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Witness Name: Andrew Holt
Statement No: WITN11040100
Dated: 12 November 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ANDREW HOLT
I, Andrew Holt, will say as follows.
INTRODUCTION
1. lam a former employee of Post Office Limited (POL).
2. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 Request addressed to me and dated
7 October 2024 (the “Request”).
3. I have received the assistance of Ashfords LLP in drafting this statement.
PROFESSIONAL BACKGROUND
4. I have considered the following documents:
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i. I [POL00193406] (email from Simon Baker regarding his handover, dated
13/08/2013);
ii. I [POL00193604] (email regarding POL training day, dated 16/08/2013);
iii. I [POL00197019] at page 2 (presentation on roles/ responsibilities for POL
officers in relation to the Mediation Scheme, dated 08/11/2013).
5. In 1995 I achieved a Masters in Information Technology and Management from
Coventry University.
6. Following my masters, between 1995 and 2009 I progressed through various IT
related positions in different organisations (including Technology Services, Banking
and Financial Services) carrying out a variety of roles from coding, systems
analysis and management, business analysis, as well as project and programme
management roles. Several of these roles were for less than a year. My main roles
during this time were the following:
i. Systems Analyst, Systems Manager & Project Manager for an Investment
Bank —1996 to 2003
ii. Business Solutions Manager for a Financial Services company — 2005 to
2007
7. \joined the POL IT function as a Business Solutions Manager on 5 May 2009. In
this position I was aligned to the financial services business function within POL.
My role was to help POL financial services to define, initiate and get approval for
IT projects that would deliver new features to their various IT systems.
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8. I was promoted to an IT Business Relationship Manger within POL on 1 January
2011, and held this job title until 31 March 2014. In this role I was responsible for
leading a team of 4 other IT Business Relationship Mangers, and I was their point
of contact for supervision and line management. However, I also worked alongside
them and together we managed IT relationships with management staff across
various business units within POL. We predominantly worked with these
Stakeholders to align their strategic business plans with the IT functions. This was
achieved by collaborating with IT architects, and ensuring each business area’s
strategy aligned with IT’s overall objectives. We also assisted departments within
POL getting IT projects initiated and progressed, providing oversight over the
projects whilst they were being delivered.
9. From 1 April 2014, POL changed my job title to Business Relationship Lead. As far
as I can recall, this change was simply made to distinguish that I was, and had
been since 1 January 2011, the group lead of the 4 other Business Relationship
Managers. As such, this change in title did not represent a change in the role itself
and I was still carrying out the same functions set out in paragraph 8 above.
10.It should be noted that from August 2013 I also took on a part-time project
management role within POL’s Project Sparrow. Project Sparrow was specifically
related to the work of the Initial Complaint and Mediation Scheme (the Mediation
Scheme) and the work of the Working Group for the Mediation Scheme (the
Working Group). I was also a point of contact into Fujitsu and the IT leadership
Team where further actions or engagement was needed. This was not a job change
or promotion, but rather an additional responsibility to my main day to day job
described in paragraph 8 above. I do not remember how many hours a week I spent
working on Project Sparrow matters, but from my recollection it was ad hoc and
varied depending on what was required from the programme. I provide further detail
in relation to my role in Project Sparrow later in this statement.
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11. I left POL on 31 December 2014 and have worked in several different organisations
in IT roles since. Initially I continued in IT Business Relationship roles, then IT
Portfolio Management, IT Service Management, and I am now an IT Consultant.
KNOWLEDGE OF HORIZON AND HORIZON INTEGRITY
12.1 confirm that I have considered the following documents:
i. I [POL00105609] (Email chain from Antonio Jamasb to Dave Hulbert re
Horizon - whole network service outage dated 09/07/2012);
ii. [POL00182875] (My email Andrea Harwood, Matt Sadler and others
regarding Horizon issues, dated 25/10/2012);
iii. I [POLO0192699] (Email chain from Simon Baker to Angela Van-Den-Bogerd
et al regarding stock adjustment issue and response, dated 02/07/2013);
iv. [POL00145546] (Email from Steve Beddoe regarding call about Horizon
improvements, dated 18/07/2013);
v. [POL00297788] (Horizon Investigation plan, dated 19/07/2013);
vi. [POL00060722] (Email from Alwen Lyons to Simon Baker regarding
transaction corrections, dated 19/07/2013);
vii. I [POL00297905] (Email chain from Rod Ismay to Simon Baker regarding
Horizon stock adjustments, dated 23/07/2013);
viii. I [POL00297984] (Email from Ron Warmington to Simon Barker regarding
Second Sight investigation into branch shortfalls, dated 26/07/2013);
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ix. [POL00193030] and [POL00193031] (Email regarding Branch Support
Programme with attached Terms of Reference, dated 31/07/2013);
x. [POL00413701] (Email from Simon Baker to Lesley J Sewell with me cc’d,
regarding Nick Wallis post on possible Horizon replacement, dated
16/08/2013);
xi. [POL00145915] (Email chain from Mark R Davies to me regarding Horizon
National Media Enquiries, dated 16/08/2013);
xii. [POL00298276] (Email from Ruth Barker copying me regarding Horizon
media enquiries, dated 16/08/2013);
xiii. I [POLO0298403] (Email from Susan Crichton to Angela Van-Den-Bogerd,
with me cc'd, regarding Horizon review workflow, dated 19/08/2013); and
xiv. [POL00344252] (My email to Lesley Sewell regarding Horizon Core Audit
Process, dated 30/01/2014).
13.As far as I can recall, I had no previous knowledge of the Horizon IT system when
I first joined POL in 2009. I also do not remember if I had any specific training on
the system after I joined POL, but rather I learned organically about it as I
progressed through my roles.
14. During my roles in POL, my knowledge of the Horizon IT system was generally only
required for strategic and project planning. In my roles I would have worked on
requesting new features and functionality on the platform via Fujitsu, and these
would have been to introduce new products or improve certain aspects of its
capabilities or functionality for different business units within POL. To do this I
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would have had some general knowledge of the system's functions and
capabilities, to understand what changes Fujitsu needed to design and deliver.
15.Nevertheless, I did also gain some knowledge on the practical operation of the
Horizon IT system. For example, I recall working on one project that related to
improving the flow of a certain transaction on the Horizon terminal. Although I
cannot recall what this transaction was, I do remember visiting a Post Office and
getting a Sub-postmaster (SPM) to show me how that transaction flow worked on
his screen. I also helped out annually in Post Office branches at Christmas time
(all staff could volunteer for this), and would have observed SPMs using the
Horizon IT system then.
16.1 cannot recall having specific knowledge of potential Bugs Errors and Defects
(BEDs) in the Horizon IT system in my first few years in POL. Fujitsu provided day
to day service management of Horizon, and reported into another team in POL IT.
