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Witness Name: ALISDAIR CHARLES JOHN CAMERON
Statement No.: WITN09840100
Dated: 18 APRIL 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ALISDAIR JOHN CHARLES CAMERON
I, ALISDAIR JOHN CHARLES CAMERON, will say as follows...
INTRODUCTION
1. _Iaman employee of Post Office Limited (“POL”). I have been employed by POL
since January 2015 as Chief Financial Officer (“CFO”) and from 2017-19 as Chief
Financial and Operating Officer (“CFOO”). I held the position of Interim Chief
Executive (“Interim CEO”) from April 2019 to September 2019. During my
employment with POL, I have also undertaken other roles and responsibilities at
different times, which I set out in my statement. I have been on medical leave
since 7 May 2023.
2. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in its Rule 9 Request to me (the “Request”),
dated 14 March 2024.
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3. Except where I indicate to the contrary, the facts and matters contained in this
witness statement are within my own knowledge. Where any information is not
within my personal knowledge, I have identified the source of my information or
the basis for my belief. The facts in this witness statement are true to the best of
my knowledge and belief.
4. Given the passage of time, I have limited recollection of some topics covered by
the Request. Where this is the case, this statement focuses on the content of
various documents provided to me by the Inquiry. To the extent that those
documents have assisted my recollection, I set out the URN of the relevant
document.
5. I was assisted in preparing this statement by Bates Wells and Braithwaite LLP,
my recognised legal representative in the Inquiry.
APOLOGY
6. When I joined POL, the business was confidently communicating that it had
found no evidence of faults with the Horizon IT system (“Horizon”), or that
convictions of Postmasters had been unsafe. Nor had any convictions been
appealed at that time. I am sorry that I accepted that Horizon was working
effectively too easily at the time, and for the time that it took us to shift focus from
the commercial performance of the business to the experience of Postmasters. It
became clear to me in 2019 that Postmasters needed far greater support, and
this demanded a culture shift in POL. In 2020 I understood that there had been
miscarriages of justice which should never have been allowed to happen, and
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which should have been rectified far earlier. I hope that this statement assists the
Inquiry in its investigations into these vital matters.
BACKGROUND
7.
10.
11.
12.
I have been asked to summarise my career and professional background.
I started work as a trainee accountant for Binder Hamlyn in September 1987.
After qualifying as a Chartered Accountant, I remained in practice until 2002.
My employer was subject to a change of control on two occasions. As a result, I
joined Arthur Andersen, becoming a partner in 1999. I became a partner of
Deloitte and Touche following another transaction in 2002.
My duties during this period were to take part in, manage and then lead external
audits, internal audits, risk management work and transaction support for
customers. I also undertook some internal management roles for Arthur
Andersen.
Later, in 2002, I left practice, becoming the Head of Internal Audit and Risk
Management for Centrica plc. At the time, the Centrica group included the AA,
OneTel, Goldfish Bank and energy companies in North America, Europe and the
UK, including British Gas.
In 2004, I was appointed Group Financial Controller of Centrica plc, managing
the production of the financial results and the external audit.
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13.
14.
15.
In 2006, I was appointed the Finance Director of British Gas Residential Energy.
In 2010, I was appointed the Finance Director of the combined British Gas. In
2012, I was appointed the Managing Director of British Gas Energy, which
provided energy to small and medium sized business customers in the UK. In
2013, I was appointed Director of Standards of Conduct for British Gas.
I have held Non-Executive (“NED”) positions at the e-learning Foundation
(2008-2012), Oxford University Hospitals (2009-2016) and Dover Harbour
(2017-2022).
In January 2015, I was appointed CFO of POL, a position I still hold. I had a
variety of executive accountabilities in this role (see below).
Positions held at POL and roles and responsibilities
16.
17.
From 2015 to 2023, my primary accountability as CFO was financial reporting
and treasury management. In addition, I was accountable for Procurement and
Safety. I also had periods of accountability for Strategy, Cash Logistics (“Supply
Chain”), Change, Property, Operations, Management Information and IT. Other
than Operations and IT I do not think that these roles had a direct bearing on
matters of relevance to the Inquiry but I am, of course, happy to answer
questions on this point.
My title changed in January 2017: I became CFOO until March 2019. Broadly, I
was accountable for the functions that supported interactions with
Subpostmasters (Postmasters”), employees and in some cases third-party
product owners (“Clients”). I was not accountable for the commercial and
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18.
19.
20.
21.
22.
contractual relationships with these groups, individual Postmasters or with the
National Federation for Subpostmasters (“NFSP”).
My executive accountability for IT started in January 2015. It was a role
designed to support the Chief Information Officer (“ClO”) and enable better
liaison with the Board. The Board were aware that I brought no previous
experience or expert understanding of IT. The CIO at the time that I joined was
Lesley Sewell and her role was to lead the IT function.
Lesley Sewell resigned in 2015 and I brought in an interim CIO, Chris Broe and
then a permanent replacement, Rob Houghton, who joined the business in April
2016. He was, as planned, promoted to the Group Executive (the “GE”) at the
end of 2016, which marked the end of my accountability for IT.
In my personal objectives, which I agreed with Paula Vennells (CEO of POL
2012 — 2019) for the start of 2015 - 2016, I had no IT objectives. In the second
half of 2015 - 2016 and 2016 — 2017, I did have IT objectives. These were
focused on the challenges described later in this witness statement: lead team
structure; separation from RMG (“Royal Mail Group Ltd”); decisions on the
Fujitsu relationship; website stability; and a Back Office project. The working of
Horizon was not referred to in my objectives.
From April 2019 I was Interim Chief Executive of POL then reverted to CFO in
September 2019 when Nick Read joined as CEO.
Between 2019 and 2023 I had reducing accountabilities, handing over
accountability for Operations in 2019 and again in 2020, Management
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Information in 2021 and Supply Chain in 2022. I took on Internal Audit and Risk
Management in 2019. Nick’s preferred operating model was to have a separate
Operations Director / Retail Director.
EXECUTIVE AND GOVERNANCE COMMITTEES
23. When I joined POL in 2015, the governance structures looked appropriate to me
and appeared to be functioning sensibly.
The relationship with the Shareholder
24. The Government (“HMG”) via the Department for Business and Trade
(previously the Department for Business, Energy and Industrial Strategy, BEIS)
(‘the Department” or “the Shareholder”) has a 100% shareholding in POL. UK
Government Investments (“UKGI”) oversees this shareholding on behalf of the
Department via a designated “Shareholder Representative”, who holds a seat
on the POL Board and its key Committees.
25. The most difficult area in POL’s governance structure was often the relationship
with the Shareholder. There can be an advantage in the alignment and
closeness of the working relationship between a Shareholder, Board and
Executive team. This seemed to be the case up to 2020 when improving the
commercial performance, especially Trading Profit, was a clear priority.
26. Most major financial decisions are made as part of a broader negotiation
between the Department and the Treasury (“HMT”). POL rarely gets to talk
directly to HMT officials. Depending on the subject, internal HMG discussions
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27.
are with a variable combination of HMT, the Secretary of State and the relevant
Minister, the Minister's policy team, the Permanent Secretary, the Department's
Finance team and UKGI. Attempts to open better lines of communication, such
as through a formal Quarterly Shareholder Meeting, have had limited success.
In my view, with a seat on the Board and its key Committees, UKGI should have
a deep understanding of POL as a business, backed up by commercial
experience. It should be vital in explaining the commercial business to the
Department and HMT and communicating the Department's needs to POL. In
my experience this has not worked effectively.
The Board and its Committees
The Board
28.
29.
I have been a member of the Board of Directors of Post Office Limited (the
“Board”) and of the GE from January 2015 until the present day, although I
have been on medical leave since 7 May 2023.
The Board was collectively responsible for setting POL’s primary business
objectives, establishing a proper governance framework and ensuring resources
and leadership to achieve its stated objectives, as set out in the POL governing
Board Terms of Reference and Schedule of Matters Reserved, 26 June 2015
(POL00362178) and as summarised in The POL Governance Induction Pack 14
April 2018 (POL00362224). POL must comply with the Companies Act and its
Articles of Association.
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30.
31.
32.
33.
34.
35.
The Terms of Reference and the Articles of Association changed from time to
time but not significantly.
The Board was led by the Chairman (Tim Parker between 2015 and 2022) and
included all of the NEDs, including the Shareholder Representative from UKGI,
together with the CEO and the CFO. There was therefore a significant NED
majority.
The Board typically had 7-8 standard meetings a year plus a 2-day Strategy
away day. Extraordinary or Additional meetings were convened where
appropriate, mostly in 2020-2022, as the Board managed POL’s response to the
Postmaster Group Litigation (“GLO”) and previous criminal convictions.
Decisions could also be made by correspondence.
Overall Board members were focused on the commercial issues faced by the
business, which was typically their background.
The introduction of the Postmaster Representative Directors was welcome and
important, although it is a difficult role for the individuals: their unique
perspectives are offered privately, and they generally need to accept collective
decisions.
The Board and its Committees have, especially since 2019, committed very
substantial amounts of time to issues associated with the matters relevant for
the Inquiry. However, the bulk of this time has focused on managing the legal
and compensation processes. Much less time has been spent on ensuring that
Horizon and the processes around it are operating effectively.
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36. Through much of my tenure, the Board was chaired by Tim Parker. Tim was an
excellent commercial Chairman. He is extremely astute, as his business record
demonstrates, he is instinctively supportive without ever being unable to
challenge and he gave the Executive team more confidence to focus on
commercial issues. In my view, his perspective on the Litigation felt less
confident and tended to follow the legal advice.
37. During 2016 — 2017, I understood that Tim commissioned a Chairman’s Review,
at the request of Baroness Neville-Rolfe, to investigate matters related to
Postmaster complaints and the mediation scheme. I do not know how this work
was reported, or how it was transitioned from the Chairman's review into
preparation for the GLO. The work was legally privileged, and my recollection is
that it was not shared, even with the Board. However, I was later included in the
work on the Suspense Accounts (see from paragraph 259). On reflection, the
Board should have insisted on seeing and understanding this work as part of
our preparation for the GLO.
Sparrow Sub-Committee
38. The responsibility for management of the initial complaint review and mediation
scheme regarding complaints concerning Horizon reliability (codenamed
“Sparrow’), the GLO, and the criminal convictions of Postmasters fell to
different committees during different periods of time.
39. The Sparrow Sub-Committee was attended by the Chairman, CEO, NEDs and
members of the Legal and Communications teams. I understood the purpose of
the Sparrow Sub-Committee was to review the progress of the Mediation
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40.
Scheme. I attended the last meeting of the Sparrow Sub-Committee in February
2015 and have seen the papers for the previous meeting in January 2015. I
discuss these meetings later in my statement (see from paragraph 150).
Shortly after I joined, the Sparrow Sub-Committee was disbanded and not
directly replaced. I do not recall the reasons, although the Mediation Scheme
was losing support from third parties and internally in POL around that time.
GLO Sub-Committee and subsequent committees
41.
42.
43.
44,
The Postmaster Litigation Advisory Board Sub-Committee, sometimes also
referred to as the Board GLO Sub-Committee, also dealt with matters within the
Inquiry’s scope. I will refer to it as the “GLO Sub-Committee” in my statement.
The GLO Sub-Committee was formed in 2018, met four times between March
and September 2018 and continued until its final meeting on 3 March 2020. It
was chaired by the Chairman of POL. Its purpose was to receive legal advice on
POL’s defence of the GLO, with key decisions referred for final approval by the
Board.
Its membership comprised the CEO (Paula Vennells, then Nick Read), the
Shareholder Representative, the Senior Independent Director and myself, with
the General Counsel (Jane MacLeod) in attendance in her role as Company
Secretary until April 2019.
With hindsight, the GLO Sub-Committee struggled in the early period of meeting
from lack of clear papers and issues such as minutes arriving late and
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45.
46.
47.
sporadically. One particular issue faced by the GLO Sub-Committee was in
June 2019, when it was discovered that the Board had not been informed of the
Claimant's schedules of information to support claim values (Draft Meeting
Minutes of the Postmaster Litigation Subcommittee of POL 20 June 2019,
POL00006752).
The GLO Sub-Committee was superseded by the Criminal Cases Review
Commission (“CCRC”) meetings which were convened many times between
April 2020 and August 2021. My recollection is that this was not a committee but
a series of meetings of the Board, chaired by the Chairman, with a specific
focus. The meetings evolved to deal with various matters such as the appeals
against the criminal convictions of Postmasters, compensation schemes and
decisions of the Board regarding POL’s duties as former prosecutor of
Postmasters in earlier criminal cases.
This work was continued from August 2021 by the Historical Remediation
Committee (“HRC”) which was chaired by the then Senior Independent Director
(Ben Tidswell) and whose membership comprised two other NEDs including the
Shareholder Representative.
I could see the papers and had the right to attend HRC meetings. I only did so
when I had a specific concern regarding the high-level legal or financial
approaches, picked up from GE briefings or reading the papers.
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Audit, Risk and Compliance Committee
48. Throughout my time at POL, I attended but was not a member of the Board's
Audit, Risk and Compliance Committee (“ARC”). The ARC was chaired by and
made up of NEDs, with a preference that the Chair and one other member
would have financial experience. The number of meetings varied according to
need, for example, how many discussions were required to finalise the Annual
Report & Accounts (“ARA”).
49. The focus of the ARC was the financial and risk management of POL. It would
appoint and receive plans and reports from the external auditors (EY and later
PWC), meeting them without management on a regular basis. It would review
the ARA and discuss adjustments and disclosures with the business and the
external auditors and make recommendations to the Board. It would agree the
Internal Audit plan which was updated regularly (see for example Post Office,
Minutes of a meeting of the Audit, Risk and Compliance Committee on 25
March 2015 POL00026719), meet the head of internal audit without
management on a regular basis, review internal audit reports and assess the
completeness of actions.
50.The ARC reviewed compliance with laws and regulations and POL’s approach
more generally, for example considering the 3 lines of defence identified by the
Risk and Compliance Executive committee (“RCC”) at a meeting on 1 May 2015
(Risk and Compliance committee meeting 1 May 2015, POL00227870).
51. The ARC would also approve policies, assess the financial reporting controls
with a focus on maintaining and testing that those controls were operational and
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52.
53.
54.
55.
56.
valid (see, for example, the Audit Risk and Compliance Committee on 10
November 2015, POL00110251), and consider specific issues of concern.
The ARC had a relationship with the Department's Audit Committee.
The ARC saw minutes and would receive regular reports from the RCC (full
detail on this committee below from paragraph 66) and updated the Board after
each meeting.
Due to the size of POL as a business and the various areas of potential risk, the
ARC also considered issues such as IT, Cyber-Security, Disaster Recovery,
Business Continuity Planning and the Whistle-blowing processes. These are set
out in detail in the Agendas and Minutes, but I do not directly reference them
here as they are general background to the issues to be considered by the
Inquiry.
Overall, I found that much of the work completed by the ARC and RCC was
sensible and challenged key issues. Carla Stent, who was the Chair for much of
this period, was diligent, hardworking, patient and considered.
However, with hindsight I feel that the ARC did not tackle the evidence
underpinning the performance of Horizon nor meaningfully consider the
potential outcomes for Postmasters if there were issues with shortfalls and
balancing. Postmasters are rarely mentioned in the documents and are treated
as a third-party rather than an integral part of the business.
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57.
58.
59.
Where issues were reviewed it was therefore through the lens of POL’s own
financial outcomes. For example, in the minutes from a meeting on 20 May
2015, the ARC focused on Postmaster debts and whether there was sufficient
narrative on the costs of Sparrow, rather than whether these matters were being
resolved satisfactorily (Post Office Limited Audit, Risk and Compliance
Committee minutes of 20 May 2015, POL00021433).
During 2016 this pattern continues in the documented minutes from meetings,
with limited or no focus on Horizon or Postmasters (POL Audit, Risk and
Compliance Agenda 17 March 2016 POL00240662) and (Post Office Audit Risk
and Compliance Agenda 19 May 2016, POL00103188).
It may have been the view of the ARC that issues of Horizon and Postmasters
were being managed through the Chairman's Review and the preparation for
the GLO. However, even if that was the case, the issues relevant to the Inquiry’s
terms of reference should have been embedded in the internal audit, risk
management and ARC agendas.
Pensions Committee
60.
In 2015, I attended Pensions Committee meetings which met to discuss the
future of the Pension Schemes and meetings of the Financial Services
Committee (“FSC”), both chaired by a NED. The purpose of the FSC was to
provide oversight into the performance of our financial services businesses. I
think that both were dissolved in September 2015, with most of their duties
transferred to the ARC or to Post Office Management Services Limited
(‘POMS’).
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Post Office Management Services Limited
61.
I was appointed to the Board of POMS on 31 March 2015 after being approved
by the Financial Conduct Authority. POMs was the entity set up to manage the
Insurance business, including its proposed acquisition of the Bank of Ireland's
share in the joint venture that was managing Insurance up to that point.
Subsequently, independent NEDs were appointed and I resigned from the
POMS Board on 30 October 2015.
The Group Executive and its Committees
62.
63.
The Group Executive (“GE”) is the most senior leadership team accountable to
the Board for the day-to-day operations of POL, and for delivering performance
measures against corporate objectives agreed with the Shareholder, as set out
in the GE Terms of Reference 19 February 2015 (Terms of Reference for POL
Group Executive, POL00362165). The GE was chaired by the CEO and
comprised her/his senior team. The GE could also be referred to as the
Executive Committee or ExCo. Most of the executives recruited into the GE had
a consistently commercial background.
My recollection is that around 2015 or 2016, delegated authorities were
changed. The GE team could only approve matters up to a value of £5 million, a
relatively small amount given that contracts might be multi-year, whereas
previously it had been £20 million. Delegated authorities were invested in
individuals not committees, so the CEO held £5 million, the CFO £4 million,
other GE members £2m and so on. As a result, any Commercial or Retail
decision of more than £2 million had to be made by the CEO. This meant that
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64.
65.
66.
67.
the GE was not formally delegated to and tended to discuss what the CEO
determined that it should.
The structure of GE meetings varied over time. Typically, there would be a
monthly decision-making meeting. Specific meetings were sometimes
scheduled to review performance or strategy. From 2019, the GE also had
tactical meetings that took place most Mondays to support the CEO’s
understanding of what was happening in the business.
The GE agendas focused on commercial matters and delivering the IT agenda,
with verbal updates on Sparrow in 2015 and later the GLO.
Risk and Compliance Committee of the GE
The Risk & Compliance Committee (“RCC”) of the GE met 5-6 times a year. It
was chaired by the General Counsel until March 2019 and then by myself in my
role as CFO. I was a member throughout. It was typically attended by senior
colleagues from across the business, the Financial Controller, the Head of
Internal Audit, the Head of Risk Management and the Head of Compliance.
The RCC’s purpose was the Executive assessment of audit, control and
compliance issues and performance. Unlike the ARC, it did not focus on the
external audit or the approval of the Annual Report & Accounts. Typically, it
operated ahead of ARC meetings to ensure that issues flagged to ARC had
already received Executive attention.
Operations
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68. POL’s governance over operational performance varied over time. In 2019-
2020, Operations was a formal Committee of the GE. At other times
performance was managed by individual Executives, including myself, Dan
Zinner and Martin Roberts.
69. Operations responsibilities included Support Services to provide effective back-
office support to the POL branch network (“the Network”) and central functions
to enable Postmasters to run Post Offices as successfully as possible. There
was a consolidated site at Chesterfield for Support Services which included
customer helpline staff and Branch & Customer support teams as set out in the
GE Agenda Monthly Update on 16 May 2016 (Group Executive Agenda Post
Office re: Monthly Update (Report P12 Flash Results to GE) by lead Chris Broe
/ Angela Van Den Bogerd, Radha Davies, Kevin 16 May 2016, POL00154004).
70. The formal Operations Committee met 6 times in 2019-2020, focusing on the
management — quality, service and cost — of treasury, cash, costs, IT, Network
and Postmaster support, loss prevention and security.
Improvement Delivery Group
71. In February 2021, a GE Sub-Committee called the Improvement Delivery Group
was formed, chaired by Dan Zinner, to ensure POL was delivering improvement
actions resulting from the GLO.
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Reflections on Governance
72.
73.
74.
75.
76.
I have commented on the various governance and leadership structures of POL
at different times during my employment. By March 2023, the General Counsel
wanted to appoint an independent third party to review POL’s Governance as
part of our work for the Inquiry.
My reservation in starting this work immediately was that, in my opinion, our
governance was flawed, and it might be better to first try and fix key issues.
Nick Read asked myself, the General Counsel and the Strategy Director to
share our views on the key issues by email, which we did between 23-26 March
2023 (Email RE: The robustness of our governance 26 March 2023
POL00423699).
My response set out my concerns relating to the Board, the lack of clear
oversight of the Retail directorate, the absence of governance over the Horizon
replacement, the lack of work being undertaken on how the end-to-end
processes to manage the financial relationship with Postmasters would work
after Horizon, and the lack of executive engagement and ownership of the
agenda of the HRC.
Akey lesson from Horizon and the Postmaster remediation activity was that
‘Horizon’ was not simply the operation of the software but the end-to-end
processes that managed the relationship with Postmasters, needing better data,
more transparency and clear, agreed processes and outcomes. No one was yet
working on how to design this.
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77.
78.
Colleagues did not dispute my views, rather suggesting their own priorities and
additional topics. Nick indicated that his focus was the quality of his team and
that decision-making should be better distributed across the business.
When I became ill in May 2023, the governance was therefore, in my view, less
effective.
Chief Financial Officer Role in 2015
79.
80.
81.
82.
From 2015-2018, Paula Vennells replaced a significant part of the Executive
team that she had formed when the business became independent. Jane
MacLeod (General Counsel) and I joined in early 2015, following lengthy
recruitment processes which in my case had to be signed off by the Department
and the Treasury.
I note Paula’s explanation in the CEO’s Report January 2015 (CEO’s Report
January 2015 - POL00219395) that the GE would now be operating more
strategically. At the time she distinguished between the GE which met monthly
to consider strategic issues and an Executive team meeting, focused on
performance, which also included the Chief of Staff, the ClO, the Chief
Marketing Officer and the Communications Director.
My understanding at the time of my appointment was that Paula wanted a CFO
who would provide her with support in improving the business.
