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Witness Name: Elliot Jacobs
Statement No.: WITN11180100
Dated: 15 August 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ELLIOT JACOBS
I, ELLIOT JACOBS, will say as follows...
1. I am a Non-Executive Director (“NED”) on the Board 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 dated 3 June
2024 (the “Request’), relating to Phase 7 of the Inquiry’s work.
3. I have been asked to address the following topics:
(a) Professional Background;
(b) Experience on POL Board;
(c) A Times article dated 19 February 2024; and
(d) Any other matters.
4. For ease of reference, and to assist the Inquiry, I have set out the queries
contained in the Request as subheadings to this statement.
5. In preparing this statement I have endeavored to identify documentation that
may assist my recollection and I have referred to such documentation in this
statement where appropriate. Where I have been unable to provide
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documentation, I have endeavored to identify the source of such
documentation.
PROFESSIONAL BACKGROUND
4, Please summarise your educational and professionalqualifications
I attended Highgate School in London leaving in 1993. I did not attend university.
My first job was working at a local stationery shop called Universal Office
Equipment (later known as UOE) in 1989. Between 1996 and 19981 worked ata
computer games business as a European Channel Marketing Manager andalso
at an accounting software company as a Sales Manager.
In 1998, I purchased 100% of the shares of UOE and assumed the role and
responsibilities of the Chief Executive Officer (“CEO”). Shortly afterwards, I
established the online business-to-business stationery division of UOE. In 2014
UOE was considering exiting its retail division, but I saw that the Post Office were
looking to franchise branches and considered it a retail opportunity. UOE
negotiated a franchise agreement with the Post Office in 2014 and successfully
combined it with its retail operations. Over the following years I negotiated multiple
franchises with the Post Office. To date, UOE has 8 stores and Post Offices in
East Finchley, Potters Bar, Crouch End, Muswell Hill, Hertford, Camden, Stoke
Newington and Ware, as well as a Banking Hub in Ware. The branch in East
Finchley won Independent Post Office of the Year in 2018. I also operate a co-
working business in Hertford. The business-to-business division of UOE was sold
in a successful trade sale in 2019 as I wanted to focus efforts and growth on the
retail and Post Office division.
In addition to my experience as CEO of UOE, I have sat on the boards of several
not-for-profit organisations:
(a) Between 2003 and 2023 I was a NED on the board of Office Friendly,
a not-for-profit cooperative association of 120 to 130 office supply
companies that buy and market collectively, with annual group
revenue in excess of £200m. Between 2010 and 2014 I was Chair of
Office Friendly, contributing to its growth as a leading organisation.
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(b) Between 2015 and 2016 I was a NED on the board of BOSS
Federation, the trade association for the business supplies industry,
playing a role in reshaping the organisation's strategic direction and
leadership.
In addition to the above, since 20111 have been training entrepreneurs across the
globe on how to develop fast-growth strategic plans on behalf of the
Entrepreneurs Organization, a notfor-profit group with over 20,000 members in
more than 100 countries. I have simultaneously been a mentor on the London
Business School's Entrepreneurship Programme. Finally, since 2021 I have been
one of two postmaster NEDs elected by postmasters and appointed to the POL
Board. I have set out further information regarding my appointment to the POL
Board below.
2. Please summarise your career background and your appointment to the
POL . i
As set out above, I have over 26 years of experience on boards of various
organisations. I have beena NED on the POL Board for three years. I understand
that POL decided to create two postmaster NED positions following the Group
Litigation Order (“GLO”). The appointment of the postmaster NEDs means that
for the first time, real-world experience and postmasters’ experiences and
perspective are brought to life and into the decision-making process of the POL
Board.
An advert for the two postmaster NED positions was promoted on the weekly
email written by Amanda Jones (the then Retail and Franchise NetworkDirector)
and distributed to all postmasters. I understand that Green Park (an external
agency) validated the applications and selected candidates that were considered
the most suitable based on criteria. I cannot recall all of the criteria used in this
process, but I remember that I appealed one of the gating requirements during the
application process. The gating criteria required applicants to receive a certain
number of positive reviews on the interna-facing Post Office review system. UOE
uses online Google reviews because we prefer that reviews are visible to the
public, but these reviews are not recorded on the internal Post Office system and
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therefore did not qualify for counting within their gating policy. POL agreed to
waive this gating requirement in the light of our reasonable explanation.
I was shortlisted by Green Park in a group of twelve candidates and interviewed
by a panel. The panel was comprised of representatives of the POL Board
including some existing NEDs, and the Head of the Association of Convenience
Stores. I recall that I was also interviewed by the Chair, Tim Parker. POL then
shortlisted four candidates for the postmasters to vote for as their representatives
based on the scores from the panel. There was an online husting followed by a
vote, where each postmaster had one vote. Mr. Ismail and I won the most votes
and were elected as postmaster NEDs. We then went through final vetting and
clearance before being approved by the Secretary of State. I estimate that the full
process took around five months.
I have sat on the POL Board since June 2021 and was due to step down in June
2024, but my term has now been extended to June 2025to ensure there is greater
continuity between the current postmaster NEDs and our successors (who are at
this time still unappointed). I applied to stand again as a postmaster NED for a
second term, but I have not been shortlisted as a candidate. I understand that
there is a gating criterion that requires the postmaster applicants to reach 90% of
daily cash declarations in all branches that they operate. Postmasters have not
previously had visibility of the cash declaration metric and the metric doesnot take
into account that there are a number of reasons that a postmaster may not cash
up a machine. For example, it does not take into account a self-service machine
crash or a postmaster logging onto another machine and not knowing a previous
login was created on another Horizon terminal even if no cash transactions were
made (just one of the many oddities of the Horizon system). If you blend all of
UOE'’s branches, they would reach approximately 90% cash declarations, but one
or two branches may fail due to the types of issue above. My understanding is that
it is significantly more difficult to reach 90% cash declarations if you have multiple
tills and multiple branches within a business.
Mr. Ismail and I spoke with the Engagement Team when they were planning the
process for recruiting postmaster NEDs as we were keen to ensure as many
applicants as possible could apply for the role. We were not asked to review
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potential metrics for the application process and this metric was not proposed to
us. I would have expressed that this metric was at the time impossible for
postmasters to measure themselves and not reflective of whether postmasters
are suitable candidates. I appealed the criterion but was informed that the
requirement could not be contested despite the fact that it was unmeasurable at
branch level and irrelevant to the actual work being undertaken as a NED.
3.P . 7 f_ and .
