WITNO9910100
WITNO9910100
WITNESS NAME: BELINDA JANE CORTES-MARTIN
STATEMENT NO: WITN09910100
DATED: 08 APRIL 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF BELINDA JANE CORTES-MARTIN
I, Belinda Jane Cortes-Martin (previously Crowe), will say as follows —
1. [have made this statement to assist the Post Office Horizon Inquiry (the “Inquiry”)
with the questions set out in the Rule 9 Request addressed to me, dated 23
February 2024 (the “Request”). The Request contains 62 questions, which I have
endeavoured to address fully within this statement.
2. I would like to make the Inquiry aware that I have received legal support from
Ashfords LLP to prepare this Statement.
Page 1 of 68
WITNO9910100
WITNO9910100
Background
3. I would like to make the Inquiry aware that I retired in March 2015 and no longer
have access to my CV. Therefore, in setting out my professional background I am
relying solely on my memory.
4. I was a Civil Servant for the majority of my working life. I joined the Civil Service
in, I believe, 1979 and I left in mid-2011. Over these years I worked in a variety of
roles across different Government departments, but for the final 2/3 years I was
the Information Director for the Ministry of Justice, dealing generally with matters
including data protection, freedom of information and records management.
5. After leaving the Civil Service in mid-2011 I set up as an independent consultant,
undertaking a range of commissions for a variety of clients. The majority of my
consultancy work related to information security, either working independently or
as an associate working with other consultancies.
6. To the best of my recollection it was early 2012 when I was invited to carry out
some work for POL. I was approached by email (followed, I think, with a
telephone conversation) in late 2011 by the Chair of POL who told me that POL
may be looking to commission an independent consultant with experience in
Government to assist POL’s work relating to Government proposals to mutualise
the Post Office. She had been given my name by a mutual acquaintance as
someone who may be interested in such a commission. She explained that as
she was the Chair she was not involved in ‘hiring’ but if I were potentially
Page 2 of 68
WITNO9910100
WITNO9910100
interested she would pass on my name to those in POL with responsibility for the
project who may (or may not) contact me. I believe it was at some point in early
2012 I was invited to a meeting to discuss the project with Susan Crichton, the
then General Counsel, and Alwen Lyons, the then Company Secretary. I recall at
the end of the meeting I was invited to submit a proposal for supporting the
project. My proposal was accepted and I carried out such work as was required,
initially working within POL’s Legal group for General Counsel. Later the work
moved into Strategy Group. Initially my work on mutualisation was sporadic and I
was working a few days a month as and when required, whilst also working on
different projects for other clients. However, as the mutualisation agenda
progressed, the work with POL took up most of my time.
. In or around October 2013 I was asked to move and work within POL’s Complaint
Review and Mediation Scheme (hereinafter referred to as the “Scheme”). I can
see from the documents provided to me that this move was announced in an
email by POL’s then CEO, Paula Vennells, on 8 October 2013 (POL00116179).
The nature of the work I would be carrying out was set out in her email and I was
invited to attend a Project Sparrow steering group meeting. I cannot recall
attending this meeting, however, I presume that I did attend. At that stage my
role was described in Paula’s email as providing secretariat support for the
Scheme, among other things, but I note from the minutes of the Project Sparrow
Steering Group meeting on 12 November 2013 (POL00137758), that Paula
announced I was to become “Programme Director for Sparrow” (the Scheme),
which I think widened the role.
Page 3 of 68
WITNO9910100
WITNO9910100
8. As far as I can recall, between October and December 2013 I completed my
outstanding work on mutualisation, and as that ran down I began my work on the
Scheme. I accepted a fixed term contract for this new role, to cover the period
from 1 Jan 2014 to 31 March 2015. Although I started to move over to my work
on the Scheme towards the end of 2013, I only officially became a POL employee
from the start of my fixed term contract on 1 Jan 2014.
9. I had agreed that a full time contract (as opposed to a day rate commission as an
independent consultant) would be appropriate for this role, because I was being
asked to commit to it on a full time basis for a fixed period.
10.Although my job title was 'Programme Director’, it became clear early on that I did
not have any strategic responsibility or any final authority to make decisions in
relation to the Scheme, and whilst I managed a small team of colleagues carrying
out work in relation to the Scheme, I did not supervise or manage any other
persons in managerial positions. Myself and my team were very much
coordinators (as opposed to decision makers), carrying out the instructions and
requirements of the Scheme Working Group (in my capacity as secretariat), the
Board, its Sub-Committee, and POL General Counsel.
11.1 also provided a support function for the new POL General Counsel, Chris
Aujard, who was a member of Working Group, in coordinating and assisting him
in relation to action points arising from the Working Group, as well as the Board
and Sub-Committee. I deal with my involvement in the Scheme and the Working
Page 4 of 68
WITNO9910100
WITNO9910100
Group in further detail under the following subheading of this statement - “Project
Sparrow, Second Sight and the Mediation Scheme.”
12. I left POL to retire when my full time contract ended on 31 March 2015. I had
always intended to retire at this time and I have not worked since.
The Horizon IT System
13. I confirm that I have considered the following documents provided to me:
(POL00041564) - Computer Weekly article dated 11 May 2009);
(POL00026572) - Ismay Report dated 2 August 2010);
(POL00149276) - email from Melanie Corfield to me on 20 October 2014;
(POL00142406) - email from Mark Underwood to me on 12 November
2014;
(POL00151216) - email from Steve Allchorn to me on 16 February 2015)
and the attachment at (POL00151217).
14.Before starting my work in POL, I do not believe I had any knowledge of the
Horizon IT System. I most likely knew that POL had a counter system, but I did
not know how this operated or who the provider of the system was. I think that
the first time I really became aware of Horizon was when I started my work on the
Scheme.
Page 5 of 68
WITNO9910100
WITNO9910100
15.The abbreviation for bugs, errors or defects (“BEDS”) was not a term I was aware
of during my time within POL. As far as I recall, the only information I was aware
of at the time in relation to possible issues and claims about a potential lack of
integrity in the Horizon IT system were the matters raised in the Second Sight
interim report, which was published before my involvement in the Scheme. I
cannot recall exactly when I read this report, but imagine I would have done so at
some point after starting my work on the Scheme. I also became aware of such
issues being raised by Justice for Sub-postmasters Alliance (JFSA) and
applicants in the Scheme. I was not aware of concerns being raised within POL
about BEDs or a lack of integrity in the Horizon IT System.
16.1 did not receive any training on the Horizon IT System during my time at POL. I
was not required to have any knowledge of the system itself - my involvement in
the Scheme did not include either investigating complaints or checking the work
of the team in POL that were responsible for investigating the complaints set out
in applications to the Scheme. I was also not required to consider or interpret any
Horizon data as part of my role.
17.I encountered the term ‘ARQ data’ during my time on the Scheme, but I have no
recollection of ever knowing exactly what it was and I would not have needed any
in depth knowledge or understanding of it to assist me in my role of managing the
Scheme and supporting the Working Group.
Page 6 of 68
WITNO9910100
WITNO9910100
18.I have been asked to address the ability of Fujitsu employees to alter transaction
data or data in branch accounts without the knowledge or consent of SPMs
(known as “remote access’). After starting work on the Scheme I became aware
of a case study in the Second Sight interim report - I believe this was ‘spot review
5’, which related to an allegation by a SPM who visited the Fujitsu offices in
Bracknell and believed he had seen live transaction data being altered by
employees working in the basement. Having reviewed (POL00151217) I now
recall this SPM was Mr Michael Rudkin. It is my understanding, as far as I recall,
that following the publication of their interim report, Second Sight was provided
with a statement from the employee who was with Mr Rudkin during his visit to
Bracknell, to the effect that what Mr Rudkin observed during his visit was a test
environment and not connected to live data.
19.1 do remember Second Sight asking POL for email data from 2008 relating to
matters concerning Spot Review 5. Having read (POL00151217), and from my
recollection from my time working on the Scheme I think that this request was the
subject of a number of exchanges between Second Sight and POL, and was
discussed in detail in two meetings in 2015. I do not recall the specifics of these
meetings, but having now reviewed the documents provided to me, I can see that
the full positions of Second Sight and POL on this matter are found in the minutes
of those meeting at (POL00022296) and (POL00063428).
20.The issue of ‘remote access’ was was raised by Second Sight on a number of
occasions during my time on the Scheme, but my understanding was that POL
considered that the matter had been addressed in its response to Spot Review 5
Page 7 of 68
WITNO9910100
WITNO9910100
and, as far as I was aware, POL and Fujitsu maintained the position that
transaction data could not be changed remotely without the knowledge of an
SPM.
21.1 did have a conversation with someone in Fujitsu about ‘remote access’ in early
2015. I cannot remember who the call was with, but I believe the conversation
was prompted by a query raised by the CEO in response to briefing she had
been provided with relating to her appearance before the BIS Select Committee
in February 2015. I recall being told by the Fujitsu employee that there was a
provision to deal with a major incident or emergency whereby a senior person at
Fujitsu could access the Horizon IT system to rectify a major problem, however,
this provision was subject to rigorous authorisation and audit arrangements and
as far as I recall, he told me that to his knowledge this provision had never been
used. He explained that POL would be involved if it were to be used, and whilst
the function existed, it did not alter the basic proposition that Fujitsu could not
remotely alter transaction data without the knowledge of the SPM. I would like to
highlight that this may not have been the specific wording used by the Fujitsu
employee during the call, but it was wording to this effect.
22.As I did not recall knowing about this provision, I reported back to POL General
Counsel. He confirmed that it was normal for every major IT system to have what
I believe he referred to as a ‘superuser facility’. Again, these may not have been
the exact words he used, but it was wording to this effect.
Page 8 of 68
WITNO9910100
WITNO9910100
23.1 can see from (POL00149276) that a few months prior to my phone call with
Fujitsu in early 2015, Melanie Corfield forwarded myself, Patrick Bourke and Tom
Wechsler an email from Andrew Parsons (an external lawyer at Bond Dickinson),
illustrating the following had been confirmed by Fujitsu — “The system has been
designed to prevent any access, either remote or direct, that would allow
individual branch transactions to be altered. Fujitsu has controlled access to the
Horizon system for software updates and maintenance purposes. This is of
course Strictly controlled with security processes in place, but could not, in any
event, be used to alter individual branch transactions — there is no facility within
the system to do this.” This would have been my understanding, however, I note
that Andrew comments that an issue had been identified relating to injecting
transaction data. I do not recall this email. I am unsure if I simply missed it, or
whether I believed it was a technical matter that lawyers were ‘getting to the
bottom of as Andrew states and I would be informed if I was required to take any
action, so I did not engage with it further.
24.1 recall that, as a result of my conversation with Fujitsu in February 2015, and the
fact that the subject of ‘remote access’ continued to crop up regularly, I
suggested to my team that it would be worth commissioning a piece of work to
look at how the superuser operation in the Horizon IT system worked. My
concern was that there seemed to be no common understanding of the term
‘remote access’, so a one size fits all answer may not be appropriate. Rather, a
wider and more sophisticated response to the issue of ‘remote access’ was
required. Unfortunately, I do not know if such work was ever commissioned after I
left POL.
Page 9 of 68
WITNO9910100
WITNO9910100
25.1 would like to stress that I was never concerned that Fujitsu might be adjusting
transaction data without the knowledge of SPMs. My understanding was,
throughout my time working on the Scheme, that transaction data could not be
altered without the knowledge of the SPM. I believed, from what I had been told,
and with my limited technical knowledge, that if any intervention was necessary,
for whatever reason, any alteration would have to be seen and accepted by the
SPM (e.g. as a transaction correction).
