recall reading the report
when I joined.
Training on Horizon
11. I had training on Horizon at some point in 2013, during my first 12 months
of working for POL. This comprised a one-day standard training course
held at one of POL’s Counter Training Offices, providing a basic
introduction on how to use Horizon as a customer-facing operative. This
training was provided to Head Office staff so that we had an
understanding of how Horizon worked and its user interface, but also to
equip us to provide support to branches in contingency situations such as
industrial action. Beyond this basic training, I did not have any knowledge
of the technical workings of Horizon. I deferred to colleagues in the IT
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team on any questions relating to IT issues or wider Horizon concerns, as
such matters fell outside of my expertise.
Knowledge of Horizon issues
12.
13.
14.
I understand Horizon was first used in POL in 1999, over two decades
before I joined the business. As noted above, my knowledge of its
technical workings was very limited.
I believe I first became aware of concerns raised about bugs, errors or
defects (“BEDs”) with Horizon due to the campaigning work of Alan Bates
and the Justice for Subpostmaster Alliance (“JFSA"). On 4 October 2012
(a couple of weeks after I joined POL) I attended a meeting with PV, James
Arbuthnot and Alan Bates of JFSA in relation to the Second Sight
investigation. I attended the meeting in a note-taking capacity only. During
the meeting, alleged Horizon errors were raised by Alan Bates.
My awareness of JFSA’s concerns about BEDs and a lack of integrity in
Horizon developed through time, particularly during the course of the
Second Sight investigation, my involvement in which is discussed at
paragraphs 33 to 44 below.
Remote alteration of Horizon data/ ARQ data
15.
I believe at some point during the course of the initial Second Sight
investigation a suggestion was raised by ex-SPMs that Fujitsu employees
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16.
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could alter branch data in the Horizon system remotely. I note from an
email from Alwen Lyons to me on 4 June 2013 [POL00029590] that the
“Rudkin case” was being included in the cohort of cases which was being
considered by Second Sight. This was discussed in Spot Review SP05
in the Second Sight Interim Report dated 8 July 2013 [POL00099063].
My knowledge at that stage of the background to the Rudkin case was
limited to what was ultimately included in the Second Sight report.
I did not have any detailed understanding of the data associated with
Horizon during my tenure as Chief of Staff, nor did I have any
understanding of specifically what ARQ data constituted.
OPERATION OF POL AND HORIZON
POL’s dealings with SPMs regarding shortfalls
17.
18.
19.
I was not directly involved in dealings with SPMs regarding shortfalls in
branch accounts. This was not part of my role.
In relation to how often SPMs would raise concerns about Horizon, and
whether this changed over time, I was primarily aware of disputed shortfalls
in branch accounts through the initial cohort of cases which were part of the
Second Sight investigation and the other cases which subsequently came to
light through that investigation.
In respect of how any reported problems with Horizon could be escalated
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within POL and/or to Fujitsu, my understanding is that SPMs would
normally raise issues with the Branch Support Centre or their Area
Manager in the first instance, and might sometimes contact more senior
managers if they were unsatisfied with the response. However, given the
nature of my role I was not close to the details of the specific policy for
escalating branch issues within POL.
20. Additionally, during my tenure I am aware that POL encouraged SPMs to
come forward with concerns for the purposes of the Second Sight
investigation and mediation scheme.
21. I have been asked whether I considered the advice and assistance
available to SPMs to have been adequate. I did not have any first-hand
knowledge of this, as interactions with SPMs was not part of my role.
However, as a result of being briefed on and reading the Interim Second
Sight report in July 2013, I formed the view that the training and support
provided by POL to SPMs on the use of Horizon had historically been
poor and this could have been one of the root causes of reported
problems using the system. It was apparent that Horizon was not
especially user-friendly, particularly in light of the diverse levels of prior IT
experience of those running Post Office branches. It appeared to be the
case that the POL training was not comprehensive and detailed enough
for the users to be able to consistently use Horizon without errors arising.
POL'’s prosecutorial function
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22.
23.
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I have been asked to set out my knowledge of POL’s prosecutorial
function, in particular, its use of Horizon data to pursue prosecutions
against SPMs for fraud, theft and/or false accounting. In so doing, I have
been referred to an email from Lesley Sewell to me on 28 June 2013
[POL00098778] and the witness statement attached to this email
[POL00130356].
I was not directly involved in POL’s prosecutorial function. Any
knowledge I gained was through briefings on the Second Sight
investigation and being briefed on later reports in relation to POL
prosecutions. The reports I refer to included the Cartwright King review
and the Brian Altman KC report, in which I understand it was concluded
that POL’s prosecution process had been “fundamentally sound”. I do not
specifically recall reading the email referenced in paragraph 22 above or
its attachment when it was sent and, upon reading it now, it appears to
corroborate the view held at the time that whilst there were some horizon
bugs, they were not systemic or used as the principal evidence for
previous prosecutions.
POL’s handling of complaints by SPMs
24.
I did not have any detailed involvement in POL’s handling of complaints
made by or litigation involving SPMs in which the integrity of Horizon was
raised. My high-level involvement was to brief PV on reports by SMEs or
to prepare her for meetings with, for example, James Arbuthnot and
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members of JFSA on a small number of occasions, as explained in the
following section. I was not involved in any of the procedural detail of the
handling of complaints by POL.
ENGAGEMENT WITH MPs IN 2012
25.
26.
27.
In respect of my involvement with preparing POL’s response to MPs or
journalists who raised concerns about the Horizon IT system prior to 2012, I
can confirm that I had no such involvement. I was not employed by POL
at that time.
I did, however, have a minor involvement in the preparation of POL’s
response to MPs who raised concerns about the integrity of Horizon
towards the end of 2012, examples of which are explained below.
The first involvement I had in the briefing of MPs on behalf of PV was on
24 September 2012, which was approximately one week after I
commenced my role as Chief of Staff. This is demonstrated by an email
from me to Theresa Iles, Alwen Lyons and Simon Baker on 24 September
2012 [POL00115748]. This email circulated a copy of a response to
James Arbuthnot, originally drafted by Simon Baker, which was to be
signed by PV. Simon Baker's letter was sent to me in draft by Theresa
Isles, who was PV’s Executive Assistant. My role was to review the letter
and to ensure it was clear and succinct before sending it as a final draft
for PV’s approval. I was not, at this stage, versed in the detail of the
JFSA issues and James Arbuthnot's involvement.
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28.
29.
