WITN10610100 The Rt. Hon. Sir Edward Davey MP - Witness Statement

Evidence on official site

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Witness Name: Sir Ed Davey
Statement No.: WITN10610100

Dated: 5 July 2024

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF RT. HON SIR ED DAVEY

I, Sir Ed Davey, will say as follows.
INTRODUCTION

1. I am the leader of the Liberal Democrats and was the Member of Parliament for
Kingston and Surbiton from 1997 to 2015 and 2017 to 2024. At the time of writing,
there are no MPs since the dissolution of Parliament on 30" May 2024, but I am

campaigning for re-election.

2. As relevant to the Inquiry, I was the Parliamentary Under-Secretary of State for
Employment Relations and Postal Affairs in the Department for Business,
Innovation and Skills (“BIS”) from 20" May 2010 to 3 February 2012.

3. 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 10 May 2024 (the
“Request’)’. I have prepared it with the support of the Government Legal
Department and counsel. I have depended on others putting documents before
me to assist with the chronology of events set out below. I have requested that
the Department for Business and Trade (“DBT”) provide a number of other
documents which would have helped me to prepare this statement, such as the
minutes of several meetings (including my meeting with Sir Alan in October 2010)

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and my ministerial diary, but I am informed that DBT does not hold or is unable
to locate these. I have attempted, where possible, to supplement my memory by
teference to publicly available records. However, I have needed to rely much
more than I would have liked on my own recollection of relevant events, which
go back 14 years and arose in the context of an exceptionally busy ministerial
diary.

Since reading about the High Court judgment in Bates & Others v Post Office in
December 2019, watching the ITV drama ‘Mr Bates vs The Post Office’, listening
to the testimonies of so many subpostmasters and hearing the evidence elicited
by the Inquiry, I have been shocked at the harm done to so many subpostmasters
over so many years, and by the scale of the lies told by Post Office Limited
(“POL”) and Fujitsu — to the subpostmasters, to the courts, to ministers of all

parties, including myself, to Parliament, to journalists and to the public.

The Post Office Horizon scandal is the greatest miscarriage of justice of our time,
and I am deeply sorry for the individuals and families who have had their lives
ruined by it. As one of the ministers over the 20 years of this scandal who had
postal affairs as part of my ministerial responsibilities, I am sorry that it took me
five months to meet Sir Alan Bates, the man who has done so much to uncover
all this, and that I did not see through POL’s lies when I and my officials raised

his concerns with them.

I have structured this statement in three sections. In the first section I describe
the relevant background and explain the way in which I worked as Secretary of
State. In section two I provide a broadly chronological account, setting out what
I knew and what I did about Horizon, based on a combination of documentary
records as made available to me and my own recollections and observations. In

section three, I offer some reflections and suggestions.

Having called for the establishment of the Inquiry, I look forward to giving oral
evidence to help it get to the truth of what went so catastrophically wrong and

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develop recommendations to prevent such a terrible miscarriage of justice ever

happening again.

SECTION 1: MINISTERIAL ROLE AND CONTEXT

Background

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I studied Politics, Philosophy and Economics at Jesus College, Oxford between
1985 and 1988. After graduation, I worked for the Liberal Democrats as their
Senior Economics Adviser between 1989 and 1993, during which time I studied
at night school in Birkbeck College, London University for an MSc in Economics.
I studied labour markets and trade quite extensively, which turned out to be
directly relevant to my Employment Affairs and Trade responsibilities during my

time as a BIS minister.

Between 1993 and 1997 I worked for Omega Partners, a management
consultancy which essentially helped businesses understand the economic and
market changes that would impact their future. During my four years with Omega
Partners, I worked on letters and parcels projects for major overseas postal
companies, such as Sweden's Posten. I therefore had some interest in and
knowledge of the postal business prior to entering Parliament, though my

experience was exclusively overseas.

I was first elected to Parliament as the Liberal Democrat MP for Kingston and
Surbiton in May 1997. I was re-elected to represent my constituency in the
subsequent general elections in June 2001, May 2005 and May 2010, and
fulfilled responsibilities on the Liberal Democrat benches and as a constituency
MP. 1 was subsequently re-elected to represent the constituency in the June
2017 election.

After becoming a constituency MP, I campaigned to stop the closure of local post
offices and to improve the services local people received both from Royal Mail
and at their Post Office. Examples include campaigning to allow pensioners to

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retain the option of collecting their pension at their local Post Office, reducing
queueing times and opposing specific branch closures. During such campaigns,
it became even more obvious how important their local post office was to people,
how strongly people felt about them and how much people trusted their local sub-

postmasters.

12. In the early 2000s, the then Labour Government had implemented the “Network
Closure Programme” and my experience of campaigning against the closure of
post offices was shared by many Liberal Democrat MPs and candidates and led
to the party developing detailed policy on how to both save local post offices and
reform Royal Mail. This was given voice in the 2010 Liberal Democrat manifesto

pledge in the following terms:

“Give both Royal Mail and post offices a long-term future, by separating Post
Office Ltd from the Royal Mail and retaining Post Office Ltd in full public
ownership. 49 per cent of Royal Mail will be sold to create funds for
investment. The ownership of the other 51 per cent will be divided between an
employee trust and the government.” (WITN10610101 Liberal Democrats
Party - Manifesto 2010 - fair taxes, fair chance, fair future and fair deal
document).

Ministerial portfolio

13. On 20" May 2010, I was appointed Parliamentary Under-Secretary of State for
Employment Relations and Postal Affairs in BIS under the coalition government.
This was my first ministerial post. I remained in that role until 34 February 2012,
when I was promoted to become Secretary of State for Energy and Climate
Change.

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My ministerial responsibilities were very wide-ranging. They were described in
“The List of Ministerial Responsibilities” published in July 2010 (WITN10610102
, List of Ministerial Responsibilities Cabinet Office July 2010) as:

¢ Postal affairs (Royal Mail and Post Office Limited)

. Employment relations (including ACAS)

. Consumer policy and consumer affairs

. Competition policy

. Corporate governance

. Company law (including Companies House)

. Social enterprise

. Insolvency service (including company investigations)

¢ General oversight of Shareholder Executive and its portfolios

. Coordination of European business

. Export Credits Guarantee

* Department Trade Policy

In fact my portfolio was even larger than this suggests, and my responsibilities
continued to grow during my 20 months in post. For example, I was also
responsible for the Groceries Supply Code of Practice and our proposed
legislation for a Groceries Code Adjudicator; I ended up with responsibility for the
Land Registry and the Met Office, as we considered setting up a “Public Data
Corporation”; and the Prime Minister (David Cameron) asked me to take charge
of Corporate Social Responsibility and to oversee a review of the future of high
streets undertaken by Mary Portas. I was also involved in the department's work
to deliver the Government's deregulation agenda. All these responsibilities led to

me attending a wide range of Cabinet sub-committees.

Indeed, within these roles, I had a long list of Coalition Agreement policies to take
forward, in addition to ministerial responsibility for this wide number of policy
areas and organisations. While the Programme for the Coalition Government
could not and did not cover everything the Government was doing, it helped set

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priorities for ministers, so I have included relevant extracts related to my work in

Annex 1.

Before I detail this ministerial work, it is worth adding that, as for all MPs who are
ministers, I also had my normal work for my constituents, as the local MP for
Kingston and Surbiton, from advice surgeries to correspondence, from visits to

local campaigns.

In addition, as I was a Liberal Democrat minister in a Conservative-led
government, I was required to keep abreast generally of issues handled by other
ministers in the department even though these did not fall within my own
ministerial portfolio.

It is probably obvious, but worth emphasising, that my time as a minister was
immensely busy with many competing priorities. A bureaucratic system was in
place in order to manage my time and ensure that ! was receiving the information,
advice and support from civil servants that I needed. I describe this system,
which centred around the ministerial private office, later in this section.

In order to give a flavour of the various areas for which I was responsible and
which were competing for my attention, I set out in Annex 2 some examples of
the sort of work that fell under my remit in each of my policy areas, aside from
Royal Mail and the Post Office.

My duties in the House also meant I covered a wide range of issues raised by
Members of Parliament in adjournment debates, in Private Members’ Bills etc,
etc. A comprehensive list is attached in Annex 3, but they ranged from Dental
Bleaching and its regulation to Debt Management Plans, from Country of Origin
Marking to Unscrupulous Builders, from the Daylight Saving Bill to the
Canterbury City Council Bill.

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I also represented the UK Government at a variety of international summits and
meetings, especially numerous European Council meetings. A list of my
overseas travel as BIS minister (as published online by the Department at the
time) is set out in Annex 4 — averaging roughly one a month across my time in

the post.

Postal Affairs brief

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The Postal Affairs brief was therefore just one part of a relatively large junior
ministerial portfolio, though it is fair to recognise it was an important part and at
times took up a lot of my time.

My main responsibilities with respect to postal affairs essentially divided into two
— the work on Royal Mail primarily aimed at bringing in private capital, and the
work on the Post Office, primarily aimed at helping prevent further closure

programmes.

These workstreams were to some extent inter-related, as Post Office Limited was
a subsidiary organisation within The Royal Mail Group, and as our policy was to
separate The Post Office from Royal Mail Group ahead of the privatisation, with
inevitable questions about the transition and the nature of relationship between
Royal Mail and the Post Office, after the separation.

Under the law, both Royal Mail Group and the Post Office operated at arm's
length to ministers and we did not get involved in issues related to day-to-day
operations — be they their business plans, their workforce relations, their

commercial strategy or their IT systems such as Horizon.

Instead, my core ministerial responsibility was in relation to Government-related
strategic issues that could affect the viability of both businesses and the service

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to the public — so in the case of Royal Mail that meant its losses, its huge pension
deficit and the existential challenge to a letters business posed by electronic
communications, and in the case of the Post Office the continuing threat to the
viability of its network and branches due to declining footfall, the digitalisation of
Government business and the impact of a wider decline of the bricks and mortar

retail sector.