26.1 do not recall if I ever read the May 2009 Computer Weekly article at
(POL00041564). This was published well before my time in POL, and I do not
recall ever being involved in any internal discussions about it. I did become aware
that Computer Weekly had written articles about Horizon and I would have read
any which were published while I was working on the Scheme.
27.1 have no recollection of reading or knowing about the Ismay Report dated 2
August 2010 at (POL00026572). I believe the first time I had heard of this report
was during the course of watching other evidence given at the Inquiry. I do not
know whether it was ever used in POL’s response to any complaints made in
applications to the Scheme as I not involved in the investigation side. It was not
my role to consider the investigation reports and I lacked the knowledge and
expertise to do so.
Page 10 of 68
WITNO9910100
WITNO9910100
Project Sparrow, Second Sight and the Mediation Scheme
Project Sparrow and POL’s oversight of the Mediation Scheme
28.1 confirm that I have considered the following documents provided to me:
vi.
vii.
viii.
(POL00116179) - email from Paula Vennells to Andy Holt and others,
copied to me, on 8 October 2013;
(POL00123004) - my email to Andrew Parsons on 21 October 2013;
(POL00099870) - email exchange between me, Peter Batten and others in
October 2013;
(POL00137758) - draft note on actions and decisions from the Project
Sparrow Steering Group meeting on 12 November 2013;
(POL00030694) - note on Project Sparrow dated 13 November 2013;
(POL00146921) - minutes of the Project Sparrow Steering Board meeting
on 25 November, likely 2013);
(POL00146934) - email chain between me, Ruth Barker and others on 28
November 2013;
(POL00100003) - memo from Chris Aujard dated 6 December 2013;
(POL00146985) - email from Andrew Parsons to me on 9 December 2013
and the attachments at (POL00146986) and (POL00146987):
POL00147108 - email from David Oliver to me on 6 January 2014 and the
attachments at (POL00147109);
Page 11 of 68
WITNO9910100
WITNO9910100
xi. (POL00147258) - email from me to Chris Aujard on 20 January 2014 and
the attachment at (POL00147259);
xii. (POL00108231) - briefing note to Alice Perkins and Paula Vennells dated
27 January 2014;
xiii. (POL00040074) - email from Nicky Mal to me and others on 31 January
2014) and the attachments at (POL00040075), (POL00040076),
(POL00040077) and (POL00040078);
xiv. (POL00100200) - memo from David Oliver to Paula Vennells and copied
to me dated 5 February 2014;
xv. (POL00116275) - email from me to Paula Vennells on 17 February 2014)
and the attachment at (POL00116276);
xvi. (POL00027452) — my note to the POL board on 20 February 2014;
xvii. (POL00100322) - briefing from me to Paula Vennells on 22 February
2014);
xviii. (POL00302500) - minutes of the meeting of the POL board on 26
February 2014;
xix. (POL00138176) - minutes of the Mediation Scheme Programme Board;
xx. (POL00147643) - email exchange with Jonathan Swil on 9 March 2014)
and the attachment at (POL00147644);
xxi. (POL00107317) - Linklaters advice dated 20 March 2014;
xxii. (POL00147831) - email from Rodric Williams to Angela Van Den Bogerd
on 25 March 2014;
Page 12 of 68
WITNO9910100
WITNO9910100
xxiii. (POL00147933) - email from Carolyn Low to me and others on 2 April
2014) and the attachment at (POL00147934);
xxiv.(POL00158128) - email from David Oliver to Paula Vennells on 3 April
2014) and the attachment at (POL00158129);
xxv. (POL00162134) - email from Chris Aujard to Alice Perkins on 7 April
2014);
xxvi.(POL00116439) - agenda and papers for the Project Sparrow Sub-
Committee meeting on 9 April 2014;
xxvii. (POL00116444) - emails between me and Paula Vennells on 9 April
2014);
xxviii. (POL00006565) - minutes of the Project Sparrow Sub-Committee
meeting on 9 April 2014;
xxix. (POL00138282) - notes of the Initial Complaints Review & Case Mediation
Scheme Programme Board on 11 April 2014;
xxx. (POL00148049) - my email to Angela Van Den Bogerd and others on 14
April 2014;
xxxi.(POL00148068) - my email to Chris Aujard on 15 April 2014;
xxxii. (POL00022683) - letter from Alan Bates to Jo Swinson MP dated 16
April 2014);
xxxiii. (POL00148101) - email from me to Mark Davies and others on 23 April
2014;
xxxiv. (POL00100566) - email from me to Peter Batten on 23 April 2014;
Page 13 of 68
WITNO9910100
WITNO9910100
xxxv. (POL00100577) - email from me to Peter Batten on 23 April 2014 and
the attachment at (POL00100578);
xxxvi. (POL00148108) - presentation dated 23 April 2014;
xxxvii. (UKGI00002255) - email from me to Peter Batten and others on 24
April 2014 and the attachment at (UKGI00002256);
xxxviii. (POL00148173) - email from me to Chris Aujard on 25 April 2014 and
the attachment at (POL00148174);
xxxix. (POL00006566) - minutes of the Project Sparrow Sub-Committee
meeting on 30 April 2014;
xl. (POL00040153) - email from David Oliver to me on 1 May 2014) and the
attachment at (POL00040154);
xli. (POL00116535) - email exchange with David Oliver and others on 5/6 May
2014;
xii. (POL00108521) - email exchange concerning the retention of data;
xliii. (POL00116562) - email exchange on 13 May 2014 and the attachment at
(POL00116563).
xliv. (POL00021426) - minutes of the Audit, Risk and Compliance Sub-
Committee meeting on 15 May 2014;
xlv. (POL00021525) - minutes of the POL board meeting on 21 May 2014;
xlvi. (POL00148420) - email from Alwen Lyons to me on 23 May 2014;
Page 14 of 68
WITNO9910100
WITNO9910100
xlvii. (POL00148478) - email from David Oliver to me and others on 29 May
2014 and the attachments at (POL00148479), (POL00148480),
(POL00148481) and (POL00148482);
xlvili. (POLO0168040) - email from David Oliver to me and others on 1 June
2014) and the attachment at (POL00168041);
xlix. (POL00027369) - paper titled Initial Complaints Review and Mediation
liv.
Wi.
Wii.
\viii.
lix.
Scheme: The way forward dated 3 June 2014;
(POL00149689) - email from Stephen Hocking to you and others on 13
June 2014;
(POL00006571) - minutes of the Project Sparrow Sub-Committee meeting
on 6 June 2014;
(POL00000213) - terms of engagement dated 1 July 2014;
(POL00021762) - my email to Charles Colquhoun on 6 August 2014;
(POL00022168) - my email to Chris Aujard and others on 6 August 2014;
(POL00129437) - record of teleconference on 11 August 2014;
(POL00101175) my email to Paula Vennells on 15 August 2014;
(POL00021800) my email to David Oliver and others on 19 August 2014)
and the attachment at (POL00021801);
(POL00148870) - my email to Alwen Lyons on 22 August 2014;
(POL00027363) - my note to the POL board dated 17 September 2014);
(POL00116714) - email from me to Paula Vennells on 25 September
2014;
Page 15 of 68
WITNO9910100
WITNO9910100
Ixi. (POL00149392) - email from me to Mark Davies and others on 28 October
2014 and (POL00149393).
Ixii.. (POL00149417) - email from Laura Pinkney to Andrew Parsons, copied to
me on 29 October 2014;
Ixiii. (POL00150869) - my email to Mark Davies on 23 January 2015);
29.1 have been asked to provide an account of my involvement in POL’s response to
the ‘emerging scandal’, including the nature and extent of my involvement in
Project Sparrow, Second Sight’s investigation, the Scheme and the Scheme's
Working Group. I would like to stress to the Inquiry that during my time within
POL, these matters were not viewed as an ‘emerging scandal.’ POL’s position in
relation to Second Sight’s interim report was that the report stated that no
evidence of systemic problems with the Horizon software had been found and, as
far as I understood, POL continued to have confidence that Horizon was working
as it should. However, POL noted that improvements could be made in the
training and support processes provided to SPMs. In response to the report POL
made a number of commitments, one of which was to create the Scheme.
Second Sight’s original investigation was completed before my involvement with
the Scheme and I had understood that after the creation of the Scheme, Second
Sight’s role changed to one of reviewing the POL investigation reports into the
complaints set out in the individual applications to the Scheme.
Page 16 of 68
WITNO9910100
WITNO9910100
30.In terms of Project Sparrow, I am not aware of the background to its set up, as
this was before my involvement in the Scheme. I do not recall if I was ever told its
original remit.
3
. Having looked at the documents provided to me with the Request, I now recall
that there was a steering group chaired by Paula Vennells, overseeing the work
of Project Sparrow. It appears that I attended at least two steering group
meetings prior the official start date for my role on the Scheme. The notes of
these meetings set out early expectations for the role, although I can see from my
review of the documents that the reality over time differed somewhat from the
early expectations.
32.To the best of my recollection, and having reviewed the documents, there were
two main strands of what was called Project Sparrow which were, until I became
involved, led by Angela Van den Bogerd - (1) the Complaint Review and
Mediation Scheme and (2) the Business Improvements Programme, which
addressed issues arising out of complaints within the Scheme. At the point that I
became involved, these two strands were separated and handled separately. I
became responsible for the Scheme and Angela continued to lead the Business
Improvement Programme.
33.Nevertheless, whilst investigations into complaints contained in Scheme
applications technically fell within the Scheme, I was not responsible for the
substance of those investigations. Angela was responsible for this work because
Page 17 of 68
WITNO9910100
WITNO9910100
of her particular expertise and experience in Horizon and the way the system
worked, and she managed the investigation team. My involvement in the
investigations was limited to chasing the progress of those investigations, along
with progress of Second Sight’s reviews of the investigations in order to
effectively manage the progress of applications within the Scheme.
34.After this split the term “Project Sparrow” was continued to be used as a short-
hand and for the Scheme, however, Project Sparrow effectively just became the
Scheme.
35.1 have been asked to explain why POL’s Board created a formal Sub-Committee
to oversee Project Sparrow. I do not know why the Board did this. As far as I can
recall, I was simply told it was going to do so and I would not have expected to be
consulted on this.
36.In terms of the process by which I was appointed as Programme Director of the
Scheme, having now reviewed (POL00116719) I assume that I had a
conversation with Paula Vennells (or someone on her behalf) prior to being
invited to a steering group meeting for Project Sparrow. I do not remember this
conversation, or the steering group meeting. Until that point I knew virtually
nothing about the work of Second Sight and I do not think I had heard of the
Scheme.
Page 18 of 68
WITNO9910100
WITNO9910100
37.My primary role was to provide secretariat support for the Chair and the Working
Group overseeing the Mediation Scheme and managing the Scheme on a day to
day basis in line with the requirements of the Working Group and POL. Although
there were less than 150 cases in the Scheme, the whole process of managing
cases through the Scheme was manual, and therefore administratively and
resource intensive. For example, the movement of cases was tracked using a
spreadsheet and every time a case moved to the next stage of the process it had
to be recorded manually. I and my team tracked the movement of cases,
progress chased if a deadline for a stage to be completed was approaching, sent
the necessary documentation to applicants and their advisors in line with the
instructions of the Chair and the Working Group, set up payment authorisations
and arrangements to check and pay invoices and complete the budgetary
requirements set by POL. Once cases completed their investigation and review
stages we were responsible for liaising with all relevant parties, including CEDR,
to arrange the mediation meetings themselves.
