WITN10680100
WITN10680100
Witness Name: Jane Hill
Statement No: 1
Dated: 24.10.24
Ref: WITN10680100
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF JANE HILL
I, Jane Hill, will say as follows:
1. I make this statement following a request for information pursuant to Rule 9 of
the Inquiry Rules 2006, dated 25 September 2024. Before I begin, I would like
to take this opportunity to extend my deepest sympathies to every individual
who suffered due to the faults in the Horizon system and the treatment that they
subsequently received from the Post Office. I hope that my evidence goes some
way to giving these individuals closure and assisting in preventing an event
such as this ever happening again.
2. I can confirm that I have had the legal assistance of Ashfords LLP in drafting
this statement.
42153557.1
WITN10680100
WITN10680100
BACKGROUND
3.
I graduated from Sussex University in 1992 with a degree in Geography. After
graduation I held various jobs before I eventually found my place working as an
assistant to a Member of Parliament (MP), Sir Richard Ottaway in 1996. I
worked for him until 2000 at which point I took a break to study for a Masters in
Interactive Multi-Media at Westminster University. I returned to work in the
House of Commons from 2002 — 2005 after which I joined M&S as a
Government Affairs Officer from 2005 — 2008. I then became Head of Public
Affairs at ITV from 2008 — 2013 before joining Post Office Limited (‘POL’) as
Head of Public Affairs on 9 September 2013.
I originally held the job at POL full time, but dropped down to 4 days a week in
May 2014. I then went on maternity leave from October 2017 — October 2018,
during which time my job title changed to Director of Public Affairs (2018).
Although my job title changed, my role did not. In 2019 I gained a place to
study Organisational Psychology at Birkbeck College (part of the University of
London) but unfortunately due to health issues I was not able to pursue my
studies and I went on long term sick leave from July 2019 before eventually
leaving POL in 2020. I reported to Mark Davies throughout my time at POL.
Although Richard Taylor was technically my line manager when Mark left in
2019, I was not working at this time and so in practical terms, never reported to
him.
My primary role was to manage POL’s relationship with Parliament - to promote
the business as well as protect its reputation. My role also involved building
42153557.1
WITN10680100
WITN10680100
relationships with other stakeholder organisations, such as rural, disability, retail
and other groups who had an interest in POL outside the political sphere.
6. The promotional side of my role included helping raise awareness among
parliamentarians and other stakeholders of POL’s strategy following separation
from Royal Mail as many would get confused between the two or did not know
that POL was now a standalone organisation. POL’s strategy at that time was
to change the way many post office branches operated. This always attracted
local interest and sometimes concern, and my job was to ensure
parliamentarians understood the rationale and context for the changes we were
making. I would seek opportunities to brief MPs either reactively, in response to
concerns raised, or proactively, often around parliamentary business. I would
also organise events in Parliament or at party conferences and use these as
briefing opportunities. The role also entailed supporting senior colleagues’
engagement with political audiences.
7. I led a team of regional public affairs managers, whose primary role was to
communicate changes to Post Office branches to local MPs and councillors and
to manage any concerns that arose. We would ensure that Post Office
colleagues were aware of any serious local concerns to planned changes and,
on occasion, seek to influence these plans where we thought that the full local
impact had not been fully considered by the business.
8. I also helped to put together submissions and briefings for relevant Select
Committee Inquiries.
9. A separate but key role was establishing and managing the development of the
Post Office Advisory Council which I have described in further detail below.
42153557.1
WITN10680100
WITN10680100
10.In terms of my team, I originally started off with a team of 5. After a restructure
this rose to 12 but around spring 2014, this roughly halved following a round of
redundancies and a further restructure. Initially one of my team members,
Sophie Bialaszewski, was responsible for communications planning around
Horizon, alongside her public affairs role, although she reported to the
Communications Director for this part of her role. She left in Summer 2014 after
which the Horizon communications planning aspect of her role was moved to
the press office. I can also recall that initially the regional public affairs
managers reported to another colleague but after a short period they were
moved to my team so that public affairs activity sat in one place.
1
. The Inquiry have asked how, when, and in what circumstances I became aware
of complaints about the Horizon system. I was aware of the complaints at the
interview process because I had researched POL prior to my job interview and
read about the complaints online. I imagine this would have come up in my
interview but I can’t remember exactly. I can recall having conversations about
Horizon with colleagues when I started the role, as part of my getting to know
the business. As referenced above, for my first six months at the Post Office
Sophie Bialaszewski was responsible for communications planning around
Horizon and so most of these conversations would have been with her. I do not
recall having any formal briefing from POL on complaints regarding Horizon.