I was enormously excited to join POL. I wanted to work for a company that
mattered, and Post Offices mattered enormously then as they do now. I wanted
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83.
84.
85.
86.
87.
to learn, to add value and to work with a team that had a real sense of urgency
to improve the long-term sustainability of Post Offices.
It became clear to me after joining that POL faced a number of potential
existential threats from the age and weakness of its IT, from its financial
arrangements (including commercial challenges) and in protecting cash (see
further from paragraph 92).
The core role of any CFO is to make sure the numbers are right. I understood
that my most important value-add beyond that was to help improve the
commercial performance of the business.
My first Finance Director roles had been in British Gas from 2006-2012 where I
had been a part of a team that had improved the profitability of the businesses
while also improving customer service and reducing customer losses. This
required some material cost reductions as one part of a wider set of changes.
Cost was an important element but only one element of that transformation.
As far as I can recall, when I was recruited to POL my understanding was that
POL had some similar needs to British Gas. The commercial performance had
to improve and reducing costs was an important element of that, but not the
only element. I recall that there was already an existing cross-POL cost
reduction programme underway when I joined, although it did not then report to
the CFO.
In terms of my broader role, in 2015, I was also asked to take on executive
accountability for IT and for Supply Chain. I explained that I had no IT
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experience or expertise but was assured that the ClO would provide that. My
role was to help manage the Board relationship and the non-technical side of
the ClO’s role. This included support with implementing an IT strategy to
transition the business away from disparate legacy IT systems (CEO Report
January 2015 POL00219395).
FINANCIAL SITUATION AT POL
88. The financial situation at POL, its operational drivers and the evolving rules it
has to follow have had and continue to have a profound impact on the matters
being investigated by the Inquiry.
Overview
89. I described the financial situation of POL as a newly independent business in
the NFSP Conference — key note speech Monday 15 April 2019 11am-11.45
(POL00270665) as follows: “The business we inherited was failing and
completely dependent on getting huge amounts of Government support every
year - £400 million in our first year of independence alone. We were losing £115
million a year from our trading, the IT estate was large, expensive to run, old,
insecure, vulnerable — and still inside Royal Mail. Our owned shops were deeply
loss making and many of our agency outlets couldn't support the people who
ran them and worked in them. Many had opening hours that were 9 - 5 Monday
to Friday which was wrong for customers. Our culture within POL was too often
that of a victim: everything was worse than it used to be, it was all someone
else's fault and nothing could be done’.
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90. During the keynote speech, I also explained that “until recently our accounts
showed that if we bought an asset — a computer or property.... We had to write
it off the day we bought it. Because our financial future was considered so
insecure, no one could reasonably assume we would still exist in a few years’
time” (POL00270665).
91. Although losses were reducing by 2015, the fundamental situation was the
same. Our task was to use HMG money to improve the business. An
independent Post Office should maintain a national network of Post Offices. By
improving its performance, it should create enough profit from trading that it
could pay for its maintenance and change programmes. This would be
“commercial sustainability’, enabling reducing financial support from HMG.
92. From 2015, POL continued to face a number of existential threats, the outcome
of which would determine the future of Post Offices. These drove management
attention and focus in three key areas:
e IT. While the systems were considered to be operating effectively, they
were also old, vulnerable, expensive to run and hard to change. IT
management had to be separated from RMG through new third-party
arrangements.
e Financial arrangements. Significant HMG funding would continue to be
needed to keep Post Offices operating and delivering the social purpose.
Retaining support was dependent on funding being reduced over time:
POL had to improve its commercial performance.
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93.
94.
95.
96.
e Protecting cash. A significant amount of POL’s business is conducted in
cash, which has increasingly become a product in its own right. Ensuring
that cash was used or recoverable was essential to POL’s business
model.
The IT landscape was a critical element of and threat to POL’s financial position
and survival following independence.
By the time I joined in 2015, the POL Board had concluded that its IT was old,
under-invested and vulnerable. POL’s IT had always been provided by RMG but
following independence, new, separate third party support structures had to be
put in place by March 2016.
There were a number of concerns regarding Horizon, the “Front Office” IT
system. It was dependent on physical data centres which were old and needed
continuous investment. It was time-consuming and expensive to change. The
contract with the system's provider, Fujitsu, was very expensive. It was slow and
expensive to extract data from it. At the same time, it was still understood to be
operating effectively as set out in paragraph 146 below.
Recognising the vulnerabilities and the high costs of service, the Board had
launched a series of material, competitive IT tenders, splitting the estate into
Equipment, Networks, Back Office, an Integrator role and Front Office. These
tenders were largely complete when I joined. Failing to deliver these IT system
changes threatened POL’s ability to trade and were my areas of IT focus, as the
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Executive accountable for IT, in 2015 and 2016. Most of the contracts landed
successfully, although the integrator role was later insourced. The separation
from RMG was managed, just in time.
97. In 2015, the Equipment contract was won by Computacentre, the Network by
Verizon, the Back Office systems by Accenture and the integrator role by ATOS.
98. POL appeared to have assumed that Fujitsu would win the Front Office contract
as only Fujitsu knew how Horizon worked, it owned the intellectual property and
Fujitsu owned and ran the data centres that supported it. However, Fujitsu
withdrew from the tender, apparently on the grounds that they did not expect to
win.
99. IBM won the Front Office award in 2015 and was contracted to create a more
modern version of Horizon, independent of Fujitsu. However, we had concerns
about the risks of Fujitsu’s exit which were discussed in the Board Meeting on
28 January 2015 (Meeting minutes: minutes of Board meeting held on 28th
January 2015, POL00021531). During this meeting the Board sought
independent assurance of the new Front Office system’s integrity and security.
100. The CIO and I identified early into agreeing the new Front Office contract with
IBM that we could not confidently expect to complete the re-build of a Horizon
equivalent with a new supplier by the time the Fujitsu contract ended in March
2017.
101. Michael Keegan from Fujitsu had also been issuing warnings over our ability to
get the work done in time for Fujitsu’s planned exit, and it was vital that POL
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102.
103.
protected the continuity of operational service in the event that the new Front
Office services were not ready in time. I therefore led the arrangements to
secure an extension to the Fujitsu contract and between March and May 2015, I
corresponded with Michael to agree a 1 year extension on the IT contract and 3
years on Telco. I acknowledged in this correspondence that we were in
agreement with Fujitsu that we had no other practical alternatives. (Email from
Alisdair Cameron to Michael Keegan and cc’d Steve Clayton and Ruth Phillips
re: RE: Fujitsu and POL 15 May 2015, FUJ00175204).
On 20 May 2015, Michael Keegan was provided with a briefing paper before
meeting me (Briefing for Meeting — Alisdair Cameron (Chief Financial Officer at
Post Office) 20/05/15 V1.0 — By: Mark Phillips, FUJ00175206). I had requested
that POL and Fujitsu work on the IT and Telco extension agreements together.
My recollection is that I did this because our view was that Fujitsu were more
willing to extend the Telco agreement, which is supported by the relative amount
of detail in this paper.
On 21 May 2015 during a Board meeting, when the new contract with IBM for
Front Office was agreed, we recommended that the Fujitsu contract be
extended by 1 year to ensure operational continuity (Memorandum for POL
Board from Lesley Sewell, Kevin Gilliland and Alisdair Cameron — Front Office
Contract Award to IBM UK Ltd and Fujitsu Horizon 21 May 2015,
POL00027278). However, the Board did not agree to the extension due to cost
concerns and asked the Front Office steering group to explore options to reduce
the capital investment.
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104.
105.
106.
It was also noted in a Memorandum for the Board on 29 June 2015, which
recommended an extension to the Fujitsu contract to ensure continuity of
service, that when the new IBM software was rolled out, any suggestion that
branch accounting was not right would delay the implementation of the new
system (Memorandum for the Board of Post Office Limited from Alisdair
Cameron — Fujitsu Extension Option by Al Cameron 29 June 2015,
POL00027309).
During a Board meeting on 7 July 2015, the Board was still reluctant to support
the proposed extension to the Fujitsu contract, not least because the cost of the
works to be done in the data centres (which housed Fujitsu’s software) to
ensure they could be maintained until March 2018 would be significant (POL
meeting minutes RE Fujitsu contract extension with handwritten annotations 2
July 2015, POL00027239).
However, continuity of service in branches was POL’s greatest concern and a
plan that assumed (a) that a major IT programme would complete on time and
(b) that service could be maintained without up-front investment was considered
to be an unacceptable level of risk. The Board therefore resolved to extend
Fujitsu’s contract as a contingency against delays in implementing the new IBM
contract.
Scrutiny of Horizon
107.
Rather than any particular scrutiny of Horizon, in my first few weeks at POL the
Board received updates on Sparrow, branch improvements and there was
discussion of the response to queries by forensic accountants Second Sight
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Support Services Limited (“Second Sight”) (see further from paragraph 156).
The engagement of the CCRC in respect of the past prosecutions and
convictions of Postmasters was also a topic of discussion. These areas are set
out in more detail in the minutes from those meetings on 28 January 2015
(Meeting minutes Board meeting 28 January 2015, POLO0021531) and in the
agenda for the meeting on 12 February 2015 (Post Office Ltd Group Executive
Agenda, meeting to be held on 12th February 2015, POL00220849).
108. As set out in the POL GE Agenda for the meeting on 12 February 2015
(POL00220849), the branch improvements paper and Second Sight responses
paper were reassuring, and shortfalls were concluded to be the result of
Postmaster error. Horizon was considered to be robust, and there was no
reason to question the convictions of Postmasters. However, with hindsight, it is
deeply uncomfortable to see the ease with which Postmasters were found to be
at fault when issues arose.
109. In the Post Office Limited — Post Office Board Agenda dated 25 March 2019
(POL00103479), there is a reference to “Privileged Reading Room materials.
Draft Deloitte report on Horizon (January 2018)” and “Summary of previous
reviews.” I do not recall seeing these documents or these references to them,
which may have been prepared for the Chairman. I describe my involvement
with Deloitte’s work from paragraph 259.
110.1 continued to accept the premise that Horizon was fundamentally robust both
because experienced Postmasters had expressed that view to me and because
I did not see how, given the number of transactions flowing through the system,
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111.
systemic problems would not be operationally and financially overwhelming to
the business. At the time I only interpreted Horizon to mean the software, and
POL did not have a broader consideration of the processing and data issues
which could leave a Postmaster with unexplained shortfalls.
With hindsight I would now conclude that insufficient scrutiny of Horizon was
undertaken before finding Postmasters to be at fault for unresolved shortfalls. I
also acknowledge that even as we sought to answer questions on the safe
working of Horizon as it operated at that point, this does not mean it operated
effectively in earlier periods. I also question the conclusion that Postmaster
training was fundamentally sound. In 2017, when I was more involved in
Operations, I attended a 2 day training course for new Postmasters and did not
consider it to be a strong basis to support Postmasters. I later chased for
improvements as a result of this.
Financial Arrangements
112.
113.
POL is supported financially by HMG which provides: a borrowing facility to fund
the cash held by Post Offices; Cash backed support through the Bank of
England’s Note Circulation Scheme; Investment Funding for material projects
like Network Transformation and a broader change programme of multiple
investments. HMG also provides Network Subsidy Payments to enable POL to
retain unprofitable branches that were necessary to the social purpose.
The social purpose is captured in two critical metrics. The first is that while
individual Post Offices will open and close over time, there should always be at
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114.
115.
116.
117.
118.
least 11,500 UK locations open. The definition of a Post Office location has
changed over time.
Secondly, locations must be distributed across the UK and cannot be focused
solely on high population areas. This is calculated according to a formula set by
HMG, encompassing a number of measures.
POL cannot borrow from anyone other than HMG without specific permission,
except for standard commercial undertakings such as leases.
The rules and definitions governing these agreements could and did change
over time, often at the point at which new Funding agreements were put in
place. The focus in 2015 and 2016 was to ensure that I and the Board properly
understood the facilities and their rules and that there were processes in place
to oversee them. The committed facilities were and remain critically important to
POL’s annual assessment of whether it is a Going Concern.
Government support was expected to reduce over time as POL’s commercial
performance improved. This was my core focus after ensuring that the financial
reporting was becoming more robust. The Board decided to focus on our
Trading Profit or EBITDAS. This focused the Executive on its own performance
and could be derived from the audited ARA, making it less subjective.
Commercial improvement was driven in three areas: gross margin; Postmaster
remuneration and POL’s own costs.
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119.
120.
121.
122.
123.
124.
Improvements in gross margin such as re-negotiating contracts with Clients
were off-set by digital competition and the decline in Government services.
Postmaster remuneration is accounted for as a cost, POL’s largest cost. The
strategy was to reduce fixed pay elements, focusing on variable remuneration
that also supported POL’s income.
When I joined, POL was significantly missing the revenue targets in its original 3
Year Plan. The resulting shortfall in gross margin was substantially mitigated for
POL by the fact that variable Postmaster Remuneration was also reduced. That
helped POL meet its targets. The business model, treating Postmaster
remuneration as a cost, creates a direct trade-off between POL’s financial
targets and Postmaster Remuneration, which was generally resolved in POL’s
short-term interests.
Reducing POL’s own costs was a significant focus for management, often
overseen by me, for several years.
Cutting the staff and non-staff costs of POL, as opposed to Postmaster
renumeration, was an act that was supportive of Postmasters. Any Postmaster I
have discussed this with over the years has considered POL to be too
expensive and bureaucratic and wanted to see those costs cut, increasing their
potential share of available profits.
Nonetheless, money could have been spent radically improving the
management of Horizon and the management of shortfalls. Our focus on POL’s
commercial performance meant that this was not a priority.
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Protecting cash
125. Much of POL’s business is conducted in cash and increasingly under
agreement with the banks, the ‘Banking Framework’, enabling customers to pay
in and withdraw cash.
126. Given the security risks, POL provides the cash, borrowing money from HMG,
taking it in and out of Bank of England vaults and delivering it to and picking it up
from Post Offices.
127. Postmasters are therefore trusted with very significant amounts of cash and
POL’s business model and ability to manage taxpayers’ money is dependent on
being able to determine how that money was used and to recover it if
appropriate.
128. POL has a view of what cash, stamps and lottery tickets a Post Office should
hold and asks Postmasters to regularly confirm the cash holdings they have by
counting (cash declarations) and reconciling the information (balancing).
129. However, POL found it difficult to extract and interpret detailed information over
a period of time from Horizon, had a limited competence in understanding how
branches worked and felt that it could not know what had happened in a branch.
130. Accordingly, POL took the view that the Postmaster was accountable for what
happened in the branch. If there was less cash than POL thought there should be
(‘a shortfall’), POL’s position was that the Postmaster was accountable for that
shortfall.
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131. Postmasters were therefore asked to pay for the shortfalls in accordance with
POL'’s view of their contracts. If unpaid, the balances were classified as debt.
This was provided against — written off to the Profit and Loss account - after 60
days, but maintained as an amount owed by that Postmaster. A rising trend of
unpaid shortfalls therefore hit the Profit and Loss account and EBITDAS very
quickly.
132. My Operations priority from 2017 was to look for ways to stop that cost
escalating. This would protect Trading Profit and the business model: POL trusts
Postmasters with hundreds of millions of pounds every day and if it does not get
the cash back from the Network, the business model fails.
133. To that end we sought to better identify branches with symptoms that suggested
a shortfall might exist. We could then count the cash, believing that a shortfall
was more likely to be resolved if it was found when smaller. However, we did not
spend sufficient time scrutinising what might be the cause of the shortfall.
134. In 2019 and 2020 better work was done seeking to proactively identify branches
that were not balancing for a period, or which had visible issues on their
accounting for stamps.
135. My feelings remain that these more innovative ways of helping Postmasters not
get into difficulty, rather than focusing on recovery after the event, could have
been instituted many years earlier and created better ways of working and
greater learnings. Unfortunately, the drive for profit meant that we focused on
what was material to us, not what was material to a Postmaster.
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136.
137.
138.
139.
With people changes and the pandemic, together with the uncontrolled
introduction of a dispute button into Horizon after the GLO, improvements to the
shortfall process went into reverse in 2021 and 2022, with the profit and loss
account charges increasing.
In 2022 the Retail directorate considered that they were undertaking
investigations into shortfalls which were not then leading to repayments by
Postmasters and that some sort of legal clarity would be needed, perhaps
triggered by deducting repayments from remuneration (Doc:
POL_GE_Postmaster Losses 16 November 2022 POL00423917and Doc:
POL_GE_Postmaster Losses 25 January 2023 POL00423921)
On 24 January 2023, I summarised my views briefly to Nick Read and Ben Foat
(Email Re: Losses 24 January 2023, POL00423698) listing the significant steps
we would have to go through before we could feasibly reclaim shortfalls from
Postmasters. In addition, even if those steps were completed satisfactorily, I did
not believe that we could practically recover shortfalls from Postmasters through
a legal process while we were still using Horizon, given its reputation.
We engaged EY to help us assess the position with investigations of shortfalls
in branches. On 11 April 2023, I summarised my understanding of their work to
that point; “it does seem that the financial cost [of shortfalls] is driven by our
inability to successfully complete investigations and not on our ability to collect
established losses. Is that fair?” (Email RE: Branch discrepancies — Findings
and recommendations 11 April 2023, POL00423700)
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140. There therefore remained a fundamental lack of clarity on the reasons for
branch shortfalls, making any fair resolution impossible. It is my view that POL’s
business model cannot continue sustainably unless this is resolved whether
using Horizon or its replacement.
POL’s current financial position
141. While the decision that POL must fund the costs of the Inquiry and
compensation schemes was politically and emotionally logical, there is really no
POL money that is separate from taxpayers’ money.
142. POL is financially incentivised to pay compensation quickly and generously
(HMG pays the compensation) but the processes to which it has to adhere to
receive that payment are bureaucratic and complex, which slows compensation
and increases its overall cost.
143. In accounting terms, where POL states that compensation will be payable, it
converts a contingent liability into an actual liability. If it does so without having
HMG funding in place, it cannot afford to pay for that liability and could be
wrongfully trading, an offence which would change the basis on which the
business can be run.
144. In a set of email exchanges between 12 and 16 May 2023 the relationship
between funding and timing is set out (Email RE: “Question” 16 May 2023,
POL00423920). I was arguing that the resulting delays are unacceptable.
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145.1 also drew attention to my concern about monthly deductions from Postmaster
Remuneration to cover shortfalls, which had been agreed with Postmasters in
earlier years during periods when proper investigations into the shortfalls had
not been done: “it took us so long to stop taking the payments. I cannot find an
argument that I would be prepared to make in public or private that says we can
hold on to the monies paid since 2019, unless we have done the same checks
as we did for the small population still paying. And of course HSS [Horizon
Shortfall Scheme] does not apply for this period”.
MEDIATION (2015)
146. In 2015, POL was confidently communicating the position that there was no
evidence of any faults with Horizon, or unsafe convictions, nor had any
convictions been appealed: “To date, we have found no evidence, nor has any
been advanced by either an Applicant or Second Sight of either faults with the
Horizon system or unsafe convictions and no convictions have been appealed.”
(CEO’s Report Jan 2015, POL00219395).
147. While POL acknowledged that there were instances where it “could have done
more” to assist applicants to the scheme, such as intervening earlier when it
became clear branches were experiencing losses, POL was steadfast that it was
the actions of the applicants themselves which had caused or contributed to the
losses suffered (CEO’s Report Jan 2015, POL00219395).
148. My understanding at the time was that the Board had initiated the mediation
scheme with good intentions and a significant amount of work had been done
even though POL was unequivocal in its position as set out above. I therefore
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accepted that the criminal trials had been fair: it did not occur to me that
important material had been withheld from the defence during prosecutions.
149. The CCRC had requested papers on a number of prosecutions without, to my
knowledge, feeling any need to intervene. It was not until Brian Altman QC (as he
then was) stated that there might have been miscarriages of justice in 2020 that I
changed my position.
150. I had little engagement with the Mediation Scheme when I joined POL, as it came
to an end shortly after I joined as CFO. There was a Sparrow Sub-Committee
meeting on 12 January 2015 which I did not attend, although I may have read the
papers at the time, and I did attend its final meeting on 18 February 2015.
151. The 18 February 2015 meeting of the Sparrow Sub-committee discussed that
the mediation scheme was failing and there was likely to be an unbridgeable
gap between the parties.
152. The proposal of the Sparrow Sub-Committee was to continue to mediate and
engage with Second Sight on individual cases, but end both the existing
mediation scheme and the broader Second Sight engagement.
153. In email correspondence in March 2015 between myself, Alwen Lyons and
others I agreed to support the proposed approach (Email from Alisdair Cameron
to Alwen Lyons, Neil McCausland, Virginia Holmes and others cc Alice Perkins,
Alasdair Marnoch, Richard Callard and others RE: Sparrow paper for the Board
- Action required 3/3/15, POL00138860). I considered that it was possible that
this decision to end the mediation scheme could “trigger’ a reaction from
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154.
155.
Parliament, the media or in the courts, however this was likely to be inevitable in
any event and therefore should be faced.
One of the options put forward by the Communications Director (Mark Davies)
in email correspondence in relation to the mediation scheme in January 2015
was that POL provide £5,000 funding to each applicant to the scheme which
could be used for legal advice. I indicated that I was content to consider that
option (Email from Paula Vennells to Mark R Davies, Alisdair Cameron, CC
Gavin Lambert and others re: Sparrow - An idea at pace! 15 January 2015,
POL00218860).
I do not recall that anything further happened in relation to this proposal, but the
feeling that the gap between the parties was so great that it needed to be
resolved in the courts was what I understood to be the guiding principle of
POL’s subsequent legal strategy.
SECOND SIGHT (2015) - SUSPENSE ACCOUNTS
156.
157.
Suspense Accounts are a common accounting practice, creating an account on
the balance sheet where unresolved transactions can be held while work is
going on to resolve them. In my experience, credit balances (amounts due to
someone) typically arose because a former customer could not be identified or
located, making it impossible to pay them an amount due. After a period, that
credit would be released as profit.
Such credit differences typically arose in POL where Horizon records created by
branches showed an amount payable to a Client greater than the Client
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believed it should be, or an amount due from a Client less than the Client
believed it should be.
