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Witness Name: David Basil George Oliver
Statement No: WITN09780100
Dated: 12 December 2024
POST OFFICE HORIZON IT INQUIRY
FIRST STATEMENT OF DAVID BASIL GEORGE OLIVER
I, David Basil George Oliver, will say as follows in response to a Request for
Information pursuant to Rule 9 of the Inquiry Rules 2006 — Request number 1 dated 4
November 2024 (the “Request’), regarding matters falling within Phase 5 and 6 of the
Inquiry.
INTRODUCTION
1. The Inquiry has asked me to provide a brief outline of my professional
background, summarising my career and qualifications.
2. I am currently employed by PA Holdings Limited, part of the PA Consulting
Group (“PA”), a professional services and consultancy firm that works with
public, private and third-sector organisations. PA provides a wide range of
services, including management consulting, IT consulting, and technology and
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innovation services across a variety of sectors, including local and national
governments.
3. I studied Natural Sciences at the University of Cambridge. I am currently a
Partner at PA. I joined PA in November 2013 as a Principal Consultant. Before
that, I spent 10 years in the Civil Service, entering as a Civil Service Policy
Fast Streamer, and going on to have a series of senior Civil Service roles
focussing on policy, strategy and private office.
4. For the relevant period of time that I was providing services to the Post Office
Limited (“POL”), I was a Principal Consultant at PA. The duration of the POL
assignment was between December 2013 and October 2014. My assignment
to POL was primarily to provide support, management and programme
management services for the Initial Complaints and Mediation Scheme (the
“Scheme”). My formal role was Programme Manager of the Scheme.
5. The Inquiry has asked me to set out in detail my appointment to that role, my
relevant training and experience, my understanding of my role and
responsibilities (including any material changes during the duration of the
assignment), who I reported to, and my general views on the competence and
professionalism of the team and managers at POL.
6. PA had a pre-existing relationship with POL, prior to me becoming employed
by PA. Ahead of the assignment, I recall being asked to attend an initial
meeting with POL (Belinda Crowe), where my assignment to POL to assist in
the running of the Scheme was first discussed.
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7. The initial assignment was to assess the programme and make
recommendations for improvements over a circa 4-week period. This
extended into supporting the delivery and administration of the Scheme.
8. I recall that the main reason for POL seeking to obtain extra support for a
degree of the administration of the Scheme was because, up until that point,
there had been a lack of general programme structure / governance for the
delivery of the Scheme and also a lack of sufficient resource within POL, to
commit to it. The Scheme was in danger of stagnating and not meeting the
assurances that POL had given to external stakeholders. There was also an
element of public scrutiny (both political and from the media) associated with
the Scheme. My past experience in the Civil Service, which included handling
external communications, led to me being selected to provide assistance to
POL.
9. As above, my educational background is in Natural Sciences. My relevant
professional background (at the time of being engaged by POL) was working
within the Civil Service, in roles focussing on policy and strategy. Generally, I
had experience of delivering and administering complex projects. I do not have
any relevant technical IT qualifications or experience, nor am I legally trained.
10. My role was to be the Programme Manager of the Scheme. In short, my role
was to assist POL in delivering and administering that Scheme, such that it
was progressed and completed as efficiently as possible, whilst servicing
(where possible) the requirements of all interested stakeholders. At the time
of my engagement by POL, the Scheme did not have a clear level of
governance, there were a significant number of cases / claims from sub
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postmasters / subpostmistresses (“SPM”) which had been entered into the
Scheme, and there were concerns within POL about how those cases could
be properly progressed and resolved through the Scheme, within an
appropriate and acceptable timescale (based, in part, on a lack of available
capacity and expertise within POL). I will necessarily provide more detail on
my role in the rest of my statement, whilst addressing the Inquiry’s specific
questions.
11. My direct POL client for the assignment was Belinda Crowe. My senior
reporting manager for the assignment was Chris Aujard. Overall project
reporting for the Scheme flowed through Chris Aujard to both Paula Vennells
and Alice Perkins. Paula Vennells and Alice Perkins were both informally
updated, and formally updated, via board / sub-committee updates. Whilst not
formally part of the Scheme, POL’s own investigation of cases which had been
accepted into the Scheme was led by Angela van den Bogerd. Angela van
den Bogerd was also responsible for managing the separate Business
Improvement workstream, which ran concurrent to the Scheme (i.e. that any
potential improvements / learning points for POL systems identified through
the administration of the Scheme and the handling of cases, would be
considered and implemented through that workstream).
12. At the time and based on my interactions, I generally considered the team
within POL, in terms of the narrow focus of my engagement (i.e. to administer
the Scheme) to be competent and professional. As above, my main client
contacts were Belinda and Chris; both of whom I understand had not been at
POL for a significant period of time before my assignment commenced in
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December 2013. Belinda appeared to be an experienced mid-senior manager,
who was open-eyed to the issues facing the Scheme and the work needed to
try and progress it. I believe that Chris had come from a predominantly
Financial Services background and appeared to have a wide-span of
workstreams under his control as General Counsel, beyond the Scheme (such
as the criminal prosecutions, general commercial, M&A etc). It was clearly a
sensitive period for POL, both in terms of potential financial and reputational
risk, and it appeared to me that there was a genuine intention by those I
worked closely with (primarily, Belinda and Chris) to progress the Scheme in
an effective manner, such that as many cases as possible could reach a
satisfactory resolution.
BRIEF ADDITIONAL BACKGROUND AND CLARIFICATION
13. Whilst the Inquiry has not asked me to address the following points, I believe
they are necessary to provide sufficient context and clarity to the answers that
I will go on to provide throughout this statement.
14. As stated above, I do not have any technical IT expertise and that my role
within POL did not involve any aspect of considering or analysing the Horizon
Software as a whole or in specific cases. Considering and / or addressing the
technical substance of any claims which were being made via the Scheme
(i.e. alleged technical faults within Horizon by SPMs) did not fall within my
remit and did not have any impact upon the administration of the Scheme
itself. The Scheme was effectively a form of dispute resolution between SPMs
and POL. Equally, the technical position adopted by POL in relation to Horizon
(ie. that there were no systemic issues), both as a mediating party within the
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Scheme and publicly, did not impact upon my administration of the Scheme
itself, nor was it part of my role to interrogate, assess or advise in relation to
POL’s technical position.
15. I am not legally trained and that, whilst POL sought external legal advice from
a number of law firms (which, in some instances, I had sight of and shall
address in this statement), my involvement in the Scheme was a separate and
distinct workstream from any civil and / or criminal proceedings that were
undertaken by POL against SPMs, and the associated legal advice that was
obtained. During my assignment with POL, I was necessarily aware of those
proceedings and the extent to which they effected the way in which they could
be progressed and settled through the Scheme. However, I was not part of
any decisions relating to the conduct of those proceedings, POL’s disclosure
obligations within (or after) those proceedings, or the safety of those
proceedings (particularly convictions).
16. During my assignment with POL, I was provided with a POL laptop and a POL
email account. I was also required to predominantly work on POL premises
and to leave my POL laptop in a secure location within POL premises
overnight. I was not provided with open access to POL systems / data during
my time working on the Scheme; my level of access was limited to information
(passed to me by the POL team) and systems which were necessary to allow
me to administer and progress the Scheme. As set out above, my work on the
Scheme for POL concluded in October 2014, at which point I no longer had
any access to my POL email account or laptop.
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17. It has therefore been c.10 years since I had any direct involvement with, or
access to, POL information and systems. For the purposes of providing this
statement, I have not been able to check or cross-refer any of the exhibits
which have been provided to me by the Inquiry, due to my inability to access
the POL laptop / email account upon which all the relevant work was
conducted.
18. Due to the above, the information and answers provided by me in this
statement are entirely limited to: (i) the content of the exhibits which have been
presented to me by the Inquiry; (ii) the relevant period where I was engaged
by POL, namely December 2013 to October 2014; and (iii) the extent of my
recollection of the Inquiry exhibits and associated issues from c.10 years ago.
19. In responding to the Inquiry’s topics and questions, I shall confirm which
exhibits have been provided to me and that I have reviewed, before
responding to the Inquiry’s specific questions and further referring to the
exhibits where applicable / necessary.
20. For the purposes of responding to the Inquiry’s deadline for this statement,
and in light of the significant scope of the Inquiry’s Request (168 individual
questions, many with a significant number of additional sub-questions,
together with in excess of 1,800 pages of accompanying exhibits), it has not
been possible to provide detailed commentary and analysis of every exhibit. I
confirm that I have reviewed each of them, in order to answer the questions
put to me. This pragmatic approach has been taken to ensure that a statement
could be provided to assist the Inquiry, within the specified timeframe and to
prevent any delay to the Inquiry’s schedule.
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KNOWLEDGE OF HORIZON ISSUES
21. The Inquiry has asked me to confirm what IT expertise I had during my
assignment with POL. As per para. 14, I did not have any such IT expertise.
22. The Inquiry has asked me to confirm what knowledge and experience I had of
the Horizon IT System during my time with POL, together with any relevant
training, any steps that I took to increase my knowledge of Horizon IT System,
any initial opinion I formed and whether I noticed any common complaints from
SPMs.
23. As per para. 14, I did not have any technical knowledge or experience of
Horizon during my time with POL. I was not provided within any specific
training on the system (beyond a broad understanding of what it did, but not
how it did it) and the role I was undertaking did not require me at any point to
take any steps to increase my knowledge of the system itself. I did not (and
do not) have the technical expertise to allow me to provide any formal opinion
on the system itself. I was generally aware that there was a dispute between
POL and SPMs, whereby POL held a position that there were no systemic
issues with the Horizon system, and that various SPMs had alleged that there
were specific technical faults with the system. Those opposing positions had
formed the basis upon which the Scheme had been created (prior to my
assignment) and was the proposed method of dispute resolution to try and
narrow the gap, or otherwise resolve, those opposing positions. In
administering the Scheme, it was not part of my role (nor did I have the
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expertise) to analyse the credibility of the respective positions of either POL
or any SPM.
24. I necessarily became aware, through my administration of the Scheme and
knowledge of the cases that were being processed through it, of various
common themes within SPM cases / claims. Those common themes were
analysed and are set out in POL00040076, as broadly falling into three
categories: (i) training and support issues; (ii) Hardware / Software Issues with
Horizon; and (iii) and lack of an audit trail.
BUGS, ERRORS AND DEFECTS (“BEDs”) IN HORIZON
25. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
25.1. POL00021872; and
25.2. RLIT0000007.
26. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
27. The Inquiry has asked me to confirm when I first became aware of allegations
and complaints regarding BEDs in the Horizon system, or a lack of integrity in
the Horizon system. I was generally aware of allegations and complaints
regarding Horizon from the outset of my assignment with POL, as those issues
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formed the whole basis upon which the Scheme had been devised and
implemented. As per para. 14, I did not have the necessary expertise, nor was
it part of my role in administering the Scheme, to reach any form of view on
the nature or veracity of the complaints. Equally, I did not have the necessary
expertise, nor was it part of my role, to form a view on the veracity of POL’s
position whereby there were no systemic issues within the Horizon system.
28. The Inquiry has asked me to confirm what, if any, knowledge I had of the BEDs
summarised in RLIT0000007. This exhibit post-dates the relevant period
where I was engaged by POL. As per para. 24, I recognise some of the BEDs
outlined in the document as falling within the common theme of Hardware /
Software issues with Horizon, identified during the administration of the
Scheme (i.e. forming the basis of SPM complaints), however I do not (and did
not) have the technical expertise to provide any substantive opinion on the
BEDs themselves.
29. The Inquiry has asked me to confirm any involvement that I, or other members
of the Scheme management, had in dealing with and responding to complaints
by SPMs. I refer to para. 11 and para. 24. I had broad knowledge and
superficial (i.e. non-technical) understanding of complaints being raised by
SPMs, in relation to those cases which had been accepted into the Scheme.
It was not part of my role to investigate or respond to the subject matter of
those complaints, as this did not relate to the administration of the Scheme
itself (as a forum for discussion and mechanism for potential dispute resolution
between the positions of POL and SPMs, through mediation). POL
investigations into individual complaints were overseen by Angela van den
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Bogerd, to inform the position that POL would adopt at any final mediation, as
a party to that mediation. I did not form part of that investigation team and was
not privy to the technical outcomes of any investigations, to the extent that any
BEDs were, or should, have been identified.
30. The Inquiry has asked me to set out my understanding of POL’s approach to
handling such complaints. I answer this in more detail at para. 177, where I
address how the Scheme operated in practice and how complaints were
processed through it.
31. The Inquiry has asked me to set out the steps POL took to investigate
concerns raised regarding systemic and / or intermittent errors in Horizon. As
per para. 29, POL’s investigations into complaints was a separate and distinct
workstream to the administration of the Scheme, managed by Angela van den
Bogerd. I was not part of the investigation workstream.
32. The Inquiry has asked me to reflect on whether I consider POL did enough to
investigate the concerns raised about Horizon. I refer again to para. 29,
whereby I was not part of the investigation workstream. I discuss later in this
statement from para. 91, the advice POL received from Linklaters on 20 March
2014 (POL00105529) — specifically that “We note that there is, so far as we
understand it, no objective report which describes and addresses the use and
reliability of Horizon. We do think that such a report would be helpful’, that
“Second Sight seem to have relied on concerns raised by the JFSA [Justice
for Subpostmasters Alliance] to prepare their report...but they do not address
any fundamental questions about the problems with Horizon”, and that “They
[Second Sight] have done so without reference to any robust evidence as to
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how and why there may have been malfunctions with Horizon or how any such
malfunctions could have caused the losses in the particular case”. On
reflection, POL should have ensured that there was an objective report which
addressed the Horizon system as a whole (which, I understand, was originally
part of Second Sight’s scope of engagement). Equally, there were concerns
raised relating to the quality of the work being undertaken by Second Sight
(see para. 96), particularly around the absence of a firm evidential basis for
complaints and issues being raised. POL attempted to rectify the position by
instructing Deloitte to undertake an assurance review (see section from para.
107), but this did not provide the objective report and evidential base which
had been absent throughout. I reiterate that my role did not relate to
investigating concerns directly, but the lack of evidence relating to the
concerns raised about Horizon had an impact upon the effective running of
the Scheme and the extent to which a satisfactory resolution (including the
narrowing of any issues) within any specific mediation case could be achieved.
FUJITSU
33. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
33.1. POL00108424; and
33.2. POL00029710.
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34. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
35. The Inquiry has asked me to confirm if I am aware of whether any “further
explanation” was provided, in relation to Angela van den Bogerd’s email on 14
April 2014 [POL00108424]. Specifically, the email chain relates to the “Helen
Rose Report” and the suggestion that “Fujitsu have the ability to impact branch
records via the message store but have extremely rigorous procedures in
place to prevent adjustments being made without prior authorisation’. I was
aware of this suggestion, which I would generally describe as the “remote
access” issue. However, I cannot recall any further discussion on this point
and cannot comment on whether it was separately progressed and discussed
by other individuals within POL. I also cannot recall any occasion where I
liaised directly with Fujitsu, during my assignment with POL. I do recall that
lines of communication with Fujitsu were tightly controlled and that, from
POL’s perspective, there was no requirement for Fujitsu to interface with the
administration or management of the Scheme itself; their involvement was
limited to assisting POL’s investigations which, as per para. 29, was led by
Angela van den Bogerd and was a distinct workstream that I was not party to.
36. POL00029710 is from 2008 and therefore pre-dates my assignment with POL.
I can see that it relates to the issue of “remote access”. I cannot recall if I ever
saw this email during my assignment with POL.
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37. The Inquiry has asked me to confirm what knowledge did I and the other
members of the Scheme management team have of Fujitsu’s remote access
privileges and their ability to amend branch transaction data. I cannot speak
as to the knowledge of any other members of the Scheme management team.
Personally, I was broadly aware of the “remote access” issue, insofar as it
formed part of the common themes within the Scheme and I was copied into
various emails where it was discussed (e.g. POL00108424). However, I refer
to paras. 14 and 23; my role did not relate to the technical investigation of
issues or the veracity of complaints themselves.
38. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
38.1. POL00138077;
38.2. POL00138101;
38.3. POL00108521;
38.4. POL00021883; and
38.5. POL00021870.
39. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
40. The Inquiry has asked me to describe any circumstances in which I had
contact with Fujitsu, whilst working for POL. As per para. 34, I cannot recall
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any occasion whereby I contacted Fujitsu or attended any meetings where
Fujitsu personnel were present.
41. On that basis, in response to the Inquiry's follow-on questions, I am not able
to confirm the identify of any individual from Fujitsu with whom I was in contact,
nor can I detail any communications regarding BEDs in Horizon, or Horizon’s
general integrity.
42. I did not consult with either POL’s or Fujitsu's IT teams to investigate any
complaints relating to Horizon; this was not part of my role. I cannot comment
on the extent to which any of the team were involved in such investigations.
43. The Inquiry has asked me to comment on the extent to which I consider
sufficient information regarding BEDs in Horizon was passed to POL by
Fujitsu. As I was not part of that relationship or line of communication /
investigation, I cannot comment upon this.
THE HELEN ROSE REPORT
44. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
44.1. POL00116487;
44.2. POL00029707;
44.3. POL00116480;
44.4. POL00116486;
44.5. POL00108439;
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44.6. FUJ00086811; and
44.7. POL00020634.
45. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
46. The Inquiry has asked me to confirm when I first became aware of the Helen
Rose Report / the Lepton Report. I cannot recall when I first became aware of
the Helen Rose Report [FUJ00086811]. Prior to reviewing the exhibits
provided by the Inquiry, I would have said that I had never seen the report
before. However, I acknowledge that the exhibits provided show that I was
copied into various emails discussing the report and that the report was
attached to some of those emails. The report itself pre-dates my assignment
with POL, though I do not recollect it as a key document in my role.
47. The Inquiry has asked me to confirm my understanding of how and why the
report was commissioned. As above, the report itself pre-dates my assignment
with POL. I cannot therefore comment upon the specific circumstances in
which it was commissioned. From reading the report itself, I can see that it
relates to a reversal transaction issue that had been raised by an SPM, which
took place in October 2012 (again, pre-dating my assignment with POL).
48. The Inquiry has asked me to confirm, during my assignment with POL, what
knowledge I had as to the findings of the report in relation to BEDs in Horizon.
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As per para. 46, prior to reviewing the Inquiry’s exhibits I would have stated
that I had never seen the report before. From reading the report as part of the
preparation of this statement, I do not (and did not) have any knowledge
beyond the content of the report itself.
49. During my assignment with POL, I do not recall the report being a substantial
issue. My understanding was that it was primarily being dealt with by POL’s
criminal prosecution team (Jarnail Singh, Chris Aujard), which was a separate
and distinct workstream to the Scheme, and one which I did not have any
involvement; I refer to para. 15. I was aware that the report had been disclosed
to SPMs (but was not involved in the decision-making process) and that the
report was referred to within various SPM claims within the Scheme, relating
to the SPMs complaints with the Horizon system.
50. The Inquiry has asked me to confirm how and to what extent were the findings
of the report communicated to me and others within the Scheme management.
As I set out above, I acknowledge that I was aware of the report during my
assignment with POL but that, until reviewing the exhibits provided by the
Inquiry, I would have stated that I never had sight of it. I have already
commented upon what I understand the findings of the report to be. I cannot
comment on the extent to which the findings (or implications) were more
broadly communicated within POL, beyond the exhibits which I have been
referred to.
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51. The Inquiry has asked me to set out my understanding of POL’s response to
the report. Beyond my understanding that it had been disclosed to various
SPMs (which led me to believe that the report’s findings were not
fundamentally problematic to POL’s overarching position, for the purposes of
the Scheme, that there were no systemic issues with the Horizon system,
which POL maintained throughout my assignment), I cannot otherwise
comment upon POL’s wider response to the report or its findings.
52. The Inquiry has asked me to set out my understanding of the use that POL
made of the report. I repeat my answer at para. 51 above.
53. The Inquiry has asked me to confirm to whom within POL the report was
disseminated. I cannot confirm the POL recipients of the report, beyond those
individuals who are included within the email chain exhibits set out at para. 44.
54. The Inquiry has asked me to confirm what, if any, impact the report had on
how I (and the team) on the Scheme dealt with and responded to complaints
from SPMs about BEDs and / or the integrity of Horizon. Beyond the fact that
the report had been disclosed by POL to various SPMs, and thereafter was
referenced by SPMs in a number of the cases being progressed through the
Scheme, the report itself did not have any impact upon the administrative
running of the Scheme. As per para. 23, my role in administering the Scheme
did not extend to the consideration of the substantive technical positions of
either POL or SPMs, in relation to the existence of BEDs or the integrity of
Horizon as a whole.
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BEDs referenced in Second Sight’s Interim Report
55. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibit:
55.1. POL00099063.
56. I confirm that I have reviewed that exhibit and it has informed my answers to
the below questions.
57. The Inquiry has asked me to confirm when and how I became aware of this
report. Whilst Second Sight’s interim report dated 8 July 2013 pre-dated my
assignment with POL, I confirm that I was aware of its content during my
assignment. I cannot recall specifically when I was made aware of it; it was
certainly towards the start of my assignment (either December 2013 or
January 2014), and it may have formed part of some initial “reading-in”
material that was provided to me when I first started my assignment with POL.
58. The Inquiry has asked me to confirm, during my assignment with POL, what
knowledge I had as to the findings of the report in relation to BEDs in Horizon.
My recollection is that the findings of the report were a consistent reference
point throughout my assignment with POL; specifically, from POL’s
perspective, that Second Sight “have so far found no evidence of system wide
(systemic) problems with the Horizon software”. As previously explained, this
was (and remained) POL’s position throughout my assignment. In terms of
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BEDs, I was aware that the report refenced “2 incidents where defects or
“pugs” in the Horizon software gave rise to 76 branches being affected by
incorrect balances or transactions, which took some time to identify and
correct’. As far as I am aware, the detail of those incidents was disclosed by
POL to Second Sight, as opposed to Second Sight identifying the incidents
through their own investigation. The report also summarised other preliminary
conclusions, some of which related to POL’s handling of individual complaints,
as opposed to issues with the Horizon system itself. As per para. 23, my role
in administering the Scheme did not extend to the consideration (or
engagement with) the substantive technical positions of either POL or SPMs,
in relation to the existence of BEDs or the integrity of Horizon as a whole.
Gareth Jenkins
59.
59.1.
59.2.
59.3.
60.
In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
POL00113111;
POL00029707; and
POL00020634.
