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Witness Name: William Hayes
Statement No.: WITN10060100
Dated: I August 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF WILLIAM HAYES
I, William Hayes, will say as follows:
INTRODUCTION
1. I.was the General Secretary of the Communication Workers Union (CWU) from
2001 to 2015 and prior to that I was a National Officer from 1992 to 2001. The
CWU was called the Union of Communication Workers (UCW) until 1995.
2. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 Request dated 17 April 2024
(the “Request’).
BACKGROUND
3. I have been asked to provide a summary of my career and qualifications prior
to joining the CWU.
4. I left school at the age of 15 years and six months in January 1969. I joined T J
Howard (later Fabrication Steel) as an apprentice fitter-welder. After which I
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joined Lunt Engineering. I obtained a City and Guilds part one in welding craft
and practice. I joined John West Foods (JWF) in 1971 as a labourer. I left JWF
in August 1973.
. I hitch-hiked around Europe in September, October, and November of 1973. I
was unemployed until February 1974.
. I joined the General Post Office on 18 February 1974 as a post man. I became
a member of the Union of Post Office Workers, now CWU, on the same day.
. I have been asked to describe the roles I held at the CWU prior to my
becoming elected General Secretary. I held a number of lay union roles with
CWU from 1978 to 1992 as a local representative, area representative, and
branch secretary.
. In May 1992 I was elected to CWU Divisional Officer and to the Executive
Council at the same time. In September 1992 I was elected to CWU National
Officer responsible for heading up CWU negotiations for Royal Mail delivery
staff, cleaners, drivers, and cash carrying drivers that deliver to Post Office
counters.
. I have been asked to summarise the background to my election as General
Secretary of the CWU and the responsibilities of the role. The CWU General
Secretary role is set out within the rule book of the CWU (CWU00000120). The
General Secretary was often referred to as the CEO. The General Secretary
was also the chief spokesperson and negotiator. All CWU employees report to
the GS. The GS reports to CWU Annual Conference and the National
Executive Council.
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10.1 have been asked to provide a summary of my professional career since
stepping down as General Secretary in 2015. I am a CWU retired member. I
play no active role in CWU aside from the occasional CWU social activity. I
was elected to Merton Borough Council as a Labour member in 2022. All other
activity is voluntary work.
THE COMMUNICATION WORKERS UNION’S ACTIVITIES AND THE NATURE
OF MEMBERSHIP
11.1 have been asked to provide a summary of the purposes and activities of the
CWU and in particular to consider the Draft CWU Rule Book 2001
(CWU00000112) and the CWU Rule Book 2004 (CWU00000120). The CWU
exists to protect and promote its membership individually and collectively
through representation at workplace and by sector at a local and national level
using industrial and political influence.
12.1 have been asked to provide an overview of the methods that the CWU
adopted to represent its members’ interests between 2000 and 2019. The
CWU consulted it members on changes proposed by the companies it
negotiated with. This was done by face-to-face engagements with members
and employers. Agreements were subject to individual ballots of the members.
13.The CWU represented its members interests on the basis of the evidence as
the CWU saw it, in the companies it had recognition with. In addition, the CWU
used its political influence in wider sectorial issues.
14.I have been asked to consider rule 11.2.1 of the CWU Rule Book 2001 and
rule 4.1.7 of the CWU Rule Book 2004. I have been asked to summarise the
nature and extent of the legal services that CWU would provide to its members
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between 2000 and 2019. The CWU provided individual legal services for its
members together with any findings in case law. The CWU protected its right
to take legal strike action. All cases were judged on a case-by-case basis.
15.1 have been asked to what extent the rule changes in and around 2004
affected legal representation to which the CWU’s members may be entitled.
The rules governing CWU representation did not change. If they did, I was not
aware of that at the time.
16.1 have been asked to provide an overview of the types of Post Office
employees, workers or contractors that CWU represented between 2009 and
2019 limited to those who use the Horizon IT system. The type of CWU
members that would have used the Horizon IT system were Crown Office
employees and administrators in Post Office counters. I am not aware of Post
Office counter staff working at Crown Office (directly owned and directly
employed) and the extent of difficulties and discipline they may have
encountered.
KNOWLEDGE OF HORIZON
17.1 have been asked to consider: NFSP00000203 (minutes of the Horizon
Working Group meeting on 22 June 1999); NFSP00000006 (minutes of the
Horizon Working Group meeting on 27 July 1999); NFSP00000066 (minutes of
the Horizon Working Group meeting on 11 October 1999); NFSP00000001
(letter from Simon Lancaster dated 9 November 1999); NFSP00000030
(memo from Matthew Payton to Derek Hodgson dated 9 November 1999);
CWU00000101 (report by Matthew Payton dated June 1999); CWU00000103
and CWU00000100 (correspondence between Derek Hodgson, Alan Johnson
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MP and others between 19 and 24 January 2000); CWU00000088 (Tony
Kearns’ memo dated 26 January 2000 and attachment of the Horizon Working
Group submission dated December 1999); CWU00000085 (minutes of the
Postal Executive meeting on 1 February 2000); and BEIS0000566 (minutes of
the Horizon Working Group meeting on 22 August 2000).