I can see from the disclosure provided to me that I am involved in part of the email
chains on 9 July 2012 [POL00105609] and 25 October 2012 [POL00182875], that
detail some Horizon related service issues, but I do not recall service issues like
this being a major cause for concern.
17.From reviewing the documents provided to me, I believe it is likely that I first
became more aware of potential BEDs and their impact on the Horizon IT system
during my handover period with Simon Baker between July 2013 and mid-August
2013, when I took on additional responsibilities within POL’s Project Sparrow.
Whilst I cannot specifically recall reading it, I would have read Second Sight’s
Interim Report on alleged problems with the Horizon system [POL00099063] in
preparation for my role within Project Sparrow. Having re-read this interim report, I
can see that Second Sight were aware of 2 incidents where defects or bugs in the
Horizon software gave rise to 76 branches being affected by incorrect balances or
transactions.
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18. Although I would have read the findings in Second Sight's interim report, I do not
recall having any concerns about a lack of integrity in the Horizon IT system.From
my experience, all IT systems have day to day incidents which require resolution,
with further root cause investigation should these cause major issues or there are
recurring themes. It appears that Second Sight explored these 2 BEDs in their
interim report and concluded that no systemic problems were uncovered during
their review. Although I cannot recall my thoughts from the time, I believe that I
would have simply taken Second Sight’s conclusions as explained and not thought
to scrutinize matters any further, especially given that they were specialist forensic
investigators engaged on an independent basis. As a consequence, I do not think
that I would have taken this report and the issues identified to indicate that there
were any broader integrity problems in the Horizon Software.
19.1 do not believe I had awareness of any specific complaints from SPMs addressing
BEDs or concerns with Horizon Integrity until I was asked to progress Horizon
related queries arising out of the work in Project Sparrow related to Second Sight
and the Mediation Scheme. Further detail of my involvement in this work is set
below under the following section of this statement: ‘Second Sight and the Working
Group dealing with Mediation’.
20.1 was not involved in or responsible for providing training on the Horizon IT system
to SPMs and I do not remember how this training was delivered. In light of this, I
am not able to comment on the adequacy of such training.
2
.In terms of the Branch Support Programme, I understood this was set up in
response to concerns in Second Sight’s Interim report about the adequacy of
training support provided to POL branches on the Horizon IT system. I have seen
an email from Gayle Peacock [POL00193030] where myself and others were
invited to a kick-off meeting regarding the Branch Support Programme and were
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asked to comment on the Programme's draft terms of reference ahead of this. I do
not remember if I attended that meeting or commented on the draft terms of
reference, but as far as I can recall I had no active role in running the Branch
Support Programme. I do have a vague recollection of assisting Angela Van-Den-
Bogerd and Gayle Peacock with pulling together a high level document explaining
the purpose and goals for the programme, but I was not involved in deciding the
detail of how the programme would be delivered, and I do not think I was I involved
in steering it. I believe that The Branch Support Programme became a sperate
initiative to the work of Project Sparrow.
HELEN ROSE REPORT
22. I have considered the following documents:
i. I [POL00022598] (Horizon Data Lepton SPSO 191320 by Helen Rose (‘Helen
Rose Report’) dated 12/06/2013);
ii. I [POL00202688] (my email to Belinda Crowe and Andrew Parsons regarding
Helen Rose report and criminal cases, dated 08/04/2014); and
iii. I [POL00303963] (Email to me from Rod Ismay regarding the Helen Rose
Report, dated 23/04/2014).
23.Prior to considering the above documents, I had no memory of the Helen Rose
report. I can see that the report is dated 12 June 2013, but it appears from the
emails at [POL00202688] and [POL00303963] that the first time I was made aware
of it was in April 2014.
24.1 do not know why the Helen Rose report was produced or who may have
commissioned it. I did not know Helen Rose and I am not aware of her specific role,
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but from the documents presented to me it appears that she worked within POL’s
security and fraud department. In light of this, I can only speculate that she may
have come across the issue explored in her report during her day to day role and
produced the document as part of her investigative work.
25.1 can see from my email at [POL00202688] that after I learned about the Helen
Rose Report I investigated the required actions arising out of it (namely in relation
to submitting the change request set out in the report's recommendations), and put
steps in place for this matter to be progressed. My email suggests that I considered
the issues raised to relate to the Branch Support Programme and I arranged with
Angela Van-Den-Bogerd and Gayle Peacock to take matters forward as part of this
work. I do not recall having further involvement with the Helen Rose report beyond
this.
26.1 cannot recall what my initial response was after reading the Helen Rose report,
nor can I recall what the response or reaction was within POL. I also do not recollect
ever considering whether the points raised within the Helen Rose report casted
doubt on the safety of the convictions of SPMs, and I am not sure now whether I
understood at the time of reviewing the report that prosecutions were based wholly
or partly on Horizon data. From reading the report now, I think Helen Rose’s
conclusions would have probably led me to believe that the issues explored in the
report related to an isolated event, that would benefit implementing the change
request she recommended.
27.1 do not remember or think I know who the Helen Rose Report was distributed to,
nor do I know any details of the nature and extent of the knowledge of the Helen
Rose Report within POL. Having reviewed [POL00303963], it appears that I had
to obtain a copy of the report from Rod Ismay, but I am not sure who else had
access to it.
