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Witness Name: Sophie Louise Underwood
Statement No.: WITN09820100
Dated: 12 November 2024.
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF SOPHIE LOUISE UNDERWOOD
I, Sophie Louise Underwood, will say as follows:
Introduction
1. 1am a former employee of Post Office Ltd (“POL”) and held the position of Public Affairs
Manager between 2 April 2013 and 22 July 2014. During my employment at POL, I was
known by my maiden name, Sophie Bialaszewski.
2. This witness statement has been prepared in response to a request made by the Post
Office Horizon IT Inquiry (the “Inquiry”) pursuant to Rule 9 of the Inquiry Rules, dated
10 October 2024 (the “Request’). The facts in this witness statement are true, complete
and accurate to the best of my knowledge and belief.
3. I left POL over ten years ago and worked there for just over a year. Because of the time
that has elapsed, I do not recall the details of all of the meetings I attended, documents I
worked on, or emails I sent during my time at POL. That said, I have studied the
documents provided to me by the Inquiry. The Request identified 29 questions to be
addressed and I have done soto the best of my ability in this statement.
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4. I have been assisted in preparing this witness statement by my legal representatives
Farrer & Co LLP.
Background
5. I have been asked to set out a summary of my career and qualificationsprior to joining
POL. I have had a varied career working in a number of different sectors, mainly with a
focus on digital skills and business transformation.
6. I studied Economics and Political Development with European Study at the University of
Exeter and graduated in 2004. After graduation, I spent a short time working at Shaw Trust
charity before joining e-skills UK (which later became The Tech Partnership) and the
following year began studying a Master's in Public Policy at University College London,
which I did alongside my work. e-skills UK was a project-based organisation focused on
helping the UK maximise the value of digital I held a number of positions at that
organisation between 2004 and 2009. When I left, I had the role of Team Manager (co-
ordinator) of the Schools Team, which managed a number of programmes and looked at
ways of encouraging more young people into STEM (science, technology, engineering
and maths) subjects and careers.
7. I left e-skills UK in 2009 and spent a year at the charity FILMCLUB, working on strategy,
partnerships and fundraising. In 2010, I joined IBM as a contractor, working as a Corporate
Social Responsibility Manager for a year. In 2011, I took on a consultant role at a small
cybersecurity firm where my role was to help organisations with their cyber security culture,
training and communications programmes. In April 2013, I joined POL as a Public Affairs
Manager.
8. I have been asked to briefly summarise the roles I held at POL.As set out at paragraph 1,
I was employed by POL for just over one year, between 2 April 2013 and 22 July 2014.
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My only role during this time was that of Public Affairs Manager within the Communications
Directorate. This was the first time I had worked within a Communications Directorate and
as such was keen to learn as much as I could. I reported into Jane Hill, Head of Public
Affairs, who in turn reported into Mark Davies, Communications Director.
9. Communications, albeit a critical function, acts in service to an organisation. It is not a
decision-making function, nor does it have the power or responsibility to make strategic
decisions as to actions of the business. I was not accountable for strategic initiatives at
POL, including those related to Horizon. My role involved providing opinion, advice and
support in relation to communications.
10. I worked on a variety of different things whilst at POL. POL was a newly independent
business when I joined, having separated from Royal Mail in 2012. I spent a lot of my time
on the development of and embedding of POLs “Post Office 2020” strategy, working with
external management consultants and colleagues across the organisation. I was the
communication representative for the “Post Office 2020” strategy work, and this took up
most of my time during my tenure.
11. As detailed later in this statement, I became involved in Horizor-related work when I was
asked to join regular Horizon calls as a communications representative in July 2013.
Shortly thereafter, I was asked to get involved in the Initial Complaints Review and
Mediation Scheme (the Mediation Scheme), also as a communications representative.
The Mediation Scheme had been established in August 2013 in response to Second
Sight’s “Interim Report into alleged problems with the Horizon system” (the Interim
Report) (POL00029650).
12. I have been asked to summarise other professional roles I have held since being engaged
by POL. When I left POL in July 2014 I joined a UK financial services organisation, where
I continue to be employed on a part time basis. I have held a number of business
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transformation roles in that organisation since and my current title is Head of Experience
and Adoption.
Knowledge of relevant issues
13.1 have been asked to set out my knowledge and understanding of the Horizon IT
system, including the existence of bugs, errors and defects (BEDs) within Legacy
Horizon and Horizon Online; remote access and that Fujitsu may be able, under certain
circumstances to delete and replace Horizon audit files containing transaction data;
when I joined POL. I did not have knowledge of the existence of the Horizon system
itself when I joined POL so it therefore follows that I did not have any knowledge of
these issues when I joined POL. I was not familiar with the term “BEDs’.
14. I have been asked to set out my knowledge and understanding of complaints made by
subpostmasters (SPMs) as to the integrity of the Horizon IT system when I joined POL,
and my knowledge and understanding that POL and previously Royal Mail Group, or
companies within it, had investigated, prosecuted and obtained convictions of SPMs
for theft, fraud and false accounting. I did not have any knowledge of these matters
when I joined POL.