I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
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61. The Inquiry has asked me to confirm what knowledge I had of Gareth Jenkins’
role as an expert witness in past criminal prosecutions and the reason why a
new Horizon Subject Matter expert was required. I was aware that POL had
an expert witness from Fujitsu (I cannot recall if I specifically knew it was
Gareth Jenkins) and that their evidence had been used, and tested through
cross-examination, during criminal prosecutions. I believe this was relayed to
me towards the start of my assignment (albeit, not in any great detail), as a
basis for understanding POL’s general technical position within the Scheme
(also supported by the Second Sight interim report), that there were no
systemic issues with Horizon. I recall knowing that POL was looking for a new
Horizon Subject Matter expert, but I do not recall knowing that this was
because of any fundamental issue with the previous expert (i.e. Gareth
Jenkins). As per para. 15, the handling of criminal prosecutions, both historic
and ongoing, was a separate and distinct workstream to my administration of
the Scheme and therefore it did not materially affect my role.
62. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibit:
62.1. POL00006798.
63. I confirm that I have reviewed that exhibit and it has informed my answers to
the below questions.
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64. The advice note from Cartwright King dated 15 July 2013 pre-dates my
assignment with POL. As per paras. 17 and 18, I am not able to access my
POL laptop or email account to check whether I ever had sight of this advice,
after I started my assignment with POL. From the exhibits provided to me by
the Inquiry, I cannot see that I was sent a copy of the advice.
65. The Inquiry has asked me to confirm what knowledge, if any, did I have of the
advice at the time of my assignment with POL. To the best of my knowledge
and recollection, I was not aware of the advice. I am aware of the content of
the advice now, through the disclosure of it by the Inquiry for the preparation
of this statement, but cannot recall ever seeing it during my assignment with
POL.
66. The Inquiry has asked me to confirm what knowledge, if any, did I have of any
contact that had taken place between Mr Gareth Jenkins and Second Sight. I
do not have any knowledge of any such contact.
67. The Inquiry has asked me to reflect on whether I consider I had sufficient
information regarding BEDs and other issues with the integrity of Horizon
during my assignment with POL. I refer again to previous sections of my
statement (paras. 14, 15 and 23). Fundamentally, I did not have the technical
expertise to offer any opinion on the issues relating to Horizon. I was also not
involved in the handling of criminal prosecutions, associated expert evidence
(i.e. Gareth Jenkins) or considerations around the safety of those resulting
convictions. For the purposes of administering the Scheme, whereby I
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understood that there were opposing positions adopted by both POL and
SPMs respectively in relation to technical issues, the analysis or veracity of
those positions was not part of my role and did not materially affect my
administration of the Scheme.
INDEPENDENT LEGAL ADVICE AND REVIEWS
Cartwright King
68.
68.1.
68.2.
68.3.
68.4.
68.5.
68.6.
68.7.
69.
70.
In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
POL00123148;
POL00123147;
POL00108247;
POL00113111;
POL00127601;
POL00112974; and
POL00116944.
I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
The Inquiry has asked me to confirm on what matters advice was sought from
Cartwright King during my assignment with POL. To the best of my knowledge,
and from reviewing the Inquiry exhibits provided to me, Cartwright King were
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engaged by POL to advise in relation to issues regarding criminal
prosecutions, such as disclosure and the preparation of criminal cases. My
understanding is that Cartwright King were effectively the default external
advisory firm for any criminal related matters.
71. The Inquiry has asked me to confirm why such advice was sought. As per
para. 15, POL’s criminal prosecution workstream was not part of my role and
did not materially affect the administration of the Scheme. I cannot comment
further on why POL sought advice from Cartwright King.
72. The Inquiry has asked me to confirm what role I had in briefing and
communicating with Cartwright King. I refer again to para. 15 and my answer
at para. 71; this was not part of my role.
73. The Inquiry has asked me to confirm who was responsible for the information
provided to Cartwright King. I refer again to para. 15. I would assume that
responsibility for instructing Cartwright King, including what information would
be passed to them, was primarily handled by Jarnail Singh and potentially with
input by Chris Aujard or Rodric Williams (as the other in-house POL lawyers).
74. The Inquiry has asked me to confirm how it was decided what information
would be provided to Cartwright King. As per my previous answers, this was
not part of my role and I can only assume that it would have been discussed
and agreed by POL’s in-house legal team.
75. The Inquiry has asked me to summarise my understanding of any advice that
POL received from Cartwright King during my assignment with POL. I refer to
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paras. 16 and 17, in relation to my inability (since October 2014 and for the
purposes of preparing this statement) to access my POL laptop or email
account. I also refer to para. 15, whereby POL’s criminal prosecution
workstream (to which, I understand, Cartwright King was predominantly
instructed to advise upon) was not part of my role. I cannot therefore comment,
in any complete or analytical sense, on the advice that POL received from
Cartwright King.
76. For the purposes of providing this statement, I have reviewed POL00006798.
I refer to my answer at para. 63, whereby the advice pre-dated by assignment
with POL and I do not have any recollection of seeing that advice during my
time with POL. My understanding of that advice from reviewing it now is that
it relates to POL’s obligations of disclosure, as a prosecuting body, and issues
relating to POL’s expert witness evidence (Gareth Jenkins).
77. The Inquiry has asked me to confirm how POL responded to any advice it
received from Cartwright King. I refer to my previous answers; I am not able
to comment upon how POL responded, as it did not fall within the scope of my
work on the Scheme.
78. The Inquiry has asked me to confirm what use was made of any advice
received from Cartwright King. I refer to my previous answers; POL’s criminal
prosecution workstream was separate and distinct to the Scheme and
therefore I cannot comment on how it was used within that workstream. I
assume that it was considered by POL’s in-house legal team and used to
inform decisions relating to criminal prosecutions.
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79. The Inquiry has asked me to confirm to whom the content of any such advice
was communicated. I cannot comment upon a full distribution list for the
Cartwright King advice at POL. I would say that, from my experience within
POL, the distribution of documents relating to criminal matters and any
detailed discussion of those matters, was quite tightly controlled by POL. I can
also say that I do not recollect Cartwright King advice being regularly passed
to, or discussed with, me. This is one of the reasons that I say I cannot readily
recollect seeing the 15 July 2013 advice (POL00006798) and why I am able
to distinguish the management of those prosecutions, from my work on the
Scheme.
Brian Altman QC
80. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
80.1. POL00021750; and
80.2. POL00040254.
81. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
82. The Inquiry has asked me to comment on what matters was advice sought
from Brian Altman QC during my assignment with POL. My understanding is
that Brian Altman QC was utilised by POL to provide a more senior level of
external legal advice, in relation to issues that carried particular complexity,
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sensitivity and / or risk. My understanding is that the engagement of Brian
Altman QC was considered to be an “escalation” of any issues, which were
considered beyond either Cartwright King or Bond Dickinson, or where a QC’s
advice was required.
83. The Inquiry has asked me to confirm why his advice was sought. I cannot
comment upon every occasion that POL instructed Brian Altman QC to
provide advice. In relation to the two exhibits which have been provided to me:
83.1. POL00021750 relates to a query arising from a Second Sight case report,
prepared in relation to a specific SPM case within the Scheme and a
potential communication issue, which could arise where an SPM did not
have a dedicated telephone line for the Horizon system (i.e. they used the
telephone line for multiple purposes). The Second Sight report concluded
that, in that particular case, the communication issues arising from multiple
usages of the telephone line, did relate to losses at that particular branch.
Brian Altman QC was asked to advise upon the disclosable status of the
report and comments upon the evidential basis for Second Sight’s assertion;
and
83.2. POL00040254 relates to a query relating to how criminal cases (i.e. those
where POL had already secured a conviction) would / could be appropriately
mediated and “settled” within the Scheme. The query had arisen from a
proposal by Sir Anthony Hooper (Chair of the Scheme’s Working Group)
relating to the treatment of those criminal cases within the Scheme. Brian
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Altman QC effectively advised that criminal cases should not be mediated
and / or settled under the Scheme.
84. The Inquiry has asked me to confirm my role in briefing and communicating
with Brian Altman QC. To the best of my knowledge and recollection, I did not
have any role in briefing or communicating with Brian Altman QC.
85. The Inquiry has asked me to confirm who was responsible for the information
and documents provided to Brian Altman QC. From the exhibits provided to
me, the instructions in those two instances were led by Andrew Parsons of
Bond Dickinson (POL00021750) and by Rodric Williams (POL00040254). My
understanding and recollection is that both Rodric Williams and Chris Aujard
had the primary line of communication with Brian Altman QC and ultimately
decided when, why and how he was instructed.
86. The Inquiry has asked me to confirm how it was decided what information
would be provided to Brian Altman QC. I refer to my answer at para. 85 above.
87. The Inquiry has asked me to summarise my understanding of the advice POL
received from Brian Altman QC during my assignment with POL. I refer to my
answer at para. 82 above.
88. The Inquiry has asked me to confirm how POL responded to the advice
received from Brian Altman QC. Generally, my view is that POL took the
advice received from Brian Altman QC seriously and afforded it due weight
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and attention. His advice (POL00040254) on the handling of criminal cases
within the Scheme was used to inform further discussions with Sir Anthony
Hooper and the Scheme’s Working Group, in relation to those cases. Whilst
the advice (POL00021750) relating Second Sight’s case review arose from
work they (Second Sight) conducted for the purposes of the Scheme, the main
thrust of the advice received by POL related to their disclosure obligations as
a prosecutor, which (as per para. 15) was therefore outside of my remit.
89. The Inquiry has asked me to confirm what use was made of any advice
received from Brian Altman QC. I refer to my answer at para. 88 above.
90. The Inquiry has asked me to confirm to whom the content of any such advice
was communicated. I refer to my answer at para. 85. My understanding is that
the direct lines of communication, both for instructing and receiving advice
from Brian Altman QC, was via Rodric Williams and Chris Aujard. I cannot
comment upon the full distribution list for any advice that was received. I
assume that it was distributed appropriately within POL, dependent on the
content. The reason that I was copied into the two advices referred to at para.
83, is that they related to (in part), or arose from, the administration of the
Scheme and discussions within the Working Group.
Linklaters
91. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
91.1. POL00074348;
91.2. POL00021989;
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91
3.
91.4.
91
5.
91.6.
91
91
7.
8.
91.9.
91
91
91.
91
91
91
91
91.
91.
92.
93.
-10.
11.
13.
14.
15.
-16.
POL00027696;
POL00021991;
POL00022083;
POL00105529;
POL00022116;
POL00022093;
POL00022117;
POL00116523;
POL00116524;
POL00116548;
POL00127347;
POL00006557;
POL00022208;
POL00021800;
POL00022227; and
POL00022231.
I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
The Inquiry has asked me to confirm on what matters advice was sought from
Linklaters during my assignment with POL. The advice obtained from Christa
Band (POL00105529) was the main piece of advice sought from Linklaters
during my assignment with POL. Similar to my answer at para. 82, in respect
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of Brian Altman, Linklaters were engaged to provide more specialised /
complex advice, at a time where there were a number of significant workflow
issues within the Scheme. The advice was obtained for the purposes of
briefing the POL Board on those issues and to try and agree a way forward.
94. The various workflow issues which primarily resulted in the Linklaters advice
are summarised at a high-level (by me) at POL00105529 (page 28). There
were growing concerns with the significant administrative cost of running the
Scheme (both in terms of POL’s own costs and also the costs of covering SPM
representation within the Scheme), the significant “expectation gap” which had
arisen (see para. 95) between the positions of POL and SPMs within the
Scheme, and the significant amount of management resource that POL was
dedicating to the Scheme.
95. The “expectation gap” was, broadly speaking, the difference in value between
the claims being presented by SPMs within the Scheme (which were
significantly higher than had ever been expected) and: (i) the value of claims
that POL had been expecting to receive; and (ii) in light of POL’s primary
position within the mediation (i.e. that there were no systemic issues with
Horizon), the amount at which POL would seek to “settle” (by way of financial
compensation) those claims. POL was conscious that any financial
compensation to SPMs would, in reality, be made using public finances and
therefore there was a significant sensitivity around this. Equally, it was
recognised that, due to the size of SPM claims, any offer of what would likely
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be perceived as a “token” payment to SPMs could be seen as derisory and
antagonise the SPMs.
96. My note at POL00105529 (page 28) also sets out the secondary concern
which had resulted in the Linklaters advice, namely concerns around the
quality of Second Sight’s case reviews within the Scheme and also the speed
at which those reviews were being completed. I shall address both points
separately. In terms of concerns around “quality” I would like to explicitly clarify
that this was not a concern borne out of any inherent disagreement with the
content of Second Sight’s case reviews, insofar as they may be generally
supportive of an SPM’s position as opposed to POL’s. The concern was
related to the quality of the work itself, in terms of the purpose for which
Second Sight’s case reviews were required: to provide an evidential basis for
any conclusions they reached and to, where possible, narrow the issues in
dispute between POL and any respective SPM within the scheme. Second
Sight’s case reviews, generally, were not achieving those outcomes and were
therefore not assisting in progressing cases through the Scheme. In terms of
concerns around speed, it was recognised that there were only two Second
Sight investigators (subsequently three) compared to a significant number of
cases within the Scheme. Due to that capacity issue, the case reviews were
not being progressed in-line with anticipated timescales, which was further
resulting in the Scheme’s stagnation (with clear potential repercussions at
frustrating the JFSA and external stakeholders with an interest in the
progression and resolution of cases within the Scheme, such as MPs).
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97. The Inquiry has asked me to confirm why such advice (from Linklaters) was
sought. I refer to my answers at paras. 92 - 96 above.
98. The Inquiry has asked me to confirm what role I had in briefing and
communicating with Linklaters. Compared to POL’s engagement with other
external solicitors (Bond Dickinson and Cartwright King), I did play more of an
active role in the instruction of Linklaters. This is because the instruction and
advice being sought was directly related to the administration of the Scheme
and arose out of issues that were impacting that project. As can be seen from
POL00074348, I sent Linklaters a Scheme mediation case on 28 February
2014, for consideration as part of their advice. POL00021989 also
demonstrates my involvement with Linklaters to produce a “workplan” for their
advice, to ensure that it addressed all of the relevant issues required.
Generally, I can recall assisting POL in gathering relevant documents and
information that were relevant to the scope of Linklaters advice
(POL00021991 — shows me obtaining relevant formal pieces of advice from
Bond Dickinson, which were relevant to the Linklaters advice). I also recall
collating comments from others within POL (Belinda, Chris) to agree and
finalise the scope of the Linklaters advice.
99. The Inquiry has asked me to confirm who was responsible for the information
and documents provided to Linklaters. I refer to my answer at para. 98. Chris
Aujard was leading on Linklater’s engagement. I recall that Chris and Belinda
were primarily responsible for identifying what would be sent. From the
exhibits referred to above, I did have a line of communication with Linklaters
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and sent various information / documents. However, as can be seen from
POL00021991, I was reliant upon others (in that case Bond Dickinson) to
identify and confirm what the relevant information / documents were.
100. The Inquiry has asked me to confirm how it was decided what information
would be provided to Linklaters. I refer to my answer at para. 99.
101. The Inquiry has asked to confirm why Linklaters were only provided with 10
spot reviews and 4 cases for preparation of the legal issues report. To the best
of my knowledge and recollection, I believe that this was because there were
only 10 spot reviews and 4 cases with a suitably complete document set for
Linklaters to review. I can explicitly confirm that there was no conscious
intention, on my part at least, to withhold any relevant information / documents
relating to particular cases from Linklaters. POL needed the Linklaters advice
to appropriately address the issues and therefore it was acknowledged that
Linklaters required the necessary information / documents to provide a robust
advice.
102. The Inquiry has asked me confirm why Linklaters were not instructed to
contact Fujitsu. I refer to my answer at para. 99. Chris Aujard was leading
Linklaters instruction. I am not aware of whether there was any explicit
instruction for Linklaters not to contact Fujitsu. I also refer to my answer at
para. 39, whereby I did not have any lines of communication with Fujitsu.
Generally, given that the scope of Linklaters advice primarily related to issues
affecting the administration of the Scheme (to which Fujitsu was not a party),
I did not (and do not) have any concerns that Linklaters’ advice was provided
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without having contact to Fujitsu. I do not believe that such contact would have
had a material effect upon what Linklaters were being asked to advise upon.
103. The Inquiry has asked me to summarise my understanding of each piece of
advice POL received from Linklaters during my assignment with POL.
103.1. _POL00105529. As per my answer at para. 92, this was the main advice
received from Linklaters. The advice confirmed that the contractual
relationship between POL and SPMs was such that SPMs did not have an
explicit right to consequential losses (consequential losses forming the main
basis of the high values of SPM claims within the Scheme, resulting in the
“expectation gap” — see para. 95). The Linklaters advice confirmed that the
key factual issue facing POL, and its position within the Scheme, was to what
extent Horizon could be said to be reliable and whether there were, in fact,
any defects which could be said to have been causative of SPM losses.
Linklaters made the point that this fundamental question had not been
satisfactorily addressed, and that “it would be far more satisfactory were
there to be a reasoned report as to why Horizon is thought to be working
properly’ and that “Second sight should have produced a report which clearly
and objectively sets out what is known about Horizon at a level of detail
which can then be used as a baseline in any individual case where the
complaint is that Horizon was not working properly’. Linklaters also advised
in relation to the treatment of cases within the Scheme where POL had
previously secured a civil judgment and / or criminal conviction. Linklaters
view (which POL was already aware of) was that there was an inherent risk
in proceeding to mediate and “settle” those cases, both in relation to what
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that could mean for the potential safety of any of those convictions, and also
a perceived acceptance that there were, in fact, issues with Horizon.
103.2. POL00022093. Linklaters provided a short follow-up piece of advice on 28
March 2014, providing an outline of what a further report on Horizon should
include. This relates to their comment in the previous advice about what they
considered to be missing and what Second Sight had failed to provide.
Linklaters confirmed that the report should be prepared by an expert with
sufficient independence from POL and effectively comprise of a
comprehensive analysis of Horizon as a system (how it worked, how it was
used), together with consideration and analysis of the defects being alleged
by SPMs.
103.3. POL00022117. Linklaters provided a further advice on 31 March 2014,
setting out suggested solutions for the future operation and direction of the
Scheme. The advice identified four main risk areas for POL, namely: the
financial costs associated with the risk of having to meet individual claims;
the costs of the applicants and Second Sight; the external communications
and reputational issues associated with not settling claims; and the external
communications, legal and reputational issues associated with settling
claims. Various options were set out for POL’s consideration, in light of those
risk areas, including: to close the Scheme and decline to mediate any cases;
amending the Scheme to clarify that cases with a criminal conviction / civil
judgment fell out of the Scheme; formalising and regularising the terms upon
which Second Sight were instructed — or, alternatively, terminating Second
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Sight’s engagement; proceeding with the advice provided in POL00022093
to instruct and obtain a new, full and objective report into the Horizon system;
consideration of a “standard” compensation offer (effectively, an ex-gratia
payment) in relation to SPM cases within the Scheme, regardless of their
legal merit; and reviewing the effectiveness of the Scheme’s Working Group
and placing POL more in control of that group.
104. The Inquiry has asked me to confirm how POL responded to the advice
received from Linklaters. It was discussed at POL Board level and afforded
considerable and serious attention. As my statement will go on to address, the
Board went on to instruct Deloitte to prepare an “assurance” report relating to
Horizon and steps were taken to regularise the scope of Second Sight’s
engagement. The terms of reference for the Scheme’s Working Group were
revisited and ultimately the POL Board did not make a decision to entirely
terminate the Scheme. I was not present at the relevant POL Board meetings.
However, my understanding and recollection is that the POL Board were
respectful of Linklaters’ advice, however chose not to proceed with all of the
recommendations relating to the Scheme, which flowed from their
consideration of the advice.
105. The Inquiry has asked me to confirm what use was made of any advice
received from Linklaters. I repeat my answer at para. 104. In relation to
Scheme cases where there was a criminal conviction, a decision was taken
whereby these would not be stripped out of the Scheme, as suggested by
Linklaters as a potential option. This was not seen as a viable course of action
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due to inevitable negative reception that would be received from both SPMs
and MPs -— it would have entirely undermined one of the reasons that the
Scheme had been implemented. A decision was made to retain those cases
within the Scheme, such that they were properly investigated and discussed,
but without proceeding to mediation. This decision is recorded in the Project
Sparrow Sub-Committee meeting minutes at POL00006565 (pages 3 and 4).
I would also note that Sir Anthony Hooper (Scheme Working Group chair) was
also in agreement that due regard should be given to any relevant Court
judgments, where they were present within any Scheme cases.
106. The Inquiry has asked me to confirm to whom the content of Linklaters advice
was communicated. As per my previous answers, the advice was obtained in
order to advise the POL Board. Where decisions were made by the Board,
based upon the advice, they were cascaded down to the relevant individuals
to be actioned. I cannot confirm the full dissemination or communication of the
advice.
Deloitte
107. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
107.1. _POL00105528;
107.2. _POLOOO06565;
107.3. POL00116502;
107.4. POL00116523;
107.5. POL00028062; and
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107.6. POL00116578.
108. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
109. The Inquiry has asked me to set out in full everything I can recall about the
discussion that took place during the Sparrow Sub-Committee meeting on 9
April 2014 in relation to instructing Deloitte. I have reviewed the minutes of
that meeting (POL00006565). I note that the discussion regarding instructing
Deloitte is set out under the heading “Updated on Horizon On-line HNG-X
(“Horizon”) Assurance Work. It refers to a “Part 1” instruction of Deloitte to
consider and assess the control framework within which Horizon operates, as
a largely desk-based exercise (i.e. not a comprehensive examination of the
system itself, as envisaged and recommended by Linklaters, which would be
considered as a “Part 2” exercise). The minutes reiterate the position that POL
had adopted throughout, based upon Second Sight’s interim report from July
2013, whereby no wide-spread systemic faults had been identified within
Horizon. On that basis, the Part 1 phase of work from Deloitte was considered
suitable for providing POL with the necessary assurances it required. Part 2
was considered a non-essential piece of work at that stage, the need for which
should be considered as and when Part 1 had been completed. It was agreed
for the Part 1 assurance work by Deloitte to be considered and agreed by the
POL Board, at their subsequent meeting. It was also agreed for the Chief
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Information Office (“CIO” — Lesley Sewell) to review the outcomes of Part 1
and update the Sub-Committee on whether Part 2 was required.
110. Beyond the meeting minutes referred to above, I do not directly recall much
more from this particular meeting. Deloitte were instructed to carry out the Part
1 assurance exercise, as agreed. I do not recall any hesitancy or unease on
behalf of the POL team in proceeding to instruct Deloitte; it was considered to
be logical follow-on from the advice received from Linklaters.
111. I The Inquiry has asked me to confirm my understanding for the reason for POL
instructing Deloitte. I refer to paras. 103.2 and 109. My understanding is that
POL were acting upon the advice provided by Linklaters, to obtain further
assurances in relation to the Horizon system.
112. The Inquiry has asked me to confirm what role, if any, I had in briefing and
communicating with Deloitte. To the best of my knowledge and recollection, I
played little or no role in instructing Deloitte. Overall control of Deloitte’s
engagement was managed by Chris Aujard, supported by Rodric Williams with
day-to-day contact with Deloitte. I note from POL00028062 (page 64) that
Deloitte acknowledge that their POL client contacts are Rodric Williams and
Belinda Crowe. Also, POL00028062 (page 61) confirms that Deloitte’s letter
of engagement was sent in Chris’ name. On the same exhibit page. Deloitte
set out their definition of the POL “Engagement Team”; I am not referred to.