Horizon IT system
I oversee 8 UOE stores and Post Offices and a Bank Hub and have direct
experience of the Horizon IT system as a postmaster. I have set out an overview
of my experience below.
The Horizon IT system is a legacy system built over two decades ago that is
outdated and would not be selected for use in the present day. It is not an intuitive
system, and it takes a significant amount of time to become competent in its use.
It does not enable postmasters to export and easily analyse data effectively. The
ability to interrogate and locate transaction errors remains incredibly challenging
even for skilled operators and postmasters (although this has been improved
recently with the addition of Branch Hub reporting tools). For example:
(a) It is not a visual, user-friendly system. The system is primarily text
based and there are few command prompts.
(b) It is difficult for postmasters to analyse data and correct potential
inaccuracies on the system. It then takes significant effort and often a
manual review of transactions to investigate a potential error.
(c) Postmasters that run multiple branches cannot obtain a global view of
data and are required to be physically present at the relevant Post
Office to interrogate data on Horizon in anything close to real time.
This makes oversight and reporting difficult.
(d) I The Horizon IT system is effective as a functioning till, but it is not
sufficiently sophisticated to manage and analyse a modern business
as a professional postmaster.
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POL’s tolerance to errors at postmaster/branch level is £0.00, which does
not reflect that c.520 million transactions are being recorded on an outdated
system which statistically may result in untraceable errors. Postmasters face
an additional burden of manually monitoring and verifying transactions
recorded electronically on a system that has a margin of error which is higher
that the tolerance permitted and for many different reasons is difficult to use.
For example, at UOE I have implemented daily manual reports at every
branch due to our fear of the reliability and the risk of significant ramifications
if errors are identified too late to be traced easily.
Experience of POL Investigation
I have direct experience of inaccurate accounting data leading to a POL
investigation into the accounts I oversee as a postmaster. In March 2023 I
received a call from the POL Chair, Henry Staunton, who informed me that the
Finance Department had a query regarding UOE’s Horizon accounts. Mr.
Staunton asked me to speak with Ben Foat, Group General Counsel, regarding
the investigation. I spoke with Mr. Foat and he was not able to provide further
details and proposed I speak with the POL Investigations team.
On 14 March 2023, I received an email from Andrew Morley, Senior Investigations
Manager within the POL Central Investigations Unit (CIU) (WITN11180101, page
5). The email copied John Bartlett, Head of the CIU, which sits within Legal,
Compliance and Governance at POL. The email informed me that the CIU and
Mr. Morley had reason to investigate alleged discrepancies at Post Offices
operated by UOE. I was asked to attend an interview to discuss the alleged
discrepancies. I agreed to attend an interview on 5 April 2023.
On 15 March 20231 received a letter from Mr. Bartlett formally inviting me to attend
a meeting at POL’s offices on 5 April 2023 with Mr. Bartlett and Mr. Morley to
discuss (1) the alleged accumulation of shortfalls in POL’s operations, (2) potential
conflicts of interest that I may have during POL Board meetings relating to
discussions of recovery of shortfalls from postmasters, and (3) potential issues
surrounding a Director's Declaration I signed on a Post Office Director
Remuneration form (WITN11180102). I was permitted to bring a friend, a
National Federation of Sub Postmasters (NFSP”) representative, a colleague, or
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a legal representative to the interview. However, they were not permitted to
answer questions on my behalf.
On 16 March 2023, I emailed Mr. Morley to request an Excel format of the PDF
statement so that I could interrogate the data. I noted that the documents enclosed
with the letter inviting me to interview were not in date order and contained no
explanation or notes for each line. I also requested original transaction data
(WITN11180101, pages 3-4). Mr. Morley asked me to address my requests to
the Postmaster Support Team (“PAST’), which was the first time I had heard of
the team (WITN11180101, page 3). I responded that it would be quicker for Mr.
Morley to provide me with the documents on the assumption that he had collated
and reviewed the data as part of his investigation (WITN11180101, page 2). Mr.
Morley separately spoke with PAST who agreed to provide additional information
and noted that it would take some time to collate the information (WITN11180101,
page 1). I was surprised that the CIU and Mr. Morley were able to make serious
allegations of discrepancies within UOE accounts without appearing to review the
full data relevant to the alleged discrepancies. I expressed my concems to Mr.
Morley and noted the significant distress the investigation had caused
(WITN11180101, page 1).
On 20 March 2023, Mr. Morley emailed me to update me that the CIU were
continuing to work to provide me with the requested advanced disclosure and
asked me to confirm that the interview could be recorded (WITN11180103, page
2). I responded that I would await proper and full disclosure of the materials and
would then take the matter under advisement. I also asked for further information
regarding the allegations and the evidence on which the CIU were relying, as well
as who within or outside POL had knowledge of the allegations (WITN11180103,
page 2). Mr. Morley replied that he did not intend to “enter into pre-interview
protected correspondence regarding disclosure’ which he had “no legal obligation
to provide”. I was advised by Mr. Morley that if I declined an audio recording of
the interview and elected for contemporaneous notes this could increase my
interview time to 6 hours (WITN11180103, page 1). I was surprised that I was not
able to access materials relevant to my interview easily to best assist the
Investigations team.
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I attended the interview on 5 April 2023 with a member of my family present for
support. I found the process extremely stressful and was concerned about the
allegations put to me. Having read the harrowing cases of unfairly prosecuted
postmasters and the way POL treated them previously, this experience had
significant echoes of the past. The fact that POL had a history of dealing with
postmasters unfairly, gave me extreme concem. The letter inviting me to attend
the interview stated that this was, “not an “under caution” interview; it is an
opportunity for both you and the investigators to discuss the three areas identified
above to increase understanding of what has happened’ (WITN11180102, page
2). I considered the interview to be an interrogation and adversarial; it was not a
collaborative discussion. The interview was similar in style to a formal police
interview as the questions put to me were interrogatory and the documents were
put to me asexhibits.
During the interview I was informed that auditors would be visiting my branches
the next day to audit UOE’s branches at the same time as the investigation. As a
result, I had to cease trading at short notice for two half days. When the auditors
attended, they informed me they intended to make adjustments to my Horizon
stock balance as they claimed I was “missing stamps” that they had identified as
being sent but not received. They did not provide any evidence to support this
allegation. They logged onto my system with their own access ID and put the
alleged “missing stamps” onto the system, despite my request to not do so. They
told me, “you can dispute it later’. This felt very wrong. As background,
postmasters are required to record stamps manually on the Horizon system. We
receive a bag containing multiple stamps which we scan onto the Horizon system,
but the specific stamps contained in the bag are not recorded automatically on the
system. We therefore must manually review and record the stamps provided. As
a result, it is possible that sometimes inaccurate records of stamps are received
and it can be difficult to establish whether the error was in the branch or the stock
centre. In contrast, when postmasters receive cash, we scan barcodes that
automatically record the precise amounts and denomination of the cash received
to us into ourHorizon system.