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SECOND SIGHT AND THE WORKING GROUP DEALING WITH MEDIATION
28. I have considered the following documents:
i. I [POL00029666] (POL Spreadsheet of Second Sight Workstreams);
ii. [POL00134525] (POL PowerPoint detailing Second Sight Mediation
Process);
iii. I [POLO0099265] (Email chain regarding mediation cases, dated 17/07/2013);
iv. [POL00192267] (Email from Simon Baker to Second Sight, identifying me
as his replacement, dated 18/07/2013);
v. [POL00297788] (Horizon Investigation Level 1 plan);
vi. [POL00192335] and [POL00297804] (Email chains regarding briefing note
for Paula Vennells/James Arbuthnot meeting, dated 19/07/2013); also
[POL00117036] (Email from Simon Baker with notes from said meeting);
vii. [POL00407565] (Email from Gareth Jenkins to Simon Baker, me cc’d,
regarding Stock adjustments, dated 22/07/2013);
viii. I [POL00137330] (Slide Pack for SPM Improvements & Mediations Weekly
Steering Group, dated 26/07/2013);
ix. [POL00162011] (Email from Sophie Bialaszewski to me regarding the
Horizon Investigation Level 1 plan, dated 13/08/2013);
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x. [POL00413697] (Email from Kay Linell to me regarding the Working Party,
dated 14/08/2013);
xi. I [POL00417109] (Report and Agenda for SPM Improvements & Mediations
Weekly Steering Group, dated 15/08/2013);
xii. [POL00298382] (Email from Alan Bates to Simon Baker, me cc’d, with
comments on Phase 1 Pack, dated 18/08/2013);
xiii. I [POL00298419] (Email from Rodric Williams to Lesley Sewell, me cc’d,
regarding Draft Letter to Fujitsu, dated 20/08/2013);
xiv. [POL00298446] (Email from Sophie Bialaszewski to me regarding ‘MP
Handling Plan’, dated 22/08/2013);
xv. [POL00146190] (My email regarding Working Party Dialin for Training Day,
dated 29/08/2013);
xvi. [FUJ00235737] (Fujitsu email chain regarding POL Mediation Process for
Sub-Post Masters and my role, dated 02/09/2013);
xvii. [POL00139864] (Email from Martin Smith to me regarding POL Weekly
Update, dated 06/09/2013);
xviii. I [POL00327060] (Email from Laura Pinkney to me regarding Weekly update,
dated 13/09/2013);
xix. I [POL00299609] (Email from Alan Bates to Paula Vennells and me (et al)
regarding the Martin Griffiths case, dated 23/09/2013);
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xx. [POL00116135] (Email from Martin Edwards to me concerning meeting with
Sir Anthony Hooper, dated 27/09/2013);
xxi. [POL00372534] (Email chain from Andrew Parsons to me regarding Working
Group and criminal investigations, dated 16/10/2013);
xxii. I [POL00123003] (Email from Andrew Parsons to me regarding Project
Sparrow, dated 21/10/2013);
xxiii. I [POL00197019] (presentation on roles/ responsibilities for POL officers in
relation to the Mediation Scheme, dated 08/11/2013);
xxiv. [POL00301456] and [POL00199985] (Emails from me to Angela Van-Den-
Bogerd with technical mediation scheme application questions, dated
23/01/2014 and 24/01/2014 respectively); and
xxv. [FUJ00239552] (Email from me to Pete Newsome regarding reaction to
Second Sight Report, dated 03/03/2014).
29.1 have been asked to describe the nature of any briefing I received from Simon
Baker upon replacing him in the role of ‘Senior Business Relationship Manager’ in
August 2013, particularly in relation to:
i. Second Sight, including the quality of their work;
ii. the nature and purpose of the Mediation Scheme, including POL’s goal
regarding the same; and
iii. the Working Group.
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30.1 would firstly like to clarify that as far as I can recall, Simon Baker was not a ‘Senior
Business Relationship Manager in POL. I can see from the documents provided to
me that his emails were signed off with ‘Head of Business Change and Assurance.”
3
.I would also like to note that the role I took over from Simon Baker in August 2013
did not lead to me changing job title or being promoted to become a Senior
Business Relationship Manager, or Head of Business Change and Assurance. As
explained earlier in this statement, I was taking on Simon Baker’s responsibilities
within Project Sparrow on a part time basis, and these responsibilities were
separate to my main day to day role as a Business Relationship Manager in POL.
32.1 believe that I received a gradual handover from Simon Baker from around July
2013 to mid-August 2013 in the run up to me taking over his role in Project Sparrow.
Simon Baker and I would have no doubt had 1-1 meetings during this period, but
due to the passage of time I cannot specifically recall when these meetings were,
or what exactly was discussed.
33.In terms of any handover that I received in relation to Second Sight, including the
quality of their work, I do not remember the conversations I may have had with
Simon Baker or anyone else about this. However I do believe I would have been
informed about the purpose of Second Sight's role as part of me joining Project
Sparrow.
34.1 cannot clearly remember what I understood Second Sight’s role to be, but from
reviewing the documents provided to me, including the reports completed by
Second Sight, I believe upon joining Project Sparrow that I would have understood
that Second Sight had initially been engaged with a wide remit to look into alleged
problems with the Horizon System, and this appears to have led to them producing
their interim report. It is then clear from the documents that their role later became
more focused on reviewing and investigating applicant's complaints in the
Mediation Scheme, which appears to have led to them producing their Part 1 and
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Part 2 Initial Complaint review and Mediation Report. I do not remember when I
would have first become aware of this proposed role change.
35.1 do not recall having views or concerns about the approach taken by Second Sight
in any of the work they were doing in connection with Project Sparrow. Based on
the documents provided to me and the timing of Second Sight's initial engagement,
I do not think I would have been involved in any discussions about Second Sight’s
initial investigation scope.
36.1 also believe that I would have received a handover from Simon Baker regarding
the nature and purpose of the Mediation Scheme, including POL’s goal regarding
the same, however again, I cannot recall the specific detail of this handover. I think
it is very likely it would have been explained to me that a scheme was being set up
as part of POL’s public commitments (which I can see are set out on slide one of
the PowerPoint at [POL00197019]) and that it would entail a process by which
SPMs could raise outstanding grievances with POL. When I joined Project
Sparrow, I believe there were different options and arrangements being considered
by the Working Group for how the Scheme would run, although I cannot recall what
these options were. I can see that the process that was eventually agreed is set
out in an internal Fujitsu email chain dated 2 September 2013 [FUJ00235737],
which indicates that I spoke with Fujitsu to update them on what the agreed process
for the Mediation Scheme would be. I can also see there was a process flow
defined in [POL00134525].
37.1 would have also received a handover from Simon Baker in relation to the Working
Group for the Mediation Scheme, but again I cannot recall the details of this.
Nevertheless, I believe that it would have been explained to me when I first joined
Project Sparrow that the Working Group was being formed to first agree the scope
of the Mediation Scheme and then once that was agreed, to help manage the
planning and processes around it as it ran. From memory I believe the Working
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Group consisted of POL members, Second Sight Members, JFSA members and
an independent Chair.
38.1 cannot recall if my line manager, anyone within POL’s senior management, or
anyone of the POL Board, set out their views to me on the matters contained
paragraph 29(i) —(iii) above. However, I do have a vague recollection about the aim
to reduce the amount of money spent on Second Sight, but I do not remember
specifically where or when this was discussed. I can see that the disclosed
document [POL00197019] alludes to this point. I do not think I would have had any
discussions with the Board members or attended ExCo meetings.
39.1 have also been asked to describe my experience of the operation of the Working
Group, to include the following matters:
i. the nature and extent of my engagement with Second Sight;
ii. the nature and extent of my engagement with Fujitsu;
iii. I the nature and extent of my engagement with POL external legal advisers;
and
iv. the nature and extent of my engagement with Mark Davies and Martin
Edwards in respect of POL responding to media reporting regarding issues
with Horizon, the Scheme, and any criticism brought against the Horizon
system and POL.
40.1 do not remember the precise details of my role and involvement with the Working
Group when I took over from Simon Baker in August 2013, but I believe it entailed
me being a Secretariat to the group, helping to organise Working Group meetings,
and being point of contact to manage actions arising out of such meetings,
particularly in relation to matters or queries that needed progressing with Fujitsu or
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POLIT. My recollection is that my involvement with the Working Group was during
the very early stages where the focus of the group was to agree the scope of the
Mediation Scheme, set out how it would run and get the process up and running.