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113. I The Inquiry has asked me to confirm who was responsible for deciding what
information and documents would be provided to Deloitte and how those
decisions were made. I refer to my answer at para. 112. My recollection is that
this was entirely dealt with by Chris, Rodric and Belinda, inline with Deloitte's
confirmation of their POL client contacts and Engagement Team.
114. The Inquiry has asked me to confirm how POL responded to the report
produced by Deloitte. In short, my recollection and understanding is that POL’s
response was negative. This is supported by the fact that POL00028062 is
version 16 of the draft Deloitte report (i.e. significant and repeat revision had
been required). Chris Aujard was not happy with the work that had been done.
I cannot recall if the Deloitte report was ever finalised. Fundamentally, the
Deloitte report did not provide the level of assurance that POL were seeking
in relation to Horizon. It was heavily caveated and did not provide POL with
any basis for clarifying its position on Horizon, or deal with the issues advised
upon by Linklaters.
115. The Inquiry has asked me to confirm what use was made of the report
produced by Deloitte. I refer to para. 114, whereby I cannot recall if the report
was ever finalised. POL had wanted, and been expecting, a piece of work that
provided the necessary assurances on the Horizon system. The Deloitte
report did not provide that level of assurance. I cannot recall what, if any, real
use was made of the Deloitte report; it did not materially change POL’s position
with regard to Horizon.
Dissemination of Advice and Reviews
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116. The Inquiry has asked me to consider POL00116502 and Belinda Crowe’s
request for me to work on a list of tasks, including a “Paper to be produced for
the next Sub-Committee setting out approaches to disseminating the Horizon
report from Deloitte and the essence of the legal opinion from Linklaters to
advisors, applicants and MPs including action planning and comms and
stakeholder engagement required’.
117. I confirm that I have reviewed that exhibit and it has informed my answers to
the below questions.
118. The Inquiry has asked me to set out in detail the work I carried out on that
task, the decision-making involved, and the substance of the paper that was
produced. I exhibit at WITN09780101 a PA invoice cover letter from 6 May
2014, sent to Belinda Crowe at POL, signed by the PA Partner in Charge of
the POL assignment. I do not know if this document has been previously
disclosed to the Inquiry, by POL. The letter confirms that I did produce a Sub-
Committee board paper dealing with the “Dissemination of the Linklaters
advice and Deloitte report”. I therefore acknowledge that I completed this
piece of work. However, the report itself has not been produced to me as an
exhibit by the Inquiry. I refer to paras. 16 — 18 of this statement. Given the
length of time which has passed, I do not have any direct recollection of the
paper I produced. It has not been produced to me as an exhibit and I have no
means of accessing the POL laptop (or email account) on which I would have
completed the piece of work. Without having sight of further materials, I regret
that I cannot assist the Inquiry any further in relation to this question.
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119. The Inquiry has asked me to confirm the approach taken by POL to
disseminating the advice and reports received from Cartwright King, Brian
Altman QC, Linklaters and Deloitte both internally within POL and externally
to other organisations and individuals outside the company, including in
particular Second Sight, the Working Group, and MPs and ministers.
120. In each of the above sections, I have spoken about my knowledge and
recollection of how and to whom I understand various advices and reports to
have been disseminated and communicated. In general terms, I can say that
POL were very careful and deliberate in how and to whom professional advice
was disseminated and communicated. This was on the basis of not
inadvertently waiving privilege in any of the documents. In that context, given
I was not a POL employee, decision-making regarding the dissemination and
communication (in terms of potential waiver of privilege) did not and could not
rest with me; I did not have the authority to do so.
121. In terms of the specific advice and reports of various parties, and the external
parties, which the Inquiry has asked me about:
121.1. I Cartwright King. I refer to para. 79;
121.2. Brian Altman QC. I refer to para. 90;
121.3. Linklaters. I refer to para. 106;
121.4. Deloitte. I refer to paras. 114 and 115;
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121.5. I The Working Group. I do not believe that any of the above advices or reports
were provided wholesale to the Working Group. They would have been used
to inform engagement and dealings, where the content related to the
administration of the Scheme (e.g. Linklaters). I reiterate my comments
about POL not wanting to inadvertently waive privilege;
121.6. Second Sight. I reiterate my comments about POL not wanting to
inadvertently waive privilege. I cannot see any basis upon which legal advice
being obtained by POL would have been shared with Second Sight; and
121.7. MPs and ministers. I reiterate my comments about POL not wanting to
inadvertently waive privilege. I cannot speak as to how (and with reference
to what information / documents) POL briefed and updated MPs or ministers.
PROJECT SPARROW
122. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
122.1. POL00030694;
122.2. POL00027482;
122.3. _POL00099977;
122.4. POL00100003;
122.5. POL00130507;
122.6. POL00116277;
122.7. _POL00006565;
122.8. POL00105528;
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122.9. POL00108430;
122.10. POL00116502;
122.11. POL00116576;
122.12. POL00116579;
122.13. POL00116580;
122.14. POL00006571; and
122.15. UKGI00002375.
123. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
124. The Inquiry has asked me to set out everything I know about the background
to Project Sparrow, including what it was, how it was established, why it was
established, its management structure and reporting lines, its terms of
reference, its objectives and how POL sought to deliver those objectives.
125. I refer to para. 4 of my statement, whereby my assignment with POL was
between December 2013 and October 2014. The background and
establishment of Project Sparrow pre-dated my assignment with POL. A
number of the exhibits produced to me (POL00030694, POL00027482 and
POL00099977) also pre-date my assignment with POL.
126. Notwithstanding the above, I provide the following answers to the Inquiry
based upon my knowledge during the time of my assignment with POL.
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127. Based upon POL00030694, which is dated November 2013, Project Sparrow
appears to have initially been set up as a form of umbrella project to cover a
range of workstreams, including the Scheme. I note from POL00105528 (page
5) that the Scheme had been established in August 2013. I cannot comment
upon when Project Sparrow was first established or the full background. I note
from POL00027482, which also pre-dates my assignment with POL, that
“Project Sparrow as initially conceived comprised two main initiatives, both of
which were launched in response to the Second Sight Report released in
2013’. The first of those initiatives was the Scheme and the second was the
business improvement programme.
128. From the point of my assignment with POL in December 2013, reference to
Project Sparrow was de facto a reference for the Scheme (from my
perspective at least). The other workstreams (criminal prosecution review and
business improvement programme) were not part of Project Sparrow / the
Scheme, during the time that I was involved. I have previously explained that
I had no involvement in those workstreams in any event.
129. The business improvement programme was led by Angela van den Bogerd
and I would assume that it was progressed under separate governance when
Belinda was asked to lead the Scheme project. There was a degree of
interface between the workstreams, as findings from the Scheme may
produce relevant issues to be considered and implemented by the business
improvement programme, but the managing of any delivery under that
workstream was led by Angela van den Bogerd; I did not have any involvement
in that workstream. The Project Sparrow / Scheme Sub-Committee Board did
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receive periodic updates on the delivery of the business improvement
programme, but this was for information purposes only.
130. It may be helpful to add that my direct POL client, Belinda Crowe, preferred to
refer to the project as the Scheme, as opposed to Project Sparrow. My
recollection is that she believed Project Sparrow lacked clarity (in terms of
what it was dealing with). I also adopted this protocol during my assignment
with POL. I believe that the origin of the name “Project Sparrow” was from a
POL legacy naming convention that they used for different projects.
131. In terms of management structure, I refer to the meeting minutes at
POL00006565. There was a Project Sparrow Sub-Committee, chaired by
Alice Perkins. I was part of the Sub-Committee, in my remit as Programme
Manager for the Scheme. Although the minutes refer to “Programme Manager,
Project Sparrow’, this was not a different role or function. The Sub-Committee
reported to the full POL Board, both on a formal and informal basis, and
primarily through Paula Vennells, Alice Perkins and Chris Aujard. I was
involved in the preparation for those briefings, where they included issues
arising from the administration of the Scheme.
132. The terms of reference for the Project Sparrow Sub-Committee are as set out
at POL00105528 (page 2).
133. In terms of the objectives of Project Sparrow and how POL sought to achieve
them, I refer to my previous answers in relation to the different workstreams
that initially fell within it and also my involvement from December 2013
onwards. From my perspective, as explained at para. 128, Project Sparrow
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was de facto the Scheme. On that basis, the primary objective of Project
Sparrow was the administration and progression of the Scheme. In doing so,
and as per POL00006571, Project Sparrow (and POL) had three fundamental
principles that it wished to pursue and achieve through the Scheme, namely:
(i) to gain a fuller understanding of the facts; (ii) to ensure a fair outcome; and
(iii) to highlight lessons learned so that improvements can be made to
business processes.
134. The Inquiry has asked me to consider POL00030694 and explain where, if at
all, my role with POL fitted within the scope and / or resources for Project
Sparrow. I reiterate that this document pre-dated my assignment with POL.
Notwithstanding that position, and with reference to the bullet points set out at
POL00030694 (page 2), in my role as Programme Manager for the Scheme
(and Project Sparrow — ostensibly the same role), I provided secretariat
support, I assisted with the creation and implementation of Scheme policy, I
provided management services for the delivery of the Scheme, I carried out
project management and administration tasks, I supported Sophie
Bialaszewski with the preparation of some external communications, and I
was involved generally with Scheme operations in terms of optimising the
mediation process and process mapping. I refer to POL00138077
(specifically, page 11 of that document), which sets out the scope of the PA
proposal for working on the Scheme.
APPOINTMENT OF SECOND SIGHT
Appointment, Terms of Reference, and Terms of Engagement
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135. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
135.1. _POL00096576;
135.2. POL00096615;
135.3. POL00117119;
135.4. _POL00099977;
135.5. POL00100123;
135.6. POL00100165;
135.7. POL00100166;
135.8. POL00100198;
135.9. POL00026743;
135.10. POL00116305;
135.11. POL00100322;
135.12. POL00100323;
135.13. POL00022146;
135.14. POL00022148;
135.15. POL00022147; and
135.16. POL00061744.
136. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
137. The Inquiry has confirmed that I was involved in the preparation of the
Engagement letter for Second Sight in 2014. The Inquiry has asked me, at
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that time, what I understood to be the ambit of Second Sight’s original role,
when first engaged by POL in 2012. I confirm that from publicly available
information, together with the exhibits produced to me, Second Sight were
originally engaged by POL in response to a number of complaints / cases
being raised by SPMs, via MPs, to investigate those complaints / cases and,
generally, the functioning of Horizon as a system.
138. The Inquiry has asked to confirm how and why did this role change over the
period between that initial engagement and the end of my assignment with
POL. I cannot comment upon any changes to Second Sight’s role prior to
December 2013. From December 2013, given that the Scheme had been
implemented and Second Sight formed part of the processes of that project
(in that they conducted case reviews of Scheme applicant cases, for
consideration and further investigation by POL) I would say that there was an
increased focus on maintaining Second Sight’s focus on the completion of
those Scheme case reviews, as opposed to their wider investigation into the
Horizon system as a whole. I should clarify that the change in focus was not
(as far as Iam concerned) as a result of POL seeking to hinder Second Sight’s
investigation of Horizon, to prevent them from investigating or potentially
identifying BEDs. It is clear from the exhibits, and from my own recollection,
that POL was genuinely trying to progress and make a success of the Scheme.
That success was dependent, in part, upon the quality and timeliness of
Second Sight’s case reviews. The shift in focus was in recognition of the fact
that cases within the Scheme were being delayed and the project as a whole
was at risk of stagnation.
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139. The Inquiry has asked me to describe the process of negotiating and
determining the terms of the Second Sight engagement letter in 2014, giving
particular attention to any terms over which it was difficult to reach agreement
and my understanding of the reasons for any such difficulty. I have reviewed
POL00100166, which is a draft engagement letter to Second Sight which set
out POL’s proposed focussed scope and terms of engagement. My
recollection is that the actual negotiation of the engagement letter was led by
Chris Aujard and / or Belinda Crowe.
140. I summarise the following terms as being those on which there was push-back
from Second Sight:
140.1. Confidentiality. The engagement letter sought to impose a confidentiality
agreement upon Second Sight, such that the information being provided to
them in order to conduct case reviews for the purposes of the Scheme
should only be used for that purpose and that they were not to engage in
any public discussion in relation the information that they were provided with.
My understanding of Second Sight’s primary push-back in relation to this
proposed clause is that it would prevent them from discussing Scheme
cases, and their broader investigational findings, with MPs. This is what
resulted in the “Side Letter’, which I discuss at para. 142 below;
140.2. “Non-compete”. The engagement letter sought to restrict Second Sight from
being instructed to act against POL, in relation to the information which had
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been provided to them for the purposes of progressing their investigation, for
a period of two years. This arose out of a general feeling within POL that,
despite Second Sight having been engaged by POL to undertake an
independent review of Horizon and thereafter to conduct independent case
reviews of claims forming part of the Scheme, Second Sight was largely
supportive of the positions of SPMs and the JFSA. Without this clause, it
would be difficult for POL to continue to openly provide information and
access to Second Sight to conduct investigations, if there was the constant
threat that Second Sight could terminate their engagement and become
instructed by SPMs or JFSA, against POL. The intention of the clause was
to provide certainty to the Second Sights commitment to the Scheme, whilst
it was ongoing. Second Sight did not want their ability to act against POL to
be restricted, if they wished to do so and felt it was appropriate; and
140.3. Scope of Services. The revised scope of services, as set out at
POL00100166 (page 7), confirmed that Second Sight’s role was to be
focussed upon delivering services for the advancement of Scheme cases,
as opposed to wider investigation of Horizon as a whole or any non-Scheme
complaints. I have spoken at para. 32 about the concerns that POL held (and
which I shared, in the context of the Scheme) as to the quality and timeliness
of Second Sight’s work. The revised scope was intended to focus Second
Sight on delivering their case reviews, such that the Scheme could be
properly administered. My understanding of Second Sight’s concern with the
revised scope is that they saw it as: (i) a departure from their original
engagement, to investigate the wider Horizon system; and (ii) would prevent
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them from investigating non-Scheme complaints which they had been
requested to investigate, directly by MPs.
141. As per the agreed engagement letter dated 1 July 2014 (POL00022148),
Second Sight ultimately agreed to the terms being proposed.
142. The Inquiry has asked me to confirm the rationale for the so called “Side
Letter” at POL00022147. The rationale for the side letter is as per para. 140.1.
Second Sight were concerned that the confidentiality clause within the
engagement letter would prevent them from continuing to speak to MPs, and
particularly James Arbuthnot MP. The side letter explicitly provides an
exception to the confidentiality arrangements, to allow Second Sight to discuss
the progress of the Scheme, with James Arbuthnot MP. It also states that,
where practicable, updates should be shared with the Working Group in
advance and presented on an anonymised basis. The rationale for the side
letter was therefore to give comfort to Second Sight that they were not being
restricted from continuing their line of dialogue with James Arbuthnot MP.
143. The Inquiry has asked me to confirm to whom the engagement letter was
disseminated both within and outside of POL. I cannot comment upon the full
dissemination both within and outside POL. The Inquiry has also asked me to
comment upon any difference in the dissemination of the engagement letter
and that of the side letter. I cannot comment on the dissemination of either but
am not aware of any attempt to keep the content of the side letter secret or
within a tighter circulation. It was a simple side agreement which provided an
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exception to Second Sight’s confidentiality obligations, to allow them to retain
a line of dialogue with James Arbuthnot MP.
144. The Inquiry has directed me to POL00022146 and asked for the meaning of
the statement “The only restriction was in relation to criminal matters” and why
I wrote this. I did not write that statement; it is Belinda Crowe’s statement. My
email within the chain was to Belinda and Chris to provide scanned, signed
copies of the engagement letter and side letter.
Second Sight Access to Documents and Information
145. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
145.1. POL00061304;
145.2. POL00061744;
145.3. _POL00021937; and
145.4. POL00021933.
146. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
147. The Inquiry has asked me to confirm by what process were decisions made
as to the documents and information that Second Sight received and those to
which they would be denied access. I refer to my answer at para. 137. Second
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Sight’s original engagement pre-dated my assignment with POL. I cannot
therefore comment on the provision of documents or information (or the extent
to which access may or may not have been denied) at any point up to
December 2013. From December 2013, my recollection is that all requests
from Second Sight were primarily received by Belinda, Angela or POL’s in-
house legal team (depending on the subject matter). There may have been
instances where requests were raised during the Scheme’s Working Group,
but these would also be progressed by Belinda or someone in the POL legal
team (potentially upon advice from external solicitors, where needed). I did not
play any role in decision making of what to disclose (or not disclose) to Second
Sight, in response to any substantive request relating to Second Sight’s
investigation. If a Second Sight request related to their role within the Scheme
(e.g. to request Scheme related administrative information or documents
relating to a particular claim), then I would have dealt with that and provided
the relevant material. I was not involved in discussions or decisions regarding
criminal cases or any more wide-ranging requests such as seen at
POL00061304, whereby Second Sight had requested POL’s entire legal files.
I did not have access to those files and it was not my role to determine how
those requests should be responded to. At no point during my assignment with
POL, did I seek to deny Second Sight access to any information or documents
which properly related to the administration of the Scheme and their role within
it. This is demonstrated in POL00061304, where after being copied into the
original request, I was removed from the chain of follow-up emails, where the
request was discussed in more detail between Chris, Belinda, Rodric and
Bond Dickinson.
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148. The Inquiry has asked me to confirm how, if at all, the approach to providing
such materials to Second Sight varied over the time of my assignment with
POL. I refer to my answer at para. 147, whereby I was not involved in the
decision making relating to Second Sight requests. I also refer to para. 140.3.
I am aware, at the same time that the Second Sight engagement letter was
being negotiated (particularly the scope of services), of a general attempt to
keep Second Sight focussed upon their case reviews within the Scheme, as
opposed to wider issues. As I have set out, this was on the basis that there
were concerns that Scheme was stagnating and POL needed Second Sight
to ensure that they were meeting the timescales required to produce reports
on mediation cases.
149. The Inquiry has asked me to confirm what role I had in the negotiation of
access to and provision of any such documents and information. I refer to
exhibits POL00021937 and POL00021933. This is an example of me
providing a note on “Pensions and Allowances “Reintroduction” Fraud” to
Second Sight. The note itself confirms that it is related to the Scheme. I did
not prepare the substance of that note, given that it contains technical
information relating to pensions, fraud and POL systems that were beyond my
technical understanding and knowledge. My role in providing that note to
Second Sight would have been limited to gathering comments from relevant
POL individuals (Chris, Belinda etc) to agree the substance of the document.
I may then have been involved in finalising the draft of the note, in terms of
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style / layout etc, before providing it to Second Sight (and once it had been
otherwise approved by POL).
150. The Inquiry has asked me to confirm which individuals contributed to the
decision-making regarding Second Sight’s access to such materials; and who
was responsible for the final decision. I refer to my answer at para. 147.
Ultimate decision-making rested with Chris Aujard or Belinda Crowe. Angela
van den Bogerd may also have been involved. As it was not part of my role, I
did not have full visibility into the decision-making process. For the requests I
was aware of, POL’s decision-making was led by Chris or Belinda, potentially
informed by external solicitors.
151. The Inquiry has asked me to confirm what policy / guidelines governed the
nature and extent of the documents and information provided to Second Sight.
I am not aware of a specific policy or set of guidelines, relating to Second Sight
disclosure; I never saw one. Insofar as the Scheme, disclosure requests would
have been considered in-line with the revised scope of services set out in
Second Sight’s engagement letter (i.e. was it relevant to their work in the
Scheme). Any request would clearly also be subject to the requirements of
both the Freedom of Information Act 2000 and the Data Protection Act 2018;
however, compliance with that legislation and the extent to which they related
to Second Sight’s requests was not part of my role and I did not make any final
decisions relating to the disclosure (or non-disclosure) of documents or
information.
Second Sight’s Interim Report — dated 8 July 2013
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152. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
152.1. POL00099063;
152.2. _POL00022120;
152.3. POL00040074;
152.4. _POL00040077; and
152.5. POL00116486.
153. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
154. The Inquiry has asked me to set out the understanding that I had, during my
assignment with POL, of:
154.1. The key findings of the interim report. My understanding of the key findings
of the report (POL00099063) are as set out at para. 8.2 of the document;
namely, Second Sight’s preliminary conclusions. The report itself is dated 8
July 2013 and therefore pre-dated my assignment with POL. All of the work
conducted up to that point, including the information and documents
provided to Second Sight in order to reach those preliminary conclusions,
also pre-dated my assignment with POL. From POL’s perspective, which
informed their position as a mediating party within the Scheme, the key
finding was that “we have so far found no evidence of system wide (systemic)
problems with the Horizon software”. I also refer to my answer at para. 58.
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154.2. The extent to which the report was disseminated within and outside of POL.
I refer to my answer at 154.1; the report was issued in July 2013 and my
assignment with POL did not commence until December 2013. I cannot
comment upon the degree of dissemination within and outside POL. To the
best of my knowledge and recollection, it was a freely available document
with no sensitivities around its existence. Whilst preparing this statement, I
have located an official POL press release’ in response to the report issued
on 7 July 2013. Both the report, and POL’s response to it, were discussed
openly.
154.3. The extent to which the report was disclosed to SPMs who raised complaints
about Horizon (whether or not they were accepted onto the Scheme). I refer
again to 154.1, in terms of the report pre-dating my assignment with POL. I
also refer to 154.2, insofar as my understanding that the report was a freely
available document. My recollection is that it was posted on the JFSA
website at some point. I also refer to various answers within this statement
(paras. 15, 88) whereby disclosure by POL (and the extent to which any
documents triggered POL’s duties of disclosure) was not part of my role.
154.4. The interpretation of the report that POL adopted in relation to the concerns
that had been raised about issues with Horizon. I refer to para. 154.1. The
primary position adopted by POL, both prior to and during my assignment
1 https://www.mynewsdesk.com/uk/post-office/pressreleases/post-office-statement-on-findings-of-
interim-report-into-horizon-computer-system-1034990
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from December 2013, was to rely upon the preliminary conclusion that no
systemic problems had been identified. As per para. 14, that was POL’s
technical position with regards their role as a mediating party within the
Scheme and was not part of my role to analyse or verify. As per para. 11,
the extent to which any of the conclusions were (or should have been)
progressed as part of the business improvement programme, headed by
Angela van den Bogerd, was not part of my role.
154.5. The steps that POL took following publication of the report. I refer again to
paras. 154.1 and 154.2. By the time of my assignment with POL in December
2013, the Scheme had been established as a means by which to engage
and resolve (where possible) complaints which had been raised by SPMs.