12. There were communications from MPs about Horizon and the mediation
scheme. However there were tight controls around all communication, internal
and external, on this subject and so if I received such a communication I would
have asked a colleague in the press team for their input, as they held the pen
on everything to do with Horizon. My role never involved directly dealing with
42153557.1
WITN10680100
WITN10680100
SPM complaints. The closest I would have got is an MP writing to me to say that
a SPM in their constituency had complained about Horizon.
13.POL00110047 outlines the Post Office Communications Plan 2015/16. I have
been asked about my involvement in setting the communications strategy for
Horizon. Horizon was one area where I had no direct involvement in setting the
communications strategy. Instead the strategy was set by the Communications
Director and Press Team, with input from Legal, Network and IT. My
involvement was to act as a communication channel for the messaging that had
already been written as my role in relation to Horizon was to help deliver the
strategy, not to create it. So I would become involved after the communications
strategy for Horizon was set, and only if communication with parliamentarians
was required.
14. My working relationship with Mark Davies was generally good although he
sometimes struggled to have the more difficult conversations. However, he was
a compassionate leader with a huge amount of empathy.
15. The Inquiry have asked me to describe my involvement with ShEx and UKGI
during my career. I did not have any day to day involvement with them. Their
primary contacts in the Communications team were the Head of Policy and
Briefing / Director of Government and the Communications Director.
16.From memory, my involvement and interaction with ShEx/UKGI occurred for the
most part when the Post Office was on the Parliamentary agenda, particularly
when the Minister was required to respond - for example when the Minister was
required to speak or answer questions about POL in the Commons. On these
occasions I would let ShEx/UKGI know who we had briefed and share our
42153557.1
WITN10680100
WITN10680100
materials. I can also recall working with a representative of ShEx / UKGI to
assist with their inter-departmental response to a piece of legislation which
sought to cap public sector redundancy pay. My role was to provide information
on how the draft legislation would effect POL if implemented. Effectively I was
the provider of information.
RELATIONSHIP WITH MEMBERS OF PARLIAMENT (MPs)
17.In answering the Inquiry’s questions on this subject matter I have reviewed the
following documents, which I have explained below:
a. POL00200475 is a detailed briefing for an Industry in Parliament Trust
dinner on 12 February 2014 at which Paula Vennells was speaking.
This is a good example of how I would support senior colleagues as
they engaged with parliamentarians. This document is a briefing for
her to read ahead of an event which provides her with information
about the event, attendees and issues that might be raised.
b. POL00101766 is an email sent from me with information for colleagues
ahead of an MP drop-in event on 10 December 2014. I set up events
such as these to help increase MPs’ awareness and engagement with
POL. We would book a room in parliament, select a topical theme and
invite all MPs and some peers to attend. At these events
parliamentarians could talk to POL colleagues about our strategy, ask
questions and raise any concerns they had — usually about changes to
post office branches in their constituency. My aim was to help facilitate
an understanding of POL’s strategy post separation.
42153557.1
WITN10680100
WITN10680100
c. POL00162224 is an email from me to Angela Van-Den Bogerd, in
advance of the MP drop-in event on 10th December 2014, requesting
her attendance and asking for some additional information for a
briefing. Angela had good knowledge about SPMs and how they used
Horizon and so I asked if she was able to attend and answer questions
after seeing that two MPs, James Arbuthnot (now Lord Arbuthnot) and
Andrew Bridgen, said they would be attending as both MPs had been
vocal on Horizon. Unfortunately, in this case she was unable to attend
due to it being a last minute invitation but she provided information for
us to take to the event in case the issue was raised. From memory
neither James Arbuthnot nor Andrew Bridgen attended.
d. POL00158072 is a Post Office weekly Briefing pack dated 27
September 2013. As noted in the document, it was produced by the
Communications team. It is relevant to me in that page 11 of the
document gives a summary of our weekly political activity and events
which we have taken part in and which I would have been involved in
arranging.
e. POL00162071 is an email chain from September 2013, which would
have been in the first few weeks of me starting at POL. A member of
the press team has circulated draft responses to BBC Wales’ questions
about Horizon. It is suggested that the story relates to a SPM in the
constituency of the then Welsh Secretary, David Jones MP. At the
time, Sophie Bialaszewski dealt with the planning on Project Sparrow
and so I think it would have been sent to her for information and she
42153557.1
WITN10680100
WITN10680100
would have forwarded it to me. I am new in the role, and keen to try
and impress my new boss, and offer to try speak to David Jones. I may
have tried calling his office but I cannot recall ever meeting with him.