Later in 2013 when Belinda Crowe joined Project Sparrow, I believe my role
changed and I no longer attended the Working Group. I believe Belinda Crowe
came on board to manage Project Sparrow and the Mediation Scheme and also
became the Secretariat for the Working Group. Sir Anthony Hooper was also
appointed as the Working Group Chair. After this point I became increasingly less
involved in the Working Group and I believe I dropped out of it altogether, although
I cannot recall exactly when. However I do recall that after I dropped out of the
Working Group my role within Project Sparrow became more focused on
progressing IT or Fujitsu requests that arose.
4
. My engagement with Second Sight was usually through the Working Group, but on
occasion I did correspond directly with them to update on action points, particularly
where they were seeking further engagement with Fujitsu or other technology
providers. I was effectively a point of contact within Project Sparrow that could
facilitate and coordinate such requests.
42.In terms of my engagement with Fujitsu, I would liaise with them in various
circumstances, for example, when POL needed their input on comms responses,
where specific technical queries in relation to the Horizon IT system had been
raised, and to provide general progress updates on the Mediation Scheme.
43.1 cannot clearly recall the nature and extent of my engagement with POL external
legal advisers including Bond Dickinson, Womble Bond Dickinson and Cartwright
King. However, having reviewed the documents provided to me, I can see there is
email correspondence between myself and Andrew Parsons of Bond Dickinson at
[POL00372534] and [POL00123003] from 16 and 21 October 2013 respectively,
during which the Mediation Scheme was in the process of being set up. It is clear
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from these emails that I was involved in liaising with Bond Dickinson to help
coordinate the setting up of the Mediation Scheme and seek their legal support and
expertise in responding to queries or concerns related to the same. In terms of any
engagement that I had with Cartwright King, I believe that they approached me to
seek IT input or clarification or gain further information from Fujitsu on technical
matters. I would have either responded, or passed on these queries and
coordinated responses between POL IT and Fujitsu teams.
44.I cannot recall having much engagement with Martin Edwards during my time within
POL, however, having read [POL00116135] I can see that I updated him on overall
progress in relation to the Mediation Scheme, so that he could provide this
information to Paula Vennells.
45.In terms of my engagement with Mark Davies, I vaguely recall that I worked with
his team on understanding the Comms plan they were putting together in relation
to the Mediation Scheme. The milestone plan for this appears in [POL00417109].
I also remember and can see from the documents provided that I assisted the
Comms team by liaising with Fujitsu or POL IT, whenever there were any specific
Comms content that needed their input due to its technical nature.
REMOTE ACCESS TO HORIZON
46. I have considered the following documents:
i. [POL00195750] (Email from lan Henderson to me regarding Bracknell
testing team’s access to back-office accounting systems, dated 25/09/2013);
ii. I [POL00220859] (Email from Belinda Crowe to me regarding Martin Rolfe’s
emails, dated 13/03/2013); also the chaser email [POL00148887] (dated
27/08/2014);
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iii. I [POLO0367583] (Email from Angela Van-Den-Boger to me regarding POL
access to audit servers, dated 01/05/2013);
iv. [POL00091394] (Email from Melanie Corfield to me regarding Second
Sights M053 Revised Draft CRR-referring to remote access, dated
13/10/2013); and
v. [POL00211254] (Email from Andrew Parsons to Rodric Williams regarding
note on Horizon remote access process, dated 21/10/2014) and
[POL00349653] (updated version of note, dated 04/11/2014).
47.Whilst I recall the topic of remote access, I cannot recall what the nature and extent
of my knowledge of this was. Having reviewed the documents provided to me, my
understanding would have been the same as set out in paragraph 3 of Melanie
Corfield’s email at [POL00091394] — that there was no remote access for individual
branch transactions, but that Fujitsu had support access, controlled with security
processes in place, to the ‘back-end’ of the system for software updates and
maintenance. All IT systems have an Administrator in place with the ability to
access a system in this way, so it would have been logical for someone in Fujitsu
to have access for this purpose.
48.As far as I can recall, I do not think I ever thought or suspected that Fujitsu had
remote access to insert, edit or delete transaction data or data in branch accounts
without appropriate process or the knowledge or consent of SPMs.
49.1 think this matter had already been investigated before I became involved in
Project Sparrow in August 2013, and it had been determined this could not be done
by Fujitsu. I also note in the email chain at [POL00195750], Simon Baker confirmed
to Second Sight on 3 July 2013 that there was no ability for POL employees who
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occasionally worked at the Fujitsu offices in Bracknell to posit transactions to the
back-office accounting systems either.
50.1 do not think I carried out or requested any further investigations to determine if
Fujitsu or POL employees working at Bracknell had the ability to insert, edit or
delete transaction data or data in branch accounts without the knowledge or
consent of SPMs, but I can see from the documents provided to me that I was
asked by Second Sight to assist them in obtaining email archives from back-up
tapes as at 31 December 2008 for the POL employees who worked on the
Bracknell testing team (see [POL00195750]). I do not know if I did assist with
obtaining this data in respect of all individuals, but the email chain at
[POL00220859] illustrates that I did try and progress this request with CSC in
respect of one of the individuals listed for all 2008 sent and received emails.
Unfortunately I do not recall what came of this request, but from the email chain at
[POL00148887], it appears a further explanation was being sought from Second
Sight as to why this information was required, due to the time and effort it would
entail.
5
I believe that any knowledge I did have around the topic of remote access would
have been gained from queries being raised about it in correspondence that I was
sent or copied in to, such as the emails noted in paragraph 46(i) — (v) of this
statement.
SECOND SIGHT INTERIM REPORT JULY 2013
52.1 have considered the Second Sight Interim Report dated 8 July 2013
[POL00099063].
53.1 do not believe I had any involvement in the preparation of the Second Sight interim
report. I believe that the report would have been prepared solely by Second Sight.
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54.1 cannot recall if I provided Second Sight with any information to help them to
produce their interim report, but given that the report was produced prior to me
Officially taking over from Simon Baker in Project Sparrow in August 2013, I believe
it is unlikely that I did.
55.1 believe that the first time I would have become aware of the bugs noted in Second
Sight’s interim report is when I read the report. I cannot recall when I read it butas
stated in paragraph 17 above, I expect this would have been during my handover
period with Simon Baker.
56.1 do not believe I passed any information to POL’s Board or ExCo regarding the
bugs raised in Second Sight’s interim report. First, as noted earlier in this
statement, I had not officially begun my role in Project Sparrow when the interim
report was published so it is unlikely I carried out any actions in relation to it, and
second, as far as I can recall, it would have been the more senior participants of
Project Sparrow who would inform the Board or ExCo on any matters that arose.
As previously mentioned above, I was often a point of contact into Fujitsu or POL
IT in relation to matters or queries arising out of Project Sparrow, but I do not think
I was ever a liaison to POL’s Board or to ExCo. I cannot recall if I saw anyone else
pass information about the bugs mentioned in Second Sight's interim report to
POL’s Board or to ExCo.