THE INITIAL COMPLANT REVIEW AND MEDIATION SCHEME (“THE SCHEME”)
The Establishment of the Scheme
155. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
155.1. _POL00022120;
155.2. POL00030694; and
155.3. POL00027482.
156. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
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157. The Inquiry has asked me to set out in detail everything I know about the
implementation of the Scheme, including, but not limited to, my understanding
of:
157.1. Its terms of reference, purpose and objectives. The terms of reference for
the Scheme are set out at page 4 of POL00138077. My understanding and
recollection of the terms of reference for the Scheme are consistent with the
information on that page. Generally, the purpose of the Scheme was to
create a framework under which SPM complaints would be investigated and,
where possible, result in a mediation meeting to try and reach a resolution
for that complaint. In terms of the objectives of the Scheme (which, for the
avoidance of doubt, had been devised / implemented prior to my assignment
with POL), my understanding is that it was POL’s attempt to formally respond
to mounting public pressure in relation to Horizon and the number of SPM
complaints. My understanding at the time was that POL wanted to do the
right thing, by properly engaging with the substance of SPM complaints,
through a process of investigation and mediation. I also agree that the
objectives of the Scheme are accurately set out in the Working Group’s
terms of reference (UKGI00002361) whereby “the Scheme’s overall
objective is to try and achieve the mutual and final resolution of an
Applicant’s concerns about Horizon and any associated issues’ and that it
must “provide a mechanism to investigate proportionately and effectively an
Applicant's concerns’;
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157.2. The possible outcomes anticipated by POL. I refer to page 6 of
POL00138077, which sets out POL’s “High Level Success Criteria” for the
Scheme. The long-term vision for the Scheme had a number of aims,
including resolving all of the complaints and retaining public confidence in
POL;
157.3. The anticipated timetable for the Scheme. The initial anticipated timescale
for the Scheme was to conclude by April 2014. As referred to in various other
answers, due to a number of factors, that timescale was extended.
157.4. The identity and role of every independent organisation that POL engaged
to assist it with operating the Scheme. I refer to page. 10 of POL00138077
which sets out all of the parties (which were generating cost to POL) who
were involved with the Scheme. While this is a very wide question and I have
referred to the majority of these parties already in this statement, however I
have provided the following overview:
a) Bond Dickinson. One of POL’s external legal advisers;
b
Cartwright King. One of POL’s external legal advisers (criminal prosecution
focus);
&
Independent Chair. Sir Anthony Hooper, Chair of the Scheme’s Working
Group and retained to provide independent and respected oversight;
d) Second Sight. Independent investigatory services;
e) Mediators (CEDR). Dispute resolution services retained to mediate any
Scheme cases;
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f) Fujitsu. POL’s source of technical data relating to Horizon, for Scheme
cases;
g) Mediation venue. Self-explanatory;
h) SPM advisors. POL committed to paying the reasonable costs of SPMs own
advisors for the Scheme; and
i) PA. I refer to paras. 10 and 134;
157.5. Other parties that I recall being involved are Brian Altman QC (see section
commencing at 80), Linklaters (see section commencing at 91) and Deloitte
(see section commencing at para. 107). Clearly, Alan Bates was involved,
on behalf of the JFSA, who sat on the Scheme’s Working Group — assisted
by Kay Linnell (independent forensic accountant).
158. The Inquiry has asked to consider pages 10 and 11 in POL00138077 and also
POL00101350, in which I refer to “my pa account’. The Inquiry has asked me
confirm:
158.1. I What was and is my connection with PA. I refer to paras. 2 and 4; and
158.2. Did PA have any role in relation to the Scheme. I refer to paras. 4, 6, 10 and
134.
158.3. In terms of the reference to “my pa account’ in POL00101350, I refer to
paras. 16 and 17. I was provided with a POL laptop and email account that
was required not to be taken off POL premises. My email in POL00101350
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was at 19:13, where I assume I was about to leave work for the day. My offer
of being available on my PA email account, if needed, reflected the fact that
I would not have external access to my POL laptop or email account and that
it was possible that the media interest may develop overnight.
The Leadership of the Scheme
159. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
159.1. _POL00138077;
159.2. _POL00040074;
159.3. _POL00040075;
159.4. POL00040076;
159.5. _POL00040077;
159.6. _POL00040078; and
159.7. POL00138147.
160. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
161. The Inquiry has asked me to provide details of the assessment of the Scheme
and any risks to POL which were identified. The Inquiry has also asked me to
describe any steps which were taken to mitigate those risks. The question
does not specify if it relates to risks / challenges to the Scheme itself (and the
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steps taken to mitigate those risks / challenges) — which the majority of exhibits
relate to — or whether it relates to wider reputational risks to POL, and the
extent to which those were mitigated. I will address both.
162. As demonstrated by the Key Issues slides in both POL00138077 and
POL00040078 a number of risks had been properly identified which could
have a material impact upon the administration and success of the Scheme
itself. These include consideration of points which I have already addressed,
such as whether Second Sight had sufficient resources (see answer at para.
138 relating to the timeliness of Second Sight work), delays associated with
data requests from Fujitsu, POL’s own capacity and capability to progress
investigations, and the potential impact of the “expectation gap” (see para. 95)
on the Scheme’s success. Each of those risks / issues were identified,
assessed and the exhibits set out the actions which were identified and
assigned, to mitigate.
163. _POL00040075 is a Media Scenario Planning document which, from
recollection, had been prepared by Mark Davies (or his team) in his capacity
as POL’s Communications Director. That document identifies a number of
additional risks (albeit there is some cross-over with the previous exhibits)
which could eventuate, and consideration of the proposed approach POL
would take with the media. The document also sets out the proposed actions
to mitigate those risks.
164. The Inquiry has asked me to confirm what key themes were identified in the
CQRs (Case Questionnaire Responses) that been reviewed by February
2014. I refer to my answer at para. 24 and reference to POL00040076, being
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an analysis undertaken by Bond Dickinson on 27 January 2014 relating to the
key themes arising from CQRs at that time. I was aware of that analysis and
agree with its content as to the position, at that time.
165. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following further exhibits:
165.1. POL00100032;
165.2. POL00138101;
165.3. POL00138167;
165.4. POL00138176; and
165.5. POL00138282.
166. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
167. The Inquiry has asked me to set out the membership of the programme board
and the extent, if any, to which it differed from the leadership / management
team for the Scheme. There was a difference between membership of the
programme board and the leadership / management team for the Scheme,
which I explain below:
167.1. As per POL00138147, Chris Aujard was the chairman of the programme
board. The membership of the programme board is set out in the same
document. Prior to the establishment of the programme board, as set out at
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POL00100032, there was a Scheme steering group which was chaired by
Paula Vennells. The membership of the steering group is set out in the same
document. I had very little sight of the steering group, beyond my attendance
at that meeting on 16 December 2013, because it had been established prior
to my assignment with POL and was replaced by the establishment of the
programme board shortly thereafter.
167.2. As evidenced by the programme board minutes provided by the Inquiry, the
programme board reported into both the Project Sparrow Sub-Committee of
the POL board (see POL00138176 page 3 - I refer to my answer at para.
131 and also para. 128, whereby my understanding is that Project Sparrow
was de facto the Scheme) and also the full POL Board (see POL00138167
page 2 — minute numbers 4 & 5). In short, the Scheme programme board
was the most proximate governance group for day-to-day administration of
the Scheme. The overall leadership, management, decision-making (in
relation to more complex, strategic, long-term or risk related decisions) and
knowledge of the Scheme went as high as the POL Board.
168. The Inquiry has asked me to set out any material changes to the structure and
membership of those teams over the period that the Scheme operated. I can
only speak for the period between December 2013 and October 2014. In my
view, the key material change in structure and membership was moving from
a governance group chaired by Paula Vennells (Scheme steering group) to a
group chaired by Chris Aujard (Scheme programme board).
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169. The Inquiry has asked me to describe the role and work of the Scheme
steering group. I refer to my answer at para 167.1 above. The establishment
of the steering group pre-dated my assignment with POL and was quickly
replaced by the programme board. I would assume that the steering group
provided a materially similar function, in terms of providing a means of
executive oversight, preliminary discussions on how to administer the Scheme
and to review the progression of cases within it. My understanding is
consistent with the note produced by Chris Aujard dated 21 November 2013
(POL00027482) whereby “The Steering Group has, however, recently agreed
that the Post Office’s interests would be better served, and greater focus
would be achieved, by separating these activities [Project Sparrow] into two
distinct projects with Belinda Crowe being appointed as Programme Director
for the first (the mediation scheme) and Angela Van Den Bogerd acting as
Programme Director for the second (the BIP) [business improvement
programme]’.
170. The Inquiry has asked me to describe the role and work of the Scheme’s
Programme Board, including a summary of the objectives, discussions and
outcomes of each of the meetings that I attended. I refer to my answer at para.
167.2, whereby the role of the Scheme’s Programme Board was to provide
governance for the day-to-day administration and progression of the Scheme.
Its overarching objective was to drive the delivery of the Scheme and the
effective management of cases being progressed through it. I have reviewed
the exhibits of Programme Board meeting minutes and associated briefing
materials. In terms of the discussion and outcomes of each of those meetings,
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I confirm that the minutes are an accurate reflection (and consistent with my
recollection) of the discussion points and associated actions, where
applicable.
Settlement Policy
171. — Inresponding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
171.1. _POL00146797;
171.2. _POL00027505;
171.3. _POL00129110; and
171.4. POL00040201.
172. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
173. I The Inquiry has asked me to set out any knowledge I had about the settlement
policy, its origins, who was responsible for it, any use made of it before its
withdrawal, and the circumstances and reasons for its withdrawal. I have
reviewed the draft settlement policy which is dated November 2013 and is at
POL00027505. Given the date, its creation pre-dates my assignment with
POL. Notwithstanding that position, my understanding and recollection is that
it had been prepared by Andrew Parsons from Bond Dickinson. I cannot
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comment further on the origin or wider authorship of the document. To the
best of my knowledge and recollection, it was never actually signed-off or
issued; in that context, it was never formally “withdrawn”, albeit I accept that
language is used in the exhibits (by Andrew Parsons, at POL00040201). It
was not part of my role to authorise or make decisions in relation to any
“settlements” for cases within the Scheme; neither did I actually attend any
ultimate mediation, where any settlement offers from POL would be made and
discussed. I recall that the draft settlement policy was used by POL as a useful
starting / reference point for considering potential settlements at mediation,
but it was not a definite policy which determined or dictated POL’s position in
relation to any prospective settlement.
The Operation of the Scheme
174. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
174.1. POL00125093;
174.2. _POL00040079;
174.3. POL00040084;
174.4. POL00040082;
174.5. POL00038682;
174.6. POL00116487;
174.7. _POL00029707;
174.8. POL00108424;
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174.9. POL00108439;
174.10. POL00040182;
174.11. POL00040183;
174.12. UKGI00002395;
174.13. POL00061460;
174.14. POL00116648;
174.15. POL00116649;
174.16. POL00021803;
174.17. POL00074651;
174.18. POL00108764;
174.19. POL00061594;
174.20. POL00021760;
174.21. POL00124439;
174.22. POL00075691; and
174.23. POL00075679.
175. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
176. The Inquiry has asked me to describe how the Scheme operated and also to
describe each discrete step in the process by which the cases in the Scheme
were dealt with, from application to mediation. During my assignment with
POL, I (with the assistance of the other PA individuals assigned to the project)
designed and implemented a “Programme Dashboard” for the administration
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of the Scheme. Reference to that document (which was effectively an excel
spreadsheet) is made in the exhibits, such as at POL00138077 (page 6),
namely a Scheme Programme Board meeting pack dated 17 January 2014.
That slide confirms that the Programme Dashboard had been developed and
would be capable of producing reporting data / management information, for
the next Programme Board meeting. The Programme Dashboard effectively
tracked the number and progression of cases through the various stages of
the Scheme, to inform general management and workflow. I have not seen a
full version of the Programme Dashboard within the exhibits provided to me
(and cannot comment on whether it is otherwise in the possession of the
Inquiry), but that document would provide the greatest degree of detail on the
distinct stages of the Scheme process, from application to mediation.
177. — Ingeneral terms, an SPM would submit an application to join the Scheme. The
initial application would be considered by the Scheme’s Working Group for
general suitability / eligibility to be dealt with under the Scheme. Where an
application / case was considered suitable / eligible, the applicant would be
provided with a Case Questionnaire (CQ) to complete, to set out a general
overview of their case and the nature of their complaint, for further
consideration. Once completed and submitted by the respective applicant, the
CQ became a Case Questionnaire Response (CQR). The CQR would be
reviewed by Second Sight in the first instance and, once considered to contain
sufficient information to allow POL to understand the nature of the complaint
and what investigation would be required to address it, it would be considered
by the Working Group for acceptance. Once accepted, the CQR was passed
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to the POL investigation team (led by Angela van den Bogerd) to produce their
own case report. POL’s case report would then be passed to Second Sight to
prepare a Case Review Report (CRR). The purpose of a Second Sight CRR
was to consider the content of the CQR (applicant information), the POL case
report (POL investigation) and also to conduct their own investigation into the
nature of the complaint and set out their evidential findings, together with a
recommendation as to whether they considered the case to be suitable for
mediation. Second Sight’s CRR would then be considered and discussed by
the Scheme’s Working Group and whether the case would be sent for
mediation, or if further investigatory work was required. The final stage of the
process, for those cases where agreement was reached by the Working
Group (and by both the SPM and POL as the mediating parties) was
mediation.
178. The Inquiry has asked me to confirm how many applications to the Scheme
were anticipated when the Scheme began. As per para. 6, the establishment
of the Scheme pre-dated my assignment with POL. The initial deadline for
applications to the Scheme (18 November 2013 — as per POL00022120 page
6) also pre-dated my assignment with POL. I cannot therefore definitively
comment upon how many applications were anticipated by POL when the
Scheme began, but my recollection is that I was informed it was between 50
— 70. I can say that from December 2013 and my assignment with POL, the
number of applications which had been received (and which continued to be
received) greatly exceeded the numbers which had been anticipated by POL.
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179. The Inquiry has asked me to confirm if the number of anticipated applications
changed over the period that the Scheme was open. As per my answer at
para. 178, the actual number of applications received as at December 2013
had already exceeded POL’s expectations on the number of applications.
From that point onwards, more applications were received and were also more
than had been anticipated.
180. The Inquiry has asked me to confirm how the deadline for applications was
set. I refer to para. 178 — both the establishment of the Scheme and the setting
of the initial deadline of 18 November 2013, pre-dated my assignment with
POL.
181. The Inquiry has asked me to confirm the approach taken for dealing with
applications received after the deadline had passed. Notwithstanding the
deadline, where applications were received after that point, we would write to
the applicant and consider any completed CQR within the Working Group,
consistent with any other application (whether received before or after the
deadline). I do not recall any instances whereby POL unilaterally refused to
accept an application, solely on the basis that the deadline had been missed.
182. The Inquiry has asked me to confirm how applications to the Scheme were
investigated. I refer to my overview at para. 177. I cannot comment in terms
of the actual mechanics of the POL investigation, to include what other third
parties they liaised with (e.g. Fujitsu for technical data or legal input from Bond
Dickinson or Cartwright King), as that fell within the remit of Angela Van Den
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Bogerd. My recollection is that where an application related to a case where
there was an existing criminal conviction, the case underwent an additional
legal review by Cartwright King before being investigated by the POL
Investigation team.
183. I The Inquiry has asked me to confirm how decisions were made as to whether
or not to support mediation for a given case. For the avoidance of doubt,
whether or not to support a mediation for a given case was a POL decision
(i.e. beyond the scope of my remit or authority). My recollection is that Bond
Dickinson provided POL with legal advice on potential mediation settlements
and I would suspect POL received similar legal advice from Cartwright King in
relation to any criminal cases. Fundamentally, my recollection is that it was a
legally driven review process. That legal review process would result in a
recommendation for a POL mediation position, agreed between Belinda
Crowe and Andrew Parsons, for an ultimate decision to be made by one or
more of: (i) Chris Aujard; (ii) Paula Vennells; and / or (iii) Angela van den
Bogerd.
184. The Inquiry has asked me to confirm what advice was obtained to assist in
this determination. I refer to my answer at para. 183.
185. The Inquiry has asked me to confirm who had the final say about the position
POL would take regarding each case. I refer to my answer at 183.
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186. The Inquiry has asked me to confirm POL’s approach to the conduct of the
mediations themselves. I refer to my answer at 173; I never attended a
mediation. My understanding is that most mediations (if not all) were attended
by a POL representative and also a representative from Bond Dickinson.
187. The Inquiry has asked me to explain the role that Fujitsu had in the operation
of the Scheme. I refer to para. 35; whereby Fujitsu were not involved in the
administration or operation of the Scheme itself and also that lines of
communication with Fujitsu were tightly controlled. As per para. 182, my
understanding is that Fujitsu were involved in assisting and providing
information for the purposes of the POL investigation into Scheme cases,
which was a separate workstream.
188. The Inquiry has asked me to describe any contribution sought and obtained
by POL from legal advisers at each stage in the operation of the Scheme. I
refer to my answer at para. 183. More generally, it is worth making the point
(demonstrated by the exhibits) that POL was an organisation that sought and
obtained a significant amount of external legal advice. I was not privy to each
and every piece of legal advice that was obtained, but POL appeared to have
a very “thin” in-house legal model that operated with a high-degree of input
and support from a wide range of panel solicitor firms, most notably Bond
Dickinson who were the default external legal advisers for the Scheme.
189. The Inquiry has asked me to describe any material changes to the operation
of the Scheme, of which I was aware, over the period in which it was in
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existence. I can only comment on the period from December 2013 to October
2014. During that time, largely, the operation of the Scheme did not materially
change and was executed in broad compliance with the operational overview
and Frequently Asked Questions (FAQs) as set out at POL00105528, which
pre-dated my assignment with POL. I have spoken about the establishment of
the Scheme’s Programme Board in terms of management, but this did not
materially affect the operation of the Scheme itself.
Executive / Board Oversight
190. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
190.1. POL00100032;
190.2. _POL00100165;
190.3. POL00027685;
190.4. _POL00116277;
190.5. POL00130509;
190.6. POL00116348;
190.7. _POL00105529;
190.8. POL00116241;
190.9. POL00116240;
190.10. POL00116562; and
190.11. POL00108742.
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191. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
192. The Inquiry has asked me to describe the nature and extent of the executive
oversight that the CEO (Paula), Chairman (Alice) and board (various) of POL
exercised over the Scheme. I refer to my answer at para. 167.2. Both Paula
and Alice sat on the Project Sparrow Sub-Committee to the Board, where the
operation and progress of the Scheme was discussed on a regular basis and,
what I would describe as, to a granular level of detail. The basis for the
Scheme (i.e. the very existence of complaints) and the Scheme itself (in terms
of administrative cost, potential compensatory cost, and associated public
relation concerns) was a major corporate risk for POL at that time. The
Linklaters advice (I refer to para. 91 onwards) directly related to risks
associated with the Scheme and was obtained for the purposes of briefing the
POL Board. Christa Band presented that advice, in person, to the POL Board.
In summary, in my view, there was a significant degree of executive oversight
over the Scheme by Paula, Alica and the POL Board.
193. The Inquiry has asked me to set out my recollections of every meeting that I
attended with the CEO and Chairman on the subject of the Scheme. I refer to
my answers at paras. 17 and 18; whereby it has been over 10 years since my
assignment with POL and I do not have access to my POL laptop / email
account (or associated calendar / diary) in order to provide a comprehensive
or complete answer to this question. From the exhibits disclosed to me, where
there are minutes of a meeting (Steering Group, Programme Board, Sub-
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Committee etc) at which I am in attendance with Paula and / or Alice, I believe
that those minutes are a fair reflection of what was discussed and what any
outcomes were. In terms of the Scheme, Belinda (as Programme Director)
had more of a direct line of communication with Paula than I did. I did not have
any informal lines of communication with Paula. Any meeting that I did have
outside of the formal governance meetings, would have had a defined purpose
for briefing or updating her on some aspect of the Scheme (see para. 282 in
relation to briefings for Paula’s meeting with James Arbuthnot MP). Chris
Aujard was primarily responsible for briefing Alice, as that was her preferred
way of working (i.e. she had an expectation that she should be briefed, as
Chairman, by one of her executives — such as the General Counsel).
Funding
194. The Inquiry has asked me to set out any knowledge I had of the budget of the
Scheme, how this changed over time and the reason for any changes. I refer
to para. 157.4 and the exhibit reference therein, which set out an initial
budgetary assessment. I did not have sight of the overall POL budget cost for
the Scheme at any point. This is not unusual, given that my assignment (and
PA’s involvement to provide external management services to POL) formed
part of that budget and was one of a number of external management costs.
Generally, I can say that my understanding is that the administrative cost of
running the Scheme was substantial and only increased over time. The
reasons for those increases were due to delays with the Scheme, the
extended duration of the Scheme from initial lifespan, and the widening pool
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of external experts who were retained by POL to provide different types of
advice at various stages. Notwithstanding that comment, I am not aware of
any instance where budgetary restraint by POL had any impact upon the
execution or delivery of the Scheme.
195. The Inquiry has asked me to confirm what knowledge I had about any cost
concerns regarding the Scheme and what, if any, impact those concerns had
on POL’s overall approach to the Scheme and decision making in relation to
individual cases. To the extent that the Inquiry’s question regarding “cost
concerns” includes the expectation gap (see para. 95) then there were
concerns on that point. The Linklaters advice (see section from para. 91
onwards) provided POL’s Board with clarification on the actual legal
recoverability of consequential losses which gave rise to the expectation gap
(i.e. the cost implication), but did not resolve the gap itself as a significant rift
between POL and SPM positions. Separate to that point, in terms of concern
over the rising administrative cost of the Scheme (see para. 194 above), there
was a significant amount of concern within POL as to size of the costs but I
cannot recall any decisions being made as a result of cost concerns that had
a material impact on the Scheme’s operation during the time of my assignment
with POL.
THE WORKING GROUP
Overview
196. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
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196.1. _UKGI00002360;
196.2. UKGI00002361; and
196.3. POL00026641.
197. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
198. The Inquiry has asked me to set out my understanding of the scope of the
Working Group. My understanding of the scope of the Working Group is
consistent with the terms of reference at UKGI00002361. Generally, the
Working Group was established to provide independent oversight over the
administration of the Scheme and ensure that there was an appropriate level
of visibility and transparency in the process, for the benefit of JFSA (Alan
Bates) and Second Sight. It was on that basis that POL sought a respected
and independent chair for the Working Group; Sir Anthony Hooper, who was
a former Court of Appeal judge.
199. The Inquiry has directed me to consider POL00040078 and explain in what
way was “a different view being taken by JFSA and Second Sight to Post
Office” as to the scope of the Working Group. My recollection is that this
comment in linked to my answer at para. 138, in relation to discussions and
negotiations around the scope of Second Sight’s work. The question being
discussed at the Working Group was whether it would oversee the previous
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work being undertaken by Second Sight (i.e. their original scope of
engagement, to investigate the Horizon system as a whole) or whether it
would be limited to their work on the mediation cases within the Scheme.