f. UKGI00004680 is an email from Mel Corfield, who sat in the press
team. She has forwarded me two Freedom of Information responses to
the BBC in respect of prosecutions. I forwarded these to the
Shareholder Executive. From reading the subsequent email
(UKGI00004692), I think that the information was requested for a
briefing. It was common for me to act as a communications channel in
this way, essentially acting as a line of communication to forward on
information as and when needed.
g. UKGI00023280 is an example of where I would be copied into an email
for information but not needed to take any action. Here, Alice Cookson
is making individuals aware of an NFSP press release saying that
“Post Office network has ‘been taken beyond a tipping point’ and its
future viability is now in doubt...” Recipients include a representative
from UKGI and the subsequent trail is a discussion amongst
representatives from BEIS and UKGI on the Government's response.
h. POL00211460 is an email chain about ‘handling Arbuthnot (and
related) correspondence’. Although I do not respond in the email chain,
Patrick Bourke references that he has spoken to me and that I have
said that we should “avoid appeasing or giving the impression of
appeasing JA”. I do not remember this conversation but I imagine that I
42153557.1
WITN10680100
WITN10680100
thought it unwise to simply tell James Arbuthnot what he wanted to
hear or to do so without knowing the full facts.
i. POL00130759 is an email sent from me to lan Murray (MP) enclosing
a short briefing on the mediation scheme and further attachments
which go to the background of the mediation scheme. I believe that
document POL00130760 is the briefing document which I attached but
I cannot say for definite. I cannot remember the context as to why this
was sent.
18.1 led the team which was responsible for communicating with MPs. The vast
majority of these communications were about changes to Post Office branches
and briefing MPs on the business’ progress to becoming commercially
sustainable following its separation from Royal Mail. I had overall responsibility
for planning, drafting and delivering these communications, ensuring they were
in line with broad key messages. As noted above, this was the case with all
communications on subjects ranging from the transformation of the post office
network, access to banking services, to mobile post offices in rural locations.
Horizon was an exception. Due to its sensitivities, the content of any
communication on Horizon was drafted separately by the Press Office with the
oversight of the Communications Director. Once these communications were
drafted, I may be consulted with to help decide to whom the communications
would be sent, although sometimes I would be out of the loop entirely. I may
also try to tighten up the language but the message would not change.
19.My team would keep records of every meeting with MPs. I remember that
initially software called Salesforce was used for this purpose, but this was later
42153557.1
WITN10680100
WITN10680100
changed to a spreadsheet which held notes on every meeting held by a
member of the public affairs team. If I met an MP or another stakeholder I would
generally send an email update to relevant colleagues on the content and
outcome of that meeting.
20.1 have been asked to describe the nature of any communication strategy
employed by POL in relation to Lord Arbuthnot and / or MPs raising concerns
about Horizon and my involvement in formulating this strategy. As noted above,
I did not have any involvement in drafting communication on Horizon or
formulating any communication strategy around Horizon.
2
.I did find the strategy on Horizon to be very robust and defensive. I recall the
strategy was to demonstrate what the mediation scheme was doing and what it
was designed to achieve rather than engage in the suggestion that the SPMs
had been treated unfairly or that there was a flaw in the Horizon system.
Obviously communications had to be consistent — there couldn't be one
message for parliamentarians and one for everyone else.
22. As time went on, I remember feeling more wary about being so robust about
the issue and I regret feeling too uncomfortable to challenge this approach in a
significant way. I remember the first day I came back from maternity leave, I
was given what I think was the draft opening statement from our QC in the
litigation trials to have a look at. I was conscious that I didn’t know anything
about legal process but I remember thinking that the tone was overly aggressive
and editing it to tone it down. I don’t think my input was taken into account.
23.In respect of the communication strategy employed by POL in relation to Early
Day Motions, this was similar to other organisations that attract political interest.
42153557.1
WITN10680100
WITN10680100
We would monitor Early Day Motions and their signatories to gauge political
opinion on a range of issues that either directly or indirectly affected POL and
we would encourage supportive MPs to sign or even table Early Day Motions.
For example, document POL00162657 is an email chain which shows the
Public Affairs Team receiving an alert on a new Early Day Motion concerning
Horizon. Mark Davies picked this up and asked the team to contact the
signatories as it would have created a difficult situation for POL if the EDM
gained traction. Personally, I would have felt uncomfortable about speaking
directly to the signatories but would have probably sent out a briefing note on
POL’s position.