57.1 cannot remember what steps, if any, I took after Second Sight's interim report. I
believe it is likely there would have been meetings held within POL about the report,
and potentially with Second Sight and Fujitsu too. It is possible that I may have
been asked to set up or attend these meetings, but I simply cannot remember.
Page 20 of 39
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POL STEERING GROUP AND FURTHER INVESTIGATIONS INTO HORIZON
INTEGRITY
58.1 have considered the following documents:
i. [POL00116179] (Email from Sarah Paddison to me regarding Project
Sparrow steering group, dated 08/10/2013);
ii. I [POL00146704] (My email to Alwen Lyons concerning Project Sparrow
update, dated 23/10/2013);
iii. I [POL00196926] (Project Sparrow Overview Document, dated 31/10/2013);
iv. [POL00139000] (Sparrow Steering Group meeting minutes, dated
05/11/2013); and
v. [POL00158093] (Email from Belinda Crowe to me regarding scope and
resources for Project Sparrow, dated 14/11/2013).
59.1 have been asked to describe my experience of the operation of the “POL Steering
Group Working Group (Sub- Postmaster Improvements and Mediations Steering
Group).” I do not recall being involved in any group with that title, but for the
purpose of addressing this question I have assumed this refers to the Project
Sparrow Steering Group (the Steering Group), as opposed to the Working Group
for the Mediation Scheme.
60.As far as I can recall, the Steering Group was formed to steer POL’s 3 public
commitments set out on slide one of the PowerPoint at [POL00197019].
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61.In terms of my role on the Steering Group, I assisted in setting up group meetings,
helped to drive any actions from such meetings, pulled together information packs,
plans and progress reports for the Steering Group by liaising with relevant people
across POL, and I was also a point of contact for questions and requests arising
out of the Steering Group that needed to be raised with POL IT and Fujitsu.
62. Unfortunately I cannot recall any specific examples, but where matters arose from
the Steering Group that required engagement with Fujitsu, I believe I would have
been the point of contact with Fujitsu on most occasions. I also believe if something
arose from the Steering Group which I felt was relevant and necessary to share
with Fujitsu, I would have done so.
63.1 cannot recall what my personal engagement might have been with POL’s external
advisors in relation to matters arising from the Steering Group, but I know that they
were engaged on some workstreams, for example, the setting up of the Working
Group and Mediation Scheme. I can see from the documents provided to me that
lam copied into correspondence from Andrew Parsons of Womble Bond Dickinson
who was involved in the setting up the Mediation Scheme. I would have been
copied into this for information purposes, and I may have also been asked help
action matters or queries from Womble Bond Dickinson. Unfortunately I cannot
recall any specific examples of this.
IMPERIAL COLLEGE LONDON
64.1 have considered the following documents:
i. [POL00300571] (Email from Rodric Williams to Michael Harvey regarding
instruction of experts on the Horizon System, dated 06/11/2013);
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ii. I [POL00199809] (Email from Jarnail Singh to Chris Aujard, with me cc’d,
regarding appointment of independent Horizon expert, dated 16/01/2014);
iii. I [POL00148693] (My email to Jarnail Singh and Andrew Parsons regarding
ICL expert report, dated 10/07/2014);
iv. [FUJ00236423] (Email from James Davidson to Bell Gavin regarding ICL
initial review and requests, dated 23/07/2013);
v. [FUJ00238073] (Fujitsu report on Horizon integrity by James Davison, dated
14/08/2014);
vi. [POL00348522] (My email to Neil Wilkinson, Lesley J Sewell, Dave Hulbert
and others regarding meeting with ICL experts, dated 22/08/2014); and
vii. I [POL00148950] (Email from Jarnail Singh to Andrew Pheasant, Jessica
Madron, cc'ing Andrew Parsons and others regarding CK Draft Instructions
to Expert, dated 05/09/2013); and [POL00325918] (same email chain, latest
reply dated 01/01/2014)
65.1 could not initially recall why the experts from Imperial College London (ICL) were
instructed by POL. From my review of the documents provided, I now remember
that they were instructed to assess and report on certain aspects of the Horizon IT
System from an assurance perspective, and I believe the reasons for this were as
set out in Jarnail Singh's email to Chris Aujard, with me cc’d [POL00199809].
66.1 have been asked to consider the following document from Cartwright King at
[POL00148749], which sets out their advice in relation to apparent concerns arising
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out of the instructions to ICL. I can see that this advice note has a particular focus
on an email from me where I state a need to “agree how we steer this or define the
requirement correctly so the scope doesn’t get out of control and we allow Imperial
College to produce independent report.” Until receiving this document from the
Inquiry, I do not believe I had any awareness of its existence, or that legal advice
had been sought on this matter.
67.1 would first like to clarify that this sentence is worded poorly from me and should
not be read as me suggesting that I did not want ICL to produce an independent
report, nor should it be read as me looking to influence ICL or their work. On the
contrary my recollection is that I was trying to ensure that the independent review
would provide a meaningful independent report, and POL stakeholders understood
what further steps and costs might be incurred. As far as I can remember the
original ICL time and effort estimate was relatively small, and Horizon was a large
complex system, so I wanted to make sure that there was an understanding that
the review would either need to be on 1.) some specific elements of Horizon where
ICL would have sufficient time to review all the detail necessary to provide
conclusions or 2.) a broader review which would likely need follow on work by ICL,
with additional cost. It was my view that if ICL could understand and assess the
previous work, they could avoid repeating work that had already been conducted
effectively. They would then be able to carry out a more detailed assessment within
the original time and effort estimates, and in turn, produce a more meaningful report
overall.
DELOITTE
68. I have considered the following documents:
i. [POL00264768] (Email from Julie George to me regarding Deloitte and
assurance work on Horizon, dated 03/04/2014)
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ii. [POL00028062] (Deloitte - Horizon Desktop Review of Assurance Sources
and Key Control Features, Draft for Discussion, dated 23 May 2014);
iii. I [POL00304662] (My email to Dave M King and Rodric Williams and cc'd
Jarnail Singh regarding documents to be sent to ICL, dated 23/05/2014); and
iv. [POL00148693] (My email to Jarnail Singh and Andrew Parsons regarding
sharing Deloitte report with ICL, dated 10/07/2014); and
v. [FUJ00241523] (Fujitsu Mediation Update).
69.From my recollection, I do not think I had any involvement in driving the work
relating to the Deloitte report at [POL00028062] and I do not know why Deloitte
had been instructed to produce this report. I can see from the email chain at
[POL00264768] that myself and Julie George were told about the Deloitte work on
2 April 2014 by Belinda Crowe, and I was informed that I did not need to speak with
Fujitsu about this as Rod Williams and Lesley Sewell were going to. I also note
from this email that Belinda asked Julie and I to provide her with relevant
documents to go to Deloitte, but I cannot recall if I passed over any documentation
for the purpose of this work. It appears from the documentation provided to me with
the Request that Julie George was involved in progressing this work going forward.
