WITNO09930100
WITNO09930100
Witness Name: Carla Stent
Statement No.: WITN09930100
Dated: 11 September 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF
CARLA STENT
I, Carla Stent, will say as follows:
INTRODUCTION
1. I make this statement in response to a request for evidence dated 8 July 2024
made by the Post Office Horizon IT Inquiry (the Inquiry") pursuant to Rule 9 of
the Inquiry Rule 2006 (the 'Rule 9 Request’). This statement relates to my role
as independent Non-Executive Director ("NED) of the Post Office Limited
("POL") and Chair of the Audit, Risk and Compliance Committee (the "ARC)
between 21 January 2016 and 17 February 2023.
2. I have sought to focus my statement on the specific questions contained within
the Rule 9 Request to assist the Inquiry with its important work in fulfilling its
Terms of Reference. However, before doing so, I wish to recognise the
devastating and long-lasting impact the Post Office Horizon IT scandal has had
on the lives of the people affected. I fully support the Inquiry's work to identify
Page 1 of 41
WITNO09930100
WITNO09930100
what went wrong and to address how these past failings should be rectified.
On a personal level, listening to the evidence and stories which have unfolded,
I admire the courage and fortitude shown by so many people, especially those
sub-postmasters ("SPMs") who are still waiting for appeals against convictions
and for compensation. I want to say how saddened I am at the suffering of those
affected, and the fact that so much remains unresolved after so many years.
This is not something I take lightly. I hope that all those who have been affected
will obtain full and fair redress, and that the Inquiry will make recommendations
to help ensure that such a situation cannot happen again.
My solicitors, Latham & Watkins (London) LLP, have assisted me in preparing
this statement, including by signposting me to contemporaneous documents to
refresh my memory of events. I have also, where necessary, refreshed my
memory by considering material in the public domain. Throughout this
statement I have referred to documents where I considered that they may be
helpful to the Inquiry and relevant to the matters on which I have been asked to
comment. However, for reasons beyond my control, I have, in some cases, not
received final versions of documents and therefore cannot be certain that I have
seen all relevant information. Some potentially pertinent documents were
received very recently and, as a consequence, I have been unable to cite
supporting material on every topic.
Page 2 of 41
WITNO09930100
WITNO09930100
PROFESSIONAL BACKGROUND AND APPOINTMENT TO POL BOARD
4. I was educated in South Africa and graduated with a Bachelor of Commerce in
1992 from what was formerly known as the University of Natal, and which is
now called the University of KwaZulu-Natal. I then went to the University of
South Africa and completed a B Compt Masters' Diploma in 1993, where
I specialised in advanced accounting, taxation, business administration and
auditing. Following this, I qualified as a South African Chartered Accountant and
this gave me reciprocal membership of the Institute of Chartered Accountants
in England and Wales.
5. I completed my accountancy articles with David Strachan & Tayler, which was
part of the Pannell Kerr Foster Group, and I transferred with them from South
Africa to London where I was a Manager until 1997. I worked for Natwest Equity
Markets as a Financial Controller until 1998, when I moved to Baring Asset
Management as an Investment Operations and Compliance Manager. I was
then recruited to join Thomas Cook Group in 2000, where I was Corporate
Finance and Special Projects Manager (UK), Director of Global Strategy &
Corporate Finance (Germany) and then Operations Director (UK). I then moved
to Barclays Bank in 2005, where I held several C-suite positions in finance,
operations and governance in the Global Retail and Commercial Bank.
Afterwards, I was recruited to join the Virgin Group in 2010 as a Partner in the
business, as well as Chief Operations Officer and I served as NED in several of
the Virgin Group's companies.
Page 3 of 41
WITNO09930100
WITNO09930100
Since leaving the Virgin Group in 2013, I have held (and continue to hold) NED
roles in a range of companies across the finance, retail and charitable sectors.
This includes NED roles at companies in regulated sectors and I sought
approval, as required, for each appointment from the Financial Conduct
Authority ("FCA") and other relevant regulators, who confirmed that, amongst
several requirements, they were satisfied that I had sufficient capacity to
discharge my duties. Before taking on any new position, I have also always
personally considered that I have sufficient time to commit and deliver against
expectations.
I was put forward to join the POL Board (the "Board") in 2015 via an externally
facilitated recruitment process. POL's chair, Tim Parker, was searching for a
qualified finance professional who could chair the ARC and would be able to
augment the financial services, retail and brand experience that existed within
POL. My understanding from conversations at the time was that he was also
looking for independent NEDs to help create a sustainable business that was
less reliant on government funding through subsidies. I believe that my
financial qualifications and the experience gained at Barclays Bank, Thomas
Cook Group and the Virgin Group were of particular interest.
I have been asked to describe the training and induction I received prior to
joining the Board. I did not request any training in relation to my role as a NED
because I had prior NED experience and had attended externally facilitated and
accredited NED training courses. In terms of training specific to POL's business,
I did not receive any training prior to my appointment to the Board. In my
Page 4 of 41
WITNO09930100
WITNO09930100
experience, training is usually only provided after joining a board so this was not
unusual. However, to the extent possible from publicly available information,
I carried out my own background research into the business during the
recruitment process, as I would do prior to taking on any board position. As a
result, I became aware of several media stories relating to alleged issues with
Horizon raised by SPMs. I was also aware of the evidence given by POL to the
Business, Innovation and Skills Committee in 2015.
During my interviews, I asked for an explanation of the situation. I was given
verbal assurances by Mr Parker, Virginia Holmes (independent NED), Paula
Vennells (Chief Executive Officer ("CEO")) and POL's independent auditors that
issues relating to Horizon were historical, that POL had ceased all private
prosecutions related to Horizon in 2015, that Horizon was ‘robust’ and that the
mediation scheme, initiated in 2013, was about to conclude satisfactorily. I had
no reason to doubt these assurances and I recall that the same message was
repeated after I joined the Board by Jane MacLeod (General Counsel) and
Rob Houghton (Chief Technology Officer ("CTO")). Prior to my appointment to
the Board, I also met with Baroness Neville-Rolfe, then Under Secretary of State
at the Department for Business, Energy and Industrial Strategy ("BEIS") on
23 October 2015. I recall that this was a short meeting where we discussed my
CV, but I do not recall her highlighting any matters relating to Horizon.
Page 5 of 41
10.
11.
WITNO09930100
WITNO09930100
POL uses Horizon as an electronic point-of-sale system (a model common
across other high street retail businesses). When I joined the Board in 2016, my
understanding was that Horizon had been through a number of changes with
‘legacy’ Horizon being rolled out in late 1999 and then superseded by Horizon
Online in 2010. During my time on the Board, there were, as part of business-
as-usual operations and like many of the businesses I have been involved in,
further iterative changes as part of the maintenance and improvement to the
Horizon system. Closer to the end of my tenure, we discussed the option of a
broader move away from Horizon as part of the Strategic Platform
Modernisation programme (see POL00448810). Since leaving the Board, I am
not aware of what actions have been taken.