15.1 have been asked to set out when my knowledge of the issues at paragraphs 13 and
14 materially changed. Some time in July 2013, the Communications Director asked
me if I would join a regular meeting with other business departments as a
communications representative. I cannot recall the name of the meeting but can see
from the documents that it was called “Regular Call re Horizon Issues” (for example,
Regular call re Horizon Issues — Meeting minutes from 19/07/2013 (POL00141561)).
Around the same time, a number of colleagues across PR, policy and public affairs
(including myself) got involved with managing Horizon-related work. It was around this
time that I became aware of the existence of the Horizon system itself and the fact that
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there were issues relating to it. I discuss the regular Horizon meeting in more detail at
paragraphs 36 to 40 below.
16.1 have been asked to set out when I first became aware of the existence, content or
gist of a number of documents which have been provided to me by the Inquiry, and to
set out what my thoughts were on these documents and any discussions I had with
others at POL regarding them. Those documents are (as described in the Request):
(i) Simon Clarke’s advice of 15 July 2013 (POL00006357);
(ii) Simon Clarke's advice of 2 August 2013 (POL00129453); and
(iii) Deloitte’s Project Zebra reports (POL00028069).
17. do not recall being aware of, or seeing the documents at (i) and (ii) above during my
time at POL. I can see from the documents provided to me that Simon Clarke was a
Barrister for Cartwright King Solicitors. I was aware that POL’s Legal team worked with
Cartwright King Solicitors but do not think that I would have been privy to legal advice
of that nature in my role as Public Affairs Manager. Regarding the documents at (iii), I
can see that in Email from Sophie Bialaszewski to David Oliver, Rodric Williams,
Belinda Crowe and others re: RE: Draft paper for the Board (POL00304030) that I was
aware in April 2014 that Deloitte was carrying out an assurance exercise and that it
would be producing a report as a result, but I do not recall seeing the report, nor does
it appear that I was aware of any further reports. I do not recall hearing the term “Project
Zebra” during my time at POL. I discuss this further at paragraphs 68 and 69 of this
statement.
POL and my role
18.1 have been asked to summarise my role and responsibilities in respect of public
relations. As set out earlier in this statement, my role was Public Affairs Manager. Public
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relations work was the remit of another team within the Communications Directorate
whom I would have collaborated, coordinated and shared documents with.
19. I have been asked to describe my role and responsibilities at POL regarding the Horizon
IT System and the response to complaints made about it. Alongside my work on the
“Post Office Strategy 2020” and other things, as set out in paragraph 11, over the
summer of 2013 I became involved in some Horizon-related work, having been asked
to do so by the Communications Director. This started with me joining the regular
Horizon calls (as detailed in paragraphs 36 to 40 below) in July 2013. Thereafter I
worked on the Mediation Scheme from a communications perspective.
20. In terms of my role and responsibilities, I joined the Horizon regular calls and was a
member of the Mediation Scheme’s Programme Board as a communications
representative. I was also involved in preparing communications documents such as
communications plans, briefing documents, communications papers, handling plans
and Q&As for the Mediation Scheme.
21. I have been asked to describe what my views were on the working culture within POL
and the management style at the time, and whether my views have changed. During
my short time at POL, I found my colleagues to be professional, helpful and supportive.
Those views have not changed.
22.1 have been asked to describe my working relationship with others who were involved
in POL’s response to complaints about the Horizon IT system, including Paula
Vennells, Mark Davies, Jane Hill, Rodric Williams, Jarnail Singh, Angela Van Den
Bogerd and Belinda Crowe.
23. Paula Vennells was the CEO of POL during my tenure. I did not have regular face-to-
face contact with Paula, however I may have answered emails from her from time to
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time, or may have been asked by more senior colleagues to send her information. For
example, in an email from me to Paula dated 27 January 2014 (Email from Sophie
Bialaszewski to Paula Vennells cc: Chris Aujard re: Second Sight (POL00100123)), I
appear to be responding to a request for information about the original Second Sight
cases. I do not recall this email, or the context in which I sent it, but assume that I sent
it following an instruction, as I open the email with “Following on from your discussion
with Belinda please find below the information we have about the original Second Sight
cases”.
24. As set out in paragraph 8, Mark Davies was the Director of Communications, and
therefore had overall responsibility for the Communications function, of which public
affairs was a distinct part. I had a great deal of respect for Mark. He was a visible leader
and made an effort to get to know and support those in his direct reporting line and the
wider team.
25. Jane Hill was the Head of Public Affairs, and as set out in paragraph 8, I reported into
her. Jane joined POL shortly after I did. I had a good working relationship with Jane
and enjoyed working with and learning from her during my time at POL.