70.1 do not remember the name Project Zebra or who had responsibility for this project
within POL. If the Deloitte work was referred to as Project Zebra, the documents
provided to me suggest that Julie George may have been responsible for this
project or had some involvement in progressing it.
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71.1 do not know the nature and extent of the knowledge and distribution of the Deloitte
report within POL.
72.I cannot recall if I actually read the Deloitte report at the time or if I was just simply
aware it existed. I can see in the email chain at [POL00148693] (which relates to
an initial review provided by ICL and their request for further documentation) that I
mention there being an overlap with the Deloitte and the ICL work. I also note that
I suggest having a meeting to discuss and understand this further with Julie
George. This may suggest that I did read the Deloitte report around that time, but I
simply cannot recall for certain. If I did read it, I do not think I would have carried
out any detailed analysis or review of it, given that as far as I am aware, I had no
involvement in commissioning or progressing this piece of work.
73.As far as my recollection goes, I do not think I ever considered whether points
raised within the Deloitte report casted doubt on the robustness of the Horizon
system and reliance on Horizon data when pursuing SPMs and/or dealing with their
claims in mediation. Reading the Deloitte report now I can see that it gives
indications as to the effectiveness of the Horizon system and sets
recommendations and actions, but again, I cannot say for certain if I even read this
at the time.
74. I do not know what work was carried out within POL in response to the Deloitte
Work.
SECOND SIGHT REPORT PART TWO: JULY/ AUGUST 2013
75. I have considered the following documents:
i. [POL00004439] (Second Sight Initial Complaint review and Mediation
Report, Part 1);
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ii. I [POLO0022150] (Second Sight Initial Complaint review and Mediation
Report, Part 2);
iii. I [POLO0207734] (Email from David Oliver to me regarding Second Sight Part
Two report, dated 21/08/2014);
iv. [POL00207767] (My email to Lesley J Sewell, Dave Hulbert, Neil Wilkinson
regarding the Second Sight Part 2 report, dated 22/08/2014);
v. [POL00148952] (Email from Belinda Crowe to Andrew Parsons and Rodric
Williams, me cc’d, regarding BBC request for an interview following Second
Sight Part 2 report, dated 05/09/2014); and
vi. I [FUJ00175066] (Email from lan O'Driscoll to Michael Harvey cc’ing James
Davidson, Pete Newsome and others regarding FOI request for a copy of
Second Sight Part Two Report, dated 03/10/2014)
76.1 cannot recall having any involvement with Second Sight in respect of the
preparation of their Part 1 and Part 2 Initial Complaint review and Mediation Report.
Given that part of my role in Project Sparrow involved being a point of contact into
Fujitsu and POL IT to action queries and requests, it is possible that I may have
assisted Second Sight with requests if they required information to complete their
report, but I cannot say this for certain and the documents provided to me do not
help me determine this.
77.Based on my recollection, I do not believe I would have had any involvement in
briefing the POL Board and POL Communications team in relation to Second
Sight’s Part 2 Report. However, I can see from [POL00207767] that I must have
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been tasked to inform POL’s IT department, Lesley Sewell (CIO) and Fujitsu about
the existence of the report and to provide a summary on what POL’s position was
in respect of it. The fact I did this is in keeping with my role within Project Sparrow,
where I often acted as a point of contact into POL IT and Fujitsu. From reading
this email now I believe that I would have drafted this summary having reached out
to others within the Project Sparrow team to learn more about the situation,
although I cannot recall who for certain.
78.1 note from my email summary at [POL00207767] that POL did not agree with the
content of Second Sight’s Part 2 report and in light of this, POL’s position was that
it should not get sent out to applicants in the Mediation Scheme. I have no
recollection if following my review of Second Sight’s Part 2 Report, that I also
personally disagreed with its content. Having re-read the Part 2 Report now I can
see it deals with a lot of operational matters, which is not an area I would usually
pick up or comment on.
79.Other than my actions set out in paragraph 77 above, I do not recall what other
steps I may have taken following Second Sight's Part 2 report. I believe it is likely
that there would have been internal meetings held within POL about the report, and
perhaps meetings with Fujitsu and Second Sight too, but I cannot remember if I
attended or helped to set up any of these meetings.
REFLECTIONS
80.1 have been asked to consider whether, in hindsight, there is anything that I would
have done differently in respect of the matters raised in this statement. Having
reflected on this, I feel that I can only respond based on what I knew or believed at
the time.
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81.If I had ever suspected there were systemic issues that compromised the integrity
of the Horizon IT system I would not have been willing to overlook this. However, I
sincerely believe I never suspected that any systemic issues existed. I
acknowledge that some documents provided with the Request do point to some
issues in relation to the system being identified and raised — such as the findings
in Second Sight reports, and some of the email correspondence I was copied into
— butas far as I can recall none of these issues provided me with a firm conclusion
that there were systemic issues affecting the integrity of the system. Given that this
was my genuine belief and knowledge at the time, I do not think there is anything I
would have done differently.
82.1 am truly saddened by the impact this has had on so many people’s lives. I would
like to express my sincere and heartfelt sympathies to all of those people who have
been effected.
83. Other than what I have set out in this statement, there are no other matters that I
wish to bring to the attention of the Chair
Statement of Truth
I believe the content of this statement to be true.
Dated: 12 November 2024
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Index to First Witness Statement of Andy Holt.
WITN11040100
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No.
URN
Document
Control Number
. POL00193406
Email from Simon Baker To:
(Angela Van-Den-Bogerd, Andy
[Holt CC: Susan Crichton RE:
(Could we get together on Thurs
please
POL-BSFF-0031469
IPOL00193604
[Email from Andy Holt To: Simon
Baker, Susan Crichton, Angela
an-Den-Bogerd and others re
[Training day
POL-BSFF-0031667
IPOL00197019
Presentation on roles and
responsibilities for POL Officers in
relation to the Mediation scheme
POL-BSFF-0035082
IPOL00105609
Email chain from Antonio Jamasb
ito Dave Hulbert re Horizon - whole
Inetwork service outage.