158. Of relevance to this and subsequent sections of my statement, Second Sight is
a firm of independent forensic accountants and investigators appointed jointly
by a small group of MPs and the Justice for Subpostmasters Alliance (“JFSA”)
in 2012 to conduct an independent investigation into Horizon. They were
contracted by POL who supported the appointment. Second Sight issued
several reports in respect of their investigations. The key one for the purposes
of my statement was the Briefing Report — Part 2 which was finalised on 9 April
2015 (see later from paragraph 178).
159. On 15 January 2015, very soon after I joined POL, I was asked by Chris Aujard,
Interim General Counsel and others for urgent help to answer questions from
Second Sight on the operation of POL’s Suspense Accounts (“SAs”).
160.1 was provided more detail in email correspondence following a Working Group
meeting of the Complaint and Mediation Scheme (Email from Rod Ismay to
Peter Goodman Re: suspense accounts 15 January 2015, POL00351276). In
summary, Second Sight were asking how much was absorbed into POL’s Profit
& Loss account from suspense accounts each year, and how much of that
related to money which was or could be properly due to Postmasters.
161. The following day, Chis Aujard sent me a separate request. He was seeking
someone who was “technically switched on re suspense accounts” and who
could “handle themselves in front of an adversarial audience”. Chris set out that
he was “concerned we give Second Sight no more information than is
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162.
163.
164.
165.
necessary...” (Email sent from Mark Underwood to Belinda Crowe and others,
re Suspense Accounts on 19 January 2015, POL00040805).
I responded on the same day by email to confirm that Rod Ismay who led the
FSC, was the right person to handle the queries from Second Sight.
I indicated that I was inclined to be open with Second Sight in response to their
queries and that Rod should be adequately prepared to answer potentially
hostile questions (reflecting the language of “adversarial” that Chris Aujard had
used) (Email sent from Mark Underwood to Belinda Crowe and others re:
Suspense Accounts, 19 January 2015, POL00040805).
Chris Aujard proposed a slightly slower timetable for POL to respond
substantively to Second Sight’s queries, while I was starting to get up to speed
with the issues raised (Email from Chris Aujard to lan Henderson cc Belinda
Crowe, Tom Wechsler, rjw RE: Meeting with Finance Team 20 January 2015,
POL00310758). This approach was approved by Paula (Email Belinda Crowe to
Paula Vennells 20 January 2015, POL00109892).
Shortly after these discussions, I saw a draft response to Second Sight, which I
was not dealing with directly. On 27 January 2015 I wrote to Chris Aujard and
Jane MacLeod that the response needed to be more comprehensive and data
driven (Email from Chris Aujard to Alisdair Cameron, CC Andrew Parsons and
Tom Wechsler and others re: FW: Suspense accounts - legally privileged -
urgent [BD-4A.FID20472253], POL00220084). I also sought confirmation, which
I received, that Second Sight were only interested in credit balances in SAs and
not branch accounts, to ensure that we were answering the right questions. This
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166.
167.
168.
169.
was an important clarification for me because shortfalls in most cases were
recorded in branch accounts between POL and an individual branch, not in the
SA.
In response to my comments, Andy Parsons from our external legal advisors,
Bond Dickinson, replied to Chris Aujard that in his view providing too much
information to Second Sight would “encourage further fishing’. I continued to
provide my comments on the draft paper to improve our response to Second
Sight’s queries (Emails between Paul Lorraine, Alisdair Cameron, Andrew
Parsons and others 29 January 2015, POL00021829).
On 28 January 2015, following a discussion, Jane MacLeod wrote to me setting
out a suggested strategic approach to the mediation scheme and Second Sight
more broadly, including how to move forward. This correspondence
demonstrates that the two of us were open at that time to providing funding for
investigations, possibly to be carried out by Second Sight, to manage the
reputational risk of proposals to end the mediation scheme (Email from Jane
MacLeod re Sparrow 28 January 2015, POL00311251).
Chris Aujard sent the response to Second Sight on 30 January 2015, and it was
copied to me on 2 February 2015.
I also provided comments on a note from Second Sight which listed their areas
of focus. I said that we had to listen to their concerns but that we should seek a
clear distinction between areas where Second Sight had evidence of an issue
and those where they speculated could be an issue (Email chain including Tom
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170.
171.
172.
173.
Wechsler, Alisdair Cameron, Avene O'Farrell and others 29 January 2015
POL00150989).
I agreed to brief Paula Vennells following a meeting with Second Sight
regarding SAs on 2 February 2015 before she went before the Select
Committee for an evidence session on the mediation scheme on 3 February
2015.
On 9 February 2015 I was asked to provide comments on a draft paper for the
Sparrow Sub-Committee by the Communications Director. My comments were
that the tone of the paper was negative and could disconcert the Committee. I
suggested allowing Second Sight to finish their work and to continue to work
with them positively on the issue of SAs (Email from Mark R Davies to Alisdair
Cameron cc'ing Jane MacLeod RE: Urgent - paper for sub committee 9
February 2015, POL00130857).
I continued to engage with the requests of Second Sight throughout February
2015, liaising with POL’s FSC team and considering options such as following
individual branch cases through to provide satisfactory answers to their queries
(Email RE: Suspense - independent firm - scope & procedures drafts. Including
Suspense - Scoping doc for Independent review and Suspense agreed upon
procedures attachment 12 February 2015, POL00312064).
I also prepared a draft response to Second Sight for the team to work on
following the meeting on 30 January 2015, enclosing data and with further
explanation regarding SAs (Suspense Update to SS Letter from Alisdair
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Cameron to lan 12 February 2015, POL00312085). The final letter was sent on
13 February, suggesting a further meeting with Second Sight.
174. On 27 February 2015 Belinda Crowe, another departing member of the Legal
team, reported back following a conversation with Second Sight (Email from
Belinda Crowe to Alisdair Cameron and others re “catch up call with Second
Sight” 27 February 2015, POL00102236).
175. Her note explains that Second Sight were grateful for my positive engagement,
but that they still suggested that there were large sums of unattributable /
unreconcilable money in an unstructured account at the end of each month.
This does not reflect my recollection of the evidence we presented to Second
Sight at the time; generally the evidence from our work was, I thought,
reassuring in respect of the operation of SAs.
176. Throughout March and April 2015, there was continued correspondence
between POL and Second Sight to try and resolve their outstanding queries. I
was also asked to consider and approve wording around SAs for the Initial
Complaint Review and Mediation Scheme End of term Report V.7
(POL00040932) dated 6 March 2015.
177. My overall recollection is that I had a final amicable meeting with Second Sight,
which according to my diary took place on 4 March 2014, and the information
provided in respect of SAs was reassuring to me and, I believed, to them.
178. However, on 13 March 2015, Mark Underwood from the Legal department
emailed me and Rod Ismay stating that Second Sight had reported experiencing
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179.
180.
181.
difficulties obtaining access to evidence from POL, including detailed
transactions relating to SAs. He highlighted particular paragraphs in the Second
Sight draft report and asked for my comments on the same.
In response to this email chain (Email chain from Mark Underwood to Alisdair
Cameron cc Rod Ismay, Belinda Crowe, Andrew Parsons RE: Second Sight's
Part Two Report and assertions made in relation to Suspense accounts, 20
March 2015, POL00225156), I set out my understanding, suggesting what I
believed to be more accurate wording in respect of the highlighted sections of
the draft report and the position that had been reached. I agreed that some
numerical data on aspects of the client accounts themselves were outstanding
and confirmed that we could close this issue. I also pushed back at the idea that
released credits to the SAs were “substantial” compared to the value of the
transactions being processed.
I wrote to Second Sight on 23 March 2015 setting out POL’s position in respect
of SAs, in particular our conclusions that they were effectively controlled. I felt
that based on the knowledge I had accumulated in the last few weeks, Second
Sight should be satisfied from the information we had provided that there was
no evidence that Postmaster credits were being released to POL’s profit and
loss account inappropriately at that time.
Second Sight responded on 27 March 2015 that the information provided by
POL 9 months previously that all unmatched transactions were posted to a
single SA “was not correct’. My understanding was that this referred to
individual client creditor accounts, where transactions were recorded to be
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182.
183.
184.
185.
matched and processed. Unmatched items would initially be held there before
being transferred to the main Suspense Account. Second Sight therefore felt
more investigations were required of unmatched items in individual third-party
client accounts and they might need to look further at the main Suspense
Account (Email from lan Henderson to Alisdair Cameron, Rod Ismay, Jane
Macleod and others RE: Client Suspense Accounts — Confidential 27 March
2015, POL00313968).
I reiterated on 30 March 2015 that I found the evidence we had obtained to be
reassuring.
On 10 April 2015, I received excerpts from Second Sight’s Part 2 report from
Mark Davies who characterised it as “flawed and inaccurate.” (Email from Mark
R Davies to Alisdair Cameron, Re: Sparrow 10 April 2015, POL00102389). In
respect of SAs, he summarised that the report claimed that POL was potentially
profiting through money in SAs which could be due to Postmasters.
In response, I suggested a clarification: the large figures in SAs represented
amounts due to Clients, and not amounts that were overdue, or unreconciled
amounts which therefore could be due to Postmasters. The description in the
Part 2 report was therefore misleading. We had already explained to Second
Sight that the statistic which gave comfort was that neither account had any
unreconciled balances which were over 6 months old, meaning that transactions
had been resolved between POL and its Clients and customers.
In summary, I did not see grounds to be concerned about the operation of the
Suspense Account or the Client Creditors. If there were unresolved credit
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186.
187.
188.
transactions due to Postmasters stuck in suspense, there would be a large
balance of older items, however the two material accounts we investigated had
no balances over 6 months old. There also was no evidence from the
investigations undertaken by POL that significant credits were being released
from SAs to Profit & Loss. I do not know whether that could have happened in
earlier years, as I am not familiar with the way the SAs were operated before I
joined POL.
I was surprised and upset by what I felt to be a gap between the conversations I
had had with Second Sight, the data we had shared and their conclusions in
Part 2 of the report. My position had been to be open with Second Sight and
answer their questions properly, even though others at POL had concerns about
their professionalism and the scope of their work. Following this experience
however, I wondered if there had been a “wilful misunderstanding” (Email from
Mark R Davies to Alisdair Cameron, Re: Sparrow 10 April 2015, POL00102389).
I had very little engagement with Second Sight thereafter in respect of SAs
although I was involved in the later Deloitte reports (see from paragraph 259),
which formed part of our preparation for the GLO.
I had no animus to Second Sight. On 9 February 2022, Tim McCormack (a
former postmaster) wrote to the Inquiry and copied Nick Read, raising a concern
about the reconciliation of cash received in our cash centres. I offered Tim
McCormack the opportunity to visit a cash centre and go through our approach
with the Head of Cash Logistics to reassure him. I agreed that he could bring
Ron Warmington of Second Sight with him.
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189.
190.
Following this visit, Tim McCormack copied the Inquiry into an email on 28
March 2022 which finished by thanking me for giving him and Second Sight the
opportunity to visit the cash centre to “see and hear for ourselves the progress
that is being made.” I therefore remained open to working with Second Sight.
I have always been conscious that they continue to argue that Postmaster
credits had been siphoned into POL’s profit and loss account but I have never
been clear of the evidence that they were relying on.
EXECUTIVE AND LEADERSHIP (Second Sight)
191.
192.
193.
194.
My emerging view across my first year at POL was that the competence of the
Finance teams and the control environment were weaker than they should have
been. There were people with operational capabilities undertaking financial
roles. This was very substantially improved over time.
In the context of Second Sight, there was significant internal back-and-forth in
correspondence as the POL teams worked through Second Sight’s requests. As
I was new to the business, I was surprised that it had taken so long to provide
the information Second Sight requested, and that the default position was to
give as little evidence as possible.
The correspondence demonstrates that I generally pushed back at this, and
used my role as CFO to engage with Second Sight in completing their
investigations.
The sense I got was that there was a core group of people at POL who led the
management of the mediation and Second Sight issues for Paula Vennells,
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195.
including Andrew Parsons, Belinda Crowe, Chris Aujard, Mark Davies, Angela
van den Bogerd and over time, Jane MacLeod. They seemed convinced that
Second Sight was acting beyond the scope of the work it had been hired to do.
The position at POL was that Second Sight would seek evidence to support its
hypotheses rather than drawing proofs from individual cases and then seeking
to prove or disprove them.
Paula seemed open to the idea that we were taking too legalistic an approach in
dealing with Second Sight (Email from Paula Vennells to Alisdair Cameron re:
Mediation Scheme 30 January 2015, POL00109933). However, I don’t recall us
discussing it specifically and I assume that, ultimately, she agreed with her
team’s consensus above.
OUTREACH BRANCH REMITTANCE ISSUE (2015)
196.
197.
The Outreach Branch remittance issue was escalated following an article in
Computer Weekly. In summary, the article had described a warning issued by
the Communication Workers Union (“CWU”) to members regarding issues in
Horizon which had been sent by the POL IT Help Desk.
It described circumstances where it was possible for an operator error to
duplicate a transaction between an Outreach branch and Central hub. Chris
Broe, the Interim ClO, informed me that the issue was known about, was
relatively rare and a change had been agreed to Horizon in order to mitigate
operator errors likely to cause the problem.
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198.
199.
We agreed the lack of escalation until that point was a concern. Chris was also
determined that the Communications team discuss IT issues with him before
they responded to journalists (Email from Alisdair Cameron to Neil Hayward,
Jane MacLeod, Paula Vennells re Outreach Branch Remittances 12 November
2015, POL00153623).
I do not recall whether this correspondence was followed up or if any further
actions were taken. I do not recall whether we made any investigations into the
potential implications on Postmasters of this issue.
HORIZON ISSUE IN (2016)
200.
201.
202.
On 9 May 2016 there was a failure of Horizon which meant that a significant
number of branches were unable to enter transactions. As part of business
continuity testing, Horizon had been operating for a short period on its
secondary server and had on the previous day been brought back to its primary
server. This test was intended to give confidence (or learn lessons) in case this
was ever required after a server failure.
However, on the morning of 9 May 2016, the primary server failed, and a reboot
of the primary server was required. This was resolved 90 minutes later, by
approximately 10.30am, and there was no further disruption to service.
I provided a note to the GE on the same day summarising the issue, the next
steps and the importance of ensuring there was no adverse impact for
Postmasters such as if the outage led to incomplete or unbalanced transactions
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203.
204.
205.
(Email from Alisdair Cameron to Angela Van Den-Bogerd RE: Fwd: Horizon
Issue — urgent 9 May 2016 POL00241349)
ANED (Tim Franklin) raised a concern to Paula Vennells that the note to the
Board, which was sent late the same day, was unacceptably delayed and led to
his being updated based on media reporting (and after being questioned about
the issue by an external partner). I acknowledged this and set out the position in
respect of incomplete transactions and how they would be managed, including
that a full review of branch level transactions would be undertaken by the back-
office team. Paula supported this approach and identified that there were
lessons to be learned quickly as a result of the system failure (Email from Tim
Franklin to Paula Vennells RE: Media coverage on Horizon system failure 9 May
2016, POL00241374).
The correspondence following this incident demonstrates the actions taken by
POL. Chris Broe set out a Lessons Learned and Proposed Actions on 10 May
2016, including improved IT incident alerting, incident handling, future
avoidance and business communications (Email from Chris Broe to Mark
Davies, Paula Vennells, Kevin Gilliland and others re: Horizon Incident 9th May
2016 - Diagnosis, Lessons Learned and Actions 10 May 2016, POL00163019).
I raised our concerns with Fujitsu on 11 May 2016, given there had been a
similar issue a couple of months previously and received a response from
Regina Moran (Fujitsu relationship lead) reiterating Fujitsu's commitment to a
successful strategic partnership with POL and confirming that the root cause
would be shared as soon as it had been identified (Email from Regina Moran to
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206.
207.
208.
209.
Alisdair Cameron, CC'ing Gavin Bell, Chris Broe, and another re: Update -
doing a full investigation and working with Oracle 11 May 2016 FUJ00169083).
This was followed by a formal letter to Fujitsu written by the new CIO Rob
Houghton on 12 May 2016 setting out POL’s grave concerns regarding the
events leading up to and the handling of the service incident. I was copied into
this correspondence (Letter from Robert Houghton to Gavin Bell (Fujitsu) re:
RE: Horizon service outage incident on 9th May 2016 (“Service Incident”) 12
May 2016, FUJ00175319).
Following further internal correspondence, Paula was updated on 25 May 2016
as to progress in responding to the incident including POL’s response to the risk
of branch shortfalls as a result of the service disruption.
The correspondence demonstrates that POL took the incident seriously and
learned lessons. We were proactive in making sure Postmasters were not out of
pocket as a result of any unbalanced transactions caused by the incident.
As far as I can recall, there has been no similar service incident since, although
business continuity testing of Horizon has been limited given its age and
fragility.
INTERIM CEO 2019
210.
In late 2018, Paula Vennells told us that she was leaving POL. Her departure
date would be April 2019. It was clear that the process to replace her would take
longer than that and an Interim CEO would be required.
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211.
212.
213.
214.
215.
216.
Appointing me as Interim CEO, as agreed between the Chairman and the
Minister, was the simplest solution because I was already a member of the
Board. I agreed to serve as Interim CEO and indicated that I would apply for the
permanent role as did one other member of the management team. The role
would be also advertised externally.
In practice, I increasingly started taking over the Interim CEO role from the
beginning of March 2019
The process to find a replacement, which would be determined by HMG,
concluded in July 2019 and I was not successful. Nick Read, the new CEO, was
quickly available and started in September 2019.
We had not found a CFO replacement, so I reverted to being CFO, a role I had
never fully relinquished.
My reflections are that the outcome of the Common Issues Trial (“CIT”) and the
pressure on POL to address the issues arising from that judgment meant that
having an entirely new CEO with no previous involvement in the business was
the right decision.
My time as Interim CEO was intense and busy. In a letter to Tim Parker on 20
March 2019 the Minister set out her expectations: respond to the GLO, make
things more attractive for Postmasters and improve financial sustainability
(Letter from Kelly Tolhurst MP to Tim Parker - Re: Appointment of Al Cameron
as interim CEO 20 March 2019, UKGI00009385). On 9 July 2019 I received a
letter from Alex Chisholm (Letter from Alex Chisholm to Alisdair Cameron re:
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217.
218.
219.
Accountable person: Instruction from BEIS permanent secretary to the CEO of
Post Office Ltd on accountabilities and responsibilities 9 June 2019,
UKGI00010163).
I provide fuller detail later in my statement of the actions I took in my role as
Interim CEO in relation to matters investigated by the Inquiry (for example the
GLO). From a governance perspective, my primary concern as CEO following
the judgment in the CIT was to change our legal advisors. We appointed new
General Counsel (Ben Foat), supported by a fresh external legal team from
Herbert Smith Freehills (‘HSF”). We also changed Leading Counsel for the final
stages of the appeal against the CIT judgment. This led to a change in legal
strategy and a move to settlement.
Akey focus of my early tenure as Interim CEO, even before the CIT judgment,
was improving support for Postmasters. This was the main focus of speeches I
discussed with the senior leadership group and delivered on 15 April 2019 at the
NFSP conference (POL00270665) in which I emphasised: “We have to make it
easier for Postmasters to make more money for less effort and in a better spirit
of partnership.” This focus was given extra momentum by the NFSP survey
highlighting the risk of losing Postmasters which led my appearance at the
Business Select Committee in May 2019.
We announced higher Postmaster Remuneration and a process to review it
further, enabling a second increase later that year. This was enabled by the very
significant increases in prices agreed for the Banking Framework.
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220. During my tenure as Interim CEO, I also got involved in two more specific
branch issues that are relevant to the Inquiry.
221. At the first individual branch, they had experienced a material shortfall. I asked
the Operations team to investigate and it took a number of weeks. The reason, I
was told, was that through a period when the Postmaster was ill, a series of
temporary Postmasters had not been recording stamps in-and-out accurately.
222. Due to my concerns that the stamp recording issue could be a significant one,
and not knowing at that stage how long I would be in role, or with POL, I
reported the issue to Ben Foat, so the issue would not be lost. I informed Nick
Read when he joined.
223. This was escalated and following an independent review led to the Stamps
remediation scheme and improvements in the stamps processes. However, I
remain concerned that the ‘solution’, scanning stamps in and out of branches
and reconciling those movements to Supply Chain’s records, was still not, in
2023, either delivered or planned within the Horizon replacement programme.
224. The second issue was that I was contacted in June 2019 by Tim McCormack, a
former Postmaster, asking to speak to me. I cover this in more detail from
paragraph 409 below.
BATES & OTHERS LITIGATION
First Involvement
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225. On 18 February 2015, as the Mediation Scheme started to lose support, there
was a suggestion, in the Sparrow Sub-Committee, that a legal case was being
prepared against POL. During late 2015, 2016, I recall there being less attention
focused on these issues by the GE and the Board: the Chairman's review was
understood to be going on, although it was kept secret as legally privileged,
even from the Board; work on SAs was not making progress; and I do not recall
being much involved with the residual elements of Sparrow/Mediation.
226. In April 2016, a High Court claim was issued against POL by a group of
Postmasters and a Group Litigation Order was subsequently issued by the
Court to manage the claims in March 2017. Around 555 claimants joined the
GLO and the Court ordered that the case would be heard through a number of
trials to cover various issues. Of the trials that went ahead, the first, the CIT,
sought to answer a number of questions about the contracts of Postmasters
with POL. The second, the Horizon Issues Trial (HIT), covered questions
relating to the robustness of Horizon, both at the time of the litigation and
historical versions. Further trials were scheduled but never took place due to
POL and the Claimants coming to a settlement agreement in December 2019.
Litigation 2017 — 2018
227.1 do not recall having much personal involvement in POL’s strategy or
management of the GLO until late September 2017, when Jane MacLeod was
discussing the approach to the Case Management Conference (“CMC”), which
was scheduled for October that year.
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228.
229.
230.
231.
232.
On 22 September 2017, in email correspondence Jane summarised some notes
for a meeting arranged with Paula Vennells and the Shareholder Representative
in advance of the upcoming CMC, which would set the legal direction for the
case for the next 1 — 2 years (Email from Jane MacLeod to Avene Regan, cc
Paula Vennells and Alisdair Cameron re Litigation- meeting with Tony Robinson,
22 September 2019, POL00250703).
Key questions to be decided in the litigation included whether Horizon was
robust and whether Postmasters’ contracts were “fair” and supported POL’s
operating practices.
