WITN10400100
WITN10400100
Witness Name: Suzanne Winter
Statement No.: WITN10400100
Dated: 2°¢ January 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF SUZANNE WINTER
I, Suzanne Winter, will say as follows:
Introduction
1. I am a former employee of Post Office Ltd and held the position of Fraud
Investigator.
2. This witness statement is made to assist the Post Office Horizon IT Inquiry
with the matters set out in the Rule 9 Request dated 28th November 2023. I
have spoken with the Witness Liaison Team in Post Office but have not relied
on any information from them other than having asked for assistance in
locating my start date at Post Office. In preparing this statement I have been
assisted by Mr Fintan Canavan of DAC Beachcroft solicitors.
Background
3. I commenced my working life in 1972 as a book clerk in The Old Bleach Linen
Mill, Randalstown and in 1973 I started employment as a counter assistant in
Page 1 of 46
WITN10400100
WITN10400100
Randalstown Sub Post Office. I was very proud to start work in a Post Office
as my father was a Postman and my mother had previously worked for the
Post Office and it was an institution held in very high repute. The Sub
Postmaster in Randalstown provided initial training and kept a watchful eye on
me and my work until I was competent in all aspects of counter work. I
assisted with the preparation of accounting documents for the weekly balance
and manually completing the balance sheet. This was of course prior to the
introduction of Horizon.
. In early 1976 I sat the Postal and Telegraphs Officer examination and after
interview was successful in obtaining employment in Ballymena Crown Office.
I received three weeks training and worked at the counter for two years. After
two years I progressed to work in the secure area of the office covering
various jobs. Dispatching cash/stock remittances to Sub Post Offices,
accepting cash/stock from Sub Post Offices, Acting Postal Executive in
charge of the incomings/outgoings of the safe, Counter supervisor and
responsible once a week for accumulating the counter balances of all the
stock units held in the office and balancing with the figures held for the safe.
These positions were usually held for a period of between four and six months
when you would then change to give you experience in all of the different
work involved. After a number of years I progressed to the writing room where
I covered a number of jobs. The Wages Duty entailed preparing the weekly
wages for each postman employed in the Ballymena Post Office and
surrounding smaller delivery offices. Post Office Sales Representative
Assistant, this job mainly involved making telephone calls to businesses to
Page 2 of 46
WITN10400100
WITN10400100
promote and sell Post Office products and services. Datapost Duty entailed
calculating monies owed by businesses using the Datapost express service.
Household Delivery Duty involved gathering all paperwork every week relating
to the customer and to the relevant delivery postman and balancing.
. A vacancy arose in the Planning Room for an auditor’s position. I applied and
after interview I was successful in obtaining the post. I worked closely with my
line manager and he would give you a weekly plan for offices to be audited.
As far as I am aware my manager and myself would usually be the only
people in the office who would be aware of the Post Offices to be visited.
Before visiting each office I needed to check stock/cash figures, staff
employed, the area to be visited and risk assessment. The majority of offices I
would visit by myself or my manager would accompany me if it involved a
larger post office.
. In 1988/1989 there was a major reorganization within the business and the
majority of staff was moved to work in Royal Mail House Belfast. Around this
time the business was split into two companies. Royal Mail and Post Office
Ltd. Initially I remained an employee of Royal Mail from March 1989 and
worked in Customer Services in Royal Mail House Belfast in the International
Return Letter section. Unfortunately after working in the section for six months
I opened a letter bomb. This incident meant I was unhappy to continue to
work in this section because of the risks and I was moved to the Business
Centre as an administrator covering various tasks. Arranging business
Page 3 of 46
WITN10400100
WITN10400100
collections, household deliveries, setting up Private Boxes and assisting the
two Postal Services Representatives to promote the business.
. A few years later I applied for a Sales Managers post in Customer Services
and was successful. This job entailed managing a portfolio of businesses and
meeting financial monthly targets. I worked in this post until around 1997/1998
when I was successful in my application to move to the Royal Mail Security
Team as an Investigator. The job entailed detecting offences against Royal
Mail ( for example complaints about money going missing in the mail,
undelivered post and working with the Drugs investigators and HMRC) and
initiating prosecutions to the Police.
. I received initial in house training provided in the office by Royal Mail and also
completed three weeks training in the Royal Mail Training School in Milton
Keynes. The training covered all aspects of the role including witness
statement taking, analyzing data, interviewing suspects, PACE, Risk
Assessments, and Surveillance. I also attended Thames Valley Police
Training College and undertook a search course. During the course of this job
I worked with other investigators in the Royal Mail team, Police and Her
Majesties Customs and Excise.
. In 2001 after another business reorganisation I moved to Post Office Ltd
based in Queens House, Belfast as an Investigations Manager in the Post
Office Security Team. I received initial training in the office and then, once
again, I attended three weeks intensive training in the Training College in
Page 4 of 46
10.
11.
WITN10400100
WITN10400100
Milton Keynes. The training again covered all aspects of the role including
witness statement taking, analyzing data, full disclosure, interviewing
suspects, PACE, Risk Assessments, working on the Horizon system,
preparing case files with any updated information. I also re-attended Thames
Valley Police Training College and undertook a search course. Once I had
received the training I was then mentored for six months by Les Thorpe my
line manager. I had the grade of manager but did not have anyone working to
me so was effectively a one person department.
After another re-organisation my role expanded to include investigating
robberies, burglaries and Tiger Kidnap situations. At various times the job title
changed but the job content remained the same. I remained in the
Investigation Team until December 2014 when I left the business under
voluntary redundancy which was available at the time. When I first came into
the role there was no agreed procedure or protocol in place and I transferred
across the basic procedures and protocols from the Royal Mail role I had held
and agreed an MOU with the police and PPS as to co-operation in
investigations and prosecutions.
I had no role in Disciplinary matters as they were dealt with by the Post Office
Contracts Manager with regard to cases involving Subpostmasters. Crown
office staff was dealt with by Human Resources and a Senior Manager. As an
investigator my role was to interview Post Office employees and agents who
were suspected of, or had admitted to, committing a criminal offence and to
ascertain the facts in the enquiry. I produced a Suspect Offender File to the
Page 5 of 46
WITN10400100
WITN10400100
Casework Team for compliance and forwarding to the Head of Security for
comment and recommendations. If Head of Security recommended
progressing the case I prepared an Evidential Report for the PSNI to get their
opinion. If the PSNI felt sufficient evidence to progress I then completed a
Prosecution File and handed to PSNI for the PPS. It was for the PSNI to
progress the file to Public Prosecution Office. Before a suspected criminal
interview I gave full disclosure to any Legal representative who was present.
The legal representative then was offered the opportunity to a meeting with
their client before the interview commenced. Should any case progress to the
court, the PSNI and PSO would assist with disclosure. I was not involved in
any decision to prosecute nor did I become involved in agreeing litigation
strategy. When progressing cases I liaised with various Post Office
departments depending on the nature of the case. I can recall working with
Post Office Contracts Managers, Area Managers, Postmaster Federation
Representatives, Audit Team, Security Casework Manager, Post Office
Helpline, Financial Recovery Investigators, Post Office Legal Services,
Finance Service Centre which included the lottery team and cheque team. At
one point in the time I worked in Investigations the PSNI underwent a re-
organisation and my initial files were sent to a local solicitor in Belfast,
McCartan Turkington Breen, and they reviewed the file and directed any
further investigations before the file went to the PSNI and DPP. If the Head of
Security, the PSNI, the PPS (or McCartan Turkington Breen) felt they needed
further investigations, more detail or further reports they would request these
and I would conduct the further investigations.