26. Rodric Williams and Jarnail Singh were both in-house lawyers in POL’s Legal team. I
did not have a close working relationship with either of them, but we did interact,
including on the regular Horizon calls in July and August 2013. Part of my role often
involved collating information from around the business to assist with the preparation
of communications documents. The Legal team, including Rodric and Jarnail, assisted
us with information gathering, assisting with fact-checking and answering queries we
had, and also advising on what information could be shared externally. I was wholly
reliant on them in that respect.
27. Angela Van Den Bogerd led the Business Improvement Programme which was part of
POL’s response to the Interim Report (the other being the Mediation Scheme). I had
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contact with Angela from time to time in the course of my work, but would not say that
we had a regular working relationship.
28.1 had regular contact with Belinda Crowe during my time at POL and we had a good
working relationship. Belinda was a Programme Director who was in charge of running
the Mediation Scheme.
29. I have been asked to describe my impression of my colleagues’ views on the merits of
the complaints made by SPMs about the Horizon IT system. I do not recall any
discussion with or between colleagues on the merits of the complaints made by SPMs
about the Horizon IT system, nor would I have expected that to be discussed within
my remit. I do recall, however, having a sense that POL and other stakeholders were
trying to resolve the concerns raised by SPMs via the Mediation Scheme and that POL
was taking the complaints raised very seriously.
Communications regarding Horizon and the related issues
30. I have been asked to describe the nature and extent of my work in (a) handling external
communications including with MPs and/or journalists and/or broadcasters and (b)
internal communications in so far as relevant to the complaints relating to the Horizon
IT system. No part of my work at POL involved dealing with journalists or broadcasters,
which was the remit of the Public Relations team. Part of my role in supporting the
Mediation Scheme involved preparing communications (with input from colleagues in
other business functions) to MPs, for example, notifying an MP that a constituent SPM
had applied to the scheme.
31.1 would have drafted or contributed to working internal communications about the
Mediation Scheme, such as briefing notes or Q&A documents, but this was a
collaborative process with colleagues from across the business. Communications
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containing legal and technical content, for example, need to be prepared in
collaboration with, and signed off by subject matter experts.
32. In particular, I have been asked to explain (i) what POL’s communication strategy was
and who was involved in setting that strategy; (ii) to what extent, if at all, did the
potential for future litigation or criminal appeals affect POL’s communication strategy;
and (iii) if on reflection, do I think that strategy was appropriate.
33.1 do not recall what POL’s overall communication strategy was at the time, nor was I
responsible for setting it. I assume that would have been the remit of the Director of
Communications, with input from all business functions of POL. I have no knowledge
of the extent to which the potential for future litigation or criminal appeals affected
POL’s communication strategy and it therefore follows that I have no opinion as to
whether that strategy was appropriate.
34. I have been asked to describe POL’s communications strategy in respect of the Interim
Report, including the use of the words “no system wide (systemic) problems”, and to
what extent, if at all, did POL try to highlight or downplay that it was an interim report.
POL issued a number of press releases about the Interim Report and the Mediation
Scheme, which were prepared by the Public Relations team, alongside subject matter
experts. I note that at the “Preliminary Conclusions” section of the Interim Report
(POL00029650) states “We have so far found no evidence of system wide (systemic)
problems with the Horizon software” and therefore it appears that in using those words,
POL was quoting directly from the report. To the best of my recollection, the colleagues
I had interactions with and the stakeholders that contributed to communications
documents I worked on, thought that the Mediation Scheme, which had been
established off the back of the Interim Report, was an appropriate way to address the
complaints raised by SPMs.
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35.1 have been asked to describe the nature and extent of my involvement with POL’s
communication with government (including the Shareholder Executive) regarding
Project Sparrow related matters. I do not recall corresponding with the Shareholder
Executive directly about Project Sparrow related matters (which included the Mediation
Scheme), but the Communications Directorate did have contact with Peter Batten from
the Shareholder Executive which I would have been copied to. I can see in Email from
Peter Batten to Belinda Crowe, Martin Edwards and others re: Horizon PQs
(UKGI00002126) that I am copied to email correspondence with Peter Batten (from
the Shareholder Executive) relating to Parliamentary Questions that had been
received.
Horizon regular call
36. I have been asked to set out the nature and extent of my involvement with the Horizon
regular call meetings, including the purpose of the meetings and my attendance at
them. I do not have any recollection of these calls but have been assisted by
documents from the Inquiry, in particular the following:
* Regular call re Horizon Issues -— Meeting minutes from 19/07/2013
(POL00141561);
e Regular Call re Horizon Issues - Name, Area and Issues / Observations /
Comments (24 July 2013) (POL00137370);
e POL Meeting Minutes from Regular Call Re: Horizon Issues on 7 August 2013
(WBON0000802);
« Meeting Minutes for Regular Call re Horizon Issues (14 August 2013)
(POL00083930);
e Meeting Minutes for Regular Call re Horizon Issues (21 August 2013)
(POL00089720); and
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e Bond Dickinson Agenda for Regular Call re Horizon Issues, and action points
from last meeting on 21 August 2013 (28 August 2013) (POL00083935).