Having reviewed these documents recently, I do not recall the question of the
fairness of the contracts being debated internally. My recollection is that the
GLO sub-committee later discussed the apparent gap between the legal
approaches of each party: the Claimants sought a decision on fairness and POL
remained focused on whether the contract was consistent with the law.
However, I am not a lawyer and may have misunderstood this point.
Following the CMC, POL’s general case management strategy was set out ina
Steering Committee Briefing paper and agreed in October 2017 (Steering Group
Briefing Paper: Update on case management strategy meeting 4 October 2017,
POL00006462). POL’s legal strategy remained largely unchanged after the
CMC as no key additional information was brought to light.
In December 2017, Jane updated me and Paula that the Steering Group would
be asked to consider at their upcoming meeting initiating settlement discussions
for two particular groups of claimants. The advice was that there was financial
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233.
234.
235.
236.
and tactical value in seeking to settle particular issues and demonstrating POL
was willing to engage to narrow the issues (Email chain from Jane MacLeod to
Andrew Parsons and Rodric Williams, Re: Postmaster Litigation 5 December
2017, POL00024292). However, I do not recall settlement discussions being
progressed any further at that time.
Until the GLO Sub-Committee was formed in 2018, I do not recall having a
formal role in POL’s management of the proceedings. However, I was usually
copied in to notes and invited to meetings by Paula and Jane as well as
participating in Board meetings.
On 28 January 2018, Jane provided a fuller update in respect of the GLO which
confirmed that there would be a first trial (CIT) for four weeks from November
2018 to determine the correct interpretation of the Postmaster contract and
whether additional terms should be implied (Email chain between Jane
MacLeod, Alisdair Cameron, Paula Vennells and others Re: Postmaster
Litigation - Briefing notes for the Board, 28 January 2018, POL00024182). Four
weeks had been set aside for a second trial in March 2019.
Jane also set out POL’s proposed strategy including contingency and mitigation
planning, the timetable for obtaining legal advice on the merits of POL’s case
(which was to be reviewed at key stages), and a proposed security for costs
application. I was informed that two Silks had been briefed, David Cavender QC
and Anthony de Garr Robinson QC (as each then was).
David Cavender QC was asked to consider how he would approach the claim if
he was advising the claimants rather than POL and highlighted particular issues
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to POL during this exercise including the reliability of Horizon, training of
Postmasters, and SAs. We also considered the gross value of the claims,
although at that stage the allegations were unsubstantiated and there were
several variables to consider such as whether any of the individual claims were
time-barred.
237. In my reply to the GLO update, I noted that settling the claim for a moderate
amount would enable POL to move forward, and we should give this serious
consideration.
238. In March 2018, the GLO Sub-Committee was set up and I was a member. The
updates were provided to us orally. The first GLO Sub-Committee meeting in
March was largely a procedural update as to the status of the GLO. During the
May meeting we considered an opinion from our instructed Silk on the common
issues, although I have not recently seen any minutes from this meeting setting
this out.
239. In correspondence on 6 June 2018, Jane MacLeod updated us that a further
CMC was scheduled for 5 June 2018 and that the claim had been valued by the
Claimants at between £80-90 million (E mail from Jane MacLeod to Tim Parker;
Ken McCall; Carla Stent; Tim Franklin, re: Postmaster Litigation - Confidential
and subject to Legal Privilege - Do not Forward 1 June 2018, POL00103336).
240. During the summer of 2018, Jane and Angela Van Den Bogerd, who was
supporting Jane, undertook a piece of work to assess the Claimants’ challenges
to the way in which the Postmaster contract was implemented ahead of the
upcoming CIT.
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241.
242.
243.
244,
My view was that we should use the time before the CIT to improve the contract
for Postmasters where we felt it was weak. However, legal advice cautioned
against clarifying the contract in any way in advance of the trial. Instead,
substantial contingency work was undertaken to risk rate the different
challenges to the contract, by impact and likelihood, assessed with reference to
legal advice.
This was discussed at the GE on 18 July 2018, and again during a Board
meeting on 31 July 2018 (Meeting minutes: minutes of Board meeting held on
31st July 2018, POL00021556) with higher impact ratings attributed to the
challenges on causation of shortfalls and liability for losses, given these would
lead to immediate financial impacts for POL in the event of an adverse
judgment. Suspension pay was categorised as an operational issue. This work
provided a clear view of where POL should focus its efforts when the CIT
Judgment was subsequently published.
Also during the summer of 2018, there was correspondence between Jane
MacLeod, Stephen Clarke (of UKGI) and me regarding a briefing with
Permanent Secretary (Alex Chisholm) of the Department scheduled for 10
September 2018 (Email from Alisdair Cameron to Stephen Clarke RE: Post
Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT
FORWARD 5 July 2018 POL00255647).
We discussed particular areas of focus for the briefing including the issues at
stake in the upcoming CIT, the implications of losing for POL, contingency
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245.
246.
247.
arrangements, and the issue of settlement. We also arranged a pre-meet with
UKGI to go over the agenda prior to the briefing.
In September 2018 I received correspondence from Jane, copying various
others from our legal advisors at Bond Dickinson, which started as a request for
guidance about security for costs (Email chain from Jane MacLeod, Andrew
Parsons, Rodric Williams and others Re: Postmaster Litigation - Security for
Costs 16 September 2018 POL00024204). Our legal team had recommended
POL make this application, which was due to be heard later that month.
However, the Claimant's legal advisors had served a request for a cross
undertaking for damages, so if POL lost the CIT we would be required to
indemnify the Claimants for the cost of providing the security. Paula Vennells
and I had particular concerns about being asked to take this decision by our
legal team, which risked public money, with “little data and no notice”. The final
decision was influenced by a desire not to back down at the first sign of a fight.
Despite this being in line with the advice provided to us, Paula and I had
concerns whether we had been advised well enough, and I felt that the
Claimants had better advisors.
On 16 October 2018, Paula and I exchanged correspondence to prepare for the
next day’s meeting with the Permanent Secretary of the Department, copying
the General Counsel and the Communications Director. Paula acknowledged
the importance of using neutral and balanced language when communicating
the risks associated with the litigation. Key areas included the focus on
resolution, but it was noted that POL was not afraid to appeal if the judgment
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248.
249.
250.
251.
was flawed and had strong legal support to do so. Contingency arrangements
were in place for various potential outcomes of the CIT, and we had a plan to
engage with the media and challenge examples of biased reporting.
In this correspondence, Paula acknowledged that Postmasters had undoubtedly
“suffered badly’. However, this was not because of Horizon but because they
had got out of their depth, and suggested there was the opportunity to engage
in mediation after the two trials were completed (Email from Alisdair Cameron to
Paula Vennells, Jane MacLeod, Mark R Davies Re: Tomorrow's GLO Meeting
16 October 2018, POL00154340).
In my response to Paula’s correspondence, I focused on the losses in the
Network which had arisen as a result of POL’s decision not to prosecute
Postmasters until we could prove that Horizon was reliable. I noted that this had
caused an increase in losses to POL, and a reduction in the recovery of
shortfalls, in the past couple of years. However, POL was improving at
identifying shortfalls earlier and sharing them with auditors and agents.
On 17 October 2017 the meeting took place for the Permanent Secretary to
scrutinise POL’s preparations for the upcoming trials and contingency plans,
including potential implications for the business of adverse findings and a
planned approach to settlement and communications.
I have now seen the Department briefing for the Permanent Secretary at that
time, which notes that “There is a consensus that it is not appropriate or feasible
to settle in the short term but there will be a mediation window in March 2019.”
(BEIS Agenda: 'Post Office: Horizon Trial Contingency Planning’ 17 October
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252.
253.
254.
2018 UKGI00008519). During this meeting, I believe the Permanent Secretary
challenged POL on plans for mediation and the argument that we could not at
this point settle the case. This is based entirely on my recollections as the
minutes from this meeting are not clear (Draft read out note of POL meeting in
HoC on 17th October 4-4:45pm 17 October 2018, UKGI00008554).
My recollection is that we felt that POL would never be able to recommend a
settlement that would satisfy the Claimants, as there were individual claimants
in the GLO who had already signed full and final settlements but had still
chosen to become involved in the litigation. The shared view was that we
needed to win or lose to resolve the complex issues raised, and our legal advice
was that we had a strong legal claim and were likely to win.
The counter-argument was that if we didn’t fight, we couldn't lose — and while
another case might emerge in 2-3 years time, that could be settled too. We
didn’t follow that line of thought believing that only a win or a loss in court would
enable a satisfactory solution for either party.
Later, I was accused of a cynical ‘kick the can down the road’ strategy when I
said that POL could manage the costs of the litigation because we had deeper
pockets. POL pursued a win or lose strategy because we thought we would win,
and we also thought that we could only reach a resolution with a decisive verdict
one way or the other. If we had wanted to ‘kick the can down the road’, we
would have settled the case in 2018 and waited for any further cases to emerge
later.
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255.
256.
257.
258.
The outcomes of the meeting were increased information-sharing with the
Department and a planned Cabinet paper on the strategic issues POL faced.
Generally, the correspondence from the beginning of the GLO, and POL’s
external communications strategy, demonstrates our intention to robustly defend
the claim. The view was that of the huge number of transactions that were
processed daily by Horizon, only a very small percentage of Postmasters who
had used it had experienced issues of the kind alleged by the Claimants. This
was reflected in our legal strategy (Email from Melanie Corfield to Mark R
Davies, Rodric Williams, Ben Float and Bob Hammond RE: For action- F&O call
on Thursday 2.15pm 21 November 2018, POL00259560).
By December 2018, POL was expecting to receive the CIT judgment mid-late
January 2019. At this stage, POL’s contingency planning included consideration
of the potential for a decision to appeal the judgment. Proposals were set out in
detail and the Chairman was responsible for the decision with Paula Vennells
and myself, based on advice from POL’s legal team.
General Counsel from UKGI had also asked to be briefed on how POL intended
to reach any decision on whether to appeal the CIT judgment. We discussed
producing an appeal matrix using our contingency planning as a guide to POL’s
response on each possible finding in the awaited judgment (Email from Jane
MacLeod to Paula Vennells, Alisdair Cameron and CC Rodric Williams re:
Board Report re Litigation CONFIDENTIAL AND SUBJECT TO LEGAL
PRIVILEGE - DO NOT FORWARD 17 December 2018 POL00260202).
Involvement in the Deloitte reports
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259. I have set out my earlier involvement in respect of POL’s SAs and answering
queries from Second Sight (see above from paragraph 156). The following
section sets out the further work POL commissioned in respect of SAs from
June 2016.
260. This work was never fully visible to me as it was conducted under legal
privilege. I assumed its purpose was to provide a definitive answer to the
concerns raised by Second Sight that the Suspense Account and any related
Client Creditor accounts could have housed Postmasters’ money before a
release to the POL profit and loss account.
261.On 1 June 2016, Mark Underwood forwarded to Deloitte a note that I had sent
him setting out the position in respect of SAs (Email from Mark Underwood to
Mark Westbrook cc'd Patrick Bourke re: Private & Confidential: Subject to Legal
Privilege 3 June 2016, POL00242323). In this correspondence I set out the
importance that all concerns raised in respect of SAs should be investigated
and issues rectified.
262.1 suggested engaging Deloitte to investigate the balances at year-end 2015 and
2016 to check my conclusions and to identify explanations for any credits
released to the POL Profit & Loss accounts to confirm that they did not belong
to Postmasters. I also suggested that POL should review every client account to
demonstrate that there were no material balances of unmatched items more
than 6 months old (as previously discussed with Second Sight), and that
unmatched credits cleared from the client accounts over the period went to an
identified SA for resolution.
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263.
264.
265.
266.
Most importantly, I recommended that Deloitte should confirm using transaction
analysis that there was no systemic branch impact and that the SAs did in fact
operate as I understood them to.
My email on 3 June 2016 (POL00242323) contains some important points. In
particular, my note had not yet been checked for accuracy, and while it could
draw conclusions on what was happening in 2016 it could not confirm how SAs
had operated in 2005. I clarified that POL had not sought to state that it was
impossible for a branch to ever be “out of pocket’ but that POL had no reason to
believe that as a result of the operation of the SAs Postmasters were
systemically and unknowingly losing money, to POL’s gain.
In early 2017, I was forwarded correspondence between our legal advisors and
Angela Van Den Bogerd seeking my approval to sharing a Deloitte paper with
them on the issue of SAs. On receipt of this, I immediately contacted General
Counsel and indicated that I had not been aware that further work was being
conducted in relation to SAs and asking to be copied into all ongoing
correspondence as I, as CFO, held ultimate accountability for preparing POL’s
accounts (Email chain from Alisdair Cameron to Jane MacLeod re: Private &
Confidential: Subject to Legal Privilege: Suspense Accounts 8 February 2017,
POL00110592).
It appears to me now that the additional work was commissioned substantially
later than my suggesting it in June 2016. I emphasised that I should be included
in any meetings and copied into information exchanges to ensure that
information provided was reliable.
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267.
268.
269.
270.
271.
Following this, on 22 March 2017, a note was sent on my behalf (by my PA) to
members of the POL Finance team setting out a planned Deloitte investigation
into SAs (Email chain from Ruth Phillips to Kay Wilson, Paul Smith and others
re suspense account 22 March 2017, POL00247840).
Through 2017, I was kept apprised of the scoping of Deloitte’s work and we
discussed how many accounts they wanted to investigate.
In November 2017, a noting paper prepared by Bond Dickinson refers to two
Deloitte reports prepared to investigate allegations made by the Claimants
pertaining to the reliability of Horizon (Post Office Group Litigation Steering
Group Meeting - Noting Paper: Deloitte Reports 3 November 2017,
POL00024323). I don’t recall this paper and I do not know if I saw it at the time.
My recollection is that the formal GLO Sub-Committee was not in place until
2018 and I did not have such a meeting on 3 November 2017, according to my
diary.
The Bond Dickinson paper notes that the first ‘Main IT Report’ dealt with
allegations that discrepancies in branches were caused by bugs in Horizon. The
second report covered allegations that POL operated SAs which held
unattributable surpluses, which could be generated from branch accounts,
which after a period were swept into POL’s profits.
The paper notes that the second report had been reviewed by Mark Underwood
and by our legal advisors. It summarises the report's conclusions that controls
should be stronger and Deloitte “should be able to establish” if POL benefited in
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272.
273.
274.
275.
the way alleged by the Claimants by reviewing branch transaction data. There
was no confirmation that this next stage of work would be undertaken.
The paper notes that, once finalised, the second Deloitte report would be
shared with me for comment. I do not recall ever seeing the Deloitte SA report
or having any further discussion about it.
As far as I can recall, the Deloitte work on SAs was never completed. While it
was overtaken by the litigation, we were not aware of any materially adverse
findings.
Following concerns raised by Lord Arbuthnot in February 2020, KPMG were
commissioned to investigate SAs again and the ARC considered a paper that
summarised KPMG’s findings: “In summary...these suspense accounts should
not result in Post Office pursuing Postmasters for sums it had or could
eventually take to profit. This is because sums housed in suspense accounts
are either not taken to a profit and loss account; or relate to unmatched
transactions due to customers (not Postmasters); or relate to surpluses rather
than shortfalls.” \t did, for completeness, describe a way in which it was
theoretically possible for it to happen (Doc_ARC_Current Operation of
Suspense Accounts, 27 July 2020, POL00423922).
It was agreed that KPMG would provide a second report on the same issue but
relating to the past which was reviewed in November by the ARC (Doc: ARC.
Committee Report, 24 November 2020, POL00030907). This reached similar
conclusions to the July 2020 report, noting two possible exceptions.
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Accounting treatment of the litigation
276. As CFO of POL, I was engaged with the accounting treatment of the litigation.
277. In May 2016, I was involved in discussions with the ARC members and our
external auditors whether POL should disclose the GLO claim in our accounts
now that it had been formally lodged in the High Court (Email from Carla Stent
to Alisdair Cameron and Tim Franklin CC'ing Peter Mclver RE: Conversation
with EY team relating to Post Office ARC meeting 26 May 2015 POL00241640).
It was noted that the GLO was an unqualified claim which POL’s management
considered to be unjustified and intended to robustly defend.
278. Discussion of the accounting treatment of the litigation and what was
appropriate disclosure in each year’s accounts was debated several times. In
particular, we discussed how we might value the claim (given that it had not yet
been quantified by the Claimants) and whether there was a liability that needed
to be provided for.
279. At a meeting of the ARC on 28 June 2016 (Post Office Limited Audit, Risk and
Compliance Committee Minutes 28 June 2016, POL00021446), it was noted
that following an estimate from the Claimants in their skeleton argument that
their claims were worth up to £90 million, EY had recommended that POL
disclose this figure in their accounts. Following a discussion, it was concluded
that while the existing draft disclosure in the contingent liability note needed to
be expanded, disclosure of the estimated claim value might not be a reliable
reflection of the actual value of that claim, and POL’s strong preference was not
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to disclose the estimated figure. This was subsequently accepted by EY in July
2017 and the estimate was not referred to in their audit report.
280. In early July 2018, I sponsored a report which considered the accounting
treatment of the GLO against IAS 37 (Post Office Group Litigation Report 1 July
2018, POL00120814). The report noted that, taking into account all available
evidence including the advice of independent experts, our legal advisors and
Leading Counsel, it was “possible although not probable” that a present
obligation existed, making the GLO a contingent liability requiring disclosure.
This report concluded that POL should disclose the claim in the 2017/18 annual
report as a contingent liability under the definition in [AS 37.
281. Following this report, an internal panel at EY tested the arguments put forward
in respect of the disclosure of the liability (Email from Alisdair Cameron to Jane
Macleod RE: POL Contingent Liability Issue and Outstanding Items 16 July
2018, POL00255796).
282. In later email exchanges with EY, they confirmed that the claim was a
contingent liability and did not need to be disclosed in their audit opinion. There
was subsequent internal discussion with General Counsel regarding the
appropriate wording for the disclosure of the claim as a contingent liability (E
mail from Jane MacLeod to Paula Vennells, Alisdair Cameron, Carla Stent and
others re Postmaster Litigation - Disclosure in the ARA 27 July 2018,
POL00255968).
283. A similar discussion took place during an ARC meeting on 29 May 2019 (Post
Office Limited Audit and Risk Committee meeting Minutes of 29 May 2019,
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POL00021447). Following this discussion, management agreed to support PWC
(our new external auditors), to seek advice from Counsel why it was difficult to
set down a reliable estimate of the claim’s value.
284. In June 2019 as POL turned more to the possibility of settlement of the GLO, we
considered that given the Claimants had still not fully quantified their claim, it
remained impossible for POL to come up with an effective estimate for
disclosure or provision in the annual report, although we could speculate on the
potential range of settlement costs (Email Chain from Alisdair Cameron to Tim
Parker, Ben Foat and Alan Watts re: FW: Letter from Kelly Tolhurst MP Re POL
(May 2019) - Legally Privileged 2 June 2019, POL00103569).
285. It was also noted by the Shareholder Representative that it was important to be
aware that disclosure in POL’s accounts of speculative figures could have
significant implications for the ultimate cost of settlement and cause concerns in
the Department which POL would need to be able to address (Email from
Thomas Cooper to Alisdair Cameron, Alan Watts and Ben Foat re: Legally
Privileged - GLO sub-committee 5 June 2019, POL00276017).
Litigation 2019 — 2020
286. In January and February 2019 my involvement in the GLO was limited. There
was a meeting of the GLO Sub-Committee on 11 February 2019, and I was
copied in on a note from Paula Vennells to various members of the GE
expressing “serious concerns” about Fujitsu's witnesses, and over our
understanding of the issues (Email from Paula Vennells to Rob Houghton, Jane
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287.
288.
289.
MacLeod, Rodric Williams and others RE: Fujitsu Call 11 February 2019,
POL00176667) I do not recall seeing any further correspondence in this chain.
During March 2019 I was increasingly acting as the Interim CEO in Paula's
absence and this was formally confirmed in April.
I therefore took a lead with the Executive team when we received the news on 8
March 2019 that POL had lost the CIT on all counts, that Mr Justice Fraser had
found that the Postmaster contract was relational (which POL had disputed),
and that he had therefore found various implied terms in that contract that POL
had not been enforcing. The judgment was extremely critical of POL.
I was in correspondence with Jane MacLeod between 8 and 11 March 2019 and
we agreed that a Board call should be set for 12 March 2019, which I had
discussed with the Chairman (Email from Alisdair Cameron to Jane MacLeod in
response to proposed email to Post Office Board following the judgement in the
Common Issues Trial 8 March 2019, POL00267444). In this correspondence I
also proposed the content of a note to be circulated to the Board ahead of the
scheduled call. Initial areas of focus included the legal approach, operational
reactions, IT, Agents, communications and stakeholder management as well as
governance, funding and budget considerations (Email from Alisdair Cameron to
Jane MacLeod RE: Board Call on the GLO — Legally privileged and confidential
11 March 2019, POL00154694).
Reaction to the Common Issues judgment
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290. My immediate concern when we received the CIT judgment was that we did not
allow immediate reactions to develop into a crisis of confidence, especially
among Postmasters. I was keen to ensure my colleagues remained focused on
delivering the agreed contingency plan, and wrote to reassure that “this is
manageable if we manage it... so lets crack on, reassuring any wobblers as we
go.” (Email from Alisdair Cameron to Jane MacLeod, Mark R Davis, Melanie
Corfield and others re GLO Decision and resulting actions required 8 March
2019, POL00136433).
291. This was also set out in my proposed wording to the Board, which I sent to Jane
MacLeod on 11 March 2019 “The Executive Team views such an extreme
verdict as a potential crisis and the outcome will depend on how we manage the
situation...” (Email from Alisdair Cameron to Jane MacLeod RE: Board Call on
the GLO - Legally privileged and confidential 11 March 2019, POL00154694).
292. On 15 March 2019, a standard email was sent on my behalf to Fujitsu which
had been written to important third parties informing them of the nature of the
judgment. I emphasised that POL was taking the strong criticisms from the
judgment very seriously and would be taking action as necessary, including
accelerating investigation of problems raised and stepping up training and
support. I acknowledged in a further email that this was not appropriate for
Fujitsu as we had already directly discussed the judgment with them (Email
from Alisdair Cameron to Duncan Tait cc Rob Houghton RE: Post Office update
— Group Litigation 15 February 2019, FUJ00171178).