28. The transparency disclosures published online by BIS suggest that I had a total
of 247 formal ministerial meetings during my time in the Department. It appears
I! met with POL 22 times; Royal Mail 15 times; the Communication Workers Union
(“CWU”) 12 times and the National Federation of Sub-Postmasters (“NFSP”) 9
times (note that some of these overlap where, for example, I had a meeting with
both POL and NFSP). It lists a further 14 meetings to discuss postal affairs,
issues or services, including the meeting with Sir Alan Bates in October 2010.

Royal Mail

29. My work on Royal Mail was extensive, not least because the policy was seen as
one of the Coalition’s more controversial proposals, especially in the light of two
previous failures to inject private capital into the country’s letters and parcels

business, under both Michael Heseltine and Peter Mandelson.

30. This work was also urgent, as I had been asked to have the legislation ready for
the Autumn. Indeed, the Postal Services Bill had its First Reading in Parliament
on 13" October 2010, just 5 months after the general election.

31. I benefited in that intense work from a report by Richard Hooper, and his update,
and because the previous Government had introduced legislation to bring in
private capital back in 2009.

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However, the previous Government's Bill did not reflect the Coalition’s policy fully

and, to my mind, needed significant change. For example:

. The amount of private capital investment envisaged was too little;

. The protections for the universal service were too weak;

« There was no provision for employee share ownership;

« The regulatory regime needed strengthening;

¢ There was no provision for change in the future governance model of Post
Office Limited.

While the legislation primarily dealt with Royal Mail, Part One of the Act dealt with
the Restructuring of the Royal Mail Group, including setting out how the Post
Office would be separated from Royal Mail, how the Post Office would remain in
the public sector, with the new provision we developed, namely an enabling

clause for the option for The Post Office to be mutualised in the future.

My work on this Bill began in earnest directly after the election, with many
meetings with officials and several with stakeholders, such as the CWU and the
NFSP.

The Postal Services Bill had its Second Reading on 27" October 2010, followed
by 20 sittings of its standing committee, from 9"" November 2010 to 9"* December
2010, with its Commons Report Stage and Third Reading on 12" January 2011,
before going to the Lords, where it concluded its passage by summer 2011.

In addition to the work for the Parliamentary passage of the legislation, work with
officials and with stakeholders was intense during this whole period. This was
primarily linked to Royal Mail and the letters and parcels business and covered
everything from how we would deal with the huge deficit in the pension fund of
Royal Mail employees to how we would give Royal Mail employees shares in the
new business and even how we would ensure that the sovereign’s head

remained on stamps after private ownership was introduced.

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37. The Post Office work in relation to this Bill is covered below.

38. In addition to the work on the legislation concerning Royal Mail's future, my other
Royal Mail work was extensive. From obtaining state aid approval for our Royal
Mail pension deficit plan to the transfer of regulatory responsibility from
Postcomm to Ofcom, from the contractual relationship between Royal Mail and
the Post Office after the sale and to how the ambitious employee share
ownership proposals in the Bill would be realised.

39. After the passage of the legislation in the summer of 2011, the focus turned to
the work preparing for the sale of shares in Royal Mail. This was extensive and
was far from completion by the time I left my role in BIS.

Post Office

40. My work on the Post Office had two main elements — first, in relation to making
the Post Office Network more sustainable for the long term, to prevent any future
closure programmes for the national network of post offices; and, second, in
relation to the Postal Services Bill, as the Post Office was separated from Royal
Mail.

41. Our top political commitment on post offices was to avoid another closure
programme — and that drove my work.

42. We had to develop a vision for the Post Office which maintained its vital and
distinct social purpose, but also made it more financially viable. Moreover, in
order for us to win a long-term commitment of Treasury funding for the Post
Office, we had to prove that both the Department and the Post Office had in effect

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a new business model that, over time, would reduce the need for large-scale

subsidy in the future and/or post office closures.

After months of hard work, we made the key Government policy statement on
the Post Office in November 2010, in a document called “Securing the Post Office
Network in the Digital Age” (WITN10610103, Coalition Agreement for stability
and reform between the Conservative and Liberal Democrat Parliamentary
Parties). As the name suggested, avoiding closures was not going to be easy.
Customers using the Post Office had fallen sharply in the previous decade. Its
revenues from Government had been slashed, as Government payments like
pensions were increasingly being paid direct into people’s bank accounts, and
many people were fast taking up online services.

My early work on this policy statement was primarily with BIS officials though I
recall the occasional meeting with the then-Managing Director of the Post Office,
David Smith. Indeed, a key part of that early work was to challenge Post Office
Ltd itself to come up with a strategy to make it more relevant to customers. They
proposed what became known as the Network Transformation Programme
(“NTP”) — a major internal restructuring, which, after piloting eventually went live
in 2012, was due to run into the following Parliament. In fact, in the course of
preparing this statement, I have learnt that the NTP went on until 2018.

At its heart, NTP aimed to convert traditional post offices to either “Post Office
Main” or “Post Office Local” business models — with the underlying economic
analysis for both being a combination of policies to increase demand and
changes to reduce costs. So, for example, Mains would be open for longer hours.
Both Mains and Local would be further integrated into existing retail premises

like newsagents, convenience stores and petrol stations.

As minister, I had to approve this new commercial model, as part of our bid to
Treasury and as what I and the department believed was a credible model. A

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combination of the results of pilots and meetings with stakeholders like the NFSP
helped to reassure me.

The political decisions for me as a minister, separate from agreeing the Post
Office's own proposals, were mainly over:

. Subsidy levels;

. Re-thinking the role of the Post Office;

. Changing the governance of the Post Office.

On subsidy levels, I was fortunate in that the then-Chief Secretary to the
Treasury was a big supporter of post offices who represented a highly rural
Scottish constituency and had long fought closures of post offices. I felt that the
£1.34 billion we secured from the Treasury to support the NTP and our overall
strategy for the Parliament was a big win.

On re-thinking the Post Office’s role, this was obviously done in collaboration
with POL, but it needed significant political and departmental push and initiative.
The 2 main planks of this work were:

“The Front Office of Government” at national and local levels;

Major expansion of the Post Office into accessible financial services.

I saw the Front Office of Government concept as complimentary to the push to
put government services online, with the role of the Post Office to be the face-to-
face option, for people who could not access the internet and for services that
could not be delivered online. However, over my time in BIS, this turned out to
be a difficult sell across government, and appears not to have been delivered to
any great extent.

Different categories of service were developed from “identity verification” e.g., for
driving licences or Home Office documents, to “processing” documents e.g., for

passport services or benefit applications.

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A considerable part of the limited time that I spent on the Post Office through
2011 was trying to push this model with other government departments and local
authorities. I felt that if we developed a suite of central and local Government
contracts for sub-postmasters, it could both increase their income and the

footfall. However, success proved limited compared with the ambition.

Moreover, I also saw the expansion of the Post Office’s role in financial services
as a real option for extra business, and it was also a way of part-delivering on
the Coalition's Programme for Government, which included a pledge to consider
a Post Office Bank. The analysis of that specific proposal was not promising and
there soon turned out to be little political support for it, at higher levels — not least
because we were already establishing the British Business Bank and the Green
Investment Bank. However, with High Street banks responding to the financial
crash by cutting services, and with the clear intent of the main banks to cut back
significantly on their presence on the High Street, there seemed to me a genuine
market opportunity, which could both support the network and help consumers

and small businesses.

Both departmental officials and the management of the Post Office seemed less
keen on this idea, arguing that such a model would not deliver specific income
streams. However, I decided to push ahead — with my main ambition set out in
the November 2010 policy statement as being that “a// UK current accounts will
be accessible through the post office network making post offices the convenient

place for people to access their cash.”

This link with the banking sector did actually take off and resulted in formal
arrangements between the banks and the Post Office, currently in an agreement,
known as ‘Banking Framework 3', where customers of 30 bank and building
society brands can use Post Offices to withdraw and deposit cash in their

accounts. They can also deposit cheques and make balance queries.

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There were a few other aspects to my ministerial work on the financial services
aspect ~ with the main one being my attempt to link up credit unions with the
Post Office network. This would have helped another of my ministerial tasks —
trying to tackle problems with high-cost credit, payday loans and loan sharks.

On changing the governance of the Post Office, the Postal Services Act
implemented our policy of separating POL from the Royal Mail Group, with its
own Board of Directors, including a non-executive director from the Shareholder
Executive (“ShEx") representing BIS.

This change in governance was important in my view. My hope for the Post
Office, especially in relation to the NTP, was that, freed of the lack of attention it
had received in the Royal Mail Group and constituted as a separate standalone

organisation, it would perform better for both the public and subpostmasters.

However, the Act also created new powers to mutualise the Post Office in future.
This was an idea put forward by the NFSP. They wanted subpostmasters to be
free of the control of the state-owned central company. And in my discussions
with them on this and other issues they did not seem to like POL and its

management.

I was attracted to this idea of mutualisation as it held out the prospect of a more
dynamic Post Office, with a better incentive system and a better relationship
between the management and subpostmasters, and it seemed a logical future

development for the new standalone company.

I commissioned a comprehensive report (WITN10610104 The Coalition: our
programme for government by David Cameron and Nick Clegg) from Co-
operatives UK, which was published in May 2011 (WITN10610105 The Co-
Operative UK Mutual Options for Post Office Ltd), and in September 2011 I

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launched a consultation titled ‘Building a Mutual Post Office’. The Government's
response to that consultation was published by my successor, Norman Lamb, in
May 2012 (WITN10610106 BIS Building a mutual Post Office - The
Government's Response). It set out the Government's next steps towards
mutualisation while emphasising the need to achieve “financial stability and
commercial sustainability” first.