18.1 have been asked to describe the nature and extent of my knowledge of the
integrity of the Horizon IT system from 2000 to 2008 including the existence of
bugs, errors or defects, and of “remote access”. I was aware of problems with
Horizon IT System during my time as CWU National Officer from 1992 to 2001.
I represented the workers who delivered cash to Post Office counters. I was
also aware of problems when I was GS at CWU from 2001 to 2015. I was
aware via CWU documents. I also read all CWU documentation on the matter.
I read the Private Eye magazine from the time that the article that appeared in
Computer Weekly. I had no detailed knowledge as this matter was covered by
other CWU National Officers.
19.1 have been asked to cover the extent to which I discussed the integrity of the
Horizon IT system with others at CWU. I discussed the integrity of the Horizon
IT system with others at CWU Executive meetings only. It was just a general
chat. My underlying impression was that there were problems with the system.
20.We knew that postmasters and postmistresses had problems with the
federation to the extent that about 600 of their members joined the CWU. That
was when I was GS. I think it was in about 2013/2014.
21.1 have been asked to summarise any steps I, or the CWU, took in order to
develop a better understanding of the integrity of the Horizon IT system. I read
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and familiarised myself with the CWU documentation on the Horizon IT system
together with the Private Eye magazine on the same. It was a big event when
Horizon came in. It seemed to me it was coming in at the same time as the
NHS computer system. My general impression was that it was a new system
and there were lots of issues with it.
POST OFFICE INVESTIGATIONS, CRIMINAL PROSECUTIONS AND CIVIL
PROCEEDINGS
22.1 have been asked to summarise my understanding of how POL conducted
branch audits or investigations into alleged shortfalls in branch accounts whilst
I was a member of the CWU. My own knowledge was balancing was
conducted on a Wednesday each week and that Horizon ITS changed that.
That is about the extent of my knowledge.
23. The CWU worked closely with the NFSP through our National Officers. In
2013/14 we became aware of a section of the NFSP were unhappy with their
National leadership. There were about 500 - 600 members. We allowed this
breakaway group to join the CWU. We gave them much support. Because the
NFSPs were not members of the TUC (the so called Bridlington agreement
which bars unions poaching each trade union members), they joined CWU. I
made an approach to NFSP and asked all of their total membership and
organisation to join CWU. I presented them with the offer at their Executive
meeting. There were several meetings. At the time they also had an offer from
Post Office Counters Limited (POCL) to fund their organisation. It seemed to
me the offer from POCL was an attempt to muzzle NFSPs and damage their
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independence. It has subsequently been described as a “sweetheart deal” by
the Tory MP that spoke out on the Horizon IT System.
24.1 have been asked to describe the nature and extent of any support the CWU
offered to SPMs in relation to raising concerns about the Horizon IT system or
related training and support services, the conduct of branch audits,
investigations into alleged shortfalls in branch accounts, and civil or criminal
proceedings against SPMs arising from alleged shortfalls in branch accounts.
Any such representation in relation to that was dealt with by the National
Officer representing our staff at post office counters.
25.1 have been asked to summarise my knowledge of or involvement with case(s)
in which CWU provided support or representation to an SPM who was
accused of misconduct or incompetence in relation to a shortfall in a branch
account and where the SPM could not explain the cause of the shortfall or
alleged that it was caused by the Horizon IT system between 2000 and 2008. I
have no specific knowledge except all SPMs (about 600) would have received
all the necessary support that all CWU members get.
RESPONDING TO THE EMERGING SCANDAL
26.I have been asked to consider: POL00041564 (Computer Weekly article dated
11 May 2009); POL00099062 (Second Sight’s Interim Report); CWU00000001
(letter to branches from Andy Furey dated 12 July 2013); POL00004439
(Second Sight Briefing Report — Part one dated 25 July 2014); POL00029849
(Second Sight Briefing Report — Part two dated 9 April 2015); CWU00000004
(letter to branches from Andy Furey dated 21 April 2015); CWU00000010
(Dave Ward and Andy Furey’s circular 84/2015 (PE) ‘B’ dated 18 June 2015);
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CWwU00000076 (Dave Ward and Simon Sapper’s circular NEC No. 114/15
dated 18 June 2015); CWU00000012 (minutes of the CWU NEC meeting on
25 June 2015); and CWU00000013 (Andy Furey’s letter to branches dated 17
August 2015).
27.1 have been asked to describe when I first became aware of the creation of the
Justice for Subpostmaster's Alliance (JFSA) and the allegations made in the 11
May 2009 Computer Weekly Article. I became aware of the allegations at the
time of the Computer Weekly 2009 article through Private Eye Magazine. I
became aware of the JFSA during 2024 ITV Drama Mr Bates versus the Post
Office.