On joining the Board, I did have an induction programme, which I believe was
of a standard format and generic in content. The POL induction provided some
supporting documentation, such as Terms of Reference, a directors' information
pack (with guidance on, for example, directors’ statutory duties) and some past
ARC papers but no legal, IT or Horizon briefings. The face-to-face induction
included a one-and-a-half-hour overview of the Horizon system which was
conducted in the ‘model office’ that replicated a Post Office branch. During this
induction, I recall being given an overview of the types of products sold and this
may have included showing, via a test system, how some customer transactions
were processed. I do not recall any detail on the 'back end' processing, SPM
reporting or any issues that were subsequently identified by the Honourable
Mr Justice Fraser (as was) or the Inquiry.
Page 6 of 41
12.
13.
WITNO09930100
WITNO09930100
On reviewing my induction schedule (POL00448802), in order to prepare this
witness statement, I note that the induction comprised a broad overview of the
principal business areas and functions. In my experience, this is not unusual
given my role as a NED without operational responsibility. I am, however, with
hindsight, struck by the absence of either a legal briefing or detailed IT briefing,
which is a different approach to other organisations that I have since joined.
Upon joining any board I would expect, as part of my induction process, a
comprehensive briefing by the legal team covering any existing legal issues
within the business, as well as to potentially be given access to the company's
external lawyers. Equally, I would also expect an IT briefing from the CTO,
especially if there are IT issues within the business.
These legal and IT briefings would have been particularly important and relevant
in assisting me to fulfil my role at POL because these issues had the potential
to impact the strategy and operations of the business, the handling of the group
litigation ("GLO") and the accounts that needed to be reviewed and
recommended by the ARC to the Board for sign off. Despite the lack of a legal
or IT briefing at the induction, I rapidly established a constructive working
relationship with the direct reports of both the General Counsel and the CTO, in
addition to the Chief Financial Officer ("CFO"). These individuals were all
regular contributors to ARC meetings on a range of business-as-usual matters
but none made me aware of any issues with the Horizon system (if, indeed, they
were aware themselves).
Page 7 of 41
WITNO09930100
WITNO09930100
14. In hindsight, despite the verbal assurances I had gained, I regret not asking
more questions about the complaints raised by SPMs during my induction
period and my early days on the board when I was familiarising myself with the
business. Assuming that I had been given both a legal and an IT briefing and
that all the known facts around Horizon would have been disclosed fully to me,
it would have provided important context, and would have likely changed my
perspective on the reliability of the Horizon system as a whole and prompted
more questioning of the GLO and business strategy.
15. As part of my induction, POL also arranged for me to spend a day visiting the
Sutton, Wimbledon Hill Road, Putney and Richmond post office branches on
3 February 2016. My conclusion was that the SPMs cared deeply about their
customers. I do not recall any issues with the Horizon system being raised with
me — although the SPMs did raise some operational challenges that they were
trying to overcome, for example, knowing if mortgage or credit card applications
had ultimately been approved. The suggestions raised to me were mostly
enhancements that would make the lives of SPMs and POL's internal staff, and
by extension, that of the public, a lot easier.
EXPERIENCE ON THE POL BOARD
General Corporate Governance
16. With hindsight, I believe that improvements could have been made to the
governance structure in relation to the litigation that existed prior to, and at the
time of, the Common Issues Judgment ("ClJ") and Horizon Issues Judgment
Page 8 of 41
17.
18.
WITNO09930100
WITNO09930100
("HIJ") (which I address in paragraph 22). However, at the time the governance
structure which existed did not strike me as much different from generally
recognised and recommended structures. As a NED, the Board and executive
committees that existed were as I expected and, when required, additional
committees were established to address specific issues, for example, the GLO
subcommittee (see paragraph 21 below). Based on the information that was
shared with us at the time, I felt that the Board operated effectively and with
dedication, with constructive discussions and debate. Post the ClJ and Hl, the
Board recognised the need for increased oversight and, as a result, met more
frequently. Between the years ending March 2020 and March 2022, the POL
annual financial accounts show that the Board had 27 ordinary Board meetings
and 71 additional meetings, the latter I recall being, primarily, to discuss the
GLO and to review past criminal cases that had been referred by the Criminal
Cases Review Commission ("CCRC").
With hindsight, the Board would have benefitted from having more detailed
oversight of legal matters and from having additional specific functional
expertise earlier in some of its committees to provide technical challenge to the
experts. A NED with legal expertise would have been very helpful much earlier
as this might have enabled more effective challenge of the external law firms
and Queen's Counsel ("QCs"), as was at the time, advising POL.
As a result of much of what I have learnt during the Inquiry hearings, it is
apparent to me now that any failings by the Board had less to do with the
governance structure we were operating under, or a failure to ask the right
Page 9 of 41
19.
20.
WITNO09930100
WITNO09930100
questions of the executive team, and more to do with the lack of openness from
the executive when it came to sharing necessary information with the Board and
its committees.
By the time that I left in February 2023, several positive changes had already
been made to the governance structure. The Board had recruited additional
NEDs with specific expertise. This included Ben Tidswell, a legal professional
who was appointed to the POL Board on 27 July 2021 and who chaired the
Historical Remediation Committee ("HRC") which was tasked with managing
the administration of the compensation schemes for SPMs. It also included Lisa
Harrington, an IT professional who worked closely with the IT team on the IT
transformation and replatforming. As part of her role, Ms Harrington helped the
business to identify the risks related to the IT transformation and replatforming
which were then fed into the risk register and the ARC, together with regular
updates into various related aspects. I believe that the appointment of SPM
NEDs was also an important development and I return to this point at paragraph
44 below.
I have been asked to give my view on the current composition of the Board with
regards to experience, expertise and abilities. The Board has changed further
since my departure and therefore I am not able to comment on the current
composition.
Page 10 of 41
WITNO09930100
WITNO09930100
Horizon and the GLO
21. When I joined the Board in 2016, I understood that a working party was
responsible for managing complaints about Horizon and I believe this had been
running since July 2013. I was never a part of that working party and therefore
was aware only of what was reported to the main Board. Updates were
infrequent, usually verbal and, as I have now learnt through the Inquiry, were of
a limited nature. After the GLO commenced, the Board agreed to establish a
GLO subcommittee on 29 January 2018, with some Board representation, to
follow the proceedings. It was only at this point that the scale of the issues
started to become clear, and I recall that the numbers of potentially impacted
SPMs eventually reached 555 by the time the case came to court in 2018.
The decision to set up the GLO subcommittee made sense to me at the time —
it meant that a dedicated team of Board members (not including myself) could
focus on steering the GLO while the rest of the Board (including myself) focused
on the extensive business-as-usual operations.