POL-0104613
IPOL00182875
Email chain from Andy Holt to
Andrea Harwood, Matt Sadler and
jothers re Post office clerk needing
lenlightening on our future within
POL-BSFF-0020938
IPOL00192699
[Email chain from Simon Baker to
(Angela Van-Den-Bogerd, Rod
Ismay, Andrew Winn and others
IRe: Stock adjustment issue and
response
IPOL-BSFF-0030762
IPOL00145546
Email from Steve Beddoe to
Simon Baker, Dave Hulbert, Chris
[Taylor and others re horizon
improvements
IPOL-BSFF-0004673
IPOL00297788
Horizon Investigation Level 1 plan
001 20130719
IPOL-BSFF-0135838
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IPOL00060722
Email from Alwen Lyons to Simon
Baker re transaction corrections -
Jo Hamilton's case
IPOL-0057201
10)
IPOL00297905
[Email chain from Rod Ismay to
Simon Baker, Andy Holt and
(Angela Van-Den-Bogerd re: FW:
[SPMRs] Stock adjustments -
is Ch.
tarfiald Dact
IPOL-BSFF-0135955
11)
IPOL00297984
[Email from Ron Warrington to
Simon Barker, Angela Van Den
IBogerd, IRH RE; second sight
investigation into shortfall of
£6,000.00 on the 4th of November
2009 in post office branch
IPOL-BSFF-0136034
12)
IPOL00193030
Email from Gayle A Peacock to
(Angela Van-Den-Bogerd, Amanda
IK Stevens, Rod Ismay and others
re: Branch Support Programme -
Response by midday Friday 2nd
‘ould be appreciated
IPOL-BSFF-0031093
13]
IPOL00193031
Branch Support Programme —
[Terms of Reference v.2
IPOL-BSFF-0031094
14,
IPOL00413701
[Email from Simon Baker to Lesley
\J Sewell, Cc'd Andy Holt Re:
Replacement of Horizon
IPOL-BSFF-0233875
15)
IPOL00145915
[Email chain from Mark R Davies to}
Martin Edwards, Chris M Day,
\Susan Crichton and Others re
Fwd: Horizon National Media
Enquiries
IPOL-BSFF-0005042
16)
IPOL00298276
[Email from Ruth Barker to Mark R
[Davies CC'd Susan Crichton, And
IHolt and others RE; Media
IPOL-BSFF-0136326
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17]
IPOL00298403
[Email from Susan Crichton to
Angela Van-Den-Bogerd cc'd Andy
Holt re: Horizon review workflow
IPOL-BSFF-0136453
18]
IPOL00344252
Email from Andy Holt to Lesley J
[Sewell re Horizon Core Audit
Process - v1 O.ppt
IPOL-BSFF-0169973
19)
IPOL00022598
[Horizon Data Lepton SPSO
191320 by Helen Rose (v.1 draft)
IPOL-0019077
20]
IPOL00202688
Bond Dickinson email - forwarded
emails between PO and Howe &
Co re disclosure in Post Office
mediation claims.
IPOL-BSFF-0040751
21)
IPOL00303963
Email from Rod Ismay to Andy
[Holt re: 2010 Report
IPOL-BSFF-0142013
22!
IPOL00029666
IPOL Spreadsheet of Second Sight
fork Stream (Outstanding
(Actions)
IPOL-0026148
23]
IPOL00134525
Powerpoint of Second Sight
IMediation Process
IPOL-0138978
24;
IPOL00099265
[Email chain involving Simon
Baker, Alwen Lyons, Susan
(Crichton and others. Re: "Current
cases".
IPOL-0098848
25]
IPOL00192267
[Email from Simon Baker To: Ron
farmington, lan Henderson CC:
[Susan Crichton and others re
IPOL-BSFF-0030330
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26
IPOL00192335
[Email from Martin Edwards to
Simon Baker, Alwen Lyons and
lothers re: briefing note for
IPaula/JA meeting.
IPOL-BSFF-0030398
27)
IPOL00297804
[Email from Martin Edwards to
Mark R Davies RE: Briefing Note
for Paula/James Arbuthnot
Meeting.
IPOL-BSFF-0135854
28 I
IPOL00117036
[Email from Simon Baker to Paula
ennells, Martin Edwards, Mark R
[Davies and others re Horizon
Investigation / JA meeting - notes
from today's 4.30 meeting,
includes actions and items to
discuss with JA. Case review
process diagram attached.
IPOL-0117870
29)
IPOL00407565
Email from Gareth Jenkins to
Simon Baker, Cc'd Andrew Winn,
[Pete Newsome and others Re:
ISPMRs Stock Adjustments
IPOL-BSFF-0232633
30]
IPOL00137330
\Sub-Postmaster Improvements &
IMediations Weekly Steering Group
IPOL-BSFF-0000096
31)
IPOL00162011
Email from Sophie Bialaszewski to
(Andy Holt and Mark Davies, re
[Horizon Investigation Level 1 plan
(006 20130808. ppt.
IPOL-0150456
32)
IPOL00413697
[Email from Kay Linell to Susan
(Crichton, Simon Baker, lan
[Henderson and others Re:
Membership and voting on the
orking party
IPOL-BSFF-0233871
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33]
IPOL00417109
Post Office Sub-Postmaster
Improvements & Mediations:
leekly Steering Group report and
lagenda.
IPOL-BSFF-0237260
34
IPOL00298382
[Email from Alan Bates to Simon
Baker, Kay Klica, Irh Advanced
Forensics and others
IRE;Comments on Phase 1 Pack
IPOL-BSFF-0136432
35;
IPOL00298419
Email from Rodric Williams to
Lesley J Sewell and cc'd Simon
IBaker, Andy Holt and others re:
[Draft Letter to Fujitsu
IPOL-BSFF-0136469
36I
IPOL00298446
Email from Sophie Bialaszewski to
Andy Holt, Rodric Williams and
Rosie Gaisford re: Mp Handling
Plan
IPOL-BSFF-0136496
37]
IPOL00146190
Email from Andy Holt to Susan
(Crichton, Angela Van-Den-Bogerd,
(Alwen Lyons and others - Re:
forking Party Dial-in for Training
IDay
IPOL-BSFF-0005317
38I
IFUJ00235737
Email from Pete Newsome to
IGareth Jenkins Cc'ing Torstein
\Godeseth re: Update on Post
(Office Mediation Process for Sub-
[Post Masters
IPOINQ0241842F
39]
IPOL00139864
[Email chain from Andy Holt to
[Martin Smith RE: Post Office Ltd?
+? Weekly update
IPOL-0141040
40,
IPOL00327060
Email from Laura Pinkney to
landy.holt' CC ing martin smith;
I'Jarnail A Singh’. RE: Weekly
Update
IPOL-0173563
Page 34 of 39
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41]
IPOL00299609
[Email from Susan Crichton to Alan
Bates, Paula Vennells, Angela
‘an-Den-Bogerd and CC: Others
IRE: Post Office Read This RE:
[Martin Griffiths
IPOL-BSFF-0137659
42)
IPOL00116135
[Email from Martin Edwards to
Andy Holt, Angela Van-Den-
IBogerd, Mark R Davies re Note of
meeting with Sir Anthony Hooper
IPOL-0117134
43]
IPOL00372534
[Email chain from Andrew Parsons
ito Andy Holt, Cc'd Susan Crichton
jand Rodric Williams Re: FW:
IMO25 - Darren King [BD-
4A.FID20472253]
IPOL-BSFF-0199927
44I
IPOL00123003
[Email from Andrew Parsons to
Andy Holt, cc Gavin Matthews,
Belinda Crowe and Jarnail Singh
re: Sparrow - text for CEO's report
IPOL-0129227
45]
IPOL00301456
[Email from Andy Holt to Angela
‘an-Den-Bogerd re: CT 1415a
Mediation: urgent requests.