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293. A key area of managing the adverse outcome of the CIT was POL’s external
communications. On 12 and 13 March 2019, there were a series of emails
between Mark Davies, myself and others, regarding the preparation of a
statement for the media on the CIT judgment
294. Initially the expectation was that the media statement would come from me as
interim CEO and I favoured wording that was open and demonstrated our
intention to reflect seriously on the issues raised. In my draft wording, I used
language such as “we will not simply put up a defence, we will face up to the
criticisms and take action” (DRAFT OVERALL MEDIA STATEMENT — in
strictest confidence, legally privileged — subject to legal advice, 15 March 2019,
POL00267739). and (Email chain from Alisdair Cameron to Mark R Davies,
Jane MacLeod cc'ing Melanie Corfield and others re: Draft media statement, 13
March 2019, POL00163485).
295. There was debate about the content of the statement internally, and it was
decided that the statement would come from the Chairman as I was not yet
announced as Interim CEO. He agreed the final version of the wording with
Mark Davies and the tone was much more standard, for example “the Judge’s
comments remind us that we must always continue to do better...We have
taken his criticism on board.”
296. I felt then and still believe that managing down the criticism, and the need to
change, in the media statement following the CIT judgment was an opportunity
lost to re-set views within POL and externally.
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297.
On 15 April 2019 I gave a speech to the NFSP in my role as Interim CEO. In
internal discussions, I was advised to use language which aligned with the
messaging already agreed in relation to the judgment and ultimately followed
this counsel (Email from Jane MacLeod to Alisdair Cameron and others re
STRICTLY CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE: Key note
speech 11 April 2019, POL00270605).
Financial and operational issues raised by the CIT judgment
298.
299.
On 22 March 2019 I sponsored a report on POL’s Operational Responses to the
GLO (“Operational Responses report”) (POL Operational Responses to the
GLO 22 March 2019, POL00269350). The Operational Responses report set up
workstreams to deal with the impact of the CIT judgment and set out key
questions to be addressed for each. Each workstream had executive owners.
The workstreams were as follows:
Legal: enabling POL to make changes in line with the judgment that would
stand the test of time, in areas such as contract variations, suspensions and the
Branch Trading Statement.
Operations: to deliver new processes. This would include a new process for
managing differences in branch accounts with built-in transparency and
independence. There would also be a programme to reduce errors. This was
put into place quickly and in the CEO Report I noted that we were already
changing the structure in Chesterfield where the Postmaster support centre
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operated with a new team focused on disputes in branches (CEO Report - The
GLO Author: Al Cameron, 30 April 2019, POL00273832).
e Agents (Postmasters): To identify the balance of remuneration, simplification,
support and lower costs that would make the proposition of working as a
Postmaster more attractive.
. Other workstreams included Communications; Stakeholders; IT/Horizon; Brand;
and Financials.
300. I was responsible for managing stakeholders and observed that “if Postmasters
remained in BAU [business as usual] mode, largely reassured and pleased with
changes, stakeholders will also relax.” (POL Operational Responses to the GLO
22 March 2019 POL00269350). It was my belief that the key was to make
progress with the Postmasters.
301. This paper also set out for the Board the need for cultural change, which would
require a material shift in attitude and behaviour, including Branch Hub
investment and improved training. To do so POL would need to be open to
criticism and demonstrate willingness to change.
302. Financially, we signalled to the Board that supporting Postmasters would
change the budget for 2019 - 2020, which was not approved until the 30 April
2019 Board and was still subject to UKGI confirmation. In total, approximately
£22 million of additional spend was budgeted, with £12 million of additional
operating costs, including £5 million of specific changes to Postmaster
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303.
304.
305.
306.
remuneration (Meeting minutes: minutes of Board meeting held on 30th April
2019, POL00021565).
In June 2019, also reflecting the likely outturn of the Banking Framework
negotiations, a Postmaster Remuneration increase worth £17 million per annum
was announced (Letter from Al Cameron to Kelly Tolhurst MP re: follow up from
meeting on 15 May 4 June 2019, UKGI00010232) with a further review to report
in the Autumn.
A further financial implication of the CIT judgment was that while POL had to be
able to recover taxpayer money that was used as cash in branches, it would
now be harder to do so in practice (Email Chain from Alisdair Cameron to Tim
Parker, Ben Foat and Alan Watts re: FW: Letter from Kelly Tolhurst MP Re POL
(May 2019) — Legally Privileged 2 June 2019, POL00103569).
Reviewing the documents from that time, I am struck by how immediately I
sought to see a change of position, attitude and operational behaviour at POL
following the outcome of the CIT judgment, backed up financially. With
hindsight, my sense is that the CIT judgment played into my existing frustrations
such as the advice not to improve the contract while the litigation was going on,
and I wanted to remedy the issues highlighted in the judgment effectively.
For example, Debbie Smith (Retail Director) had convinced me through 2018
that POL was not treating Postmasters as well as a retailer would treat staff in
its shops, and we had started considering how to improve this position. In my
role as interim CEO I began to prioritise making Postmasters jobs easier,
supported by POL’s improving finances. It is my view that, although it was an
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adverse outcome, the CIT judgment allowed POL to utilise Trading Profit in
2019 — 2020 in a way that might not have attracted Board support previously.
Legal Strategy following CIT judgment
307.
308.
309.
As I have indicated, the CIT judgment was extremely critical of POL, including
its approach to the litigation thus far. Part of my immediate reaction to the CIT
judgment was that we had been badly served by our legal advice, given the
adverse outcome. I wanted the advice POL received in future to be easier to
challenge. However, despite the scale of the loss in the CIT, there was no
immediate change to POL’s proposed legal strategy.
Instead, very shortly after we received the CIT judgment, I received
correspondence from Jane MacLeod setting out proposals including appealing
the judgment and an application for Mr Justice Fraser (the Judge presiding over
the GLO) to recuse himself (see further from paragraph 311) (Email chain from
Alisdair Cameron to Jane MacLeod RE: Board sequencing 16 March 2019,
POL00268475). Jane had brought in Lord Neuberger (former president of the
Supreme Court) and Lord Grabiner QC (as he then was) to advise POL on
these issues. I was uncomfortable that they came from the same chambers as
David Cavender QC.
I was keen for some independent advice and we involved the firm Norton Rose
Fulbright in discussions from that point to act as a check and balance to the
decisions we were making (Email chain from Alisdair Cameron to Jane
MacLeod RE: Board sequencing 16 March 2019, POL00268475). In April 2019
we stood down Norton Rose Fulbright and POL introduced Herbert Smith
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(“HSF”) to act as our primary solicitors for the remainder of the GLO (CEO
Report - The GLO Author: Al Cameron 30 April 2019 POL00273832).
310. We also had a change in General Counsel. Jane MacLeod left the business and
Ben Foat (“Ben”) was appointed General Counsel in May 2019.
Decision to make application for recusal of Mr Justice Fraser
311.
312.
313.
As early as 14 March 2019, our legal team sought advice from Lord Neuberger
on a potential application by POL for Mr Justice Fraser to recuse himself from
the remainder of the GLO (Email from Jane MacLeod to Jane MacLeod RE:
Litigation Options 15 March 2019, POL00268060). POL received Lord
Neuberger’s advice shortly thereafter, which was broadly that POL had good
prospects in a recusal application (Advice by Lord Neuberger on the recusal
application 14 March 2019 POL00025910). This advice was caveated: he had
looked “only very cursorily’ at the materials but expressed concerns that the CIT
judgment was “wrong in principle and unfair in practice”.
The advice was shared with me by Jane who proposed that POL instruct Lord
Grabiner QC to present the recusal application. Most of the following
discussions were happening concurrently with discussions regarding an appeal
of the CIT judgment (see from paragraph 329).
My recollections are that recusal was a new concept to me and an
uncomfortable one, because it seemed radical, aggressive and played to the
sense that POL was arrogant. The application also conflicted with my desire for
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314.
315.
316.
POL to be visibly open to change. I recall the Shareholder Representative felt
similarly uncomfortable.
However, the legal advice was that the decision on recusal was urgent as
arguments about unfairness had to be made in the recusal rather than forming
part of any appeal of the CIT judgment. If we did not challenge quickly, POL
would look like we had consented to the criticisms in the CIT judgment and Mr
Justice Fraser’s approach. We only had a number of days from receiving the
CIT judgment and legal advice in which to make the decision (POL Board
Meeting - Minutes of a call of the Board of Directors of POLTD 18 March 2019,
POL00027594).
On 18 March and 20 March 2019 Jane MacLeod held conferences with Lord
Grabiner QC to discuss the decision on a recusal application (Note of
conferences on 18/3/2019 and 20/3/2019 with Lord Grabiner QC,
POL00006397). Lord Grabiner is quoted as saying that the CIT judgment was
“unbelievable nonsense and demonstrated apparent bias’.
During the second Board dial-in on 20 March 2019, Jane summarised for the
Board that “there was no practical alternative.” The legal advice was strong that
POL should make a recusal application and not to do so would have a
detrimental impact on not only the remaining trials but also would destabilise the
business. Lord Neuberger had supported Lord Grabiner’s view and “thought that
not taking the aggressive course (recusal) carried more risk than taking it from a
legal basis.” (POL Board Meeting - Minutes of a call of the Board of Directors of
POLT 18 March 2019 POL00027594).
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317. On 20 March 2019, following internal discussions, the Board met to decide
whether to apply for Mr Justice Fraser to recuse himself as the judge presiding
over the GLO. A report on this decision was prepared by myself and Jane in
preparation for this decision (Post Office Limited The Board of Directors
Discussion Paper — The Background to Recusal and other issues 20 March 2019,
POL00103473). This paper set out three options for POL; to continue our original
legal strategy of working through the trials scheduled with Mr Justice Fraser
despite concerns following the CIT judgment; apply for recusal for the opportunity
to continue the trials under a different judge; or seek settlement. The Chairman
and Shareholder Representative were conflicted from voting in the decision on
recusal but were present at the Board meeting.
318. During the final Board call, the Board discussed the legal advice we had
received and that there would be an increased risk of an adverse outcome in
future trials if Mr Justice Fraser continued to preside (Board call GLO 20 March
2019, POL00021563). The main argument of force against making the
application was the near-term reputational impact and risk of further alienating Mr
Justice Fraser if it was unsuccessful, although it was noted that his views were
already pronounced in the CIT judgment. Norton Rose Fulbright attended to
provide independent advice and concluded that while there were risks, the
greater upside in making a recusal application outweighed them. My view was
that the final decision was balanced. In the end however, the strength of the legal
advice meant that the Board supported a resolution for a recusal application with
Lord Grabiner QC to be instructed.
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319. My recollection of these meetings is that we were very uncomfortable with
having to make this decision. Personally, I recall being influenced by a
suggestion at one of these meetings, which was not minuted, that, if upheld, Mr
Justice Fraser’s finding that the Postmaster contract was a relational contract
would, over the next year or two, make it impossible for the Post Office to
function because we could not operate individual contracts with implied terms
with that number of Postmasters. It was my concern about the effect of the CIT
judgment on POL’s sustainability as a business that ultimately swayed me into
following our legal advice and supporting an application for recusal.
320. It became evident in the weeks and months following the CIT judgment that the
impact of a relational contract was not as feared, that each time POL would
seek to enforce an element of the Postmaster contract the Postmaster would
challenge the application of the individual contract in those circumstances, and
this would be overwhelming for POL. Postmasters largely did not challenge the
way POL implemented their contracts following the CIT judgment.
32
. In the end the recusal application had been made less than a month after POL
received the CIT judgment. Had we had more time and been able to consider
this fully, I do not believe that we would have supported a recusal application.
322. On 21 March 2019, proposed wording was circulated for a press statement on
POL'’s anticipated recusal application (Email from Mark R Davies to Jane
MacLeod, Alisdair Cameron cc Mark Underwood, Patrick Bourke, Melanie
Corfield RE: Statement 21 March 2019, POL00269061). I provided my
comments on the proposed wording and pushed for the statement to focus on
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323.
324.
325.
POL’s need to change rather than the anticipated strength of our defence. I also
recognised that the advice from our legal advisors (both new and previous) was
that recusal was both justified and necessary to protect Post Offices (Email from
Cameron RE: Statement: legally privileged and strictly confidential 21 March
2019, POL00269063).
On 9 April 2019 Jane MacLeod updated us that the recusal application had
been refused but, unexpectedly, POL’s application for permission to appeal that
decision was also refused (see further below from paragraph 329) (Email from
Jane MacLeod to Alisdair Cameron, Thomas Cooper, CC Avene Regan and
others re: Post Office - Recusal Application - confidential and subject to legal
privilege - do not forward 9 April 2019, POL00359925). Subsequently the
question became whether to appeal the CIT judgment to the Court of Appeal
separately, or in conjunction with an appeal on the recusal decision.
In my response to Jane’s update on the outcome of the recusal application, I
pointed out that this assumed that POL was happy to appeal the recusal
decision without further debate, and in particular the grounds for appeal of the
CIT judgment and whether the two appeals would be joined needed discussion.
(Email from Alisdair Cameron to Jane MacLeod re. Post Office - Recusal
Application CONFIDENTIAL AND SUBJECT TO LEGAL PRIVILEGE - DO NOT
FORWARD 9 April 2019, POL00103490).
I raised my discomfort at the process in an update to the Chairman on 12 April
2019 (Email from Alisdair Cameron to Tim Parker re. Update 12 April 2019,
POL00103495). In particular, I had become increasingly concerned that David
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Cavender QC had reacted emotionally to the CIT judgment and was no longer
able to give us the best advice in relation to the recusal appeal or POL’s legal
strategy more broadly.
326. The tension between the legal advice and the Board’s concerns are partly
evidenced in my Interim CEO report to the Board on 30 April. It was decided
that POL would proceed with the recusal and CIT judgment appeals separately,
against legal advice. (CEO Report - The GLO Author: Al Cameron 30 April 2019,
POL00273832). My recollection is that this decision was motivated by concerns
that the more controversial unfairness arguments in the recusal application
could undermine the more conventional grounds for appealing the CIT
judgment.
327. On 11 May 2019 Ben Foat notified us that POL had lost the recusal appeal
argument (Email from Ben Foat to Alan Watts, Kirtsen Massey, CC Alisdair
Cameron and others re: Group Litigation - recusal application - legally privileged
and highly confidential 11 May 2019, POL00360195). On 13 May 2019 I wrote
to the GLO Sub-Committee and HSF that “recusal is finished’ and we should
put together a team to settle the case (Email from Alisdair Cameron To Tim
Parker, Thomas Cooper, Ken McCall & Ors RE: request for appeal on recusal
13 May 2019, POL00103539).
328. On 4 June 2019, as part of a broader discussion about the impact the litigation
was having on POL’s brand and in terms of cost, I recognised the damage that
the efforts to recuse Mr Justice Fraser had caused and noted that POL was now
focusing on changing the narrative (Email from Alisdair Cameron to Alan Watts,
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Ben Foat cc'd Thomas Cooper re: Legally Privileged - GLO sub-committee 4
June 2019, POL00275995).
Decision to appeal CIT judgment
329. As set out above, many of the discussions regarding whether POL should
appeal the CIT judgment were running concurrently to those regarding the
recusal application and are contained in the same documents. However, for
ease I have separated these issues in my statement.
330. On 15 March 2019 Jane MacLeod provided a note to me, the Shareholder
Representative and the Chairman setting out advice from Lord Neuberger on a
potential recusal application (Email from Alisdair Cameron to Thomas Cooper
re. URGENT: Litigation Options - Confidential and Subject to Legal Privilege 15
March 2019, POL00103438). The Shareholder Representative replied that he
was more comfortable with appeal than recusal, a view that I think was largely
shared.
331. On 18 March 2019, during a call with the Board and Lord Neuberger to discuss
legal advice in respect of the CIT judgment appeal (and recusal), we were
informed that any appeal of the CIT judgment had to be submitted within 21
days, making it less urgent than the recusal issue although still pressing. (POL
Board Meeting - Minutes of a call of the Board of Directors of POLTD 18 March
2019 POL00027594). During this meeting, Lord Neuberger presented options to
the Board and arguments for not accepting the CIT judgment. In particular, in
his view, Mr Justice Fraser had accepted evidence into the CIT which was not
relevant. The Board put various questions to Lord Neuberger and it was
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332.
333.
334.
335.
acknowledged that this was a difficult decision. POL wanted to be clear that
even while appealing, the business was still committed to making operational
changes and improvements.
On 20 March 2019, during the same Board call that the recusal application was
discussed and approved, the Board agreed to seek permission to appeal the
CIT judgment (call GLO 20 March 2019, POL00021563).
As set out above, the initial recusal application was refused on 9 April 2019
(Emails re recusal application 9 April 2019, POLO0359925). On 14 April 2019 I
received an update from Jane that the application to the Court of Appeal for
permission to appeal the recusal decision had been filed. I was advised that
POL should consider filing the appeal of the CIT judgment decision without
approaching Mr Justice Fraser so that those appeals could be heard together by
the Court of Appeal (Email chain including Jane MacLeod (POL); Ruth Cowley
(Norton Rose Full Bright "NRFB"); Glen Hall (NRFB) & Others Re: Postmaster
Litigation Update 14 April 2019, POL00270753).
During April 2019, POL’s legal team and our advisors debated the grounds for
appeal of the CIT judgment (Email from Andrew Parsons to Jane MacLeod c.c.
Amy Prime, Ben Foat: Subject 'Catch Up 17 April 2019, POLO00006513). I note
that I was not copied into this correspondence and do not recall debating the
potential grounds for appeal in detail other than as outlined in Board minutes.
However, following fuller discussion by the Board, and as above, POL decided
against legal advice to separate the recusal appeal and the CIT judgment
appeal on 30 April 2019 (CEO Report 30 April 2019, POL00273832).
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336.
337.
338.
Once the appeals had been separated, during May 2019 we focused on the
nature of the CIT judgment appeal and whether the unfairness arguments or
even a “recusal lite” argument should be included given the recusal application
(and the application to the Court of Appeal for permission to appeal against the
refusal of that application) had been unsuccessful. The Court of Appeal had
made clear its criticisms of the recusal application and it was acknowledged that
we needed to reassess our approach to the appeal against the CIT judgment to
reflect this (Email from Ben Foat to Alan Watts, Kirtsen Massey, CC Alisdair
Cameron and others re: Group Litigation - recusal application - legally privileged
and highly confidential 11 May 2019, POL00360195).
During these discussions, I echoed the view of the Shareholder Representative
that the current legal strategy was lining POL up for further criticism. I proposed
urgent consideration of whether the appeal grounds should be narrowed to pure
points of legal interpretation of the contract rather than echoing the
unsuccessful unfairness arguments in the recusal application (Email from
Alisdair Cameron to Thomas Cooper, Tim Parker, Shirine Khoury-Haq and
others re: RE: Post Office trial 12 May 2019, UKGI00043848).
During POL’s consideration of the grounds of appeal of the CIT judgment, David
Cavender QC continued to hold onto the original legal strategy including broad
appeal grounds (Email from Alisdair Cameron To Tim Parker, Thomas Cooper,
Ken McCall & Ors RE: request for appeal on recusal 23 May 2019,
POL00103539). Following an observation from Ben Foat at a hearing in relation
to POL’s application for permission to appeal the CIT judgment, where he
described the relationship between Mr Justice Fraser and David Cavender QC
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as “strained” and when POL’s application was subsequently refused (Email from
Ben Foat to Alisdair Cameron re: Group Litigation- Legally Privileged — Highly
Confidential on 23 May 2019 POL00275357), we decided to appoint a different
silk (Helen Davies QC — as she then was) to lead a narrower and less
combative appeal of the CIT judgment which better reflected POL’s adapted
approach to the litigation. I was supportive of this narrower approach to the
appeal (Email from Alisdair Cameron to Alan Watts, Kirsten Massey, Ben Foat
and Others re GLO Pre Meet and Sub Committee — Legally Privileged and
Confidential 7 June 2019, POL00103576).
339. The GLO Sub-Committee subsequently met on 12 June 2019 and approved
grounds of appeal of the CIT judgment that had been reduced by Helen Davies
QC from 55 to 8 pages. The appeal grounds removed the arguments relating to
procedural unfairness and did not “defend any clauses within the contract that
we did not think defensible” (Post Office Limited Minutes of Postmaster
Litigation Subcommittee Held on 12 June 2019, POL00103595). This carefully
reasoned approach felt much more comfortable and appropriate than the
strategy put forward by the Silks instructed previously by POL.
340. On 27 June 2019, HSF informed us that following a restrictive order from Mr
Justice Coulson which surprised Helen Davies QC in “both content and tone”,
she was reconsidering whether POL might avoid the CIT judgment appeal
application being heard by that Judge. I expressed concerns in response to this
that we were not changing our approach but appeared to be “doubling down”.
(Email Chain from Alisdair Cameron to Alan Watts and Ben Foat re: Privileged &
Confidential 27 June 2019, POLO0103599). The final hearing of the CIT
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The
341.
342.
343.
judgment appeal was heard by Mr Justice Coulson in November 2019 and was
refused.
Horizon Issues trial (HIT)
As set out above, the second trial in the GLO was the HIT and was scheduled to
start in March 2019. On 11 February 2019, Paula Vennells wrote to colleagues
and copied me expressing “serious concerns” about Fujitsu’s witness
statements, asking Jane MacLeod and Rob Houghton to have a “frank” phone
call with Fujitsu, and seeking better clarity on our defence (Email from Paula
Vennells to Rob Houghton, Jane MacLeod, Rodric Williams and others RE:
Fujitsu Call 11 February 2019, POLO0176667). This followed supplementary
evidence submitted by the Claimants which set out new lines of argument. I do
not recall seeing any replies to this correspondence.
On 21 February 2019 the GLO Sub-Committee minutes recorded that in the
view of POL’s Silk, Anthony de Garr Robinson QC (“Tony Robinson QC” as he
then was), Horizon was “critically robust’ and that while POL was not seeking to
prove that the system did not have any bugs, it accurately recorded data in most
cases and that bugs identified to date could be explained (Meeting Minutes of
the Group Litigation Subcommittee of POL 21 February 2019, POL00006753).
This was part of a brief to the GLO Sub-Committee ahead of the start of the HIT.