Briefings
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As shown in an email from Theresa Iles to Janet Walker dated 28
September 2012 [POL00107793], I attended a meeting with James
Arbuthnot, PV and Alan Bates on 4 October 2012 (which is discussed at
paragraph 13 above). This was around two weeks after I had started in
post as Chief of Staff. I was there in an observation/ note-taking capacity
rather than to contribute my views to the discussion.
I followed up with a summary (described as a “read out”) of the meeting
by email on 4 October 2012 at 11.45pm to Simon Baker, Alwen Lyons
and Susan Crichton [POL00097030]. POL’s perspective at the time was
that the Horizon IT system was operationally sound, but, notwithstanding
this, the business wished to work with Alan Bates and the JFSA to
assuage their concerns. A number of action points were agreed at the
meeting as recorded in my email. In particular, Mr Bates was to be
invited to POL Head Office to provide wider feedback to the network
support teams. I note that I later contacted Alan Bates to provide him with
an update on progress following our meeting (email chain between
Theresa Isles, PV and me on 18 October 2012 [POL00097058}).
on the integrity of Horizon (including remote access)
30.
I have been asked to describe my involvement in briefing PV, Alice
Perkins and other senior managers or Board members on the integrity of
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the Horizon IT System (including remote access), and how I determined
what information to give to them.
31. There were two principal categories of briefs I would help to co-ordinate:
(1) background briefings to prepare PV (or occasionally Alice Perkins) for
meetings with external stakeholders; and (2) internal briefing papers, for
example CEO reports for the Board. Typically, the content and detail of a
briefing would come from the relevant SME in POL. My role as part of
PV's office was to: a) ensure the briefing was provided on time to inform
the engagement; b) edit the document to ensure that it covered an
appropriate amount of detail, taking into account the target audience’s
time constraints; and c) make sure that it was clear and succinct. When
the topic was not entirely familiar to me, I would prepare the draft briefing
paper then send it to the SME to check that the important messages had
been captured correctly and comprehensively in my summary.
32. I recall one occasion when I collated a briefing paper for the full Board,
which was an update on the work programme following the publication of
Second Sight’s first report dated 26 July 2013 [POL00298004]. This was
a consolidation of inputs from various SMEs across the business. My role
was to ensure that the salient matters were addressed in a
comprehensive, yet succinct, manner.
INSTRUCTION OF SECOND SIGHT
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Appointment of Second Sight and relationship with Second Sight post-appointment
33.
34.
35.
I was not personally involved in POL's decision-making process in
respect of the appointment of Second Sight. My understanding is that
Second Sight was instructed in the period of June to July 2012, which
was around two to three months before the commencement of my role as
Chief of Staff in September 2012.
Following the commencement of my Chief of Staff role, I was aware that
Susan Crichton, as POL General Counsel, was the senior executive
member with lead responsibility for the appointment and management of
Second Sight. To my understanding, such responsibility would have
included determining the ambit of Second Sight's investigation, as well as
the methodology of any such investigation (including, for example, the
sample of cases which were to be reviewed, as well as the information
and documentation to be accessed).
I have been referred to an email dated 6 June 2012 from Susan Crichton
to Alice Perkins and PV, copying in Lesley Sewell, Alwen Lyons, Simon
Baker and Angela Van-Den-Bogerd [POL00113791]. Attached to this
email were two documents, namely the Terms of Reference for the
Horizon investigation, as well as Second Sight’s own proposal in respect
of the investigation. The Terms of Reference document is dated 6 June
2012 and is authored by Susan Crichton. It set outs the background to
POL’s proposal for an independent review of past cases, the objectives
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and scope of such a review, information regarding Second Sight suitability
and qualifications, as well as the estimated timescales and costs. The
ambit and methodology of Second Sight’s proposed investigation is
covered in the “Objectives and Scope” section of the same, namely:
“Objectives & Scope
The Post Office has instructed an independent third party organisation,
2nd Sight Limited [to] provide a proposal to conduct a review which
would include the following tasks:
Select a representative sample of cases that have led to
prosecutions/court-appointed restitution. The sample needs to cover
cases:
e where defendants claim they didn't take any cash
e where assertions have been made that ‘The System’ (i.e.
Horizon) caused the shortage (include the old and new versions
of Horizon if possible)
e which have been taken up by MPs
Carefully review all company-held documentation focussing heavily on
probable reasons why shortfalls occurred or built up
Interview company investigators to gain insights and verify fairness of
findings
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36.
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Review defence submissions focussing on evidence of innocence
(consider separately False Accounting and Theft)
Try to establish why the shortages arose (assign each case to a
Probability Category such as: Skill shortfall; Diversion to Failing
Business; Straightforward Theft (by whom?); Mysterious
Disappearance; etc.)
Review all materials from the viewpoint of the Defence (seek Proof of
Innocence and test evidence indicative of guilt)
Study and selectively test, the ‘Horizon’ system in order to find any
‘Black Hole’, Program Bug; etc. that might have caused mysterious
shortages
Reach conclusions on each case and identify any system
issues/concerns”
I am asked to describe how senior managers within POL viewed Second
Sight and the purpose of its investigation. As I was not personally
involved in the Second Sight appointment process, I did not have direct
knowledge of senior managers’ views upon the instruction of Second
Sight. My understanding is, however, that POL senior managers’ views of
Second Sight at the time of appointment would have been consistent with
the “Objectives and Scope” section in the Terms of Reference referenced
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at paragraph 35 above. In addition, I believe that the purpose of the
appointment would have been born out of a desire by senior managers to
clarify and further investigate the matters set out in the “Background”
section of the same document, as set out below:
“Background
Post Office Limited has decided to conduct an independent review of a
number of closed, and possibly some open fraud and theft cases. The
background is that the Post Office has, in accordance with its
statutorily-authorised powers, pursued cases involving fraud, theft and
false accounting principally in the criminal courts. This has resulted in
a large number of prosecutions and restitution of stolen funds. In
recent years, a number of defendants have asserted that there are
issues with the Post Office’s National Computer System, ‘Horizon’. The
defendants claim that the system has been throwing up mysterious
differences (shortages) for which they have taken have taken the
blame. Some of these cases have been taken up by Members of
Parliament and this has resulted in heightened publicity attaching to
individual cases and to the issue as a whole. This involvement and
publicity has also lent support to assertions that Horizon really is the
root cause of the problem and that some of those convicted only made
false accounting entries because there seemed at the time to be no
other viable course of action. They claim, in effect, that they have been
unfairly convicted and financially ruined.”
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37.