37.1 can see from these documents that these meetings were regular, and for the most
part took place on a weekly basis during July and August 2013. They were attended
by representatives from Legal, Financial Services Centre (FSC), Security, Network,
Information Technology & Change, and Communications. I can see that I was in
attendance as a communications representative at all of the meetings listed in
paragraph 36 above, save for the meeting on 14 August 2013 which was attended by
another member of the Communications team. A colleague from the Public Relations
team was in attendance on 19 and 24 July 2013.
38. It is clear from the July notes that the purpose of the meeting was to “identify any issues
around the integrity of horizon from a technical perspective and take any necessary
action” (POL00141561 and POL00137370), although on 21 August 2013 the purpose
is set out as being “to ensure visibility, support and communication across the
business” (POL00089720).
39. I can also see, based on the notes, that I rarely commented during the meetings. Based
on the minimal actions I was assigned, I can only assume that I attended those
meetings for awareness purposes and to ensure that the appropriate business
functions were aware of various issues. For example, in the 21 August 2013 meeting
my action was “to copy Jarnail Singh and Rodric Williams into emails going forward
regarding new MP cases, reporting and relaying information regarding queries from
MP’s to Rosie Gaisford of Bond Dickenson”.
40. I have been asked to set out my recollection of the initial meetings in July and August
2013, including what was discussed regarding note/minute taking and/or record
keeping for those meetings. As set out above, I do not have a recollection of these
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meetings but I have been assisted by the documents provided to me by the Inquiry. I
do not have a recollection of what was discussed regarding note taking, minute taking
or record keeping for those meetings. I can see, however that on 16 August 2013,
Dave Posnett, Accredited Financial Investigator, sent an email to Andrew Parsons
stating that the notes would be collated in an independent spreadsheet which would
be circulated to attendees. I do not recall receiving this spreadsheet nor have I seen
documents that suggest I did, although I would assume it was circulated to attendees
in the ordinary course.
41.1 have been asked to what extent, if at all, I was aware of any instructions to shred or
destroy notes made as part of the Horizon regular call. I have no recollection of ever
being instructed to shred or destroy notes made as part of the Horizon regular call, or
at all, during my time working at POL. If I had ever been given this instruction, I would
have remembered it as it would have been a very unusual request.
The Mediation Scheme and Project Sparrow
42.1 understand that the Mediation Scheme was originally one of two strands of a large
strategic programme known as Project Sparrow, which was set up in July 2013 by the
Executive and Board in response to the Interim Report. I think it initially comprised two
initiatives, the Mediation Scheme and the Business Improvements Programme. I
understand that the two initiatives were separated later in 2013 so that they became
two distinct projects.
43.1 have been asked to describe my involvement in the establishment of the Mediation
Scheme and the Working Group. I did not have any involvement in setting up or
designing the Mediation Scheme, but played a role in considering and advising on
POL's communications approach in relation to it during my tenure.
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44.1 have been asked to set out what the internal POL view was on the purpose of the
Mediation Scheme, including whether there was any divergence of views on that issue.
My understanding of the purpose of the Mediation Scheme (which I understood to be
the internal POL view) was that it had been established to address individual complaints
raised by SPMs about the Horizon system and resolve complaints where possible. I do
not recall if there was any divergence of views on that issue and was not privy to any
discussions indicating the same.
45.1 have been asked to what extent, if at all, the Mediation Scheme was designed to
identify whether there were problems with the Horizon IT system. As set out above, my
understanding of the Mediation Scheme at the time was that it had been established to
resolve complaints raised by SPMs. I was aware that there was a Business
Improvements Programme running in parallel to the scheme, which had been set up to
address any business improvement issues that were identified whilst complaints were
being dealt with by the Mediation Scheme. In that sense, my view at that time was that
POL was taking matters seriously and committed to making improvements.
46. I have been asked to describe what my views were at the time of the appropriateness
of POL's approach to the establishment and running of the Mediation Scheme. Whilst
it is difficult to recall what my personal views were at the time, I suspect I would have
felt the same as my colleagues and stakeholders, in that the Mediation Scheme was an
appropriate response to resolve individual complaints. As things progressed into early
2014, my view was that POL rightly took the appropriate action to involve more senior
colleagues, external mediators and management consultants to deal with the Mediation
Scheme and individual cases. It was not within my remit to decide what strategic action
POL should take. My job was to help to ensure that it was communicating what it was
doing clearly and concisely.