As part of a discussion of the risks of the HIT, this meeting also covered remote
access. Tony Robinson QC reported that the case on remote access from
Fujitsu had changed over time, and while initially Fujitsu had said that remote
access was not possible, the Deloitte investigatory audit had found that it was.
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The Claimant's IT expert was arguing that the scope of remote access was
even greater than currently stated, and the Court was likely to test this
allegation fully. It was also confirmed that only Fujitsu could change data and
there was no suggestion that PO had ever operated a policy to get Fujitsu to
manipulate the branch data.
344. Reading this now, I am struck by the reference to a Deloitte audit, which I do not
recall ever seeing. As noted in paragraph 37 my involvement in Deloitte’s work
was limited to Suspense Accounts. I do not remember noticing this reference at
the time.
345. Generally, the discussion on remote access did not strike me as significant as
my understanding was that the Claimants were fully aware that it was possible
in preparations for the litigation: Jane MacLeod had flagged this on 28
November 2016 in emails that made it clear that the issue was being discussed
with a QC and that the Claimants would be notified (Email Re: Postmaster
Litigation : Remote access from draft letter to Freeths - LEGALLY PRIVILEGED
— DO NOT FORWARD 28 November 2016 POL00357549).
346. On 7 March 2019, shortly before the HIT was due to begin, Jane wrote to
confirm that both parties’ experts had agreed that Horizon was “relatively robust’
and therefore Mr Justice Fraser could not find otherwise (Email from Jane
MacLeod to Tim Parker, Ken McCall, Carla Stent and Others re Post Office -
Postmaster Litigation Confidential and Subject to Legal Privilege - Do Not
Forward 7 March 2019, POL00103408).
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347. However, despite the experts’ conclusions we remained deeply anxious about
the possible findings from the HIT, particularly given the conclusions that Mr
Justice Fraser had reached about POL in the CIT judgment. During discussions
of the CIT judgment, there was therefore a focus on the need to ensure POL
had a clear view on the reliability of Horizon (Board call GLO 20 March 2019,
POL00021563).
348. On 20 March 2019, Rod Williams from POL’s legal team noted in a HIT update
that during cross-examination the Claimants had been largely successful in
demonstrating that POL’s reliance on Horizon was “overstated and blinkered”,
that POL was withholding data which could assist in resolving branch
accounting issues from Postmasters and that improvements to the system were
“overstated” (Email from Alisdair Cameron to Rodric Williams, Jane MacLeod
RE: Update on Horizon Issues Trial - Post Office Group Litigation 20 March
2019, POLO0268869).
349. In my reply to this update, I stated that I did not disagree with some aspects of
the findings and asked whether POL could demonstrate that even where
criticisms are well-founded that did not mean Horizon generated the losses
complained of. I considered whether we might accept some of the points made
and emphasised that POL’s strategy was to rectify some of the cultural
underpinnings that still existed in relation to the issues. I was advised in
response that the focus of the case was overall Horizon robustness and that
evidence from witnesses should not be relevant given the trial was to be
decided on expert evidence about technical issues (Email from Rodric Williams
to Alisdair Cameron and Jane MacLeod, re: Update on Horizon Issues Trial -
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350.
351.
352.
Post Office Group Litigation - SUBJECT TO LEGAL PRIVILEGE - DO NOT
FORWARD 20 March 2019, POL00268881).
I took this on board and remained anxious about preserving the experts’
“relatively robust’ finding, suggesting on 3 June 2019 that the GLO Sub-
Committee should consider the HIT strategy so Mr Justice Fraser did not go
beyond the expert witness remit of this trial (Email from Alisdair Cameron to Ben
Foat cc'd Veronica Branton and Alan Watts re: GLO Sub-Committee — Legally
privileged 3 June 2019 POL00275871).
On 7 June 2019 Rod Williams reported that the Claimants’ IT expert in cross-
examination admitted that he was not aware of any instance where transaction
data had been remotely deleted or edited, and that Fujitsu “insertions into
transaction data... were very rare, only done when necessary and carried out
with great care” (Email from Rodric Williams to Alisdair Cameron, Rob
Houghton, Mark R Davies & others cc Catherine Hamilton, Mark Underwood,
Angela Van-Den-Bogerd & others RE: Update on Horizon Issues Trial — Post
Office Group Litigation 7 June 2019, POL00026043). This was helpful evidence
to POL’s case, although with hindsight I feel that we perhaps focused too
greatly on good news rather than the overall direction of the HIT. The HIT was
concluded on 2 July 2019 and we awaited the final judgment.
On 2 October 2019, before the HIT judgment was handed down (but after the
trial had concluded) Ben Foat reported to Nick Read, myself, Alan Watts and
Mark Davies that there had been a disclosure incident regarding Fujitsu's
Known Error Logs (“KELs”). POL had relied upon Fujitsu's evidence that old
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353.
354.
versions of the KELs were overwritten and no longer existed. However, Fujitsu
had now reported that the relevant logs had been found (Email from Ben Foat to
Nick Read, Alistair and Mark Davies cc: Shikha Hornsey, Rodric Williams,
Sherrill Taggart, RE GLO — Disclosure Incident 2 October 2019, POL00026216).
As a result, POL had given inaccurate information to the Court which could
influence the verdict in HIT and change our perception of the case. It also
brought into real question POL’s credibility, particularly given we had already
been criticised In respect of the approach to managing disclosure In the
litigation.
I replied on 3 October 2019 in respect of the KELs disclosure incident
emphasising my distress and that POL needed to tell the Court immediately. I
also noted that this was the third time we had been misled by Fujitsu (Email
chain from Alisdair Cameron to Ben Foat cc Nick Read and Mark R Davies Re:
GLO Disclosure Incident re. KEL logs 3 October 2019, POLO0112591). During a
subsequent Board meeting to discuss the disclosure incident we considered
whether this was likely to impact the experts’ assessments of Horizon, and that
it would need to be factored into POL’s contingency planning.
On 22 October 2019, the GLO Sub-Committee met to consider a detailed
update on changes since the contingency planning was first implemented for
the HIT. This paper assumed a worst-case outcome, where Postmasters might
refuse to open branches, and outlined possible responses from enhanced
monitoring to preparing for “pop-up” Post Offices (PO GLO Board Sub-
Committee Paper — Operations and GLO Contingency Planning Report 22
October 2019, POL00112645). While these measures never had to be
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implemented, it reflects the sense of potential crisis as we awaited the outcome
of the HIT judgment.
355. On 4 December 2019, Ben Foat sponsored a paper to provide a HIT Judgment
Contingency Planning Update (Horizon Issues Trial Judgment Contingency
Planning Update 4 December 2019, POL00129086). This paper was intended
to provide reassurance that POL was prepared to respond to potential
operational impacts following the HIT judgment and that these measures could
be refined and adapted quickly to suit the outcome and reassure Postmasters.
The paper also acknowledged the likely sources of historical claims including
suspension pay, notice periods and repaying shortfalls. This contingency
planning operated in conjunction with tactical meetings on settlement (see from
paragraph 358).
356. On 9 December 2019, we received the embargoed HIT judgment, which found
that the latest version of Horizon was relatively robust. However, the remainder
of the judgment, including the conclusions on the robustness of historic versions
of Horizon (Legacy), were adverse to POL and the Claimant's expert evidence
had been preferred. Mr Justice Fraser concluded that there was a material risk
that bugs in older versions of Horizon had caused shortfalls in branches.
357. As a result of the HIT judgment, Ben Foat noted that Horizon contingency
planning should now be implemented as POL could expect to receive claims
based on historical shortfalls, and analysis would need to begin in respect of
Postmasters who had convictions on the basis of evidence of Horizon (Email
chain between Ben Foat, Tim Parker, Tim Franklin and others RE: GLO - High
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Level Review Embargoed Horizon Judgment - Section M 9 December 2019,
POL00043341).
Mediation and settlement of the litigation
358.
359.
360.
Mediation had been considered as part of the litigation strategy at least from
January 2019 where, during a meeting of the GLO Sub-Committee, it was
reported that both sides in the claim had agreed that it was better to receive the
CIT and Horizon judgments before entering into mediation. We considered
during this meeting whether the Claimant group could be categorised for
mediation purposes, for example to exclude those with a criminal conviction, or
whose claim was out of time (Meeting Minutes of the Postmaster Litigation
Subcommittee of POL 28 January 2019, POL00006756).
During the discussions on recusal, settlement was set out as one option
however it was highlighted that Claimants who had already been through
mediation were now part of the GLO, and settlement would not prevent further
claims in the future. As set out in earlier sections, our legal advice at that time
was to continue to robustly defend the claims (POL00103473).
However, following the refused recusal application appeal on 13 May 2019 I
asked the GLO Sub-Committee to put together a settlement team
(POL00103539). It had been my gut reaction to the CIT judgment that POL
should change its legal strategy due to the scale of the loss and criticism we
received. However, it took 2 months to make the necessary change to POL’s
legal team (see above paragraph 217).
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361. On 24 May 2019, during internal correspondence I set out that if POL’s only
priority was to minimise negative brand impact, we should consider settling the
GLO at that stage and create an independent process to manage historical
issues. However, I acknowledged that step had potential consequences (Email
from Patrick Bourke to Mark Davies re: Brand, press coverage and solutions 24
May 2019, POL00118056).
362. On 3 June 2019, I asked Ben Foat to add to the agenda for the upcoming GLO
Sub-Committee meeting to “Propose an approach to settlement (timing,
approach, team, remit and governance).” (Email from Alisdair Cameron to Ben
Foat cc'd Veronica Branton and Alan Watts re: GLO SubCommittee - Legally
privileged 3 June 2019 POL00275871). The following day I emphasised in a
further note copying in the Shareholder Representative that settlement was now
“Plan A” (Email from Alisdair Cameron to Alan Watts, Ben Foat cc'd Thomas
Cooper re: Legally Privileged - GLO sub-committee 4 June 2019, POL00275995).
363. On 7 June 2019 I provided an update to the GLO Sub-Committee, noting that
Alan Watts’ plan for settlement was to go to mediation first, helping us to better
gauge settlement and reassure Mr Justice Fraser that POL was keen to make
progress (Email from Alisdair Cameron to Alan Watts, Kirsten Massey, Ben Foat
and Others re GLO Pre Meet and Sub Committee - Legally Privileged and
Confidential 7 June 2019 POL00103576). HSF led the settlement work, initially
reporting to me and subsequently reporting to Nick Read. As Nick was CEO
from September 2019, he worked with HSF on the final stages of the
settlement, and I took a step back.
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364. The nature of an emerging settlement was discussed by the GLO Sub-
Committee on 17 September 2019 (Post Office Limited Postmaster Litigation
Subcommittee Agenda & Minutes 17 September 2019, POL00026939). By this
stage, POL’s legal strategy was to focus fully on exploring settlement options,
based on a review of advice on settlement from HSF. Our discussions were
based on an informal understanding of how any settlement was likely to be
attributed between the Claimants, their legal team and their funders. It was also
acknowledged that HMG approval would be required before any settlement
could be reached.
365. A formal settlement approach (and upper limit figure) was approved by the GLO
Sub-Committee on 13 November (Meeting Minutes of the Postmaster Litigation
Subcommittee of POL 13 November 2019, POL00006759) and the negotiated
settlement (including Claimants legal costs) was approved on 10 December
2019. The settlement was not just financial but included agreement that POL
would not appeal the HIT judgment and that Brian Altman QC (as he then was)
would assess the CCRC cases (Postmaster Litigation Subcommittee Agenda 22
January 2020, POL00292587).
366. Following the agreed settlement on 10 December 2019, there was a debate with
the Communications team regarding how we should answer the question about
how POL funded the settlement (Email from Alisdair Cameron to Patrick Bourke,
Nick Read and Ben Foat RE: Mediation 10 December 2019, POL00290109).
This discussion centred around the issue of whether we could confirm that the
settlement was not funded from HMG investment or the Network Subsidy. I
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The
367.
368.
369.
offered a narrow and a broader choice of wording, recognising that it was HUG
money in any case.
involvement and role of the Department and UKGI in the litigation
From 11 March 2019 when we received the outcome of the CIT judgment, we
noted the need to be communicating with the Department, as Shareholder
(Email from Alisdair Cameron to Jane MacLeod RE: Board Call on the GLO -
Legally privileged and confidential 11 March 2019, POL00154694).
On 16 March 2019, we had a call with the Department and UKGI to manage the
outcome of the CIT judgment. During the meeting the Minister raised a number
of concerns regarding the litigation thus far: including concerns that POL’s legal
advice to date was poor; that POL needed to share more information with the
Department; and that she was worried about Postmaster remuneration levels.
During the meeting the Chairman confirmed that POL would not seek more
financial support as a result of the litigation, and that we were looking for a
different person to lead the appeal of the CIT judgment to alleviate concerns
regarding our legal advice.
UKGI and the Department sought to strike a balance for the Minister's
statement following the CIT judgment. I was not copied into this note at the time
(Email from Mpst Tolhurst (BEIS) to Tom Cooper (UKGI), Gavin Lambert cc
William Holloway and others RE: POL discussion with SoS and Kelly Tolhurst 16
March 2019, UKGI00017593). Number 10 approved the Minister's final
statement.
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370. On 19 April 2019, Richard Watson, a UKGI lawyer, reached out to HSF copying
the Chairman and myself seeking a discussion on the litigation so that the
Department remained updated (Email from Richard Watson to Alisdair Cameron
and others re Joining up 17 April 2019, POL00270909).
371. On 15 May 2019, I attended a meeting with the Minister (Email from Eleanor to
Carl Creswell, Craig Watson, Cecilia Vandini re Note of Kelly/Al/Tim meeting on
POL — 16 May 2019, UKGI00009777). The Minister had the opportunity to raise
concerns including why legal counsel “kept getting it wrong”, costs of the
litigation and reputational damage. We provided reassurance regarding POL’s
new approach to the litigation. We set out that we would cost out different
scenarios in POL’s 5-year plan for the July 2019 Board and would share with
the Department. We emphasised POL’s commitment to improving relationships
with Postmasters, although this would take time, and agreed that POL would
work more closely with the Department in future to improve public
communication with a better tone to admit mistakes and fallibility.
372.1 followed up our commitment to better communicate with the Minster with the
Shareholder Representative and a member of the Minister's policy team the
same day (Email chain from Carl Creswell to Thomas Cooper, Alisdair Cameron
and Pauline Sullivan re: Supporting the Minister 16 May 2019, UKGI00017603).
373. As we received major updates in the litigation, such as permission to appeal the
CIT judgment being refused by Mr Justice Fraser on 23 May 2019, we sought to
keep the Department informed, although we had to follow the rules where the
updates were embargoed (Email from Alisdair Cameron to Thomas Cooper, Tim
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Parker & Ben Foat RE: Appeal hearing on common issues 23 May 2019,
POL00103557).
374. On 2 June 2019, I sent a draft letter for the Chairman to send to the Minister,
answering key questions in respect of the current status of the litigation,
changes to litigation strategy following the appointment of the new legal team,
possible settlement scenarios, an assessment of potential costs of the litigation,
operational consequences and confirmation of POL’s ability to fund any
settlement (Email Chain from Alisdair Cameron to Tim Parker, Ben Foat and
Alan Watts re: FW: Letter from Kelly Tolhurst MP Re POL (May 2019) - Legally
Privileged 2 June 2019, POL00103569).
375. On 4 June 2019, I also sent a formal letter to the Minister focused on
commercial matters (Letter from Al Cameron to Kelly Tolhurst MP re: follow up
from meeting on 15 May 4 June 2019, UKGI00010232). This covered an
increase in Postmaster remuneration; the franchising consultation process;
asking her views on improving communication; and a number of commercial
priorities.
376. In an email on 7 June 2019, I acknowledged the Minister's anxieties in respect
of the litigation (Email from Alisdair Cameron to Alan Watts, Kirsten Massey,
Ben Foat and Others re GLO Pre Meet and Sub Committee - Legally Privileged
and Confidential 7 June 2019, POL00103576).
377. On 28 June 2019 I sent a further letter to the Minister, again with a largely
commercial focus but confirming that we were now much more open to
information sharing and thanking her for her support to date (Letter to Kelly
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378.
379.
Tolhurst MP from Al Cameron re. follow up letter of 19" 28 June 2019,
UKGI00010371).
The Minister replied to my letter on 5 July 2019. She recognised our openness
to discussing new litigation strategies. She also confirmed that a Department
representative would attend the subsequent GLO Sub-Committee meetings
(Letter from Kelly Tolhurst MP to Al Cameron - Re: PoL Litigation and
engagement with DWP 1 July 2019, UKGI00010369). Richard Watson from the
Department attended the meetings from 17 September 2019.
After I moved back into the CFO role, responsibility for the relationship with the
Minister moved to Nick Read.
Reflections on the litigation
380.
381.
382.
Over 2018 I had become increasingly convinced that POL needed to change
the way we approached the business on several fronts. Most important was
building a better, more open, more supportive and more rewarding relationship
with Postmasters.
I felt that the litigation had made it harder for us to admit where we needed to do
better and to change. The defence was often prioritised over the business.
I therefore reacted to the CIT judgment with a belief that we must change our
culture and approach, openly acknowledging criticisms and being publicly
determined to change. I was able to obtain Board agreement to investing in
some of these objectives in 2019 — 2020.
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383.
384.
385.
386.
The change of legal advisors was important and enabled the change of strategy
to seeking settlement.
Following the judgments in 2019, I felt that decisions on how POL managed
ongoing projects such as the previous criminal convictions, and improved
operations, should not lie with those individuals who had presided over the
trials. We were unlikely to reassure anyone that POL had changed if the
membership of committees such as the GLO Sub-Committee remained
unchanged. Similarly, while I agreed to continue to sponsor Operations until
Nick Read found a successor, I recommended that different people should
assess POL’s operations and processes against the requirements of the
judgments to ensure an adequate response to the GLO.
In November 2020 I prepared a paper “What Went Wrong? A Draft for
Discussion” (19 November 2019, POL00175235). This was drafted for Nick
because I was concerned that if we didn’t articulate a view on what went wrong,
promises that it could not happen again could seem hollow. I intended it as a
purely personal view, addressing both what I had seen and what I thought had
happened before I joined the business.
In the paper I set out my belief that at the heart of the issues experienced by
POL was a culture which stopped us from dealing with Postmasters in a
straightforward and acceptable way. This skewed POL’s judgements about
prosecutions and subsequent management of the litigation. On reflection, I still
agree with the conclusions that I reached in this document today.
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387.
388.
The paper was discussed with Nick Read, Richard Taylor (then
Communications director) and Ben Foat and I believed helped to prompt some
cultural challenge for the leadership team in early 2021. I had intended the
paper to be a first draft to be built on by others to create a shared narrative for
POL to test against in the future. I am not aware that ever happened.
With Nick’s agreement, in 2020 I helped bring in Deloitte to provide an
independent assessment of which operational objectives following the GLO we
believed had been delivered and whether that could be proven to be the case.
This proved to be a substantial piece of work with complex areas including the
ongoing issues of proving Horizon worked and managing shortfalls in the
Network.
PROSECUTION OF POSTMASTERS
389.
390.
391.
In my previous role within British Gas, at times prosecutions were sought
against people who, we believed, stole electricity or gas. Getting the attention
and support of the Police was sometimes difficult, depending on their other
priorities.
Having an expert, in-house function at POL for prosecutions therefore seemed
to me a sensible and pragmatic approach. I understood that POL had no
specific powers and that any organisation could work in this way if it had the
right skills.
Anumber of the criminal convictions based on Horizon were not prosecuted by
POL, but by state prosecution authorities such as the CPS. This suggests that
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POL acting as prosecutor was not a decisive factor in the miscarriages of
justice. However, I do now believe that the separation of investigators and
prosecutors is important, and POL should never again act as prosecutor.
392. Around November 2015, I asked POL’s legal team for an updated Prosecutions
Policy for the GE. I did this because there were apparently concerns expressed
in the Network that a reduction in prosecutions was having an adverse impact
(Email from Jane Macleod to Rodric William, John M Scott, Angela Van-Den-
Bogerd and others RE: Prosecution policy 13 November 2015, POL00176615).
393.1 do not recall the specific concerns expressed in the Network referred to by
Jane MacLeod in her email but as CFO my sense was that the previous years
of prosecutions had kept these losses relatively small, that they were growing
and that if people did not have to pay for shortfalls, the financial stability of the
business would be at risk.
394. The policy was subsequently presented to the Board and endorsed on 21 March
2016 (POL Minutes: Board Meeting held 21 March 2016, POL00027598). I do
not recall being asked to provide specific input in relation to the policy.
395. While prosecutions had ceased as a result of Sparrow, the expectation was that
they would be re-started when the legal processes were completed and POL
identified expert witnesses that could testify robustly on our behalf in respect of
the causes of shortfalls.
396. Later, in June 2017 I provided a standard update to the GE on issues getting
focus within Operations, including the need for further safety equipment to
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support Postmasters as more weapons were being used in robberies (Email
chain from Ben Foat to Rodric Williams Re: Ops Board and Losses & Crime
Group 27 June 2016, POL00249527).
397.1 also sent on my note to Jane calling out the FSC’s concern “over the ability of
legal to respond on the debt collection process.” We had been trying to work out
how to approach the legal work around debt collection where we considered
there were amounts which Postmasters owed to us. These were being provided
for as losses.
398. Following a meeting, I clarified my understanding on 27 June 2017 that: “We
should not attempt to prosecute any cases where the losses had arisen from or
were identified via trading and Horizon rather than straight theft, until two things
happen. First, we complete the Deloitte work on systems reliance. Secondly, the
CCRC opine.” (Email chain from Ben Foat to Rodric Williams Re: Ops Board
and Losses & Crime Group, 27 June 2017, POL00249527).
399. I felt that our approach should be confirmed in a formal decision and asked the
legal team to prepare a brief to discuss with Paula Vennells.
400. I also suggested we identify a suitable test case for a prosecution which relied
on Horizon, and raised a perennial cost concern that if we were not going to use
a specialist team that can undertake prosecutions, then it was not sensible
financially to continue funding them.
401. On 2 August 2017 following a Board meeting one of the agreed actions noted
that “The CEO explained that the decision not to prosecute agents if they could
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402.
403.
use the Horizon system as a defence would be reconsidered once Deloitte had
completed their work on Horizon and could be used in court as an expert
witness” (Status Report for Post Office Limited 2 August 2017, POL00103308).