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It became clear to me that the views of POL senior management on the
capacity of Second Sight to handle the investigation in a timely and
objective fashion evolved over time. In particular, by mid-2013 there were
growing concerns by senior managers regarding the progress of the
Second Sight investigation. These included the following matters:
a)
zz
There was a desire to bring the Second Sight investigation to a timely
conclusion, preferably before the Parliamentary summer recess. By
that stage in mid-2013, the number of cases to be reviewed had
significantly increased. This materially contributed to Second Sight
being unable to deliver its conclusions by the end of 2012 as originally
envisaged. Such delays led to questions regarding when Second
Sight’s investigation would, in fact, be ultimately concluded, and
whether there was potential for even further slippage of timescales.
Relatedly, there were concerns regarding budget overruns and the
amount of public money being expended on an investigative process
which had no foreseeable conclusion. As noted above, while POL
senior managers were fully supportive of the Second Sight
investigation, they were also anxious to ensure that public funds were
expended responsibly. I understood that POL itself did not enforce any
explicit budgetary or time constraints on the Second Sight
investigation, as it wished to ensure that the integrity and
independence of the investigation was maintained throughout.
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38.
39.
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However, this approach meant that the investigation risked continued
delays, costs overruns, and potential deviation from its original scope.
By this stage, there were queries regarding whether Second Sight
itself had both sufficient capacity and objectivity to produce a
comprehensive and objective report beneficial to all stakeholders. In
terms of capacity, Second Sight was a firm comprising essentially two
directors. Queries were therefore raised regarding whether the firm
was, in fact, adequately resourced to undertake an investigation that
was now significantly more expansive than originally envisaged. In
terms of objectivity, POL senior managers had some concerns
regarding the extent to which Second Sight had adopted subjective
(and sometimes emotional) views of the evidence presented to them,
instead of taking a more neutral and evidence-based stance ordinarily
consistent with an independent investigation.
Such concerns continued to be voiced throughout 2013.
I have been asked to explain the management of POL’s response to
Second Sight information requests and investigations into Horizon. It was
clear from a letter from Alice Perkins to James Arbuthnot which was
drafted on 21 March 2013 [POL00097781] that POL wished to cooperate
fully with the Second Sight investigation and Second Sight’s requests for
evidence. As noted above, in my role as Chief of Staff, I did not have first-
hand awareness or knowledge of how POL responded to specific Second
Sight information requests. I was aware, however, that there were some
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40.
41.
42.
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practical challenges experienced in retrieving certain information which
had been sought (for example some information was stored on archived
IT systems or paper-based repositories).
I have also been asked to explain the contents of my email to PV on 27
June 2013 at 20:55 [POL00098777] regarding POL’s relationship with
Second Sight, in particular:
a) why I stated that “we need to be careful not to overplay our hand with
SS [Second Sight] — they could turn out to be quite dangerous if we
threaten them with legal action or attempt to replace them with another
firm’; and
b) why I stated that POL should explain “to JA [James Arbuthnot] calmly
but firmly why he cannot allow SS to disseminate a misleading interim
report.”
By way of background, my email was a response to a previous email on
the same day from PV at 20:02, inquiring whether I had any “further
thoughts” following an earlier meeting that day to discuss the Second
Sight investigation and a forthcoming update to MPs. It is also set against
the growing concerns in relation to the progress of the Second Sight
report, as set out at paragraphs 37 to 38 above.
Accordingly, in the email referenced above, when asked by PV whether I
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43.
44.
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had any further thoughts following the meeting with James Arbuthnot, I
replied with my personal opinion regarding the various courses of action
presented. While I did not have a decision-making role, I set out what I
considered to be the repercussions of those various courses of action.
As the email indicates, there were suggestions being made by some
colleagues to replace Second Sight with another investigation firm which
might have possessed the requisite capacity. My personal view, insofar as
I recall, was that doing so might be portrayed as POL seeking to suppress
Second Sight’s report as POL did not like its findings, which would have
been inappropriate and incorrect. I noted that it would be “quite
dangerous’ if Second Sight was replaced or dismissed, in that they would
likely (and understandably) feel aggrieved and possibly escalate matters
further by briefing the media and/or MPs directly. I believed that a more
moderate and balanced approach would be to maintain a good working
relationship with Second Sight to ultimately ensure that their findings were
sufficiently objective and robust. I considered that this would be in the
best interests of both POL and all other stakeholders concerned.
Given, in my view, that replacing Second Sight was not the preferred
course of action, the alternative approach was to adopt the “softer option”
of explaining “to JA [James Arbuthnot] calmly but firmly why he cannot
allow SS to disseminate a misleading interim report”. Practically speaking,
this alternative approach meant either “delay[ing] or reposition[ing]’ the
interim report as a “very neutral status update”. Against the backdrop of
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concerns regarding Second Sight’s capacity and objectivity, I considered
that it would be inadvisable for a report to be published which, as we
perceived it at the time, only represented a partial (and not entirely
objective) picture. Such a course of action could be construed as
“misleading”. Accordingly, I suggested that it may need to be explained to
James Arbuthnot that the manner in which the interim report was
presented should be amended in order to manage expectations and
ensure that its contents were accurately portrayed.
POL’s response to MPs and journalists on the integrity of Horizon in 2013 and 2014
45.
46.
I am asked about the extent to which, from 2012, I was involved with
POL’s response to MPs and journalists who raised concerns as to the
integrity of the Horizon IT System. My role did not involve briefing or
dealing with journalists directly; this was handled by POL’s separate
Communications Team.
In relation to my involvement in responding to queries raised by MPs, my
role was principally to prepare briefing notes or written communications on
behalf of PV (or, on occasion, Alice Perkins) in respect of their meetings
with James Arbuthnot, or to provide an opinion on the tone or content of
the communications with him. Examples of my involvement in preparing
briefing notes for meetings with James Arbuthnot in 2013 can be seen in an
email from me to Alice Perkins on 21 March 2013, copying PV and others
[POL00097781]; and in a further email from me on 3 July 2013 to PV and
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Alice Perkins, copying others regarding a James Arbuthnot briefing
[POL00098898]. Examples of my involvement in preparing communications
with James Arbuthnot and Jenny Wilmott MP in 2014 can be seen in an
email chain between me, PV, Belinda Crowe, Chris Aujard, David Oliver and
Mark Davies on 12 and 13 May 2014 [POL00116554, POL00116557 and
POL00116562]. I also sent an email on PV’s behalf to James Arbuthnot on
10 May 2014 [POL00101018].
THE HELEN ROSE REPORT
47.