38.We also organised the Working Group meetings and completed the minutes and
paperwork for the meetings. I believe these meetings were held weekly as the
Scheme progressed in the form of, a full face to face meeting every month to
discuss substantive issues and a telecon each week (if required) for case
progression and urgent business. If actions required chasing, I would do this and
would provide updates to the Working Group as requested. I also supported the
Chair of the Working Group by dealing with correspondence relating to the
Scheme by preparing draft letters for his consideration either for applicants,
advisors or external stakeholders raising questions about the Scheme.
Page 19 of 68
WITNO9910100
WITNO9910100
39.1 also assisted in making sure that POL completed its action points from the
Working Group meetings. To this end I often commissioned and co-ordinated
briefings for POL General Counsel to be able to respond to requests for
information arising from those meetings.
40.My work as Programme Director of the Scheme also involved gathering and
providing information and advice when requested by POL’s Board and Sub-
Committee for consideration by POL General Counsel before being submitted to
the Board.
41.In terms of my involvement with Second Sight, I managed the day to day
relationship with them, however, this did not start until after the publication of their
2013 interim report and my involvement in the Scheme. I negotiated resources
with them, paid their invoices and was generally their main point of contact within
POL for requests for information.
42.To the best of my recollection the scope of my role as Programme Director
developed over time. When I signed my full time contract for the role, the General
Counsel, as my line manager, was required to agree work objectives with me. I
do not have a copy of those objectives and I cannot remember the detail of them
but as far as I can recall those objectives were broadly to provide secretariat
support for the Scheme and Working Group, manage the day to day relationship
with Second Sight and take any necessary actions as required by the Board and
Page 20 of 68
WITNO9910100
WITNO9910100
POL in relation to the Scheme. I think the nature or description of the role was an
emerging picture and it evolved as the Scheme developed. The Scheme and the
role was new and it was it was left to me and POL General Counsel to develop it
in line with the Working Group’s and Board's requirements.
43.Within POL I imagine my role would have likely been referred to as Mediation
Scheme Programme Director, or secretariat support to the Scheme Working
Group. Having reviewed the papers, it may also have been referred to as Project
Sparrow Programme Director, however, I would not have called myself this as I
do not think the term ‘Project Sparrow’ was understood by anyone other than
Board and ExCo members and a few people closely connected with the work.
44.As mentioned earlier in this statement, in my role I had a small team assisting me
with the operation of the Scheme. We were located in POL’s Legal group and, as
far as I recall, my team comprised 7 people at its largest (although there were
several personnel changes throughout the Scheme). My line manager was Chris
Aujard (General Counsel to POL and member of the Working Group). I also
reported to the Board and its Sub-Committee, through POL’s General Counsel,
who were overseeing the Scheme. As my role was not permanent and was
specific to the Scheme, I do not think it was otherwise part of POL’s main or
overarching governance structure.
45.With the advice of PA consulting, who came in to assist with the establishment of
the Scheme when I started my role, we replaced the CEO chaired steering group
Page 21 of 68
WITNO9910100
WITNO9910100
with a Programme Board, chaired by POL General Counsel, to oversee the
Scheme from within POL. However, it soon became clear that this was not a
‘Programme’ in the sense that it was not delivering a major change programme,
and although the Programme Board appears to have met a few times in early
2014, it was soon disbanded. The POL Board established a Sub-Committee to
oversee the Scheme instead and it appears that a sub group of ExCo was also
established. I have no recollection of the ExCo group and do not recall attending
any meetings.
46.1 kept my work for POL and my work for the Working Group separate and I never
felt conflicted in my role as Programme Director for the Scheme and secretariat
for the Working Group. For example if the Chair had made a ruling on an
application within the Scheme and asked me to send it simultaneously to POL
and JFSA to ensure both parties received the information at the same time, I
would do that, and at no time did POL expect me to treat it favourably in relation
to the Scheme. There were also occasions when Second Sight raised matters
with me and I added them to the agenda for the Working Group meeting so that if
POL was going to, for example, deny requests for information from Second Sight,
it would have to do so on the record and with the knowledge and opinion of the
Working Group’s Chair. The Inquiry should note that POL was represented by
two members on the Working Group, POL General Counsel (Chris Aujard, who
was also my line manager) as the senior manager in POL responsible for the
Scheme and Angela Van Den Bogerd as the leader of the complaints
investigation team. It was for those members, particularly POL General Counsel,
that I would commission and co-ordinate briefings from experts within POL so
Page 22 of 68
WITNO9910100
WITNO9910100
that they, as members of the Working Group, could respond to requests from the
Working Group.
47.1 have been asked if I informed members of the Working Group, JFSA or other
third parties about my position on ‘Project Sparrow.’ I am not sure that any project
names were referred to outside of POL. The Working Group members knew that I
worked for POL and, as far as I am aware, that POL General Counsel was my
line manager, but I do not remember whether or how I described my exact role to
the Working Group. As far as I recall I always made it clear when speaking to a
member of the Working Group if I were speaking for POL (which I sometimes did
to pass on messages or information from POL) or as Secretariat to the Working
Group.
48.In relation to Second Sight’s work on the Scheme I believe that POL’s Board was
responsible for deciding the ambit of Second Sight’s investigation and amending
or terminating Second Sight’s contract with POL.
49.1 believe that Chris Aujard (and later Jane MacLeod) as General Counsel was
responsible for deciding the documents or information to be provided to Second
Sight.
50.1 had no authority to make decisions relating to the matters in paragraphs 48 and
49 above. Rather, I would offer assistance and opinion on such matters if I felt
necessary or was asked to do so. I can recall one example of this in relation to
Page 23 of 68
WITNO9910100
WITNO9910100
the matter of Second Sight’s contract with POL. There was an ongoing debate
between Second Sight and POL in that Second Sight believed it had a role
beyond the individual applications in the Scheme and POL disagreed. My
understanding was that following the publication of the Second Sight interim
report of 2013 and the creation of the Scheme, the role of Second Sight changed
to a role of reviewing POL’s investigations on Scheme applications. This change
pre-dated my involvement in the Scheme and I had no input into it. I recall that at
some point - I do not recall when - it became clear that Second Sight disagreed
with this later definition of its role and there were several attempts to resolve the
matter, but I do not think any totally succeeded. I had a number of conversations
with Second Sight directors about this and I tried to resolve the issue through
suggesting a letter of engagement, which it appeared Second Sight had not had.
However, I eventually had to refer this issue to POL General Counsel I was
unable to resolve it and it was outside of my level of authority to attempt to force
the matter. As stated above, I am not sure that the matter was ever totally
resolved.
.In terms of briefings, I provided these as and when requested or required by the
Board (or Sub-Committee), POL General Counsel or other senior managers. I
included in briefings any information either requested or which I felt may be
relevant. Any technical or legal input for such briefings was obtained from either
lawyers, Angela Van Den Bogerd or relevant subject experts within POL, such as
IT or Comms. I cannot specifically recall including information regarding BEDS in
any briefings as, as far as I am aware, the matter never arose. Had it done so
that information would have been provided by either POL Legal, Angela or IT. In
Page 24 of 68
WITNO9910100
WITNO9910100
terms of ‘remote access’, I have dealt with my recollection of passing on
information about this is in paragraphs 18-25 above. As far as I recall POL’s
position, or at least my understanding of it, in relation to BEDs (although as
stated earlier in this statement, is not an abbreviation I ever recall hearing at the
time) and remote access didn’t change throughout the period I worked in POL.
52.1 liaised with the Shareholder Executive (“ShEx”) on routine matters of
Parliamentary Questions and correspondence and would also brief ShEx if
requested by the Board. ShEx was also represented on the Board and Sub-
Committee and therefore as far as I am aware had access to all Board papers on
the Scheme. I also very likely provided briefings for POL senior managers if they
were meeting Government to discuss the Scheme. As ever, my briefing would
have pulled together input from the relevant subject experts within POL. Any
technical information relating to Horizon, or any legal information relating to
prosecutions that the subject experts provided, would have been inserted into the
briefing by me (or someone on my team). The only information included in any
briefing that was not either provided by or cleared by a subject expert would be
facts and figures relating to the progress of applications in the Scheme. To the
best of my recollection I only directly briefed a Minister once — this was Jo
Swinson in advance of a Westminster Hall debate. The debate was about the
Scheme, so my role in the Scheme meant I was best placed to provide the brief.
53.1 do not know if any senior managers and / or directors of POL were concerned
about personal liability for malicious prosecution. If it were ever discussed in my
presence, I have no recollection of it.
Page 25 of 68
WITNO9910100
WITNO9910100
54.From documents provided to me, I can see that the setting up of the Scheme and
the Working Group was announced in August 2013. This pre dates my
involvement in the Scheme and I was not privy to any discussions about this.
The press release announcing the introduction of the Scheme on 26 August 2013
shows that it was established following the publication of Second Sight’s report
into the Horizon IT system, published in July 2013. The press release said that
Second Sight’s report stated that so far no evidence of systemic problems with
the Horizon software had been found. However, it noted that improvements could
be made in the training and support processes provided to SPMs. In response to
the report POL made a number of commitments, one of which was to create the
Scheme.
55.1 can see references to settlement strategies within the documents provided to
me, for example (POL00137758) shows that a settlement policy was developed
to be discussed by ExCo, but I now have no recollection of the policy or any
discussions about it. However, once the Scheme was underway and mediations
had started, as far as I can recall the general strategy was to resolve and settle a
complaint if at all possible, provided the agreed outcome was not unreasonable
or totally disproportionate. As far as I can recall, before every mediation there
were discussions between lawyers, Angela Van Den Bogerd, the POL mediator
and someone from my team to ascertain a broad understanding as to what a
possible mediation outcome might be. This was to try to ensure consistency, as
the mediator may not have been directly involved in the investigation process for
the actual complaint being mediated. However, it was accepted and understood
Page 26 of 68
WITNO9910100
WITNO9910100
that the mediator needed to have flexibility to respond on the on the basis of what
arose during mediation discussions. In order to ensure POL avoided delaying a
mediation meeting because of staff unavailability, it used a number of different
personnel as mediators.
56.1 have considered the following from my email at 06:43 on 28 November 2013 at
(POL00146934): “On the point about...the system, the fact is that no such
problems have been found...the Scheme is not designed to identify such
problems, it is to deal with complaints”. As mentioned above, I do not believe I
was aware of the term BEDs at the time, but in any event the Scheme was not
set up to investigate potential issues with the Horizon IT System. Rather, the
Scheme was designed to give SPMs an opportunity to make a complaint which
would be investigated. As mentioned in paragraph 29 of this statement, this was
one of the commitments made by POL to improve the support provided to SMPs,
following the publication of Second Sight’s interim report.
57.The contents of the email exchange at (POL00146934) suggests to me that my
understanding of the Scheme’s purpose represents the view held within POL
generally, and this had been the view since before I became involved in the
Scheme. However, I also understood that POL was of the view that during the
course of investigating and reviewing the individual complaints in the Scheme, it
was, of course, possible that a systemic problem with Horizon could be identified
and that was a matter which would have to be addressed. Nevertheless, the main
aim of the Scheme was to address complaints.
Page 27 of 68
WITNO9910100
WITNO9910100
58.1 have been asked if I at all considered there to be a difference between what
POL stated publicly about the Mediation Scheme compared to what was
discussed internally. I do not recall thinking that there was a difference, however,
I do think that it became clear once the Scheme got underway that POL’s view of
Second Sight’s role and how the Scheme would work differed from others’ views,
such as JFSA and Second Sight. I cannot account for the reason for this as I was
not involved in the initial set-up of the Scheme. I think perhaps a general desire to
get the Scheme up and running quickly before thrashing out all the necessary
detail prior to the Scheme starting and/or being announced may have been a
contributory factor. An example of this would be not having agreed clear terms of
engagement with Second Sight and, defining its role in relation to the Scheme
from the outset. It also appears to be the case from the various comments set out
in (POL00146939), as discussed in the preceding paragraph of that document,
that there was a difference of opinion between JFSA and POL about the aim of
the Scheme. Having said that, I do not recall feeling that the difference was
significant at the time.