22. With the benefit of hindsight, I believe it was inappropriate for the initial Horizon
issues to have been managed by a working party (with no Board representation)
for an extended period of time. Furthermore, once the GLO subcommittee had
been subsequently established, the members of the subcommittee were,
I understand, limited in what they could disclose to the main Board because of
warnings about legal privilege and confidentiality. During my time on the Board,
I understood legal professional privilege to mean that distribution of any
information relating to a specific matter should be limited. In relation to the GLO,
Page 11 of 41
23.
24.
WITNO09930100
WITNO09930100
the directions of the General Counsel, Jane MacLeod, were that no information
should be shared or forwarded without first seeking the permission of the legal
team. Not being a lawyer myself, I relied on the expert opinion of the General
Counsel and of the external lawyers advising POL. I have subsequently learnt,
by following Inquiry hearings, that legal privilege can be waived in limited
circumstances but I was not aware of that at the time.
I recall that most legal updates to the main Board concerning the GLO were of
a procedural nature, primarily verbal and given by the General Counsel.
POL had advice from a wide range of external experts, as well as, indirectly via
the Board representative for UK Government Investments ("UKGI"), advisors
acting for BEIS, UKGI, HMRC and the Treasury. However, prior to the HlJ in
December 2019 and the standing down of the GLO subcommittee in January
2020, updates from advisors were mostly delivered to the GLO subcommittee,
of which I was not a member. Thereafter, more information was shared with the
full Board and external experts and professional advisors regularly attended
meetings; the additional board meetings, in particular (see paragraph 16
above).
It is clear now that the pre-2020 governance structure prevented some Board
members, including myself, from providing the level of scrutiny the GLO
deserved. I recall that in July 2019, in an effort to improve board scrutiny of the
litigation related matters, the Board discussed that the GLO subcommittee be
stood down and all issues relating to it and the Horizon failings be brought to
the main Board. This decision was finally implemented in January 2020
Page 12 of 41
25.
26.
WITNO09930100
WITNO09930100
(see POL00448806, pages 2-3) and, together with the changes in personnel,
including a change in 2019 of the POL CEO, General Counsel and supporting
external legal teams, meant the full Board subsequently had much improved
levels of oversight of the post-GLO remediation work.
As a Board, I recall that we discovered in April 2020 that a number of key reports
and documents that concerned Horizon (some of which pre-dated my
appointment and others of which were produced during my tenure) had not been
shared with us on the basis of legal privilege. I recall that the Board only
received a copy of, for example, the Swift Review a few months later; from
evidence given to the Inquiry to date, I understand it was sent via email by Tom
Cooper on 30 July 2020. At around the same time as the Board discovered the
various Horizon reports, I also became aware of Gareth Jenkins, who was
named as having been an expert witness for Fujitsu Services Limited
("Fujitsu"). I never met him or had any personal dealings with him and I never
saw any of the expert witness statements he provided, nor that of any other
Fujitsu witnesses. As a result of listening to this Inquiry, I now know more about
Mr Jenkins and his role in the Horizon matter.
I was surprised and angry to learn that the Swift Review, in particular, had not
been shared with us at the time it was produced in 2016, especially as, when
the GLO began shortly afterwards, the Board was being repeatedly assured by
the then General Counsel, members of the executive team and the various law
firms representing POL that the Horizon system was robust. Given the weight
Page 13 of 41
WITNO09930100
WITNO09930100
of so much expertise, and not being a legal or IT expert myself, I trusted the
recommendations that I received.
27. The ClJ handed down by Mr Justice Fraser on 15 March 2019 marked a turning
point, both in my own understanding of the severity of the situation and that of
the whole Board. We began to fully recognise the impacts on the affected SPMs
and this enabled a significant cultural shift within POL as outlined below.
POL culture
28. Following the ClJ, the Board was determined to right the wrongs of the past.
Ahead of the HlJ, in early 2019, eight workstreams were established to start to
drive change to processes, practices and culture, and a budget of £22 million
was agreed to improve operational processes and the relationship with SPMs
(see POL00448806, page 2). I discuss the relationship between POL and the
SPMs in more detail from paragraph 33 below. The workstreams were, I
believe, initially managed by the Operations team (see POL00167372, pages
3-4, POL00448793, pages 9-10, and POL00448794, pages 8-9, for examples
of updates to the Board by the Operations team) and later by the Improvement
Delivery Group formed in February 2021 (see POL00448801, page 5). A list of
around 400 actions was tracked with completion statuses verified by internal
audit and Deloitte (see, for example, POL00448811 and POL00448801). By
July 2021, about 75% of the actions had been completed (see POL00448796,
page 2).
Page 14 of 41
29.
30.
WITNO09930100
WITNO09930100
Nick Read joined as CEO in September 2019. He began to enable a culture
change within POL and showed a willingness to focus on and address past
issues. Equally, the change in General Counsel and the external legal advisors
(referenced in paragraph 24) had a tangible effect on culture — with a greater
transparency and openness in providing fuller updates to the Board being a key
difference. Mr Read appointed individuals to his management team over the
next few years who had significant experience in their fields and who appeared
to have the cultural values that he was seeking to demonstrate and embed, and
which the Board supported. I believe that later on, in March 2022, a new Director
of Cultural Change, Communications and Engagement started at POL.
By July 2019, work had been done to start to overhaul the branch network
related operational processes (see POL00279838) and the Board received
regular updates on progress. This included work to improve processes, for
example, onboarding, and suspension and termination. The aim was to enable
greater transparency, more open communication and the validation of
circumstances prior to taking any action. A dedicated loss prevention
organisation structure was also stood up to prevent losses from occurring and
to improve resolution and transparency. I recall that updates shared with the
Board indicated early signs of positive progress. As I cover in more detail below,
I recall that in late 2020 the organisation undertook a listening exercise with
SPMs to reshape the support model, moving from telephone-based support to
online support via the new Branch Hub tool (which I discuss further in paragraph
41). POL also developed new policies for working with SPMs (see
Page 15 of 41
31.
32.
WITNO09930100
WITNO09930100
POL00448808) and a new support guide for SPMs (see POL00401622, page
2), and the language of communications was reviewed to be reflective of the
learnings from the ClJ and HlJ.
From mid July 2019, POL was on a journey to integrate the changes.
The revised cultural tone from the top — both from the Board and executive
management — felt clear to me. In 2021, the executive team rolled out initiatives
such as ‘Adopt an Area’ and training focusing on a 'Week in the life of a
postmaster’ (see POL00448669, page 2), both of which I discuss below, as well
as a 'We are Post Office’ campaign to embed the new values and behaviours.