Clearly, it was the view of JFSA and Second Sight that: (i) that work should
continue; and (ii) it should be overseen by the Working Group. This is
evidenced at POL00026641 (page 1), whereby “Alan Bates raised the issue
of the scope of the Working Group and whether the intention was that the
Terms of Reference would replace existing documentation particularly but not
limited to the ‘raising concerns about horizon’ documentation’ and that “JFSA
felt the Terms of Reference as drafted were insufficiently broad’. POL’s
position, as I set out at para. 138, was to try and ensure that Scheme cases
were investigated and progressed in an expeditious manner, for the benefit of
applicants and all members of the Working Group.
200. The Inquiry has asked me to confirm how, if at all, did the scope of the Working
Group change over the period that I was part of it. The membership and
chairmanship of the Working Group was consistent throughout my assignment
with POL. My view is that the objectives of the Working Group remained
broadly consistent with those set out in the terms of reference at
UKGI00002361. On reflection, I do not recall that paragraph 4.6 in that
document — “manage the administration of the Scheme so as to ensure that
the Scheme’s processes and procedures are offering value for money for
taxpayers” — was ever really enacted or a point of focus for the Working Group,
during my time in it.
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Meetings
201. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
201.1. POL00026666;
201.2. POL00026638;
201.3. POL00026639;
201.4. POL00026640;
201.5. POL00026641;
201.6. POL00026635;
201.7. POL00043626;
201.8. POL00026636;
201.9. POL00026637;
201.10. POL00026656;
201.11. POL00026643;
201.12. POL00026642;
201.13. POL00026644;
201.14. POL00026633;
201.15. POL00026652;
201.16. POL00026653;
201.17. POL00026660;
201.18. POL00026663;
201.19. POL00043627;
201.20. POL00026657;
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201.21. POL00026659;
201.22. POL00026667;
201.23. POL00026668;
201.24. POL00026664;
201.25. POL00026673;
201.26. POL00026665;
201.27. POL00026672;
201.28. POL00026671;
201.29. POL00026683;
201.30. POL00026674;
201.31. POL00026676;
201.32. POL00026679;
201.33. POL00026680;
201.34. POL00026685;
201.35. POL00043628; and
201.36. POL00026684.
202. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
203. The Inquiry has asked me to explain how the Working Group operated. I refer
to my answer at para. 177 in terms of how and where the Working Group sat
within the Scheme’s process itself. In terms of actual operation, I refer to again
to UKGI00002361 and specifically paragraph 6, namely the Working Groups
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“Working process”. This is broadly a fair reflection of how the Working Group
operated in practice, whereby practices were determined by the Chair,
meetings were held at least once a month with further ad-hoc meetings being
arranged as and when required, the meetings were to remain confidential to
the members of the Working Group unless there was agreement that
information could be disclosed, and accurate minutes of the meetings were
kept and approved by the Chair. I consider POL00026660 (page 1) to set out,
in my view, a fairly standard agenda for discussion points in each Working
Group meeting.
204. The Inquiry has asked me to describe my role within the Working Group and
the work I carried out in that role. I supported Belinda Crowe who acted as
secretariat to the Working Group. Although I was likely seen as attending on
behalf of POL (as a consultant providing services to POL), I was not de facto
a “POL representative” within the Working Group. My role was restricted to
providing secretariat support to Belinda, or Sir Anthony Hooper as required,
and to provide administrative support and updates on the cases being
progressed within the Scheme and their current position. I was not a voting
member of the Working Group. I would occasionally participate in meetings in
order to provide Scheme updates, on a factual basis and with reference to the
case tracker. I did not make decisions on the suitability of cases to be included
within the Scheme, the suitability of cases for mediation, or what any potential
outcome of a mediation would be. Equally, I did not engage with the technical
subject matter forming the basis of either POL’s, or an SPM'’s, respective
position.
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205. The Inquiry has asked me to set out what I know about the role and activities
of each of the other POL members of the Working Group. As per my answer
at para. 204, answering this question requires a degree of nuance to
differentiate between POL individuals attending Working Group meetings, and
POL individuals who were there as bona fide POL representatives with the
authority to speak on behalf of POL as a mediating party and Working Group
member (i.e. to exercise POL voting rights). Belinda Crowe attended the
Working Group but in her capacity as Programme Director for the Scheme and
therefore, similar to my role, largely provided secretarial and administrative
support to the Working Group and Chair, and factual case progression
updates where required. Actual POL representatives at Working Group
meetings varied but, as demonstrated by the various minutes, included Chris
Aujard, Angela van den Bogerd, and Rodric Williams — usually supported by
Bond Dickinson. That representation made sense, as an interface between
POL legal (Chris, Rod) and POL investigations (Angela).
Information provided by POL to the Working Group
206. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
206.1. POL00040144;
206.2. POL00040146;
206.3. POL00040151;
206.4. POL00040152;
206.5. POL00040153;
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206.6. POL00040154;
206.7. POL00124439;
206.8. POL00101297; and
206.9. POL00040282.
207. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
208. The Inquiry has asked me to describe how decisions were made as to the
information that would be provided to the Working Group. I do not fully
understand the context and relevance of the exhibits which have been
provided to me, in order to answer this question. The majority of the material
relates to the preparation of briefing notes, and the notes themselves, to
inform POL’s position (i.e. POL representatives — Chris, Rod, Angela) at the
Working Group, on behalf of POL. They are not papers which were being
prepared for the Working Group and, in my view, there is no basis upon which
the content should have been shared. Similarly, I expect Alan Bates on behalf
of JFSA (potentially in collaboration with Second Sight, on specific issues, and
SPMs) to have prepared for meetings and attended on an informed and
briefed basis, as to what their position was. This is not unusual. I would equally
not expect to have been provided with information from Alan Bates, JFSA or
Second Sight as to the basis of their position. Generally, the Working Group
would have access to the investigatory work products of both POL and Second
Sight (once finalised) and would be provided with full and transparent updates
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on the progression of cases through the Scheme and the reasons for any
delays. POL’s position in relation to any wider points would be relayed during
the course of meetings, by an authorised POL representative (Chris, Rod,
Angela etc).
209. ~The Inquiry has asked me to describe how decisions were made as to the
position that POL would take on any issues to be determined by the Working
Group. POL’s position would be informed by any individuals who held relevant
information relating to the relevant issue. That information would be collated
and considered by Chris Aujard as General Counsel, discussed as appropriate
with other senior executives (e.g. Paula, Angela if it related to investigation
detail, Mark Davies if there was a substantial PR concern relating to a
particular issue), before Chris would make a final decision on the majority of
day-to-day issues — potentially with the input and assistance of Rodric and /
or Bond Dickinson. I would sometimes be involved in the preparation of
materials (i.e. briefing notes) which would assist in that decision making, but
that would largely consist of collating relevant information and comments from
other POL individuals who had the requisite technical and / or legal
knowledge. The only instances where I would offer my own view /
recommendation for consideration by Chris would be where any issue related
to the administration or operation of the Scheme itself. For example, I would
provide my view on the general quality and timeliness of Second Sight work,
insofar as the work product expected and required to progress cases through
the Scheme or narrow the issues in dispute.
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210. The Inquiry has asked me to confirm which individuals had input into any such
decision making. Day-to-day decision-making lay with Chris Aujard as General
Counsel. Ultimate decision-making on any particularly sensitive issues lay with
Paula Vennells, on the advice of Chris. Input into decision-making came from
a number of sources, including Angela, Rodric, Bond Dickinson, Mark Davies,
Belinda and myself (to the extent set out at para. 209 above).
211. The Inquiry has asked me to confirm who had the final say in any such
decision-making. I refer to my answer at para. 210 above.
Communication with Sir Anthony Hooper
212. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
212.1. POL00108268;
212.2. POL00116305;
212.3. POL00100322;
212.4. POL00100324;
212.5. POL00002329;
212.6. POL00116536;
212.7. POL00116544;
212.8. POL00108528;
212.9. POL00021844;
212.10. POL00021803;
212.11. POL00101053;
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212.12. POL00040221;
212.13. POL00040233;
212.14. POL00075193;
212.15. POL00065213;
212.16. POL00101305;
212.17. POL00040263;
212.18. POL00040264;
212.19. POL00040265;
212.20. POL00040266;
212.21. POL00040267; and
212.22. POL00136853.
213. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
214. The Inquiry has asked me to describe the nature of the communications
between POL and Sir Anthony Hooper in respect of both the work of the
Working Group and any parallel meetings and communication that took place
alongside the activities of the Working Group.
215. In answering this question, I would reiterate that the entire purpose and
rationale for appointing Sir Anthony Hooper as Chair of the Working Group, in
his capacity as a former Court of Appeal judge, was to provide a recognised
and senior level of independent oversight to the Working Group. It was to
provide proper assurances to Second Sight, Alan Bates, JFSA and interested
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MPs that the Scheme was being scrutinised and arbitrated by a well-respected
and nonpartisan intermediary, outside of POL. That remained the position
throughout. In my recollection, Sir Anthony Hooper performed his duties
expeditiously and impartially.
216. In respect of the Working Group, communications between POL and Sir
Anthony Hooper related to the arranging of meetings, agreement and
circulation of agendas and minutes, and correspondence relating to cases
being considered by the Working Group and within the scheme.
POL00040264 is a good example of this, whereby Sir Anthony Hooper sent a
letter to Chris Aujard to provide various Second Sight case review reports.
217. In relation to “parallel meetings and communication”, I can see from the
exhibits (POL00108268) that in February 2014 a meeting was arranged
between Paula Vennells and Sir Anthony Hooper. POL00100322 is a briefing
note for Paula (which I was involved in preparing), to prepare for that meeting.
The discussion points are set out at point 6 of that briefing note and entirely
relate to the Working Group and administration of the Scheme. There is a
further reference at POL00108528 where I email Sir Anthony Hooper and
confirm that Paula and Chris wanted a catch up. I would not categorise any of
these instances of communication or meetings as “parallel” or materially
beyond the topic of the Working Group. Sir Anthony Hooper deliberately
maintained a level of formality with all members of the Working Group. It’s not
unusual for members to separately meet with the Chair of a governance group
and it does not undermine the integrity of the group or the Chair's position. It
was not an attempt by POL to sway Sir Anthony Hooper. The meetings and
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correspondence that I am aware of related to the discussion and resolution of
legitimate issues (including the consideration of criminal cases) within the
Scheme and the Working Group and potentially to agree agenda points for
formal Working Group meetings.
218. The Inquiry has asked me to confirm how frequently representatives of POL
met with, spoke with, or corresponded with Sir Anthony Hooper outside of the
ambit of the formal Working Group meetings and communication. I am aware
of the meetings and correspondence as set out in the exhibits which have
been provided to me. I am not aware of the full extent of meetings or
correspondence between Sir Anthony Hooper and POL and have no way of
checking (I refer to paras. 17 and 18).
219. The Inquiry has asked me to confirm why such parallel communications took
place. I refer to my answer at para. 217.
220. The Inquiry has asked me to confirm what knowledge I have of the matters
that were discussed on any such occasions. I refer to my answers at paras.
217 and 218. To the best of my knowledge and recollection, all matters
discussed with Sir Anthony Hooper would have been in the context of his role
as Chair of the Working Group and related to the discharging of his duties as
Chair of the Working Group.
Communication with Sir Alan Bates
221. In responding to this topic, and in order to address the Inquiry's questions, the
Inquiry has asked me to consider the following exhibits:
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221.1. POL00116500;
221.2. POL00116501;
221.3. _POL00116507;
221.4. POL00116521;
221.5. POL00040144;
221.6. POL00040145; and
221.7. POL00021872.
222. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
223. The Inquiry have asked me to set out my recollection of any communication
that occurred between POL and Mr Alan Bates, outside the ambit of the
Working Group, during my time working on the Scheme. Sir Alan Bates was
an applicant of the scheme and therefore there would have been direct
communication with him relating to his application. I am not aware of the full
extent of the correspondence between Sir Alan Bates and POL and have no
way of checking. I see from the exhibits (POL00116500 and POL00021872)
that following a letter from Sir Alan in April 2014 and a freedom of information
request in May 2014, there was communication outside of the ambit of the
working group. These were two isolated incidents and I am not aware that any
communication took place other than through the Working Group and
mediation
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224. The inquiry has asked me to confirm what matters were raised by Sir Alan
Bates in the communications that occurred with POL, and how POL
responded. I refer to my answer at para. 217. In relation to POL00116500
there was an internal POL discussion that discussed the points raised within
the letter. I helped prepare a draft response on behalf of POL and a
commentary of the letter was prepared ahead of the 30 April 2014 Working
Group meeting. In relation to POL00021872, Bond Dickinson and Belinda
Crowe drafted response relating to the freedom of information request.
The Response to Second Sight’s Findings
225. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
225.1. POL00006554;
225.2. POL00006555; and
225.3. POL00004439.
226. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
227. The Inquiry has asked me to summarise my understanding of the findings in
Second Sight's Briefing Report Part One. My understanding is that Second
Sight’s Briefing Report Part One was meant to be a factual description of the
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Horizon System within the POL network, including providing background
about the operation of the POL systems and the use of Horizon as an
accounting piece of software. My understanding is Second Sight's Briefing
Report Part One was designed to be helpful factual reference document that
could be used by the mediator and parties to mediation as a reference piece.
This is noted by Andrew Parson at POL00006555 (page 3).
228. The Inquiry has asked me to describe POL’s response to Second Sight’s
Briefing Report Part One, and what my contribution to that response was. I
refer to my answer at para. 227. POL believed that Second Sight’s Briefing
Report Part One designed to be helpful factual reference and provided a
substantial amount of the content for the report. POL were concerned with
some of the unsupported assertions and lack of accuracy. I refer to my answer
at para. 23. I did not have the technical expertise to provide any substantive
technical feedback, but I suspect I will have had a role in consolidating POL’s
comments.
229. The Inquiry has asked me to state who else at POL made a contribution to
their response to Second Sight’s Briefing Report Part One. Belinda Crowe,
Angela van den Bogerd, Chris Aujard and Rodric Williams all received the
report and would have provided feedback.
230. The Inquiry has asked me to state what legal advice was obtained in respect
of POL’s response to Second Sight’s Briefing Report Part One. As far as I am
aware, the report was reviewed by the in-house legal team, Chris Aujard and
Rodric Williams, and it was reviewed by Bond Dickinson
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231. The Inquiry has asked me to state who had the final say as to the nature and
form of POL’s response to Second Sight’s Briefing Report Part One. I cannot
recall specifically, though it is likely to have been Chris Aujard,
232. The Inquiry has asked me to describe how and to whom was POL’s response
to Second Sight’s Briefing Report Part One disseminated. I cannot comment
upon the degree of dissemination within or outside POL.
Briefing Report — Part Two (Thematic Issues) - dated 21 August 2014
233. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
233.1. POL00006552;
233.2. POL00006553;
233.3. _POL00100479;
233.4. POL00021844;
233.5. POL00021803;
233.6. POL00021934;
233.7. POL00021909;
233.8. POL00022149;
233.9. _POL00006557;
233.10. POL00132931;
233.11. POL00022208;
233.12. POL00021916;
233.13. POL00040210;
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233.14. POL00021904;
233.15. POL00022212;
233.16. POL00021866;
233.17. POL00040491;
233.18. POL00021800;
233.19. POL00040221;
233.20. POL00021954;
233.21. POL00021953
233.22. POL00021922;
233.23. POL00040233;
233.24. POL00021760;
233.25. POL00123336;
233.26. POL00021883;
233.27. POL00021773;
233.28. POL00021886;
233.29. POL00132933;
233.30. POL00027113;
233.31. POL00040252;
233.32. POL00040253;
233.33. POL00021763;
233.34. POL00022240;
233.35. POL00148981; and
233.36. POL00148982.
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234. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
235. The Inquiry has asked me to summarise my understanding of the findings in
Second Sight’s Briefing Report Part Two. My understanding of the rationale
behind the production of Second Sight’s Briefing Report Part Two is explained
in exhibit POL00040253, namely that Second Sight suggested that they would
provide an overarching thematic report which would allow them to write shorter
individual case reports. This would be done by drawing upon spot reviews. It
was hoped that this would reduce costs and make the case reports more
manageable. My understanding of Second Sight’s findings was that they had
identified key thematic issues relating to the POL systems. This included, but
was not limited to, transactional anomalies associated with ATMs, lottery
terminals, motor vehicle licenses and foreign currency.
236. The Inquiry has asked me to describe POL’s response to Second Sight’s
Briefing Report Part Two, and what my contribution to that response was.
POL's response is summarised in exhibit POL00006552 by Andrew Parsons
who explains that the report lacks detail and evidence to back up sweeping
conclusions. I refer to my answer at para. 23. I did not have the technical
expertise to provide any substantive technical feedback, my role was to draw
together others' comments on those findings and to depersonalise POL’s
response to the report and ensure the response was measured and factual. I
also helped to prepare the logic note (POL00040253). This note followed the
decision of the Chair of the working group that the release of Second Sight’s
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Briefing Report Part Two should not be delayed while the disagreement
between POL and Second Sight was resolved. This is because Second Sight
were providing an independent view. However, it was felt by POL that they
needed in parallel to provide clarity that they did not accept the report or its
content. I believe the note was sent to all recipients of Second Sight’s Briefing
Report Part Two I also helped draft the email (POL00132933) to applicants of
the Scheme expressing POL’s position and highlighting some of their various
concerns with the report.
237. The Inquiry has asked me to state who else at POL contributed to their
response to Second Sight’s Briefing Report Part Two. As can be seen from
the exhibits, input into the response came from a number of sources, including
Paula Vennells, Angela van den Bogerd, Belinda Crowe, Rodric Williams,
Chris Aujard, Bond Dickinson, Mark Davies, and myself. Brunswick Group, a
PR and crisis management company were also engaged. Paula would have
had ultimate oversight of the response — it would have been led by Chris
Aujard.
238. The Inquiry has asked me to state what legal advice was obtained in respect
of POL’s response to Second Sight’s Briefing Report Part Two. The report was
reviewed by the in-house legal team, Chris Aujard and Rodric Williams, and it
was reviewed by Bond Dickinson. Beyond that I am not able to say.
239. The Inquiry has asked me to state who I believe had final say as to the nature
and form of POL’s response to Second Sight’s Briefing Report Part Two. I
refer to my answer at para. 237. Paula Vennells, assisted by Chris Aujard and
Mark Davies, would have led the response.
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240. The Inquiry has asked me to describe how and to whom was POL’s response
to Second Sights Briefing Report Part Two disseminated. Exhibit
POL00027113 shows that POL’s response was shared with the Working
Group, which included Sir Alan Bates and Sir Anthony Hooper. The same
email explains that Angela Van Den Bogard also wrote to the applicants of the
Scheme who had received the Second Sight Part Two Report.
241. The Inquiry has asked me to consider the exhibit POL00021916. I confirm that
I have reviewed this exhibit, and it has informed my answers to the below
questions. I shall make specific references to the exhibit where necessary, to
explain my answers. However, it is important to highlight that this document
was a speaking note that I prepared for Belinda Crowe.
242. The Inquiry has asked me to explain why I was “so concern[ed]” about Second
Sight’s Briefing Report Part Two. I refer to my answer at para. 241. It was
Belinda’s concern that I was noting the point is intended as a speaking point
for her to raise with Second Sight.
243. The Inquiry has asked me to explain why I felt that Second Sight’s Briefing
Report Part Two adversely impacted applicants at mediation. I refer to my
answer at para. 241. It was felt that due to the quality of the report and the
lack of evidence to support the conclusions, Second Sight’s Briefing Report
Part Two was not helpful as it did not narrow the gap between mediating
parties, as needed.
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244. — The Inquiry had asked me to explain in what way I believe the scope of Second
Sight’s work had slipped. I refer to my answer at para. 241. It was felt that not
only had timescales slipped but Second Sight had widened their scope to
include expressing opinions on matters outside their professional discipline.
An example being providing a commentary on the fairness of agent contracts
and contract law.
245. The Inquiry has asked me to explain why I believed POL would be “forced” to
take a particular response to the report in its “current form”. I refer to my
answer at para. 241. It was felt that the report could drive a wedge between
the parties, it would further complicate the Scheme and it would not narrow
the issues, and therefore POL would need to respond.
246. The Inquiry has asked me to explain, on reflection in the present day, my
thoughts about the views that I held at the time. Having reflected extensively
on this matter, I still believe that Second Sight’s Briefing Report Part Two was
not ready for publication at that stage, as it did not document and evidence
their findings adequately or in sufficient detail.
247. The Inquiry has asked me to consider the exhibits POL00040074 and
POL00040076. I confirm that I have reviewed these exhibits, and they have
informed my answers to the below questions. I shall make specific references
to the exhibits where necessary, to explain my answers.
248. The Inquiry has asked me to describe what POL’s views were as to the
existence and nature of any common themes arising from the application to
the Scheme. POL acknowledged and were aware that there were key themes
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in the applications to the Scheme but at that point in time, those applications
had not been investigated.
249. The Inquiry has asked me to describe how, if at all, did my view vary over the
period I was involved with the Scheme. Throughout the entire period I was
engaged in the Scheme, POL’s view remained constant, that there were no
systemic issues with Horizon and that had been tested by a High Court judge
with the help of an expert witness. It was consistently acknowledged that there
were similar themes and / or areas raised by applicants but it was not
acknowledged that the themes being raised showed systemic issues with
Horizon.
POL’s view of Second Sight
250. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
250.1. I POL00099977;
250.2. POL00100134;
250.3. POL00116250;
250.4. POL00100198;
250.5. POL00100200;
250.6. POL00116255;
250.7. POL00116276;
250.8. POL00116270;
250.9. POL00116279;
250.10. POL00100322;
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250.11. POL00100323;
250.12. POL00074462;
250.13. POL00108377;
250.14. POL00116523;
250.15. POL00116524;
250.16. POL00116578;
250.17. POL00108742;
250.18. POL00022227;
250.19. POL00022231; and
250.20. POL00040290.
251. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
252. The Inquiry has asked me to set out my understanding of the opinion in which
Second Sight was held by the POL executive and by members of the Scheme
management team at the start of my work with the Scheme. At the beginning
of my assignment there were capacity concerns raised by numerous people
and that view solidified because Second Sight failed to hit some of their
timelines.
253. The Inquiry has asked me to explain how, if at all, did those opinions change
over the period that I worked on the Scheme. In addition to the capacity
concerns, which were highlighted in the Working Group meeting of 27 March
2014, exhibit POL00026644, by April 2014 an internal discussion was taking
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place in relation to the quality of the work that Second Sight was providing. It
was felt their report lacked detail and would make sweeping conclusions
without the evidence to back them up.