59.1 am unable to explain the background to Andrew Parsons’ suggestion within
(POL00123004) that “Work is continuing on managing SS out of the Scheme. In
general, SS’ role is gradually being reduced until they can be removed entirely.
This work has already begun”. I only became involved in the Scheme in October
2013, shortly before this email from Andrew on 21 October 2013, and I do not
recall this email at all. Clearly Second Sight remained involved in the Scheme for
Page 28 of 68
WITNO9910100
WITNO9910100
some 18 months after this email by Andrew Parsons (which was the period I was
working on the Scheme), but it is clear from the documents I have been asked to
review that the work of Second Sight and their continued involvement in the
Scheme was a subject discussed regularly by the Board and the Sub-Committee.
60.1 do not know the reasons for the above approach in respect of Second Sight's
continued involvement in the Scheme. I do recall from early on in my involvement
in the Scheme that POL was concerned about impartiality. I believe that this was
the impression I came away with when attending my first steering group meeting
on Project Sparrow. I also have a very vague recollection from many months
before my involvement in the Scheme (perhaps in late 2012 or early 2013) of
Susan Crichton asking me whether I had any contacts who were forensic
accountants. My recollection (although it may not be entirely accurate as I was
not really aware of the Second Sight work at this time) was that POL was
concerned about lack of progress by Second Sight, but I do not know whether
this concern went beyond Susan Crichton. I think that I may have I passed on
some contact details, but I do not think this was followed up.
61.From my recollection, I believe that POL wanted to ensure that it could draw a
line under the concems about Horizon at the end of the Scheme, once the
applications had all been investigated, mediated (where the parties agreed to
mediation) and resolved where possible. I believe the aim of this was to ensure
that the role of the Working Group and Second Sight did not continue to become
Page 29 of 68
WITNO9910100
WITNO9910100
part of any permanent arrangement for investigating new complaints as they
arose.
62.1 do recall that the Board (through the Sub-Committee while it existed) were
keeping the Scheme under review. I can also see from the documents provided,
for example (POL00137758), that ExCo were also involved in decisions relating
to the Scheme. I do not know if there were any other considerations or
discussions by POL senior management about amending the nature of the
Scheme or the Working Group.
63.Those people who were involved in discussions relating to any review of the
Scheme and strategies around the same would have been Board and Sub-
Committee members, ExCo, Angela Van Den Bogerd, lawyers, myself and others
in my team who were involved in preparation of options. ShEx was also
represented on the Board and the Subcommittee, so they would have been
aware of such information. Unfortunately I cannot recall the specific discussions,
but I see from minutes of various meetings I have been provided with they
focussed upon whether the Scheme was effective in terms of achieving its aims
in terms of cost and timeframe expectations. I do not know if there was a
difference of views on these issues. I would imagine that any difference that
existed between Board or ExCo members would not have been discussed in front
of me.
Page 30 of 68
WITNO9910100
WITNO9910100
64.1 think one of the reasons as to why the Scheme was kept under review was due
to the fact that POL had set up the Scheme at considerable cost and before
doing so Second Sight had presented findings in its interim report that there was
no evidence of systemic problems with Horizon at that stage of the Second Sight
investigation. For these reasons it seemed reasonable to me, and indeed good
practice, that POL would keep the Scheme under review, to know whether or not
it was working as originally intended, and to consider other options if they were
not happy with how it was working.
65.1 have been asked to describe my recollection of the board meeting on 26
February 2014. Unfortunately I do not have any specific recollection of this
meeting and I therefore defer entirely to the minutes of that meeting at
(POL00302500). Following a review of the minutes, I can see that whilst I
attended that part of the meeting which dealt with the Scheme I did not appear to
play an active part in the meeting.
66.1 prepared the paper for the meeting (see POL00027452). As far as I can recall,
all papers prepared for Board meetings were prepared on behalf of an ExCo
member - in my case this would have been POL General Counsel. I believe we
would have discussed the potential contents of the report and I would have pulled
it together with input from other relevant people for approval before being
submitted to the Board. I believe that the Board was presented with a full and
accurate picture of (a) the current status of the Mediation Scheme and (b) the
future plans for the Mediation Scheme and / or Second Sight during this Board
meeting. As is noted in the meeting minutes under the sub heading ‘INITIAL
Page 31 of 68
WITNO9910100
WITNO9910100
COMPLAINT REVIEW AND MEDIATION SCHEME’, the Board seems to have
requested a paper setting out the worst case scenario and this is the commission
I, and POL General Counsel, appear to have fulfilled.
67.Whilst I have very little recollection of this, I can see from the papers that I had
some involvement in commissioning a piece of work by Linklaters, to provide
legal advice to the Board in relation to Horizon/the Scheme. I would not have
reviewed this advice in any particular detail, so I do not recall having any specific
view on it. I imagine the decision to get this advice would have come from a
Board discussion and I would have simply been assisting POL General Counsel
in in obtaining it. I do not recall what actions POL took as a result of such advice.
68.In terms of the documents that POL allowed Second Sight to access, and as far
as I can recall, it was my initial understanding that following a discussion at a
Working Group meeting, Second Sight were provided access to all relevant legal
files, and I was in involved in making sure that they were provided with such files
as they requested. However, I recall that it later transpired that they also wanted
access to legal advice which POL considered to be legally privileged. I do not
know what this specific advice was. As far as I recall I only became aware in
early 2015 of the fact that Second Sight wanted access to privileged legal advice.
Apart from the POL investigation reports on the applications within the Scheme, I
have no recollection of any other investigation reports Second Sight wanted
access to.
Page 32 of 68
WITNO9910100
WITNO9910100
69.As alluded to above, I believe that there was a difference in opinion between
Second Sight and POL in terms of the scope of Second Sight’s work in relation to
the Scheme, in so far as POL thought that Second Sight’s role was limited to
reviewing POL investigation reports on applications within the Scheme, but
Second Sight seemed to think it had a wider role, although I do not recall that this
wider role was ever fully articulated. Apart from the privileged information
contained in the legal files, I think that Second Sight was provided with the
information and the documents it requested and needed to fulfil its role in relation
to the Scheme. However, there was clearly a disagreement about the scope of
Second Sight’s work and their access to wider information relating to that.
Nevertheless, the only issue I can specifically recall in connection to this is the
issue of Second Sight’s access to email data relating to the Spot Review 5, which
I have dealt with earlier in this statement.
70.1 have been asked to what extent I agreed with Mark Davies’ point - “/ have been
thinking about the question we will get about why we won't let SS look at
everything - too which the obvious answer is there is no evidence of a problem”
(POL00150869). I cannot recall this email or whether I had any view on it. If I had
to speculate on how I may have approached this email, I believe I would have
been considering whether or not, or how, the provision of all information
requested by Second Sight would have assisted individual applicants in the
Scheme.
Page 33 of 68
WITNO9910100
WITNO9910100
71.1 do not know the eventual outcome in respect of POL’s position on retaining
Horizon data held by Fujitsu beyond the normal seven year retention period once
the Scheme had ended. However, my position at page 7 of (POL00108521) that
a “proper retention policy exists for a purpose and I do not think we can put a
blanket ban on destruction” needs to be read in context of the rest of that email
chain. As a general proposition I do think that a retention policy exists for a
reason, for example a legal reason related to Data Protection, and therefore I
would not think it appropriate to put a blanket ban on the destruction of data and
documents, as doing so could risk breaching legal requirements. However, when
reading the rest of that email chain at (POL00108521), it is clear that my
suggestion in these specific circumstances was for POL to tell Fujitsu to
immediately stop destroying data at the end of the seven year retention period as
a temporary measure to ensure that no data was destroyed that may be needed
to investigate Scheme applications, and then come to a considered view about
retention of data going forward which could be agreed with Fujitsu. I escalated
the matter to the ClO to ensure that data destruction at Fujitsu was halted as a
matter of urgency.
72.1 do not recall the Board meeting on 21 May 2014, but I have reviewed the
minutes of such meeting at (POL00021525). I do not know what Alwen Lyons
meant when she wrote “It’s a bit smoke and mirrors but here are the minutes,
comments asap please” at (POL00148420). From my review of the minutes, it
seems that subject to the work of Deloitte, there remained at Board level an
appetite for amending the Scheme.
Page 34 of 68
WITNO9910100
WITNO9910100
73.1 believe the meeting with Second Sight on 11 August 2014 at (POL00129437)
probably came about as a result of an action point raised in a previous Working
Group meeting. This action would have likely related to POL’s comments on
Second Sight's draft report of August 2014. Part of my role was to try and ensure
that whatever POL decided it wanted to do, it did so in a way that was
transparent and properly documented. This would have included making sure
that if there was an action point raised by the Working Group, such action point
was addressed. Exactly how it was addressed was a matter for POL. In relation
to the August 2014 Report my main interest would have been the Scheme and
trying to make sure the applicants within it were assisted by any reports delivered
by Second Sight. It would not have been helpful for an applicant to attend
mediation and raise an issue citing a Second Sight report, for a POL
representative to then tell the applicant that they disagree with the report as it
goes beyond the scope of Second Sight’s expertise or scope of work.
74.1 did not disagree with the position taken by POL in the meeting on 11 August,
particularly in that I agreed with Paragraph 22 of the minutes that it could not be
right for Second Sight to undertake work on instructions from other people (e.g.
MPs) and require POL to fund this without prior agreement. I would have thought
it reasonable that any additional work commissioned from Second Sight should
be discussed with POL first to ensure it either fell within the scope of their work,
or was generally accepted as new work to be undertaken and funded.
Page 35 of 68
WITNO9910100
WITNO9910100
75.1 did not draft the briefing at (POL00149393) and I cannot recall whether I
contributed to it. I imagine it would have been compiled with the input from
various people within POL, and presumably it would have been agreed with
POL’s General Counsel.
76.1 have been asked in particular to what extent I agreed with the following passage
of the briefing at (POL00149393): “To start from a contrary position, whereby PO
must prove the system’s reliability, goes against both common sense and
established practice. Bluntly, it is not PO’s job to prove that Horizon did not cause
the losses incurred by Applicants to the Scheme, but for Applicants to provide
evidence that it did”. This appears to me to be a legal position and I imagine it
was drafted by a lawyer, but I cannot be certain. I do not recall if I held any
particular view in relation to this.
77.1 also find it difficult to say now the extent to which I agreed or disagreed with the
commentary on Second Sight’s reports within the briefing at (POL00149393).
POL’s assessment of the reports would not have been a matter for me and I
seldom, if ever, read POL’s investigation reports on Scheme applications, nor
Second Sight’s review of those reports. However, there was certainly an
expectation at the outset by POL (and I believe also the Working Group Chair,
although I cannot recall this for certain) that Second Sight would give a
recommendation on whether mediation was appropriate in the cases that they
reviewed. As far as I recall there was an early case in the Scheme where Second
Sight did not recommend mediation, following their review of POL’s investigation.
Page 36 of 68
WITNO9910100
WITNO9910100
However, Second Sight later announced that they would recommend mediation
in all cases going forward on the basis, as far as I recall, of a query from JFSA. I
think the Working Group Chair asked Second Sight to reconsider this position,
but they declined. I would like to emphasise to the Inquiry that I do not remember
the exact detail of any discussions had in relation to this and due to the amount of
time that has passed, it is possible that my recollection may be inaccurate.