By this time, I believe that the framework for a change in culture had been
established and, by the time I left, it was being rolled out and embedded. The
progress was scheduled to be monitored and by the end of 2022, I recall that
we were starting to see improvements in the metrics but with more work to do.
As with any cultural change, we knew that this would take time.
During Phases 1-3 of the Inquiry, the Board actively encouraged the POL
management and leadership to attend some of the initial hearings, which gave
them the opportunity to hear, first-hand, the individual human impact stories of
SPMs as well as the evidence of other witnesses. As a Board, we individually
attended some of these hearings too — I attended on 14 October 2022 (see
POL00448792). Culturally, I believe that this was a significant positive
development, as the management and the Board were seeking to bring the
lessons learnt from the Inquiry back into the organisation and, by hearing
directly from the SPMs and others giving early evidence, we gained further
Page 16 of 41
WITNO09930100
WITNO09930100
insight into what we needed to do to change systems, processes and culture as
soon as practical. I am unaware if this practice continued after my departure
from the Board.
POL BOARD RELATIONSHIP WITH SUB-POSTMASTERS
33. When I joined POL, SPMs were treated as agents running their own businesses,
rather than customers or employees (with exception of the Crown Post Offices
or ‘Directly Managed Branches' as they became known). When this was first
explained to me I felt it was strange that SPMs were not treated instead as
customers, given that they represent the Post Office brand and provide Post
Office services. However, I believe that this structure was seen within the
organisation as being of benefit to the SPMs as they could be entrepreneurial
in their ventures and (outside of the Post Office product sales) could operate in
an unconstrained manner. It was also of financial benefit to POL as it meant that
the SPMs were not direct employees of the organisation.
34. SPMs only started to be viewed as customers of POL after the ClJ in March
2019. On reflection, I believe that the business had, collectively over decades,
allowed the contractual relationship to define what might otherwise have been
a customer-centric partnership. Clearly, with hindsight, this was a mistake.
Had POL adopted more of a 'service culture’ towards SPMs and treated them
as its customers, it could have encouraged a genuine two-way dialogue and
created a relationship that worked for the benefit of both parties.
Page 17 of 41
WITNO09930100
WITNO09930100
35. After the ClJ, the Board recognised the need to improve trust between POL and
36.
the SPMs (see, for example, POL00167372, page 4, and POL00448813, page
2). The Board wanted to take a strong lead on implementing material
improvements ahead of the HIJ and there was a pivot towards focusing, not just
on what we should do, but how we were doing it. Whilst trust needs to be earned
and takes time, the executive team (under Mr Read's leadership) stood up a
number of initiatives to begin to address this. These included structural changes
and enhancements to communications with SPMs, as well as increasing the
awareness of SPM's lived experience by POL management. I give some
examples below.
Structural changes included introducing a revised retail network structure in,
I believe, May 2019, and introducing an Area Manager for every branch,
irrespective of size. In early 2021, the team responsible for the new Strategic
Platform Modernisation programme had early engagement from SPMs which
helped to prioritise key deliverables, including '"PUDO' (Pick up/drop off) — an
initiative to work with carriers other than Royal Mail (such as DPD, Hermes and
Evri) to manage the increase in online shopping by the public. I recall receiving
confirmation in January 2021 that the programme had a workstream on SPM
engagement and that SPMs were being treated as business partners (see
POL00448667, pages 7-8). SPMs were also subsequently invited, in October
2021, to give their opinions on which devices should be chosen for new branch
technology (see POL00448797, page 6).
Page 18 of 41
37.
38.
39.
WITNO09930100
WITNO09930100
An example of the enhancement of communications with SPMs was the SPM
survey in March 2021, which was a chance for direct feedback. I recall that one
of the key themes was that SPMs wanted increased communication from POL
— a common theme in any feedback survey but one that POL considered
seriously. Mr Read and the executive management team sought to increase
communication via several channels including (but not necessarily limited to)
written, video, in person and ‘Branch Hub’, which I discuss further below.
In September 2021, POL appointed a serving SPM, Hithendra Cheetirala, to the
executive management team as Postmaster Experience Director. Around June
2021, Mr Read proposed a scheme whereby a small number of SPMs would
spend six to nine months at POL's headquarters rotating through several
projects, for example, designing training materials. Initiatives like these
represented a fundamental shift in mindset, with an emphasis on increasing
communication with SPMs, and ensuring SPMs were represented, and could
give feedback, at all levels of the business.
To increase awareness of SPMs' lived experience by POL management, POL
launched the 'Adopt an Area’ initiative in 2021 (see POL00448669, page 2, and
POL00448809). Each retail area was assigned one of POL's Senior
Leaders/Managers, who would visit Post Office branches in that area (initially,
virtually, on account of the Covid pandemic) and speak to SPMs and their staff,
and the initial response was positive. Feedback was collated centrally in a 'Voice
of the Postmaster’ scorecard to identify top challenges and action being taken
(see POL00448667, page 12). In addition to this and to augment it, in March
Page 19 of 41
40.
41.
WITNO09930100
WITNO09930100
2021, the Board was told that POL would run 'Week in the life of a Postmaster’
training, putting management in the SPMs' shoes and providing insight into
different aspects of what it is really like to run a branch (see POL00448669,
page 2). I understand that POL had previously offered a short ‘Postmaster
Experience’ session as part of a broader training module but the new week-long
programme was intended to give management a more rounded and in-depth
insight into the day-to-day business of a Post Office branch. I believe that the
‘Week in the life’ training was later rolled out to all POL central support staff.
I believe that in order for any cultural change to be effective, words and actions
need to be aligned and action must be taken on multiple re-enforcing levels.
There are many ways to do this and probably no singular right way. But I believe
that the steps taken (including the examples that I have described above) were
a good start and, in particular, the survey was a good way to set a baseline for
measuring and evaluating progress. It was intended that the impact of these
steps would be measured and adapted as necessary over time and I hope that
more has continued to be done after I left — both in terms of actions based on
learnings and measuring progress.
In the second quarter of 2019, the Board discussed a new initiative known as
‘Branch Hub’, which was designed to replace the various communications
platforms and channels used by POL and SPMs. It was envisaged that Branch
Hub would be a single point of interface for the SPMs as a self-serve portal that
could be accessed via their own devices. It was intended that functionality would
be expanded over time. I recall discussing at the March 2019 Board meeting
Page 20 of 41
WITNO09930100
WITNO09930100
that SPMs should be included in setting the prioritisation and in the testing and
design of the roll-out. It was thought that the system would also benefit POL as
it would support ongoing operational transformation activities — for example,
delivering an improved on-boarding experience and improving in-branch
process efficiency and operational controls.
42. I believe that the success of an initiative such as Branch Hub is dependent on
the take up and usage by the people it is designed for — in this case the SPMs.