24.As far as I can recall the Post Office Advisory Council (‘POAC’) was established
in response to a Government/Liberal Democrat policy paper about the future of
the Post Office. I cannot remember the details but I think that there was
pressure from the Shareholder, now that POL was independent, for its
governance to evolve. There was talk about the POL becoming mutual and
POAC was part of this mutualisation theme. Ultimately it was about opening up
POL, with the aim being to bring a range of voices closer to the governance of
POL.
25. There were around 25 members, comprising employees, postmasters,
representatives from the unions, National Federation of SPMs (NFSP), retail,
consumer groups, disability organisations and digital. Membership was
voluntary. It was chaired by a Non Executive Director. Paul Vennells was also
a member and I remember that she always attended the meetings which were
held 2 — 3 times a year.
42153557.1
WITN10680100
WITN10680100
26.1 was responsible for establishing the Council and running the secretariat. This
included recruiting members, setting meeting agendas and following up actions.
For example, POL00423968 and POL00423972 show me tweaking agendas. It
was very time consuming as it involved a lot of management of colleagues in
what was not a very culturally open organisation. For example, getting people to
agree to agendas and managing sensitivities about opening up certain areas of
the business, particularly with unions and the Chief Executive around the table.
It was disbanded before I left because it became a talking shop, with no one in
POL taking on any recommendations even though good ideas came up and
Paula Vennells supported it.
27.The Inquiry have asked me to consider POL00295528. However, this is an
email chain from before I started and so I do not feel able to comment upon it.
As to whether complaints were prioritised on the basis of the sender, I would
only generally respond to parliamentarians, or other stakeholder organisations,
and so my audience was relatively narrow. It is standard practice in stakeholder
management to consider an individual’s position. For example, if there was
correspondence from somebody who was deemed, at that time, to be
particularly relevant because of their policy area then their correspondence may
be flagged to me so that I could have greater oversight of our response.
However, everyone would be responded to in a timely manner no matter who
they were.
Second Sight, Project Sparrow and the Mediation Scheme
28.1 do not remember having any role in formulating POL’s communication strategy
in relation to Second Sight’s investigation. Those close to the mediation
42153557.1
WITN10680100
WITN10680100
scheme, including the legal team, would have worked with colleagues in the
press team to formulate the communication strategy, with the communication
director having overall responsibility. I can remember that communication was
tightly controlled due to its sensitivity and need for confidence. I would have
been brought in after the strategy had been decided if there were to be any
communication to MPs.
29.Similar to the response to Second Sight’s investigation, I would have had
minimal involvement in formulating POL’s response to their Part 2 Report.
POL00306722 is an email from Melanie Corfield forwarding me two documents:
Response to Second Sight Part 2 report; and Rebuttals — updated September
2014. I understand that these are the same documents as at POL00002415
(Response to Second Sight Part 2 report) and POL00306723 (Rebuttals —
updated September 2014). POL00002415 is very technical and I would not
have had a hand in writing this. I cannot remember POL00306723 and do not
know who wrote this but it is clear from reading the document now that POL
were maintaining a very robust position against the allegations. I was often
forwarded information to keep me in the loop in case I was asked about it. Often
it was for my general awareness of the operation of POL and no further action
from me would be taken.
30.The media strategy would have been set by the Communications Director and
the Press Office, following the publication of Second Sight’s Part 2 Report. They
would have also had input from the Legal and others close to the mediation
scheme. This might have been discussed with the Communications Director's
direct reports when we all met but I cannot recall anything specifically. My area
42153557.1
WITN10680100
WITN10680100
of expertise was public affairs, and while I had worked closely with PR and
press teams in my career, my views on media strategy were never sought on
this issue. I trusted the professional judgment of those that I worked with.
3
.I recall that Brunswick, a PR Consultancy, was brought in to help manage
POL’s reputational risks but, from memory, my involvement with them was
minimal. POL00384446 shows a member of my team, Sophie Bialaszewski, in
her Horizon Communications Planning role, pulling together information to send
a briefing pack to Brunswick with Mark Davies asking for contribution by myself
and others. I cannot recall whether or not I contributed but I was not close to the
detail in respect of Horizon and SPM prosecutions and so I do not think I would
have had anything substantive to contribute. I do not believe that I was at the
meeting when Brunswick were first briefed. This memory is supported by
POL00207399, an email chain showing me introducing myself to them in
August 2014, 2 months after they were initially instructed.
32.POL00384471 is an email from Sophie Bialaszewski sent in June 2014 and
attaching Brunswick's ‘Horizon: Public Affairs Messaging’ (POL00384472) and
asking for mine and others feedback. I cannot remember this email and there is
no email chain to suggest I responded.