It does not appear that progress has been made towards mutualisation since the
2010-15 Parliament, although I note with interest that the idea has come back
onto the agenda recently, with a ministerial meeting to discuss it with union and
co-operative representatives reportedly taking place in February this year
(WITN10610107, The Guardian Article: ‘Constructive’ talks held over transfer of
Post Office ownership to operators).

How government works

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I had not expected to be a minister prior to becoming one in May 2010 and so
had not thought about it or received any training. Moreover, within the Liberal
Democrats there was no history or experience of MPs becoming ministers, so it
felt like being thrown in at the deep end. As a junior Liberal Democrat minister in
the coalition government, I did not have the benefit of any special advisers to

help me either.

I did seek advice early on from a friend of mine who had served as a senior civil
servant, and she stressed the importance of thanking your officials — as ministers
were highly reliant on officials to get their work done (and it being the right thing
to dol).

So from day one — and for many months afterwards, as I “learnt the ropes” — I
was very much guided by the civil servants in my private office in terms of all
aspects of the job. They always seemed highly professional and organised. I like

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to think I was giving clear political direction — not least from the Coalition
Agreement — but as I began gradually to understand both the role of minister and
read myself into the many areas I was responsible for, I was inevitably heavily
reliant on their advice and guidance. I recall the officials from my private office
regularly consulting me on my diary, including future engagements, and trying to
understand how I wanted to work, combining time in the Department, in
Parliament, in the constituency and with my family.

A key part of the work was led by the ministerial red box — which you were given
every evening and weekend to work through by your private office. The private
office operated as the buffer between you as a minister and the rest of the
department and indeed the rest of government. Their job in preparing your nightly
red box was to ensure you had all the information you needed or had requested.
Indeed, a key part of a red box was the diary and briefing folder for the next day
~— containing all the papers the private office felt you needed to prepare you for

your ministerial work the next day.

It was immediately obvious that you had to prioritise because there was just so
much to learn and to do. I found officials very knowledgeable and enjoyed
engaging with them and felt their advice was generally of very high quality and,
given both the complexity of Government and the sheer breadth of my
responsibilities, I was grateful for the way they always seemed to produce
objective and impartial information, backed up by evidence and experience.

Due to the breadth of my responsibilities, I seemed to be engaging with a very
large number of different civil servants, and outside Government agencies. One
issue relevant to this inquiry was how I engaged with BIS officials and ShEx
officials and, from my perspective as a minister, I didn’t really see them as
especially different: they were all part of the civil service machine there to assist

me.

Ministerial correspondence and Parliamentary questions
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As previously touched on, the vast majority of letters and Parliamentary
questions I dealt with as a minister would come to me from my private office in
my ministerial box. Officials in my private office would decide which letters to put
in my box for my attention and reply.

The full contents of my red box always varied — in subjects and in length — but
mine would regularly take at least 2 hours to complete, and sometimes longer,
partly because I was responsible for so many different areas. I would normally
do my red box once I got home, and I would regularly work very late into the night

to complete it.

Essentially a red box would contain submissions from civil servants seeking
decisions on everything from policy options to whether you wanted to have a
meeting, submissions from civil servants to brief you before a meeting,
submissions with drafts of speeches, those parts of the correspondence sent to
you as a minister that they felt you needed to see and to reply to, with draft replies
already prepared, and drafts of parliamentary answers to questions MPs had
tabled. These were usually put towards the bottom of the box and there were
usually a large number of these on any given day. There was invariably a lot of

paper to get through every night.

The private office also managed the correspondence — letters and emails —
addressed to me, and would make decisions about which of it I needed to see

and when.

Generally speaking, where letters were received from an MP or a very important
stakeholder (such as a recognised trade union), any letter in response would go
out in my name and I would sign it — but the draft response would be prepared
for me by the relevant department officials. My nightly red box would generally
contain something like 20 to 25 of these, though this could vary significantly.

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Sometimes you would only be provided with the draft response, and sometimes
you would also be given a copy of the letter which it was responding to — there
was no rule, and officials used to exercise their judgement about what you
needed to see. There was so much paper, it would have been impossible for
Officials to provide everything.

Where the issues raised in correspondence were more difficult and/or required
me to think about them carefully, officials would bring them to my attention
specifically —- and normally face-to-face. As I explain below, the second letter
from Sir Alan Bates is an example where this happened: officials (I think in my
private office) highlighted the letter to me and asked me what I wanted to do.

Unless officials highlighted specific correspondence in this way, I would generally
be content to follow the advice of officials and sign off the draft letters in the red
box without spending too much time on them, unless there was something
particular that struck me when reading them.

Where the letter was not from an MP or key stakeholder, generally officials would
respond. We receive so much correspondence, ministers would have no time to
do anything else if they replied personally to every letter. I am aware of the
evidence of Alan Milburn in Phase 2 of the Inquiry (2nd December 2022, from
page 49 line 3), where he described the sheer volume of work to get through as
a minister:

“You know, it's difficult, I think, for people to understand, who haven't been in
government, just how much stuff there is. You know, you're getting a lot of
stuff coming at you all the time and there's a lot of correspondence, a lot of,
nowadays, emails, and so on and so forth. So there does have to be some
filtering mechanism, you know, because, otherwise, it just -- you're faced with
an avalanche that it's just impossible to deal with... I don't want to, in any way,
give the impression that ministers are victims in all of this because, in the end,
you're in government, you know, you're responsible for what happens in your

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Department, that's the rule of the game, so to speak, even though, very often,
to be perfectly honest, there are things that are happening in your Department
that you have absolutely zero line of sight of, because it's almost impossible
to have any line of sight of it...I mean it's a crazy way of life. I mean, you know,
there's a reference to Alistair and Steve and I on Christmas Eve having a
conflab about whatever it was in relation to Horizon, that wouldn't be unusual.
There's another reference somewhere to meeting at 12.30 in the morning,
trying to cobble together a decision. I mean, these are not unusual things. So
it's a very intense thing to do, it's the most purposeful thing I've ever done in
my life and I don't regret a moment of it. But it is -- it's pretty busy.”

My own experience is very similar. Officials would generally respond to letters
from individual members of the public.

Career after BIS

I continued to serve as Parliamentary Under-Secretary of State for Employment
Relations and Postal Affairs until 3°! February 2012, when I was promoted to
become Secretary of State for Energy and Climate Change. I served in that post,
alongside my role as MP for Kingston and Surbiton, until the May 2015 general
election, at which I lost my seat.

As Secretary of State, I had numerous wide-ranging responsibilities, including:
taking an Energy Bill through Parliament, from its first reading in November 2012
to its final passage in December 2013, which transformed the UK's electricity
industry and dramatically increased investment in renewables; leading the UK
delegation to three UN Climate Change Conferences; launching new
government strategies on Community Energy and Fuel Poverty; and
implementing a range of initiatives to promote energy efficiency and home

insulation.

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80. Between May 2015 and my return to Parliament at the June 2017 general
election, I was not an MP and took on a number of roles, both paid consultancy
and voluntary advisory positions — mostly related to my interest in renewable
energy. My main focus in taking on paid roles, beyond earning a living, was
saving money to support my severely disabled son John, who needs 24-hour
care now and for the rest of his life.

81. In line with the Ministerial Code, I sought advice from the Advisory Committee on
Business Appointments (“ACOBA”) before taking up these roles, and in each

case the Committee advised that there was no reason for me not to do so.

82. In September 2015, I was appointed as Chairman of Mongoose Energy, a
community energy co-operative company, and separately began providing
consultancy services to the law firm Herbert Smith Freehills (“HSF”) in relation to
energy and climate policy.

83. I have since learnt from media reports that HSF acted for POL from 2019 —
several years after I took up my role with them. HSF is a large company with
thousands of clients, and I had no knowledge at the time I worked with them that
it was separately representing POL. I never had any conversations with anyone
at HSF about the Post Office or the Horizon scandal.

84, In January 2016, I took on a part-time role as a consultant for MHP
Communications, advising its clients on communications and government
relations. The following month, I was appointed as a Non-Executive Director at
Nord Engine Capital, an investment firm, to advise and assist them on the use of
their clean technology fund. I also did a number of smaller pieces of consultancy
work for a variety of clients, all in the area of energy and climate change.

85. In April 2016, I became a trustee of Tourism for All, a charity focusing on
accessible tourism, and in July 2016 I became a patron of the Sustainable

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86.

87.

88.

89.

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Futures Foundation, a charity promoting environmental sustainability for the
public benefit. Also in 2016, I became a member of the Advisory Board of ENGIE
UK, a low-carbon energy supply and services company. In February 2017, I was
appointed to the Advisory Board of Next Energy Capital, a specialist investment

and asset management firm in the international solar sector.

All of this work has been on the public record for several years now, because the
advice of ACOBA is published on their website.

I returned to Parliament as MP for Kingston and Surbiton at the 2017 general
election, and was re-elected in December 2019. Immediately following the 2019
general election, I became Acting Leader of the Liberal Democrats, and was
elected Leader in August 2020.

After being re-elected in 2017, I dropped most of my consultancy work, but
continued working for Mongoose Energy, HSF and Next Energy Capital, not least
to be able to continue to fund extra care support for my disabled son. However,
by February 2022, I had ended all such consultancy work, and I have closed my

consultancy firm, Energy Destinations.

During my time as an MP, all of my business and charity roles have been properly
declared on the Register of Members’ Financial Interests, in line with the Code
of Conduct for MPs.

SECTION 2: MY KNOWLEDGE OF HORIZON

90.

In this section, I provide a broadly chronological account of what I was told and
what I did in relation to Horizon.

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91. Itis worth emphasising at the outset that, whilst it is now clear that there were
disastrous problems with Horizon — and with the Post Office’s conduct towards
subpostmasters — which are now rightly the focus of this public inquiry, that was
not at all clear at the time. I was responsible for a large number of important
issues across a very broad portfolio, and with respect to all the issues I dealt with
in Postal Affairs, the Horizon issue was one amongst many — and indeed, I was
continually advised it was a matter for the Post Office, because it was a day-to-
day operational issue.