48.
I have been asked to set out the nature and extent of my understanding of
the creation of the Helen Rose report and POL’s response to the same.
In doing so, I am asked to consider document [FUJ00086811] (“the
Helen Rose report’). I was not involved in the creation of the Helen Rose
report and I do not recall being involved in POL’s response to it when I was in
post.
I did not personally share the Helen Rose report with, or provide a brief on the
Helen Rose report to more senior managers, board members, SPMs or MPs.
It would not be within my role to unilaterally share any information with SPMs
or MPs. I believe I first became aware of the Helen Rose report when it was
mentioned in an email from Rodric Williams to me on 23 October 2013
[POL00108163], in which he provided his contribution to the CEO Report for
the Board. I took the view at that time that it was not sufficiently material to
include reference to the Helen Rose report in the CEO report for the Board
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49.
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which I was compiling on that date, as set out in the email chain with Rodric
Williams. I did, however, arrange for a brief on the report (and other matters)
to be prepared for PV prior to the November 2013 Board (email from me to
Belinda Crowe, Chris Aujard, Rodric Williams and Sarah Paddison on 28
October 2013) [POL00196705]. I did not engage in this brief myself due to
my being on leave.
I am asked to what extent, if at all, did the matters concerning ARQ raised
in the Helen Rose report make me or anyone else at POL concerned that
past convictions may have been unsafe. I cannot speak for the view taken
by the legal team or any others who reviewed the Helen Rose report.
From my perspective, I did not review the report in detail and was
reassured by email communications in which I was informed Brian Altman
KC was of the view that it “added very little” and it was unlikely to become
an important document in the future.
THE INTERIM REPORT AND THE MEDIATION SCHEME
Involvement in response to Second Sight reports and the Mediation Scheme
50.
My involvement with POL’s preparation for, and response to the Second
Sight Interim report was consistent with the responsibilities of my Chief of
Staff role. As noted above, my role was primarily one of a conduit: to
collate information from the relevant business leads and SMEs, then to
synthesise such information into an accessible format for PV, the Board
or other audiences. For example, in terms of POL’s preparation for the
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51.
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Second Sight report, I produced the internal briefing note for the James
Arbuthnot meeting on 3 July 2013 ahead of the publication of Second
Sight’s Interim Report. This was attached to my email to Alice Perkins and
PV of the same date [POL00098898]. The information contained in the
briefing note was provided by various business leads, including Susan
Crichton, Alwen Lyons and Mark Davies.
In relation to the Initial Complaint Review and Mediation Scheme (“the
Mediation Scheme”) and the Working Group established to monitor the
Mediation Scheme (“the Working Group’), I did not have any substantive
role or responsibilities in either entity. I do not recall passing any
information to the Mediation Scheme or the Working Group.
Project Sparrow
52.
Project Sparrow was the internal name given to POL's follow-up of the
Second Sight Interim Report, its engagement with JFSA, the operation of
the Mediation Scheme, and matters connected to the same. A
subcommittee of the Board, chaired by Alice Perkins, and including PV
and at least one non-executive director, was established to provide
oversight of this programme of work. As described in the email chain
between Alice Perkins, PV, and Chris Aujard dated 10 March 2014
[POL00116321], it was considered that a smaller group of individuals
would help provide dedicated and more efficient governance for this work.
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POL’s treatment of complaints regarding Horizon
53. I have been asked to describe policies and strategies adopted by POL in
responding to complaints made about Horizon as part of the Mediation
Scheme (and more widely). As noted above, I had limited involvement in
the operation of the Mediation Scheme, and was not involved in the
process to determine which complaints/cases might be accepted as part
of the Mediation Scheme.
54. In terms of POL’s wider policies and strategies to respond to complaints
made about Horizon, I was aware of the following primary workstreams
during my tenure as Chief of Staff, as set out in the Board report dated 26
July 2013 [POL00298004):
a) Completion of the review of the remaining 47 cases which had been
referred to Second Sight for investigation by JFSA and MPs, with the
aim of seeking some form of resolution in each case. This formed the
basis of the Mediation Scheme.
b) POL had instructed Cartwright King to undertake a review of its past
and present prosecutions to identify any cases where the Second
Sight report ought to be disclosed. It had also been consulting with
Brian Altman KC to provide additional advice and independent
oversight over this process. Further details of these reviews are set out
at paragraph 75 below.
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c) Significant improvements to training and support for SPMs was
proposed, to be led by Angela van den Bogerd, and supported by a
programme board. This workstream related to the Branch Support
Programme and the Branch User Forum, further discussed at
paragraphs 61 to 65 below.
d) It was also anticipated that similar, historical complaints about Horizon
may be made following media and Parliamentary attention arising from
the Second Sight interim report. My understanding is that the
Mediation Scheme was intended to be extended to such new cases,
with a filtering (or application process) to be implemented for those
new, additional complaints prior to their acceptance in the Mediation
Scheme.
I have also been asked to describe my involvement in liaising with MPs
and government in respect of complaints made about Horizon in the
Mediation Scheme (and more widely). I did not have a role in briefing MPs
directly; such a responsibility would have been led by the POL
Communications team. As noted above, my role was limited to ensuring
that PV was well-prepared for any meetings with MPs. In terms of
communications with the government, I had an informal role in keeping
the Shareholder Executive (“ShEx”) team updated with matters across
POL. For instance, this included providing updates to POL’s ShEx team
regarding progress of the Working Group (see, for example, the email
correspondence from myself to Will Gibson (ShEx) attaching a last draft
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of the Horizon statement dated 8 July 2013) [UKGI00001730]). It also
included liaising with the ShEx team regarding the progression of the
Mediation Scheme (see, for example, the update provided in the email to
Will Gibson and Peter Batten (ShEx) dated 24 October 2013)
[UKG1I00002119]. This complemented the more formal engagement
mechanisms between ShEx and POL, for example, PV’s monthly
meetings with the relevant ShEx director, and ShEx’s representation on
the Board.
Branch Support Programme
56.
57.
I have been asked to explain the purpose of the Branch Support
Programme (“the Programme’), how it was implemented, and my
involvement in it. The Programme was primarily established, as a result of
the findings in the Second Sight Interim Report, to improve the
effectiveness of POL’s processes regarding the training and support
offered to subpostmasters across the network.
I have been referred to the Terms of Reference of the Programme (dated
19 July 2013) [POL00089711]. The purpose of the Programme, as set
out in its Terms of Reference, was as follows:
The purpose of this Programme is to understand the current business
processes, operational procedures and ways of working which are in
place to support branches, identify the gaps and produce
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58.
