WITNO9890800
WITNO9890800
Witness name: Simon Recaldin
Statement No.: WITN09890800
Dated: 16 October 2024
POST OFFICE HORIZON IT INQUIRY
EIGHTH WITNESS STATEMENT OF SIMON RECALDIN
1. 1, Simon Recaldin, of 100 Wood Street, London EC2V 7ER, will say as follows:
INTRODUCTION
2. 1am employed by Post Office Limited (“Post Office”) as the Director of the
Remediation Unit.
3. I make this witness statement in response to a request dated 24 September
2024 for information pursuant to Rule 9 of the Inquiry Rules 2006. Further to
my sixth Witness Statement dated 4 September 2024, the Inquiry has
requested supplemental information relating to the Horizon Shortfall Scheme
(‘HSS’).
4. For the purposes of the data below, Post Office has implemented a data cut-off
date of 30 September 2024.
OUTSTANDING CLAIMS
WORK\54357767\v.1
Page 1 of 7
WITNO9890800
WITNO9890800
5. Post Office has proceeded on the understanding that the settled and
outstanding claims include all claims that meet the Eligibility Criteria. The term
‘settled claim’ is defined as a claim where an Applicant has accepted an offer in
full and final settlement. The term ‘outstanding claim’ refers to a claim where an
Applicant has yet to receive an offer or has received an offer but has yet to
accept it in full and final settlement.
6. As requested by the Inquiry, a breakdown of settled and outstanding claims is
as follows:
Total I Total Outstanding I Outstanding Outstanding claims
settled I outstanding I claims claims made I made since 1
claims I claims made between 28 I January 2024
between 1 I November
May 2020/2020 and 31
and 27 I December
November I 2023
20201
Complex I 505 1070 224 128 718
Standard I 1213 I 791 108 53 630
BAT 597 3 2 1 0
7. As at 30 September 2024, the 1,864 outstanding claims includes 457 offers
which have been made to Applicants: 373 of these offers have been rejected;
and Post Office awaits a response from Applicants in relation to 84 offers made.
8. In relation to outstanding claims, 373 are currently in the Dispute Resolution
Procedure (“DRP”) (this includes all stages of the DRP from when a claim
enters into the procedure up to, and including, mediation).
' See paragraphs 104 to 108 of my sixth Witness Statement which confirm that progress was impeded due
to funding not being confirmed until March 2021.
WORK\54357767\v.1
Page 20f7
WITNO9890800
WITNO9890800
9. In relation to claims concerning bankruptcy’, there are:
a. 56 outstanding claims which were made between 1 May and 27
November 2020, all of which have received an offer;
b. 15 outstanding claims which were made between 28 November 2020
and 31 December 2023; and
c. 87 outstanding claims which have been made since 1 January 2024.
10. It is not possible to provide data in relation to outstanding claims that concern
taxation issues as these issues only arise once an offer has been accepted and
the tax top up offer made. Following acceptance of an offer, the offer sum is
paid to the Applicant and thereafter, the taxation position is determined and,
where required, a tax top-up payment is made to the Applicant. Therefore, there
are no outstanding claims that concern tax issues.
APPLICATIONS RECEIVED
11.Further to paragraph 154 of my sixth Witness Statement, the table below shows
the updated figures for applications’ categorised by their case complexity:
Total Applications Applications Applications
Applications I received received between I received since 1
received between 1 May I 28 November I January 2024
2020 and 27I2020 and 31
November 2020 I December 2023
Complex 1856 678 237 941
Standard I 2361 1235 242 884
BAT 600 566 29 5
2 Defined as either i) the Applicant has an insolvency flag on Post Office systems following information
received from the Official Receiver; or ii) the claim includes an insolvency Head of Loss.
* Please note that an application means all applications received by Post Office, whether they are eligible
or ineligible. Once an application has been determined to be eligible, it is referred to as acclaim.
Therefore, not all applications become claims and the numbers of applications and claims will not be the
same.