I spent significant time reviewing the alleged discrepancies (including the
additional stamps which had been put onto my system) and disproved the vast
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majority. It was not proven that the remaining discrepancies were accurate or that
UOE owed any money to POL, but on the balance of probabilities and because I
could not prove that I did not owe these amounts, I agreed to pay a small amount
to reflect an amount that was not accounted for over a 10-year period across 8
UOE branches. A few weeks after this POL identified an accounting error in UOE’s
favour related to stamps. This amendment meant the net amount owed by UOE
was nearly cancelled out entirely. I was concerned that postmasters in similar
situations may not have the ability or resources to spend significant time working
through very detailed data to respond to the alleged discrepancies. I was
surprised that the investigation took an adversarial, accusatory approach following
the lessons learned about the inaccuracy of Horizon IT data and the nature of
investigations into postmasters. As part of the investigation, it was identified that
my branches had not had the “dispute” button activated on their Horizon Trading
Period settlement screen and so the process for reporting discrepancies had
therefore not been properly setup by Post Office and alternate processes had not
been clearly outlined or trained by POL. I accepted the offer of additional training
for my Branch Managers on remuneration declarations and logging disputes. It
was also accepted that there needed to be greater clarity on the process for
identifying conflicts of interest reported in Board papers at the outset of Board
meetings.
On 16 January 2024, I emailed Melanie Park, Central Operations Director in the
Retail Team, to confirm the finalised reporting on UOE’s account and provide
written confirmation of the withdrawal of the investigation (POL00448303). Ms
Park responded that she would speak with the Legal team. I forwarded the email
to Mr. Staunton and Mr. Ismail to notify them that UOE’s trading account had not
been updated with the removal of the invalid claims of losses and a letter of
withdrawal had not been issued (POL00448303). I did not understand the delay
in resolving the issue, which first began in March 2023. Mr. Staunton responded,
copying POL CEO Nick Read, noting the unsatisfactory handling of the matter and
recognising the “tremendous upset” caused.
On 8 February 2024, I received a letter notifying me that the investigation had
been closed (WITN11180104). This was almost a year after the investigation
opened
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and my interview was conducted. The letter noted that recommendations had
been made to the Corporate Secretariat that instructions, training and advice to
future potential Directors should be improved in relation to the declarations on
remuneration. As a result of the accusations made against me, the way that
conflicts are reported changed so that only new conflicts are noted and there is
standing notice of other conflicts in minutes.
EXPERIENCE ON POLBOARD
4. Prior to, or on being appointed to the POL board, did you receive any training
relevant to the role? If so, please summarise the nature of this training.
To the best of my recollection, save for a communication on expenses, I was not
provided with written training manuals orsupporting documentation.
In the last two weeks of May 2021, and before my formal appointment to the POL
Board, I had approximately 15 to 20 calls with individuals from various
departments. These calls included briefings with the Group COO Owen Woodley,
internal audit Johann Appel, Group General Counsel Ben Foat, Group CIO Jeff
Smyth, and the CEO Nick Read.
I also attended training with the Institute of Directors and Notum Training (an
external training provider). The latter provided an overview of the responsibilities
of a NED and key attributes expected of NED, such as how to have constructive
conversations with senior individuals within the business and not to take on an
Executive role, and understanding who we represent. It was important that we
understood who we represent as we had been elected by postmasters but our
role as NEDs was not to act solely on their behalf but for the good of the company
and its wider stakeholders. This remains a difficult balancing act that Mr. Ismail
andI have had to navigate to ensure we bring fair challenge whilst avoiding conflict
from our role as a postmaster. As far as I recall, there were no printed training
materials produced from or for the sessions.
I was buddied with another NED, Lisa Harrington, which was an informal
arrangement where Ms Harrington would support me if I had queries. Ms
Harrington had significant experience from her time as Chief Customer Officer at
BT and I considered that she had a detailed understanding of technology. I was
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also introduced to Beatrice Fraenkel, Chair of Merseyside NHS Foundation Trust,
to witness her leading a Merseyside NHS Foundation Trust Board meeting via
Teams.
The GLO concluded before I joined the POL Board as a NED. I did not receive a
briefing or summary of the GLO when I joined the POL Board. I referred to external
resources, such as books and television series, to gain a more in depth
understanding of the GLO. No corporate overview was provided of POL’s
understanding of the issues or learnings arising from the GLO.
In my experience, the POL Board had not considered the infrastructure and
training required to support postmaster NEDs with what is a significant role.
5. What briefings, if any, did you receive on the issues addressed by the Inquiry.
such as the Horizon IT system, the prosecution of subpostmasters and the Group
Litigation Order (GLO) on joining the POL board? If you received such briefings.
please reflect on theirquality.
The POL Board spends a lot of time dealing with the past and Board members
are regularly briefed on matters which are linked to the issues addressed by the
Inquiry, as discussed below. I received briefings on the core issues addressed by
the Inquiry upon joining the POL Board. However, I felt that significant further
understanding was necessary, so I spent additional time reading and referring to
external sources such as books and the media to ensure I had a sound
understanding of these issues.
I have set out below my experience of the briefings and meetings which take place
at POL.
Regular Board Meetings
The POL Board meets formally every six to eight weeks, but additional ad hoc
meetings often take place in the interim. Prior to each meeting, Board members
receive detailed briefing packs via a system called Diligent, which are generally a
couple of hundred pages long. Additional papers were sometimes provided in the
“Reading Room,” but this is no longer the case.
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Board packs have evolved over time and now generally include minutes from the
previous meeting(s), an action tracker, a report from the CEO, and briefings which
fall under the main headings of Finance, People, Transforming Technology,
Rebuilding Trust, and Governance.