It was successfully used during Covid for branches to be able to order PPE
(see POL00448807). Usage slowed a little after that but I recall that, by the end
of my tenure, the Board was told that adoption by SPMs of both the digital portal
and the mobile app was reported to be high and that it was intended that Branch
Hub would ultimately be integrated into the Horizon replacement system as part
of the Strategic Platform Modernisation programme.
43. AsIleft POL in February 2023, I am not aware if these releases were delivered
successfully or not.
Sub-Postmaster NEDs
44. As part of a concerted effort to get the voice of the SPMs into POL and into the
boardroom, in June 2020, the Board discussed and expressed support for the
appointment of SPM NEDs. The purpose for having SPM NEDs was announced
in a press release on 17 August 2020 as being to "advocate the interests of
more than 8,000 Postmasters". I recall that the Board believed that having the
representatives of the SPMs involved in the decision-making and in setting
Page 21 of 41
WITNO09930100
WITNO09930100
POL's future strategic direction would be very valuable. There was discussion
about whether there should be one or two SPM NEDs and, initially, the Board
decided to appoint one — which I recall was due to concerns over the size of the
Board. However, following feedback from (I believe) the National Federation of
SubPostmasters ("NFSP") and the Communication Workers Union ("CWU"),
the Board recommended and UKGI agreed to appoint two SPM NEDs and this
decision was announced in January 2021.
I recall that, from the outset, the Board wanted the SPM NEDs to be
representatives of the network of SPMs, elected by them and not by POL.
We did agree certain criteria that would be required to be an effective and
credible NED, including experience of developing a Post Office business and a
minimum tenure as a SPM. Applicants were assessed by recruitment specialists
with expertise in recruiting NEDs in the public sector, before completing a
competency-based interview with an independent panel (see POL00448795,
pages 5-6). Shortlisted candidates then canvased the SPM network for support
ahead of an election, which was overseen by an independent, external body.
The two SPMs with the most votes were recommended to the Board and the
Secretary of State for BEIS for final approval. This approval was a formality in
terms of the governance structure and the Board never intended to (and did not)
exercise any right to veto the outcome of the election. The two successful
candidates, Sarfaraz (known as Saf) Ismail and Elliot Jacobs, were appointed
as SPM NEDs by the Secretary of State on 3 June 2021 (see POL00448670,
page 1).
Page 22 of 41
46.
47.
48.
WITNO09930100
WITNO09930100
I welcomed the appointment of the SPM NEDs and encouraged the democratic
election process, with oversight by independent organisations and panels, as
I believed it went a long way to rebuilding trust with the SPMs and in ensuring
that the individuals elected would have credibility amongst their peers.
With the benefit of hindsight, before the HlJ, the Board suffered from a lack of
direct interaction with SPMs. The voice of the customer (SPMs in the case of
POL) needs to be heard directly by any board. Had this existed earlier, it might
have allowed for details on the issues with Horizon to surface earlier and for a
more constructive and open culture to develop (see paragraph 34 above). I felt
that the appointment of SPM NEDs in June 2021 was an important step forward
in this respect. Having the SPM NEDs at Board and committee meetings
ensured that Board decisions more formally considered the impact on or benefit
to the SPMs and their direct engagement helped to shape POL's strategy and
its implementation (see, for example, POL00448670, page 7, and
POL00448796, page 3). I was particularly pleased that POL was able to have
two SPM NED seats because I have experienced personally, and have seen
elsewhere, the challenges of being a lone representative.
I have been referred to an article in 'The Times' newspaper dated 19 February
2024 (RLIT0000201) which includes a statement from Mr Jacobs regarding his
and Mr Ismail's treatment by the Board. I left the Board on 17 February 2023
and so I served alongside Mr Jacobs and Mr Ismail for around 20 months. I was
surprised by the article and I do not recognise the attitudes it described or the
Page 23 of 41
WITNO09930100
WITNO09930100
terminology it used. I did not see evidence of the assertions made in the article
although I was not part of the Board in the year leading up to its publication.
49. For my part, I believe that the contributions of the SPM NEDs were not
disregarded and that they were given a voice in and outside Board meetings to
share their points of view. I recall being impressed that, in their first meeting,
they did not hold back, asked many questions and posed good challenges that
were debated. I also encouraged the appointment of Mr Jacobs to the ARC in
advance of the 5 December 2022 meeting (see POL00447940, page 5) to bring
a more detailed SPM view to the ARC's discussions. While I was only on the
Board for Mr Jacobs' first two ARC meetings, I found him to be a very helpful
addition to the committee's membership.
50. There were a few occasions where suggestions made by the SPM NEDs were
not able to be implemented either because they were not commercially viable
or not appropriate on a national scale. These decisions were only taken after
full exploration by POL's executive management team, in the same way that
suggestions by any Board member on other topics would have been
considered.
POL BOARD RELATIONSHIP WITH EXTERNAL STAKEHOLDERS
51. I have been asked to describe the Board's relationship with the NFSP, CWU,
Fujitsu, UKGI and the Department for Business and Trade ("DBT"), formerly
BEIS.
Page 24 of 41
WITNO09930100
WITNO09930100
52. A board does not typically have a direct relationship with customers, suppliers
or other external stakeholders. This is usually the remit of the executive
management team, from whom the board will often get feedback via board
materials and board meetings, as well as more informal discussions.
53. From the information shared at Board level about interactions with these
stakeholders, I would describe all these relationships as professional and POL
took interactions with each seriously, preparing for meetings with each
diligently. As in all businesses, there are periods when the parties have differing
views and objectives. However, my experience was that POL sought to have a
constructive dialogue to work through these differences to find a solution.
NFSP
54. I never met any representatives of the NFSP during my time on the Board.
My understanding is that the NFSP was originally envisaged to serve as a trade
association representing the SPMs, and it was established to create a helpful
link between the SPMs and POL. However, it did not appear to be well-used by
the SPMs, perhaps because it had been funded by POL since 2015/2016 (rather
than by membership fees) — and this sentiment was expressed to me on some
of my visits to Post Office branches in March 2019. I recall that the Board
discussed whether there was a way to reform the NFSP to make it a more
democratic organisation that was valued by, and accountable to, the SPMs.
55. I also recall that the Board asked the NFSP to review new SPM policies
(see POL00448816, page 3), and it was suggested at a Board meeting in
Page 25 of 41
WITNO09930100
WITNO09930100
December 2022 that the NFSP could assist in delivering training to SPMs in
relation to the Strategic Platform Modernisation programme (see
POL00423919, page 7).
Cwu
56. I never met with the CWU but I recall discussions at Board level about
negotiations over pay, bonuses, and other matters common to any
union/business dialogue.
57. I believe that the CWU was funding a significant employment tribunal case.
The case was managed by a steering group within POL (of which I was not a
member) and I recall the Board receiving occasional summary updates on this
topic.