59.
60.
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recommendations to rectify the issues.
The Terms of Reference also set out how the Programme was to be
implemented. The approach was to follow “normal project management
principles”, with a governance structure established, key stakeholders
identified, and a project plan with key milestones and deliverables
developed. In terms of governance, the Programme was requested to be
established by Alice Perkins and PV. Angela Van-Den-Bogerd was to
lead the Programme, with Gayle Peacock and Amanda Stevens
accountable for running the Programme at an operational level.
In terms of key stakeholders, the Terms of Reference set out each
business area, together with the respective individuals responsible at both
the Programme Board level and the Working Group level. The key
deliverables of the Programme, as well as the key performance indicators
and how the Programme’s success would be measured, were also set
out. This included, for example, agent and _ colleague
engagement/satisfaction, the quality of training and support provided, the
value of branch losses and debt, costs, the structure, as well as the
robustness of the system.
I have been asked to describe my involvement in the Programme. I did
not have any substantive involvement in the establishment of the
Programme, nor did I have direct responsibilities at any level in relation to
the Programme itself. However, I may have received ad hoc updates on
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the Programme, and other Project Sparrow workstreams, through the
course of collating updates for PV or the Board.
Branch User Forum
61. I have been asked to explain the purpose of the Branch User Forum (“the
Forum’), how it was implemented, and my involvement in it. The Forum
was established as a mechanism through which subpostmasters, JFSA,
and other key stakeholders could raise any concerns regarding POL
processes, training and support.
62. I have been referred to the draft Terms of Reference for the Forum (dated
19 August 2013) [POL00027664]. My understanding of the purpose of the
Forum is consistent with that described in its Terms of Reference, as
follows:
The purpose of the Branch User Forum is to provide a way for sub-
postmasters and others to raise issues and insights around business
processes, training and support directly feeding into the organisation’s
thinking at the highest level. The forum is a forward looking
mechanism to ensure the business processes and approaches are fit
for purpose for users and are in keeping with Post Office behaviours
and values.
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63. The Forum’s Terms of Reference also set out its specific objectives,
namely:
e To assess issues raised from with[in] the Post Office network;
identify appropriate solutions and recommend improvements to
rectify the root cause and prevent recurrence of the issue.
e To assess issues raised from Post Office support/central functions;
identify appropriate solutions and recommend improvements to
rectify the root cause and prevent recurrence of the issue.
e To input into the design of the end to end process for new products
and services before launch to the Post Office Network.
e To assess improvement suggestions from the Post Office network
and support/central function i.e. “would this work?”
64. Membership of the Forum consisted of either those responsible for the
design and delivery of POL policies, processes, training and support, or
were the end users of the same. The Forum comprised a core POL senior
manager population, who was entitled to refer to a subgroup of POL
experts to assess the operational implications of issues and improvement
opportunities. The Chair of the Forum was Angela Van Den Bogerd, and
membership consisted of representatives from the POL IT & Change
team, POL Network team, POL Commercial team, representatives of
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65.
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subpostmasters, and representatives of the Crown (Directly Managed)
Branches.
I have been asked to describe my involvement in the Forum. I did not
have any substantive involvement in the establishment of the Forum, nor
did I have responsibilities at any level in relation to the Forum itself.
Involvement with Mediation Scheme and Working Group
66.
67.
I have been asked to describe my involvement in briefing POL senior
managers in respect of the Mediation Scheme. The briefings to PV and
Alice Perkins (as well as other senior managers) generally originated from
the dedicated project team established to implement and run the
Mediation Scheme from around October 2013. Accordingly, once the
dedicated project team had been onboarded, I did not have a major role
in preparing briefings or directly passing on information in respect of the
Mediation Scheme and Working Group to POL senior managers. My main
ongoing involvement was limited to incorporating updates on the
Mediation Scheme, Working Group and other ‘Project Sparrow’
workstreams into the CEO’s Report to the Board.
Prior to the establishment and onboarding of the full dedicated project
team however, there may have been occasions, albeit limited, when I
prepared briefings for PV and the Board. I would do so in a manner
consistent with the briefings I prepared on other matters, namely by
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collating relevant information from the respective business leads and
synthesising the information into a readable format. Examples of such
occasions included the following:
a)
An update to the Board, which I prepared on 26 July 2013 regarding
the key workstreams arising in response to the Second Sight report,
and which also included an update on the establishment of the
Mediation Scheme [POL00298004]. The update provided further
details in relation to the likely profile of the proposed mediator, the
possible outcomes of the mediation process, discussions with James
Arbuthnot, Second Sight and JFSA regarding the process, as well as
alternatives to mediation.
A briefing to PV, which I prepared in advance of her meeting with Sir
Anthony Hooper on 24 September 2013. The briefing was to prepare
PV for her initial meeting with Sir Anthony Hooper to discuss his
potential role as Chair of the Working Group (which was tasked with
running the Mediation Scheme). The briefing was attached to my email
of the same date, and sent to PV, copying in Susan Crichton, Alwen
Lyons, and Theresa Iles [POL00116131].
In terms of the Mediation Scheme and Working Group more generally, I did
not have any substantive involvement in the determination of the scope of
either entity. While I may have been involved in preliminary discussions
regarding the establishment of the Working Group itself (see for example
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my email to Mark Davies dated 6 July 2013, copying in Alwen Lyons, PV,
Lesley Sewell, Susan Crichton and Theresa Iles [POL00099050], I do not
recall being involved in producing the Working Group’s Terms of
Reference.
I have been asked to describe the extent to which I was involved in any
decision-making relating to the ambit of Second Sight’s investigation or its
access to relevant information and documents. As noted at paragraph 42
above, I did not have any substantive decision-making role in respect of
Second Sight's investigation. Such a role would have been undertaken by
the dedicated project team established to implement and run the
Mediation Scheme, reporting to the General Counsel and PV.
Notwithstanding this, on several occasions, in the course of preparing
briefing notes for PV, I had limited input to dialogue regarding Second
Sight’s involvement (see for example my email to Belinda Crowe, Chris
Aujard and David Oliver dated 5 February 2014 and the corresponding
attachment regarding the pros and cons of the three options in respect of
Second Sight’s continued involvement [POL00116250] and
[POL00116251], and my email to PV and Theresa Iles dated 13 February
2014 regarding the meeting with Sir Anthony Hooper, including how to
engage with Second Sight going forward [POL00108257]. As discussed
in paragraphs 40 to 44 above, at an earlier stage in the process, prior to
publication of the Interim Report and establishment of a dedicated project
team, I did set out my concerns should the ambit of Second Sight’s
investigation be changed ahead of the publication of the Interim Report
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[POL00098777].