254. ~The Inquiry has asked me to explain my understanding of the reasoning for
these opinions. The minutes of the Working Group meeting of 27 March
(POL00026644 page 4) notes that Second Sight had missed a deadline for
submitting their thematic report and there were other delays caused by
Second Sight. The concerns about the standard of their work became more
apparent the more reports that were received.
255. The Inquiry has asked me to explain my own opinion of Second Sight. I would
like to point out that I wasn't managing their activity, so I am not able to state
if they were being frustrated by what they were being provided by POL. I don't
know if information was being withheld from them. The problem I witnessed
was that the work wasn't of the quality required, was not produced in a timely
fashion and the work was not helping to progress mediation.
256. The Inquiry has asked me to explain, on reflection in the present day, to what
extent, if at all, do I believe that the opinions within POL were justified. I refer
to my answer at para. 255. I witnessed that the work wasn't of the quality
required. It often lacked detail and it would make conclusions without providing
supporting evidence. I also refer to para. 286.
Criminal Case Review and Prosecution Policy
257. In responding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
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257.1. POL00030694;
257.2. POL00038633;
257.3. _POL00138077;
257.4. POL00100136;
257.5. POL00040062;
257.6. POL00113111;
257.7. POL00027760;
257.8. POL00123176;
257.9. POL00021424;
257.10. POL00030716;
257.11. POL00116258;
257.12. POL00027754;
257.13. POL00027755;
257.14. POL00038644;
257.15. POL00027451;
257.16. POL00021750;
257.17. POL00127601;
257.18. POL00112974; and
257.19. POL00123322.
258. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
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259. ~The Inquiry has asked me to set out my understanding of POL’s role in
prosecuting sub-postmasters for theft and false accounting. I refer to my
answer at para. 15. During my assignment with POL, my understanding was
that POL acted as a private prosecutor and prosecuted cases themselves. I
was necessarily aware of those proceedings and the extent to which they
affected the way in which they could be progressed and settled through the
Scheme. However, I was not part of any decisions relating to the conduct of
those proceedings, POL’s disclosure obligations within (or after) those
proceedings, or the safety of the convictions. My assignment was in relation
to the Scheme, which was a separate and distinct workstream from any civil
and / or criminal proceedings that were undertaken by POL against SPMs. As
explained at para. 134, part of my assignment was to support POL employees
with the preparation of some external communications. As can be seen in
exhibit POL00113111 (page 74), I assisted in the drafting of responses to
individuals who were under investigation for theft and / or false accounting.
The description of me as a Legal Consultant in the minutes of the Audit, Risk
and Compliance Sub-Committee (POL00021424) is incorrect.
260. The Inquiry has asked me to explain to what extent was the POL Board and /
or senior management concerned that convictions had been secured on the
basis of potentially unreliable data generated by Horizon. Throughout my
assignment, POL were confident that data generated by Horizon was reliable.
I was aware that there was a dispute between POL and SPMs, whereby POL
held a position that there were no systemic issues with the Horizon system.
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261. The Inquiry has asked me to describe to what extent the Scheme
management team discussed POL’s involvement in prosecuting sub-
postmasters and to provide details of any discussions that took place. I refer
to my answer at para. 259. The Scheme’s management were aware that POL
brought private prosecutions, both for theft and false accounting. The Scheme
management was aware of those proceedings and the extent to which they
affected the way in which they could be progressed and settled through the
Scheme.
262. ~The Inquiry has asked me to consider exhibit POL00113111. I confirm that I
have reviewed this exhibit and it has informed my answers to the below
questions. I shall make specific references to the exhibit where necessary, to
explain my answers.
263. The Inquiry have asked to confirm whether Dave Posnett’s email of 26 March
2024 on p.112 was addressed to me, and if so, to please explain “your input
into NFA letter re other cases” and any advice you provided as a result of Mr
Posnett’s request. I do not recall assisting with the drafting of ‘No Further
Action’ letters to individuals. When correspondence cut across the scheme, I
may have been asked to assist in the tone of the letter, but I had no
responsibility for ‘No Further Action’ decisions. (POL00113111 page 12).
264. The Inquiry has asked me to set out full details of my understanding of POL’s
strategy and actions in respect of past convictions of sub-postmasters that
involved the use of data from the Horizon IT System in evidence. I refer to my
previous answers; POL’s criminal prosecution workstream was separate to
the Scheme and therefore I was not aware of POL having a strategy. I note
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from exhibit POL000214264 that I was present at the February 2014 Audit, Risk
and Compliance (‘ARC’) Committee. The membership of the committee was
normally very tight and limited. I believe I was invited to the meeting to assist
with communicating the prosecution policy to the board. As can be seen from
POL00027754, I was asked to send the board paper relating to the review of
the current prosecution policy to EXCO. I had no input into the recommended
changes of the policy.
265. The Inquiry has asked me to explain what involvement the Scheme’s
management team had with the review of past criminal prosecutions
undertaken by Cartwright King, and what my understanding was at the time
as to the reason why that review was undertaken. I refer to my answers in the
section commencing at para. 68. I did not have any involvement into the
review of past criminal prosecutions undertaken by Cartwright King. I am
unable to speak to Scheme management as a whole.
266. The Inquiry has asked me to explain what contribution the Scheme’s
management team made to disclosure decisions in relation to past and
ongoing prosecutions. I did not contribute to any disclosure decisions, but I
am unable to speak to Scheme management team.
267. The Inquiry has asked me to describe what impact Second Sight and the
Scheme had on POL’s approach to bringing prosecutions. The approach
taken by POL relating to prosecutions had been initiated before I started my
assignment. I was not made aware that any review or changes to the
prosecution policy was related to the Second Sight and / or the Scheme.
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268. The Inquiry has asked me to explain the process by which changes to the
prosecution policy were implemented. I refer to my answer at para. 264. I was
invited to the February ARC meeting, which was a single-issue meeting
relating to the proposed changes to the prosecution policy, to assist with
communicating the proposed changes to the board. I am not aware why
changes to the prosecution policy were implemented.
269. The Inquiry has asked me to explain what role I had in assisting any such
changes to the prosecution policy and to develop the new policy. I refer to my
answer at para. 268. I assisted with communicating the proposed changes to
the POL Board and would have then been in a position to draft any additional
correspondence that may have been required in relation to those changes,
though I do not recall having to do so.
Public Statements and Media Strategy
270. In responding to this topic, and in order to address the Inquiry's questions, the
Inquiry has asked me to consider the following exhibits:
270.1. POL00123148;
270.2. POL00040056;
270.3. POL00138101;
270.4. _POL00040075;
270.5. POL00116579;
270.6. POL00116580;
270.7. POL00044356;
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270.8. POL00101295;
270.9. POL00101297;
270.10. POL00101305;
270.11. POL00101316;
270.12. POL00101350;
270.13. POL00101361;
270.14. POL00101362; and
270.15. POL00040282.
271. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
272. The Inquiry has asked me to explain what role the management team of the
Scheme had in providing oversight of POL communications / PR. I refer to my
answer at para. 6. My past experience in the Civil Service not only involved
project delivery, but also handling external communications, so providing input
into POL communications / PR was within my professional competence. In
addition, Belinda had joined POL from the Ministry of Justice, originally, so
would have been comfortable in handling external communications. We would
work with Mark Davies through his team, and through Sophie, who was
embedded into the Scheme team, to agree POL public facing position issues.
Scheme management were consulted and had a role in drafting and agreeing
media lines where it could impact public perception on the Scheme. I was also
asked to assist on wider associated issues as and when required.
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273. The Inquiry have asked to explain my understanding of POL’s public
communications strategy in relation to journalists and the wider public in
respect of Horizon, Second Sight and the Scheme. In respect of Horizon, the
strategy was to reassure and reiterate that Horizon was a functioning system
and had no systemic flaws. This was done by reference to independent
validation, namely that Second Sight's interim report provided that Horizon
was a reliable system and with no systemic flaws. This allowed POL to
reassure all stakeholders that the prosecutions were safe. In respect of a
communications strategy relating to Second Sight, there was minimal public
comment on Second Sight by POL. When Second Sight’s Briefing Report Part
Two was obtained by different journalists, POL confirmed their position was
that the report was inaccurate (POL00101305). The communications strategy
in relation to the Scheme is outlined in POL00116580. The purpose of the
communications strategy was to show there was a desire by POL to resolve
SPM’s concerns, and that the Scheme had been established with an
Independent Chair to investigate any complaints and to resolve them through
mediation if possible.
274. The Inquiry has asked me to consider how, if at all, did this strategy change
over the period that I worked for POL, and the reasons for any changes. During
my assignment, there was no change in strategy in respect of Horizon, Second
Sight or the Scheme. I refer to my answer at para. 273. Following journalists
obtaining Second Sight’s Briefing Report Part Two, there was an overt
statement disagreeing with the report and expressing concerns about its
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accuracy, but I was not aware of an active campaign to communicate this
sentiment more broadly, it was only in response to specific requests.
275. The Inquiry has asked me to consider in turn each news publication,
broadcast, and or transmission relating to Horizon, Second Sight and the
Scheme that occurred during my time working on the Scheme and to set out:
i) how the publication was received in POL; ii) the detail of POL’s response;
iii) how POL’s response was prepared; and iv) how POL’s response was
delivered.
276. It is difficult to recall the exact way in which each publication was received by
POL and / or the detail of the response. However, there was overarching
guidance and some contingency planning for potentials areas of media
interest, both of which were led by the media and communications team. The
wording of such statements or briefings were finalised by Mark Davies and the
press office. The POL press office would field queries and request input from
members of POL or Scheme management, if and when required. There was
often a collaborative development of a position and an agreed approach
relating to who and how to engage with journalists. When POL were made
aware that different media outlets had obtained a copy of Second Sight’s
Briefing Report Part Two (POL00101350), the proposed media coverage was
received with concern as it was felt it was inaccurate. The subsequent media
coverage, where the journalists had altered their line following input from Post
Office, was met more calmly. The Scheme management were not in any way
authorised to speak to the media unless prior approval was given by the POL
press office.
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Engagement with Politicians
277. — Inresponding to this topic, and in order to address the Inquiry’s questions, the
Inquiry has asked me to consider the following exhibits:
277.1. I POL00108232;
277.2. POL00100124;
277.3. POL00100126;
277.4. POL00100128;
277.5. POL00100144;
277.6. POL00116246;
277.7. POL00116247;
277.8. POL00100142;
277.9. POL00100141;
277.10. POL00100136;
277.11. POL00100203;
277.12. POL00108257;
277.13. POL00100191;
277.14. POL00108351;
277.15. POL00026743;
277.16. POL00100210;
277.17. POL00100226;
277.18. POL00116258;
277.19. POL00100254;
277.20. POL00077180;
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277.21. POL00116325;
277.22. POL00108341;
277.23. POL00116340;
277.24. POL00130527;
277.25. POL00116344;
277.26. POL00108346;
277.27. POL00100445;
277.28. POL00116353;
277.29. POL00116356;
277.30. POL00116351;
277.31. POL00116367;
277.32. POL00116381;
277.33. POL00116334;
277.34. POL00116382;
277.35. POL00027700;
277.36. POL00116407;
277.37. POL00116413;
277.38. POL00100506;
277.39. POL00116436;
277.40. POL00116500;
277.41. POL00116507;
277.42. POL00025801;
277.43. POL00116530;
277.44. POL00116531;
277.45. POL00116536;
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277.46. POL00116544;
277.47. POL00116548;
277.48. POL00116549;
277.49. POL00116550;
277.50. POL00116551;
277.51. POL00116552;
277.52. POL00116553;
277.53. POL00116562;
277.54. POL00116563;
277.55. POL00100737;
277.56. POL00100695;
277.57. POL00116579;
277.58. POL00116580;
277.59. POL00131522;
277.60. POL00025801;
277.61. POL00131534;
277.62. POL00116584;
277.63. POL00100891;
277.64. POL00116593;
277.65. POL00116648;
277.66. POL00116649;
277.67. POL00116661;
277.68. POL00116668;
277.69. POL00116679;
277.70. POL00101054;
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277.71. POL00101053;
277.72. POL00116944;
277.73. POLO0109115;
277.74. POL00109203;
277.75. POL00109204; and
277.76. POL00105556.
278. I confirm that I have reviewed those exhibits and they have informed my
answers to the below questions. I shall make specific references to exhibits
where necessary, to explain my answers.
279. The Inquiry has asked me to explain what I understood to be POL’s
communications strategy in relation to parliamentarians such as Lord
Arbuthnot and Oliver Letwin MP and to government ministers, in respect of
Horizon, Second Sight and the Scheme, and to further explain: i) how, if at all
this strategy changed over the period that I worked for POL; ii) the reasoning
for any changes; iii) the extent to which POL were seeking to persuade MPs
that their constituents’ concerns were wrong; and iv) the extent to which POL
were seeking to listen and investigate those concerns.
280. Similar to my answer at para. 273, the communication strategy in respect of
Horizon was to reassure and reiterate that Horizon was a functioning system
and had no systemic flaws. This allowed POL to reassure parliamentarians
that the prosecutions were safe. This strategy never altered during my
assignment. In respect of a communications strategy relating to Second Sight
and the Scheme, as Second Sight and the Scheme were a mechanism for
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investigating the MPs complaints, POL tried to reassure parliamentarians that
the Scheme was the correct route for their complaints to be resolved, and
Second Sight had the ability to independently to look into the complaints as
part of the Scheme, and report directly to parliamentarians if required. Again,
this strategy never altered during my assignment. I am not aware that POL
ever explained to parliamentarians that their constituents were wrong. The
communication strategy with politicians was always that the Scheme would
investigate their constituent's claims and if POL found evidence of a
miscarriage of justice, they would deal with it accordingly. It is worth repeating
that the purpose of the Scheme was to create a framework under which SPM
complaints would be investigated and, where possible, result in a mediation
meeting to try and reach a resolution for that complaint. Engagement with
parliamentarians allowed POL to listen to, and investigate, constituents’
concerns.
281. The Inquiry has asked me to take in turn each meeting that occurred between
POL and Lord Arbuthnot and / or any other members of parliament during my
time working for POL and set out to the best of my knowledge: i) who attended
the meetings; ii) how the attendees at the meetings were briefed for the
meetings, including everyone responsible for contributing to the briefings; iii)
the source of any evidence used to prepare the briefings; iv) to what extent, if
at all, POL’s IT and problem management teams were consulted in preparing
briefings; v) how I personally prepared for any contributions I made towards
the briefings; vi) how decisions were made as to the scope and limits of the
information provided to the parliamentarians at each meeting, including who
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was responsible for those decision; vii) POL’s objectives for the meetings; viii)
a full account of what was said in the meetings; and ix) any and all action that
was taken as a result of the meetings.
282. It is difficult to recall the exact details of each meeting between POL and Lord
Arbuthnot and / or any other members of parliament during my assignment.
POL engaged with parliamentarians on a wide range of issues. My role in
relation to meetings with parliamentarians is helpfully highlighted within the
exhibits, namely, to pull together a briefing note for members of POL who were
attending those meetings. I would walk the attendees through the briefing
notes, which would usually include either Alice and / or Paula. I would often
then be tasked to work on certain things within the briefing note with other
senior leaders within POL (POL00116247). Where necessary, I would add
any follow up points to the briefing document. I also helped to draft an agreed
agenda with the parliamentarian’s secretary (POL00100128). As far as I can
recollect, I only attended one meeting with Lord Arbuthnot, on 28 January
2013, as the Scheme was being discussed (POL00026743). From the
exhibits, I can see that the senior leadership team of POL attended those
specific meetings; this included Alice Perkins, Paula Vennells, Angela Van
Den Bogerd, Mark Davies and Chris Aujard. Usually, an agreed agenda and
a written briefing was provided to POL individuals, and there was a pre
meeting which often resulted in an updated briefing document being provided.
Alice and / or Paula led the pre-meeting briefings with them. I was never
instructed to withhold anything from the briefing. The set of correspondence
for the January 2014 meeting (POL00100124) is a good example of the
preparation that took place for the meetings. The process for briefing
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parliamentarians was no different to briefing the POL board. I took care to
make sure the data was, as far as I was aware, fair, ttue and accurate. The
only primary evidence that I would have provided would have been the status
of the cases currently in the Scheme. Everything else was provided by other
teams. POL’s IT team would have provided input into these briefings. Fujitsu
may have provided input, but that would not have been through the Scheme
or me. The objective of the meetings with Lord Arbuthnot and other
parliamentarians, was to reassure parliamentarians that the Scheme was the
correct route for their complaints to be resolved, to update them on the
progress of the Scheme and to reassure them that POL was taking the
Scheme seriously, committing necessary resource and progressing cases
expeditiously. POL00026743 shows that a final note was agreed between
POL and the office of Lord Arbuthnot following the meeting that I attended. A
list of actions was noted and agreed upon. I believe that the actions flowed
from the meeting.
283. The Inquiry has asked me to explain my understanding as to how Lord
Arbuthnot'’s stance in relation to the Mediation Scheme changed during 2014,
and to further explain: i) what my understanding was for the reason for any
change; ii) how POL responded to Lord Arbuthnot’s changing stance; and iii)
how and by whom decisions on that response were made.
284. I refer to my answer at para. 4; my assignment ended in October 2014.
POL00026743 minutes that as of January 2014, Lord Arbuthnot was pleased
with progress being made under the scheme. I’m unaware of any material
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change in that position being communicated to the Scheme team or to me
directly.
GENERAL
285. The Inquiry has asked me to reflect on my time with POL and set out whether
there is anything I would have handled differently with hindsight, in relation to
the Horizon IT System and its associated issues. As I’ve made clear
throughout my statement, my role as Programme Manager for the Scheme did
not involve any direct involvement with, or analysis of, the Horizon IT System
itself. My answer to this question is therefore limited to the Scheme and the
associated issues which arose during its operation, until the end of my
assignment with POL in October 2014. Given my involvement with the
Scheme, I have inevitably followed the evidence which has emerged during
the course of the Inquiry and the associated media coverage. My answer to
this question is therefore in two parts: (i) reflection upon my involvement with
the Scheme, based upon my recollection of the knowledge and information I
had at that time; and (ii) reflection upon my involvement with the Scheme,
including my knowledge of the events which post-dated my assignment with
POL and the evidence which the Inquiry has heard.
286. Based upon my recollection of the knowledge and information I had at the
time, I cannot identify any points at which I would have handled things in a
materially different way. I was engaged by POL to assist with the
administration of an already established Scheme and in the wider context of a
significant period of public scrutiny of POL. I believe that at all times I
performed my role properly and with professional integrity. I believe that the
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Scheme was set up with the right intentions, in order to investigate and
hopefully resolve as many of the SPM complaints as possible; that was
certainly the basis upon which I worked on the Scheme and tried to progress
cases through it. Ultimately, I was not a POL representative and did not have
the power or authority to dictate POL’s position as a party to the Scheme and
mediations. I have reflected upon the period in August 2014 when Second
Sight issued their Part 2 report. I have set out in this statement my view that
the Part 2 report did not deliver what was needed for the Scheme’s cases at
that time, in terms of providing a clear evidential basis for the issues being
raised. I reiterate my comments earlier in this statement that this criticism is
not in relation to the factual basis of the issues themselves, but that the report
did not further or clarify the positions of either POL or any respective SPM; the
distance between the parties was not narrowed. The Part 2 report should have
resulted in POL obtaining the evidence base that would have facilitated
meaningful mediations. The Part 2 report released to applicants in August
2014 did not do that. At that point, in hindsight, I believe POL should have
commissioned altemative independent work in order to fill that evidential gap.
Proceeding to mediate cases from that point, in the absence of further
evidence which may have resulted in concessions by either mediating party,
feels like a missed opportunity. I sympathise with the SPMs who feel like their
cases were never going to be resolved through the Scheme. Notwithstanding
that reflection, I do not believe that I could have materially changed the course
POL was taking.
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287. Reflecting upon my involvement with the Scheme, if I had the benefit of the
knowledge I have now (i.e. that POL’s position that there were no systemic
issues was untrue) I would have escalated it with the PA management team
(through our standard processes) and advised that it was no longer an
assignment that we could legitimately participate in. I am comfortable that PA
would have supported me in that decision and any subsequent escalation.
288. The Inquiry has asked me to confirm if there is anything further, relevant to the
Inquiry’s terms of reference, of which I think the Chair of the Inquiry should be
aware, or any other matter that I wish to bring to the attention of the Chair. I
confirm that there is nothing further and I hope that this statement is of
assistance to the Chair.
Statement of Truth
I believe the content of this statement to be true
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Index to the First Witness Statement of David Oliver
WITNO9780100
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No.
URN
Document Description
Control number
POL00040076
Key Themes Emerging out of the applications
to the scheme
POL-0036558
POL00021872
Email from Andy Holt to Andrew Parsons re:
New Requests (Bates - freedom of
information requests)
POL-0018351
RLITO000007
Appendix 2 - Summary of Bugs, Errors,
Defects - Judgment (No.6) "Horizon Issues"
to Bates & Ors v the Post Office Ltd (No 6:
Horizon Issues) (Rev 1) [2019] EWHC 3408
(QB) (16 December 2019) (Horizon Issues
Judgment)
RLITO000007
POL00105529
Legally privileged initial complaint and
mediation scheme review by Chris Aujard
POL-0105096
POL00108424
Email from Andrew Parsons to Belinda
Crowe, Angela Van-Den-Bogerd and others
re: Post Office Mediation Claims. [BD-
4A.FID20472253]
POL-0106524
POL00029710
Email from Andrew Winn to Alan Lusher re:
Rivenhall
POL-0026192
POL00138077
Post Office; Initial Complaint Review and
Mediation Scheme Programme Board Slides
POL-BSFF-
0000313
POL00138101
Initial Complaints Review and Case
Mediation Scheme Programme Board.
POL-BSFF-
0000337
POL00108521
Email from Lesley J Sewell to Andy Holt,
Belinda Crowe, Chris Aujard and others re:
Requests to retain Fujitsu data
(CRO3170/ROM3170)
POL-0106618
10.
POL00021883
Email from Belinda Crowe to Dave Hulbert re:
Second Sight Part Two
POL-0018362
11.
POL00021870
Email from Andrew Parsons to Belinda
Crowe, Rodric Williams and Andrew
Pheasent and others re: Response to Second
Sight Part 2 report Final Draft (incorporating
ADVB DO and AP comments
POL-0018349
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URN
Document Description
Control number
POLO0116487
Email from Andrew Parsons to Belinda
Crowe, David Oliver, Rodric Williams and
others re Post Office Mediation Claims
POL-0115055
13.
POL00029707
Email from Andrew Parsons to Belinda
Crowe, Angela Van-Den-Bogerd, Andy Holt
and Rodric Williams and others, re: Post
Office Mediation Claims.
POL-0026189
14.
POL00116480
Appendix 1 - Credence data and Fujitsu
transaction logs for Lepton SPSO 191320
POL-0115048
15.
POL00116486
Horizon Spot review, response, SRO1 Debit
cards - cash withdrawals and GIRO
payments.
POL-0115054
16.