Page 6 of 46
WITN10400100
WITN10400100
The Security team’s role in relation to criminal investigations and
prosecutions
12.I have been provided with and considered the following documents and while
a number of them look familiar there are also a number I do not recall. A few
are perhaps related more to Royal Mail and I had left that business when
([POL00030902)) was issued.
i) Casework Management Policy (version 1.0, March 2000)
([POL00104747]) and (version 4.0, October 2002)
([POL00104777));
ii) Rules and Standards Policy (version 2.0, October 2000)
([POL00104754));
iii) “Investigation Procedures Policy (version 2.0, January 2001)
([POL00030687));
iv) Disclosure Of Unused Material, Criminal Procedures and
Investigations Act 1996 Codes of Practice Policy (version 1.0, May
2001) ([POL00104762));
v) “Security Managers’ Guide to the Prosecution Support Office” (May
2001) ([POL00121455]) (see paragraphs 6 and 33);
vi) “Royal Mail Group Security — Procedures & Standards — Arrest
Procedures” (Version 2.0, May 2001) ([POL00104760]) (in
particular paragraph 3.15);
vii) I Appendix 3 of Investigation Policy “Notes of Interview — Northern
Ireland” (Version 5.0, November 2002) ([POL00039952));
Page 7 of 46
WITN10400100
WITN10400100
viii) “Royal Mail Group Security — Procedures & Standards — Searching”
(September 2006) [POL00094163] (see paragraph 2.3 in
particular);
ix) Police and Criminal Evidence (Northern Ireland) Order 1989 (1
March 2007) ([POL00121591]);
x) "Royal Mail Group Ltd Criminal Investigation and Prosecution
Policy" (1 December 2007) ([POL00030578], which appears to be
substantially the same as the policy of the same date with a
variation on the title at [POL00104812]) (see, in particular, section
3), -8-
xi) "Royal Mail Group Security - Procedures & Standards - Standards
of Behaviour and Complaints Procedure" (version 2, October 2007)
([POL00104806));
xii) I “Royal Mail Group - An Inspection of the Royal Mail Group Crime
Investigations Function” (July 2008) ([POL00121607));
xiii) I "Royal Mail Group Crime and Investigation Policy" (version 1.1,
October 2009) ([POL00031003));
xiv) "Post Office Ltd - Security Policy - Fraud Investigation and
Prosecution Policy" (version 2, 4 April 2010) ([POL00030580));
xv) “Post Office Ltd Financial Investigation Policy" (4 May 2010)
([POL00030579));
xvi) "Royal Mail Group Security - Procedures & Standards - The
Proceeds of Crime Act 2002 & Financial Investigations" (version 1,
September 2010) ([POL00026573));
Page 8 of 46
WITN10400100
WITN10400100
xvii) "Royal Mail Group Security - Procedures & Standards - Initiating
Investigations" (September 2010) ([POL00104857));
xviii) "Royal Mail Group Ltd Criminal Investigation and Prosecution
Policy" (version 1.1, November 2010) ([POL00031008)});
xix) Post Office Ltd Financial Investigation Policy (version 2, February
2011) ([POL00104853));
xx) Post Office Ltd Anti-Fraud Policy (February 2011)
([POL00104855]); xxi) "Royal Mail Group Policy Crime and
Investigation S2" (version 3.0, April 2011) ([POL00030786));
xxi) “Royal Mail Internal Information Criminal Investigation Team-
Casefile Construction England, Wales and Northern Ireland”
(Version 1.0, June 2011) ([POL00104877));
xxii) “Royal Mail Internal Information Criminal Investigation Team -
Appendix 1 to 8.2 Suspect Offender Reports, Preamble Guide,
England, Wales and Northern Ireland” (Version 1.0, June 2011)
([POL00104879));
xxiii) “Royal Mail Internal Information Criminal Investigation Team — 8.2
Guide to the preparation of suspect offender reports, England,
Wales and Northern Ireland” (Version 1.0, June 2011)
([POL00104881]);
xxiv) “Royal Mail Internal Information - Casework Management and PSO
Products and Services” (Version 1.0, June 2011) ([POL00104888])
(particularly paragraph 9.3);
xxv) “Post Office Prosecution Policy” (version 1.0, 1 April 2012)
((POL00031034)):
Page 9 of 46
WITN10400100
WITN10400100
xxvi) “Post Office Ltd PNC Security Operating Procedures” (August
2012) ([POL00105229));
xxvii) "Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement (with flowchart)", (October 2012) ([POL00104929]);
xxviii) "Undated Appendix 1 - POL Criminal Investigations and
Enforcement Procedure (flowchart)", (October 2012)
([POL00105226));
xxix) The undated document entitled “POL — Enforcement & Prosecution
Policy” ([POL00104968});
xxx) "Post Office Limited: Criminal Enforcement and Prosecution Policy"
(undated) ([POL00030602));
xxxi) "Conduct of Criminal Investigations Policy" (version 0.2, 29 August
2013) ([POL00031005));
xxxii) “Post Office Prosecution Policy England and Wales” (1 November
2013) ([POL00030686)) (in particular paragraph 1.2);
xxxiii) "Conduct of Criminal Investigations Policy" (version 3, 10 February
2014) ([POL00027863));
xxxiv) "Conduct of Criminal Investigations Policy" (September 2018)
((POL00030902)).
13.From what I can recall the Security Team included The Head of Security,
Policy and Standards Manager, Senior Casework Manager and Compliance
Manager. Casework Team, Fraud Investigators covering Scotland, England,
Wales and Northern Ireland. Legal Services, Financial Investigators, Physical
Security Managers. There may have been others but I cannot recall. There
Page 10 of 46
WITN10400100
WITN10400100
were numerous re-organisations throughout my time in the business and
changes to titles and roles within teams making it difficult to be specific about
some of these matters. Significant changes that I can recall was a particular
reorganisation when there was a major cut back in the number of
investigators. I cannot recall exactly when this happened. During another
business reorganisation additional posts were created such as Financial
Investigators and a Fujitsu Liaison Officer. I believe the Audit Team was
integrated into Security at some point although I am unsure of that. The team
in NI was always small and so many of the re-organisations had little direct
day to day impact on us.
14.To the best of my knowledge I was not involved in the development and/or
management of the above policies. I was, as mentioned before, involved
working with Post Office Security, the PSNI and Public Prosecution Service to
develop a Memorandum of Understanding for prosecution cases in NI.
15.Any legislation, policies or guidance governing the conduct of investigations
conducted by the Security Team during my period of working within that team,
if relevant, would have been communicated usually by Policy and Standards
or the Casework team. From my recollection a different caution was issued in
Northern Ireland and the Police and Criminal Codes of Practice in Northern
Ireland were followed rather than their England and Wales equivalent. The
correct routines for NI were applied. Different, NI specific, forms would also be
used when conducting a formal interview. After completing a Suspect
Offender file and receiving authority from the Head of Security to progress, an
Page 11 of 46
WITN10400100
WITN10400100
Evidential Report would be prepared and handed to the PSNI. I would discuss
the report with the PSNI Investigating Officer and receive advice if further
statements or documents etc. were required. Once the Evidential file was
completed to the satisfaction of the Police I produced a Prosecution File. This
file would be handed to the Police for forwarding to PPS. Once the PPS had
read the file I would meet with them to discuss.
16.I was not working in investigations when the Post Office separated from Royal
Mail and joined Post Office at a later date.
17.I do not recall the process for dealing with complaints about the conduct of an
investigation by the Security Team but if I had to speculate I think it would be
dealt with by a Senior Manager and filtered to your line manager. I do not
remember any complaints being made around my investigations.
18.In respect of supervision over criminal investigations conducted by Security
Managers this would be overseen by your Team Leader/ Line Manager and
also the Casework/Compliance manager. Ongoing cases would be discussed
by regular telephone contact, monthly one to one meetings, attending
interviews and Team meetings. A casework compliance check was carried
out to ensure everything had been completed correctly and that the same
standards were being applied across the wider team and all required
documentation was in place. At a monthly meeting your cases would be
discussed in one to one sessions and if any further actions needed to be
taken these would be discussed and agreed. I also received guidance and
Page 12 of 46
WITN10400100
WITN10400100
instruction from PSNI and PPS which was often of greater impact as it
addressed the NI specific issues.
19.I have been asked how Post Office policy and practice regarding investigation
and prosecution of Crown Office employees differed from the policy and
practice regarding investigation and prosecution of SPMs, their managers and
assistants. From what I can recall there was no difference in the investigations
I undertook with regard to Crown office staff and Sub Postmasters. From
recall there was a reduction in the number of audits conducted due to
cutbacks and if assistants were suspected of committing a crime the SPM
was advised to report the matter to the police, as it was more in line with an
employment matter, and provide our contact details instead of the Post Office
Security Investigation Team being directly involved.