IPOL-BSFF-0139506
46)
IPOL00199985
[Email from Andy Holt to Angela
an-Den-Bogerd Re: CT1415a
Mediation: Urgent requests
IPOL-BSFF-0038048
47]
IFUJ00239552
Email from Andy Holt to Pete
Newsome, Michael Harvey, James
[Davidson RE: Fw: Reactive lines
IPOINQ0245657F
48]
IPOL00195750
[Email from lan Henderson to Andy
Holt, Dave M King, Ron
farmington & Ors RE: Access to
back office accounting systems
IPOL-BSFF-0033813
49)
IPOL00220859
Email from Belinda Crowe to Andy
Holt, Angela Van Den Bogerd,
Belinda Crowe and others - Re:
IFW: Email retreival
IPOL-BSFF-0058922
Page 35 of 39
WITN11040100
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50)
IPOL00148887
[Email from Belinda Crowe to Chris
Aujard, CC'ing: Belinda Crowe,
IRodric Williams and others - Re:
Email retrieval
IPOL-BSFF-0008007
51)
IPOL00367583
[Email from Angela Van-Den-Boger
ito Andy Holt, Jessica Barker re:
IURGENT ACTION PLEASE
IPOL-0185714
52)
IPOL00091394
Email from Melanie Corfield to
Belinda Crowe, Rodric Williams,
(Angela Van-Den-Bogerd; re: M053
Revised Draft CRR
IPOL-0090416
53)
IPOL00211254
[Email from Andrew Parsons to
IRodric Williams, Belinda Crowe re:
[Horizon Access [BD-
4A.FID20472253]
IPOL-BSFF-0049317
54]
IPOL00349653
[Email chain from Andrew Parsons
ito Belinda Crowe, Rodric Williams
jand others re: Remote access
IPOL-BSFF-0175374
55]
IPOL00099063
Signed Interim Report into alleged
problems with the Horizon system
IPOL-0098646
56]
IPOL00116179
Email from Sarah Paddison to
Andy Holt, Susan Crichton, Angela}
‘an-Den-Bogerd and others re
Project Sparrow steering group
IPOL-0117178
57]
IPOL00146704
[Email from Andy Holt - Project
Sparrow Update, to Alwen Lyons
IPOL-BSFF-0005831
Page 36 of 39
WITN11040100
WITN11040100
58)
IPOL00196926
Project Sparrow Overview
document
IPOL-BSFF-0034989
59]
IPOL00139000
Sparrow Steering Group - Key
Points and Actions from Meeting
IPOL-BSFF-0001220
60,
IPOL00158093
Email from Belinda Crowe to Andy
Holt, Angela Van-Den-Bogerd,
IMark R Davies and others re:
Scope and Resources for Project
Sparrow
IPOL-0146626
61)
IPOL00300571
[Email from Rodric Williams to
Michael Harvey Re: Expert on the
[Horizon System - Subject to
(Common Interest Privilege
IPOL-BSFF-0138621
62I
IPOL00199809
Email from Jarnail Singh to Chris
(Aujard CC'ing Hugh Flemington,
Andy Hold and others RE: Budget
land Draft Appointment of
Indanandant Harizan Evnart far
IPOL-BSFF-0037872
63)
IPOL00148693
[Email chain from Andy Holt to
Jarnail Singh Andrew Parsons cc
Andrew Pheasant Gavin Matthews
Martin Smith & others RE: Expert
IPOL-BSFF-0007814
64
IFUJ00236423
Email from James Davidson to
Bell Gavin, cc Michael Harvey re
IFW: ICL initial review and requests}
IPOINQ0242528F
65]
IFUJ00238073
Fujitsu report on Horizon integrity
by James Davison
IPOINQ0244178F
Page 37 of 39
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WITN11040100
66I
IPOL00348522
Email chain from Andy Holt to Neil
ilkinson, Lesley J Sewell, Dave
[Hulbert and others re: The Round
[Table Meeting with the IT Experts
IPOL-BSFF-0174243
67]
IPOL00148950
Email from Jarnail Singh to
(Andrew Pheasant, Jessica
IMadron, cc'ing Andrew Parsons
jand others re: CK Draft
Instructions to Expert
IPOL-BSFF-0008070
68
IPOL00325918
[Email from Andrew Pheasant to
Jarnail Singh, Martin Smith,
(Andrew Parsons and others Re;
ICK Draft Instructions to Expert
[BD-4A.FID20472253]
IPOL-0173053
69]
IPOL00148749
Advice from Cartwright King
Solicitors re matters of concern
arising out of the instruction of
Imperial Consultants Limited
IPOL-BSFF-0007870
70I
IPOL00264768
Email from Julie Gpoerge to
Belinda Crowe, Andy Holt Re: RE:
[Horizon
IPOL-BSFF-0102831
71)
IPOL00028062
Report: Horizon Desktop Review
lof Assurance Sources and Key
(Control Features - draft for
discussion, Deloitte
IPOL-0023065
72)
IPOL00304662
[Email from Andy Holt to Dave M
King, Rodric Williams and cc'd
Jarnail Singh re: FW: Document
List for Post Office Horizon Expert
itness Engagement
IPOL-BSFF-0142712
73)
IFUJ00241523
Fujitsu - POL - Mediation Update.
IPOINQ0247628F
Page 38 of 39
WITN11040100
WITN11040100
74,
IPOL00004439
Initial Complaint Review and
[Mediation Scheme - Briefing
Report - Part One - Prepared by
Second Sight
1$00005507
75]
IPOL00022150
Initial Complaint Review and
Mediation Scheme - Mediation
Briefing Report: Draft V2
IPOL-0018629
76I
IPOL00207734
[Email from David Oliver to Andy
Holt, Rodric Williams and Belinda
Crowe, re: Second Sight Part Two
report
IPOL-BSFF-0045797
77)
IPOL00207767
Email from Andy Holt To: Lesley J
Sewell, Dave Hulbert, Neil
ilkinson re URGENT FW:
Second Sight Part Two report
IPOL-BSFF-0045830
78I
IPOL00148952
Email from Belinda Crowe (POL)
ito Andrew Parsons (WBD); Rodric
illiams (POL) & Others Re:
[Request for an interview following
second sight investigation
IPOL-BSFF-0008072
79]
IFUJ00175066
[Email from lan O'Driscoll to
Michael Harvey CCing James
Davidson, Pete Newsome and
jothers re: RE: Freedom of
Information Act Request re:
Second Sight Part Two Report
IPOINQ0181247F
Page 39 of 39