As I was not required to personally attend the meetings of the Working
Group, I did not have a first-hand view into the operation of the Working
Group. My understanding of what had occurred in Working Group meetings
would generally be the result of reviewing summaries of those who had
attended such meetings. I therefore cannot recall forming any personal
views on how the Working Group operated.
POL’s strategy in responding to Second Sight Report
71.
72.
I am asked to describe the nature and extent of my involvement in POL’s
response to Second Sight investigations and/or applications made to the
Mediation Scheme. I do not recall being directly involved in POL'’s
response to applications made to the Mediation Scheme. I was, however,
involved in POL’s response to the Second Sight Interim Report, albeit not
in any decision-making capacity. I have discussed the nature and extent
of my involvement in POL’s response to the Second Sight Interim Report
at paragraph 50 above.
I am also asked to describe POL’s strategy in preparing responses to
applications to the Mediation Scheme and/or Second Sight reports. In
relation to POL’s strategy regarding its response to the Second Sight
reports, my substantive involvement related to POL’s response to the
Second Sight interim report (dated 8 July 2013), and I am therefore
responding to this question on that basis only. My understanding of POL’s
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general strategy in responding to the Second Sight interim report was to
emphasise the seriousness with which POL was taking the Second Sight
investigation process, ensuring that the relevant lessons would be learned
from the findings where appropriate. It was important that the Second
Sight report was understood to be rigorous, independent, and grounded in
the facts. However, it was also important that confidence in POL was not
to be undermined unfairly, given Second Sight’s findings in the interim
report were that there was no evidence to support any suggestion of
systemic failures with Horizon. At the same time, POL acknowledged that
there may have been potential deficiencies with historical processes
regarding Horizon user experience for SPMs, and therefore improved
training and support for SPMs was required. POL also wanted to reaffirm
its commitment to completing the review of the remainder of cases yet to
be considered by Second Sight, which were put forward by JFSA and
MPs. POL’s strategy is encapsulated in detail in the briefing note for the
James Arbuthnot meeting on 3 July 2013 [POL00098898], as discussed
at paragraph 50 above. In relation to POL’s strategy in response to
Mediation Scheme applications, as I did not have any substantive
involvement in such applications, I do not have any personal insight of
POL’s strategy in respect of the same. I refer to paragraphs 53 to 54
above in relation to my understanding of POL’s strategy at the time.
Additionally, I have been asked to describe POL’s approach to disclosing
documentation to Second Sight. I did not have any role in Second Sight's
access to relevant information and documents or POL’s approach to
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disclosure of the same.
POL relationship with Fujitsu
74.
I have been asked to describe my views on the nature and extent of
Fujitsu’s assistance in POL’s response to applicants of the Mediation
Scheme. I was not involved in dialogue between Fujitsu and POL in
relation to Mediation Scheme applicants. At a general level, I do not recall
any matters of concern raised by the project team regarding Fujitsu's
assistance in the Mediation Scheme.
POL review of past convictions based on Horizon data
75.
I have been asked to explain my involvement in POL’s review of past
convictions obtained in reliance on Horizon data. I was not directly
involved in this review. However, I was made aware of the fact of the
review when collating information for the completion of CEO and/or Board
reports. In the course of drafting the Board report dated 26 July 2013,
which provided an update on progress following publication of the Second
Sight interim report [POL00298004], I was supplied with information from
SMEs regarding (inter alia) the Cartwright King review. This included the
fact that Cartwright King was reviewing past and present POL
prosecutions to identify any cases where the Second Sight report ought to
have been disclosed, and that it was then for the defendant to decide
whether to apply to the Court of Appeal for permission to appeal a
conviction based on additional information. I was made aware of the fact
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that, as of 22 July 2013, Cartwright King had reviewed 124 cases, with
the following outcomes:
e The prosecution was discontinued in three cases as not being
in the public interest;
e Disclosure to the defence had been provided in six cases;
e In all cases, the recommendation is that POL should oppose
any attempted appeal; and
e It was not believed that any of the cases would satisfy the test
for compensation from the government for a miscarriage of
justice under the Criminal Justice Act.
76. I was also made aware of the fact that POL was consulting Brian Altman
KC to provide additional advice and independent oversight on this case
review process, as well as any wider criminal law questions that might
arise. Counsel's scope of work was also to include recommendations
regarding POL’s future prosecutions strategy.
Investigation of POL’s suspense account
77. I have been asked to comment on my knowledge and involvement with
the investigation of POL’s suspense account. I do not recall having any
knowledge or involvement in this aspect of the investigation.
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Criticisms of POL in JFSA letter to Sir Anthony Hooper (dated 10 November 2014)
78.
I have been asked for my views in relation to the criticisms made of POL
by Alan Bates in his letter to Sir Anthony Hooper dated 10 November
2014 [POL00107151]. This letter was sent to Sir Anthony Hooper after I
had left my role as Chief of Staff in October 2014. I do not recall reviewing
this letter at the time.
POL’s internal communications regarding challenges to Horizon
79.
80.
81.
I have been asked about my involvement in POL’s _ internal
communications regarding challenges to Horizon, and what POL’s policy
was in respect of such communications.
My personal involvement in POL’s internal communications regarding
challenges to Horizon did not extend beyond my Chief of Staff
responsibilities, which have already been discussed above. The POL
Communications team led on internal communications and I had limited
involvement in this in my role as Chief of Staff.
I was not aware of any formal POL policy in respect of internal
communications on this matter. However, if media reports on a certain
topic intensified, then it would be normal practice for the Communications
team to circulate an update together with the business’ views on that topic
to POL staff members.
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Treatment of applications made to Mediation Scheme
82.
83.
I have been asked whether I had concerns that I (or those responding to
Mediation Scheme applications) were not receiving accurate and/or
complete information regarding BEDs, remote access, or integrity of the
Horizon system. As noted above, I did not have any personal involvement
in the Mediation Scheme, including POL’s responses to Mediation
Scheme applications. I am therefore unable to provide an informed view
on whether those responding to applications to the Mediation Scheme
were receiving accurate/complete information regarding BEDs, remote
access, or the integrity of the Horizon system. I do not recall any specific
concerns which were flagged to me by the dedicated project team in
relation to the same.