33.POL00101778, POL00101786 and POL00101793 are all email chains relating
to a debate in Parliament on 17 December 2014 about the Post Office
Mediation Scheme. It was part of my job to be aware of debates that were
directly or indirectly relevant to POL, and plan how we could put our position
across. In some instances, if we thought it would be beneficial, I would contact
MPs and ask if they were willing to attend the debate to, for example, ask
42153557.1
WITN10680100
WITN10680100
questions and put forward points which were helpful to POL. If they were
supportive, I might brief them on the issue. In respect of this particular debate,
the email chain shows that I am looking to line up a list of potentially supportive
MPs but I cannot recall whether or not I did approach any MPs. It was not
unusual for me to compile a list of supportive MPs, in case we decided to ask
them to participate, but after weighing up the pros and cons decide not call upon
them. Even if we did ask supportive MPs if they were willing to attend and
speak in a debate, there was no guarantee that they would have done so.
34.POL00149293 is an email chain concerning an article written in ‘Wales Online’
where the Ogmore MP, Mr Iranca-Davies is demanding “that the Government
publish a leaked report which is believed to be highly critical of the Post Office’s
handling of problems with the Horizon computer problem”. The email exchange
shows me suggesting we try to meet him or send him a briefing and Belinda
Crowe asks me for a word before deciding how to proceed. I cannot remember
the outcome of that conversation. If I had written to Mr Iranca-Davies the key
content would have been provided by Belinda’s team and the Press Office.
35.POL00150364 is an email chain which shows my response to an email from
Gerry Sutcliffe MP who has written in about a former SPM who alleged that she
was the victim of mistakes made by Horizon. In my reply I set out some
background and say that, while the mediation scheme is closed to new
applicants, we would be happy to investigation the SPM’s concerns. I can’t
remember whether Mr Sutcliffe followed up. Following my reply, I forward a
copy of the email to Belinda Crowe so that she is aware of the issue and could
take any relevant action to help the SPM if they came forward.
42153557.1
WITN10680100
WITN10680100
36.POL00101478 is an email chain discussing correspondence from James
Arbuthnot who is expressing his concern about how the mediation scheme is
working. It was very common for me to be copied into email chains such as this
so that I was aware of current issues in case any input was needed from a
public affairs position. I cannot recall what, if any, action I took in response. I
never met James Arbuthnot. I only ever remember meeting with one MP (lan
Murray) about Horizon related issues. In that situation, it was merely to make
introductions between the MP and Patrick Bourke as I knew Mr Murray.
37.The above emails demonstrate the nature and extent of my engagement with
MPs in relation to Horizon. My role was very reactive, responding to MP
communications and I often acted as a communication channel between POL
and the MPs, sharing information and messaging that POL wanted to put out.
As mentioned above, any messaging which went out on Horizon or the
mediation scheme was carefully controlled with me effectively acting as a
communications channel but having little input into the actual wording. I was
often copied into communications so that I was aware of issues in case my
advice about who and when to brief was needed.
38.From memory, my engagement with MPs following the publication of Second
Sight’s Part 2 report and the mediation scheme was limited. The publication of
Second Sight’s report was very difficult for POL and a rebuttal document was
drafted (POL00002415). I can see that Mel Corfield sent me a copy of the
Rebuttals document and Response to Second Sight Part 2 Final report in an
email of 23 September 2014 (POL00306722). It is possible that I would have
sent something similar out to MPs who had constituents in the mediation
42153557.1
WITN10680100
WITN10680100
scheme. POL00078261 is a planning grid that shows a record of
correspondence sent by me to MPs with SPMs in their constituency who applied
to the mediation scheme. I cannot say for definite, but I believe that
POL00078267 is an example of one of these emails. Again, this is an example
of how I would have acted as a communications channel between the Mediation
team and MPs where the issue of Horizon is concerned.
39.In respect of the mediation scheme, I was often copied into correspondence
about it and was briefed on facts such as the number of participants and MPs
who had constituents in the scheme, but my role was peripheral. If an MP asked
a question specifically about the scheme, I would have let the Mediation team
know and they would have drafted the response. Again, my role was more
reactive than proactive, responding to messages and acting as a go-between
between MPs and the Mediation team.
40. The Inquiry have provided me with document POL0040075 which is a
presentation entitled ‘Media Scenario Planning: Initial Complaint Review and
Mediation Scheme’. I would not have been involved in this and cannot
remember the presentation although it is possible that I would have been asked
to action some of the action points listed in it, in respect of communication with
MPs.