92. With all issues in such a busy portfolio, you had to be able to rely on the advice
of civil servants, and you were not in a position to dig into the detail of every
question that came across your desk. As I have stated publicly, I believe I was
seriously misled by the Post Office. I do not know if one or more civil servants
misled me during my time as a minister, or if they were themselves misled by
POL. I hope the Inquiry can shed light on this. However, if I had known then what
we all know now - if the Post Office had told the truth — of course I would have
acted differently.

Initial knowledge

93, I was appointed Parliamentary Under-Secretary of State for Employment
Relations and Postal Affairs on 20 May 2010.

94. I cannot recall having an initial briefing on Royal Mail and the Post Office, though
I expect I did, during my first weeks in office. However, I am very confident that I
did not receive any specific briefing on the Horizon system, nor was it something
that it would have occurred to me to ask for specific briefing on. My concern with
POL was primarily at the level of strategic policy, which was a consequence of
the fact POL was an arm's-length body. I did not expect to be involved with
operational matters such as staff, buildings or IT systems. I was not aware of the

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95.

96.

97.

98.

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Horizon system in particular, though of course I would have realised that POL

would have a computer system used in Post Office branches.

As far as I recall, I was unaware of any complaints made by subpostmasters as
to the integrity of the Horizon system before I took office. Nor was I briefed on
this issue on taking up my ministerial role. Nor was I aware that the Post Office /
Royal Mail Group themselves investigated, prosecuted and obtained convictions

against subpostmasters.

Sir Alan Bates

On 20" May 2010 — the day of my appointment — Sir Alan Bates (on behalf of the
Justice For Subpostmasters Alliance, “JFSA”) wrote a letter to me
(UKGI00016119, Letter from Alan Bates on behalf of Justice For Subpostmasters
Alliance). In that letter, he explained the history of Horizon and — in forceful terms
- referred to JFSA’s allegations. He asked for a meeting “where we can present

our case to you’.

I have no memory of receiving or reading this letter, and (consistent with the
usual departmental practice) I think it unlikely that it was provided to me. Reading
it now, the letter is strongly expressed and I would be surprised if I did read it. On
the other hand, I note that the draft response says that “/ do appreciate your
concerns” — which may suggest I was shown the letter. If I was shown a copy, it
was Certainly not flagged up by officials as a letter which I needed to give serious
thought to or which raised important issues in which I should consider digging

into.

I was, however, given a draft response prepared by officials. This would have
been one of many — probably around 20 or 25 — such draft responses that I would
have been asked to sign overnight, as was the case most nights. As a minister it

is necessary to rely heavily on the judgements of the officials advising you,

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including in relation to correspondence — otherwise Government would grind to
a halt.

99. The draft response declined the suggested meeting. The reason given for this
refusal in the letter was that the Horizon system was an operational matter for
POL, which was an arm’s-length body. That accorded with my understanding of
the relationship between the Government and POL at the time: it was not my role
as a minister to intervene in POL’s day-to-day operations. I understood this to be
the case for practical reasons: ministers did not get involved in the day to day
running of the business. That made sense to me. I was not qualified to, and would
not have had time to, get involved in the day-to-day running of POL.

100. Though I do not recall my response, I would have read it at speed and signed it
in reliance on the advice of officials without giving the matter any deep
consideration — there would have been nothing in this draft response which would
have made me think that this was an important issue that officials were getting
wrong and which I needed to grapple with. The signed letter was sent to Sir Alan
on or shortly after 318 May 2010 (ABAT00000001 Letter from Edward Davey MP

to Alan Bates re answer to his request for a meeting).

101. On reflection, and with the benefit of hindsight, I am really sorry that I followed
the advice and did not question it, and I can also see why Sir Alan took offence
at the phrase “/ do not believe a meeting would serve any useful purpose’. It was

poorly judged, and I apologise to Sir Alan for signing it off.

102. I should have accepted Sir Alan’s request for a meeting when he first made it.
However, I remain unconvinced that an earlier meeting would have changed the
course of events. I expect that I would have put the same questions to my officials
and POL, and received the same categorical assurances about the integrity of
Horizon that I did later that year.

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103.

104.

105.

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I received a second letter from Sir Alan dated 8" July 2010 (UKGI00016099,
Letter from Alan Bates to Edward Davey MP, re Justice for Subpostmasters
Alliance) In that letter he criticised my response to his previous letter and stated
“You can listen to your civil servants telling you these issues are really an
operational matter for POL to deal with. You can even listen to POL telling you
Horizon is wonderful, that there has never ever been a problem, it is inherently
robust and these are just a few malcontents trying to cause trouble. Or you can
meet with us and hear the real truth behind Horizon and what the Post Office is
actually up to.” He gave some concrete examples of his allegations against the
Post Office.

I recall being shown that letter by officials (probably in my private office) and
being asked what I wanted to do. Realising that Sir Alan was quite cross with my
initial reply, and reflecting on the seriousness of the concerns he was raising, I
told my officials I wanted to meet him. I do not remember what, if any, advice my
Officials gave me at the time, but I did then meet Sir Alan on 7 October 2010. I
note that Mike Whitehead’s briefing dated 5" October 2010 (UKGI00000062,
Briefing/Update for Edward Davey ahead of meeting with Alan Bates (JFSA))
stated that officials recommended offering a meeting “for presentational
reasons”. As far as I can remember, that briefing — long after the meeting had
been arranged — was the first time that “presentational reasons’ for the meeting
were mentioned to me. They were certainly not the reason I decided to meet Sir
Alan Bates following his second letter. As set out above, I told officials I wanted
to meet him because I could see he was cross at my initial response and wanted

to hear his concerns directly.

My meeting with Sir Alan took place on 7th October 2010 (having been
rescheduled). Shortly ahead of this meeting, I received a written briefing dated
5th October 2010 from Mike Whitehead, a civil servant in ShEx. I have been
shown by the Inquiry an email dated 21st July 2010 from Oliver Griffiths, a civil
servant in ShEx, to David Smith (POL00417098 Email Tracy Abberstein on
behalf of David Y Smith to Mike Granville, Martin Humphreys, Lesley J Sewell cc

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Mike Young re FE Justice for SPMS), stating “We have to date said that this is
an operational matter for POL and resisted calls to impose a review of Horizon
etc. We are in theory happy to continue holding this line - but if we do so and it
turns out that there have been problems with Horizon, then there will be
significant political heat. Grateful therefore if you could let me know how confident
POL is that there is nothing behind these claims.” I did not see this document at
the time and I was not consulted on or aware of its contents. In particular, I had
not been asked whether I was happy to hold the line that any consequences
flowing from faults in Horizon was an operational matter for the Post Office, and
I believe the “We’ in this sentence relates to the civil servants in ShEx. I imagine
the reference to “political heat” was intended to make the point that MPs and also
I and my colleagues in government would be incredibly unhappy if it transpired
that we had not been given the full truth by ShEx and/or the Post Office —- as has
proved to be the case.

106. The briefing set out the following advice:

“Our objectives

Tactically we would advise that you seek to establish at a very early stage
whether legal action against POL is imminent/planned. If so, it would be
prudent to adopt a 'sub judice' approach in the comments you make.

o Emphasise that the issues raised by the JFSA are operational and
contractual matters for POL.

o Make clear that, as the shareholder, Government has an arm's length
relationship with the company and does have any role in its day to day
operations.

o Establish whether, as reported, the JFSA is committed/planning to initiate
legal action against POL.

o If so, note that it will be for the relevant legal process to decide on the
JFSA case and that the issues are effectively sub judice.

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o Demonstrate that you are prepared to hear the JFSA's side of the story
(JFSA claim both POL and officials are covering up the problems with
Horizon) but make clear that it you are not in a position to offer substantive
comment.

o Avoid committing to set up an independent/external review of Horizon.”

107. It went on to state as follows:

“The NFSP are dismissive of the JFSA's claims. They have suggested that if
there were systemic faults with Horizon as claimed, there would be incidents
of ‘averages’ as well as ‘shortages’. NFSP are also of the view that in some of
these types of cases the subpostmaster genuinely is not to blame but that a
member of his/her family or other employee is. Contractually however the
subpostmaster is personally liable. Horizon system and POL process on

accounting irregularities

Integrity of the Horizon system

The Horizon system has been in place for over 10 years. In a typical month
the system conducts around 80 million customer sessions with 230 million
transactions across the system. This is delivered through around 35,000
counter positions in around 12,000 Post Offices which perform weekly and
monthly accounting balances. Around £175m per day is settled to over 700
client companies who use Post Office Ltd - a substantial flow of data to and
from organisations with regularly audited accounts. Over its extensive period
of operation the system has proved robust. The cases identified by JFSA
where there is some kind of allegation in respect of the system are a miniscule
proportion of the many millions of accounting events that subpostmasters
have done within the system. Furthermore around 15% of POL's transactions
have been conducted over Crown Office terminals which run exactly the same

system yet no issues have been identified. If there were any systematic

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integrity issues within the system they would have been evident over the past

10 years.

NFSP and CWU have expressed confidence in the system.

The system is currently being updated to ‘Horizon Online’. This is to achieve
benefits in running costs and change management. It is not being done
because there are any doubts about the robustness of the original Horizon
system.

The integrity of both Horizon and Horizon online is built on tamper proof logs,
real time back ups, and absence of ‘backdoors’ so that aif data entry or
acceptance is at branch level and is tagged against the log-on ID of the user.
This means that ownership of the accounting is at branch level and it is

impossible to make changes to branch accounts remotely.

Critically, Horizon creates a separate audit file of every transaction done with
every record written to the log having a unique incrementing sequence
number. This is retained remotely for seven years and cannot be altered in
any way. Therefore, in any legal case relating to the system or allegations that
data was missing, this audit log can be produced to identify exactly what was
recorded onto the system in the branch concerned at the time concerned.