Fujitsu
58. Fujitsu managed various aspects of POL's IT estate. Not being an IT expert
myself, I relied on the expert opinion of the relevant IT accountable executive
and of the external advisors to POL. By the time I joined the Board, I understood
that the relationship between POL and Fujitsu had become more challenging.
I recall that, in February 2016, the Board considered a business case on the IT
platform (see POL00448814). Fujitsu had been given notice that their contract
would not be renewed, and a new provider had been appointed — but by
February 2016, it was clear that the new provider would not be able to deliver.
It was therefore proposed that the Fujitsu contract would be extended to March
Page 26 of 41
59.
60.
61.
WITNO09930100
WITNO09930100
2021, with the option for two further one-year extensions if necessary — both of
which were later exercised. I had been in post for a matter of weeks at this point
and was reliant on IT expertise, and I therefore had no reason to question this
decision.
I recall that in 2018, the Board was informed that a number of key Fujitsu staff
who understood Horizon were retiring, making the system changes required for
the changing commercial imperatives, increasingly hard to implement.
This concern about loss of staff was reiterated in 2020, and again in 2021
(see POL00167384, page 6, and POL00448670, page 11). I recall that the CEO
and Chief Information Officer ("ClO") at the time in 2018/19, Paula Vennells and
Rob Houghton, had regular calls with the Fujitsu CEO. By June 2020, and in
response to Fujitsu approaching POL to seek an early termination of the overall
Horizon agreement, the Board supported the high-level intent for the Strategic
Platform Modernisation programme and mobilisation of activities to reduce
POL's dependence on Fujitsu in the long term (see POL00167384, page 7).
This programme was further developed over the coming months.
In September 2022, the Board approved the exercise of a further extension to
the Horizon agreement (see POL00447940, page 17). I am unaware how
matters have unfolded since, given that I stepped down from the Board in
February 2023.
From October 2018, POL was also seeking to move away from its Belfast Data
Centre, provided by Fujitsu, to a cloud-based solution. I believe that Fujitsu was
Page 27 of 41
WITNO09930100
WITNO09930100
supportive of this migration and there was initially good co-operation between
Fujitsu and the cloud storage provider. However, I recall that there was later
concern over Fujitsu's ability to deliver on the migration and their apparent lack
of engagement. Both Jeff Smyth (who held a number of roles in the POL IT
function including CTO and ClO) and Nick Read (CEO) worked with Fujitsu at
executive level to try to get clearer accountability but it was felt that POL had
limited leverage (POL00448670, page 4, and POL00448667, pages 14-15).
The Board and ARC had regular updates on this matter (see, for example, the
following Board updates: POL00448667, pages 14-15, POL00448669, page
15, POL00448799, pages 5 and 12-13, and POL00447940, pages 15-17). The
executive management team tried to leverage the broader government
relationship with Fujitsu to unlock certain areas — including trying to arrange for
Fujitsu's CEO to see a government minister in June 2021 (see POL00448670,
page 11). I cannot recall if this meeting ever took place. It became clear to the
Board that the migration had become much more complex than initially
anticipated and the Board agreed to abandon it (see POL00447940, pages 16-
17). When I left the Board, POL was in the process of agreeing an extension to
the data centre services contract with Fujitsu, at incremental cost.
UKGI
62. The relationship each of the Board and executive management team had with
UKGI was probably different depending on their role in POL. Some functions,
such as finance, had, I believe, more frequent and detailed interactions. I viewed
the relationship — which, for me, was almost solely with the UKGI representative
Page 28 of 41
WITNO09930100
WITNO09930100
on the Board, first Richard Callard and then Tom Cooper — as that of a typical
shareholder relationship. However, UKGI was more akin to a private equity
shareholder because it had dedicated teams who were able to conduct in-depth
analysis on behalf of the Board representative. UKGI typically had more
information than the rest of the Board. As POL00448805 notes (at page 2), this
was to enable enhanced oversight of POL's investment activities and
robustness of the underlying controls by UKGI.
63. Prior to the GLO, my perception was that most interactions between UKGI and
the Board were in connection with funding and with meeting the access
requirements that POL had to deliver — namely maintaining 11,500 branches
with the required geographic spread.
DBT/BEIS
64. For most of my tenure the DBT was known as BEIS and I will refer to it here as
such. The Board did not interact with BEIS very often but when we did, I recall
that the meetings were professional and the preparations beforehand were
extensive. A new BEIS Minister would occasionally attend Board meetings;
such attendances were usually very structured, well-planned and ran to the tight
timetable set by BEIS.
65. I was not personally involved in agreeing the terms of any Horizon-related
compensation schemes with BEIS or any of the government departments, nor
in agreeing any settlement with any SPM. I was also not involved in the creation
of the mediation scheme in 2013 (referred to in paragraph 9 above) and I believe
Page 29 of 41
WITNO09930100
WITNO09930100
the final mediations were concluding at the time I joined the Board. I was,
however, party to the discussions at Board level relating to the various
compensation schemes that were established after the ClJ and HlJ.
I understood that my role as a NED was, together with my colleagues and
following advice from Herbert Smith Freehills ("HSF"), in particular, to review
and make recommendations on the compensation frameworks to BEIS for their
approval (as the funding of the scheme was wholly dependent on the
government). Once the frameworks were approved, the HRC then worked with
POL's external lawyers to implement the settlement schemes. I was not a
member of the HRC.
I recall that the Board and management wanted to put right the wrongs of the
past as quickly as possible, but had to be equally mindful of the need to ensure
that taxpayer money was spent carefully. There therefore needed to be a logical
basis on which to establish a fair level of compensation. This became very
complicated given the number of categories of loss, some of which were more
straightforward to compensate whilst others carried a higher degree of
subjectivity. It felt, at times, that the process was frustrating the desire of the
impacted SPMs, the management and the Board to reach an agreed settlement.
In November 2021, the Board asked Tim Parker to speak to the Minister to
discuss funding as we were conscious that we were approaching the two-year
anniversary of the Historical Shortfalls Scheme ("HSS") in May 2022 with little
progress on the settlement with relevant claimants (see POL00448798, page
6). This did appear to improve in November 2022 with the agreement of the
Page 30 of 41
67.
68.
69.
WITNO09930100
WITNO09930100
funding for SPM detriment for suspensions and for the late applications to the
HSS.
I am aware that a number of impacted SPMs are still awaiting compensation
and I remain hopeful that a solution can be found to remedy this situation.
My role as Chair of ARC required that the committee carefully considered and
challenged the management and external auditors’ recommendations for the
provisions made and the supporting disclosures in POL's annual reports and
accounts. The ARC sought the expert advice of the financial and legal
professionals and, collectively, all parties sought to implement the accounting
principles accurately. As a result of POL being financially dependent on BEIS,
the Board had to obtain comfort that BEIS would continue to fund the business
for at least 12 months post the date of signing the annual report (with the Board
considering the Group's financial forecasts for a 15-18 month period), in order
for the accounts to be prepared on a going concern basis. This usually required
POL to obtain several Companies House filing extensions, before the required
letters of comfort were received.