The CEO report provides a holistic picture of the current status quo at POL
including - at a high level - updates relating to issues addressed by the Inquiry,
such as the GLO Compensation Scheme, overturned convictions, the Horizon
Shortfall Scheme, postmaster engagement, culture, Horizon IT services and new
technology (such as the “Strategic Platform Modemization Project’ (“SPMP”),
which was set up to develop a replacement for the Horizon IT System). The other
briefings are more specific, focused updates on these topics, specific projects, and
other POL business matters. Some of these briefings are connected to issues
addressed by the Inquiry in some way, others are not. During Board meetings we
also receive verbal briefings from various committees and groups, including those
tasked with overseeing Inquiry related matters like compensation, such as the
Remediation Committee, Nominations Committee (‘NomCo”), and the People
team. Where Board briefings are connected to Inquiry related issues, the focus is
mainly on functional process and approval of funding rather than focusing on
lessons learned.
The quality of the briefings is mixed but there is flexibility to attend pre-briefings
and request further information if required. Generally, the papers are not strategic
and do not suggest or recommend an outcome; they instead provide significant
information for Board members to review, note or make a decision on.
Other Board meetings
In addition to regular Board meetings, POL holds annual Strategy meetings over
the course of two half days. These meetings do not tend to deal with issues
addressed by the Inquiry but plans for the future. The purpose of the meetings is
to discuss potential ideas but, in my opinion, they are not productive as there is
limited execution of ideas.
When I joined POL, I attended a small number of Criminal Case Review
Commission (“CCRC’) meetings which focused solely on historical remediation,
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looking at Court of Appeal Criminal Division (“CACD”) cases and the Horizon
Shortfall Scheme. The meetings were established by former Chair, Tim Parker,
so that these matters could be considered outside of regular Board meetings. My
understanding is that the CCRC did not constitute a formal subcommittee and it
was disbanded shortly after I joined POL. It was replaced by the Historical
Remediation Committee - now called the Remediation Committee - which is
chaired by Ben Tidswell. No postmaster NEDs sit on this committee. The minutes
of the CCRC meetings I attended are legally privileged, and I have not appended
copies of the minutes to this statement.
Committee Meetings
Board members sit across the various committees at POL, but committees have
their own meetings separate to the Board. Although I am not part of it, I understand
the Remediation Committee is responsible for reviewing Horizon-related cases to
be appealed before the CACD. Previously, I had no knowledge of these
discussions beyond the brief verbal update provided by the committee during
Board meetings. However, in an attempt to cultivate greater transparency, the
minutes of the meetings are now being disseminated outside of the committee,
and non-members can request to attend themselves as “observers” and receive
copies of minutes.
I siton two committees at POL as a NED: the Audit, Risk and Compliance (“ARC”)
committee, and the Investment Committee. The remit of the ARC Committee is
laid out in its terms of reference and includes dealing with risks arising in the
business. The business has a large number of “high” risks. This makes identifying
one high risk from another high risk difficult and the prioritising of risk challenging.
This was highlighted in the recent Grant Thornton report, which I have set out
further details of later in my statement. The Investment Committee deals with
major investment projects across the business. I understand that it was
established because the Board lacked sufficient oversight on multiple projects with
over £50 million expenditure which were not in budget or on time and that the
committee was expected to monitor and challenge the progression of projects.
The Quality of Briefings
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I have generally found the briefings I have received as a POL Board member to
be of poor quality and often incomplete. Papers rarely propose an outcome or
recommendation, and it is often not clear what the author or sponsor of the paper
thinks is the appropriate course of action. Instead, the information is simply
presented to the Board and we are expected to make a decision for the Executive.
Board members have flexibility to engage with the executives writing the briefings
to get a deeper understanding of a matter, and with bigger topics there will
generally be a “pre-briefing” session as mentioned, but this is insufficient to
address the issue. During briefings I regularly question the quality and accuracy
of data provided. For example, on 15 July 2024, I attended an Investment
Committee meeting where I pointed out that the data provided in the briefing
around phase completion dates conflicted with the information given to the
committee earlier in the year. The committee was informed that a phase would be
completed by June 2026, whereas in the previous meeting we had been informed
that the phase would start in June 2026. The milestone was both important and
significant as it related to the Horizon replacement internally referred to as SPMP
or “New Branch IT” (“NBIT’). It was acknowledged that the data provided in the
July documentation was incorrect and therefore misleading. Although not
deliberate, I do feel that POL has a tendency to blend accurate data with
inaccurate data meaning the true picture on a project is often skewed and can
result in the Board (or committee) not being fully informed when making a
decision. A further strategic review is being undertaken with Teneo (another
external provider) to improve how the business is run andits strategic focus, which
I have dealt with in further detail below.
Past Roles and Project Phoenix
The Board also receives briefings on Past Roles and Project Phoenix. Until
recently this was only referred to at Board level as “Phoenix,” but has now been
separated into the two separateworkstreams.
(a) My understanding is that Project Phoenix is the investigation of any
current POL employee in the business at the time that postmasters
were wrongfully convicted who could have been involved in their
conviction. The intention was to identify the employees, categorise
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them and identify whether it was appropriate for them to remain in the
business. Project Phoenix is the confidential project name and I
understand that there are no formal Terms of Reference.
(b) Past Roles is the review of current employees within the Remediation
Unit (“RU”) or in a Postmaster facing role who have previously worked
for POL in auditing, investigation, suspension or termination of
postmasters and/or were connected to historic Horizon shortfall cases
or had awareness of the issues in Horizon but failed to act
appropriately. Such employees may pose a risk to the integrity and
independence of work in the RU and/or prevent POL from enabling
the culture change it is trying to carry out. I understood that I was to
be appointed to the Past Roles panel to give a postmasters’ view to
the panel, but to date I have not been invited to attend any meetings
and have not seen minutes of meetings that took place. I have
exhibited details of the Past Roles Terms of Reference and
accountabilities (POL00448306, POL00448307, and POL00448308).
I understand that the Terms of Reference are now wider than those
set out in the exhibited document.
On 9 February 2024, I emailed the Board following a meeting in which I had
expressed my frustration that Project Phoenix (as mentioned, at the time the
Board referred to Project Phoenix and Past Roles as a combined issue of
“Phoenix”) had not been resolved and there had been no further update on
activities (POLO0448309). I requested an update on the committee’s
meetings and decisions arising from it as I did not consider the level of
feedback to the Board was sufficient. Owen Woodley, Deputy CEO, provided
an update to the Board and confirmed that Karen McEwan, Group Chief
People Officer, was overseeing the projects (POL00448309). I requested
further Board discussion and an ongoing update on the projects
(POL00448309). I considered it unusual that the employees identified in the
projects had not been suspended, when in contrast postmasters and
subpostmasters would be suspended on a regular basis when investigations
were ongoing.