Audit and investigation
20.1 have been asked to consider the document “Condensed Guide for Audit
Attendance” ([POL00104821]). I do not recall this document. From what I can
recall if the auditor on site, reported a significant loss or if the Counter
Clerk/Sub Postmaster volunteered they had inflated the cash figure an
investigator would be asked to attend. Attendance would also be required if
the investigator had requested the audit due to concerns with the accounts or
if another department had concerns. The investigators role on attendance
would be to introduce themselves, their second officer and the audit team.
They would explain why they were visiting the office, issue a caution, advise
the person of their Legal Rights and Post Office Friend Rule, make a
Page 13 of 46
2
22.
WITN10400100
WITN10400100
notebook entry recording that. The investigator would remain onsite and await
the final outcome of the audit and report to the contracts manager and to Line
Manager. If there was no reasonable explanation for a loss identified the
investigator would remind the person they were still under caution and invite
them for a formal interview. This interview was arranged at an appropriate
venue. My official notebooks were stored in a safe in my office or may have
been sent to one of the security teams. I did not retain these myself when they
were complete and do not have any at my home.
.I have been asked if a shortfall following an audit of a Post Office branch was
identified who determined whether an investigation was raised. During my
employment there were different triggers to raise an investigation but cannot
recall what they were. I received my investigation cases from the Casework
Management Team and recall the Financial Service Centre would be
contacted for information relating to the lottery, cheques etc. When the branch
was run by a SPM the relevant contract manager was only involved in the
disciplinary decision making. I do not recall the triggers or criteria for raising a
fraud case.
I have been asked to consider section 7 of ([POL00085977]) regarding the
differences between the audit process between Northern Ireland and England
and Wales. I do not recall any specific differences between Northern Ireland
and England and Wales in the audit process. I had limited involvement in the
Post Office audit processes as I was in the Investigation team.
Page 14 of 46
WITN10400100
WITN10400100
Decisions about prosecution and criminal enforcement proceedings
23.Following an investigation in Northern Ireland a Suspect Offender file would
be prepared and forwarded to Head of Security for any recommendations.
They would review the information available and make any decisions. The
decision would be communicated to the Casework Manager and the file would
then be returned to me. Once the Casework Manager authorised progression
of the file I produced an Evidential Report and handed it to the PSNI. The
PSNI would consider the material and discuss the Report with me, if any
additional material would be required and how to set out and produce a
Prosecution file for progression to the Public Prosecution Service. This
process was put in place by me after I joined the Security Team. Over the
years this process developed and changed. An example of a significant
change was when the PSNI had a reorganisation and Post Office Cases were
processed through Ernie Waterworth, Solicitor, McCartan, Turkington and
Breen as mentioned earlier.
24.I have been asked to consider ([POL00031034]) paragraphs 4.3 and 4.4 and I
do not recall any instances of disagreement arising in relation to investigations
or prosecutions. I am unable to give an opinion if the Post Office maintained a
consistent prosecution policy as I was not involved with prosecution decisions.
In NI the PSNI reviewed the files and sought clarification before the file went
to the PPS and it was the PPS who decided if a prosecution would proceed. I
did not have a role in that decision making and had no involvement in any
England and Wales prosecution cases so I cannot comment on the policy or
consistency of the application of any policy.
Page 15 of 46
WITN10400100
WITN10400100
25.1 cannot recall any circumstances where steps were taken to restrain a
suspect’s assets by criminal enforcement methods such as confiscation
proceedings were considered. I believe that Trained Financial Investigators
would make these decisions. I was not, as far as I recall, ever involved in any
cases of this sort nor do I recall ever being consulted about such steps.
26.I have no recall as to who decided whether criminal enforcement proceedings
should be pursued nor do I recall any incident when that decision was made.
Training, instructions and guidance to investigators within the Security
Team
27.I have been asked what instructions, guidance and /or training were given to
investigators within the Security team particularly in relation to Northern
Ireland, and how was this provided:
e I received training in house before attending a three week training
course in the Post Office Training College in Milton Keynes. All aspects
of interviewing individuals suspected of a criminal offence, taking
witness statements, conducting searches, obtaining, reviewing and
complete disclosure of evidence and report writing was covered. I was
tested to ensure I passed the level of competence required to conduct
PACE 1984 Codes of Practice interviews.
e I also attended subsequent workshops and refresher courses when
there were significant changes to legislation or working arrangements
within the Casework Team.
Page 16 of 46
WITN10400100
WITN10400100
e After training I was then mentored by my line Manager Les Thorpe for
6 months.
28.To assist with Northern Ireland Law I would have taken advice from PSNI or
PPS. There would be circumstances where information would be sought from
third parties who might hold relevant evidence where shortfalls were identified
in branch eg: The Paid Order Unit. In NI the various departments were
relatively small and we maintained close contact.
29.With regard to Fujitsu I cannot recall if data would be requested in all cases of
cash shortfalls as we had been assured by Fujitsu that the Horizon system
was completely reliable. These assurances were given from Senior Managers
at meetings and during Horizon Training. I did not get involved with Fujitsu
until working in the business for a number of years when we were informed
we had to produce an expert witness statement from Fujitsu in investigations.
The decision to get expert reports was not made by me and I cannot recall
who first advised me that I should get a report. I recall there were protocols to
follow should you require their assistance and Horizon data would not always
be requested if admissions had been made. I found the Fujitsu evidence
statements hard to follow as they often had a lot of technical detail in them.
30.A Suspect Offender Report would be included in the case file and sent to
Casework Manager to forward to the Head of Security for a decision to be
made with regard to recommendations. I also worked at Crown Office
Counters using the Horizon system during the Christmas periods when non
counter staff would go in to local offices to provide support.
Page 17 of 46
WITN10400100
WITN10400100
31.1 have been asked to consider ([POL00121467]), ([POL00121485)),
([POL00129311}), ([POL00158977] and [POL00158978)). I do not recall these
forms.
32.1 have also viewed the following documents: Casework Management
document ([POL00104747]) (version 1.0, March 2000) and ([POL00104777])
(version 4.0, October 2002). David Posnett’s email dated 23 May 2011
([POL00118096]) and ([POL00118108]), ([POL00118109]), ([POL00118101}),
([POL00118102]), ([POL00118103]), ([POL00118104]), ([POL00118105)),
((POL00118106]) and ([POL00118107)).
33.1 cannot recall if I was provided with either the 2000 or 2002 version of the
Casework Management document when I was an investigator within the Post
Office Security Team. With regard to instructions given on page 2 of the 2000
version and on page 2 of the 2002 version. I do not recall the documents.
From recall there was no prosecution process in place in Northern Ireland
until after 2000. Compliance checks were carried out by the Casework
Manager against a scoring sheet of 100. The scoring mark was discussed
with my Team Leader at monthly meetings. I recall this was to ensure
consistency and a high standard of all investigations and my understanding of
the compliance documents attached to the email from Dave Posnett dated 23
May 2011 was to help preparing case papers. I do not recall having any role
in relation to their development or management. My understanding of the
document entitled “Guide to the Preparation and Layout of Investigation Red
Page 18 of 46
WITN10400100
WITN10400100
Label Case File" was to advise of any identified failures in security as shown
as the second from last point on document ([POL0011802)) after copy reports
and tape summary. This could be where passwords for the Horizon system
had been shared, high levels of cash held in the counter tills, sharing of dates
stamps, safe door left open/unlocked etc. I do not know who drafted the
document entitled “Identification Codes,” but I do recall seeing it. I do not
recall anyone ever raising the question if the document should be amended or
suggesting it was inappropriate. My understanding of assigning identification
codes to suspected offenders was the information was required to complete
documents for Non Policing Authorities for entry onto the PNC (Police
National Computer).
Analysing Horizon data, requesting ARQ data from Fujitsu and
relationship with Fujitsu
34.When I held the position of Investigator/Fraud Manager within the Security
Team and any SPM/SPMs manager(s) or assistant(s)/ Crown Office
employee(s) attributed any discrepancy to the Horizon system, I would have
asked them to give details of the problems and if the matter had been
reported to the Helpdesk or their Area Manager. The matter would be raised
with my line manager and Casework Manager and a decision would be made
to request Horizon data to be reviewed for the period in question. From my
recall Horizon transactions could be viewed on Credence but only a few
months. An ARQ needed to be authorised if you needed to view further back
than this. During my work as a Post Office Investigator I was unaware of any
issues relating to the Horizon system that could cause balancing
Page 19 of 46
WITN10400100
WITN10400100
discrepancies. During my initial training and at various meetings I was always
informed that the Horizon system was reliable. I do recall some times when
SPMs would cite Horizon as the issue but cannot recall the offices or the
issues. I do not recall any of these being prosecuted with me as the
Investigating officer. I would have relied on IT personnel or Fujitsu to confirm
or deny any of these matters if they did arise.