41.As mentioned above, when I first started at POL, Sophie Bialaszewski, a
member of my team, was responsible for the communications planning around
Project Sparrow. POL00147377 is an email sent by Sophie in January 2014
about the media strategy for Project Sparrow which was to go to the Board. I
cannot recall contributing to this document but think I would have been copied in
42153557.1
WITN10680100
WITN10680100
for awareness. As referenced above, Sophie reported to the Communications
Director for this aspect of her role.
42.1 do not know what process was in place by which information about Horizon
and Project Sparrow were passed to the Communications team in POL as by
the time I received any information, it had already been filtered through the
press team and I would only see the finished material.
RELATIONSHIP WITH THE MEDIA
43.My role was narrowly focused - perhaps blinkered - on Public Affairs and so I
had little, if any, involvement with the media. I do, however, recall that what the
media was reporting was directly at odds with what colleagues were saying —
they were adamant that Horizon was robust. I had worked in other large, high
profile organisations and experienced situations where this had happened
before and so I was used to this tension.
44.POL00162505 is an email from Mark Davies letting senior colleagues know that
the BBC is planning a programme on Horizon, alongside a debate in the House
of Commons. The email attaches a ‘Panorama note’ which has not been
disclosed but I imagine lays out POL’s position on Horizon. I would not have
been involved in drafting this.
45.POL00174376 is an email from me to Mark Davies, Melanie Corfield and Ruth
Barker, forwarding an email from my friend who worked for a TV listings
magazine giving me a heads up of the transmission date of the Panorama
programme. I remember I asked her if she could do this as the BBC were not
forthcoming with the transmission date. I did not have any role in the media
42153557.1
WITN10680100
WITN10680100
response to the Panorama TV programme - this was simply me using my TV
contacts to try and be helpful to the Press team so they had as much notice as
possible before Panorama was broadcast.
46.POL00228588 is a request from BBC Panorama for Paula Vennells to be
interviewed on the Horizon system issues which I have forwarded to Mark
Underwood for his information. This email is not relevant to Public Affairs and so
I am unsure why it was sent to me. I would not have had any involvement in
whether Paula should attend a media interview and certainly no decision-
making power although there is a chance that Mark might have canvassed for
views at the team meeting, but I cannot remember. This is likely an example of
me being copied into information so that I am in the loop about current issues.
SELECT COMMITTEE — FEBRUARY 2015
47.POL00150551 is an email chain attaching my tracked changes to POL's
response to a Westminster Hall debate (POL00150552). The email chain
indicates that the first draft was written by Belinda Crowe and Mel Corfield.
However, as the document was intended for use with MPs, I would have
reviewed it. My review would be primarily focused on the language and style of
communication, not the actual content as can be seen in the tracked changes.
48.P0L00027731 is an email from Mark Davies to senior colleagues regarding an
update on Project Sparrow and the Department for Business, Innovation and
Skills (‘BIS’) Select Committee hearing in February 2015.
49.PO0L00310730 is an email chain about lan Henderson from Second Sight
appearing before the BIS Select Committee to give evidence and concerns
42153557.1
WITN10680100
WITN10680100
being raised about him giving evidence alongside Paula Vennells. It was part of
my role to liaise with the Committee which is why I think that I picked this up and
called the Clerk who I state is “not budging” on the position. Mark Davies
subsequently drafted wording to be sent to the Clerk following my conversation
with them, further explaining why POL is concerned that they give evidence
separately to Second Sight. POL00150982 is the email chain discussing this
proposed wording with myself and others making suggested amendments.
50. Following the BIS Select Committee hearing, Rod Williams sets out his legal
advice in an email to Mel Corfield which Mark Davies subsequently forwarded to
myself and others (POL00221138). Mark is particularly concerned about making
a statement to the BBC in respect of the allegation from Second Sight that POL
were not disclosing information to the Defence in connection with the
prosecution. Although I am copied in, this would have been for information only I
would not have been involved in drafting a statement to the BBC.
5
.Following the BIS Select Committee hearing, Belinda Crowe emailed me with a
mark-up of the transcript, along with a document identifying which points
needed rebutting. She sent this to me asking me to “hold the pen finally in terms
of finessing this from a PA perspective” (POL00221184). My role was to finesse
the language and make it presentable but I did not fact check the content as this
was carried out by Belinda, along with Andrew Parsons of Bond Dickinson. I
cannot remember this specific document and whether anything actually
happened with it, it might have just been prepared to be kept in the back pocket
in case we needed to use it.