POL00108439
Email from Andrew Parsons to Rodric
Williams, Belinda Crowe and others, RE: Post
Office Mediation Claims "Lepton Report"
POL-0106538
17.
FUJ00086811
Horizon data, Lepton SPSO 191320, Draft
Report by Helen Rose
POINQ0092982F
18.
POL00020634
Email chain from Andrew Parsons to Chris
Aujard, Rodric Williams, Jarnail Singh and
others re: Helen Rose Report and CQRs re
Gareth Jenkins report
POL-0013826
19.
POLO0099063
Signed Interim Report into alleged problems
with the Horizon system
POL-0098646
20.
POLO0113111
Email chain from Sharron L Jennings to
Martin Smith re: Prosecution of Philip
Dauncey. ®This also contains attachments of
Case Note Entries
POL-0110499
21.
POL00006798
Legal advice on the use of expert evidence
POL-0017590
22.
POL00123148
Email chain from Sophie Bialaszewski to
Jarnail Singh cc David Oliver, Rodric Williams
and others RE: Post Office Ltd /Abbas & Daw
- 41459 - Selsey Road - POLTD/1314/0014
[BD-4A.F1D20472253]
POL-0129353
23.
POL00123147
Email from Jarnail Singh to David Oliver cc
Rodric Williams RE: briefing on Cartwright
King review work
POL-0129352
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URN
Document Description
Control number
POL00108247
Advice on Evidence Report for Philip
Dauncey. Advice by Harry Bowyer
(Cartwright King)
POL-0106372
25.
POL00127601
Email chain from Jarnail Singh to Kathryn
Alexander, cc'd Shirley Hailstones, Belinda
Crowe and others re Mediation Applicants'
Criminal Files.
POL-0134366
26.
POL00112974
Project Magellan- Generic Disclosure Review
- Schedule of Extracts Of Disclosable
Material
POL-0110369
27.
POLO00116944
Email from Jarnail Singh to David Oliver,
Rodric Williams, Belinda Crowe and others
re: RE: Rt Hon James Arbuthnot MP letter
POL-0117793
28.
POL00021750
Email from Andrew Parsons to Rodric
Williams, re: FW, Disclosure query
POL-0018229
29.
POL00040254
Email chain between Gavin Matthews, Rodric
Williams, Andrew Parsons and others RE: ,
Advice from Brian Altman QC on Suggested
Approach to Criminal Case Mediation
POL-0036736
30.
POL00074348
Email from David Oliver to Christa Band RE
Documents email four - Case M001
POL-0070911
31.
POL00021989
Email from David Oliver to Christa Band re:
Mediation Scheme-confidential and privileged
POL-0018468
32.
POL00027696
Email from David Oliver to Paula Vennells
RE: Scope for Linklaters work
POL-0024337
33.
POL00021991
Email from David Oliver to Johnathan Swil re:
Advice for Linklaters
POL-0018470
34.
POL00022083
Email from David Oliver to Jonathon Swil,
Chris Aujard and Belinda Crowe and others,
RE Draft report
POL-0018562
35.
POL00022116
Email from Belinda Crowe to Rodric Williams
regarding plans going forwards
POL-0018595
36.
POL00022093
Outline of points produced by Linklaters to
explain Horizon and form a basis for a report
to respond to public criticism and individual
complaints by SPMs.
POL-0018572
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URN
Document Description
Control number
POL00022117
Preliminary Note on the Future of the
Mediation Scheme - Post Office Limited
POL-0018596
38.
POL00116523
Email from Mark Davies to Belinda Crowe,
Chris Aujard, Sophie Bialaszewski, and
others, Re: 2014 01 22 Initial Complaint
Review and Mediation Scheme Briefing
POL-0114594
39.
POL00116524
The Post Office and the Horizon System -
POL-0114595
40.
POL00116548
Email chain David Oliver to Mark R Davies,
Sophie Bialaszewski cc Jane Hill RE:
Correspondence for review (for Paula)
POL-0117476
41.
POL00127347
Email chain from Sophie Bialaszewski to
Melaine Corfield, Rodric Williams, Matthew
Fielden cc Belinda Crowe, David Oliver RE:
Linklaters advice re potential format for the
Horizon Computer system report
POL-0132889
42.
POL00006557
Email re Project Sparrow
POL-0017651
43.
POL00022208
Email from Jonathan Swil to Belinda Crowe,
Melanie Corfield, Rodric Williams and others
regarding Version 4 of part 2 response
POL-0018687
44.
POL00021800
Email from Belinda Crowe to David Oliver,
Melanie Corfield and Andrew Parsons RE:
Fwd: Second Sight's Draft Part Two Report
POL-0018279
45.
POL00022227
Email chain from Melanie Corfield to
Jonathan Swil, Belinda Crowe, David Oliver
and other regarding examples for letter to SS
POL-0018706
46.
POL00022231
Email chain between Jonathan Swill, Belinda
Crowe, Chris Aujard and others, regarding a
letter to Second Sight re quality of work.
POL-0018710
47.
POL00105528
Project Sparrow Subcommittee ToR and
discussion documents: Options for the future
of the Scheme; Update on Horizon
Assurance Work; public statements made re
ICMRS and overview of ICRMS.
POL-0105095
48.
POLO0006565
Project Sparrow Sub-Committee Minutes
POL-0017844
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Document Description
Control number
POLO0116502
Email chain between Sophie Bialaszewski,
David Oliver, Belinda Crowe and others - Re:
Project Sparrow Sub-Committee - POL Initial
Complaints Review and Mediation Ministerial
Commitments
POL-0114592
50.
POL00028062
Report: Horizon Desktop Review of
Assurance Sources and Key Control
Features - draft for discussion, Deloitte
POL-0023065
51.
POL00116578
Email chain from Ruth X Baker to Mark R
Davies, Belinda Crowe cc Nina Arnott and
others Re: Continue but refine
POL-0114598
52.
WITNO9780101
POL APRIL invoice cover letter v2.docx
WITNO9780101
53.
POL00030694
Note on resources for Project Sparrow
POL-0027176
54.
POL00027482
Post Office Limited - Board Paper - Project
Sparrow Update by Chris Aujard
POL-0024123
55.
POL00099977
Minutes for meeting on 27 November re:
Costs, Second Sight
POL-0099560
56.
POL00100003
Post Office Limited, PROJECT SPARROW -
UPDATE, 2013
POL-0099586
57.
POL00130507
Memo from Chris Aujard to POL Board, cc'd
ExCo re: Project Sparrow Update
POL-0124097
58.
POL00116277
Email from Belinda Crowe to Martin Edwards
re Sparrow.
POL-0117270
59.
POL00108430
Email from Paula Vennells to Theresa Iles re:
Sparrow Sub-Committee
POL-0110986
60.
POLO00116576
Email chain from Mark R Davies to Belinda
Crowe, Paula Vennells, Chris Aujard and
others re: Sparrow s/c
POL-0117504
61.
POL00116579
Email from Mark R Davies to David Oliver,
Sophie Bialaszewski, Belinda Crowe and
others, Re: AP Slide Deck Comms Lines
POL-0114599
62.
POL00116580
PowerPoint Presentation: Communication
Key Messages
POL-0114600
63.
POL00006571
Project Sparrow Sub-Committee Minutes 6
June 2014
POL-0017847
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URN
Document Description
Control number
UKGI00002375
Email chain from Richard Callard to Peter
Batten re: FW: Board Papers
UKGI013189-
001
65.
POL00096576
Post Office Limited: Proposal to carry out an
Independent Review of Past Fraud and Theft
Cases
POL-0096159
66.
POL00096615
Draft, Post Office Limited, Terms of
Reference: Proposal for an independent
review of the company's systems relating to
the occurrence of apparent shortfalls in
individual PO branch accounts
POL-0096198
67.
POL00117119
Email from Alwen Lyons to Angela-Van-
Bogerd, Simon Baker, Mike Granville and
others re Horizon TOR
POL-0117951
68.
POL00100123
Email from Sophie Bialaszewski to Paula
Vennells cc: Chris Aujard re: Second Sight
POL-0099706
69.
POL00100165
Email from David Oliver to Paula Vennells re
For 1130 Meeting - Mediation Scheme
POL-0099748
70.
POL00100166
Draft Engagement Letter from Chris Aujard
for POL to Second Sight RE: Initial Complaint
Review and Mediation Scheme
POL-0099749
71.
POL00100198
Email from David Oliver to Paula Vennells
RE: Second Sight and James Arbuthnot
POL-0099781
72.
POL00026743
Final Note by David Oliver of Meeting held on
28/01/2014 between Post Office and James
Arbuthnot MP
POL-0023384
73.
POL00116305
Email from Paula Vennells to Belinda Crowe,
David Oliver, Chris Aujard and others re.
Papers for tomorrow - our pre-meeting, and
meetings with Second Sight and Tony
Hooper.
POL-0117298
74.
POL00100322
Memorandum from Belinda Crowe to Paula
Vennells, and others, re: Briefing for the
meetings with Second Sight and Sir Anthony
Hooper on Monday 24 February.
POL-0099905
75.
POL00100323
Annotated Agenda, Meeting with Second
Sight on 24 February 2014.
POL-0099906
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URN
Document Description
Control number
POL00022146
Email from Belinda Crowe to Rodric Williams
regarding second sight side engagement
letter
POL-0018625
77.
POL00022148
Engagement letter in relation to the initial
complain review and mediation scheme
POL-0018627
78.
POL00022147
Engagement letter in relation to the Initial
Complaint Review & Mediation Scheme
POL-0018626
79.
POL00061744
Email chain from Belinda Crowe to Andrew
Parsons and Rodric Williams re: Email
retrieval [BD-4A.FID255887215]
POL-0058223
80.
POL00061304
Email chain from Rodric Williams to Chris
Aujard and Andrew Parsons cc Belinda
Crowe re: Access to legal files
POL-0057783
81.
POL00021937
Email from David Oliver to Ron Warmington
and lan Henderson re: Note on pensions and
allowances reintroduction fraud
POL-0018416
82.
POL00021933
Document responding to points raised by
Second Sight investigation. Initial Complaint
Review and Mediation Scheme ®Pensions
and Allowances "Reintroduction" Fraud
POL-0018412
83.
POL00022120
Overview of the initial complaint review and
mediation scheme.
POL-0018599
84.
POL00040074
Email from Nicky Mal to Chris Aujard, Fay
Healey, Belinda Crowe and others, RE: "The
Scheme Programme Board Papers."
POL-0036556
85.
POL00040077
Independent Resolution of future cases
policy- project brief
POL-0036559
86.
UKGI00002361
Initial Complaint Review and Mediation
Scheme Terms of Reference for the Working
Group
UKGI013175-
001
87.
POL00101350
Email chain from Nina Arnott to Piero
D'Agostin, David Oliver and others re: Radio
4 Transcription
POL-0100933
88.
POL00040075
Post Office Media Scenario Planning- Initial
Complaint Review and Mediation Scheme
Presentation
POL-0036557
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WITNO9780100
No. I URN Document Description Control number
89. I POLO0040078 I Initial Complaint Review and Mediation POL-0036560
Scheme Programme Board
90. I POL00138147 I Initial Complaints Review & Case Mediation POL-BSFF-
Scheme Programme Board 0000378
91. I POLO0100032 I Initial Complaints Review & Case Mediation POL-0099615
scheme Steering Group
92. I POLO0138167 I Initial Complaints Review & Case Mediation POL-BSFF-
Scheme Programme Board 0000396
93. I POLO0138176 I Initial Complaints Review & Case Mediation POL-BSFF-
Scheme Programme Board 0000405
94. I POL00138282 I Initial Complaints Review & Case Mediation POL-BSFF-
Scheme Programme Board 0000508
95. I POL00146797 I Post Office Executive Committee: Horizon - POL-BSFF-
Initial Complaint Review and Mediation 0005924
Scheme Settlement Policy
96. I POL00027505 I Initial Complaint Review and Mediation POL-0024146
Scheme - [Draft] Settlement Policy
97. I POLO0129110 I Email from Belinda Crowe to Chris Aujard, cc. I POL-0132847
David Oliver re: Initial Complaints and
Mediation Scheme - Settlement Policy.
98. I POLO0040201 I Email from Andrew Parsons to Belinda POL-0036683
Crowe, Angela Van Den Bogerd, Rodric
Williams etc, RE: M127- CRR response and
settlement analysis
99. I POLO0125093 I Email from Kathryn Alexander to Carole POL-0131093
Butler, Chris J Gilding and others re: M029
Report case summary.
100. I POL00040079_ I Email from Angela Van Den Bogerd to Claire I POL-0036561
Parmenter, Belinda Crowe cc Andrew
Parsons and others RE: Training Pack for
POL mediation attendees
101. I POL00040084 I Email from Nicky Mal to Belinda Crowe, Chris I POL-0036566
Aujard, Angela Van-Den-Bogerd, RE:
Remaining papers for the Scheme
Programme Board
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WITNO9780100
URN
Document Description
Control number
102.
POL00040082
Initial Complaint Review and Mediation
Scheme- Briefing to Post Office Attendees
POL-0036564
103.
POL00038682
Draft Paper for the Working Group on Delays
in Investigating Cases
POL-0027993
104.
POL00040182
Email from Andrew Parsons to David Oliver,
RE: FW: Mediation Pack v2
POL-0036664
105.
POL00040183
PO Initial Mediation Scheme Pack - Draft
POL-0036665
106.
UKGI00002395,
Email from David Oliver to Chris Aujard cc
Belinda Crowe, Angela Van Den Bogers and
others re Mrs Javinder Barang - Lower
Stondon Post Office - Late application to
scheme
UKGI013209-
001
107.
POL00061460
Peter Holmes case study: Email from Rodric
Williams to Harris Matthew, Angela Van-Den
Bogerd CC various others re M003 -
Holmes/Jesmond PO) - POL GC Approved
POL-0057939
108.
POL00116648
Email from David Oliver to Belinda Crowe,
Mark R Davies, Sophie Bialaszewski and
others re: Letter from M005 to PM.
POL-0117521
109.
POL00116649
Letter to David Cameron PM from Mrs
Jennifer O Dell ®Re: Mrs O'Dell's Second
Sight case
POL-0117522
110.
POL00021803
Email from Roderic Williams to Caroline
Culver re: Part 2 SS Report
POL-0018282
111.
POL00074651
Email from Belinda Crowe to Angela Van-
Den-Bogerd, Lena Hameed, Andrew Parsons
and others re MO33 IA/QA - Discusses early
settlement
POL-0071214
112.
POL00108764
Email chain from Angela Van-Den-Bogerd to
Andrew Parsons, Belinda Crowe, David
Oliver and others, RE: New CQRs
POL-0106842
113.
POL00061594
Email chain from Angela Van-Den-Bogerd to
Shirley Hailstones, Jonny Gribben, Matthew
Harris and others, RE: Updated Evidence
Files (Lynette Hutchings)
POL-0058073
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Document Description
Control number
114.
POL00021760
Email from Rodric Williams to Andrew
Parsons re: Applicants letter P2 (response to
Second Sight Report)
POL-0018239
115.
POL00124439
Email from Stephen Hocking to Rodric
Williams re: Escalation points for WG.
POL-0126742
116.
POLO00075691
Email from Patrick Bourke to Andrew
Parsons, cc'd Jessica Barker RE: Schduling
[BD-4A.F1D20472253]
POL-0072254
117.
POL00075679
Email from Patrick Bourke to Belinda Crowe
and Andrew Parsons cc: David Oliver re.
Schduling.
POL-0072242
118.
POL00027685
Email from Chris Aujard to Belinda Crowe,
David Oliver, Angela Van-Den-Bogerd and
others RE: The ARC meeting on Tuesday
POL-0024326
119.
POL00130509
Initial Complaint Review and Medication
Scheme Paper (to be provided shortly on
Egress)
POL-0124099
120.
POL00116348
Email from Neil Hayward to Belinda Crowe,
cc Paula Vennells, Chris Aujard and others re
Post Office Ltd Board - Mediation Scheme
Update March 2014 v3 following advice from
Linklaters
POL-0117341
121.
POL00116241
Briefing Note from Belinda Crowe to Paula
Vennells cc Chris Aujard, Hugh Flemington
‘and others' re: Briefing for your 1-2-1 with
Alice
POL-0117235
122.
POL00116240
Email from Belinda Crowe to Martin Edwards,
David Oliver, Chris Aujard and others RE:
Briefing for Paula's 1-2-1 with Alice
POL-0117234
123.
POLO0116562
Email chain from Martin Edwards to Belinda
Crowe, Mark R Davies and others®RE:
Sparrow: Draft Letters and Next steps
POL-0117490
124.
POL00108742
Email chain from Avene O'Farrell to Chris
Aujard cc Amanda A Brown re: FW: Printed
Re: Sparrow update paper
POL-0111004
125.
UKGI00002360
Email from Belinda Crowe to Alwen Lyons,
Alice Perkins, Alasdair Marnoch and Others
UKGI013174-
001
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WITNO9780100
ic
a
4
Document Description
Control number
RE Board Sparrow Subcommittee Papers -
Working Group Terms of Reference
126.
POL00026641
Initial Complaint Review and Mediation
Scheme - Working Group - Minutes - 30
January 2014
POL-0023282
127.
POL00026666
Working Group for the Initial Complaint
Review and Mediation Scheme (Key points
and actions from the conference call)
POL-0023307
128.
POL00026638
“Working Group for the Initial Complaint
Review and Case Mediation Scheme"
Amended Minutes of 03/01/2014
POL-0023279
129.
POL00026639
“Working Group for the Initial Complaint
Review and Case Mediation Scheme
Standing Agenda" for 16/01/2014.
POL-0023280
130.
POL00026640
Meeting Minutes for Working Group for the
Initial Complaint Review and Case Mediation
Scheme
POL-0023281
131.
POL00026635
Working Group for the Initial Complaint
Review and Case Mediation Scheme
Standing Agenda for Thursday Calls
POL-0023276
132.
POL00043626
Working Group for the Initial Complaint
Review and Case Mediation Scheme
POL-0040129
133.
POL00026636
Working Group for the Initial Complaint
Review and Case Mediation Scheme
Standing Agenda for 20/02/2014
POL-0023277
134.
POL00026637
"Working Group for the Initial Complaint
Review and Case Mediation Scheme
Standing Agenda" for 27/02/2014.
POL-0023278
135.
POLO0026656
Face to face meeting of the working group -
Initial complaint review and mediation
scheme- 7 March 2014
POL-0023297
136.
POL00026643
Working Group for the Initial Complaint
Review and Case Mediation Scheme
Standing Agenda for 13/03/2014
POL-0023284
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Control number
137.
POL00026642
Working Group for the Initial Complaint
Review and Case Mediation Scheme
Standing Agenda
POL-0023283
138.
POL00026644
Working Group for the Initial Complaint
Review and Case Mediation Scheme -
Minutes for 27/03/2014.
POL-0023285
139.
POL00026633
Initial Complaint and Mediation Scheme
Working Group Minutes of 01/04/2014.
POL-0023274
140.
POL00026652
Working Group for the Initial Complaint
Review and Case Mediation Scheme minute
dated 17/04/2014
POL-0023293
141.
POL00026653
Working Group for the Initial Complaint
Review and Case Mediation Scheme Minute
POL-0023294
142.
POL00026660
Working Group for the Initial Complaint
Review and Case Mediation Scheme Meeting
Minutes of 24/04/2014
POL-0023301
143.
POL00026663
Minute - Initial Complaint Review and
Mediation Scheme - Working Group 1 May
2014
POL-0023304
144.
POL00043627
Initial Complaint Review and Mediation
Scheme Working Group - Minute of meeting
dated 6 May 2014.
POL-0040130
145.
POL00026657
Working Group for the Initial Complaint
Review and Case Mediation Scheme -
Minutes of case conference call 15 May
2014.
POL-0023298
146.
POL00026659
Minute of Initial Complaint Review and
Mediation Scheme - Working Group 20 May
2014
POL-0023300
147.
POL00026667
Meeting Minutes for the Working Group for
the Initial Complaint Review and Case
Mediation Scheme
POL-0023308
148.
POL00026668
Working Group for the Initial Complaint
Review and Case Mediation Scheme -
Working Group Minute - 5th June
POL-0023309
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Control number
149.
POL00026664
Working Group for the Initial Complaint
Review and Case Mediation Scheme Meeting
Minutes - 12th June.
POL-0023305
150.
POL00026673
Minute - Initial Complaint Review and
Mediation Scheme - Working Group 16 June
2014
POL-0023314
151.
POL00026665
Working Group for the Initial Complaint
Review and Case Mediation Scheme -
Minute of Working Group Call 26 June 2014.
POL-0023306
152.
POL00026672
Minute - Working Group for the Initial
Complaint Review and Case Mediation
Scheme - 10th July 2014
POL-0023313
153.
POL00026671
Working Group for the Initial Complaint
Review and Case Mediation Scheme -
Minutes of the Working Group Call 17 July
2014
POL-0023312
154.
POL00026683
Working Group for the Initial Complaint
Review and Case Mediation Scheme Meeting
Minutes of 24 July 2014
POL-0023324
155.
POL00026674
Minute - Working Group for the Initial
Complaint Review and Case Mediation
Scheme - 31st July 2014
POL-0023315
156.
POL00026676
Minute - Working Group for the Initial
Complaint Review and Case Mediation
Scheme - 28 August 2014
POL-0023317
157.
POL00026679
Working Group for the Initial Complaint
Review and Case Mediation Scheme -
Meeting Minutes (04/09/14).
POL-0023320
158.
POL00026680
Minutes - Working Group for the Initial
Complaint Review and Mediation Scheme -
11 September 2014
POL-0023321
159.
POL00026685
Working Group for the Initial Complaint
Review and Case Mediation Scheme Meeting
Minutes - 16.09.14.
POL-0023326
160.
POL00043628
Standing Agenda for Thursdays calls -
Working Group for the Initial Complaint
Review and Case Mediation Scheme
(25/09/14).
POL-0040131
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Control number
161.
POL00026684
Minute - Working Group for the Initial
Complaint Review and Case Mediation
Scheme - 02 October 2014
POL-0023325
162.
POL00040144
Email from David Oliver to Andrew Parsons,
RE: As discussed.
POL-0036626
163.
POL00040146
Working Group Briefing Note 30 April
POL-0036628
164.
POL00040151
Email from David Oliver to Andrew Parsons,
RE: Briefing Note
POL-0036633
165.
POL00040152
Working Group 30 April Briefing Note
POL-0036634
166.
POL00040153
Email from David Oliver to Chris Aujard,
Belinda Crowe, RE: Working Group 30 April
Briefing Note
POL-0036635
167.
POL00040154
Post Office Briefing Note, Working Group
POL-0036636
168.
POL00101297
Email from Belinda Crowe to Mark R Davies,
Belinda Crowe, Melanie Corfield and others
re: FW: E-mail to Working Group
POL-0100880
169.