35.1 cannot recall for definite if an ARQ data was requested every time a SPM
was attributing a shortfall to problems with Horizon. Horizon transactions
could be viewed on Credence. If a case was going to progress for prosecution
an ARQ was requested. There was only a certain number allowed to be
requested each month from Fujitsu and you might have to wait until the
following month.
36.1 do not recall if the ARQ data was provided to the SPM as a matter of course.
This would be a decision made by the PPS.
37.1 do not recall [FUJ00124306] but if I required information or a witness
statement the Casework Manager had to authorize this. I recognise Andy
Dunks and Penny Thomas as contacts in Fujitsu and there was also an expert
witness from Fujitsu who provided a detailed witness statement when
prosecution cases were progressing through the court in Northern Ireland. I
do not recall their name.
Relationship with others
Page 20 of 46
WITN10400100
WITN10400100
38.A few years before I left the Post Office the system for progressing Suspect
Offender files changed and I presented my Evidential files/Prosecution Files
to Ernie Waterworth, Solicitor in McCartan, Turkington and Breen instead of
the PSNI. I cannot recall the reason why but may have been due to a re-
organisation within the PSNI. I also do not remember if the cases were based
on Horizon data showing apparent shortfalls.
Prosecution in Devolved Nations
39.When I joined the Post Office Security Team there was no _ internal
prosecution process in place as Northern Ireland has its own courts and
system. As I had worked in Royal Mail Security previously and cases were
handed to the police, a similar process was put in place for Post Office
Investigations. I worked with Post Office Security Team, Post Office Legal
Team, PSNI, and the Public Prosecution office to develop and agree a
Memorandum of Understanding on how to progress Suspect Offender files
through the courts.
40.1 did not have any experience of the Northern Ireland legal system when I
became involved in this work.
41.I have been asked to describe the process by which cases were investigated
and prosecuted in Northern Ireland. In particular, to describe how the process
in Northern Ireland differed from England and Wales and any ways in which
the process in Northern Ireland changed during the time I was involved.
Investigation Cases were conducted in the same ways as the rest of the
Page 21 of 46
42.
43.
WITN10400100
WITN10400100
United Kingdom except as mentioned in paragraph 37. The Head of Security
made the decision for progressing an Evidential Report to the PSNI.
Meetings would take place with the PSNI to discuss the case and if further
evidence or statements were needed. A Prosecution file was processed and
handed to Public Prosecution Office. I, and sometimes my line manager or
another investigation manager, met with the Public Prosecution Office to
discuss any queries. I do not recall if any of these cases were based on
Horizon data showing shortfalls.
I have been asked to explain what instructions were complied with in
preparing a prosecution file to support criminal proceedings in Northern
Ireland. Several meetings took place during the course of a prosecution with
Police and Public Prosecution Service. The instructions regarding preparing a
Suspect Offender File were complied with in the same way as in England and
Wales. At this stage the Memorandum of Understanding agreed by the PSNI
and PPS was followed. An Evidential Report would initially be sent to the
police for consideration. The Police would examine the report and advise on
the case if any additional material was required. Once the Police agreed
sufficient evidence had been provided a Prosecution file was prepared and
handed to the PPS. I would have meetings with officers and the Director of
Public Prosecutions and the legal team assigned to the case.
I have been asked to provide details of the individuals I worked with on cases
in Northern Ireland. Northern Ireland Post Office Investigation Team: Keith
Gilchrist and Simon Hutchinson. Northern Ireland Physical Security Manager:
Page 22 of 46
WITN10400100
WITN10400100
Roy Wallace. Line Managers: Les Thorpe, Jude Trotter, Paul Dawkins, Dave
Pardoe, Ged Harbinson, Diane Matthews and Helen Dickinson. The
Casework Team: Graham Ward, Dave Posnett, Helen Rose. Royal Mail
Security Team: William Boyd and Paul McCloskey. Post Office Investigators:
Steve Bradshaw, Paul Whittaker, Chris Knight and Jon Longman, The Audit
Team: Linda McLaughlin, Peter Todd, Terry Smithson, Ina Crawford, Sean
McCaughey, Rosemary Curran and John McKenny. Contracts Managers:
Denise Reid, Kenny Sharp and Brian Trotter. Retail Managers: Carol Heaps,
Aiden McNeill, Gary Groogan, and Vivienne O’Hare. Cash Centre: Stephen
McAlveen Cash Centre Manager PSNI: George Clydesdale and other officers.
Public Prosecution Service: Stephen Herron (DPP) and other solicitors.
Barrister: Charlie McKay QC and other barristers.
44.The major difficulty I encountered was when I joined Post Office Security
there was no prosecution process in place as Northern Ireland has its own
systems.
Involvement in criminal prosecution case studies being examined by the
Inquiry
Prosecution of Alan McLaughlin
45.1 do not have any direct recollection of this case and therefore I can only rely
on what is contained in the documents provided to me with the Request.
46. In providing my account I have considered the following documents:
i) The audit report p176 to p188 [AMCL0000031];
Page 23 of 46
WITN10400100
WITN10400100
ii) The interview transcript (dated 26 July 2001) (commencing at
13:04) pages 94 to 125 [AMCL0000014];
ili) The interview transcript (undated but presumably dated 26 July
2001) (commencing at 13:51) p126 to 143 [AMCL0000014];
iv) The interview transcript (undated but presumably dated 26 July
2001) (commencing at 14:37) p144 to 171 [AMCL0000014];
v) The interview transcript dated 26 July 2001 (commencing at 15:21)
p172 to 199 [AMCL0000014);
vi) The interview transcript dated 26 July 2001 (commencing at 16:07)
p200 to 207 [AMCL0000014];
vii) The incident log [POL00113386];
viii) The email from Graham Ward to Suzanne Winter, dated 22
September 2004 p156 [AMCL0000031];
ix) The statement of complaint p257 to 260 [AMCL0000031];
x) The letter from John J Rice & Co Solicitors dated 19 April 2004
enclosing the defence statement [AMCL0000035];
xi) The indictment dated 26 April 2004 [AMCL0000034];
xii) The list of witness statements (which appear to have been filed at
the same time as the statement of complaint) p262 to 293 and p312
to 326 [AMCL0000031];
xiii) The list of exhibits p.367 to 373 [AMCL0000031];
xiv) The letter from Richard Gardiner of McClure Watters, Chartered
Accountants, to John J Rice & Co Solicitors enclosing his draft
report (dated 22 December 2004) p33 to 65 [AMCL0000031];
xv) The case result form [AMCL0000033);
Page 24 of 46
WITN10400100
WITN10400100
xvi) The certificate of conviction dated 4 November 2021
[AMCL0000036];
xvii) The Court of Appeal judgment in R v McLaughlin [AMCL0000037];
xviii) Mr McLaughlin's prepared for the application to the Court of Appeal
in Northern Ireland [AMCL0000040].
47.My recollection of the case was when Casework advised me of overclaims
identified in the pouches of paid foils received in the Paid Order Unit Lisahally
from Brookfield Post Office. The overclaims resulted from values being
claimed in add listings for which no pension or allowance foil existed. This
was a paper based system relying on production of "vouchers" to align with
the sums paid out.
48. My role was to investigate all lines of enquiry and gather evidence to identify if
a crime or suspected crime had been committed.
49.Once aware of these discrepancies I received authority to arrange with the
Paid Order Unit (POU) Lisahally to set aside the pouches dispatched from
Brookfield Post Office and I would collect. I examined these pouches and
recorded all discrepancies on a schedule. After a number of weeks as the
overclaims were continuing and counter balances were not indicating
overages I arranged a special audit of the accounts.
50.A number of weeks' worth of pouches and balances were checked and other
enquiries conducted. From my recall these would include the history of the
Page 25 of 46
WITN10400100
WITN10400100
office, Human Resources Print Out, Training of Sub Postmaster, Audit
concerns, Cash Management Records and a preliminary report would have
been sent to my Team Leader and Casework Manager. They would review
the case and authorise me to arrange to have a Special Audit conducted.