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47. I have been asked to describe my role and responsibilities in relation to the running of
the Mediation Scheme. I attended meetings and calls (sometimes alone, sometimes
with other members of the Communications team). My work involved preparing
communications documents with the input of key stakeholders across the business, for
example the Mediation Scheme FAQ pack and template letters (examples of these are
set out at Email from Sophie Bialaszewski to Alan Bates cc Ruth Barker, Angela Van
Den Bogerd re Mediation Pack Letter and Information (POL00146088), Letter from
Angela Van Den Bogerd to Alan Bates re Initial Complaint Review and Mediation
Scheme (to be known as the Scheme) (POL00146089) and Letter from Angela Van-
Den-Bogerd to Alan Bates to be distributed to SPMs re: Initial Complaint Review and
Mediation Scheme (to be known as the Scheme) (POL00146090) and a
communications plan. Key stakeholders were involved in inputting the appropriate
information into those documents. I trusted that the information provided by
stakeholders and subject matter experts was accurate and if I had sensed that it wasn't,
I would have asked for more details and clarification. I do not recall ever getting a sense
that information provided to me was inaccurate or untrue. If I had, I would have
escalated it to my line manager (who was Head of Public Affairs) and then to the
Director of Communications.
48. Specifically for the Mediation Scheme, my role involved a lot of coordinating and
collating information in order to prepare communications documents. An example of
this is evident in an email from me to Angela Van Den Bogerd (Email from Sophie
Bialaszewski to Angela Van-Den-Bogerd RE: Feedback (POL00200202)) in which I ask
her to review a document I had prepared.
49. I have been asked to explain POL’s strategy in responding to applications and who was
responsible for that strategy. I never worked on individual cases or the actual mediation
of cases, and therefore, do not have any comment to make in that regard. I do not recall
who was responsible for that strategy.
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50.1 have been asked to set out my involvement in creating the “Managing Expectations
Gap” document, and any work I carried out in managing expectations. I do not recall
preparing this document, nor is it written in my style. I have, however, been assisted by
the documents provided to me by the Inquiry to an extent. I can see that I worked on a
document called “Managing Expectations Gap” in November 2013 with Andy Parsons,
Senior Associate at Bond Dickinson (Initial Complaint Review and Mediation Scheme -
Managing Expectations (POL00146799)). I can only assume that my input into the
document was from a communications perspective. It appears that this document was
created to address what had been identified as a “expectations gap” amongst the
different stakeholders involved in the Mediation Scheme (including Second Sight, the
Justice for Subpostmasters Alliance and MPs) in terms of what they believed the
Mediation Scheme would provide by way of resolution or settlement. On its face, it
appears to be a “scenario planning” document, setting out different options, rather than
a document defining a strategy. In an email to Mark Davies on 12 November 2013, I
attached this document and set out my thoughts on what could be required by way of
communications documents to address these differing expectations. Whilst I may have
been involved in preparing the “Managing Expectations Gap” document, it appears on
its face to be an Executive Committee (ExCo) document, and I would not have been
the one to brief ExCo on it. I don’t recall ever having briefed ExCo about the Mediation
Scheme during my time at POL. Other than working on this document, I do not recall
carrying out other work related to managing expectations specifically. However, as set
out in this statement, I was involved in preparing communications and briefing
documents for stakeholders which set out what the Mediation Scheme was.
5
. I have been asked to describe the extent of my involvement in developing the internal
or external communications strategy in relation to the running of the Mediation Scheme.
I was involved in preparing the Mediation Scheme communications plan for Mark
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Davies, which he appears to have been tasked with by ExCo (Email chain from Sophie
Bialaszewski to Mark Davies, cc'd Jane Hill re Mediation Scheme Comms Plan Draft
(POL00162098)). I prepared the plan with input from key stakeholders which is
evidenced in an email from me to Mark Davies and other communications colleagues
in December 2013 (Email from Sophie Bialaszewski to Mark R Davies, Jane Hill, Nina
Arnott & others RE: Mediation Scheme - please can you review (POL00198974)). In
that email, to which I attach a working draft, I say “anything in red I’m not sure about
and I'd particularly like your views on’.
52. I have been provided with three different iterations (Mediation Scheme Communications
Plan (POL00198975), Strictly Confidential - Mediation Scheme Communications Plan
(POL00301400) and Mediation Scheme Communications Plan (POL00407896)) of this
document, and would say that it was not necessarily a “communications strategy” in the
traditional sense. Rather, it was a “plan of action” in response to setting up the Mediation
Scheme, which focused on ensuring that communications were consistent and clear
across stakeholders (including MPs). The documents that I have been provided with
set out a relatively short timeline to which the plan applied — 8 July 2013 to 13 October
2014. In the context of the Mediation Scheme, which I understand ran into 2015 and
well after I had left POL (in July 2014), I can only assume that additional
communications plans would have been prepared after my departure as the nature of
communications is to evolve, change and develop in response to evolving situations.
53.1 have been asked to what extent I was involved in devising the policy to settle claims
made to the Scheme and to describe how the policy was formed. I do not recall how
the policy was formed, although have been assisted by the documents provided to me
by the Inquiry. Based on the documents, I can see that I was copied to a thread of
correspondence with other POL colleagues attaching various drafts and iterations of
the policy, which appears to have been initially drafted by Bond Dickinson. I can see
that all those copied to the email correspondence made comments on the draft policy.