WORK\54357767\v.1
Page 3 of 7
WITNO9890800
WITNO9890800
ELIGIBILITY
12. The table below provides information regarding the eligibility position of
applications under the HSS*:
Total Applications I Applications I Applications I Applications
received received received since
between 1] between 28 I 1 January 2024
May 2020 I November
and 27 I 2020 and 31
November December
2020 2023
Application 4179 2349 449 1381
determined
eligible
Application 373 123 57 193
determined
ineligible
13. The reasons for determining an application as ineligible include:
a. The fact that there is no contractual relationship between Post Office and
the Applicant (as required pursuant to the Eligibility Criteria) for example
where an application is made by a branch assistant or branch manager;
b. The claim relates to a pre-Horizon period;
c. The claim relates to a software version outside the scope of HSS as set
out in the Eligibility Criteria; and
d. The application is from an Applicant with Horizon related convictions
therefore, their application is be managed by the Overturned Convictions
Process.
“Please note there is a difference between applications received at paragraph [11] and Eligibility
determinations at paragraph [12] of 265 applications. This is due to these 265 applications being
processed for eligibility assessment.
WORK\54357767\v.1
Page 40f7
WITNO9890800
WITNO9890800
14. The Inquiry has asked Post Office to (i) indicate how many eligibility decisions
are being challenged by the Applicant and (ii) advise whether any challenges
have been successful. Unfortunately, this data is not held electronically
therefore, it is not possible to run searches for this information. From my
knowledge, only a small number of eligibility challenges have been received. In
my experience, if further appropriate evidence is provided by the Applicant, the
cases are deemed eligible.
15.To confirm, Applicants who disagree with eligibility decisions can, and do,
challenge the outcome and some of these have been successful. By way of
example, a successful challenge may result from the Applicant providing
additional information to assist with the eligibility determination.
16.Post Office is arranging for such data to be captured centrally going forwards.
FIXED SUM OFFER PAYMENTS.
Fixed Sum Offer Payment
17. The Fixed Sum Offer Payment has been divided into three cohorts: (1)
applications recently received that Post Office considers may be appropriate for
the Fixed Sum Offer Payment including all other applications that have yet to
receive an offer, (2) Applicants who have received but not accepted offers below
£75,000, and (3) individuals who will receive the mass mailout.
18. Cohort (1) is underway and so far, 266 letters have been sent out. To date,
Post Office has received 56 acceptances of the Fixed Sum Offer and 54 of
these have been paid. Commencing on 18 October 2024, letters inviting
Applicants to apply for the Fixed Sum Offer will be sent to cohort (2).
WORK\54357767\v.1
Page 5of7
WITNO9890800
WITNO9890800
19.In relation to cohort (3) and further to paragraph 15(c) of my sixth Witness
Statement, the mailout regarding the Fixed Sum Offer Payment is planned to
commence no later than 31 October 2024.
20.The mail out will be sent in batches given the volume of individuals who are to
be contacted; the mailout could include up to 30,000 recipients. It is anticipated
and planned for the mailout to be completed by the end of the year. The mailing
list has been extracted from the two Postmaster remuneration sources which
operated during the Horizon period. All Postmasters’ details are then validated
against Experian to find the most recent address which will be used for the
mailing. Where a letter is returned or a response is not received, they will be
followed up using alternate address tracing methods.
Top-Up Payment
21.Where Applicants have settled their claim in full and final settlement for less
than £75,000, their redress payment(s) will be topped up to £75,000 (“Top-Up
Payment”). As at 14 October 2024,1,771 Applicants have received a Top-up
Offer letter in this regard, with a further 24 letters to be sent as soon as possible.
These letters concern complex cases where further work is required for
example, an Applicant who has died since accepting full and final settlement of
their claim. Post Office needs to determine whether or not there is a will and
engage with personal representatives in relation to the claim.
22. As at 14 October 2024, 1,194 Applicants have accepted the Top-Up Payment.
Once an offer for either a Fixed Sum Offer or Top-Up Payment has been
accepted by the Applicant, on receipt of the acceptance, Post Office will make
payment to the Applicant within ten working days.
WORK\54357767\v.1
Page 6 of 7
WITNO9890800
WITNO9890800
STATEMENT OF TRUTH
I believe the content of this statement to be true.
Signed:
Dated: 16 October 2024
WORK\54357767\v.1
Page 7 of 7