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On 19 April 2024, I emailed the Board again to update that a number of
postmasters had contacted Mr. Ismail and I regarding statements made at
the Inquiry by current employees who remain in the business and were
involved in the Horizon issues (POL00448297). I expressed my concern
regarding the lack of visible process on the Past Roles and Project Phoenix
reviews, which I did not consider reflected the culture change POL had
promised. I again requested a full and immediate update to be provided to
the Board of the names and individual status of all those listed in the Past
Roles and the Project Phoenix reviews.
On 26 April 2024, Mr. Ismail and I emailed the Board expressing our urgent
and deeply troubling concerns regarding Past Roles and Project Phoenix
(POL00448298). In the email, we noted that our previous requests for
updates had failed to result in any outcomes beyond confirming the number
of staff members falling within the scope of each project. We expressed our
concerns regarding the apparent lack of urgency and transparency
surrounding the ongoing investigations. We noted that I was originally
supposed to be part of the Past Roles review board, but this did not
materialise. We considered it imperative that the POL Board demonstrate a
commitment to accountability and transparency in addressing these issues.
We requested that all individuals falling within the scope of Project Phoenix
and Past Roles were suspended pending a full, independent investigation,
and a full report to be provided by 29 April 2024. Mr. Read responded
recognising that POL had not been as forthright in its actions as many would
have liked, although this was not a straightforward issue, and agreed to
present an approach to the Board (POL00448298).
On 3 May 2024, we received an update on Past Roles work (including what
was previously known as Project Phoenix) from Mr. Woodley. I understand
that the communication is legally privileged and so I have not exhibited the
communication to this statement. We received further updates on 11 May
2024, 18 May 2024, 25 May 2024, 3 June 2024, 8 June 2024, all of which I
understand are legally privileged and therefore not exhibited to this
statement.
Page 16 of 31
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The POL Board’s approach to Past Roles and Project Phoenix concerned
me because it indicated that POL remains unable to make difficult decisions
and adhere to a strategy.
6. Please describe the culture at board level, identifying any relevant individuals.
I do not consider that postmasters have sufficient involvement in, or oversight of,
the POL Board and Senior Management and its decision making. The result is
that the organisation has failed to become the “postmaster centric” organisation it
claims it wishes tobe.
(a)
(b)
(c)
Mr. Ismail and I are not consistently invited to meetings that we could
contribute to, and decisions are instead made by the Group Executive
or Senior Management without full consideration of the impact on
postmasters. On occasion I have felt that there were separate groups
within the Board, which resulted in certain individuals being excluded.
For example, I was not involved in the Historic Remediation
Committee, or Remuneration Committee (“RemCo”), for Senior
Management and so there was no postmaster NED representation.
The result is that decisions are made that may not accurately consider
the position of postmasters.
Due to a lack of postmaster involvement, POL does not proactively
invest in initiatives that benefit postmasters only. For example, self-
service tills would benefit a postmaster but may not significantly
benefit POL directly and so are not invested in. However, when a
strategic partner threatens to terminate an arrangement in the
absence of such an investment POL will take action as there are
significant and direct implications if they do not.
Mr. Ismail and I have raised issues in meetings and made requests
that do not seem to result in action. As set out above, we had to make
several requests for updates on Past Roles and Project Phoenix
before we received satisfactory updates. This creates the impression
that Mr. Ismail and I are an annoyance on the POL Board. My
impression is that the POL Board would prefer a more passive
Page 17 of 31
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postmaster NED who does not challenge the Board decision making
and Senior Executives directly.
Mr. Ismail and I are not permitted to talk openly to postmasters about actions we
have taken. For example, we repeatedly asked Richard Taylor (who was Director
of Communications) whether we could do a regular update to postmasters, but
this was denied. Therefore, our communications were heavily restricted and
extremely limited. This has led to accusations by postmasters that we have failed
to make the difference they expected — and has undermined our credibility with
some postmasters- when in reality we have achieved significant progress on
many fronts (but with much more still to do).
The extent to which NEDs on the POL Board wish to effect change in the
organisation varies, which can slow progress. Members of the Board often have
multiple NED positions and may not have the time or the technical knowledge to
engage with some matters. For example, to the best of my knowledge Mr. Ismail
and I are the only members of the Board to have direct experience of Horizon and
its operational issues. The current Board has a number of experienced portfolio
NEDs but currently lacks direct retail and technology experience to bring suitable
challenge in these areas to the Executive.
During my tenure as a postmaster NED, we have had three Chairs (excluding the
interim Chair).
(a) Tim Parker was a professional and fair Chair that gave people
sufficient time to be heard and effectively summarised issues
following topics. I considered I worked well with Mr. Parker and my
impression was that he was genuinely interested in hearing my view.
Mr. Parker left in September 2022 and prior to his departure appointed
me to ARC and Mr. Ismail to the Nominations Committee where he
felt our experience would be most beneficial to the organisation.
(b) Henry Staunton had a different style to Mr. Parker (who was Chair
during the Horizon issues meetings and had a strong focus on the
past, a little on the present but rarely addressed the future). Mr.
Staunton was keen to press on as swiftly as possible with redress for
Page 18 of 31
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postmasters, but he was more forward looking and thought
commercially; he wanted to bring the future of the business to the front
of mind and challenged the CEO to focus more on the opportunities
and current business. My experience was that Mr. Staunton wanted
to drive change and put the postmasters at the centre of the
organisation. He wanted to have more postmasters on the POL Board
and across more committees, but I understand there was some
pushback from the Board and members of the Senior Executive
although I cannot speak to this directly. I found Mr. Staunton to bean
effective and supportive Chair and was shocked when he was
dismissed by the Secretary of State.
(c) Nigel Railton has only recently joined the Board and appears to want
to progress the organisation in a positive and swift way. He has
initiated a strategic review (currently being carried out by Teneo) and
recruited a number of interim hires in key leadership roles to fill gaps
in the leadership capability.
I understand that Ben Tidswell joined the POL Board as a NED to provide a legal
view to the Board. He acted up as Chair when we had periods without a Chair.
Nick Read has been CEO throughout my time on the POL Board. I consider Mr.