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I made what I describe as “minor tweaks” to a working draft on 11 November 2023
(Email from Sophie Bialaszewski to Belinda Crowe, Andy Holt, Angela Van-Den-Bogerd
Re: ExCo paper - settlement policy (POL00197021) and Horizon - Initial Complaint
Review and Mediation Scheme Settlement Policy (POL00197022)). My changes
appear to be limited to giving my opinion from a communications point of view and
ensuring that the wording in the document was consistent with other communications
documents that had been prepared about the Scheme.
54. I have been asked how, when responding to queries or questions regarding Horizon, I
satisfied myself that the answers I provided were accurate. I was never directly asked
queries or questions about Horizon in the course of my role. When compiling
communications documents or information factsheets, I relied on the relevant person
within the business to provide the answer, and trusted that the responses that they
provided were accurate, especially in relation to legal or technical information which
was outside of my area of expertise.
55.1 have been asked to describe the nature and extent of my involvement with POL
decision making in respect of Second Sight’s remit and/or the scope of their instruction
in the Mediation Scheme, including whether to produce thematic reports. I had no
involvement in respect of Second Sight’s remit or the scope of their instruction in the
Mediation Scheme. This was not the remit of Communications, rather a strategic
business decision.
56. I have been asked to consider the Mediation Scheme settlement policy
(POL00197022) and to explain what I meant by my comment at paragraph 4.1 that “The
scheme has to be seen as legitimate/credible”. This relates to the comments and
“tweaks” that I describe at paragraph 53 above. I can see from the documents that the
settlement policy (POL00197022) contained a line that said:
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“It is vital for the Post Office that...the Scheme...not only achieves its objectives but
is generally considered to having successfully resolved the concerns of
Subpostmasters and is acknowledged as having been a success.”
57.1 commented on this line in the document and said “The scheme has to be seen as
legitimate/credible”. I suspect that my view at the time was that it was not enough for
POL to know internally that the Mediation Scheme was legitimate and credible. All
parties needed to agree that it was legitimate and credible, including MPs and the SPMs
applying to it. If they did not, they would not have seen it as a credible scheme worth
applying to.
58. I have been asked to describe the nature and purpose of the Sparrow Steering Group
and the Initial Complaints Review and Case Mediation Scheme Steering Group /
Programme Board, including the extent of my role on those committees.
59.1 can see from the documents that I attended a Sparrow Steering Group meeting in
November 2013, although I do not recall attending it. The notes of that meeting state
that I was Mark Davies’ deputy and that he was not in attendance. Therefore I can only
assume that I attended that meeting as his deputy.
60. Similarly, I can see that I attended one of the Mediation Scheme Steering Group
meetings on 16 December 2013, when Mark was not in attendance. Therefore, as
above, I can only assume that I was attending that meeting as his deputy.
61.1 do not recall the nature and purpose of the Sparrow or Mediation Scheme Steering
Groups, although I can see that they were attended by very senior colleagues, including
the CEO. On that basis, I assume that they were forums that were used to discuss
issues and provide updates about Project Sparrow and later, the Mediation Scheme, to
Board-level executives.
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62. I was a member of the Mediation Scheme Programme Board, which I understood to be
the group that had “on the ground” responsibility for the management of the Mediation
Scheme. I cannot recall the Programme Board meetings that I attended but I have been
assisted by the documents provided to me by the Inquiry, which indicate that I attended
Programme Board meetings in January, February and March 2014. In February 2014 I
was accompanied by Mark Davies from a communications perspective. I can see that
at the February 2014 meeting (Initial Complaints Review & Case Mediation Scheme
Programme Board (POL00138147)) a number of actions were assigned to me,
including drafting a “paper on media risk for ExCo” and creating “reactive lines that are
aligned to the Second Sight themes”. I do not recall what these specific actions relate
to, however I suspect I would have worked with the relevant stakeholders (and Mark
Davies) to take them forward as was usual practice in my role. For example, any work
relating to media would have required input from the Public Relations team. I
understood that the Mediation Scheme had grown bigger in the preceding months and
more resources had been pulled in, including external management consultants PA
Consulting. The following day, I sent an email to Mark Davies (Email from Sophie
Bialaszewski to Mark R Davies and Jane Hill RE: PO business improvements
(POL00344384)) in which I said:
“Mark I am still really happy to be the point person on this working with members of
the comms team - I'm really happy to do the work I will just need guidance re
positioning with the media/MPs (from those that have more experience than me).”
63.1 suspect that I raised this with Mark because, as above, the Mediation Scheme had
grown and there was more going on, it was rightly getting more attention within the
organisation, including at Executive and Board level.