Subpostmasters are trained on the system, there is material to support in
branch and helplines are available. If an error occurs through a user mistake
- there is a full system in place for investigation and error resolution. If there is
a local disconnection of the system at a branch for any reason, IT controls
detect the outages and raise recover alerts to the branch to check and update

the accounts,

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wi

As with any large organisation, Post Office Ltd has and continues to implement
a range of mechanisms whereby accounting processes and outputs are

regularly reviewed to ensure ongoing accuracy.

Action taken with subpostmasters for accounting irreqularities

Post Office Ltd has a regular system of auditing subpostmasters' accounts. If
irregularities are discovered, then a formal and thorough investigation is
triggered and, if necessary, action can be taken in accordance with the
subpostmaster's contract. Subpostmasters have the right of representation
throughout internal disciplinary procedures - and if the case leads to summary
termination of contract, there is the right of appeal to an appeals manager who
considers the case. Again there is a right to representation through this
process - this role is often undertaken by the NFSP.

In certain cases, following consultation with legal advisers, a decision may be
made by POL to pursue a criminal case. Since 2005 there have been 230
criminal cases that have proceeded to Court. Of these 169 have been found
guilty and 18 defendants cautioned. Of the remaining 43, 1 was found not
guilty but this was nothing to do with any Horizon challenge. 42 cases were
not carried forward for a variety of reasons (but there is no suggestion that any
of these reasons were related to concerns about Horizon).

As there is a legal contract between the subpostmaster and Post Office Ltd, if
a subpostmaster believes that his/her contract has been terminated
inappropriately; he/she can also refer the process into the legal system.

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No court has ever ruled that there have been problems with the Horizon
system.” (UKGI00000062 Briefing/Update for Edward Davey ahead of
meeting with Alan Bates (JFSA))

108. This is the only substantive written briefing I received on Horizon. It indicated that
Horizon had “proved robust’, that there were no “systematic integrity issues”, that
the unions had “expressed confidence in Horizon’, that there was training, there
were proper audit processes and no “backdoors”, there had been regular
reviews, there was an appeals process and legal representation, and no court

had ever found problems with Horizon.

109. I would have taken from this that officials were confident in Horizon and that the
Post Office had had it independently assured. That for the vast bulk of the
network it seemed to be working. And that those who had been prosecuted had
had legal representation, and the legal process would have had a much greater
chance to get to the bottom of any issues than I could conceivably do as a

minister.

110. On 7th October 2010, I met with Sir Alan Bates. I think it is very likely that a note
was taken, but despite my requests I have been informed that DBT do not hold
or cannot locate a copy of any such note. I do recall that Sir Alan set out his
concerns relating to the Horizon system and the treatment of subpostmasters,
and I listened. I do not remember in any detail what was said at the meeting, but
I am likely to have followed the lines to take set out in the briefing note
(UKG100000062, Briefing/Update for Edward Davey ahead of meeting with Alan
Bates (JFSA)), not least because of the warnings about this being sub judice. I
note that Issy Hogg, who was present at the meeting as a solicitor for some of
the subpostmasters, told the BBC in 2011 about me that “he gave us a very
sympathetic ear, listened to us for quite some time”. (WITN10610116 BBC
Surrey Post Office Investigation News Article, produced by Nick Wallis)

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111.

112.

113.

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After the meeting I told my officials to get answers to the points Sir Alan had
raised. I can see from one of the documents provided to me by the Inquiry
(POL00107182) that these included:

. Whether the contract has changed since 1994 to reflect Horizon
e Lack of audit trail for subpostmasters

. POL can access the system remotely and make changes to it

* Frequency of software updates

. Equipment moved from one branch to another

e No regular audit systems

. Subpostmasters having to agree to a loss or can't open the office the next
day

* Processes for suspension and afterwards

I am informed that on 4th November 2010, Mike Whitehead of ShEx met with
POL to follow up on the issues discussed in my meeting with Sir Alan, as I had

instructed.

The Inquiry has shown me an email exchange, with the subject title “JFSA’,
between Mike Whitehead of ShEx and Mike Granville of POL, which took place
on 26th November 2010 (POL00120478 Email thread from Mike Granville to
Mike Whitehead RE: JFSA - audit files and clearance processes). Mr Whitehead
requested urgent answers in relation to the points raised by Sir Alan. I note that
Mike Whitehead stated in his email that “Ed Davey is coming under extreme
pressure to respond on these cases. Can you get something across to me today.”
Mr Granville apparently provided a note relating to some of the cases (which I
have not seen) and indicated that he would provide “some more generic
material’. Mr Whitehead asked “can we quote POL as categorically stating that

there is no remote access to the system or to individual branch Horizon terminals

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which would allow accounting records to be manipulated as JFSA claims?" In
response, Mr Granville stated “The system is based on a user log in, and all
actions have to be endorsed by the user. POL cannot remotely control a
branches system. Any technical changes by Fujitsu that impact the system have
to go through clearance processes which would prevent any amendment to
existing data. The independent audit file is in place and can show all the system
activity, down to a single keystroke, in a particular branch.” (POLO0120478 Email
thread from Mike Granville to Mike Whitehead RE: JFSA - audit files and
clearance processes). For the avoidance of doubt, I did not see these emails at
the time.

114. It appears that, shortly thereafter, POL forwarded a paper entitled “JFSA
response issues” to officials in ShEx (presumably Mike Whitehead)
(POL00089001 Note re: JFSA response issues - paper for BIS). I did not see this
paper at the time, but I note now that it recorded the discussion between Mike
Whitehead and the Post Office, following my meeting with Sir Alan, as follows:

“Follow up points from POL meeting with Mike Whitehead on 4
November (subsequent to the JFSA meeting with Edward Davey).

Points discussed at the meeting

- Whether the contract has changed since 1994 to reflect Horizon - The
Contract has had a series of amendments and associated operational
instructions which mean that it remains a proper legal and commercial
document with respect to the operation of a Post Office. There has been no
legal challenge to the appropriate nature of POL's agency contracts

- Lack of audit trail for subpostmasters - subpostmasters can pull off a
transaction log every day and declare their cash at the end of the day. The
facilities are there for subpostmasters to track their own transactions should
they wish

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- POL can access the system remotely and make changes to it-. The system
is based on a user log in, and all actions have to be endorsed by the user.
POL cannot remotely control a branches system. Any technical changes by
Fujitsu that impact the system have to go through clearance processes
which would prevent any amendment to existing data. The independent
audit file is in place and can show all the system activity in a particular

branch.

- Frequency of software updates - these are normal operational updates such
as those that occur in any system. They do not indicate in any way any
faults or unreliability in the system

- Equipment moved from one branch to another. If any equipment is moved
from one branch to another there is no potential for past transactions in any
way to impact the system. Transactions are not held on or tagged to the
equipment in the branch - they are recorded against the branch code. As
previously advised - every transaction undertaken on the system is
independently recorded and maintained in a separate tamper proof audit
log. There is always therefore the capability to track back transactions
related to the branch independent of the equipment on which it was

undertaken.

- No regular audit systems- our audit systems are based on random choice
and on risk factors. Audits from the central team are not needed for the
subpostmaster to operate the system or to know where they are with their
own account. Subpostmasters can obtain a full transaction log, make daily
cash declarations and can regularly balance their account. They have

access to phone help and personal visit in any cases of difficulty.

- Subpostmasters having to agree to a loss or can't open the office the next
day - this is not the case. If there is a discrepancy in an account when it is

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balanced, the subpostmaster has the option for ‘settle centrally.' — this
means that they can roll the system over whilst the issue is being looked
into. It is a standard process which does not imply acceptance or otherwise
of the discrepancy by the subpostmaster. It is a standard part of the

process.

- Processes for suspension and afterwards - The Post Office processes
cover the situation whereby the subpostmaster is made clear of the
situation, has the opportunity for interview, can be accompanied at that
interview — and there are clear rights of appeal once the decision is made
(the attached document summarises the situation). In cases where the Post
Office Investigation Branch is involved, the procedures followed within their
investigation and interviews are fully compliant with the relevant UK
legislation. The attached note explains further the credentials of Post Office
Investigators (who would always be involved in a case that involved
prosecution).”

115. Among other things, the paper states:

“Next Steps within POL

The Horizon system and accompanying contractual processes remain fully
robust. Their integrity and sound basis have been demonstrated over many
years, and they have underpinned the provision of effective and sustainable
service to Post Office customers. POL refutes the unsubstantiated allegations
made by the JFSA.

POL maintains a legal contractual relationship with subpostmasters which is
based on values of trust and mutual respect. In cases where there are reasons
why this relationship cannot continue, there are full processes of internal
appeals and the parties can have full subsequent recourse to the UK legal
system. As a matter of course, and on an ongoing basis, POL works with the

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National Federation of Subpostmasters (a recognised representative body for
subpostmasters) on the development of contractual and associated process

matters.

Looking forward, as part of its future strategy consistent with the Policy
Statement outlined by Government in November 2010, Post Office Ltd will be
seeking to further review its contracts and accompanying processes to meet
the changing needs of its customers. This approach will continue to ensure
that the contractual basis and associated procedures between Post Office Ltd

and individual subpostmasters remains sound. fair. commercial and equitable.

It is this combination of;

- the current robustness and integrity of Horizon.

- clear internal processes with appeal systems with the ultimate backstop
of the UK legal system (should cases be referred to it),

- ongoing liaison with the NFSP as the recognised group representing
subpostmasters and

- a forward looking approach to the further development of contracts and
associated policies in line with developing strategy and Government policy

that provides assurance to BIS that the approach taken by Post Office Ltd
continues to be fair and equitable.”