28.1 have been asked to provide an account of any steps taken by me or the CWU
between 2009 to 2019 in raising any concerns regarding the integrity of the
Horizon IT system with POL, the government, the Shareholder
Executive/UKGI, MPs and peers or journalist. Representation was made
through our National Officers. When I was a National Officer no specific
concerns were raised with me.
29.1 have been asked about the extent to which me or the CWU liaised or
communicated with the NFSP and / or the JFSA in relation to the integrity of
the Horizon IT system. I have also been asked about the CWU’s relationship
with the NFSP. Our relationship with the NFSP was through the council of Post
Office unions. When that body was disbanded the NFSP and the CWU dealt
with matters bilaterally through a National Officer.
30.1 have been asked to summarise the nature and extent of any involvement the
CWU had, or the support or representation it provided, in relation to claims by
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SPMs represented by Shoosmiths in 2011, efforts by SPMs convicted of theft,
fraud offences or false accounting to overturn their convictions, and POL’s
Initial Complaint Review and Mediation Scheme. To the best of my knowledge,
we were not involved.
WHISTLEBLOWING
31.1 have been asked to describe any practice, policy or procedure adopted by
the CWU between 2000 or 2019 to enable members or officials to report
wrongdoing in so far as it related to the matters to which this Inquiry relates.
The CWU represented POL members individually and collectively as
previously described.
GENERAL
32.My overall impression was that the subpostmasters and subpostmistresses
were poorly served by the NFSP and I was concerned when the NFSP took
the offer from POL to fund their trade union that this would end in tears. As has
been stated elsewhere the NFSP became an in-house union described as a
yellow union. Sadly, this has been borne out in the real time experience of
individual postmasters and postmistresses.
Statement of Truth
I believe the content of this statement to be true.
Dep
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Signed
Dated:
Index to First Witness Statement of William Hayes
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IRN
Document Description
Control Number
Cwuo00000120
Rules for Communication
Workers Union
Cwu00000120
Cwuo0000112
Draft CWU Rule Book 2001
Cwuo00000112
NFSP00000203
Meeting minutes of Horizon
Working Group meeting of 22
June 1999 and agenda for
meeting on 27 July 1999
VIS00007651
NFSP00000006
Minutes of 4" Meeting of the
Horizon Working Group on
27 July 1999
VIS00007454
NFSP00000066
Letter on Horizon Working
Group Meeting on 8
November, attached is
meeting agenda and minutes
of Horizon working group
meeting on 11 October 1999
VIS00007514
NFSP00000001
Letter on Horizon Working
Group meeting from Simon
Lancaster to David Higlett
vIS00007449
NFSP00000030
Letter from Matthew Payton
to Derek Hodgson; copied to
Colin Baker by fax,
containing memo of Horizon
Working Group meeting on 8
Nov 1999
VIS00007478
Cwuo00000101
CWU Research — Horizon
Project — A Short History by
Matthew Payton (Research
Assistant)
Visooo09905
Cwu00000103
Letter from Derek Hodgson,
Terry Deegan and Colin
Baker to Alan Johnson MP re
Future of the Post Office
Network
VIS00009907
10
CWwu00000100
Letter from Derek Hodgson
(CWU) to Johnson MP
(Department of Trade and
Industry) re: Horizon Working
Group
visoo009904
1
Cwuo00000088
Circular: CWU Circular on
Horizon Working Group No.
18/2000 (PE) ‘A’
VIS00007762
12
cwuo00000085
Minutes: CWU Postal
Executive Meeting Minutes
(No. 51/2000) of 01/02/00
VIS00007759
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13
BEISO000566
Notes of the 10" Meeting of
the Horizon Working Group
22/08/2000
ViS00014092
14
POL00041564
Bankruptcy, prosecution and
disrupted livelihoods —
Postmasters tell their story;
reported by Rebecca
Thomson - Article
POL-0038046
15
POL00099062
Email from Simon Baker to
Paula Vennells, Mark Davies
and others re: Second Sight
POL-0098645
16
Cwuo00000001
Letter: CWU Letter to
Branches No. 489/13 re-
Second Sight and Horizon
VIS00007675
17
POL00004439
Initial Complaint Review and
Mediation Scheme - Briefing
Report — Part One —
Prepared by Second Sight
VISO0005507
18
POL00029849
Initial Complaint Review
Mediation Scheme: Second
Sight Briefing Report — Part
Two
POL-0026331
19
Cwuo00000004
Letter: CWU Letter to
Branches No. 269/15 re-
Second Sight Findings
ViS00007678
20
Cwuo00000010
Letter: CWU Letter to Postal
Executive on issues faced by
SPMs 84/2015 (PE) ‘B’
ViS00007684
21
Cwuo00000076
Circular: CWU NEC No.
114/16 re-NFSP, POL and
CwWu
vIS00007750
22
Cwuo00000012
Minutes: CWU NEC meeting
minutes of 25/06/15
VIS00007686
23
Cwuo00000013
Letter: CWU Letter to all
branches No. 533/15 with
postal members re: ‘Post
Office: Panorama
Programme on Horizon
Issues”
VIS00007687
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