64.1 have been asked to consider the document entitled “Email from Jarnail A Singh to
Andy Holt, Chris Aujard, Belinda Crowe and Others RE: FW: Post Office Ltd - Draft
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Prosecution Policy” (POL00196662) and the attached POL Prosecution Policy
reviewed by Simon Clarke - Cartwright King (POL00196663) and explain the nature
and extent of my involvement in considering POL’s prosecution policy. I had no
involvement in formulating or considering POL's prosecution policy. I may have been
asked about how to formulate communications relating to it, but had no involvement in
determining the content.
65. I have reviewed other documents provided to me by the Inquiry and can see that I was
copied to correspondence with Jarnail Singh and other stakeholders later in October
2013 (Email from Jarnail A Singh to Andy Holt, Chris Aujard, Belinda Crowe, Angela
Van-Den-Bogerd & others cc Hugh Flemington RE: Post Office Ltd - Draft Prosecution
Policy (POL00329696)) which Jarnail provided information about POL’s prosecution
policy, in particular the factors taken into account by POL when deciding to prosecute.
I can only assume that I was collating information to include in a communications
document for the Mediation Scheme, and Jarnail was providing the information we had
requested. A similar approach is evidenced in email correspondence in January 2014
(Email from Jarnail Singh to Sophie Bialaszewski re: Post Office Ltd /Abbas & Daw -
41459 - Selsey Road - POLTD/1314/0014 [BD-4A.FID20472253] (POL00382925)) in
which I request information from the Legal team for the “Media Q&A bank of questions
were are developing”, in which I ask the question “/f we were to be asked by the
press...what is your prosecution policy?’. I also can see from the documents that I
prepared a “reactive briefing” regarding the prosecutions policy for Chris Aujard in the
Legal team in February 2014 (Prosecutions Policy Reactive Briefing (POL00200785)).
A reactive briefing is prepared to ensure that the business is prepared for external
enquiries and has a consistent communications approach to deal with those. I can see
from the documents that POL was making changes to its prosecution policy at the time
therefore I assume that the Communications team was being asked to prepare a
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reactive briefing in relation to that, which is common practice. Based on the documents,
it appears that I was coordinating sign off of this document.
66. I have been asked to consider some undated handwritten notes and some emails with
further notes (Note and printed/annotated email from Belinda Crowe to Sophie
Bialaszewski re: Sparrow comms and agenda (POL00417116)) and to confirm if they
are my notes. I have also been asked to provide the background to making these notes.
The handwriting in these notes looks like mine at the time. I do not recall making these
notes but having studied the document it appears to be an agenda of some sort, and
notes from a meeting. The notes are not dated nor do they indicate what meeting they
relate to or who that meeting might have been with. I cannot assist the Inquiry any
further in this respect.
67.1 have been asked to what extent I was involved in decision making in respect of (a)
modifying the Mediation Scheme and/or Working Group and (b) closing the Working
Group. I had no involvement in decision making in respect of modifying the Mediation
Scheme or Working Group or closing the Working Group. My involvement in the
Scheme was limited to the early stages, and as set out earlier in this statement, I left
POL in July 2014.
Project Zebra
68.1 have been asked to explain the nature and extent of my involvement with Project
Zebra. “Project Zebra” is not a term I was familiar with or aware of during my time at
POL. I am now aware that the term “Project Zebra” related to a piece of assurance work
carried out by Deloitte for POL in 2014, which I was aware of to a limited extent during
my time at POL. I was not, however, directly involved in that work.
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69. I have been asked to explain what I was told about the findings of Project Zebra and/or
what POL planned to do in response to the Deloitte reports. As set out in paragraph 17
above, I can see from the documents that from around April 2014 that Deloitte was
carrying out an assurance exercise for POL related to Horizon and that it would be
producing a report as a result. I do not recall ever hearing the term “Project Zebra”
during my time at POL. I do not recall being provided with the reports or being privy to
any discussions as to what POL planned to do in response to the findings. In any event,
I understand that the final report was delivered in June 2014, at which point I had
handed in my one months’ notice to leave POL.
Conclusion
70. I have been asked to reflect on my time at POL and set out whether there is anything I
would have handled differently with hindsight. I can confirm that there is nothing that I
would have handled differently with hindsight. If I ever felt that I was being asked to do
something wrong, I would have escalated to the Head of Public Affairs (who was my
line manager) or to the Director of Communications and made it clear that I was
uncomfortable.
71.1 have been asked 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 and I can confirm that from my
perspective, there is not.