POL’s approach to the substantive issues
78. I confirm that I have considered the following documents:
i. I (FUJ00086811) - “the Helen Rose report”;
ii. (POL00020634) - email from Andrew Parsons to me and others on 17
June 2014;
iii. (POL00021764) - email from Andrew Parsons to me on 31 July 2014;
iv. (POL00021855) - email from Melanie Corfield to me on 8 August 2014 and
the attachment at (POL00021856);
v. (POL00022216) - letter from Rodric Williams to Second Sight on 14
August 2014);
vi. (POL00040255) - email from Angela Van Den Bogerd to Andrew Pheasant
on 11 September 2014 the attachment at (POL00040256);
vii. (POL00022240) - my email to Chris Aujard and others on 3 September
2014 and the attachment at (POL00022241);
viii. (POLO0006558) - my email to Andrew Pheasant and others on 19
September 2014 and the attachment at (POL00006559);
Page 37 of 68
WITNO9910100
WITNO9910100
ix. (POL00101398) — my email to Richard Callard on 25 September 2014;
x. (POL00214304) - email from lan Henderson to me on 9 December 2014
and the attachment at (POL00214305);
xi. (POL00040498) - email from Andrew Parsons to me on 10 December
2014;
xii. (POL00040518) - email exchange with Paul Loraine and others on 19
December 2014;
xiii. (POL00022296) - attendance note of meeting with Second Sight;
xiv. (POL00132936) — my email to Chris Aujard and others on 22 January
2015;
xv. (POL00102236) - email to Alisdair Cameron and others on 27 February
2015; and
xvi. (POL00040837) - Andrew Parsons’ email to me on 3 February 2015 and
the attachment at (POL00040838).
79. It would not have been my decision on how to respond to the substantive issues
raised by applicants in the Scheme or by Second Sight, as that was a matter for
the relevant subject experts, the POL team investigating Scheme applications
and lawyers. Although substantive issues did cross my desk on occasion, the
extent of my involvement would have been to attempt to review them, raise what I
thought might be relevant questions and refer to the relevant subject experts to
provide Angela Van Den Bogerd, POL General Counsel and any other person
who I thought needed to be aware with the answers or further information they
Page 38 of 68
WITNO9910100
WITNO9910100
needed to respond to such issues. It was very much a case of trying to co-
ordinate activity to make sure the right people were involved so that matters were
resolved.
80.1 believe that I became aware of the Helen Rose report at some point in 2014,
although I do not recall exactly when. Following my review of the report and the
email correspondence around this matter, I do not think that I appreciated at the
time the extent to which the contents of it may have been important to those
SPMs who had been convicted of theft, a fraud offence or false accounting on the
basis of data generated by the Horizon IT System.
8
-Having looked at the email chain at (POL00148049), it seems that the Helen
Rose report was a matter that arose in the Working Group and I did raise
questions about it. However, on review of my emails in this chain, it is clear that I
was trying to coordinate answers to potential questions raised by the report by
trying to make relevant people aware of the contents of the report. In particular, I
would want to ensure that Angela Van Den Bogerd and POL General Counsel
were in possession of all the facts to deal with the issue at the Working Group,
and that lawyers were briefing POL General Counsel in relation to any related
disclosure issues. I would imagine I would have drafted my latest email in this
chain following a conversation with Rodric Williams from Legal and Andrew
Parsons. I do not recall what subsequently happened in relation to this matter at
the Working Group.
Page 39 of 68
WITNO9910100
WITNO9910100
82.1 would like to stress to the Inquiry that I was not involved in the process of
disclosure in relation to criminal prosecutions as this fell entirely outside of my
responsibility, expertise and competence. I was aware that a process had been
established (I believe prior to my involvement with the Scheme), to ensure that
POL fulfilled its disclosure obligations. My only involvement was that the cost of
the disclosure exercise was met by the Scheme budget. Otherwise, apart from
getting input from lawyers on the subject (if needed) when pulling together
briefings, I was not involved at all in the exercise.
83.1 note that I am also copied in to an email from Andrew Parsons on 17 June
2014, which refers to the Helen Rose report (POL00020634). I do not recall this
email and I believe I would have been copied in for information purposes only. I
do not know if the advice set out by Mr Parsons was followed - “try to down play
the importance of the HR report in any POL Investigation Reports. We
recommend minimalizing or ignoring entirely the HR Report when responding to
CQRs”. I believe it is likely that I would have read this email, but not personally
taken any further action in relation to it. I was not involved in the POL
investigation reports and having looked at the subject experts on the copy list of
this email, I believe I would have considered that this was a matter for them.
84.1 have been asked about my involvement in POL’s response to Second Sight on
the allegation that there were unexplained gains in the POL suspense account as
a result of SPMs settling false discrepancies. I would not have got involved in the
specific detail or technicalities related to POL suspense accounts as it was a
Page 40 of 68
WITNO9910100
WITNO9910100
subject outside of my area of knowledge and expertise and a matter for the
subject experts such as POL Finance. I think this issue was an action point
arising out of a Working Group meeting. As alluded to earlier in this statement, I
was responsible for coordinating matters to ensure that action points raised by
the Working Group were addressed and completed by POL. To the best of my
recollection, I believe I commissioned some work in relation to this issue on
behalf of POL, which culminated in a meeting between Second Sight and POL’s
CFO to answer Second Sight’s outstanding questions. I helped to organise this
meeting, but I would not have attended the meeting or been involved in the detail
of the discussions.
85.1 have also been asked various questions that relate to Second Sight’s part 2
report. As far as I can recall, Second Sight had issued an interim report in 2013
(prior to my involvement in the Scheme) and then what I thought was called the
part 2 briefing report in April 2015 (after I had retired from POL). However, having
now reviewed the Rule 9 disclosure I can see that there was also a “thematic
report’ in August 2014, also called the part two report. From the documents I
have read this report was not meant for publication but was produced as a
briefing report for Scheme applicants. The documents show that I would have
been involved in discussions on POL’s strategy in responding to the August 2014
report as it was relevant to the Scheme and I can see from the email at
(POL00006558) that I forwarded a document to Andrew Pheasant and others
which appears to be POL's response to such report, in which I suggested some
minor track changes. This document is found at (POL00006559). I can see that
my suggestions were only minor formatting changes or slight re-wording of
Page 41 of 68
WITNO9910100
WITNO9910100
sentences to aid understanding. I also note that I offered to draft a letter from
Angela Van Den Bogerd to accompany the amended response when sending it
off, however, I believe this letter would have simply been a cover letter, and my
offer to draft it was consistent with that part of my role which saw me co-
ordinating activity to support POL members of the Working Group.
86.The content of my email to Alwen Lyons on 22 August 2014 at (POL00148870)
relates to Second Sight’s “thematic report” of August 2014, and would have been
an amalgam of input from others which I pulled together. I think that much of this
email’s content would have been drawn from POL comments already passed to
Second Sight on the draft report, for example, Rodric Williams’ letter, addressed
to Second Sight and dated 14 August 2014 (POL00022216).
87.1 assume that I sent my email to Alwen Lyons because Second Sight’s August
2014 report concerned matters relating to the Scheme which may become public,
and I had been asked to alert the Board of this, presumably on the basis that it
would be inappropriate for Board members to read about the report in the media
without having been briefed about it.
88.1 would have been satisfied that the information I included in this email to Alwen
Lyons was accurate because it would have been an agreed approach using
information and opinions gathered from relevant subject experts. I wouldn't
question the information provided by subject experts that I pulled together for a
Page 42 of 68
WITNO9910100
WITNO9910100
briefing to the Board, unless something jumped out at me. I cannot recall a
situation where this ever occurred.
89.In relation to POL sharing Second Sight’s August 2014 report with UKGI/ShEx
and / or government, I think I saw it as being ultimately a matter for the Board, as
is indicated in my email to Richard Callard on 25 September 2014
(POL00101398). The Inquiry will see from this email that I also thought it was
important for the Working Group, or at least the Chair, to be consulted on the
matter of sharing the report with Ministers should POL wish to do so as POL, like
all members of the Working Group, was subject to the confidentiality restrictions
relating to the Working Group. I believe the August 2014 Second Sight report was
shared with ShEx/UKGI, because ShEx was represented on the Board and the
Board members would, I assume, have received a copy of the report.
90.1 do not recall personally briefing the Board, ShEx or Government on POL’s
strategy in its response to the substantive issues raised by applicants and
Second Sight in the Scheme. The Board would, I assume, have seen the various
Second Sight reports and POL’s response to them, and then been able ask any
further questions of the subject experts. I may then have provided the Board with
whatever briefing it asked for, and what the General Counsel asked me to give. I
do not know whether the Second Sight reports were ever given to Ministers and,
if so, whether they asked any further questions following receipt.
Page 43 of 68
WITNO9910100
WITNO9910100
Criminal cases and new expert:
91. I do not recall having any involvement in POL’s review of criminal convictions
secured using data generated by the Horizon IT System. I may have been aware
of this work happening, but this would have been dealt with by POL’s legal team
and would have been outside of my responsibility and expertise.
92.1 also do not believe I had any involvement POL’s approach to Professor Kramer
and Dr Dulay to prepare an expert report on Horizon — again, this was a matter
which would have been dealt with by POL’s legal team. If I were involved then I
have no recollection of it and it could only have been in some peripheral way.
93.1 do not recall my email to Patrick Bourke and others on 23 October 2014 at
(POL00091397), nor do I know what James Davidson meant when writing “The
continued failure of Second Sight (and now potentially Imperial College) to
acknowledge (or at worst engage with) this core principle results in much of the
frustration...”. I do not recall what occurred after I forwarded this to Patrick
Bourke with my further questions. It was often the case that something crossed
my desk which I thought it may be important and beyond my role and expertise,
and I would pass it on to others in POL with the knowledge and expertise to deal
with it. Generally I would only follow things up if they directly affected the Scheme
or the Working Group, otherwise I would assume that they would have been
picked up and dealt with by those responsible.
Page 44 of 68
WITNO9910100
WITNO9910100
Closure of Working Group
94.1 confirm that I have reviewed the following documents:
i. I (POL00149574) — my email to Angela Van Den Bogerd and others on 19
November 2014 and the attachment at (POL00149575);
ii. (POL00116814) - email from Patrick Bourke to you me and others on 24
November 2014;
iii. (UKGI00002621) - email from Richard Callard to me on 11 December
2014 and the attachment at (UKGI00002622);
iv. (POL00101845) - email exchange with Rodric Williams on 12 December
2014 and the attachment at (POL00101846);
v. (POL00076592) - email exchange with Patick Bourke and others on 16/17
December 2014;
vi. (UKGI00002892) - email exchange with Tim McInnes and others on 18
December 2014;
vii. (POL00150466) - email from Patrick Bourke to me on 1 January 2015 and
the attachment at (POL00150467);
viii. (POL00022293) - agenda and papers for Project Sparrow Sub-Committee
meeting on 12 January 2015;
ix. (POL00006575) - minutes of the Project Sparrow Sub-Committee meeting
on 12 January 2015;
x. (POL00109892) - email exchange with Avene O'Farrell on 20 January
2015;
Page 45 of 68
WITNO9910100
WITNO9910100
xi. (POL00150852) — my email of 9 January 2015;
xii. (POL00102109) - email chain with Patrick Bourke and others on 4
February 2015 and the attachment at (POL00130853);
xiii. (POL00311943) - my email to Chris Aujard and others on 9 February 2015
and the attachment at (POL00311944);
xiv. (POL00021908) - email from Andrew Parsons to me on 9 February 2015);
xv. (POL00132939) - email exchange on 11 February 2015;
xvi. (POL00102161) - email from Larissa Wilson to me and others on 16
February 2015 and the attachments at (POL00102162) and
(POL00102163);
xvii. (POL00006574) - minutes of the Project Sparrow Sub-Committee meeting
on 18 February 2015;
xviii. (POL00151290) - my email to Patrick Bourke and others on 26 February
2015 and the attachment at (POL00151291);
xix. (POL00102245) - email exchange with Chris Aujard on 27 February 2015;
xx. (POL00063428) - note of meeting on 4 March 2015; and
xxi. (POL00022498) - email from Mark Underwood to Melanie Corfield and
the attachment at (POL00022499).