This demonstrates the settled position at that time was not to prosecute
Postmasters until the conclusion of any litigation given the allegations were that
Horizon was leading to shortfalls.
Between August and 27 October 2017, I initiated a dialogue with Mark Raymond
who led the team that would undertake prosecutions on behalf of POL. I
explained to him that any prosecutions were at least a year away and he set out
some factors in response which he considered would be needed for a test case.
He had raised possible cases for prosecution but acknowledged that due to the
current Deloitte review of Horizon underway POL was not in a position to
proceed with any prosecutions at that stage (Email from Mark Raymond to
Alisdair Raymond and Mark Ellis RE: Cases suitable for prosecution 27 October
2017, POL00251125).
In paragraph 136 above, I explained that these issues are unresolved and by
April 2023, losses were rising and not being properly investigated. I was very
clear that we could not enforce recoveries without the right work being
completed. My informal view was and is that POL should not pursue
Postmasters for shortfalls through legal action while Horizon is in its current
form.
RELATIONSHIPS WITH STAKEHOLDERS
Postmasters
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404. In my executive roles I rarely got involved with issues faced by individual
Postmasters, as the primary stakeholder relationship with POL was through the
Network or Retail teams. The teams I was responsible for provided operational
support and I tended to see that through the lens of collective statistics, control
measures, efficiency and cost effectiveness. This was consistent with how I had
overseen the running of a call centre in a previous job. However, there were a
few individual scenarios that I was made aware of during my tenure which I set
out below.
405. In July 2016, Paula Vennells asked myself and Rob Houghton for a report into
the Dalmellington Error bug which was an issue raised in a blog by Tim
McCormack. Jane MacLeod responded to Paula’s request to reassure Paula
that the matters Tim McCormack had raised were subject to review and that
they were “on top of this” (Email from Rob Houghton to Gavin Bell and others
Re: Dalmellington error in Horizon / problemswithpol 1 July 2016,
POL00029993).
406.1 was not copied on the rest of the correspondence following this, which I can
now see was concluded with a clear explanation from Fujitsu that the problem
was understood and had been resolved, and that monitoring checks had been
made to identify any further issues for Postmasters. I am not aware that I was
included in any further correspondence with Fujitsu discussing this potential
bug.
407. On 30 October 2017, I was copied into correspondence relating to a sudden
closure of a post office in Rutherglen, where concerns were raised that the
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408.
closure had been without consultation or proper warning. In the correspondence
it was identified that the branch had to be closed following the suspension of the
Postmaster when an audit identified a loss of £123,000 (Email from Mark R
Davies to Linda Bonar, Ruth X Barker, Alice Cookson and others re: Save
Rutherglen Post Office 30 October 2017, POL00163217). We discussed that
better messaging was needed to explain closures to the public than “operational
reasons”. I could understand public frustration and wondered if we could be
more open to explain that we were investigating issues. However, I can now see
that in later emails, into which I was not copied, the communications team
advised that it was an extremely complex situation compounded by other events
at nearby branches and therefore it was difficult to communicate fuller reasons
to the public and media without legal implications. I do not recall having this
information at the time.
In February 2018 I was copied by Paula Vennells into correspondence
regarding a Postmaster complaint (Email from Paula Vennells to Alisdair
Cameron and Debbie Smith re Seaton Post Office and Post Office Ltd 20
February 2018, POL00253502). In summary, the complaint was in relation to a
nearby branch opening shortly after the Postmaster had newly opened his own
branch, and he had concerns about the impact on trading. There was a further
perceived lack of consultation in this scenario. In my response I focused less on
the specifics of the issue, which were being handled, than POL’s issue with
“getting the human engagement bit wrong”. I acknowledged the difficulties of
asking junior employees to take on the burden of dealing with the human side of
their work and suggested that POL as a business needed to give more in terms
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of engagement, training and support through our field ops teams, with a clearer
escalation to senior employees to assist.
409. Much later in June 2019, while I was interim CEO, I was contacted directly by
Tim McCormack who flagged an issue being experienced in branches by
Postmasters. I was grateful for this and against the strong advice of POL’s
Communications Director, I spoke with Tim McCormack about the issue. I did this
because I felt it was important to engage with potential critics and as part of
POL’s determination to change in culture, and to view criticism as an opportunity
to do better (Email from Mark R Davies to Melanie Corfield, Mark Underwood,
Angela Van-Den-Bogerd RE: Fwd: Another Computer Error. Chain includes
correspondence with Tim McCormack. 23 June 2019 POL00136417).
410. The issue that Tim McCormack raised was with Horizon and was being
identified and managed locally in branches but had not been escalated or
properly resolved. We were able to assist in communicating the issue and its
solution to the Network transparently for resolution and Tim McCormack later
thanked us for this approach (Email RE: “The error, Catch 22...” , 29 June 2019,
POL00423915).
NFSP
411.At the GE on 12 March 2015 and the Board meeting on 18 June 2015 (Post
Office Limited Board meeting minutes -18'" June 2015 re Agreement with NFSP,
UKGI00017284), POL approved a new agreement with the NFSP whereby POL
would provide most of the NFSP’s funding. The agreement also included a clause
that the NFSP could not criticise POL in public. It is clear to me that these facts
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undermined NFSP’s independence from POL in its representation of
Postmasters.
412. This agreement was reached because of a concern that if the NFSP failed, as a
trade representative, they would be replaced by a Union, possibly the CWU.
413. In the Operational Responses Report dated 22 March 2019 (POL00269350), I
emphasised: “We need an effective representative body for agents
(Postmasters) that they can support. Can the NFSP evolve to fulfil that role, or
will agents prefer to replace it? How can we help without undermining its
confidence?”
414. In early April 2019, I was working on a speech to give in my role as Interim CEO
at the NFSP conference. As set out earlier in my statement (from paragraph
218), I was keen to use the opportunity to show Postmasters that we were
listening to them, valued them and to explain what POL thought was important.
In the final version of the speech I delivered, I asked the NFSP to “become
more truly representative” and “be open and challenging.” (NFSP conference —
key note speech: Monday 15 April 2019, 11am - 11.45 POL00270665).
415. In the Board papers for 30 April 2019 (PO Board Agenda — 1.19 Wakefield 30
April 2019, POL00163556), I reported attending the NFSP conference. We had
recently released the NFSP from the clause in our agreement preventing them
criticising us in public. We had promised a deeper review of Postmaster
remuneration at the Board meeting that October. We recognised that the
conference had highlighted the extent to which Postmasters had felt neglected. I
acknowledged that POL should not complain about the NFSP putting the
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business and HMG under pressure to do more for them. This discussion and the
Postmaster survey led to a Select Committee in 2019 and improved remuneration
for Postmasters.
Media
416.1 have set out at various points during my statement where I was involved in
discussions regarding POL’s engagement with the media, particularly during the
litigation and when I was interim CEO.
417. More generally, while I did not tend to seek out media contact, I occasionally
answered questions on a particular Annual Report.
418.1 recall undertaking at least one media training session as part of my role. I have
been provided with a media training script from January 2019 (Post Office
Media Training Scenario: Horizon 21 January 2019, POL00262341), although I
do not have specific recollections about this session.
419.1 occasionally received requests to speak to journalists but was advised not to
by Nick Read and Richard Taylor.
Fujitsu
420. As set out earlier in my statement (see from paragraph 98), when I joined POL,
Fujitsu had withdrawn from the Front Office IT tender and would therefore be
exiting the business, except for its ongoing support contract for our Telco
business.
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421.
422.
423.
424,
425.
Part of the reasoning for appointing IBM to complete the Front Office project
was their proposed “collaborative and partnership approach to working with
other suppliers...A stable and robust stock control and accounting platform that
will mitigate against Sparrow scenarios in the future.” (Memorandum for POL
Board from Lesley Sewell, Kevin Gilliland and Alisdair Cameron - Front Office
Contract Award to IBM UK Ltd and Fujitsu Horizon, 21 May 2015,
POL00027278).
In entering the new contract with IBM, we had acknowledged internally that
Fujitsu had been difficult colleagues; concerns had been raised previously about
their levels of service. Further, we could have managed shortfalls better with
more accessible data on branch transactions and sought to achieve with this a
new Front Office system. Finally, and as set out earlier in my statement, it was
accepted that Horizon, and the infrastructure on which it was built, was
vulnerable (see paragraph 94).
Unfortunately, despite the clear motivations to implement a new Front Office
system, over the next few months, the Interim CIO and I developed our
assessment that the IBM replacement programme for Horizon was not credible,
despite the enormous work that had gone into the procurement.
I therefore asked the Interim CIO to engage Fujitsu and see whether there was
a way in which we could evolve the relationship: I could not see any practical
alternative to keeping the Front Office systems running.
By November 2015, we had reached a consensus between Fujitsu (led by
Regina Moran) and POL (led by me) to work together to reach an agreement for
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426.
427.
428.
Horizon to continue with a new functionality and expanded scope (Minutes of
meeting at 20 Finsbury Street - Chris Broe, Alisdair Cameron, Gavin Bell, Nigel
Shaw and Regina Moran 20 November 2015, FUJ00175270).
During a meeting on 20 November 2015, the minutes report that I raised the
issue of Fujitsu remaining an independent witness in the litigation if they were to
continue to be the provider of POL’s Front Office services. I was reassured by a
member of Fujitsu that an independent expert approach was in place. I do not
have specific recollections of raising this and can refer only to the minutes
recorded.
Subsequently, on 9 February 2016, the Board approved the termination of the
IBM contract and the extension of the Horizon contract with Fujitsu.
I have explained that part of the motivation for POL moving to another Front
Office service provider was difficulties we had in our relationship with Fujitsu. On
9 May 2016, before we had agreed to continue working with Fujitsu longer term,
I complained to Regina Moran about the quality of their service, noting in
particular issues with their response to a Postmaster remuneration issue and
Horizon failure where we felt that Fujitsu had not demonstrated an
understanding of the urgency or seriousness of the situation (Email from Regina
Morgan to Alisdair Cameron, cc to Rob Houghton, Chris Boe and others Re:
Service Horizon etc 9 May 2016, FUJ00175302). Regina Moran responded to
my concerns briefly that a full review of the issue had been organised and she
would revert further.
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429.
430.
431.
432.
433.
On 19 June 2016 I contacted Regina Moran again following a meeting with her
to set out that there was a need for a “radical recasting” of POL’s relationship
with Fujitsu across a range of issues including leadership, culture and cost
(Email chain from Regina Moran to Gavin Bell re: Fwd: Follow Up 19 June
2016, FUJ00175336). I stated that POL was committed to the relationship with
Fujitsu but emphasised that it needed to be sustainable, setting out a list of key
priorities.
After this period, the ownership of the relationship with Fujitsu moved
progressively to Rob Houghton and he led the next contractual evolution.
My general recollection from 2017 onwards is that the relationship with Fujitsu,
especially once Regina Moran had moved on, did not develop as POL had
hoped. We had envisaged a more modern partnership with Fujitsu enabling a
digital transformation of Horizon, including a move to the cloud. It became
apparent that they did not have the capability to deliver this objective.
During the litigation I was no longer the executive responsible for IT and did not
oversee the Fujitsu relationship, which had moved to Rob Houghton. On 25
March 2019, the Board minutes refer to an IT error that had affected Horizon
which was fixed overnight (Post Office Limited Board Meeting Minutes 25 March
2019, UKGI00017291). I do not have any further recollection of this incident or
whether we were later informed of the root cause. I do not know whether POL
liaised with Fujitsu at the time about this issue.
I do recall during my time as Interim CEO meeting with Duncan Tait (of Fujitsu)
and that I asked him why Fujitsu witnesses seemed so unable to manage the
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questions being posed to them in the litigation. This reflected Paula Vennell’s
concerns about Fujitsu’s witnesses earlier that year (POL00176667). I do not
recall Duncan Tait providing any response.
434.1 do not recall any further discussions of bugs, errors and defects, prosecutions
or expert evidence being part of my correspondence with Fujitsu. In the period
when I was responsible for the relationship with Fujitsu (2015 and into 2016) I
do not recall being aware of there being serious errors in Horizon. It is possible
that they were discussed during the second contractual evolution (led by Rob
Houghton) as, although I would have had sight of the Board papers, my role in
this was more peripheral.
435. On 5 November 2019 I prepared a note to Nick Read before a meeting with
Fujitsu to share my experiences (Email from Rodric Williams to Ben Foat,
Sherrill Taggart, Jacqueline Scott and others Re: FW: Fujitsu decisions thoughts
- legally privileged 5 November 2019, POL00288080). In it I summarised
concerns, in particular that Fujitsu might think that POL did not have the
capacity or will to exit the Horizon and Telco contracts. I acknowledged that POL
would not now choose Fujitsu to provide Front Office systems as their
technology and digital skills were “lagging”. It had been pointed out that the
individuals who had designed and understood Horizon were similarly aging and
many were now retiring. I raised particular concerns over Fujitsu’s
“performance” during the litigation, referring to the evidence that had been
provided and POL relied upon which later turned out to be inaccurate (see
above from paragraph 352). I also suggested that a team from POL should go
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436.
to Japan for a serious discussion with Fujitsu about the future of the relationship
with POL, and the timetable for an exit strategy. I do not believe this happened.
It is very clear that the level of scrutiny applied to Fujitsu’s operation of Horizon
was not sufficient. The existence of remote access, for example, demonstrates
that POL simply didn’t understand fully how Horizon worked.
CONCLUSIONS
Ownership and the Future of POL
437.
438.
439,
It always seemed unlikely to me that the Post Office network could be owned by
a financial investor. It has never looked profitable enough to fund dividends and
it was hard to see political appetite for the required structural and governance
changes.
However, a mutual ownership of Post Offices would enable Postmasters to own
the Network. Postmasters are, as well as being the channel through which Post
Office sells most of its product, its greatest cost in any given year. Lower
Postmaster remuneration increases POL’s profit and enables POL to hit its profit
targets. “Putting Postmasters First’ normally falls at this first hurdle.
My strong belief is that Postmasters need to own the Network. The cost will be
considerable, the governance complex and the timing should align with the
replacement of Horizon, with Postmasters offered new contracts.
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440. The roll-out of a Horizon replacement will be extremely complex, crystallising
WITNO09840100
WITN09840100
any shortfalls in the Network. It will require a high degree of trust between POL
and Postmasters, which is hard to envisage.
Statement of Truth
I believe the content of this statement to be true.
Signed: / G RO
Dated: 18 April 2024 I 12:53 BST
Page 115 of 137
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DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
Index to First Witness Statement of Alisdair John Charles Cameron
No. URN Document description Control Number
POL00362178 POL governing Board Terms I POL-BSFF-
of Reference and Schedule of I 0190688
Matters Reserved (26 June
2015)
2. POL00362224 POL Governance Induction I POL-BSFF-
Pack (April 2018) 0190734
3. POL00006752 Draft Meeting Minutes of the I POL-0018010
Postmaster Litigation
Subcommittee of POL
(20/06/2019)
4. POL00026719 Post Office, Minutes of a I POL-0023360
meeting of the Audit, Risk
and Compliance Committee
(25/03/2015)
5. POL00227870 Risk and Compliance I POL-BSFF-
committee meeting I 0065933
(01/05/2015)
6. POL00110251 Audit Risk and Compliance I POL-0108070
Committee - November 2015
(10/41/2015)
7. POL00021433 Post Office Limited Audit, I POL-0018063
Risk and Compliance
Committee minutes of
20/05/2015 (20/05/2015)
8. POL00240662 POL Audit, Risk and I POL-BSFF-
Compliance Agenda I 0078725
(17/03/2016)
9. POL00103188 Post Office Audit Risk and I POL-0102771
Compliance Agenda
(19/05/2016)
Page 116 of 137
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DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
10. I POL00362165 Terms of Reference for POL I POL-BSFF-
Group Executive I 0190675
(19/02/2015)
11. I POLO0154004 Group Executive Agenda I POL-BSFF-
Post Office re: Monthly I 0013109
Update (Report P12 Flash
Results to GE) by lead Chris
Broe / Angela Van Den
Bogerd, Radha Davies, Kevin
(16/05/2016)
12. I POL00423699 Email Subject The I POL-BSFF-
robustness of our I 0238490
governance (26/03/2023)
13. I POL00219395 CEO's Report - January 2015 I POL-BSFF-
(01/01/2015) 0057458
14. I POL00270665 NFSP conference - key note I POL-BSFF-
speech: Monday 15 April, I 0108728
11am - 11.45 (12/04/2019)
15. I POL00021531 Meeting minutes: minutes of I POLO000064
Board meeting held on 28th
January 2015 (28/01/2015)
16. I FUJ00175204 Email from Alisdair Cameron I POINQ0181385F
to Michael Keegan and cc'd
Steve Clayton and Ruth
Phillips re: RE: Fujitsu and
POL (15/05/2015)
17. I FUJ00175206 Briefing for Meeting - Alisdair I POINQ0181387F
Cameron (Chief Financial
Officer at Post Office)
20/05/15 V1.0 - By: Mark
Phillips (19/05/2015)
18. I POL00027278 Memorandum for POL Board I POL-0023919
from Lesley Sewell, Kevin
Gilliland and Alisdair
Cameron - Front Office
Contract Award to IBM UK
Page 117 of 137
DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
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WITN09840100
Ltd and Fujitsu Horizon
(21/05/2015)
19.
POL00027309
Memorandum for the Board
of Post Office Limited from
Alisdair Cameron - Fujitsu
Extension Option by Al
Cameron (29/06/2015)
POL-0023950
20.
POL00027239
POL meeting minutes RE
Fujitsu contract extension
with handwritten annotations.
(02/07/2015)
POL-0023880
21.
POL00220849
Post Office Ltd Group
Executive Agenda, meeting
to be held on 12th February
2015 (12/02/2015)
POL-BSFF-
0058912
22.
POL00103479
Post Office Limited - Post
Office Board Agenda
(25/03/2019)
POL-0103062
23.
POL00423917
Doc: POL_GE_Postmaster
Losses 16 November 2022
(16/11/2022)
POL-BSFF-
0238732
24.
POL00423921
Doc 03.00_POL_GE: GE
Report, 25 January 2023 —
no redactions (25/01/2023)
POL-BSFF-
0238736
25.
POL00423698
Email Subject: Losses
(24/01/2023)
POL-BSFF-
0238489
26.
POL00423700
Email = Subject: Branch
Discrepancies — Findings and
Recommendations
(11/04/2023)
POL-BSFF-
0238491
27.
POL00423920
Email "Question" - with
redactions for privilege.
(16/05/2023)
POL-BSFF-
0238735
Page 118 of 137
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28.
POL00138860
Email from Alisdair Cameron
to Alwen_ Lyons, Neil
NcCausland, Viringa Holmes
and others cc Alice Perkins,
Alasdair Marnoch, Richard
Callard and others RE:
Sparrow paper for the Board
- Action required
(03/03/2015)
POL-BSFF-
0001081
29.
POL00218860
Email from Paula Vennells to
Mark R_ Davies, Alisdair
Cameron, CC Gavin Lambert
and others re: Sparrow - An
idea at pace!
(15/01/2015)
POL-BSFF-
0056923
30.
POL00351276
Email from Rod Ismay to
Peter Goodman Re:
suspense accounts
(15/01/2015)
POL-BSFF-
0176997
31.
POL00040805
Email sent from Mark
Underwood to Belinda Crowe
and others, re Suspense
Accounts (19/01/2015)
POL-0037287
32.
POL00310758
Email from Chris Aujard to lan
Henderson cc Belinda
Crowe, Tom Wechsler, rjw
RE: Meeting with Finance
Team (20/01/2015)
POL-BSFF-
0148808
33.
POL00109892
Email from Avene O'Farrell to
Belinda Crowe and Alisdair
Cameron, cc Chris Aujard
and Gavin Lambert re
Second Sight meeting with
finance team to discuss
suspense accounts
(20/01/2015)
POL-0111104
Page 119 of 137
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34.
POL00220084
Email from Chris Aujard to
Alisdair Cameron, cc
Andrew Parsons and Tom
Wechsler and others re: FW:
Suspense accounts - legally
privileged - urgent [BD-
4A.FID20472253]
(27/01/2015)
POL-BSFF-
0058147
35.
POL00021829
Emails between Paul
Lorraine, Alisdair Cameron,
Andrew Parsons and others
(29/01/2015)
POL-0018308
36.
POL00311251
Email from Jane MacLeod
To: Jane MacLeod re
Sparrow (28/01/2015)
POL-BSFF-
0149301
37.
POL00150989
Email chain including Tom
Wechsler (POL); Alisdair
Cameron (POL); Avene
O'Farrell & others Re:
(29/01/2015)
POL-BSFF-
0010101
38.
POL00130857
Email from Mark R Davies to
Alisdair Cameron cc'ing Jane
MacLeod RE: Urgent - paper
for sub committee
(09/02/2015)
POL-0124313
39.
POL00312064
Email RE: Suspense -
independent firm - scope &
procedures drafts. Including
Suspense - Scoping doc for
Independent review and
Suspense agreed upon
procedures attachment
(12/02/2015)
POL-BSFF-
0150114
40.
POL00312085
Suspense Update to SS
Letter from Alisdair Cameron
to lan (12/02/2015)
POL-BSFF-
0150135
41.
POL00102236
Email from Belinda Crowe to
Alisdair Cameron, Mark
POL-0101819
Page 120 of 137
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Davies, Jane MacLeod and
others. Re: "Catch up call
with Second Sight”
(27/02/2015)
42.
POL00040932
Initial Complaint Review and
Mediation Scheme ( End of
Term Report V7
(06/03/2015)
POL-0037414
43.
POL00225156
Email chain from Mark
Underwood to Alisdair
Cameron cc Rod_ Ismay,
Belinda Crowe, Andrew
Parsons RE: Second Sight's
Part Two’ Report and
assertions made in relation to
Suspense accounts
(20/03/2015)
POL-BSFF-
0063219
44,
POL00313968
Email from lan Henderson to
Alisdair I Cameron, Rod
Ismay, Jane Macleod and
others RE: Client Suspense
Accounts —- Confidential
(27/03/2015)
POL-BSFF-
0152018
45.
POL00102389
Email from Mark R Davies to
Alisdair Cameron, Re:
Sparrow (10/04/2015)
POL-0101972
46.