42153557.1
WITN10680100
WITN10680100
52.In terms of my role in making preparation for the BIS Select Committee hearing
in February 2015, prior to it taking place I assisted by acting as a liaison
between POL and the committee clerk, as shown in POL00310730 where I am
seen to have spoken to the clerk about Second Sight and POL giving evidence.
I also put together a briefing pack for witnesses to read ahead of being
questioned. This would have contained information on the issues that were
likely to be covered in the session, as well as biographies of committee
members. This has not been disclosed by the Inquiry but would have been an
extensive document. I would have been guided on the content by the Select
Committee Inquiry’s Terms of Reference which would provide areas that would
be covered in the session. To create this document I would have spoken to
different departments to obtain information for the briefing, for example the
Mediation team and legal for details of the mediation scheme, IT for details
about Horizon and Angela Van-Den Bogerd for details about training and
support for sub-postmasters and background data such as how many people
use Horizon. My role was to collect all of this information from the business and
pull it together so that there was one note which could be given to Paul Vennells
and Angela Van-Den Bogerd so that they had all the relevant information
needed to answer any questions. After the information was collated I would
have sent it to each relevant department for their review to fact check. Legal
colleagues would have had oversight and I think that Patrick Bourke and Mark
Davies would have reviewed the final note to decide on any particular areas that
should be emphasised.
53.POL00117096 is an email that I sent to Paula Vennells the evening before the
hearing with two attachments. The first is key facts on the mediation scheme for
42153557.1
WITN10680100
WITN10680100
Paula to have in front of her (POL00117098). This is not the full briefing but an
abbreviated version so that she has key information easily accessible to her on
the day. The second contains additional information on anticipated areas of
questioning (POL00117097). I would have drafted these, with input from the
press team, mediation team, legal, IT and Network.
54.In addition to oral evidence, we also provided written evidence which is at
POL00026702. Again, I would have written this, with input from the press team,
mediation team, legal, IT and Network. Patrick Bourke and Mark Davies would
have signed it off.
55.Ahead of colleagues appearing in front of a select committee, it was usual for
me to ask a public affairs consultancy to take them through a rehearsal. I
imagine that the same would have been true in this case although I don’t
remember the details.
56. Following the hearing, it was the role of the Press team and Communications
Director to decide what the appropriate lines to take were in respect of the press
although I was sometimes copied into correspondence for information purposes.
CONCLUSIONS
57. There are no other matters that I would like to draw to the Chair's attention.
42153557.1
WITN10680100
WITN10680100
Statement of Truth
I believe the contents of this statement to be true.
Signed:
Dated: 24 October 2024
42153557.1
POL00110047
INDEX
Post Office Communications Plan 2015/16
WITN10680100
WITN10680100
POL-0111143
POL00200475
Industry in Parliament Trust dinner agenda
POL-BSFF-0038538
POL00101766
Email from Jane Hill to Gavin Lambert, Mark R Da-
vies, Richard R Weaver and others in re to 'infor-
mation for MP drop in tomorrow' dated 09/12/2014.
POL-0101349
POL00162224
Email from Jane Hill to Angela Van-Den-Bogerd,
Belinda Crowe and Mark R Davies. RE: event in
Parliament tomorrow - 4 to 6pm.
POL-0150661
POL00158072
Post Office weekly briefing pack to support the prin-
ciples in our leadership behaviours around knowing
the numbers and working with others.
POL-0146415
POL00162071
Email from Mark Davies to Jane Hill re BBC Wales -
Horizon Documentary
POL-0150516
UKGI00004680
Email from Jane Hill to Laura Thompson re FOI re-
sponses on prosecutions.
UKGI015494-001
UKGI00004692
Email from Laura Thompson to Richard Callard re:
FW: FOI Responses to Prosecutions
UKGI015506-001
UKGI00023280
Email from Tom Cooper to Annabelle Miles CC'ing
Alex Col, Stephen Clarke and others RE: NFSP-
Embargoed Press Release on POL Select Commit-
tee Inquiry
UKGI032175-001
POL00162657
Email from Martine Munby to Mark R Davies, Pat-
rick Bourke, Mark Underwood & Ors RE: Post Of-
fice - Monitoring I Early day motion 427 - POST OF-
FICE HORIZON COMPUTER SYSTEM
POL-0151053
POL00211460
Email from Mark R Davies to Patrick Bourke cc
Belinda Crowe, Chris Aujard and others RE: Han-
dling Arbuthnot (and related) correspondence - re-
garding Second Sight and hostile MPs
POL00211460
POL00423968
Email from Mark R Davies to Louise Chatfield:
Please ignore the attachment to my last email- this
is the right attachment.