95.1 do not recall the specific reasons as to why POL considered alternatives to the
Scheme again in late 2014 / early 2015. As mentioned previously in this
statement, it was my understanding that the Working Group and the Scheme
Page 46 of 68
WITNO9910100
WITNO9910100
were under continuous review by the Board, the Sub-Committee and ExCo
throughout my involvement in the Scheme. It seems that there was an ExCo
discussion about the Scheme which is referenced at (POL00021908), following
which the incoming General Counsel, Jane MacLeod, put a proposal to the Sub-
Committee jointly with Mark Davies, Communications Director, suggesting
amendments to the Scheme in February 2015 (POL00102162). I do not recall
that discussion and do not believe I was involved in it. The document at
(POL00006574) suggests that the proposal was agreed in principle by the Sub-
Committee on 18 February 2015, subject to notification of the Board and the
completion of some further work. As far as I recall there was a further discussion
between the new POL General Counsel and the CEO, shortly after the Sub-
Committee meeting, which I attended, which resulted in bringing forward the
amendments to the Scheme that the Sub-Committee had agreed. I cannot recall
specifically what prompted that but I think it may have been as a result of me
asking the new POL General Counsel how she wanted the Programme Team to
handle the upcoming Working Group meeting in view of the fact that a decision
had been made to alter the Scheme.
96.1 was clearly involved in some, but not all discussions on amending/closing the
Scheme. Ultimately it was the Sub-Committee, presumably endorsed by the
Board, that decided. As far as I recall my view was that it was a matter for POL to
decide what it wanted to do. I think that I felt that if the original idea of the
Scheme was aimed at hearing SPM complaints with a view to resolving
complaints and drawing a line under the matter, then it had not worked. If
anything, some SPMs and JFSA seemed less happy than when the Scheme
Page 47 of 68
WITNO9910100
WITNO9910100
started, Second Sight was publicly critical of POL and there was, as far as I
recall, a notification of legal action by a group of SPMs in the future. As such, I
agreed that there was little point in carrying on with the Scheme in the same
format, as long as those applicants remaining in the Scheme were able to have
their complaints investigated and mediated as they had been expecting. I was
also leaving shortly, so whatever decision was made I was unlikely to be involved
in the next steps.
97.In terms of what POL wanted out of the Scheme and the Working group, from the
documents provided to me I cannot see that the outcomes POL desired were
achieved. This may be the reason why a decision was taken to close down the
Working Group and Scheme. I think (and hope) that at least a small number of
applicants in the Scheme who submitted a complaint which was resolved were
satisfied.
Deloitte & Project Zebra
98.1 confirm that I have considered the following documents provided to me:
i. I POL00138190 - email from to me Lesley Sewell and others on 31 March
2014 and the attachment at (POL00138191);
ii. (POL00117519) - email from Rodric Williams to Gareth James on 2 April
2014 and the attachments at (POL00117520), (POL00117521),
(POL00117522), (POL00117523) and (POL00117542).
iii. (POL00138209) my email to Gareth James on 3 April 2014;
Page 48 of 68
WITNO9910100
WITNO9910100
iv. (POL00108462) - engagement letter dated 9 April 2014;
v. (POL00138270) - email from Gareth James to Chris Aujard and others on
28 April 2014 and t(POL0013827);
vi. (POL00328471) - email from Gareth James to Lesley Sewell on 29 April
2014 and the attachment (POL00294440);
vii. (POL00147957) - email from Gareth James to me on 7 April 2014; and
viii. (POL00107160) - Deloitte report dated 23 May 2014.
99.1 do not know where the name ‘Project Zebra’ came from and as far as I can
recall I only had a tangential role in commissioning the work from Deloitte. I
believe I was asked to assist POL General Counsel and the CIO to commission
the work for the Board, but I do not know who was responsible for deciding the
ambit of “Project Zebra” or why it was limited to a review of assurance work,
rather than an investigation in itself. It seems that this was a matter for the Board,
POL General Counsel and the CIO, as indicated by the email chain at
(POL00147957), where I appear to be coordinating the work by forwarding my
discussions with Deloitte to relevant people, and helping to arrange a meeting
between Deloitte and the CIO to finalise the scope of the project.
100. I have no recollection of what POL did with the reports produced by Deloitte
and I suspect that I never engaged with the content of such reports. It would have
been for relevant subject experts to decide whether it raised any matter of
importance and for the Board to decide whether the contents gave it the
Page 49 of 68
WITNO9910100
WITNO9910100
reassurances it required in relation to Horizon. As such, I do not think I would
have had any views on the contents of these reports.
POL’s approach to journalists
101. I confirm that I have considered the following documents:
i. (POL00149829) - email from Melanie Corfield to me on 5 December
2014);
ii. (POL00109547) - email exchange between me and Mark Davies on 7
November 2014;
iii. (POL00101712) - email from me to Mark Davies on 8 December 2014;
and
iv. (POL00101728) - email from me to Melanie Corfield on 9 December 2014.
102. I was sometimes asked for a view on how POL should respond to journalists
raising issues regarding the Horizon IT System, but I had no authority to make
the final decisions on this and my input generally related to matters regarding the
Scheme and the Working Group. I also liaised with Comms if anything arose in
relation the Scheme requiring a Comms response. However, I am not a Comms
expert, so any view that I did provide on how to respond to journalists, or what
should be in a Comms response, would have been a lay-person’s view, and
ultimately may not have been followed. I imagine my general view would have
been to engage as little as possible while the Scheme was running but ultimately
such decisions were not for me to make.
Page 50 of 68
WITNO9910100
WITNO9910100
103. I do not recall if POL had a specific strategy on responding to journalists. As
far as I was aware, journalist enquiries were dealt with on a case by case basis.
Leaving POL
104. As mentioned earlier in this statement, I left POL on 31 March 2015 to retire. I
had always intended to retire at this point, and I recall making that clear before
signing my full time contract with POL. There was no other reason as to why I left
POL at this time.
General
105. I was not involved in any of the following matters: (1) POL prosecutions of
SPMs, which, to the best of my knowledge had ceased before my involvement in
the Scheme (2) the disclosure of information to SPMs convicted on the basis of
Horizon data (which was an ongoing exercise as far as I am aware which was
undertaken by lawyers and (3) GLO proceedings, which occurred after my
retirement .
106. My involvement in the Scheme was approximately 18 months and I feel that I
can only reflect on this short time period, based on the knowledge that I had at
that time. I do not remember for certain how many prosecutions I understood
POL had brought since Horizon was introduced, but I think I believed it to be
around 200. I cannot now recall where I got that figure from. There were less than
150 applications to the Scheme, and of this number between 30 and 40 of the
Page 51 of 68
WITNO9910100
WITNO9910100
complaints related to cases involving a criminal prosecution. In light of these
figures I agreed with POL that the numbers were small compared to the total
number of Horizon users. I understood there to be a high level of confidence in
POL at senior levels, and I think NFSP, about the integrity of Horizon. Due to this,
I honestly believed at the time that POL was getting the balance right between
investigating complaints and defending the integrity of its systems. I now
understand that the number of Horizon related prosecutions and complaints are
far greater than anything that I was aware of during my involvement in the
Scheme. However, in absence of this knowledge at the time, I do not know how I
would have been able to do anything differently in relation to handling challenges
to the integrity of the Horizon IT System by SPMs, Members of Parliament,
journalists and members of the public.
107. Having now read the Helen Rose and Deloitte reports with the information I
have gleaned from the Inquiry, the various court cases and media reports during
the years since I left POL, I have considered whether I should have engaged
further with those reports and other substantive issues that crossed my desk
(even though this fell outside the scope of my role), and if so, whether this would
have made any difference to where matters are today. However, given the
technicalities of those reports and the substantive matters relating to the Horizon
IT system, I do not think I would have understood the issues enough to
comfortably challenge or question what the subject experts were saying about
Horizon, or even realise there was a potential need to challenge any assurances.
Page 52 of 68
WITNO9910100
WITNO9910100
108. I would like to express to the Inquiry how sorry I am to the SPMs and their
families who have been affected. I have watched with incredulity as the situation
has changed in comparison to how I understood matters to be when I left POL on
31 March 2015, to where we are now.
109. Other than the matters addressed within this statement, there are no other
matters that I would like to bring to the attention of the Chair of the Inquiry
I believe the content of this statement to be true.
Dated: 08 April2024
Page 53 of 68
WITNO9910100
WITNO9910100
Index to the First Witness Statement of Belinda Cortes-Martin
No
URN
Document Description
Control Number
POL00041564
Bankruptcy, prosecution and disrupted
livelihoods - Postmasters tell their story;
reported by Rebecca Thomson - Article
POL-0038046
POL00026572
Horizon — Response to Challenges
Regarding Systems Integrity
POL-0023213
POL00149276
Email chain including Melanie Corfield
(POL); Belinda Crowe (POL); Patrick
Bourke (POL) & Others Re: Remote
access to reactive statement
POL-BSFF-0008396
POL00142406
Email chain from Mark Underwood to
Belinda Crowe, Patrick Bourke and
Andrew Parsons Re: March 2010 -
Incident Details
POL-0143638
POL00151216
Email chain from Steve Allchorn to Mark
Underwood re FW: Spot Review 5
Summary
POL-BSFF-0010328
POL00151217
Summary of Information Provided by Post
Office/Fujitsu to Second Sight
POL-BSFF-0010329
POL00116179
Email from Sarah Paddison to Andy Holt,
Susan Crichton, Angela Van-Den-Bogerd
and others re Project Sparrow steering
group
POL-0117178
POL00123004
Email from Belinda Crowe to Andrew
Parsons, Andy Holt and Angela Van-Den-
Bogerd re Sparrow - text for CEO's report
POL-0129228
POL00099870
Email chain from Belinda Crowe to Peter
Batten re: Horizon PQs
POL-0099453
10.
POL00137758
Actions and Decisions from the Project
Sparrow Steering Group meeting
POL-BSFF-0000259
11.
POL00030694
Note on resources for Project Sparrow
POL-0027176
Page 54 of 68
WITNO9910100
WITNO9910100
12.
POL00146921
Project Sparrow Steering Board - Minutes
of Meeting 25 November (no year date)
POL-BSFF-0006048
13.
POL00146934
Email from Angela Van-Den-Bogerd to
Ruth X Barker, Belinda Crowe and
Andrew Parsons. Re: Alan Bates
Commented on 'DRAFT Media Statement
- Mediation Scheme Closed to
Applications in Mediation Scheme
POL-BSFF-0006061
14.
POL00100003
Post Office Limited, PROJECT
SPARROW - UPDATE, 2013
POL-0099586
15.
POL00146985
Email from Andrew Parsons to Belinda
Crowe, Chris Aujard cc Claire Parmenter
RE: Second Sight Engagement Letter
POL-BSFF-0006110
16.
POL00146986
Engagement letter addressed to Ron and
lan, in relation to the Initial Complaint
Review & Mediation Scheme
POL-BSFF-0006111
17.
POL00146987
Draft Letter from Post Office to Ron
Warmington & lan Henderson RE:
Engagement Letter in relation to the Initial
Complaint Review & Mediation Scheme
(the “Scheme”)
POL-BSFF-0006112
18.