116. The assurances that the Horizon system was “fully robust’, that its “integrity and
sound basis have been demonstrated over many years” and that the JFSA’s
allegations were “unsubstantiated” have now been shown to be both untrue and
inconsistent with what POL actually knew at the time. Nevertheless, this was the

spin that POL employees chose to put on the information it provided to the

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Government following my direction that Sir Alan Bates’ questions were

answered.

117. As I have said above, I was not shown this paper at the time. However, I was
provided with a draft letter to Sir Alan, which I signed and sent dated 7"
December 2010. This letter states:

“Following our meeting, the points you raised as Chairman of the Justice for
Subpostmasters Alliance (JFSA) are being followed up on my behalf by
officials as part of our dialogue with the company. However, as I made clear
at the meeting, neither I nor the Department can intervene in cases which are
sub judice or where court action had been determined, as in Mrs Misra’s and

Mrs Buffrey’s cases.

I recognise that the core of the JFSA’s concerns relates to the Horizon system
to which you attribute the financial discrepancies and shortages which have
led to a number of subpostmasters having their contracts terminated and
subsequent court action. However POL continues to express full confidence
in the integrity and robustness of the Horizon system and also categorically
states that there is no remote access to the system or to individual branch
terminals which would allow accounting records to be manipulated in any way.
In addition, I understand that all system activity, down to the individual key
stroke, is also recorded into a separate vaulted transaction file with every
record encrypted and written to the log and with each record having a unique
incrementing sequence number. This log is retained on a separate server
independent of Horizon for at least seven years, cannot be altered in any way
and all access to it is securely controlled. This approach is consistent with that
of banking systems and provides a fully secure audit file which can show all
system activity in a particular branch.

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In your letter of 14 October, you suggest that the wider introduction of the Post
Office local (Essentials) model will wipe out that part of the investment of the
subpostmaster relating to the original post office element of the business. I
can assure you that, although the precise details have still to be finalised, there
will be appropriate financial arrangements in place to reflect either the
relocation of post office services or the transition from the current contract
model to the new one at the same site. I would also emphasise that there will
be no programme of post office closures.” (POL00186759, Letter from Edward
Davey to Alan Bates RE: Response to Letters Dated 14 and 21 October 2010).

418. The draft of this letter was essentially the response from officials to me as a

minister, following my direction that I wanted these questions answered, in the

form of a reply to Sir Alan himself.

419. I cannot recall a detailed discussion with officials about this letter or the detailed

findings set out in POL's response to Mike Whitehead’s questions, but I strongly
expect there was one, although DBT has not been able to provide any minutes
or submissions to that effect.

Members of Parliament

420. As aminister, when Members of Parliament raise matters with you, you inevitably

121.

take them more seriously, and there was a small trickle of correspondence and
parliamentary questions from MPs on this issue. None of these seemed to raise
any issues that fundamentally questioned the advice that I had received from
officials and the Post Office.

Perhaps of even greater note, and having checked the record, I was not asked a

single question on Horizon on the floor of the House or in 20 sittings of the Postal

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Services Bill committee. Nor do I recall receiving any media enquiry about it at
all during my 20 months in post.

122. There were many other questions on the Post Office from MPs, primarily around
the viability of the network and the broader policy changes we were making, but

Horizon was never raised in oral questions or debate at any stage.

123. However, to assist the Inquiry, which has provided examples of the small amount
of correspondence and parliamentary questions I received on this, let me try to
explain how these were dealt with.

124. On correspondence, a draft response to Mary Glindon MP dated “October 2010”,
prepared by officials, is typical (UKGI00014068, Letter from Edward Davey MP
to Mary Glindon MP re: Mr Peter Holmes' problems with Post Office Ltd). I am
confident I would have sent a reply in these terms or similar. It stated:

“Under the postal sector reforms introduced in 2001 by the previous
Government, Royal Mail (which includes Post Office Ltd (POL)) was given
greater commercial freedom, as the management and unions had requested,
and Government has assumed an arm’s length role as a shareholder in a

public limited company ...

The issues raised by Mr Holmes are operational and contractual matters for
POL and the Government does not have any role in the day to day operations
of the post office network. I understand that POL continue to express full
confidence in the integrity and robustness of the Horizon system which has
been operating for 10 years and typically processes 230 million transactions
a month from over 30,000 counter positions in nearly 12,000 post office

branches.

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The integrity of Horizon is built on tamper proof logs, real time back ups, and
absence of ‘backdoors’ so that all data entry or acceptance is at branch level
and is tagged against the log-on ID of the user. I also understand that Horizon
creates a separate audit file of every transaction done with every record
written to the log having a unique incrementing sequence number. This is
retained remotely for seven years and cannot be altered in any way.
Therefore, in any legal case relating to the system or allegations that data was
missing, this audit log can be produced to identify exactly what was recorded
onto the system in the branch concerned at the time concerned. Help lines are
available. If an error occurs through a user mistake — there is a full system in
place for investigation and error resolution. If there is a local disconnection of
the system at a branch for any reason, IT controls detect the outages and raise

recover alerts to the branch to check and update the accounts.

In cases of suspension and termination of contract, subpostmasters are
contractually entitled to be accompanied at appeal hearings by a National
Federation of SubPostmasters’ representative or friend. Appeals are heard by
a senior POL manager not previously involved in the case and legal avenues
are also available if the subpostmaster continues to feel his contract has been
wrongly terminated.

I have however recently met with representatives of the Justice for
Subpostmasters Alliance to listen to their concerns and my officials are

following up with Post Office Ltd some of the points made.”

125. As POL provided additional information to officials, the content of draft responses.
changed. A typical later example is a draft response to Karen Lumley MP dated
“February 2011” (UKGI00013913 Draft Letter from Edward Davey MP to Karen
Lumley MP re: concerns raised by constituents about Post Office Horizon
system).

126. I would not have signed any letter which I did not believe was true.

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127. During my time as a BIS minister, three MPs tabled written Parliamentary
Questions in relation to Horizon. [UKGI00000062; POL00417098;
WITN10610110; WITN10610111; WITN10610112; WITN10610113] Written
Parliamentary Questions are a very regular occurrence — a search of
Parliament's online database suggests that I received 2,144 during my time as a
BIS minister. In the same way as routine correspondence, officials would prepare
a response which would be placed in the red box. Unless officials flagged some
issue which I needed to grapple with, I would read and sign these at speed based

on the advice given by officials.

128. Wherever MPs were dissatisfied by the response to a Parliamentary question,
they could attempt to raise the issue in debate in the House. Having checked the
parliamentary record, Horizon was never raised on the floor of the House during

my time as a BIS minister.

129. When MPs wish to raise issues with ministers, often they do so informally in the
division lobbies. Horizon, and the treatment of subpostmasters, was not an issue
that I recall ever being raised with me in this way. However, the Inquiry has
provided me with a letter from Lord Arbuthnot of Edrom — then an MP — dated
15th December 2011, which mentions that he and I discussed it at some point
before then. I do not now recall anything about it, though I expect it was an

informal conversation.

130. So the basic point is this. The alarm bells had been rung by Sir Alan Bates.
Following our meeting I asked for information in relation to each of the points he
raised, and received clear assurances — based on independent testing of their
system, because the courts had examined the issue, and because the NFSP
seemed to believe there was no issue. Not only had the submission from Mike
Whitehead in dated 5th October said that the NFSP had no concerns, I
specifically raised this at a meeting with the General Secretary George Thomson,

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131.

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as part of a much broader agenda. He quickly dismissed the concerns of the
JFSA. Given that he and his NFSP colleagues had always given me the
impression that they were no friend of POL, and that they were democratically
elected by sub postmasters, that only seemed to confirm both the advice I had
received and the findings of many courts. I didn’t see sufficient evidence to
warrant setting up an investigation.

I would finally like to underline the point that ministers are reliant on people telling
them the truth. If you are lied to directly by your officials, or indirectly by an arm’s-
length body like the Post Office, it seems to me inherently difficult for any minister
with a complex and busy portfolio to have sufficient information to question the
replies they have received in good faith. Nonetheless, I wish I had somehow
managed to see through the misinformation I was given, and I am sorry I didn't.

SECTION 3: REFLECTIONS

132.

133.

134.

After I left BIS in February 2012, I don’t remember hearing anything about the
Horizon system until the High Court judgment in Bates v Post Office in December
2019. Like so many others, I was shocked by the enormous scale of this

miscarriage of justice.

It was clear to me that, following that historic judgment, there needed to be a full,
statutory public inquiry to get to the bottom of this scandal and hold those
responsible to account, and that the victims must have their names cleared and

receive full and fair compensation.

Over the next six months, during which time I was Acting Leader of the Liberal
Democrats, my party issued calls in Parliament for all of these to happen. In June
2020, I signed an Early Day Motion in Parliament urging the Government to
establish a judge-led public inquiry at the earliest opportunity. (WITN10610114

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UK Parliament Motion for Judge-led public inquiry into the Horizon Scandal -

signed by 151 Members)

135. I was very pleased when the Inquiry was eventually established, and delighted
when Parliament finally passed the legislation to quash the wrongful convictions
of subpostmasters in May 2024. However, I believe the Government must go
further and faster to pay full and fair compensation to all victims as quickly as

possible.

136. I am currently working with three separate constituents who are victims of the
Horizon scandal and came to me as their MP for help in overturning their
convictions and securing compensation. Hearing from them and assisting with
their cases has helped me see even more clearly the appalling way POL has
treated subpostmasters, the trauma many have suffered as a result, and the
inadequacies of the current compensation schemes when it comes to ensuring

victims get the redress they deserve.

137. Since the 2019 judgment, and thanks in large part to the evidence elicited by the
Inquiry, I have had the chance to learn more about how this terrible miscarriage
of justice was able to occur, as well as what happened since my time in BIS to
expose it. I have spent a lot of time thinking about the changes that are needed
to prevent a similar scandal from happening in the future.