Read to have good intentions and a desire to effect change in the organisation,
although sufficient change has failed to materialise over the past 5 years of his
leadership. Whilst some progress has been made, he has been focused
significantly on the addressing the past and this has resulted in a lack of success
in driving change for the present and the future. I have generally worked well with
Mr. Read. There were some reservations expressed by NEDs following
responses provided by Mr. Read to the Department of Business & Trade Select
Committee (“DBTSC”) on 27 February 2024, alongside concerns of POL making
the required full and frank disclosure in relation to documentation requested by the
DBTSC. It was agreed by the POL NEDs on 29 February 2024 that an evidential
based review should be conducted in relation to the information provided to
DBTSC. Five potential responses were reviewed for accuracy, which broadly
related to Project Pineapple (which I will discuss in more detail later in my
Page 19 of 31
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statement), the ‘untouchables’ comment made by Mr. Read, postmaster culture
and engagement, and whether Mr. Read had tried to resign as CEO. The review
assessed whether there was a possibility that Mr. Read might have made a
statement that was not verifiably true, or whether there was a possibility that Mr.
Read may have made statements that might have the capacity to mislead or could
have been put more fully or clearly. Two of the five statements were concluded to
have the capacity to mislead or could have been put more fully or clearly but were
not concluded to have been statements that were verifiably not true. The
remaining three statements were dismissed. It was considered a matter of
judgment, but it was recognised that Mr. Read was under intense pressure and
media scrutiny. I have exhibited a copy of the report provided to NEDs to this
statement (WITN1 1180105).
The POL Board includes a representative for the UK Government via UKGI (UK
Government Investments). When I joined the representative was Tom Cooper.
My experience was that Mr. Cooper genuinely cared about improving POL and
ensuring the right actions were taken with respect to postmasters. He regularly
engaged and discussed matters outside of Board meetings with Mr. Ismail and
myself. He brought fair challenge to discussion and the committees, and I thought
Mr. Cooper's departure from the POL Board was a loss. Mr. Cooper was replaced
by Loma Gratton.
Rachel Scarrabelotti was Company Secretary at the time I made my declaration
on remuneration to the Board, which was subsequently investigated as set out
above. I did not consider that I was given sufficient guidance or any support on
how to complete the declaration. There was no guidance given to me when I
joined the Board about the mechanisms and expectations for declaring conflicts
at the start of meetings. I have since sought independent advice from my
accountants in connection with thesedocuments.
Grant Thornton Report
In addition to the above, between 2023 and 2024 Grant Thomton carried out a
review of Governance and Board Effectiveness. Grant Thorton issued a report
on 25 June 2024 (POL00446477). I am generally aligned with the findings. Key
findings included (POL00446477, page7):
Page 20 of 31
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(a) A lack of unifying purpose and group-wide strategy between POL and
its Shareholder. POL struggles to establish accountability for defining
a unifying long-term purpose and strategy, leading to varied
interpretations of POL's strategic ambition.
(b) I Conflict around the role of the Shareholder versus the Board and
breakdown of the relationship.
(c) Leadership capacity at POL is currently affected by ongoing and
upcoming Board rotations, which inevitably impact leadership
cohesion and corporate memory. Additionally, the lack of detailed
succession planning at both Board and Executive levels presents a
risk to future operations.
(d) Decision-making forums at Enterprise level lack pace and do not
enable accountability. Until December 2023, there were over 100
personnel in the senior leadership team with a variety of singular and
collective accountabilities, a CEO with 12 direct reports, 12 GE level
committees and further innumerable committees, groups, and forums
that resided within Enterprise levels.
(e) Culture - a lack of trust, accountability and performance
management.
Grant Thornton found that the above issues highlight the need for: a unifying
strategy, greater role clarity through updating foundational governance
documents, streamlined decision-making processes, _ significant
improvements in succession planning and a cultural shift towards
accountability and long-term planning.
Following the report, a number of recommendations were made to the Board in
July 2024 (as detailed in POL00446477, pages 9 - 11). These recommendations
include:
(a) Strengthening succession planning and _ ensuring effective
management of the people agenda. This will be achieved through
managing the composition of the Board to maintain a strong decision-
Page 21 of 31
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making body, agreeing key criteria for assessing the required
composition of the Board, evaluating and developing the postmaster
NED role and formalising rotations and the selection process.
(b) Reviewing underlying processes, including promoting greater
transparency to ensure all NEDs access content from Board and
Committee meetings, ensure decisions are not taken outside of the
formal governance structure and without proper debate, and to
provide greater oversight of the work of NomCo and RemCo.
(c) Consider and address the need to mitigate risks to corporate memory,
fill skill gaps, and address lack of diversity.
7. Please summarise your experience of the board's relationship with and
approach towards subpostmasters (SPMs).
To the best of my knowledge, the POL Board does not engage directly with
SPMs and is distant from them. The connection with SPMs is through Mr.
Ismail and myself as the postmaster NEDs, as set out in detail throughout
my statement.
8. Please summarise your understanding and experience of the board's
relationship with any key external stakeholders, such as the National Federation
of SubPostmasters (NFSP), Communications and Workers Union (CWU), UK
Government Investments (UKGI) and the Department for Business and Trade
DBT).
The NFSP is an independent members organisation supporting operators of Post
Office branches and is acknowledged by POL as a representative body of
operators. To the best of my knowledge, NFSP receives significant funding from
POL to carry out its work. The NFSP represents approximately 800 postmasters.
NFSP will negotiate with POL on postmaster matters such as pay. In my
experience, NFSP is ineffective at protecting the interests of postmasters. It does
not scrutinise POL’s decisions (for example, around fair pay) or negotiate
effectively and appears to lack independence from POL. I consider that
postmasters need representation with the ability to properly challenge POL and
advocate for postmasters.
Page 22 of 31
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68.
69.
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The CWU represents approximately 100 postmasters but is a ‘non-recognised’
union for postmasters. The CWU are invited to certain meetings to represent their
postmasters’ interests, but they do not always attend.
Voice of the Postmaster (“VOP”) is a group that was set up by independent
postmasters around 18 months ago in response to their members feeling that their
opinions were unrepresented. VOP now represent approximately 1000
postmasters. Recently, they started to write to the UK Government directly and
spoke to the media, which meant that POL lost control of the narrative. Following
this, POL have engaged with VOP and invite them to attend focus groups and to
be more actively involved in Postmaster Policy reviews.
UKG's role is to ensure that the UK Government's money is spent appropriately
and that its investments are well managed. For example, they would take the case
for systems upgrades to the Government on behalf of POL. The POL Board
interacts with representatives of UKGI. I have not interacted with UKGI
representatives regularly beyond Ms Gratton (and previously Mr. Cooper) who sits
on the POL Board.
Representatives of DBT occasionally attend POL Board meetings, along with the
Secretary of State or Post Office Minister. I had some discussions with DBT
regarding policy but otherwise have hadlimited interactions.