POL00147108
Email from David Oliver to Belinda Crowe,
Chris Aujard RE: Briefing for POL CEO
Bilat with Alice
POL-BSFF-0006231
19.
POL00147109
Note from Belinda Crowe to Paula
Vennells cc'ing Chris Aujard, Hugh
Flemington and others re: Briefing for 1-2-
1 with Alice.
POL-BSFF-0006232
20.
POL00147258
Email from Belinda Crowe to Chris Aujard
- RE: DRAFT - Second Sight Engagement
Letter
POL-BSFF-0006381
21.
POL00147259
Engagement Letter in relation to the Initial
Complaint Review and Mediation Scheme
POL-BSFF-0006382
22.
POL00108231
Briefing Report For Meeting With Rt Hon
James Arbuthnot MP
POL-0110959
Page 55 of 68
WITNO9910100
WITNO9910100
23.
POL00040074
Email from Nicky Mal to Chris Aujard, Fay
Healey, Belinda Crowe and others, RE:
"The Scheme Programme Board Papers.
POL-0036556
24.
POL00040075
Post Office Media Scenario Planning-
Initial Complaint Review and Mediation
Scheme Presentation
POL-0036557
25.
POL00040076
Key Themes Emerging out of the
applications to the scheme
POL-0036558
26.
POL00040077
Independent Resolution of future cases
policy project brief
POL-0036559
27.
POL00040078
Initial Complaint Review and Mediation
Scheme Programme Board
POL-0036560
28.
POL00100200
Letter from David Oliver to Paula
Vennells, RE: Second Sight.
POL-0099783
29.
POL00116275
Email chain from Belinda Crowe to Paula
Vennells, Mark R Davies, Martin Edwards
and others re Sparrow
POL-0117268
30.
POL00116276
Success Criteria Document - SS
POL-0117269
31.
POL00027452
paper prepared for the Post Office Ltd
Board by Belinda Crowe
POL-0024093
32.
POL00100322
Memorandum from Belinda Crowe to
Paula Vennells, and others, re: Briefing
for the meetings with Second Sight and
Sir Anthony Hooper on Monday 24
February.
POL-0099905
33.
POL00302500
Post Office Limited Board meeting
minutes
POL-BSFF-0140550
Page 56 of 68
WITNO9910100
WITNO9910100
34.
POL00138176
Initial Complaints Review & Case
Mediation Scheme Programme Board
POL-BSFF-0000405
35.
POL00147643
Initial Complaints Review & Case.
Mediation Scheme Programme Board
POL-BSFF-0006766
36.
POL00147644
Post Office Limited: Horizon Mediation
Scheme
POL-BSFF-0006767
37.
POL00107317
Legally privileged report prepared by
Linklaters on behalf of Post Office into
initial complaint review and mediation
scheme legal issues
POL-0105625
38.
POL00147831
Email from Rodric Williams to Chris
Aujard, David Oliver, Angela Van-Den-
Bogerd re POL's Legal Files: Draft Email
to SS for Comment Please
POL-BSFF-0006954
39.
POL00147933
Email from Carolyn Low to Chris Aujard,
Belinda Crow, cc'd Jonathan Swil and
others - Re: Scheme options paper : to be
discussed at 10.30 on 3/4/14
POL-BSFF-0007056
40.
POL00147934
Initial complaint and Mediation Scheme:
The Way Forward - Summary of Issues
and Options Appraisal.
POL-BSFF-0007057
41.
POL00158128
Email from David Oliver to Paula Vennells
and cc'd Martin Edwards, Belinda Crowe
and others re: Slides For Scheme
discussion on Monday
POL-0146455
42.
POL00158129
PO Initial Complaint and Mediation
Scheme slides on the way forward -
Discussion draft: Summary of general
issues and options
POL-0146456
43.
POL00162134
Email chain from Chris Aujard to Alice
Perkins, Cc Mark Davies, Paula Vennells
and others re Sparrow Sub-Committee
POL-0150577
44.
POL00116439
Post Office Project Sparrow Sub
Committee Meeting ToR and Initial
Complaint Review and Mediation Scheme
document
POL-0117423
45.
POL00116444
Email from Paula Vennells to Belinda
Crowe, Mark R Davies cc. Chris Aujard
and others re: Alice.
POL-0117428
Page 57 of 68
WITNO9910100
WITNO9910100
46.
POLOO0006565
Project Sparrow Sub-Committee Minutes
POL-0017844
47.
POL00138282
Initial Complaints Review & Case.
Mediation Scheme Programme Board
POL-BSFF-0000508
48.
POL00148049
Email from Belinda Crowe to Angela Van-
Den-Bogerd, Andrew Parsons, Andy Holt
and Rodric Williams re: Post Office
Mediation Claims.
POL-BSFF-0007172
49.
POL00148068
Email trail from Belinda Crowe to Chris
Aujard, David Oliver cc Belinda Crowe re:
Sparrow Sub- Committee
POL-BSFF-0007191
50.
POL00022683
Letter from Alan Bates to Jo Swinson re:
Justice for Subpostmasters Alliance, Initial
Case Review & Mediation Scheme
POL-0019162
51.
POL00148101
Email from Belinda Crowe to Mark R
Davies, Sophie Bialaszewski, Martin
Edwards, and others re: Alan Bates letter
to Jo Swinson
POL-BSFF-0007224
52.
POL00100566
Email Chain from Peter Batten to Belinda
Crowe re Published Mediation Scheme
Docs
POL-0100149
53.
POL00100577
Email Chain from Peter Batten to Belinda
Crowe re Published Mediation Scheme
Docs
POL-0100160
54.
POL00100578
Letters from Jenny Willott MP (on behalf
of BIS) to Alan Bates and Sir Anthony
Hooper re Initial Case Review and
Mediation Scheme
POL-0100161
55.
POL00148108
Initial Complaint Review and Mediation
Scheme- ExCo Sub-Committee -
Response to JFSA Letter
POL-BSFF-0007231
56.
UKGI00002255
Email from Belinda Crowe to Peter
Batten, Richard Callard, cc'ing Martin
Edwards and Belinda Crowe, Re: Horizon
JFSA letter submission (letters) (2).doc
UKGI013069-001
57.
UKG1I00002256
DRAFT letters from Jenny Willott MP to
Alan Bates, Sir Anthony Hooper and
Paula Vennells dated April 2014
UKGI013070-001
Page 58 of 68
WITNO9910100
WITNO9910100
58.
POL00148173
Email from Belinda Crowe to Chris Aujard
cc'ing Belinda Crowe and David Oliver re:
POL_Second Sight_250414_2.doc
POL-BSFF-0007296
59.
POL00148174
Post Office Ltd Board Sub Committee The
role of Second Sight in supporting the
Scheme
POL-BSFF-0007297
60.
POLO00006566
Project Sparrow Sub-committee Minutes
30 April 2014
POL-0017845
61.
POL00040153
Email from David Oliver to Chris Aujard,
Belinda Crowe, RE: Working Group 30
April Briefing Note
POL-0036635
62.
POL00040154
Post Office Briefing Note, Working Group
POL-0036636
63.
POL00116535
Email chain with David Oliver, Mark R
Davies and Others - Re: JA Handling Plan
- Willott DO Comments
POL-0114596
64.
POL00108521
Email from Lesley J Sewell to Andy Holt,
Belinda Crowe, Chris Aujard and others
re: Requests to retain Fujitsu data
(CRO3170/ROM3170)
POL-0106618
65.
POL00116562
Email chain from Martin Edwards to
Belinda Crowe, Mark R Davies and others
RE: Sparrow: Draft Letters and Next steps
POL-0117490
66.
POL00116563
Draft Letter to James Arbuthnot re the
Mediation Scheme and MPs involvement
POL-0117491
67.
POL00021426
Audit Risk and Compliance Sub-
Committee Minutes of 15/05/2014
POL-0018056
68.
POL00021525
Meeting Minutes: minutes for Board
meeting held on 21st May 2014
POLO000058
69.
POL00148420
Email from Alwen Lyons to Christopher
Aujard and Belinda Crowe RE: Draft
Minutes in Confidence.
POL-BSFF-0007543
70.
POL00148478
Email from David Oliver to Belinda Crowe,
Mark R Davies, Chris Aujard and others -
Re: First draft of slides for Alice on
Monday
POL-BSFF-0007601
Page 59 of 68
WITNO9910100
WITNO9910100
71.
POL00148479
Chairman Briefing DRAFT NOT POLICY
POL-BSFF-0007602
72.
POL00148480
Scenario One - Post Office Take Control
DRAFT NOT POLICY
POL-BSFF-0007603
73.
POL00148481
Scenario Two Continuity DRAFT NOT
POLICY
POL-BSFF-0007604
74.
POL00148482
Scenario Three Post Office Defend
Position DRAFT NOT POLICY
POL-BSFF-0007605
75.
POL00168040
Email from David Oliver to Mark Davies,
Belinda Crowe, Sophie Bialaszewski RE:
Pack for Alice meeting
POL-0163337
76.
POL00168041
Chairman Briefing Session Sparrow draft
POL-0163338
77.
POL00027369
Post Office Ltd Board Sub Committee —
Initial Complaints Review and Mediation
Scheme: The way forward
POL-0024010
78.
POL00149689
email from Stephen Hocking to Rodric
Williams, Chris Aujard, Belinda Crowe
and others re Strictly Private &
Confidential - Subject to Legal Privilege
POL-BSFF-0008807
79.
POL00006571
Project Sparrow Sub-Committee Minutes
6 June 2014
POL-0017847
80.
POL00000213
Engagement letter of Ron Warmington &
lan Henderson in relation to Initial
Complaint Review & Mediation Scheme
VIS00001187
81.
POL00021762
Email from Belinda Crowe to Charles
Colquhoun, Rod Ismay and Andrew
Parsons re: Suspense account paper
Second Sight
POL-0018241
82.
POL00022168
Email from Belinda Crowe to Chris Aujard
and Angela Van Den Bogerd regarding
project sparrow
POL-0018647
83.
POL00129437
Second Sight’s Draft Part Two Mediation
Briefing Report — (“the Report”) re: Record
of teleconference on 11 August 2014
POL-0135014
Page 60 of 68
WITNO9910100
WITNO9910100
84.
POL00101175
Email chain from Belinda Crowe to Paula
Vennells re: Second Sight part 2 report.
POL-0100758
85.
POL00021800
Email from Belinda Crowe to David Oliver,
Melanie Corfield and Andrew Parsons RE:
Fwd: Second Sight's Draft Part Two
Report
POL-0018279
86.
POL00021801
Draft letter/email from Chris Aujard to Ron
Warrington and lan Harrington Re:
Second Sight's Part Two Mediation
Briefing Report
POL-0018280
87.
POL00148870
Email from Belinda Crowe to Alwen Lyons
and Mark R Davies re Possible note for
the Board re Second Sight's Part Two
report
POL-BSFF-0007990
88.
POL00027363
Strictly Confidential Post Office Ltd Board
Initial Complaints Review and Mediation
Scheme: Update Paper by Chris Aujard
and Belinda Crowe.
POL-0024004
89.
POL00116714
Email from Gavin Lambert to Gavin
Lambert re FW: Sparrow
POL-0117584
90.
POL00149392
Email from Belinda Crowe (POL) to Mark
R Davies (POL); Patrick Bourke (POL) &
Others Re: CEO JA Version 3 Document
POL-BSFF-0008512
91.
POL00149393
Briefing for Chief Executive (In
confidence) Paula Vennells conversation
with James Arbuthnot
POL-BSFF-0008513
92.