POL-BSFF-0238784
POL00423972
Post Office Advisory Council: Inaugural Meeting,
18th and 19th March 2014.
POL-BSFF-0238788
POL00295528
Email from Theresa Iles to Mia Porter re FW: An-
drew Tyrie MP.
POL-BSFF-0133578
POL00384446,
Email from Mark R Davies to Sophie Bialaszewski,
Nina Arnott, Jane Hill and others, Re: Pack for
Brunswick
POL-BSFF-0211333
POL00384471,
Email from Sophie Bialaszewski to Mark R Davies,
David Oliver, Melanie Corfield and others, Re:
POL-BSFF-0211358
42153557.1
WITN10680100
WITN10680100
Brunwick Public Affairs Messaging
AW,
POL00384472,
POL Brunswick Horizon Public Affairs Messaging
POL-BSFF-0211359
18.
POL00207399,
Email from Belinda Crowe To: Jane Hill, Mark R Da-
vies and CC: Melanie Corfield re RW Letter to SS
13082014.docx
POL-BSFF-0045462
19.
POL00147377
Email thread from Sophie Bialaszewski to Mark R
Davies, Nina Arnott, Jane Hill & others RE: Scheme
Media Planning
POL-BSFF-0006500
20.
POL00040075
Post Office Media Scenario Planning- Initial Com-
plaint Review and Mediation Scheme Presentation
POL-0036557
Hil,
POL00002415
Post Office, Initial Complaint Review and Mediation
Scheme, PO Reply to Second Sight's Briefing Re-
port —Part Two
VIS00003429
1,
POL00306723
Report about Draft Rebuttals documents
POL-BSFF-0144773
28},
POL00306722
Email from Melanie Corfield to Jane Hill. CC ing
Mark R Davies, Nina Arnott and others. RE: Spar-
row latest
POL-BSFF-0144772
24.
POL00101778
Email from Mark R Davies to Belinda Crowe, re
ONE show
POL-0101361
©),
POL00101786,
Email from Mark R Davies; re: ONE show Belinda
Crowe to
POL-0101369
26.
POL00101793
Email from Mark R Davies to Belinda Crowe, re De-
bate next week
POL-0101376
2 TE
POL00149293
Email chain including Jane Hill (POL); Belinda
Crowe (POL); Melanie Corfield (POL) & Others Re:
Media Coverage following 2nd sight report
POL-BSFF-0008413
28.
POL00150364
Email chain including Belinda Crowe (POL); Jane
Hill (POL); Mark R Davies (POL) & Others Re: PO
Mediation Service
POL-BSFF-0009476
2),
POL00101478
Email from Mark R Davies to Belinda Crowe, cc'd
Avenue O'Farrell, Tom Wechsler, Chris Aujard and
others re: Post Office mediation process
POL-0101061
30.
POL00162505
Email from Mark Davies to Martin George, Mark
Siviter, Peter Markey and others others re: Pano-
rama and Horizon
POL-0150911
Bi
POL00174376
Email chain from Jane Hill to Mark Davies, Melanie
Corfield and others re Panorama
POL-0168376
32.
POL00228588
Email from Jane Hill to Mark Underwood1 Re: FW:
BBC Panorama IV request
POL-BSFF-0066651
B35
POL00150551
Email chain from Jane Hill to Patrick Bourke, Mark
R Davies, cc'd Tom Wechsler and others re The
"dossier".
POL-BSFF-0009663
42153557.1
WITN10680100
WITN10680100
34.
POL00027731
Email from Mark R Davies to Paula Vennells, Mar-
tine George, Neil Hayward and others RE: Sparrow
update
POL-0024372
ck,
POL00310730
Email from Jane Hill To: Mark R Davies, Patrick
Bourke CC ing Belinda Crowe and others. RE: BIS
Committee hearing 3 February 2015
POL-BSFF-0148780
36.
POL00150928
Emails from Jane Hill to Mark R Davies RE: FW:
Letter to committee
POL-BSFF-0010040
37.
POL00221138
Email from Mark R Davies to Rodric Williams,
CC'ing Melanie Corfield, Jane Hill and others RE:
Legal position on legal advice
POL-BSFF-0059201
38.
POL00221184
Email from Belinda Crowe to Melanie Corfield, An-
drew Parsons, Mark Underwood and others RE:
Doc for select committee
POL-BSFF-0059247
42153557.1