POL00109933
Email from Paula Vennells to
Alisdair Cameron re:
Mediation Scheme
(30/01/2015)
POL-0111120
47.
POL00153623
Email from Alisdair Cameron
to Neil Hayward, Jane
MacLeod and Paula Vennells
Re: Outreach Branch
Remittances (12/11/2015)
POL-BSFF-
0012735
48.
POL00241349
Email from Alisdair Cameron
to Angela Van-Den-Bogerd
POL-BSFF-
0079412
Page 121 of 137
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DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
RE: Fwd: Horizon Issue —
urgent (09/05/2016)
49. I POL00241374 Email from Tim Franklin to I POL-BSFF-
Paula Vennells RE: Media I 0079437
coverage on Horizon system
failure (09/05/2016)
50. I POLO0163019 Email from Chris Broe to I POL-0151371
Mark Davies, Paula Vennells,
Kevin Gilliland and others re:
Horizon Incident 9th May
2016 - Diagnosis, Lessons
Learned and Actions.
(10/05/2016)
51. I FUJ00169083 Email from Regina Moran to I POINQ0175264F
Alisdair Cameron, CC'ing
Gavin Bell, Chris Broe, and
another re: Update - doing a
full investigation and working
with Oracle. (11/05/2016)
52. I FUJ00175319 Letter from Robert Houghton I POINQ0181500F
to Gavin Bell re: RE: Horizon
service outage incident on
9th May 2016 (“Service
Incident”) (12/05/2016)
53. I UKGIO0009385 Letter from Kelly Tolhurst MP I UKGI020193-001
to Tim Parker - Re:
Appointment of Al Cameron
as interim CEO (20/03/2019)
54. I UKGI00010163 Letter from Alex Chisholm to I UKGI020971-001
Alisdair Cameron re:
Accountable person:
Instruction from BEIS
permanent secretary to the
CEO of Post Office Ltd on
accountabilities and
responsibilities (09/06/2019)
Page 122 of 137
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55.
POL00250703
Email from Jane MacLeod to
Avene Regan, cc Paula
Vennells and Alisdair
Cameron te _Litigation-
meeting with Tony Robinson
(22/09/2017)
POL-BSFF-
0088766
56.
POL00006462
Steering Group — Briefing
Paper: Update on case
management strategy
(04/10/2017)
POL-0017767
57.
POL00024292
Email chain from Jane
MacLeod to Andrew Parsons
and Rodric Williams, Re:
Postmaster Litigation
(05/12/2017)
POL-0020771
58.
POL00024182
Email chain between Jane
MacLeod, Alisdair Cameron,
Paula Vennells and others
Re: Postmaster Litigation -
Briefing notes for the Board.
(28/01/2018)
POL-0020661
59.
POL00103336
Email from Jane MacLeod to
Tim Parker; Ken McCall;
Carla Stent; Tim Franklin, re:
Postmaster Litigation -
Confidential and subject to
Legal Privilege - Do not
Forward. (01/06/2018)
POL-0102919
60.
POL00021556
Meeting minutes: minutes of
Board meeting held on 31st
July 2018 (31/07/2018)
POL0000089
61.
POL00255647
Email from Alisdair Cameron
to Stephen Clarke RE: Post
Office Group Litigation -
SUBJECT TO LEGAL
PRIVILEGE - DO NOT
FORWARD (05/07/2018)
POL-BSFF-
0093710
Page 123 of 137
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DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
62. I POL00024204 Email chain from Jane I POL-0020683
MacLeod, Andrew Parsons,
Rodric Williams and others
Re: Postmaster Litigation -
Security for Costs
(16/09/2018)
63. I POL00154340 Email from Alisdair Cameron I POL-BSFF-
to Paula Vennells, Jane I 0013439
MacLeod, Mark R Davies Re:
Tomorrow's GLO Meeting
(16/10/2018)
64. I UKGI00008519 BEIS Agenda: ‘Post Office: I UKGI019330-001
Horizon Trial Contingency
Planning’ (17/10/2018)
65. I UKGI00008554 Draft read out note of POL I UKGI019362-001
meeting in HoC on 17th
October 4-4:45pm
(17/10/2018)
66. I POLO0259560 Email from Melanie Corfield I POL-BSFF-
to Mark R Davies, Rodric I 0097623
Williams, Ben Float and Bob
Hammond RE: For action-
F&O call on _ Thursday
2.15pm (21/11/2018)
67. I POL00260202 Email from Jane MacLeod to I POL-BSFF-
Paula Vennells, Alisdair I 0098265
Cameron and CC Rodric
Williams re: Board Report re
Litigation © CONFIDENTIAL
AND SUBJECT TO LEGAL
PRIVILEGE - DO NOT
FORWARD (17/12/2018)
68. I POL00242323 Email from Mark Underwood I POL-BSFF-
to Mark Westbrook cc'd I 0080386
Patrick Bourke re: Private &
Page 124 of 137
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WITN09840100
Confidential: Subject to Legal
Privilege (03/06/2016)
69.
POL00110592
Email chain from Alisdair
Cameron to Jane MacLeod
re: Private & Confidential:
Subject to Legal Privilege:
Suspense Accounts
(08/02/2017)
POL-0108307
70.
POL00247840
Email chain from Ruth
Phillips to Kay Wilson, Paul
Smith and others re
suspense account
(22/03/2017)
POL-BSFF-
0085903
71.
POL00024323
Post Office Group Litigation
Steering Group Meeting -
Noting Paper: Deloitte
Reports (03/11/2017)
POL-0020802
72.
POL00423922
Doc: ARC_Current Operation
of Suspense Accounts, 27
July 2020 (27/07/2020)
POL-BSFF-
0238737
73.
POL00030907
Doc: ARC Committee
Report, 24 November 2020
with redactions for privilege.
(24/11/2020)
POL-BSFF-
0238738
74.
POL00241640
Email from Carla Stent to
Alisdair Cameron and Tim
Franklin CC'ing Peter Mclver
RE: Conversation with EY
team relating to Post Office
ARC meeting (26/05/2016)
POL-BSFF-
0079703
75.
POL00021446
Post Office Limited Audit,
Risk and Compliance
Committee Minutes of
28/06/2018 (28/06/2018)
POL-0018076
Page 125 of 137
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WITN09840100
76.
POL00120814
Post Office Group Litigation
Report (01/07/2018)
POL-0126427
77.
POL00255796
Email from Alisdair Cameron
to jane Macleod RE: POL
Contingent Liability Issue and
Outstanding Items
(16/07/2018)
POL-BSFF-
0093859
78.
POL00255968
email from Jane MacLeod to
Paula Vennells, Alisdair
Cameron, Carla Stent and
others re PostMaster
Litigation - Disclosure in the
ARA. (27/07/2018)
POL-BSFF-
0094031
79.
POL00021447
Post Office Limited Audit and
Risk Committee meeting
Minutes of 29/05/2019
(29/05/2019)
POL-0018077
80.
POL00103569
Email Chain from Alisdair
Cameron to Tim Parker, Ben
Foat and Alan Watts re: FW:
Letter from Kelly Tolhurst MP
Re POL (May 2019) - Legally
Privileged (02/06/2019)
POL-0103152
81.
POL00276017
Email from Thomas Cooper
to Alisdair Cameron, Alan
Watts and Ben Foat re:
Legally Privileged - GLO sub-
committee (05/06/2019)
POL-BSFF-
0114080
82.
POL00176667
Email from Paula Vennells to
ROb Houghton, Jane
MacLeod, Rodric Williams
and others RE: Fujitsu Call
(11/02/2019)
POL-BSFF-
0014730
83.
POL00267444
Email from Alisdair Cameron
to Jane MacLeod in response
to proposed email to Post
Office Board following the
POL-BSFF-
0105507
Page 126 of 137
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DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
judgement in the Common
Issues Trial (08/03/2019)
84. I POL00154694 Email from Alisdair Cameron I POL-BSFF-
to Jane MacLeod RE: Board I 0013791
Call on the GLO - Legally
privileged and confidential
(11/03/2019)
85. I POL00136433 Email from Alisdair Cameron I POL-0140886
to Jane MacLeod, Mark R
Davis, Melanie Corfield and
others re GLO Decision and
resulting actions required
(08/03/2019)
86. I FUJ00171178 Email from Alisdair Cameron I POINQ0177359F
to Duncan Tait cc Rob
Houghton RE: Post Office
update - Group Litigation
(15/03/2019)
87. I POLO0267739 DRAFT OVERALL MEDIA I POL-BSFF-
STATEMENT — in strictest I 0105802
confidence, legally privileged
— subject to legal advice
(15/03/2019)
88. I POLO0163485 Email chain from Alisdair I POL-0151719
Cameron to Mark R Davies,
Jane MacLeod cc'ing Melanie
Corfield and others re: Draft
media statement
(13/03/2019)
89. I POL00270605 Email from Jane MacLeod to I POL-BSFF-
Alisdair Cameron and others I 0108668
re STRICTLY
CONFIDENTIAL AND
SUBJECT TO LEGAL
PRIVILEGE: Key _ note
speech (11/04/2019)
Page 127 of 137
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DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
90. I POL00269350 POL Operational Responses I POL-BSFF-
to the GLO (22/03/2019) 0107413
91. I POL00273832 CEO Report - The GLO I POL-BSFF-
Author: Al Cameron I 0111895
(30/04/2019)
92. I POLO0021565 Meeting minutes: minutes of I POLO000098
Board meeting held on 30th
April 2019 (30/04/2019)
93. I UKGIO0010232 Letter from Al Cameron to I UKGI021040-001
Kelly Tolhurst MP re: follow
up from meeting on 15 May
(04/06/2019)
94. I POL00268475 Email chain from Alisdair I POL-BSFF-
Cameron to Jane MacLeod I 0106538
RE: Board sequencing
(16/03/2019)
95. I POLO0268060 Email from Jane MacLeod to I POL-BSFF-
Jane MacLeod RE: Litigation I 0106123
Options (15/03/2019)
96. I POLO0025910 Advice by Lord Neuberger on I POL-0022389
the recusal application
(14/03/2019)
97. I POLO0027594 POL Board Meeting - Minutes I POL-0024235
of a call of the Board of
Directors of POLTD
(18/03/2019)
98. I POLO0006397 Note of conferences on I POL-0017702
18/3/2019 and 20/3/2019 with
Lord Grabiner Qc
(20/03/2019)
99. I POL00103473 Post Office Limited The I POL-0103056
Board of Directors Discussion
Paper - The Background to
Page 128 of 137
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Recusal and other issues
(20/03/2019)
100.
POL00021563
Board call GLO 20 March
2019 (20/03/2019)
POLO000096
101.
POL00269061
Email from Mark R Davies to
Jane MacLeod, = Alisdair
Cameron cc Mark
Underwood, Patrick Bourke,
Melanie Corfield RE:
Statement (21/03/2019)
POL-BSFF-
0107124
102.
POL00269063
Email from Cameron RE:
Statement: legally privileged
and strictly confidential
(21/03/2019)
POL-BSFF-
0107126
103.
POL00359925
Email from Jane MacLeod to
Alisdair Cameron, Thomas
Cooper, CC Avene Regan
and others re: Post Office -
Recusal Application -
confidential and subject to
legal privilege - do not
forward (09/04/2019)
POL-BSFF-
0185646
104.
POL00103490
Email from Alisdair Cameron
to Jane MacLeod re. Post
Office - Recusal Application
CONFIDENTIAL AND
SUBJECT TO LEGAL
PRIVILEGE - DO NOT
FORWARD (09/04/2019)
POL-0103073
105.
POL00103495
Email from Alisdair Cameron
to Tim Parker re. Update
(12/04/2019)
POL-0103078
106.
POL00360195
Email from Ben Foat to Alan
Watts, Kirtsen Massey, CC
Alisdair Cameron and others
re: Group Litigation - recusal
application - legally privileged
POL-BSFF-
0185916
Page 129 of 137
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WITN09840100
DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
and highly confidential
(11/05/2019)
107.I POL00103539 Email from Alisdair Cameron I POL-0103122
To Tim Parker, Thomas
Cooper, Ken McCall & Ors
RE: request for appeal on
recusal (13/05/2019)
108.I POL00275995 Email from Alisdair Cameron I POL-BSFF-
to Alan Watts, Ben Foat cc'd I 0114058
Thomas Cooper re: Legally
Privileged - GLO sub-
committee (04/06/2019)
109. I POLO00103438 Email from Alisdair Cameron I POL-0103021
to Thomas Cooper re.
URGENT: Litigation Options -
Confidential and Subject to
Legal Privilege (15/03/2019)
110.I POL00270753 Email chain including Jane I POL-BSFF-
MacLeod (POL); Ruth I 0108816
Cowley (Norton Rose Full
Bright "NRFB"); Glen Hall
(NRFB) & Others Re:
Postmaster Litigation Update
(14/04/2019)
111.I POL00006513 Email from Andrew Parsons I POL-0017818
to Jane MacLeod c.c. Amy
Prime, Ben Foat: Subject
‘Catch Up' (17/04/2019)
112.I UKGI00043848 Email from Alisdair Cameron I UKGI052165-001
to Thomas Cooper, Tim
Parker, Shirine Khoury-Haq
and others re: RE: Post Office
trial (12/05/2019)
113.I POL00275357 Email from Ben Foat to I POL-BSFF-
Alisdair Cameron re: Group I 0113420
Litigation- Legally Privileged -
Page 130 of 137
DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
WITNO09840100
WITN09840100
Highly Confidential
(23/05/2019)
114.
POL00103576
Email from Alisdair Cameron
to Alan Watts, Kirsten
Massey, Ben Foat and
Others re GLO Pre Meet and
Sub Committee - Legally
Privileged and Confidential
(07/06/2019)
POL-0103159
115.
POL00103595
Post Office Limited Minutes
of Postmaster Litigation
Subcommittee Held on 12
June 2019 (12/06/2019)
POL-0103178
116.
POL00103599
Email Chain from Alisdair
Cameron to Alan Watts and
Ben Foat re: Privileged &
Confidential (27/06/2019)
POL-0103182
117.
POL00006753
Meeting Minutes of the Group
Litigation Subcommittee of
POL (21/02/2019)
POL-0018011
118.
POL00357549
Email Subject: Postmaster
Litigation - Remote Access:
extract from draft Letter to
Freeths - LEGALLY
PRIVILEGED - DO NOT
FORWARD (28/11/2016)
POL-BSFF-
0183270
119.
POL00103408
Email from Jane MacLeod to
Tim Parker, Ken McCall,
Carla Stent and Others re
Post Office - Postmaster
Litigation Confidential and
Subject to Legal Privilege -
Do Not Forward (07/03/2019)
POL-0102991
120.
POL00268869
Email from Alisdair Cameron
to Rodric Williams, Jane
MacLeod RE: Update on
POL-BSFF-
0106932
Page 131 of 137
DocuSign Envelope ID: 35848B78-14EA-4B48-AF01-6881BFF848DD
WITNO09840100
WITN09840100
Horizon Issues Trial - Post
Office Group Litigation
(20/03/2019)
121.
POL00268881
Email from Rodric Williams to
Alisdair Cameron and Jane
MacLeod, re: Update on
Horizon Issues Trial - Post
Office Group Litigation -
SUBJECT TO LEGAL
PRIVILEGE - DO NOT
FORWARD (20/03/2019)
POL-BSFF-
0106944
122.
POL00275871
Email from Alisdair Cameron
to Ben Foat cc'd Veronica
Branton and Alan Watts re:
GLO SubCommittee - Legally
privileged (03/06/2019)
POL-BSFF-
0113934
123.
POL00026043
Email from Rodric Williams to
Alisdair Cameron,Rob
Houghton, Mark R Davies &
others cc Catherine Hamilton,
Mark Underwood, Angela
Van-Den-Bogerd & others
RE: Update on Horizon
Issues Trial - Post Office
Group Litigation (07/06/2019)
POL-0022522
124.
POL00026216
Email from Ben Foat to Nick
Read, Alisdair and Mark
Davies cc: Shikha Hornsey,
Rodric Williams, — Sherrill
Taggart, RE GLO -
Disclosure Incident
(02/10/2019)
POL-0022695
125.
POL00112591
Email chain from Alisdair
Cameron to Ben Foat cc Nick
Read and Mark R Davies Re:
GLO-Disclosure Incident re.
KEL logs (03/10/2019)
POL-0110061
126.
POL00112645
PO GLO Board Sub-
Committee Paper -
POL-0110112
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Operations and GLO
Contigency Planning Report
(22/10/2019)
127.I POLO0129086 Horizon Issues Trial I POL-0132243
Judgment Contingency
Planning Update
(04/12/2019)
128.I POL00043341 Email chain between Ben I POL-0039823
Foat, Tim Parker, Tim
Franklin and others RE: GLO
- High Level Review
Embargoed Horizon
Judgment - Section M
(09/12/2019)
129.I POL00006756 Meeting Minutes of the I POL-0018014
Postmaster Litigation
Subcommittee of POL
(28/01/2019)
130.I POLO0118056 Email from Patrick Bourke to I POL-0114743
Mark Davies re: Brand, press
coverage and _— solutions
(24/05/2019)
131.I POL00026939 Post Office Limited I POL-0023580
Postmaster Litigation
Subcommittee Agenda &
Minutes (17/09/2019)
132.I POLO0006759 Meeting Minutes of the I POL-0018017
Postmaster Litigation
Subcommittee of POL
(13/11/2019)
133.I POL00292587 Postmaster Litigation I POL-BSFF-
Subcommittee Agenda I 0130650
(22/01/2020)
134.I POL00290109 Email from Alisdair Cameron I POL-BSFF-
to Patrick Bourke, Nick Read I 0128172
and Ben Foat RE: Mediation
(10/12/2019)
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135.I UKGI00017593 Email from Mpst Tolhurst I UKGIO27600-001
(BEIS) to Tom Cooper
(UKGI), Gavin Lambert cc
William Holloway and others
RE: POL discussion with SoS
and Kelly Tolhurst
(16/03/2019)
136.I POL00270909 Email from Richard Watson I POL-BSFF-
to Alisdair Cameron and I 0108972
others re Joining up
(17/04/2019)
137.I UKGI00009777 Email from Eleanor to Carl I UKGI020585-001
Creswell, Craig Watson,
Cecilia Vandini re Note of
Kelly/Al/Tim meeting on POL
- 15/5 (16/05/2019)
138.I UKGI00017603 Email chain from Carl I UKGI027610-001
Creswell to Thomas Cooper,
Alisdair Cameron and
Pauline Sullivan re:
Supporting the Minister
(16/05/2019)
139.I POLO00103557 Email from Alisdair Cameron I POL-0103140
To Thomas Cooper, Tim
Parker & Ben Foat RE:
Appeal hearing on common
issues (23/05/2019)
140.I UKGI00010371 Letter to Kelly Tolhurst MP I UKGI021179-001
from Al Cameron re. follow up
letter of 19 (28/06/2019)
141.I UKGI00010369 Letter from Kelly Tolhurst MP I UKGI021177-001
to Al Cameron - Re: PoL
Litigation and engagement
with DWP (01/07/2019)
142.I POL00175235 What went wrong? A draft for I POL-0170332
discussion (19/11/2010)
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143.
POL00176615
Email from Jane Macleod to
Rodric William, John M Scott,
Angela Van-Den-Bogerd and
others RE: Prosecution policy
(13/11/2015)
POL-BSFF-
0014678
144.
POL00027598
Post Office Ltd Minutes:
Board Meeting held on 21st
March 2016 (21/03/2016)
POL-0024239
145.
POL00249527
Email chain from Ben Foat to
Rodric Williams Re: Ops
Board and Losses & Crime
Group (27/06/2017)
POL-BSFF-
0087590
146.
POL00103308
Status Report for Post Office
Limited. (02/08/2017)
POL-0102891
147.
POL00251125
Email from Mark Raymond to
Alisdair Raymond and Mark
Ellis RE: Cases suitable for
prosecution (27/10/2017)
POL-BSFF-
0089188
148.
POL00029993
Email from Rob Houghton to
Gavin Bell and others Re:
Dalmellington error in
Horizon / problemswithpol
(01/07/2016)
POL-0026475
149.
POL00163217
Email from Mark R Davies to
Linda Bonar, Ruth X Barker,
Alice Cookson and others re:
Save Rutherglen Post Office
(30/10/2017)
POL-0151537
150.
POL00253502
Email from Paula Vennells to
Alisdair Cameron and Debbie
Smith re Seaton Post Office
and Post Office Ltd
(20/02/2018)
POL-BSFF-
0091565
151.
POL00136417
Email from Mark R Davies to
Melanie Corfield, Mark
POL-0140870
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Underwood, Angela Van-
Den-Bogerd RE: Fwd:
Another Computer Error.
Chain includes
correspondence with Tim
McCormack (23/06/2019)
152. Email "The error, Catch 22" — I POL-BSFF-
POL00423915 no redactions (29/07/2019) 0238730
153.I UKGI00017284 Post Office Limited Board I UKGI028242-001
meeting minutes - 18th June
2015 re Agreement with
NFSP (18/06/2015)
154. I POL00163556 PO Board Agenda — 1.19 I POL-0151767
Wakefield (30/04/2019)
155.I POL00262341 Post Office Media Training I POL-BSFF-
Scenario: Horizon I 0100404
(21/01/2019)
156.I FUJ00175270 Minutes of meeting at 20 I POINQ0181451F
Finsbury Street - Chris Broe,
Alisdair Cameron, Gavin Bell,
Nigel Shaw and Regina
Moran (20/11/2015)
157.I FUJ00175302 Email from Regina Morgan to I POINQ0181483F
Alisdair Cameron, cc to Rob
Houghton, Chris Boe and
others Re: Service Horizon
etc (09/05/2016)
158.I FUJ00175336 Email chain from Regina I POINQ0181517F
Moran to Gavin Bell re: Fwd:
Follow Up (19/06/2016)
159.I UKGI00017291 Post Office Limited Board I UKGI028249-001
Meeting Minutes - 25th March
2019 (25/03/2019)
160.} POL00288080 Email from Rodric Williams to I POL-BSFF-
Ben Foat, Sherrill Taggart, I 0126143
Jacqueline Scott and others
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Re: FW: Fujistu decisions
thoughts - legally privileged
(05/11/2019)
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