I have also been asked why I consider POL’s investigation of allegations
made by SPMs as part of the Mediation Scheme did not identify new
BEDs, a lack of integrity in Horizon, or the extent of remote access. I have
discussed above, at paragraphs 13 to 16, the extent of my general
awareness of those three matters. On the basis that I am not speaking
with the benefit of hindsight, I recall being made aware of the general
progress of the Mediation Scheme as part of assembling the relevant
briefing documentation and updates for senior managers. However, I had
limited direct knowledge of the manner in which cases submitted to the
Mediation Scheme were assessed and investigated, and accordingly am
unable to express a personal view.
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84.
85.
86.
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I have been asked to describe my views on the reasons/motives for
subpostmasters making applications to the Mediation Scheme or
campaigning in respect of Horizon. I kept an open mind about the varying
circumstances and motivations of the many SPMs that were coming
forward by this point in time, but in essence my understanding is that
overwhelmingly they were motivated by a desire to address what they
(rightly) viewed as inappropriate treatment by POL and clear their names
of injustices.
Relatedly, I have been asked to what extent I believe the Mediation
Scheme fulfilled POL’s intended purpose in establishing it. My
understanding of the intended purpose of the Mediation Scheme, when it
was originally established, was to ensure that the existing cases
submitted to the Second Sight process would be properly reviewed and
resolved. This was to be done by assisting the specific SPM and POL to
find common ground in resolving the SPM’s complaint, via an
independent and neutral mediator. It was also envisaged that additional
historical cases might be submitted for mediation as a result of the media
and Parliamentary attention arising from the Second Sight Interim Report.
Such cases would be assessed for suitability prior to inclusion in the
Mediation Scheme.
On the basis of my limited direct knowledge of the Mediation Scheme and
its processes, I believe that POL entered into mediation discussions with
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positive intent. While I understand some cases were successfully
resolved in advance of mediation, in light of how events subsequently
unfolded and with the benefit of hindsight, it is clear that the Mediation
Scheme did not fulfil its intended purpose, given the fact that a large
number of SPMs remained of the view that their concerns were not
addressed.
Termination of Working Group
87.
I have been asked to explain why POL terminated the Working Group. It
appears that the Working Group was terminated in early 2015. This
occurred after I left my role as Chief of Staff in October 2014. I was not
party to any discussions or decisions regarding its termination, or the
communication of that termination to any stakeholders.
Deloitte and Project Zebra
88.
I have been asked to what extent I was involved or aware of the
instruction of Deloitte on Project Zebra. While I was aware of the
appointment and copied into emails regarding Deloitte’s instruction in
early 2014 (see for example the email from Belinda Crowe to me on 12
May 2014, [POL00116554]), I was not involved in the instruction of
Deloitte on Project Zebra.
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THE DEATH OF MR MARTIN GRIFFITHS
89.
90.
I am asked to describe the nature and extent of my involvement in POL's
response to the tragic news that Mr Griffiths had taken his own life. I first
became aware that Mr Griffiths had been involved in an incident on or
around 23 or 24 September 2013. I note that I was copied into an email
from Mark Davies to PV on 24 September 2013 in relation to Mr Griffiths.
[POL00116133]. I believe that I may have been informed of this before
the email was sent, perhaps verbally. I was not expected to brief PV on
this matter. Given its importance and very sad circumstances, members
of POL senior management had briefed PV directly. I was not expected
to take any action in relation to this email; I had been copied for
information only.
I provided an update to Alice Perkins by email on 2 October 2013 at
1.10pm [POL00116145]. In particular, I note that Alice had asked
whether James Arbuthnot had been spoken with, given that Alan Bates
had copied him into an email in respect of Mr Griffiths’ accident. My
involvement at this stage was to provide an update to Alice Perkins about
PV’s communication with James Arbuthnot to explain the steps that POL
was taking to support Mr Griffiths’ family, and more generally. I believe I
may have obtained an update on the date of Mr Griffiths’ funeral at the
request of PV, but I had no substantive involvement beyond being copied
into emails and providing isolated pieces of information, when requested.
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91.
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I am asked to set out the nature and extent of my involvement in POL’s
decision making in offering Gina Griffiths a discretionary payment.
Although I may have been copied into some emails on this topic, I was
not part of the decision-making process. This sensitive matter was dealt
with at a senior level in POL, without any substantive involvement from
me.
POL’S RESPONSE TO COMPLAINTS FOLLOWING THE MEDIATION SCHEME
Involvement_in POL’s response to_ concerns raised by SPMs, MPs and journalists
regarding Horizon
92.
93.
I am asked to summarise the extent to which I was involved in POL’s
response to concerns raised by MPs and journalists regarding Horizon.
Given the heading of the section in the Request I assume this relates to the
period following the closure of the Working Group to the letter of claim in the
group litigation. My involvement in POL’s response to concerns raised by
SPMs, MPs and journalists regarding Horizon was limited to preparing some
briefing notes in for meetings with MP James Arbuthnot when I was in my
role of Chief of Staff (between September 2012 and October 2014). I was
not involved in POL’s response to concerns raised by SPMs MPs and
journalists after that date.
I am further asked about my role in briefing the POL Board/ senior
management on Horizon following the closure of the Working Group. I was
not involved in any activities following the closure of the Working Group as I
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moved on from my role as Chief of Staff in October 2014 and was no longer
involved in the Mediation Scheme or its aftermath in any way.
POL’s response to journalists in 2015
94.
I am asked to describe the nature and extent of my involvement in POL’s
response to journalists running, or proposing to run, stories on the
Horizon IT system, including Panorama. I! am referred to a number of
emails relating to communications within POL in respect of the Panorama
documentary. Although I may have received the general update emails
from the communications team, as they were sent throughout the
business, I was not involved in POL’s response to journalists at this stage.
That was not part of my remit in my new role as Group Strategy Director
at POL, which I commenced in October 2014. For this reason, I was not
involved in any discussions on, or contact with, Richard Roll following his
appearance on Panorama.
THE SWIFT REVIEW
95.
96.
I was not involved in any aspect of the Swift Review as it post-dated my
time as Chief of Staff. I note that the Swift Review report is dated 8
February 2016 which is significantly after I transitioned to my new role in
October 2014.
I do not recall being given the Swift Review to read or receiving a brief in
relation to its contents.
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GROUP LITIGATION AND POL’S RESPONSE
97. I was not involved at all in the group litigation as this process was
instigated after I had left my Chief of Staff role in October 2014 and it did
not fall to be part of my subsequent roles at POL.