During the interview with Mr McLaughlin he mentioned having difficulty in
processing certain documents which I understood were the inputting errors.
He also stated he had had counter losses and staff dishonesty but as I had
always been assured there wasn’t any problem with the Horizon system with
regard to cash discrepancies I did not consider the counter losses to be
attributed to the Horizon system. I do not recall Mr McLaughlin suggesting
any direct issue with Horizon that would cause cash discrepancies or
suggesting there was some error which could be attributed to Horizon.
51.1 interviewed Mr McLaughlin, under caution with the assistance of Les Thorpe,
my line manager.
52.The Public Prosecution Service made the charging decision in this case. I do
not recall any specific discussion with them on the decision or leading to the
decision.
53.The Director of Public Prosecutions authorised the prosecution of Mr
McLaughlin.
54.From recall and viewing the Audit Report dated 3" September 2004 [refer to
AMCL0000031] Page 192 Mr McLaughlin had not raised any concerns
Page 26 of 46
WITN10400100
WITN10400100
regarding the Horizon system creating losses when audited in May 2001.
During interview on 26th July 2001 he did raise concerns regarding losses
and staff dishonesty but not Horizon. I do not believe Horizon data was
available at this time to view or that he was raising Horizon as an explanation
for the losses.
55.1 was the Disclosure Officer in this case but all disclosure decisions were
made by the PPS and my job was to maintain the record of documents and
disclosure in the Post Office.
56.My understanding of this role was to disclose any relevant material involved
during the investigation regardless of if it undermines the prosecution case.
Again this was overseen by the PPS and the PSNI.
57.Cases in Northern Ireland would have been discussed with the Public
Prosecution Service, their solicitors and barristers. I do recall speaking with
Juliet McFarlane at certain times and other solicitors in Post Office Legal
Services but it may not have been about this particular case.
58.My reflections of this case are that I had no reason to believe the Horizon
system was unreliable and caused balancing discrepancies as Fujitsu had
always stated it was completely reliable. I had no concerns with regard to its
integrity. The main issue was in overclaims for cash against paper vouchers
for Pension payments and so the Horizon element was not a main concern
from memory. In light of the information now available I think I would have
Page 27 of 46
WITN10400100
WITN10400100
asked for further checks but cannot speculate as to whether there would be
any different view on the prosecution decision within PPS as the evidence
related to the claims for cash against the vouchers provided and no overages
being generated in any audits and reviews.
Prosecution of Maureen McKelvey
59.1 do not have any direct recollection of this case and therefore I can only rely
on what is contained in the documents provided to me with the Request.
60. In providing my account I have considered the documents below.
i) The call logs pp.19 - 24 [PNI00000001_ 071];
ii) The intervention logs p.6 & pp.15-18 [PNI00000001_ 071];
iii) The audit report, sent to Ms McKelvey, dated 29 August 2001 pp.8-
11 [PNI00000001_ 071);
iv) The letter from Denise Reid, contract manager, to Ms McKelvey
dated 1 November pp.12-13 and response from Ms McKelvey p.14
[PN100000001_ 071];
v) The record of interview dated 4 April 2002, starting at 11:35 pp.50-
66 [PNI00000001_ 062};
vi) The record of interview dated 4 April 2002, starting at 12:22 pp.67-
78 [PNI00000001_ 062};
vii) I The record of interview dated 27 May 2005, starting at 14:45 pp.79-
104 [PN1I00000001_ 062);
Page 28 of 46
WITN10400100
WITN10400100
viii) IThe report of Suzanne Winter pp.3-12 [PNI00000001_ 082];
ix) The letter from DS McAuley to the Legal Registrar confirming there
is sufficient evidence to proceed with the prosecution dated January
2004 p.1 [PNI00000001_082];
x) The statement of complaint p.3 [PNI00000001_ 062);
xi) The letter from the DPP to the Senior Law Clerk dated 22 March
2004 p.3 [PNI00000001_ 039];
xii) I The directions for committal proceedings, dated 22 March 2002
pp.5-8 [PNI00000001_ 039];
xiii) I The letter from the DPP to the Chief Constable dated 29 March
2004 p.4 [PNI00000001_ 039];
xiv) The legal rights form and right to a friend form, signed by Suzanne
Winter and Ms McKelvey, dated 4 April 2002 [PNI00000001_ 043);
xv) The Draft Indictment [PN1I00000001_ 057];
xvi) The Indictment [PNI00000001_ 055];
xvii) The notice of intention to request the court to conduct a preliminary
inquiry, dated 7 April 2004 P.1 [PNI00000001_ 062);
xviii) The prosecution brief for the committal proceedings, dated 20 April
2004 [PNI00000001_058];
xix) The confirmation of compliance with primary disclosure dated 20
April 2004 P.1 [PNI00000001_ 080).
xx) The letter from DPP to John J McNally & Co dated May 2004 688
enclosing the letter [PNI00000001_ 075);
Page 29 of 46
WITN10400100
WITN10400100
xxi) The letter from Kevin Shiels to Detective Constable Coyle dated
May 2004 regarding the disclosure of prosecution material under
section 5 of the CPIA 1996 p.1 [PNI00000001_ 076];
xxii) The letter from Claire Gallagher to John J McNally & Co dated May
2004 confirming receipt of the defence statement p.2
[PNI00000001_ 076);
xxiii) The letter from Claire Gallagher of the PPS to Detective Constable
Coyle dated May 2004 (p.1) [PNI00000001_064];
xxiv) The letter from John J McNally & Co to the DPP dated 10 May 2004
693 and the enclosed defence statement —pp.3-6
[PNI00000001_ 076);
xxv) The letter from the NI Court Service listing the case for arraignment
dated 11 May 2004 p.4 [PNI00000001_064];
xxvi) The letter from Claire Gallagher of the PPS to Detective Constable
Coyle dated 12 May 2004 [PNI00000001_ 063};
xxvii) The letter from DC Coyle to the DI of Omagh Police Station dated
21 May 2004 pp.2-3 [PNI00000001_ 078];
xxviii) The letter from the DPP to JJ McNally & Co, dated 15 June 2004
[PNI00000001_ 037]; - 16 - xxix) The letter from Kevin Shiels to
John J McNally & Co dated 15 June 2004 regarding disclosure
under section 7 CPIA 1996 p.1 [PNI00000001_ 078);
xxix) The note of the discussion between Suzanne Winter and Rosemary
Curran of POL regarding the accounting system on 23 June 2004
pp.7-12 [PNI00000001_072];
Page 30 of 46
WITN10400100
WITN10400100
xxx) The letter from John J McNally & Co to Detective Constable Coyle
dated 22 July 2004 _ seeking secondary disclosure
[PNI00000001_ 073]:
xxxi) The letter from Goldblatt McGuigan, chartered accountants, to
Suzanne Winter dated 23 July 2004 pp.4-6 [PNI00000001_ 072];
xxxii) The letter from Brian Curran of the DPP to John J McNally & Co
dated 27 July 2004 [PNI00000001_ 079];
xxxiii) The letter from Suzanne Winter to Colin Coyle of PSNI dated 30
July 2004 [PNI00000001_ 069];
xxxiv) The letter from Detective Constable Coyle to the Criminal Justice
Unit dated 2 August enclosing a letter from J McNally & Co pp.2-4
[PN100000001_ 071];
xxxv) The letter from Omagh Crown Court Office listing the case for trial,
dated 6 August 2004 p.1 [PNI00000001_ 072];
xxxvi) The letter from Inspector J McCleery to the PPS regarding
disclosure dated 16 August 2004 p.1 [PNI00000001_ 071];
xxxvii) The letter from Claire Gallagher of the PPS to Detective Constable
Coyle dated 23 August 2004 [PNI00000001_ 067];
xxxviii)The letter from Claire Gallagher of the PPS to prosecution counsel,
Mr McKay, dated 23 August 2004 [PNI00000001_ 068];
xxxix) The letter from Paul Dale on behalf of the DPP to John J McNally &
Co dated 23 August 2004 [PNI00000001_ 070];
xl) The letter from Dr M Cavert to John McNally & Co dated 6
September 2004 pp.4-5 [PNI00000001_038);
Page 31 of 46
WITN10400100
WITN10400100
xli) I The letter from John J McNally & Co to the DPP dated 7 September
2004 in relation to Ms McKelvey’s health p.3 [PNI00000001_ 038];
xlii) I The letter from John J McNally & Co to the DPP dated 7 September
2004 enclosing the medical report [PNI00000001_ 065);
xliii) The note from the PPS to Kevin Shiels dated 8 September 2004
(pp.2-5 [PNI00000001_ 038];
xliv) The note dated 10 September 2004 p.1 [PNI00000001_ 038];
xlv) The letter from Charles McKay to the Assistant DPP, dated 6
November 2004 pp.4-5. [PNI00000001_ 036];
xlvi) The note of the trial [PNI00000001_052] & [PNI00000001_053]
61.The casework team in the POU in Lisahally raised concerns with regard to
overclaims in the paid Benefit foils received in their office from Clanabogan
Post Office. The overclaims had been identified when conducting a routine
check. These checks were performed against all offices during the year on a
spot check but reasonably routine basis and if any issue was flagged it would
trigger further investigations. The overclaims were identified by claiming for
foils that were not present in the bundle. For a number of weeks I arranged
with the Manager of the POU to redirect Clanabogans Pouches to me for
further checks to be carried out. These checks identified further overclaims of
foils being claimed but not present. I would have conducted further enquiries
to gather as much information about the office, who worked in the office. How
long the SPM had been in office, any concerns raised either by the SPM or to
the SPM from Gary Groogan, Retail Manager, Denise Reid, Contracts
Manager or the Audit Team. Credence information would be checked on
Page 32 of 46
WITN10400100
WITN10400100
Horizon with regard to the overclaims and call logs for any queries raised. The
claimed missing foils should have created an overage but cash declarations
and balance were not indicating this.