Duty of candour

138. Without wishing to pre-empt the findings of this Inquiry, I think a big challenge
this scandal highlights is what can be done when senior executives in an
organisation like the Post Office are prepared to lie — not only to victims,
journalists and ministers, but even to Parliament and the courts.

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139.

140.

141.

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Our system of government is essentially built on the assumption that people in
positions of trust — such as the leadership of the Post Office — tell the truth. It is
hard to imagine how it could function without that basic assumption. For example,
ministers are given a huge amount of advice and information from officials every
day. They simply do not have the time or means to interrogate ail of it to check

for themselves whether it is true or false.

I believe that most people in public life are decent and honest. Yet, from the
Hillsborough disaster to the infected blood scandal to the Horizon scandal and
many others, we have seen all too often a tendency to cover up mistakes, to

close ranks to protect institutions, and indeed to lie.

I therefore strongly support the calls from Hillsborough Now, Covid-19 Bereaved
Families for Justice, Inquest and many others for a statutory “duty of candour”
on all public authorities, public servants and officials to act in the public interest
and with transparency, candour and frankness — in other words, always to tell
the truth.

Oversight of arm’s-length bodies

142.

143.

At the same time, it is important to consider ways to strengthen oversight of
arm’s-length bodies such as the Post Office. I believe that splitting POL out from
the Royal Mail Group in 2012 and putting an official from the ShEx (now UKGI)
on its board for the first time were steps in the right direction, but they clearly
failed to ensure proper transparency and oversight.

Perhaps it might be necessary to require Departmental Permanent Secretaries
and/or ministers themselves to sit on the boards of such organisations — though
in the case of ministers, the sheer number of arm’s-length organisations may not
always make this a practical solution, especially when combined with the extent

of ministerial churn. An alternative would be to give Parliamentary Select

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Committees a greater role, with Parliament more generally having greater

powers and resources to scrutinise all arm’s-length bodies.

Ministers and the courts

144. Looking back at the advice I received for my meeting with Sir Alan Bates in
October 2010, I remember that it seemed to me at the time that one of the most
important points officials were making was that this issue had been adjudicated
by the courts. Judges, lawyers and juries had, I was told, dealt with these issues,
and it was not for a minister to overrule them.

145. As a firm believer in the rule of law and the independence of the judiciary, I found
that a very powerful argument. Yet clearly this scandal has demonstrated that
courts can get it very wrong, multiple times.

146. This raises serious questions for the judiciary and the legal profession, How was
it possible for so many lawyers, in so many cases, to get things so badly wrong?
We all rely on the court process to examine all the facts of a case in minute detail,
to expose lies and get to the truth — and to bring in experts when issues are
complex such as how an IT system is functioning. I hope the Inquiry can get to
the bottom of why the normal legal process failed over Horizon and make
recommendations on reform, though I am not legally qualified to speculate on
what they might be.

147. From my perspective, the inter-relationship between ministers and the judiciary
may need some consideration, with the central question being: what could a
minister do if they feel that the courts might be getting something wrong, without
interfering with judicial independence?

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148.

149.

150.

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This might at least empower ministers to feel they could raise a questioning
eyebrow if a similar set of miscarriages of justice were to arise. I am afraid I do
not have an easy answer, recognising that no one wants to create a ministerial

power that could be abused to undermine our courts.

Perhaps some new process could be created for ministers to raise any such
concerns with a senior judge, or some existing process within the Ministry of
Justice could be augmented — though it would obviously be far preferable if the
judiciary and legal profession could review their own practices in the light of the
Inquiry’s findings.

It has also been shocking to read about the failures of POL and its lawyers to
disclose crucial information about the bugs in the Horizon system to defendants
and to the courts. Our legal system relies on lawyers living up to their disclosure
obligations, and though I am not a lawyer it seems clear that there must be strong
sanctions for those who fail to do so — including imprisonment in the most serious

cases,

Prosecutorial powers

151.

152.

POL’s more than 700 wrongful prosecutions of subpostmasters also calls into
question the role of POL and indeed all publicly owned bodies in undertaking

criminal prosecutions themselves.

There may of course be certain public bodies, such as the Serious Fraud Office,
for whom this makes sense. But in general, it seems to me that prosecutions in
the public interest are best left to the Crown Prosecution Service, which is subject

to independent inspections by HM Crown Prosecution Service Inspectorate.

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Whistleblower protections

153. I also reflect on the importance of the Fujitsu whistleblower, Richard Roll, in
exposing the lies about Horizon — first on BBC’s Panorama documentary
“Trouble at the Post Office” in August 2015, and later in the High Court. I note
that Mr Justice Fraser described Mr Roll's evidence as “very important” to the

case.

154. If we are to prevent future scandals like this, we must make it easier for
whistleblowers like Mr Roll to come forward earlier to expose institutional lies and
wrongdoing. For that reason, I strongly support the proposals put forward by
Whistleblowers UK and by my Liberal Democrat colleague Baroness Kramer in
a Private Members’ Bill for a new “Office of the Whistleblower” with new legal

protections for whistleblowers.

Future of the Post Office

155. Finally, there is clearly a lot of work to do to rebuild trust and confidence in the
Post Office - among both subpostmasters and the public as a whole — after it
has been so badly shattered by this scandal.

156.1 believe that the radical idea of mutualisation, which came from the
subpostmasters themselves when I was in BIS, and which we legislated for in

the Postal Services Act 2011, might offer a productive way forward.

157. The work I commissioned on mutualisation and the consultations that were
undertaken over a decade ago all seemed quite promising at the time: giving
subpostmasters, employees and customers greater ownership and control in
how the Post Office was run seemed attractive when I was championing it back
then and I have always been disappointed that it was not taken forward. In the

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light of this shocking miscarriage of justice, it seems this approach might offer a
real way of both empowering subpostmasters and gradually restoring the
reputation of the Post Office.

458. I very much look forward to reading the Inquiry’s recommendations on these and
other issues, and I hope they can help to bring about the changes needed to stop

miscarriages of justice like this from ever happening again.

Statement of Truth

I believe the content of this statement to be true.

Dated:

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ANNEX 1: Coalition Programme for Government extracts

To give a sense of the breadth and quantity of my work at BIS, these are the priorities
set out in the Coalition's Programme for Government that fell in my areas of ministerial

responsibility.

We will seek to ensure an injection of private capital into Royal Mail, including
opportunities for employee ownership. We will retain Post Office Ltd in public
ownership.

We will review employment and workplace laws, for employers and employees, to
ensure they maximise flexibility for both parties while protecting fairness and providing

the competitive environment required for enterprise to thrive.

We will make it easier for people to set up new enterprises by cutting the time it takes
to start a new business. Our ambition is to make the UK one of the fastest countries
in the world to start up a new business. We will reduce the number of forms needed

to register a new business, and move towards a ‘one-click’ registration model.

We will consider the implementation of the Dyson Review to make the UK the leading
hi-tech exporter in Europe, and refocus the research and development tax credit on
hi-tech companies, small firms and start-ups.

We will review the range of factors that can be considered by regulators when
takeovers are proposed.

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We will reinstate an Operating and Financial Review to ensure that directors’ social
and environmental duties have to be covered in company reporting, and investigate
further ways of improving corporate accountability and transparency.

We will ensure that Post Offices are allowed to offer a wide range of services in order
to sustain the network, and we will look at the case for developing new sources of

revenue, such as the creation of a Post Office Bank.

We will give regulators new powers to define and ban excessive interest rates on credit

and store cards; and we will introduce a seven-day cooling-off period for store cards.

We will oblige credit card companies to provide better information to their customers
in a uniform electronic format that will allow consumers to find out whether they are

receiving the best deal.

We will introduce stronger consumer protections, including measures to end unfair

bank and financial transaction charges.

We will take forward measures to enhance customer service in the private and public

sectors.

We will introduce, as a first step, an Ombudsman in the Office of Fair Trading who can
proactively enforce the Grocery Supply Code of Practice and curb abuses of power,

which undermine our farmers and act against the long-term interest of consumers.

We will give Post Office Card account holders the chance to benefit from direct debit

discounts and ensure that social tariffs offer access to the best prices available.

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We will encourage shared parenting from the earliest stages of pregnancy ~ including

the promotion of a system of flexible parental leave.

We will support pro-development trade deals, including the proposed Pan-African Free
Trade Area.

We will ensure that UK Trade and Investment and the Export Credits Guarantee
Department become champions for British companies that develop and export
innovative green technologies around the world, instead of supporting investment in

dirty fossil-fuel energy production.

We will phase out the default retirement age and hold a review to set the date at which
the state pension age starts to rise to 66, although it will not be sooner than 2016 for
men and 2020 for women. We will end the rules requiring compulsory annuitisation at
75.

We will support the creation and expansion of mutuals, co-operatives, charities and
social enterprises, and enable these groups to have much greater involvement in the

running of public services.

We will give public sector workers a new right to form employee-owned co-operatives
and bid to take over the services they deliver. This will empower millions of public
sector workers to become their own boss and help them to deliver better services,

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ANNEX 2: Examples of work in other policy responsibilities at BIS, in addition
to postal affairs

A. Employment Affairs, inter alia:

1. The abolition of the default retirement age

2. The development of proposals for shared parental leave, with initial consultation

3. The introduction of a new right to request flexible working for all employees

4. Consultation on further plans to promote equal pay

5. Regular meetings of the European Ministerial Council for Employment and
Social Affairs

6. Meetings with ACAS

7. Reform of Employment Tribunals and work on “employment dispute resolution”
outside tribunals

8. The Employment Law Review

9. Work to extend employee share ownership

B. Company Law and Corporate Governance, inter alia:
41. Corporate reporting reform — including with the Financial Reporting Council
2. Work to promote Women on Boards, not least the Davies Review

3. Work on a new EU law to require transparency for British and EU firms involved
in the extractive industries, where they operated in developing countries

4, Deregulation of audit for micro-enterprises, at the EU
5. Work on policy areas linked to The Insolvency Service, especially around “pre-
packs”

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C. Competition Policy, inter alia:

1.