In addition to the above, I understand that there is an ethical wall with the Treasury
which prevents the POL Board or Senior Management from liaising directly with
members of the Treasury.
TIMES ARTICLE 19 FEBRUARY 2024
9. Please consider RLITO000201. Please set out in detail the matters raised in this
article, the relevant_background, chronology and individuals, and your account,
including what caused you to believe that you were ‘ignored and seenj...Jas an
annoyance’ by other members of the POL board.
In January 2024 there was reporting in the news that Richard Taylor, the then
Director of Communications, had been recorded saying that many postmasters
were guilty. As a result of this reporting, Mr. Ismail and I spoke with Mr. Staunton
Page 23 of 31
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72.
73.
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regarding our concerns and the issue that Mr. Taylor's comments were proof of
our fear that there were people within the organisation who still believed that
postmasters were guilty (specifically, our concern was around the Project
Phoenix/Past Roles cohort). Our discussion was given the confidential name
‘Project Pineapple’.
Mr. Staunton prepared a file note of our conversation on 14 January 2024 that he
circulated to us for comment (POL00448302). As referenced in the file note, we
discussed that postmasters who had not come forward to be exonerated were
“guilty as charged” and that postmasters did not feel they were believed. We
discussed the amount of power held by Mr. Foat and our experience of
investigations treating postmasters as guilty until proven innocent. We also
expressed concern that individuals who had been subject to criticism remained
within POL, including Martin Roberts who I was told was separately under
investigation. We requested that the Board address the culture in POL, which we
considered toxic, and the establishment of a Board Committee on Culture on
which Mr. Ismail and I would sit to ensure it was postmaster centric. We also asked
to be on all committees including RemCo.
On 16 January Mr. Staunton circulated the file note of our conversation to the
NEDs: Benjamin Tidswell, Brian Gaunt, Simon Jeffreys, Amanda Burton, and
Andrew Darfoor (see POL00448299 and POL00448300). The email was titled
Project Pineapple. I understand that the email was separately sent to Mr. Read,
although I was notcopied to this communication.
On or around 18 January 2024, the email was circulated by Mr. Read to
colleagues, including Mr. Foat and Mr. Roberts. I cannot speak to why the email
was circulated to Mr. Foat or Mr. Roberts and I was not copied to the email. Mr.
Staunton notified the NEDs that the email had been circulated beyond the
intended group. Mr. Read never apologised for his forwarding of the email to me
directly or sought to help resolve the difficult situation his actions had caused which
I was both surprised and disappointed by. Instead, he chose to blame Mr Staunton
for sending the document unsecured on email. Mr. Staunton recognised that Mr.
Ismail and I were now, “exposed to further investigations from these two
individuals [Mr Foat and Mr Roberts] particularly in view of the fact that the
Page 24 of 31
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Investigations Team were “untouchable” (to use Nick’s words)”
(POL00448301).
Mr. Read described the Investigations team as “untouchable” in a NED-only
meeting on Microsoft Teams on 18 January 2024. I understood this to be a
reference to a process failure at POL which resulted in there being ineffective
oversight of the current investigation team. There were two issues: (1) the
Investigations team were investigating, or had investigated, a number of members
of the POL Board and Senior Management including Mr. Staunton, Mr. Read, Mr.
Roberts, Ms. Davies and myself. This meant that it was difficult for those members
of the Board to exercise oversight or challenge over the Investigations team, in
case it was suggested that there was a conflict of interest, and (2) POL’s “Speak-
Up” function is overseen by the Investigations team. Therefore, if a “Speak-Up”
report was made to the Investigations team it would essentially be investigating
itself. As such Mr. Read was expressing his frustrating that it was difficult to hold
the Investigations team to account as they were, in his words, “untouchable”.
Between 23 and 25 January 2024, Mr. Ismail raised several issues with Mr.
Staunton and in preparation for the upcoming POL Board meeting (see
POL00448304 and POL00448305). These issues included:
(a) The confidential email on Project Pineapple being sent to individuals
involved.
(b) I The presence of employees previously identified as high risk in the
historic Horizon IT scandal remaining within the POL workforce.
(c) The lack of credibility of the PM Engagement Team.
(d) A thorough investigation into all Non-Disclosure Agreements
executed since Mr. Read took office as CEO.
(e) A review of the role of Mr. Foat as Legal Counsel to ensure
transparency and accountability and a change of culture and
indecision.
Page 25 of 31
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78.
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(f) A change in the discriminatory culture targeting postmasters.
(g) I The establishment of an Oversight Committee featuring postmasters
and NEDs and empowered to proactively act and ensure
accountability among stakeholders.
Mr. Staunton was dismissed from his role prior to the January Board meeting
and these issues were not discussed at the Board following his departure.
I understand that at some stage, these concerns were leaked to the press
The above is an account of my understanding of the issues raised in the
article.
10. Please set out any other concerns (if any) you may have about your
experience on the POL board.
The Board has received a number of updates on potential technology to replace
Horizon.
The replacement of the Horizon system was already underway before I joined and
had a Board sponsor (Ms Harrington) supporting the head of the project. No
individual Board member has had the same engagement as Ms Harrington since
her departure (partly due to her skill set not being replicated on the Board). The
POL Board have been shown the technology at various stages - visiting the live
site at Holborn and the test system in HQ. Whilst as a "replacement" it is beginning
to show signs of capability, the key elements that Mr. Ismail and I have repeatedly
called for have been ignored. For example, we have requested front facing
screens to ensure compliance and enable the effective and faster selling of our
services to customers, as well as self-serve and automation capabilities to reduce
postmaster operating costs and to create a system fit for 2030 and beyond, rather
than simply a copy of the existing Horizon processes. The current programme is
late, overbudget and has had a series of govemance and external reviews rating
it poorly. I am concerned that the real extent to which the programme is proving
challenging is being understated to the Board and the Investment Committee and
we do not have sufficient visibility of the challenges in replacing the Horizon
system.
Page 26 of 31
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81.
82.
83.
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To date, the issues surrounding this project are manifold and remain unresolved
and unanswered. The Investment Committee continues to challenge the project
due to it being overdue and overbudget. The project speaks to the governance
issues with POL, as highlighted by Grant Thornton's report. A lot of work is now
underway to improve the project and I am hopeful following the Chair's
appointment of additional, experienced interim leadership to the Senior Executive
team - along with the current external strategic review being carried out by Teneo
- we will have a clearer view on how to remedy the current failings of the project
and more widely the business.