62.To establish what was happening in the office a Special Audit was requested
and authorised from Casework. In April 2002 I attended Clanabogan Post
Office and was accompanied by Les Thorpe, my Team Leader and John
McKenny, Auditor. On arrival at the office I would have identified the SPM,
introduced the team and explained that we would be closing the office to
conduct a Special Audit due to concerns arising. Legal Rights and Post Office
Friend arrangements were explained and they were asked to give their
attention to the audit as it took place. Les Thorpe and I observed the audit and
at the completion the audit result was, from the documents disclosed, a
shortage of £152.80. I can’t recall but I believe Mrs. McKelvey arranged with
Stephen Atherton to conduct the investigation interview at his office in
Omagh.
63. During the interview Maureen McKelvey stated she checked that she entered
the foils on the Horizon system when paying the cash out and then at the end
of the evening she checked them against a computer print out and had not
identified any errors. The system operated with regard to the Camphill
account was that Maureen Mckelvey took the foils from the books and paid
the total due with one cheque. Mrs McKelvey stated the process for receiving
her cash remittance from Belfast had changed and she was unable to request
a special delivery of cash to help cover the office. This meant on occasion she
quite often had no money to pay out to customers and she had to use shop
Page 33 of 46
WITN10400100
WITN10400100
money until her cash remittance was received. Maureen McKelvey was
advised further pouches required to be examined and she and her solicitor
were invited to attend examination of these pouches. In May 2002 further
pouches were examined in the Crown Office in Omagh. Roy Wallace, Post
Office Security assisted and Stephen Atherton and Maureen McKelvey
observed. Further discrepancies were identified.
64.1 formally interviewed Maureen McKelvey in May 2002 and no explanation
was offered as to the discrepancies in the paid pension and allowances. A
Suspect Offender file was prepared and forwarded to the Casework Team.
The Head of Security directed production of an Evidential file for the Police. I
handed the Evidential file to Police and received guidance from them on
completing statements and if any further evidence was required. I cannot
recall any specific directions but this was the standard approach to the file
productions. I produced a Prosecution file and handed the file to officers in
the PPS. Further discussions would have taken place between myself and
PPS. The PPS made the decision to progress the case to court and Mr
Charlie McKay BI was appointed to the case. I would have several meetings
with him and PPS solicitors before the case was presented in court. I believe
there was someone I needed to get a statement from on the day of the court
case but cannot remember who it was.
65.I have considered the following documents
i) The index of witnesses (pp.9-15) [PNI00000001_ 039]
ii) The witness statement of Una Kelly dated 26 September 2002 pp.6-
7. [PNI00000001_062]
Page 34 of 46
WITN10400100
WITN10400100
iii) The witness statement of Michael Scarlett dated 26 September
2002 pp.8-9. [PNI00000001_062]
iv) The witness statement of Bernadette Mellon dated 27 September
pp.10-11. [PNI00000001_062] v) The witness statement of Glenn
McDonald dated 7 October 2002 pp.12 -13. [PNI00000001_062]
v) The witness statement of Susan Hanna dated 26 September 2002
pp.14-15. [PNI00000001_062]
vi) The witness statement of John McKenny dated 25 September 2002
p.16 [PNI00000001_062]
vii) IThe witness statement of Kenneth Sharp dated 7 November 2002
p.17-18 [PNI00000001_062]
viii) The witness statement of Robert George Wallace dated 28 October
2002 pp.19 -20. [PNI00000001_062]
ix) The witness statement of Frederick Leslie Thorpe dated 25 October
2002 pp.21-22. [PNI00000001_ 062]
x) The witness statement of Suzanne Winter dated 14 October 2002
pp.23-25. [PNI00000001_062]
xi) The witness statement of Suzanne Winter dated 15 October 2002
pp.26-28. [PNI00000001_062]
xii) The witness statement of Suzanne Winter dated 17 October 2002
pp.29-30. [PNI00000001_062]
xiii) IThe witness statement of Tony Kennedy dated 23 July 2003 pp.31-
36. [PNI00000001_062]
Page 35 of 46
WITN10400100
WITN10400100
xiv) The witness statement of Una Kelly dated 6 January 2004 p37.
[PN100000001_ 062] xvi) The witness statement of Michael Scarlett
dated 8 January 2004 pp.38-39. [PNI00000001_062]
xvii) The witness statement of Sonia Cassidy dated 5 January 2004 pp.40-
42. [PNI00000001_062]
xviii) The witness statement of Tony Kennedy, dated 23 July 2003 pp2-7.
[PN1I00000001_045]
xix) The witness statement of Michael Scarlett dated 8 January 2004 pp.2-
3. [PNI00000001_050]
xx) The witness statement of Una Kelly dated 6 January 2004 p4.
[PNI00000001_050] xxi) The witness statement of Sonia Cassidy dated 5
January 2004 pp.5-7. [PNI00000001_050]
xxii) The list of exhibits pp.43-48 [PNI00000001_062]
xxiii) The Schedule of Unused Material p.2 [PNI00000001_ 037]
xxiv) The Schedule of Non-sensitive Material [PNI00000001_040]
xxv) The Schedule of Sensitive Material p.8 [PNI00000001_ 044]
66.1 cannot recall if any Horizon data (and in particular ARQ logs) were
requested from Fujitsu in this case. I do recall receiving a witness statement
from Fujitsu at some point but this may have been for another case.
67.As in the earlier named case I was the Disclosure Officer in the case.
68.As disclosure officer when I gave the Evidential File to Police they gave
guidance and advice as how to present the Prosecution File.
Page 36 of 46
WITN10400100
WITN10400100
69.1 met regularly with the PPS, PSNI and spoke with Post Office legal team
during my time as an investigator and my role as a witness was, probably,
discussed when relevant. I do not recall any specific discussion about my role
in regard to any specific case. My own belief was that my role as a witness
was to explain what I had done in a case and what I had discovered.
70.I have been asked on my reflections now on the way the investigation and
prosecution of this case was conducted by the Post Office and the outcome of
the case. Again I think this case relied heavily on the paper vouchers/Foils
and cash requests and deliveries rather than Horizon discrepancies. This is
based on my recollection and review of the various documents. In hindsight
and with what information we now have I believe different additional
investigations could have assisted in addressing the cash issue. However
considering the information we had at the time and the assistance and
decision making of the PPS I do not think there was any major concern with
the investigation.