POL00040282
Email from Tom Wechsler to Chris Aujard,
Rodric Williams, Andrew Parsons and others,
RE: Briefing Note Working Group
POL-0036764
170.
POL00108268
Email from Belinda Crowe to Theresa lles,
Amanda A Brown, cc Martin Edwards and
others re Meeting between Paula and Sir
Anthony Hooper about progress on the
Mediation Scheme the Working Group
POL-0110967
171.
POL00100324
Annotated Agenda, Sir Anthony Hooper.
POL-0099907
172.
POL00002329
Email chain between Chris Holyoak, Ron
Warmington, lan Henderson and others re:
the draft letters to Aver and Howe and Co
VIS00003343
173.
POLO00116536
Email chain from Mark R Davies to David
Oliver, Sophie Bialaszewski and Belinda
Crowe re: JA Handling Plan (to be provided
shortly on Egress)
POL-0114597
174.
POL00116544
Email from Paula Vennells to Martin
Edwards. Re: Letter from Tony Hooper to
Jenny Willott
POL-0117472
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Control number
175.
POL00108528
Email from David Oliver to Anthony Hooper,
Amanda A Brown, Theresa Iles, and Sarah
Paddison re Meeting with Paula and Chris
POL-0110989
176.
POL00021844
Email from Andrew Parsons to Belinda Crowe
and Chris Aujard re: Mediation for M)22 and
M127
POL-0018323
177.
POL00101053
Email from Belinda Crowe to Sophie
Bialaszewski, Mark R Davis, Chris Arnold and
others re: FW Post Office - proposed July
meeting
POL-0100636
178.
POL00040221
Email from Andrew Parsons to Belinda Crowe
and David Oliver, RE: "letter to Tony re Part
2"
POL-0036703
179.
POL00040233
Email from Rodric Williams to David Oliver,
Andrew Parsons, Belinda Crowe, RE: Email
to Tony
POL-0036715
180.
POL00075193
Email from Chris Lucy Overhill to Chris
Aujard CC David Oliver, Belinda Crowe and
Others RE: Letter from chair M001, M002,
M019, M035, M052, M066, M079 & M143
POL-0071756
181.
POL00065213
Letter from Sir Anthony Cooper (Working
Group) to Chris Aujard Re Initial complaint
review and mediation scheme part two report
POL-0061692
182.
POL00101305
Email from Belinda Crowe to Paula Vennells,
Chris Aujard, David Oliver and others re: Re:
Sparrow update
POL-0100888
183.
POL00040263
Email from Georgia Barker to Chris Aujard,
Re: Letter from Chair-Mo17&MO21
POL-0036745
184.
POL00040264
Letter from Sir Anthony Hooper to Mr. Aujard,
Initial Complaint Review and Mediation
Scheme ("the Scheme"): Case M017
POL-0036746
185.
POL00040265
Post Office Mediation
Scheme®DRAFT®Second Sight - Case
Review Report(Baljit Singh SETHI)
POL-0036747
186.
POL00040266
Letter from Sir Anthony Hooper to Mr. Aujard,
RE: Initial Complaint Review and Mediation
Scheme (Case M021)
POL-0036748
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Document Description
Control number
187.
POL00040267
Post Office Mediation
Scheme®DRAFT®Second Sight - Case
Review Report(Sunil Khanna)
POL-0036749
188.
POL00136853
Email from Georgia Barker to Chris Aujard cc:
Belinda Crowe, David Oliver and others. RE:
Letter from Chair- M065
POL-0125406
189.
POL00116500
Email from David Oliver to Chris Aujard, Chris
Day, Neil Hayward and others RE: meeting of
ExCo Sub Committee
POL-0117434
190.
POL00116501
Letter from PV to Alan Bates re: response to
letter to minister for postal and regulatory
affairs
POL-0117435
191.
POL00116507
Email chain from Sophie Bialaszewski to
Jane Hill, Nina Arnott and Mark R Davies Re:
FW: Letter form the Minister for Employment
Relations and Consumer Affairs
POL-0117439
192.
POLO0116521
Email from Belinda Crowe to Mark R Davies,
Paula Vennells, Martin Edwards and others
re: Alan Bates Letter.
POL-0117453
193.
POL00040145
Letter from Alan Bates to Jo Swinson, RE:
Justice for SPMs Alliance
POL-0036627
194.
POL00006554
Email from Andrew Parsons re SS Report
POL-0017648
195.
POLO0006555
Draft Report on Branch Operating
Procedures Prepared by SS
POL-0017649
196.
POL00004439
Initial Complaint Review and Mediation
Scheme - Briefing Report - Part One -
Prepared by Second Sight
VIS00005507
197.
POLO0006552
Email from Andy Parsons re Draft SS
Thematic Report
POL-0017646
198.
POL00006553
Draft Thematic Issues Report
POL-0017647
199.
POL00100479
Email from David Oliver to Paula Vennells re
Partial draft thematic report
POL-0100062
200.
POL00021934
Email from Ron Warmington to Angela Van
Den Bogerd, Belinda Crowe and Chris
Holyoak re: Second Sight Briefing Report
Part Two
POL-0018413
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Document Description
Control number
POL00021909
Email from Sarah Haywood to Andrew
Parsons, CC Angela Van-Den-Bogerd, Phil
Bowdery and Mark Wood, re: Second Sight
Briefing Report - Part two
POL-0018388
202.
POL00022149
Email from Belinda Crowe to Andrew
Parsons, Angela Van Dan Bogerd and others
regarding Second sight part two report
POL-0018628
203.
POL00132931
Email from Belinda Crowe to Jessica Madron,
cc Piero D'Agostino, Chris Aujard and others
- RE: Part 2 Report - 5 August 2014 DRAFT
POL-0136268
204.
POL00021916
Email from David Oliver to Belinda Crowe,
Andrew Parsons and Matther Fielden re: I will
print hard copies.
POL-0018395
205.
POL00040210
Email from Andrew Parsons to Belinda
Crowe, David Oliver, RE: Part 2 Appendix-
letter to second sight re Part 2 Preliminary
Comments
POL-0036692
206.
POL00021904
Email from David Oliver to Angela Van Den
Bogerd, Jessica Madron, Andrew Parsons
and others re: DRAFT Letter to Second Sight
re Part 2 Preliminary Comments
POL-0018383
207.
POL00022212
Email from David Oliver to Jonathan Swil and
Belinda Crowe regarding the draft letter to
second sight re part 2 preliminary comments
12082014
POL-0018691
208.
POL00021866
Email chain between Belinda Crowe, Ron
Warmington, lan Henderson and others, re:
Second Sight's Draft Report Part Two Report.
POL-0018345
209.
POL00040491
Second Sight's Draft Part Two Mediation
Briefing Report
POL-0036973
210.
POL00021954
Initial Complaint Review and Mediation
Scheme BRIEFING REPORT - PART TWO
PREPARED BY SECOND SIGHT@®(Draft)
POL-0018433
211.
POL00021953
Email from Andrew Parsons to Angela Van-
Den-Bogerd, Rodric Wiliams, Belinda Crowe
and David Oliver re: Part 2 Report
POL-0018432
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Document Description
Control number
212.
POL00021922
Email chain between Andrew Parsons, David
Oliver, Belinda Crowe, Melaine Corfield and
others re: Responding to the Part Two Report
POL-0018401
213.
POL00123336
Email from Rob King to Andy Hayward cc
Dave Posnett re Second Sight Part Two
Report.
POL-0129535
214.
POL00021773
Email chain between Paul Inwood, Belinda
Crowe, Dave Hulbert and others re: Second
Sight Part Two.
POL-0018252
215.
POL00021886
Email from Kim Abbotts to Andrew Pheasant
re: Second SIGHT Part Two
POL-0018365
216.
POL00132933
Email from Belinda Crowe to Angela Van-
Den-Bogerd, Andrew Parsons, Rodric
Williams and others, RE: Latest Draft POL
Letter to SS Part Two Recipients
POL-0136270
217.
POL00027113
Email from Belinda Crowe to Angela van den
bogerd and others RE Message from Angela
Van Den Bogerd
POL-0023754
218.
POL00040252
Email from Parsons Andrew to David Oliver,
Draft Logic Njote-Part Two Report
POL-0036734
219.
POL00040253
LOGIC NOTE re: Circulation of the second
sight part two report.
POL-0036735
220.
POL00021763
Email from Andrew Pheasent to Rod Ismay
re: Second Sight Part Two - ATM and other
bits of sections 2
POL-0018242
221.
POL00022240
Email from Belinda Crowe to Chris Aujard
regarding second sight part two - introductory
section
POL-0018719
222.
POL00148981
Email chain from David Oliver ®To: Andrew
Parsons CC Angela Van-Den-Bogerd and
Melanie Corfield Re Response to Second
Sight Part 2 report DO comments +
Brunswick comments
POL-BSFF-
0008101
223.
POL00148982
Draft response to Second Sight's initial
complaint review and mediation scheme
briefing report part 2
POL-BSFF-
0008102
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Control number
224.
POL00100134
Meeting with Alice Perkins, Paula Vennells
and David Oliver
POL-0099717
225.
POL00116250
Email chain from David Oliver to Martin
Edwards, Belinda Crowe and Chris Aujard re.
Draft note for Paula.
POL-0117244
226.
POL00100200
Letter from David Oliver to Paula Vennells,
RE: Second Sight.
POL-0099783
227.
POL00116255
Email from Mark Davies to David Oliver re
Second Sight and James Arbuthnot.
POL-0117249
228.
POL00116276
Success Criteria Document - SS
POL-0117269
229.
POL00116270
Email from Martin Edwards to Paula Vennells
re David's Sparrow Note which relates to
Second Sight's engagement
POL-0117263
230.
POLO0116279
Email chain from Martin Edwards to Belinda
Crowe, David Oliver, Amanda A Brown ‘and
others' re: Next Monday ExCo
POL-0117272
231.
POL00074462
Email from Andrew Parsons to Chris Aujard,
Rodric Williams, David Oliver, and others re:
M001 - Initial Thoughts [BD-
4A.FID25886824] - Second Sight Report
POL-0071025
232.
POL00108377
Email from Belinda Crowe to Sarah Paddison
RE URGENT: Sparrow Update
POL-0110979
233.
POL00040290
File Note from Second Sight meeting with
POL. Records discussions including work
rate and cost per case.
POL-0036772
234.
POL00038633
Draft note from Chris Aujard (GC) to Post
Office Board Ltd
POL-0027944
235.
POL00100136
Email thread from Paula Vennells to Alice
Perkins re: Further Briefing Tomorrow
POL-0099719
236.
POL00040062
Email from Andrew Parsons to Hugh
Flemington, RE: Re-drafted draft
prosecutions paper
POL-0036544
237.
POL00027760
Email from Chris M Day to Alwen Lyons,
Chris Aujard, Fay Healey and others re
Prosecution Policy Paper
POL-0024401
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Document Description
Control number
238.
POL00123176
Email from John Scott to Sophie
Bialaszewski, Belinda Crowe, David Oliver
and others re: Investigation Review Meeting -
Criminal Investigations Policies and
Guidance
POL-0129381
239.
POL00021424
Post Office Limited Audit, Risk and
Compliance Sub Committee Minutes of
11/02/2014
POL-0018054
240.
POL00030716
Post Office Audit, Risk and Compliance
Committee, Prosecutions Policy Appendix A,
Chris Aujard, February 2014
POL-0027198
241.
POL00116258
Email chain from Belinda Crowe to David
Oliver, Chris Aujard, Martin Edwards and
Mark Davies Re: URGENT Prosecutions
policy and MPs meeting etc.
POL-0117251
242.
POL00027754
Email from Alwen Lyons to Chris Aujard,
Chris M Day, Kevin Gilliland and others re
Draft Prosecution Paper for the Board
POL-0024395
243.
POL00027755
POL Board Paper - Review of the Current
Prosecution Policy - Chris Aujard.
POL-0024396
244.
POL00038644
Note from Chris Aujard to POL Board re-PO
Prosecution Policy
POL-0027955
245.
POL00027451
POL Board: Review of the Current
Prosecution Policy, version February 2014
POL-0024092
246.
POL00123322
Email chain from Victoria Brooks to Dave
Posnett, Belinda Crowe, Andrew Parsons
and others®re: Pensions & Allowances
‘Reintroduction’ Fraud - Confidential [BD-
4A.FID20472253]
POL-0129521
247.
POL00040056
Email from Sophie Bialaszewski to Ruth
Barker, Belinda Crowe, David Oliver etc, RE:
Initial Complaint Review and Mediation
Scheme QA SB Comments 06.01.2013
POL-0036538
248.
POL00044356
Email from Jarnail Singh to Martin Smith, RE:
bulletpoints on the evidence in R v. Misra
POL-0040835
249.
POL00101295
Email from Cathal Wogan to Belinda Crowe,
Mark R Davies, Carmel McCarthy and others
re: RE: Request for an Interview
POL-0100878
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Control number
250.
POL00101316
Email from Mark Davies to David Oliver,
Chris Aujard and Gavin Lambert re: FW: You
& Yours
POL-0100899
251.
POL00101361
Email from Angela-Van-Den-Bogerd, to
Richard Weaver, Mark Davies and others re:
The news
POL-0100944
252.
POL00101362
Email from Mark Davies to Bryan Hewson re:
The news
POL-0100945
253.
POL00108232
Email from Martin Edwards to Theresa Iles
and Sarah Paddison re Briefing pack for the
meeting with James Arbuthnot
POL-0110960
254.
POL00100124
Letter from Belinda Crowe to Chairman and
Chief Executive, Post Office Limited cc: Chris
Aujard RE: Briefing for Meeting with RT Hon
James Arbuthnot MP
POL-0099707
255.
POL00100126
Email from David Oliver to Alice Perkins,
Jorja Preston, Paula Vennells cc: Theresa
Lies, Marin Edwards, Sarah Paddison re:
Meeting with JA Tomorrow attachment:
Agenda for JA Meeting
POL-0099709
256.
POL00100128
Email from David Oliver to Alice Perkins,
Jorja Preston, Paula Vennells cc: Theresa
LLes, Martin Edwards, Sarah Paddison and
others re: Meeting with JA Tomorrow re:
Agenda for JA Meeting pdf
POL-0099711
257.
POL00100144
Email chain from Alice Perkins to David
Oliver and Paula Vennells re: Further Briefing
for Tomorrow
POL-0099727
258.
POL00116246
Agenda for the meeting between Alice
Perkins, Paula Vennells and David Oliver
POL-0117240
259.
POL00116247
Letter from Chris Aujard (General Counsel) to
Chair and Chief Executive Post Office
Limited; Re: Further Briefing for James
Arbuthnot Meeting
POL-0117241
260.
POL00100142
Email from Chris Aujard to Angela Van-Den-
Bogerd cc: Paula Vennells re: URGENT
POL-0099725
261.
POL00100141
Email thread from Martin Edwards to Paula
Vennells re: Further briefing for tomorrow
POL-0099724
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WITNO9780100
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Document Description
Control number
262.
POL00100203
Email from David Oliver to Janet Walker, RE:
Post Office-proposed meeting
POL-0099786
263.
POL00108257
Email from Martin Edwards to Paula Vennells
and Theresa Iles cc: Sarah Paddison re Post
Office - proposed meeting
POL-0110963
264.
POL00100191
Email from David Oliver to Paula Vennells,
RE: MP's meeting
POL-0099774
265.
POL00108351
Email from Louise Chatfield To Theresa Lies
RE Urgent James Arbuthnot MP's meeting
POL-0110974
266.
POL00100210
Email from Belinda Crowe to Alice Perkins,
RE: Next steps following meeting with James
Arbuthnot
POL-0099793
267.
POL00100226
Email from David Oliver to Martin Edwards,
Mark R Davies RE: FW: Draft Meeting note
and letter
POL-0099809
268.
POL00100254
Email from David Oliver to Belinda Crowe,
Sophie Bialaszweski, RE: FW: Post office
update meeting, Monday 24 March at 5:45pm
POL-0099837
269.
POL00077180
Email from Belinda Crowe to Mark R Davies,
Chris Aujard, Rodric Williams and others re:
FW: MPs - forwarding note to MPs issued in
2014
POL-0073743
270.
POL00116325
Email to Belinda Crowe, Mark R Davies, Jane
Hill and others from Sophie Bialaszewski Re:
Briefing note for Paula (to go to Alice
Monday)
POL-0117318
271.
POL00108341
Email from David Oliver to Belinda Crowe RE
Phone Call between James and Paula
POL-0110972
272.
POL00116340
Email from David Oliver to Mark R Davies,
Martin Edwards, Chris Aujard and others re:
Note for PV call with JA 18032014.docx
POL-0117333
273.
POL00130527
Email from Sophie Bialaszewski to David
Oliver, Belinda Crowe re Briefing Paper for
Paula
POL-0124108
274.
POLO00116344
Email from David Oliver to Martin Edwards,
Theresa Iles, Sarah Paddison and others re:
Note for PV call with JA 18032014 Final.
POL-0117337
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275.
POL00108346
Letter from David Oliver to Paula Vennells
RE Note for call with James Arbuthnot - 18
March
POL-0110973
276.
POL00100445
Email from David Oliver to Janet Walker re.
draft email and prep for 24th
POL-0100028
277.
POL00116353
Email chain from Belinda Crowe to Martin
Edwards, Mark R Davies and Chris
Aujard®RE: James Arbuthnot
POL-0117346
278.
POLO00116356
Email chain from Belinda Crowe to Mark R
Davies, Martin Edwards, David Oliver and
others RE: James Arbuthnot
POL-0117349
279.
POL00116351
Email from Sophie Bialaszewski to Mark R
Davies, Belinda Crowe cc: David Oliver re:
Briefing with POAC MP names
POL-0117344
280.
POL00116367
Email from Mark R Davies to Paula Vennells
cc Martin Edwards, Chris Aujard 'and others'
re: MPs Meeting
POL-0117360
281.
POL00116381
Email chain with Belinda Crowe, Paula
Vennells, Chris Aujard and others - Re: Draft
approved by James for MPs' Meeting
POL-0117374
282.
POL00116334
Draft Briefing for POL Chairman and Paula
Vennells, for Meeting with James Arbuthnot,
MPs, JFSA and Second Sight - Version 6
POL-0117327
283.
POLO0116382
Email from Sophie Bialaszewski to Mark R
Davies and Ruth X Barker re: response to
Priti Patel's letter by Paula Vennells
POL-0117375
284.
POL00027700
Email from Mark R Davies to Paula Vennells,
Martin Edwards, David Oliver and others RE:
Questions about the briefing
POL-0024341
285.
POL00116407
Email from Chris Aujard to Mark R Davies,
David Oliver, Angela Van-Den-Bogerd and
others re Confidential - MP Meeting
POL-0117391
286.
POL00116413
Email from Theresa Iles to Martin Edwards,
Chris Aujard, David Oliver 'and other' re: FW:
James Arbuthnot MP Letter 310314
POL-0117397
287.
POL00100506
Email from Belinda Crowe to Paula Vennells
re: Letter to James Arbuthnot v2
POL-0100089
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288.
POL00116436
Email from Paula Vennells to Mark R Davies,
Belinda Crowe, Chris Aujard ‘and others' -
Re: JA Response
POL-0117420
289.
POL00025801
Post Office Limited Board Sub Committee -
Initial Complaints Review and Mediation
scheme Ministerial Commitments
POL-0022280
290.
POL00116530
Email from Louise Chatfield to Mark Davies
cc Sophie Bialaszewski re James Arbuthnot
letter
POL-0117460
291.
POL00116531
Email chain from Mark R Davies to David
Oliver, Sophie Bialaszewski, Mark R Davie
and others re James Arbuthnot Letter
POL-0117461
292.
POL00116549
Draft letter from Paula Vennells to Ms Willott
re response to letter and letter from Alan
Bates - Operational concerns
POL-0117477
293.
POL00116550
Draft letter from Paula Vennells to James
Arbuthnot re Initial Complaint Review and
Mediation Scheme - Interim report, progress
to date, Alan Bates' letter
POL-0117478
294.
POL00116551
Email from Martin Edwards to Belinda Crowe,
David Oliver1, Mark R Davies, cc Chris
Aujard re updated letters to James Arbuthnot
and Ms Willott
POL-0117479
295.
POLO0116552
Letter from PV to Ms Willott re Alan Bates.
POL-0117480
296.
POL00116553
Draft Letter To James Arbuthnot
POL-0117481
297.
POLO0116563
Draft Letter to James Arbuthnot re the
Mediation Scheme and MPs involvement.
POL-0117491
298.
POL00100737
Email from Belinda Crowe to David Oliver,
Sophie Bialaszewski, Letter from James
Arbuthnot MP
POL-0100320
299.
POL00100695
Letter from James Arbuthnot to Paula
Vennells, Mediation process case review
POL-0100278
300.
POL00131522
Email from Matthew Fielden to Rodric
Williams, Cc David Oliver re Ministerial
Commitments & Working Group ToR etc.
POL-0121343
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Control number
POL00131534
TOR - Ministerial Commitments, Detail of
scheme as published, Working group ToR
(not published), Journey to the WG and
Scheme,
POL-0121355
302.
POL00116584
Email from David Oliver to Chris Aujard and
Mark Davies, RE: Signed copy of James
Arbuthnot Letter
POL-0117509
303.
POL00100891
Email sent from Melanie Corfield to Belinda
Crowe, Sophie Bialaszewski and others re :
Draft note to Mps
POL-0100474
304.
POLO00116593
Email from Belinda Crowe to Avene O'Farrell,
Chris Aujard, Mark R Davies and others re
Draft note to MPs
POL-0117518
305.
POL00116661
Email from Chris Aujard to Sophie
Bialaszewski, Belinda Crowe, Avene O'Farrell
and others re urgent letter from James
Arbuthnot.
POL-0117534
306.
POLO0116668
Email from Mark R Davies to Belinda Crowe,
Martin Edwards, Melanie Corfield and others
Re: Urgent; Letter from James Arbuthnot,
POL draft response
POL-0117541
307.
POL00116679
Email from Belinda Crowe to Sophie
Bialaszewski, Martin Edwards, Avene
O'Farrell and others RE: Draft email from
James Arbuthnot to MPs
POL-0117552
308.
POL00101054
Email from Martin Edwards to Paula
Vennells, Belinda Crowe, Sophie
Bialaszewski and others re: FW Draft email
from James Arbuthnot to MPs
POL-0100637
309.
POL00109115
Email chain from Avene O'Farrell to David
Oliver re: Rt Hon James Arbuthnot MP
letter®
POL-0111027
310.
POL00109203
Email from Avene O'Farrell to David Oliver
and Tom Wechlser re: Letter for James
Arbuthnot
POL-0111031
311.
POL00109204
Letter from Paula Vennells to Rt Hon James
Arbuthnot MP re: Working Group Meetings.
POL-0111032
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No. I URN Document Description Control number
312. I POLO0105556 I Email from Tom Wechsler to Samikah POL-0105123
Ahmed, Re: Subject Mediation Scheme
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