ANY OTHER MATTERS
In summary, in my experience there is desire within the POL Board to effect
change following the issues identified during the Inquiry and previous legal
cases. I have some reservations about the effectiveness of the Senior
Leadership and its ability to challenge issues, make difficult decisions, and
secure change within POL. However, I hope that with better continuity of
Board members, better management of initiatives, and sufficient oversight
we can improve the effectiveness of the Board and Senior Leadership to
deliver real and lasting change in the organisation.
I have serious concerns about how investigations into postmasterscontinue
to be conducted following my experience of an investigation in 2023. I am
particularly concerned about the way the investigation was conducted
following the lessons learned from the GLO and many of the issues raised in
the Inquiry. It suggests to me that there remain parts of POL where
postmasters are treated as “guilty”, and the burden is on them to disprove
allegations. There needs to be greater oversight of the teams carrying out
investigations to ensure that they are accountable for how investigations are
conducted and a separation of whistleblowing from the Legal and
Investigations teams.
That being said, I recognised the significant efforts that POL has made to
respond to the issues raised in the Inquiry and the steps taken to put
postmasters at the centre of the organisation (such as the creation of the
postmaster NED role). I hope that going forward we continue to strengthen
Page 27 of 31
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the relationship with postmasters and listen to them to make sure that this
does not happen again. This work has begun but is far from finished.
POL and its Senior Leadership have consistently struggled to make critical
decisions over my time on the board. POL lacks the ability to think proactively
and often fails to make tough decisions that have consequences (Project
Phoenix and Past Roles for example). This inability to make the hard and
right decisions has been its failing in the past and it risks remaining an
organisation unwilling to learn that making tough but necessary decisions is
a key part of leadership. The organisation does not seem to act effectively
without a clear checklist to follow. When clearly tasked with a set of actions
it is capable of meeting them, given the appropriate challenge, guidance,
support and funding.
I believe the Grant Thornton report and the upcoming Teneo review will help
the business with the challenge of evolving to become the Post Office that
postmasters, the Government and its communities need. The
implementation of a new IT system, the continuing development of the
postmaster NED role, better engagement across the business with
postmasters, improved postmaster remuneration and real strategic decision
making are key initiatives which lie at the heart of effective change. My
expectation is that with the recent changes in leadership these initiatives will
be properly implemented in the spirit of the Grant Thornton report.
Page 28 of 31
Statement of Truth
I believe the content of this statement to be true.
I GRO lellot Jacobs
Signed:!
15 August 2024
Dated:
Page 29 of 31
WITN11180100
WITN11180100
First Wi s f Elliot J
WITN11180100
WITN11180100
No.
URN
Document Description
Control Number
ITN11180101
Emails between E Jacobs, A
[Morley, J Bartlett, B Foat dated
14 to 16 March 2023
1TN11180101
1TN11180102
Letter from J Bartlett to E
Nacobs dated 15 March 2023
ITN11180102
ITN11180103
Emails between E Jacobs, J
Bartlett, A Morley dated 20
[March 2023
ITN11180103
'TN11180104
Letter from J Bartlett to E
Wacobs dated 8 February 2024
1TN11180104
ITN11180105
Draft Terms of Reference for
(Review of the Department of
Business & Trade Select
[Committee Statements &
Correspondence (DBTSC)
IConfidential report to the POL
Board’ dated 20 March 2024
ITN11180105
. [POL00448303
Emails between H Staunton, E
Wacobs, S Ismail, N Read
dated 16 January to 17
Nanuary 2024
IPOL-BSFF-WITN-006-
(0029992
IPOL00448306
Email from P Quinn to E
Wacobs, S Recaldin, D Willis, J
IMarwood, P Heap, L ONeill, J
Adams, E Hocking dated 27
INovember 2023
IPOL-BSFF-WITN-009-
(0000001
IPOL00448307
Draft ‘Past Roles Review
Panel Roles and
Accountabilities’ dated 30
[October 2023
IPOL-BSFF-WITN-009-
(0000002
IPOL00446477
IGrant Thornton ‘Post Office
Limited - Governance Review’
(dated 25 June 2024
IPOL-BSFF-099-0000003
10.
IPOL00448309
Emails between E Jacobs, K
McEwan, A Burton, O
loodley, N Read, B Tidswell,
IS Ismail, B Gaunt, Darfoor, S
Veffreys ,L Gratton, C
IBrocklesby dated 9 to 10
February 2024
IPOL-BSFF-WITN-009-
(0000004
1
IPOL00448297
Email from E Jacobs to S
Ismail, B Tidswell, L Gratton, B
Gaunt, A Darfoor, S Jeffreys,
IN Read, A Burton, K McEwan,
I(O Woodley dated 19 April
2024
IPOL-BSFF-WITN-004-
(0060544
12
IPOL00448298
Emails between B Tidswell, E
IPOL-BSFF-WITN-004-
Page 31 of 31
WITN11180100
WITN11180100
Jacobs, N Read, L Gratton, B
Gaunt, S Ismail, S Jeffreys, A
(Burton, A Darfoor, K McEwan,
IN Marriott, O Woodley dated
26 to 27 April 2024
(0060957
13]POL00448308 ITerms of Reference for ‘Past IPOL-BSFF-WITN-099-
Roles Project! (0000003
14)POL00448302 [Emails between H Staunton, S JPOL-BSFF-WITN-006-
llsmail, E Jacobs, D Blanchard (0029777
dated 14 to 15 January 2024
15]POL00448299 [Emails H Staunton, B Tidswell, POL-BSFF-WITN-005-
IB Gaunt, S Jeffreys, A (0010717
(Burnton, A Darfoor, S Ismail, E
Vacobs dated 15 to 16 January
2024
16]POL00448300 =‘ [Emails between H Staunton, S JPOL-BSFF-WITN-005-
Ismail, E Jacobs dated 14 to (0010720
15 January 2024
171POL00448301 Email from H Staunton toA = [POL-BSFF-WITN-005-
Burton, A Darfoor, S Ismail, E (0010781
Wacobs, S Jeffreys, B Tidswell,
IB Gaunt dated 18 January
2024
18]POL00448304 [Emails between E Jacobs, S_ +IPOL-BSFF-WITN-006-
Ismail, H Staunton dated 24 to (0030695
26 January 2024
191POL00448305 = [Document attached to IPOL-BSFF-WITN-006-
IPOL00448304 — issues raised
ith Chairman
(0030696
Page 31 of 31