General
71.1 have been asked to what extent (if any) did I consider a challenge to the
integrity of Horizon in one case to be relevant to other ongoing or future
cases? In light of what we know now and also knowing more about how
computers are not infallible I think there would be more merit in understanding
how one error discovered may impact on other alleged errors. However I am
not sure that an error in one process could impact on a totally different
Page 37 of 46
WITN10400100
WITN10400100
process. The two cases in this statement relied on the old process where
someone brought their pension, child benefit or other benefits book into the
Post Office, the counterfoil was stamped and the voucher ripped out. The
SPM then enters the transaction into the Horizon system and it calculates
what cash was due and SPM paid this to the person. If they were constantly
overpaying against the counterfoils (which could be checked with the
vouchers) then there was an error which needed to be explained. I
understand now that if Horizon recorded a different transaction to the one the
SPM entered then this could cause an error but if there was a consistent
pattern and none of the patterns showed that there was an under payment
and so the cash showed an excess then it causes a concern. The concern
and error did not prove illegal activity but the SPM would need to provide an
explanation.
72.I have been asked whether re there any other matters that I consider are of
relevance to Phase 4 of the Inquiry (Action against Sub-postmasters and
others: policy making, audits and investigations, civil and criminal
proceedings, knowledge of and responsibility for failures in investigation and
disclosure) that I would like to draw to the attention of the Chair.
73.1 think there are some issues with the way the Post Office operated as a
whole which are relevant. In NI the team was small and there was a collegiate
and collaborative approach. When I acted as second Investigator in England
& Wales offices I felt there was a much more hierarchical approach. People
very much stayed in their role and did not seek to expand outside it. In NI I
Page 38 of 46
WITN10400100
WITN10400100
would have been able to speak to people of all levels in different teams and
would have felt free to disagree and debate matters. I feel this was very much
less apparent in the England and Wales offices. I do think that the different
legal and legislative approaches in the jurisdictions was a significant factor. I
always felt secure as there was a review process beyond me to check what I
was providing and to seek additional material if needed.
74.1 do feel very sorry for anyone who has been wrongfully accused and
convicted. I cannot try to understand their pain and upset. I also wanted to say
that this revelation, the Inquiry and the news which has followed has also
been upsetting to me. As stated above I was very proud of being able to come
and work for Royal Mail and the Post Office as we had very close family links
as both my parents worked in these businesses. I was always proud of my
connection and I was proud of the people I worked with. They were all very
dedicated and hard working people and had a pride in their work. The
revelations which suggest those higher up in the business knew about
problems but didn’t share these with the people on the ground has created a
situation where I am no longer able to share with people I meet what I used to
do. The hard work has been tainted. I hope this Inquiry can uncover the
issues and can identify what went wrong, where it went wrong, who knew
about it and why changes were not made sooner.
Statement of Truth
I believe the content of this statement to be true.
Page 39 of 46
WITN10400100
WITN10400100
Signed:
Dated: 2"4 January 2024
Page 40 of 46
Index to First Witness Statement of Suzanne Winter
WITN10400100
WITN10400100
No.
Description
URN
Control Number
Final Draft of the Post Office Conduct
of Criminal Investigation Policy
POL00030902
POL-0027384
Investigation Policy: Casework
Management (England & Wales) v1.0
POL00104747
POL-0080387
Investigation Policy: Casework
Management (England & Wales) v4.0
POL00104777
POL-0080417
Investigation Policy: Rules & Standards
v2.0
POL00104754
POL-0080394
Investigation Policy - Investigation
Procedures v2 January 2001
POL00030687
POL-0027169
"Investigation Policy: Disclosure of
Unused Material, Criminal Procedures
and Investigations Act 1996 Codes of
Practice" v0.1
POL00104762
POL-0080402
Security Managers’ Guide to the
Prosecution Support Office
POL00121455
POL-0127718
Investigation Policy: Arrest procedures
v2.0
POL00104760
POL-0080400
Investigation Policy: Notes of Interview
- Northern Ireland
POL00039952
POL-0036434
10.
Searching - Royal Mail Group Security
Procedures & Standards in relation to
conducting searches
POL00094163
POL-0094286
11.
Codes of Practice 2007 (Police and
Criminal Evidence) Northern Ireland
Office - Order 1989 Article 60, 60A and
65
POL00121591
POL-0127853
12.
S02 Royal Mail Group Criminal
Investigation and Prosecution Policy
December 2007
POL00030578
POL-0027060
13.
"Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy"
POL00104812
POL-0080444
14.
Royal Mail Group Security —
Procedures and Standards: Standards
of behaviour and complaints procedure
No.10-X v2
POL00104806
POL-0080438
15.
Royal Mail Group-An Inspection of the
Royal Mail Group Crime Investigations
Function: July 2008. Inspection Report
POL00121607
POL-0127869
16.
Royal Mail Group Crime and
Investigation Policy v1.1 October 2009
POL00031003
POL-0027485
17.
Post Office Ltd - Security Policy: Fraud
Investigation and Prosecution Policy v2
POL00030580
POL-0027062
18.
Post Office Ltd Financial Investigation
Policy, May 2010
POL00030579
POL-0027061
19.
RMG Procedures & Standards -
POL00026573
POL-0023214
Page 41 of 46
WITN10400100
WITN10400100
Proceeds of Crime Act 2002 &
Financial Investigations doc 9.1 V1
20.
Royal Mail Group Security Procedures
& Standards: Initiating Investigations
doc 2.1
POL00104857
POL-0080489
21.
RMG Ltd Criminal Investigation and
Prosecution Policy v1.1 November
2010
POL00031008
POL-0027490
22.
Post Office's Financial Investigation
Policy
POL00104853
POL-0080485
23.
Post Office Ltd. Anti-Fraud Policy
POL00104855
POL-0080487
Royal Mail Group Policy - Crime and
Investigation (S2) v3 effective from
April 2011, owner Tony March, Group
Security Director
POL00030786
POL-0027268
25.
"Royal Mail Internal Information
Criminal Investigation Team: Casefile
Construction England, Wales and
Northern Ireland" v1
POL00104877
POL-0080509
26.
Appendix 1 to 8.2 Suspect Offender
Reports, Preamble Guide England,
Wales and Northern Ireland v1
POL00104879
POL-0080511
2%.
"Royal Mail Internal Information
Criminal Investigation Team: Guide to
the preparation of suspect offender
reports, England, Wales and Northern
Ireland" v1
POL00104881
POL-0080513
28.
Royal Mail Internal Information: 8.11
Casework Management and PSO
Products and Services v1
POL00104888
POL-0080520
29.
Post Office Prosecution Policy V1
POL00031034
POL-0027516
30.
Post Office Ltd PNC Security Operating
Procedures
POL00105229
POL-0080854
31.
“Post Office Limited: Internal Protocol
for Criminal Investigation and
Enforcement (with flowchart)"
POL00104929
POL-0080561
32.
Undated Appendix 1 - POL Criminal
Investigations and Enforcement
Procedure (flowchart)
POL00105226
POL-0080851
33.
POL - Enforcement and Prosecution
Policy (with comments)
POL00104968
POL-0080600
34.
POL: Criminal Enforcement and
Prosecution Policy
POL00030602
POL-0027084
35.
Conduct of Criminal Investigation Policy
for the Post Office. (Version 0.2)
POL00031005
POL-0027487
36.
Post Office Prosecution Policy England
and Wales (effective from 1/11/13,
review 1/11/14)
POL00030686
POL-0027168
37.
Conduct of Criminal Investigations
POL00027863
POL-0024504
Page 42 of 46
WITN10400100
WITN10400100
Policy v0.3
38.
Condensed Guide for Audit Attendance
v2
POL00104821
POL-0080453
39.
Audit Process Manual - Chapter 3 -
Performing a Branch Audit - v1.2.0
POL00085977
POL-0083035
40.
Email from Ruth Robinson To:
po_security_community Re: Corporate
Security Newsbrief Issue 22
POL00121467
POL-0127730
41.
Email chain from Ruth Robinson To:
Po_security_community Re: Corporate
Security Newsbrief Issue 28
POL00121485
POL-0127748
42.
Email from Dave Posnett to Helen
Dickinson, Andrew Daley, Keith
Gilchrist and others. Re:Cartwright
Training Day in Birmingham change of
start time
POL00129311
POL-0135205
43.