My personal interactions with BEIS outside of board meetings were limited.
The Chair of the BEIS Audit and Risk Assurance Committee organised bi-
annual conferences which I attended on several occasions, in my role as Chair
of ARC, during my time on the Board. Members of the BEIS Audit and Risk
Assurance Committee also attended POL ARC meetings as observers on
30 March 2021 and 26 September 2022. I assured the BEIS attendees that
Page 31 of 41
WITNO09930100
WITNO09930100
I would welcome their interactions in the meeting and gave them the opportunity
to share reflections with the ARC members at the end of the meeting but there
was no feedback on either occasion.
70. I also had a meeting with the BEIS Audit Chair shortly before my departure
(6 February 2023) from the Board to discuss general matters related to POL.
WHISTLEBLOWING
71. Iamno longer a member of the Board, and the whistleblowing practices may
have evolved since my departure. I am therefore unable to comment on the
current culture, policies or procedures.
72. Whilst I was on the Board, the Group General Counsel had overall responsibility
for the implementation of the whistleblowing policy and appointed a third-party
supplier to run POL's whistleblowing facility (which was provided at various
times by InTouch, Expolink/NAVEX Global and Convercent). I believe that the
whistleblowing function was managed by the Financial Crime team and that they
produced monthly management information reports, although the ARC only
received summary information as part of an annual update (see POL00448815,
page 3).
73. The Whistleblowing Policy ("Policy") and POL's whistleblowing practices were
reviewed at least annually by the ARC with the objective of ensuring that
individuals could confidentially, without fear of retribution, report concerns to be
investigated. The ARC was asked to ensure that the Policy complied with
Page 32 of 41
74.
75.
76.
wr
regulatory changes, including any new FCA requirements, and in response to
the outcome of relevant reviews such as the internal audit of the area which
concluded in January 2019 with a Satisfactory rating.
I have been asked to reflect on the adequacy and effectiveness of the Policy
and POL's whistleblowing procedures. I have addressed this question
separately in relation to SPMs and internal POL staff.
Although they were entitled to use the service, I do not recall any SPM
whistleblowers coming through the process, although some cases were raised
by agent assistants (see POL00448815, page 3). POL took various steps to
increase awareness of the whistleblowing facility, and encourage
whistleblowers to come forward, which I discuss in more detail below. In relation
to SPMs specifically, POL provided updated whistleblowing guidance, as well
as training to identify whistleblowing reports for referral to the whistleblowing
team.
As regards POL staff, I found the effectiveness of the Policy and whistleblowing
procedures to be similar to other organisations I have worked at. In my
experience, the number of whistleblowing reports is usually low and reports are
often found to relate to an individual's grievance which therefore should be
handled via the Human Resources processes, rather than a situation which fits
the definition of a true 'whistleblow' which concerns itself with issues that are in
the public interest — for example, a criminal offence like fraud, health and safety
matters, a miscarriage of justice, etc.
Page 33 of 41
WITNO09930100
/TNO9930100
WITNO09930100
WITNO09930100
77. I recall that POL asked HSF to review the Policy alongside the Investigation
Policy and the Postmaster Complaints Policy. They reported back in March
2021 with suggestions to further strengthen the policies. A number of policy
changes were considered at the time (including HSF's suggestions), such as
checking that whistleblowers feel supported and clarifying that reporters don't
need to provide evidence. I believe that POL adopted these changes.
78. In the months leading up to March 2022, several additional enhancements to
the whistleblowing process were made: (i) POL re-ran an assessment of its
whistleblowing framework using benchmarking tools from the whistleblowing
charity, Protect; (ii) a new case management system was fully operational;
(iii) mandatory whistleblowing training was also put in place, which was
delivered to all POL employees between March and September 2021 via an
online training platform; and (iv) a whistleblower feedback form was created to
be issued following the conclusion of each investigation (see POL00448815,
pages 1-2). Separately, a Central Investigations Unit, reporting into the Group
Legal Director (Sarah Grey, who in turn reported into Ben Foat as General
Counsel), was established to oversee and investigate all complex and material
cases.
79. I do not believe that staff were discouraged from making whistleblower reports.
As aNED with no direct management or operational responsibility, serving after
the prosecutions had been suspended, I cannot comment on why some staff
who were working on prosecutions and/or Horizon-related investigations did not
make reports via whistleblowing channels if they were concerned about the
Page 34 of 41
80.
81.
WITNO09930100
WITNO09930100
fairness of POL prosecutions and had not received adequate responses to
concerns/queries that they may have raised with management at the time.
However, I recall that the ARC requested that HSF review past whistleblowing
cases going back to 2013 to identify if there was any evidence that
whistleblowers or the subjects of the reports (specifically SPMs) suffered
detriment.
Like many other organisations, and especially after the HlJ, POL sought to
increase awareness of the whistleblowing policy and practices, and encourage
staff to come forward with any concerns (see POL00448815, page 1). Posters
were placed in POL's offices reminding staff of the whistleblowing channels and
surveys were conducted via the intranet to understand the level of awareness
within the business. My recollection is that following these awareness
campaigns, the volume of whistleblower reports did increase. I believe that this
included some reports around unethical behaviour and policy breaches,
suggesting that POL staff were more alive to the importance of escalating a
broad range of issues.
Zarin Patel, an independent POL NED, was appointed as the newly created
independent 'Whistleblowing Champion’ in March 2021 (see POL00401622,
page 4). It is normal for there to be a member of the executive team or, more
often, an independent NED appointed as a whistleblowing champion with a
generic email address to which staff can send information. I supported this
appointment believing that it was a good practice for POL to adopt. At or around
the same time, a dedicated Whistleblowing Manager role was created (see
Page 35 of 41
WITNO09930100
WITNO09930100
POL00448815, page 2) and a whistleblowing team was established, with whom
Ms Patel met quarterly.
82. I am not aware of any whistleblower reports since the ClJ and HlJ that were
expressly related to Horizon. However, I recall that whistleblower reports
continued to be received that related to SPMs and that concerned allegations
of, for example, fraud and cash discrepancies. It is my understanding that these
cases were passed to the Central Investigations Unit to consider in light of the
findings of the ClJ and HlJ, including assessing whether there was any possible
link to Horizon.