GENERAL
Reflections
98. I have been I have been asked to comment on whether there is anything I
would have handled differently, with hindsight, in relation to the Horizon IT
System and its associated issues. I have given considerable thought to this
question, and reflected, at length, on my responsibilities as Chief of Staff from
September 2012 to October 2014.
99. As I have set out in this statement, my role as Chief of Staff primarily
comprised supporting PV on a day-to-day basis, and in particular co-
ordinating and preparing briefing documentation to or on behalf of PV. I was
not the SME on any particular issue, nor did I have any substantive decision-
making accountabilities. At the time, I was reassured that POL was
establishing what I believed to be a rigorous and appropriate approach to
investigate and resolve the emerging concerns of SPMs, namely setting up
the Mediation Scheme overseen by an independently-chaired Working Group
involving both Second Sight and the JFSA. While the collapse of this process
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post-dated my role as Chief of Staff, it is evident, with hindsight, that those
arrangements were wholly inadequate to deal with what we know now to be
the scale of past injustices. Given the parameters of my role, it is difficult to
identify specific examples of what I might have done differently at the time, as
my awareness of circumstances now is markedly different to my
understanding then. Notwithstanding this, I wish to express my sincere
sympathies to the SPMs that have been so profoundly impacted by the
matters considered by this Inquiry.
100. Should there be any additional documents relating to the matters being
considered by the Inquiry, I would be very willing to review such documents
and assist the Inquiry further.
Statement of Truth
I believe the content of this statement to be true.
Signed: I
Dated:
GRO I
18 April 2024 I 12:57 PM BST
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Index to First Witness Statement of Martin Edwards
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No. URN Document Description Control
Number
1. POL00041564 I Computer Weekly article dated 11 May POL-0038046
2009
2. POL00026572 Rod Ismay Report dated 2 August 2010 POL-0023213
3. POL00029590 I Email from Alwen Lyons to Martin POL-0026072
Edwards dated 4 June 2013
4. POLO0099063 Second Sight Interim Report dated 8 July} POL-0098646
2013
5. POL00098778 Email from Lesley Sewell to Martin POL-0098361
Edwards dated 28 June 2013
6. POL00130356 I Witness Statement of Gareth Idris POL-0120540
Jenkins
7. POL00115748 Email from Martin Edwards to Theresa POL-0114919
lles, Alwen Lyons and Simon Baker
dated 24 September 2012
8. POL00107793 I Email from Theresa Iles to Janet Walker I POL-0110840
dated 28 September 2012
9. POL00097030 I Email from Martin Edwards to Simon POL-0096613
Baker, Alwen Lyons and Susan Crichton
dated 4 October 2012
10. POL00097058 I Email chain between Theresa Isles, POL-0096641
Paula Vennells and Martin Edwards
dated 18 October 2012
11. POL00298004 Briefing paper for the Board ‘Update on I POL-BSFF-
the work programme arising from the 0136054
Horizon report’ dated 26 July 2013
12. POL00113791 Email from Susan Crichton to Alice POL-0112899
Perkins and Paula Vennells dated 6 JuneI
2012
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13. POL00097781 Email from Martin Edwards to Alice POL-0097364
Perkins, Paula Vennells and others
re: Draft letter for James Arbuthnot dated
21 March 2013
14, POL00098777 Email from Martin Edwards to Paula POL-0098360
Vennells dated 27 June 2013
15. POL00098898 I Email from Martin Edwards to Paula POL-0098481
Vennells and Alice Perkins, copying
others regarding James Arbuthnot
briefing dated 3 July 2013
16. POL00116554 I Email from Belinda Crowe to Martin POL-0117482
Edwards dated 12 May 2014
17. POL00116557 Emails between Martin Edwards, Paula I POL-0117485
Vennells, Belinda Crowe and others
dated 12 May 2014
18. POL00116562 Email from Martin Edwards to Belinda POL-0117490
Crowe, Mark R Davies, Chris Aujard and
others dated 13 May 2014
19. POL00101018 Email from Martin Edwards on behalf of I POL-0100601
Paula Vennells to James Arbuthnot
dated 10 July 2014
20. FUJ00086811 The Helen Rose Report (last edit date of I POINQ009298
12 June 2013) 2F
21, POL00108163 I Email from Rodric Williams to Martin POL-0110958
Edwards dated 23 October 2013
22. POL00196705 I Email from Martin Edwards to Belinda POL-BSFF-
Crowe, Chris Aujard, Rodric Williams 0034768
and Sarah Paddison dated 28 October
2013
23. POL00116321 Email chain between Alice Perkins, POL-0117314
Paula Vennells, and Chris Aujard dated
10 March 2014
24. UKGI00001730 I Email from Martin Edwards to Will UKGI012544-
Gibson dated 8 July 2013 001
25. UKGI00002119 I Email from Martin Edwards to Will UKGI012933-
Gibson and Peter Batten dated 24 001
October 2013
Page 47 of 48
WITNO9760100
WITNO9760100
26.
POL00089711
Branch Support Programme — Terms of
Reference v.2 dated 19 July 2013
POL-0086686
27.
POL00027664
Post Office Branch User Forum (The
Forum) — draft Terms of Reference dated
19 August 2013
POL-0024305
28.
POL00116131
Email from Martin Edwards to Paula
Vennells, copying in Susan Crichton,
Alwen Lyons, and Theresa Illes dated 24
September 2013
POL-0117130
29.
POL00099050
Email from Martin Edwards to Mark
Davies copying in Alwen Lyons, Paula
Vennells, Lesley Sewell, Susan Crichton
and Theresa Iles dated 6 July 2013
POL-0098633
30.
POL00116250
Email from Martin Edwards to Belinda
Crowe, Chris Aujard and David Oliver
dated 5 February 2014
POL-0117244
31.
POL00116251
Note from David Oliver to Paula Vennells
copying in Chris Aujard, Belinda Crowe
and Martin Edwards dated 5 February
2014
POL-0117245
32.
POL00108257
Email from Martin Edwards to Paula
Vennells and Theresa Iles dated 13
February 2014
POL-0110963
33.
POL00107151
Letter from Alan Bates to Sir Anthony
Hooper dated 10 November 2014
POL-0105459
34.
POL00116133
Email from Mark Davies to Paula
Vennells dated 24 September 2013
POL-0117132
35.
POL00116145
Email from Martin Edwards to Alice
Perkins dated 2 October 2013
POL-0117144
Page 48 of 48