Email - Investigation Circular 4 - 2011:
Police Bail under the Police and
Criminal Evidence Act 1984, Mandatory
Reading for all Royal Mail Group
Security (Investigations)
POL00158977
POL-0147056
44,
Royal Mail Security Investigation
Circular 4-2011: Police Bail under the
Police and Criminal Evidence Act 1984
POL00158978
POL-0147057
45.
Email from Andrew Wise to Michael
Stanway forwarding an email re
Casework Compliance
POL00118096
VIS00012685
46.
Appendix 1 - Case Compliance
checklist
POL00118108
VIS00012697
47.
Appendix 2 - File construction and
Appendixes A, B and C: "Compliance
Guide: Preparation and Layout of
Investigation Red Label Case Files"
POL00118109
VIS00012698
48.
Appendix 3 - Offender reports and
Discipline reports: "Compliance Guide
to the Preparation and Layout of
Investigation Red Label Case Files"
POL00118101
VIS00012690
49.
Appendix 4 - Offender reports layout:
"POL template Offender Report (Legal
Investigation)"
POL00118102
VIS00012691
50.
Appendix 5 - Discipline reports layout:
"POL template Offender Report
(Personnel Investigation)"
POL00118103
VIS00012692
51.
Appendix 6 - Identification codes
POL00118104
VIS00012693
Appendix 7 - Tape Interviews. "POL
Security Operations Team guide:
Summarising of Tape Recorded
Interviews."
POL00118105
VIS00012694
53.
Appendix 8 - Notebooks: Guidance on
POL00118106
VIS00012695
Page 43 of 46
WITN10400100
WITN10400100
using notebooks in investigations.
54.
Appendix 9 - Case Progression Toolkit.
POL00118107
VIS00012696
55.
Emails between Suzanne Winter and
Andy Dunks, Maureen Moor RE FW:
ARQ/1213/184-195 HELPDESK Calls.
FUJ00124306
POINQ0130520F
56.
Criminal Appeal (Northern Ireland).
Criminal Procedure Form 2 - Notice of
Appeal/ Application for Leave of Court
re: Alan McLaughlin/ Brookfield Post
Office (636 pg.)
AMCLO0000031
AMCLO000031
57.
pension and allowance - Tape recorded
interviews - Financial Logs
AMCLO0000014
AMCLO0000014
58.
Incident Log -- Brookfield PO branch
FAD 181704
POL00113386
POL-0110794
59.
MCLAUGHLIN - Ltr from Defence Sols
with Defence Statement attached to
The Crown Court
AMCLO000035
AMCLO0000035
60.
MCLAUGHLIN - Charge & Indictment -
Crown Court Belfast
AMCL0000034
AMCLO0000034
61.
MCLAUGHLIN - Fine and
Compensation Order - Crown Court
AMCLO0000033
AMCLO0000033
62.
MCLAUGHLIN - Certificate of
Conviction - Crown Court Northern
Ireland
AMCL0000036
AMCLO0000036
63.
R v Alan William McLAUGHLIN
(judgment of Court of Appeal Northern
Ireland)
AMCLO0000037
AMCLO0000037
64.
MCLAUGHLIN - unsigned and undated
statement prepared for NI Court of
Appeal application
AMCLO0000040
AMCLO0000040
65.
Letter from J McCleery to PPS Belfast
chambers regarding further
documentation disclosure on R V
Maureen McKelvey
PNI00000001_071
VIS00013112_071
66.
Notice of Intention to Request Court to
Conduct a Preliminary Inquiry. Plus
associated court papers: statement of
complaint, list of witnesses, exhibits,
ROTI
PNI00000001_062
VIS00013112_062
67.
Letter from PSNI re R V - Maureen
McKelvey re alleged theft
PNI00000001_082
VIS00013112_082
68.
Bundle of docs: Registry 258267,
Indictable Directions, Department of the
Director of Public Prosecutions R v
Maureen McKelvey
PNI00000001_ 039
VIS00013112_039
69.
Consigna Form explaining Legal Rights
to Maureen McKelvey ahead of
interview with the prosecutor
PNI00000001_043
VIS00013112_043
70.
Draft Indictment. RE: Maureen
PNI00000001_057
VIS00013112_057
Page 44 of 46
WITN10400100
WITN10400100
McKelvey
71.
Charges, statement of offence and
particulars of offence RE: Maureen
McKelvey. Annotated on arraignment
on 17.05.04
PNI00000001
055
VIS00013112
055
72.
Brief for Committal Proceedings. RE:
Maureen McKelvey
PNI00000001
058
VIS00013112
058
73.
Particulars of service and Schedule of
non sensitive Material R v Maureen
McKelvey
PNI00000001
080
VIS00013112
080
74.
Letter from John J McNally & Co
requesting interview tapes
PNI00000001
075
VIS00013112
075
75.
Letters, incl from K Shiels to PSNI
enclosing copy of Defence Statement,
R - V - Maureen McKelvey defence
statement
PNI00000001
076
VIS00013112
076
76.
Letters RE: Personal Service on each
Crown Witness in the Omagh Crown
Court - Sitting at Dungannon - 13th
September 2004.
PNI00000001
064
VIS00013112
064
Vs
Letter from C Gallagher to D/Con C
Coyle. RE: R V Maureen McKelvey.
Omagh Crown Court (Sitting at
Dungannon)
PN100000001
063
VIS00013112
063
78.
Bundle of evidence for R. Maureen
McKelvey
PNI00000001
078
VIS00013112
078
79.
Letter re: R v Maureen McKelvey,
Department of the Director of Public
Prosecutions, Schedule of unused
material (Post Office) (Issued stamp
14.10.04)
PNIO00000001
037
VIS00013112
037
80.
Letter Re Case listing for the 13th of
September 2004 - corrs to Prosecution
Counsel from D of Public Prosecutions
R - v - Maureen
PNI00000001
072
VIS00013112
072
81.
Letter from John J McNally & Co to
PSNI requesting secondary Disclosure
PNIO0000001
073
VIS00013112
073
82.
Letter from Brian Curran, Western
Circuit for Director of Public
Prosecutions to John J.Mc Nally & Co
Solicitors. Re: R v Maureen McKelvey
PNI00000001
079
VIS00013112
079
83.
Letter regarding disclosure statement
from S Winter to C Coyle re Maureen
McKelvey
PN1I00000001
069
VIS00013112
069
84.
Letter from G Gallagher on behalf of
DD of Public Prosecutions Re; Expert
report in R V Maureen McKelvey
PNI00000001
067
VIS00013112
067
Page 45 of 46
WITN10400100
WITN10400100
85.
Letter from Claire Gallagher to Charles
McKay - Bar Library Re:
Correspondence in R V Maureen
McKelvey - Disclosure
PNIO00000001
068
VIS00013112_068
86.
Letter from Paul Dale for the director of
Public Prosecutions to John J McNally
& Co Solicitors re; R v Maureen
McKelvey
PN100000001
070
VIS00013112_070
87.
Correspondence R v Maureen
McKelvey
PNI00000001
038
VIS00013112_038
88.
Letter from John J. McNally & Co to
Dept of the Director of Public
Prosecution. RE: Maureen McKelvey
medical report
PN100000001
065
VIS00013112_065
89.
Special fees payable to Counsel Mc
Kelvey re: offence of theft
PNI00000001
036
VIS00013112_036
90.
R -v - Maureen McKelvey Handwritten
attendance note of case before Judge
McFarland
PN100000001
052
VIS00013112_052
91.
R -v - Maureen McKelvey prosecution
case minutes
PNI00000001
053
VIS00013112_053
92.
R v Maureen McKelvey additional
statement, statement of witness Tony
Kennedy (Post Office)
PNI00000001_I
045
VIS00013112_045
93.
R-v-Maureen McKelvey Additional
Statements bundle: Michael Scarlett,
Una Kelly, Sonia Cassidy
PNI00000001
050
VIS00013112_050
94.
DPP NI Office - Disclosure of
Prosecution Material - R v Maureen
McKelvey
PN100000001
040
VIS00013112_040
95.
R v Maureen McKelvey Additional
Statements, SOLS LTR Additional
Police Papers to Kevin Shiels PSNI
(reference number 258267) re: Theft at
Omagh from dates unknown until
4.4.02 R v McKelvey
PNI00000001
044
VIS00013112_044
Page 46 of 46