POL00149417
Emails from Laura Pinkney to Andrew
Parsons, cc: Tom Wechsler, Belinda
Crowe and others re: Prosecution Docs
[BD-4A.FID20472253].
POL-BSFF-0008537
93.
POL00150869
Email from Mark D Davies to Louise
Chatfield re: Possible script
POL-BSFF-0009981
94.
FUJ00086811
Horizon data, Lepton SPSO 191320, Draft
Report by Helen Rose
POINQ0092982F
95.
POL00020634
Email chain from Andrew Parsons to
Chris Aujard, Rodric Williams, Jarnail
Singh and others re: Helen Rose Report
and CQRs re Gareth Jenkins report
POL-0013826
Page 61 of 68
WITNO9910100
WITNO9910100
96.
POL00021764
Email from Andrew Parsons to Belinda
Crowe, Angela Van-De-Bogerd re:
Suspense account paper Second Sight
POL-0018243
97.
POL00021855
Email from Melanie Corfield to Belinda
Crowe, Andrew Parsons, Angela Van Den
Bogerd and others re: Response to
Second Sight Part 2
POL-0018334
98.
POL00021856
Response to Second Sight Part 2
POL-0018335
99.
POL00022216
Letter (sent by email) from Rodric
Williams to Ron Warmington and lan
Henderson regarding Second sight's part
two mediation briefing report
POL-0018695
100.
POL00040255
Email from Angela Van- Den Bogerd to
Andrew Pheasant Re: Response to
Second Sight Part 2 report
POL-0036737
101.
POL00040256
Initial Complaint Review and Mediation
Scheme, Reply of Post Office Limited to
Second Sight's Briefing Report — Part Two
POL-0036738
102.
POL00022240
Email from Belinda Crowe to Chris Aujard
regarding second sight part two —
introductory section
POL-0018719
103.
POL00022241
Draft response to second sight's initial
complaint review and mediation scheme
briefing report - part 2
POL-0018720
104.
POL00006558
Email re Response to Second Sight Part 2
report Final Draft
POL-0017652
105.
POLO0006559
Response to Second Sight Part 2 report
Final Draft
POL-0017653
106.
POL00101398
Email from Belinda Crowe to Richard
Callard, cc'd Chris Aujard, Gavin Lambert
and others re: JFSA Letter
POL-0100981
107.
POL00214304
Email from lan Henderson to Belinda
Crowe, Chris Aujard, Tom Wechsler and
others RE: Second Sight Questions for
POL-BSFF-0052367
Page 62 of 68
WITNO9910100
WITNO9910100
POL
108.
POL00214305
Initial Complaint Review and Mediation
Scheme
POL-BSFF-0052368
109.
POL00040498
Email from Andrew Parsons to Belinda
Crowe, Mark Underwood, Re: Second
Sight Questions for POL
POL-0036980
110.
POL00040518
Email from Paul Loraine to Andy Holt,
Belinda Crowe re: Second Sight
Questions - Your Help Needed
POL-0037000
111.
POL00022296
Notes on meeting held with Second Sight
on the 9th of Jan 2015
POL-0018775
112.
POL00132936
Email from Belinda Crowe to Chris Aujard,
Alisdair Cameron cc Ruth Phillips, Jane
Hill, Mark R Davies RE: Sparrow
POL-0136273
113.
POL00102236
Email from Belinda Crowe to Alisdair
Cameron, Mark Davies, Jane MacLeod
and others. Re: "Catch up call with
Second Sight".
POL-0101819
114.
POL00040837
Email sent from Andrew Parsons to
Belinda Crowe re : Suspense account
POL-0037319
115.
POL00040838
Legal advice summary by Womble Bond
Dickinson, re Access to suspense account
data
POL-0037320
116.
POL00091397
Email from Belinda Crowe to Patrick
Bourke, Tom Wechsler, Rodric Williams
and others re Notes for the 1600 meeting
POL-0090419
117.
POL00149574
Email from Belinda Crowe to Angela Van-
Den-Bogerd, Mark R Davies, Chris Aujard
and others re Commercial in confidence —
ExCo presentation.
POL-BSFF-0008694
118.
POL00149575
Powerpoint - Options for the Scheme
POL-BSFF-0008695
Page 63 of 68
WITNO9910100
WITNO9910100
119.
POL00116814
Email to Chris Aujard, Rodric Williams,
Mark R Davies and others from Patrick
Bourke Re: Scheme - Con with Counsel
POL-0114611
120.
UKG1I00002621
Email chain from Richard Callard to Peter
Batten and Belinda Crowe with copy to
Chris Aujard and others re: Sparrow
Questions for Parliamentary Debate
17/12/2014
UKGI013435-001
121.
UKG1I00002622
Draft - Response to the list of Sparrow
Questions for Parliamentary Debate
17th December 2014
UKGI013436-001
122.
POL00101845
Email from Rodric Williams to Belinda
Crowe re: Sparrow Questions
POL-0101428
123.
POL00101846
Email from Rodric Williams to Belinda
Crowe, re: Sparrow Questions
POL-0101429
124.
POL00076592
Email from Tom Wechsler to Belinda
Crowe, Rodric Williams and others Re:
Jo's conversations with James Arbuthnot
— actions coming out
POL-0073155
125.
UKG1I00002892
Email chain from Belinda Crowe to Tim
Mcinnes, cc'ing Richard Callard, Patrick
Bourke and others re: Next Steps - Call
on Sparrow
UKGI013706-001
126.
POL00150466
Email from Patrick Bourke to Belinda
Crowe re: Suggestions for the Board
POL-BSFF-0009578
127.
POL00150467
Draft Proposition to Board - Sparrow
‘Reset’
POL-BSFF-0009579
128.
POL00022293
Agenda for Sparrow sub-committee
meeting to be held on the 12 Jan 2015 to
discuss the initial compliant and mediation
scheme.
POL-0018772
129.
POL00006575
Sparrow Sub-Committee Minutes 12 Jan
2015
POL-0017849
Page 64 of 68
WITNO9910100
WITNO9910100
130.
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
POL-0111104
131.
POL00150852
Email from Rodric Williams to Andrew
Parsons re: Second Sight - Part 2
Questions
POL-BSFF-0009964
132.
POL00102109
Email from Patrick Bourke to Mark R
Davies and Belinda Crowe; re: Next steps
POL-0101692
133.
POL00130853
Post Office - Risks and Second Sight
Report
POL-0120752
134.
POL00311943
Email from Belinda Crowe to Chris Aujard,
Andrew Parsons, Rodric Williams and
others re: Note of telecon with lan
Henderson 20 Jan
POL-BSFF-0149993
135.
POL00311944
Note of call with lan Henderson - Second
Sight
POL-BSFF-0149994
136.
POL00021908
Email from Andrew Parsons to Belinda
Crowe re: URGENT - paper for sub
committee
POL-0018387
137.
POL00132939
Email from Mark Underwood to Belinda
Crowe, Chris Aujard, Andrew Parsons
RE: Note of telecon with lan Henderson
20 Jan
POL-0136276
138.
POL00102161
Email from Larissa Wilson to Mark R
Davies, Belinda Crowe, Jane MacLeod re
2015 02 18 Sparrow papers
POL-0101744
139.
POL00102162
Project Sparrow Sub-committee Update
and Options report v6
POL-0101745
140.
POL00102163
Letter from Mr Hooper to Mr Bailey; re:
Initial Complaint Review and Mediation
Scheme
POL-0101746
141.
POL00006574
Sparrow Sub-Committee Minutes 18 Feb
2015
POL-0017848
Page 65 of 68
WITNO9910100
WITNO9910100
142.
POL00151290
Email from Belinda Crowe to Patrick
Bourke, Tom Wechsler, Mark Underwood
re 260215 0934 Scheme Report (2).docx.
POL-BSFF-0010402
143.
POL00151291
POL Initial Complaint Review and
Mediation Scheme Report.
POL-BSFF-0010403
144.
POL00102245
Email from Chris Aujard to Belinda Crowe,
Alisdair Cameron, Mark Davies and
others. Re: "Catch up call with Second
Sight: Confidential and Privileged".
POL-0101828
145.
POL00063428
Susan Rudkin case study: File Note of
meeting between POL and Second Sight
4/3/2015 at1pm
POL-0059907
146.
POL00022498
Email from Mark Underwood to Melanie
Corfield, CCing Belinda Crowe, Patrick
Bourke, Tom Wechsler and others re
Scheme Report Final
POL-0018977
147.
POL00022499
Post Office Complaint Review and
Mediation Scheme Report
POL-0018978
148.
POL00138190
Email from Belinda Crowe to Lesley J
Sewell, Angela Van-Den-Bogerd, Rodric
Williams and others RE: Horizon
POL-BSFF-0000419
149.
POL00138191
Outline of points produced by Linklaters to
explain Horizon and form a basis for a
report to respond to public criticism and
individual complaints by SPMs
POL-BSFF-0000420
150.
POL00117519
Email from Rodric Williams to Gareth
James, Copying in Belinda Crowe, Chris
Aujard and others. Re: Strictly Private &
Confidential - Subject to Legal Privilege
POL-0115136
151.
POL00117520
Initial Complaint Review and Mediation
Scheme DRAFT Fact file
POL-0115137
152.
POL00117521
A table of the themes which underlie
some of the allegations that Horizon is
deficient
POL-0115138
153.
POL00117522
Post Office Mediation Scheme: Draft note
re Outline of report on Horizon prepared
by Linklaters LLP
POL-0115139
Page 66 of 68
WITNO9910100
WITNO9910100
154.
POL00117523
Presentation: Horizon Core Audit Process
- James Davidson
POL-0115140
155.
POL00117542
Description of Fujitsu's System of IT
Infrastructure Services supporting Post
Office Limited’s POLSAP and HNG-X
applications
POL-0115159
156.
POL00138209
Email from Belinda Crowe to Gareth
James, Chris Aujard, Cdesourdy,
Dtansley and others RE: Strictly Private &
Confidential
POL-BSFF-0000438
157.
POL00108462
Letter from Deloitte LLP to Chris Aujard
re: assisting Post Office Ltd litigation
POL-0106560
158.
POL00138270
Email chain from Gareth Jenkins to Chris
Aujard, Rodric Williams, Belinda Crowe
and others RE: Project Zebra
POL-BSFF-0000499
159.
POL00138271
HNG-X Review of Assurance Sources :
Executive Summary Drafted by Deloitte
POL-BSFF-0000500
160.
POL00328471
Email from Gareth James to Lesley J
Sewell, Chris Aujard, Rodric Williams and
others RE: Updated Document
POL-0179472
161.
POL00294440
HNG-X Review of Assurance Sources :
Executive Summary - Draft Drafted by
Deloitte
POL-0170608
162.
POL00147957
Email chain from Belinda Crowe to Chris
Aujard Re: Fwd.: Outline objectives,
services and deliverables
POL-BSFF-0007080
163.
POL00107160
Deloitte , Horizon: Desktop Review of
Assurance Sources and Key Control
Features , Draft for Discussion, Version
16
POL-0105468
164.
POL00149829
Email from Melanie Corfield to Belinda
Crowe, CC'd Patrick Bourke, Tom
Weschler and Rodric Williams Re: Urgent
BBC
POL-BSFF-0008947
165.
POL00109547
Email from Mark D Davies to Louise
Chatfield re: Possible script
POL-0111065
166.
POL00101712
Email from Belinda Crowe to Mark R
Davies re: BBC Today Programme
POL-0101295
Page 67 of 68
WITNO9910100
WITNO9910100
167.
POL00101728
Email from Belinda Crowe to Melanie
Corfield, Mark r Davies, Patrick Bourke
and others re:Line
POL-0101311
Page 68 of 68