Statement of Truth
Signed:
Dated: 12-Nov-2024
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Index to First Witness Statement of Sophie Louise Underwood
No. URN Document ‘Control Number
1 POL00029650 I Interim Report into the alleged problems with the/POL-0026132
Horizon system
2 POL00141561 I Regular call re Horizon Issues — Meeting minutesPOL-0142946
from 19/07/2013
3 POL00006357 I Advice on the use of expert evidence relating toPPOL-0017625
the integrity of the Fujitsu Services Ltd Horizon]
System
4 POL00129453 I Simon Clarke's Advice re: Disclosure - The Duty[POL-0134937
to record and retain material - Post Office LTD
5 POL00028069 I Deloitte Draft Board Briefing document further toPOL-0023072
report on Horizon desktop review of assurance}
sources and key control features
6 POL00304030 I Email from Sophie Bialaszewski to David Oliver,IPOL-BSFF-0142080
Rodric Williams, Belinda Crowe and others re: RE:
Draft paper for the Board
7 POL00100123 I Email from Sophie Bialaszewski to Paula VennellsIPOL-0099706
cc: Chris Aujard re: Second Sight
8 UKGI00002126 I Email from Peer Batten to Belinda Crowe, MartinUKGI012940-001
Edwards and others re: Horizon PQs
9 POL00137370 I Regular Call re Horizon Issues - Name, Area andiPOL-0135345
Issues / Observations / Comments
10 I WBONO000802 IPOL Meeting Minutes from Regular Call Re:\WBD_000672.000001
Horizon Issues on 7 August 2013.
11 POL00083930 [Meeting Minutes for Regular Call re Horizon IssuesIPOL-0080861
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12
POL00089720
[Meeting Minutes for Regular Call re Horizon IssuesI
IPOL-0086695
13
POL00083935
[Bond Dickinson Agenda for Regular Call re Horizon
issues, and action points from last meeting on 21
August 2013
IPOL-0080866
14
POL00146088
[Email from Sophie Bialaszewski to Alan Bates cc}
Ruth Barker, Angela Van Den Bogerd re Mediation]
Pack Letter and Information
IPOL-BSFF-0005215
15
POL00146089
Letter from Angela Van Den Bogerd to Alan BatesI
re Initial Complaint Review and Mediation SchemeI
(to be known as the Scheme)
IPOL-BSFF-0005216
16
POL00146090
Letter from Angela Van-Den-Bogerd to Alan BatesI
fo be distributed to SPMs re: Initial Complaint]
Review and Mediation Scheme (to be known as theI
Scheme)
IPOL-BSFF-0005217
17
POL00200202
Email from Sophie Bialaszewski to Angela Van-I
[Den-Bogerd RE: Feedback
IPOL-BSFF-0038265
18
POL00146799
Initial Complaint Review and Mediation Scheme -
(Managing Expectations
IPOL-BSFF-0005926
19
POL00162098
[Email chain from Sophie Bialaszewski to MarkI
Davies, cc'd Jane Hill re Mediation Scheme CommsI
Plan Draft.
IPOL-0150543
20
POL00198974
[Email from Sophie Bialaszewski to Mark R Davies,
Nane Hill, Nina Arnott & others RE: Mediation]
‘Scheme - please can you review
IPOL-BSFF-0037037
21
POL00198975
[Mediation Scheme Communications Plan
IPOL-BSFF-0037038
22
POL00301400
Strictly Confidential - Mediation Scheme!
Communications Plan
IPOL-BSFF-0139450
23
POL00407896
Mediation Scheme Communications Plan
IPOL-BSFF-0232835
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24
POL00197021
[Email from Sophie Bialaszewski to Belinda Crowe,I
Andy Holt, Angela Van-Den-Bogerd Re: ExCoI
paper - settlement policy
IPOL-BSFF-0035084
25
POL00197022
Horizon - Initial Complaint Review and Mediation
[Scheme Settlement Policy
IPOL-BSFF-0035085
26
POL00138147
Initial Complaints Review & Case MediationI
Scheme Programme Board
IPOL-BSFF-0000378
27
POL00344384
[Email from Sophie Bialaszewski to Mark R DaviesI
jand Jane Hill RE: PO business improvements
IPOL-BSFF-0170105
28
POL00196662
[Email from Jarnail A Singh to Andy Holt, ChrisI
Aujard, Belinda Crowe and Others RE: FW: Post]
\Office Ltd — Draft Prosecution Policy
IPOL-BSFF-0034725
29
POL00196663
IPOL Prosecution Policy reviewed by Simon ClarkeI
+ Cartwright King
IPOL-BSFF-0034726
30
POL00329696
[Email from Jarnail A Singh to Andy Holt, ChrisI
(Aujard, Belinda Crowe, Angela Van-Den-Bogerd &
jothers cc Hugh Flemington RE: Post Office Ltd +
[Draft Prosecution Policy
IPOL-0175825
31
POL00382925
Email from Jarnail Singh to Sophie Bialaszewski re:
Post Office Ltd /Abbas & Daw - 41459 - Selsey
Road - POLTD/1314/0014 [BD-4A.FID20472253]
IPOL-BSFF-0209812
32
POL00200785
Prosecutions Policy Reactive Briefing
IPOL-BSFF-0039250
33
POL00417116
INote and printed/annotated email from Belinda
\Crowe to Sophie Bialaszewski re: Sparrow comms
land agenda.
IPOL-BSFF-0237267
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