DEPARTURE FROM POL BOARD AND SUBSEQUENT EVENTS
83. Iserved on the Board from 21 January 2016 to 17 February 2023. Generally, a
NED should serve a maximum of two terms of three years when working for a
government-owned asset such as POL. My second term was approved on
29 January 2019. Shortly before the end of my second term, I recall having two
separate telephone calls with Mr Parker and Mr Cooper. They asked me to
remain on the Board for an additional period to finalise the annual report and
accounts for the 2021/22 year end and to prepare for them to be laid before
Parliament, which was subsequently done on 23 February 2023. The accounts
were approved and signed in August 2022 (see POL00448812) but there was
a delay in publication due to an outstanding approval from BEIS on a
remuneration matter (see POL00447940, page 7). In my final ARC meeting on
23 January 2023, the ARC recommended to the Board that the 2021/22 annual
Page 36 of 41
WITNO09930100
WITNO09930100
report and accounts were published (see POL00448800, page 2). I handed in
my resignation letter on 17 August 2022 and I stepped down from the Board on
17 February 2023, after handing over to the new ARC Chair, Simon Jeffreys.
84. I have been asked to set out my understanding of the circumstances which led
to the dismissal of Henry Staunton as POL Chairman on 27 January 2024 and
the resignation of Alisdair Cameron as CFO on 25 June 2024. I left the Board
before the departure of either Mr Staunton or Mr Cameron and am therefore
unable to comment on the circumstances which led to those events.
REFLECTIONS
85. Looking back on events now, with the advantage of knowing more than I knew
at the time, I believe that the organisational culture and ways of working led to
an over-reliance on the views of and advice from a limited group of senior
leaders. As the Inquiry has heard from others, the Board was not party to the
full facts at many key moments, especially during the first three years of my
tenure from 2016-2019. The more details that emerge via the Inquiry, the more
I am forced to reconcile how little was shared with myself and others on the
Board by those responsible for managing the Horizon IT failings. Had all the
known facts around Horizon been disclosed to us fully, I believe that this would
have likely changed my perspective on the reliability of the Horizon system as
a whole and prompted more questioning, particularly of the GLO and the
associated business strategy. In addition, I believe that the Board would have
benefitted from more detailed oversight of legal matters, having the voice of
Page 37 of 41
WITNO09930100
WITNO09930100
SPMs heard more directly and additional specific functional expertise earlier in
some of its committees to provide technical challenge to the experts. POL later
appointed individuals to provide that functional expertise, who all made valuable
contributions.
86. Following the ClJ, management and the Board focused on beginning to right
the wrongs of the past and I felt that this led to a significant cultural shift within
POL. As I have outlined above, I believe that, by the time I left, the framework
for this change in culture had been established and was being rolled out and
embedded. Cultural change takes time but I believe that the early signs were
encouraging and I hope that more has continued to be done since I left the
Board.
87. I hope that all those who have been affected by Horizon will obtain full and fair
redress, and that the Inquiry will make recommendations to help ensure that
such a situation cannot happen again.
Statement of Truth
I believe the content of this statement to be true.
11 September 2024
Dated:
Page 38 of 41
WITNO09930100
WITNO09930100
Index to First Witness Statement of Carla Stent
No. I URN Document Description Control Number
1. POL00448810 Post Office Limited — POL-BSFF-WITN-
Strategic Platform 017-0039718
Modernisation, Business
Case Review Final Report
by Deloitte dated May 2021
2: POL00448802 New Chair of Audit POL-BSFF-WITN-
Induction Programme for 8; 017-0000034
9 February 2016
3. POL00448806 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 28 017-0023723
January 2020
4. POL00167372 Board minutes of Post POL-0161312
Office Ltd dated 30 July
2019
5. POL00448793 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 08 013-0000003
April 2020
6. POL00448794 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 26 013-0000012
May 2020
7. POL00448801 Postmaster Journeys, Post} POL-BSFF-WITN-
Office Limited, Final Draft I 015-0009298
Report by Deloitte dated
March 2021
8. POL00448811 Post Office Limited's POL-BSFF-WITN-
Internal Audit Report dated] 017-0039770
30 June 2021
9. POL00448796 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 27 013-0000070
July 2021
10. I POL00279838 Table of Changes to POL-BSFF-0117901
Operational Processes
dated 5 July 2019
11. I POL00448808 Post Office Limited's Audit,I POL-BSFF-WITN-
Risk and Compliance
Committee Report dated
26 January 2021
017-0032971
Page 39 of 41
WITNO09930100
WITNO09930100
No. I URN Document Description Control Number
12. I POL00401622 Minutes of Post Office POL-BSFF-0228292
Limited's Audit, Risk and
Compliance Committee
dated 30 March 2021
13. I POL00448669 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 30 013-0000055
March 2021
14. I POL00448792 Email from Ben Foat to POL-BSFF-WITN-
Benjamin Tidswell, Carla I 005-0008848
Stent and others, re:
Inquiry Hearing dated 07
October 2022
15. I POL00448813 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 29 022-0000196
October 2019
16. I POL00448667 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 26 013-0000046
January 2021
17. I POL00448797 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 26 013-0000076
October 2021
18. I POL00448809 Email from Veronica POL-BSFF-WITN-
Branton to Tim Parker, 017-0033798
Carla Stent and others, re:
Postmaster Engagement
dated 12 February 2021
19. I POL00448807 Letter sent by Amanda POL-BSFF-WITN-
Jones via One News dated] 017-0032012
05 January 2021
20. I POL00448795 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 27 013-0000031
October 2020
21. I POL00448670 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 03 013-0000062
June 2021
22. I RLITO000201 The Times article dated 19} RLIT0000201
February 2024
23. I POL00447940 Board minutes of Post POL-BSFF-107-
Office Limited dated 27
0000024
Page 40 of 41
WITNO09930100
WITNO09930100
No. I URN Document Description Control Number
September 2022
24. I POL00448816 Post Office Limited's Audit,I POL-BSFF-WITN-
Risk and Compliance 043-0000002
Committee report dated 30
March 2021
25. I POL00423919 Board minutes of Post POL-BSFF-0238734
Office Limited dated 06
December 2022
26. I POL00448814 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 09 030-0000004
February 2016
27. I POLO0167384 Board minutes of Post POL-0161324
Office Limited dated 30
June 2020
28. I POL00448799 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 28 013-0000081
September 2021
29. I POL00448805 Post Office Limited's POL-BSFF-WITN-
Change Assurance ReportI 017-0019760
dated 28 February 2020
30. I POL00448798 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 03 013-0000077
November 2021
31. I POLO0448815 Post Office Limited's Audit,}I POL-BSFF-WITN-
Risk and Compliance 042-0000007
Committee report dated 28
September 2021
32. I POL00448812 Email chain from Rubia POL-BSFF-WITN-
Khanom to Carla Stent and 017-0047842
others, re: POL ARA 2021-I
22 — For Information dated
17 August 2022
33. I POL00448800 Board minutes of Post POL-BSFF-WITN-
Office Limited dated 24
January 2023
013-0000088
Page 41 of 41