Merger of the OFT and the Competition Commission, into the Competition and
Markets Authority

Reform of Competition Law, resulting in the Enterprise and Regulatory Reform
Act 2013

D. Consumer Policy, inter alia:

1.

2.

Citizens Advice

Consumer Focus

Consumer law — existing and reform

Credit regulation — high-cost credit, payday lending, debt advisory services

Credit unions

E. Trade Policy

1.

2.

Leading the White Paper on Trade and Investment

Attending meetings of the EU Ministerial Council on Competitiveness — which
oversaw work around the Single Market

Attending meetings of the EU Ministerial Council on Trade, with significant work
around the EU-Korea FTA

Setting up and leading within the EU Ministers for both these councils the
“Likeminded Group for Growth”, to push a pro-growth agenda at the EU level

Work around the WTO, including attending the Ministerial round in Geneva for
Doha

Export Credit Guarantee Department

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ANNEX 3: House of Commons debates as BIS minister

To give a sense of the breadth and quantity of my parliamentary work as a BIS
minister, this is a list compiled from Hansard of the legislation, debates and oral
questions on which I led or responded for the Government in the House of Commons.

A. Legislation

1. City of Westminster Bill

2. Canterbury City Council Bill

3. Lawful Industrial Action (Minor Errors) Bill
4. Postal Services Bill

5. Daylight Saving Bill

6. Gangmasters Licensing (Extension to Construction Industry) Bill

B. Debates

1. Higher education funding

2. Postal services in Scotland

3. Marine training and employment

4. Post Office network

5. Employment law

6. Unscrupulous lenders

7. Consumer credit and debt management
8. Unscrupulous builders

9. Citizens Advice bureaux

10. I Economic development in the North East

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11.

12.

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

24,

25.

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False self-employment status

Promotion of women in business

Special Representative for International Trade and Investment
Country of origin marking

Workplace drug testing

Dental bleaching

International Labour Organisation convention on domestic workers
Co-operatives and mutuality

Debt management plans

Opportunities for the next generation

Effect of late payments on small and medium-sized enterprises
Consumer Focus Wales

Loft conversions

Debt advice and debt management services

Reform of the pub industry

C. Oral questions

1.

2.

Flexible working

Use of Royal Mail by public bodies

Pubs and the beer tie

Financial viability of the Post Office network

EU free trade agreement with Peru and Columbia
Health and safety regulations

Citizens Advice

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10.

11.

12.

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

30.

31.

Companies Investigation Branch
Groceries Supply Code of Practice
Royal Mail sorting offices
Business regulation

Operating and Financial Review
Future of the Post Office network
Bank lending to social enterprises
Flexible working and shared parental leave
Employment law

Post Office collection charges for small businesses
Daylight saving time

Private investment in Royal Mail
Royal Mail deliveries
Pre-packaged administrations
Fossil fuel subsidies

Post boxes

Small business recruitment
Groceries Code Adjudicator

Big Society

Unfair dismissal

Farepak Christmas savings club
Office of Fair Trading

Payday lending

Transparency in company profits reporting

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32.

33.

34.

35.

36.

37.

38.

39.

40.

41.

42.

43.

44.

45.

46.

Corporate social responsibility

Debt advice agencies

Phoenix companies

Tata plant in Scunthorpe

High-cost credit

EU directives

Outward investment to Azerbaijan

Representation of women on company boards

Payment card surcharges

Public data corporation

Liquidation of Bank of Credit and Commerce International
Employment law in Northern Ireland

Transfer of Undertakings (Protection of Employment) regulations
Royal Mail postcode database

Public.interest declarations

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ANNEX 4: Overseas travel as BIS minister

DBT was unable to provide me with my ministerial diary, but I have been able to put
together this list of my overseas travel from the transparency data published online by
BIS.

30 June 2010

European Business Summit, meeting with Trade Commissioner and Employment

Commissioner

Brussels, Belgium

14 July 2010

Informal Competitiveness Council meeting and informal meeting with CEO of Belgium
Post

Brussels, Belgium

10 September 2010

Trade Foreign Affairs Council. Meeting with Minister of State for Foreign Trade in

France

Brussels, Belgium

5-6 October 2010
Meetings with Ministers and officials

Berlin, Germany

7-8 January 2011

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Visit to discuss priorities ahead of Polish EU Presidency

Warsaw, Poland

13-18 January 2011
Informal EPSCO Council meeting and bilateral meetings

Budapest, Hungary

2 March 2011
Accompanying the DPM at trade talks

Brussels, Belgium

12-13 May 2011

Foreign Affairs Council (Trade) and bilateral meeting with Commissioner for Trade and
Polish Minister for Economic Affairs

Brussels, Belgium

30 May 2011
EU Competitiveness Council

Brussels, Belgium

4 July 2011

To develop relations with Germany and help to drive forward the EU growth agenda

Berlin, Germany

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7-8 July 2041

Employment, Social Policy, Health and Consumer Affairs ERSCO Council

Sopot, Poland

13 July 2011

Joint visit with the Secretary of State for Health to discuss employment issues

Brussels, Belgium

25-26 September 2011
Trade Foreign Affairs Council

Brussels, Belgium

28-29 September 2011
Competitiveness Council

Brussels, Belgium

20-21 October 2011
European Ministers’ meeting on employment relations

Krakow, Poland

13-15 November 2011

European Ministers’ meeting on EU Growth

Stockholm, Sweden

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17 November 2011

Meeting with a UK delegation, the European Commission and Members of the
European Parliament to discuss better regulation

Brussels, Belgium

28 November 2011
Meetings with UK and German ministers on EU growth and employment relations

Berlin, Germany
14-15 December 2011
European Trade Foreign Affairs Council meeting

Geneva, Switzerland

It is not included in the list published by BIS, but I also represented the UK at the World
Trade Organisation's eighth ministerial conference in Geneva, 15-17 December 2011.

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Index to First Witness Statement of Sir Ed Davey

No,

URN

Document Description

Control Number

WITN10610101

Liberal Democrats Party - Manifesto 2010 -
fair taxes, fair chance, fair future and fair
deal document

WITN10610101

WITN10610102

List of Ministerial Responsibilities -
Including Executive Agencies and Non-
Ministerial Departments, prepared by the
Cabinet Office - July 2010 edition

WITN10610102

WITN10610103

Coalition Agreement for stability and reform
between the Conservative and Liberal
Democrat Parliamentary Parties

WITN10610103

WITN10610104

The Coalition: our programme for
government by David Cameron and Nick
Clegg

WITN10610104

WITN10610105

The Co-Operative UK Mutual Options for
Post Office Ltd

WITN10610105

WITN10610106

BIS Building a mutual Post Office - The
Government's Response

WITN10610106

WITN10610107

News Article on Constructive talks held
over transfer of Post Office Ownership to
Operators, by Mark Sweney

WITN10610107

UKGI00016119

Letter from Alan Bates on behalf of Justice
For Subpostmasters Alliance

UKGI026912-001

ABATO0000001

Letter from Edward Davey MP to Alan
Bates re answer to his request from a
meeting.

ABATO0000001

10.

UKGI00016099

Letter from Alan Bates to Edward Davey
MP, re Justice for Subpostmasters Alliance

UKG1026892-001

11.

UKGI00000062

Briefing/Update for Edward Davey ahead of
meeting with Alan Bates (JFSA)

VIS00001023

12.

POL00417098

Email Tracy Abberstein on behalf of David
Y Smith to Mike Granville,Martin
Humphreys, Lesley J Sewell cc Mike
Young re FE Justice for SPMS

POL-BSFF-
0237249

13.

POL00107182

Justice for Subpostmasters Alliance
Response Issues - suspension and
termination numbers, case updates and
follow-up from 04/11/2010 meeting.

POL-0105490

14,

POL00120478

Email thread from Mike Granville to Mike
Whitehead RE: JFSA - audit files and
clearance processes

POL-0126170

15.

POL00089001

Note re: JFSA response issues - paper for
BIS

POL-0080962

16.

POL00186759

Letter from Edward Davey to Alan Bates
RE: Response to Letters Dated 14 and 21
October 2010.

POL-BSFF-
0024822

Page 61 of 62
WITN10610100
WITN10610100

17.

UKGI00014068 I Letter from Edward Davey MP to Mary
Glindon MP re: Mr Peter Holmes' problems

with Post Office Ltd

UKG1024861-001

18.

com

21.

UKGI00013913 I Draft Letter from Edward Davey MP to
Karen Lumley MP re: concerns raised by
constituents about Post Office Horizon

system

UKGI024706-001

WITN10610110 I Parliamentary Question raised by Priti
Patel (Witham) to Edward Davey,

Department for Business, Innovation &
Skills Re: representations received by

JSFA

WITN10610110

WITN10610111

Parliamentary Question raised by Priti
Patel (Witham) to Edward Davey,
Department for Business, Innovation &
Skills Re: cost estimate to SPMs of errors
in Horizon and if he will make a statement

WITN10610111

WITN10610112 I Parliamentary Question raised by Nicholas
Brown (Newcastle Upon Tyne East) to
Edward Davey, Department for Business,
Innovation & Skills Re: recent assessments
of Horizon's performance and whether

errors were reported

WITN10610112

22.

WITN10610113 I Parliamentary Question raised by Michael
Weir (Angus) to Edward Davey,
Department for Business, Innovation &
Skills Re: figures of prosecutions and
investigations of SPMs by Post Office,
complaints, operational faults reported and

Horizon's cost

WITN10610113

23.

WITN10610114 I UK Parliament Motion for Judge-led public
inquiry into the Horizon Scandal - signed by

151 Members

_——I
WITN10610114

24,

WITN10610116 I BBC Surrey Post Office Investigation News

Article, produced by Nick Wallis

WITN10610116

Page 62 of 62