WITN11200100​ Alan Barrie ​ - Witness Statement

Evidence on official site

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Witness Name: Alan Barrie
Statement No.: WITN11200100

Dated: 31 October 2024

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF ALAN BARRIE

I, Alan Barrie, will say as follows:

INTRODUCTION

1. I am a former employee of Post Office Limited (“POL”). I have set out my
professional background at paragraphs 8 to 33 below.

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 19 August
2024 (the “Request’), and in response to the questions raised in that
Request.

3. As an overarching point, I left POL in 2004. I have addressed the questions
put to me by the Inquiry honestly and to the best of my ability, based on my
memory of evidence. However, I would like to highlight that I am being asked
to comment on events which took place over twenty years ago, and it has
been difficult to recall with precision certain meetings, dates and information.
Similarly, some of the matters I have been asked to comment on are outside

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my personal knowledge. Where that is the case, I have indicated this.

4. There has also been a large amount of media coverage around the Horizon
IT system (“Horizon”), the prosecutions of sub-postmasters, and the legal
challenges brought over the past few years. As a result of this, it is inherently
difficult to separate out what I knew at the time with what I have subsequently

become aware of through such coverage.

5. I have tried my best to provide accurate information to the best of my
recollection and have answered the Inquiry’s questions honestly, however
the period of time since these events and since I have left POL does make it
difficult to answer some of the questions, which relate to events many years
ago.

6. I have followed the Inquiry as closely as possible and I have been shocked by
issues exposed by it. It has caused me to reflect on my time at POL and I am
genuinely sorry for the dreadful impact these events have had on affected sub-
postmasters and their families. Given what I know now, part of me wishes that
I had stayed longer at POL. Had I seen the need to draw attention to a
fundamental problem with Horizon, I believe I would have done so, but for now
I am grateful to have the opportunity to address the questions posed to me by
the Inquiry.

7. I instructed a law firm, Kingsley Napley LLP, to assist in the preparation of
my statement.

Professional Background

8. I completed 6 Highers at school and went to university in Edinburgh to study

business and accounting. I did not complete my degree, however, moving

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back to Inverness to manage a family start-up business, BM Trucks, which I

did until 1982.

9. In 1982 I became a branch manager at Transport International Pool in
Edinburgh, where I worked until 1985. In this role, my biggest customer was
Royal Mail Letters (“RML”). When they advertised for a mails network
inspectors’ (“MNI”) role in RML, which was a subsidiary of Royal Mail Group

(“RMG”) at the time, I decided to apply for it.

10.As a result, I joined RML on 1 November 1985. MNis were graduate entrants
and relevant industry job changers who were to become a cadre of highly
trained change management experts, capable of dealing with large-scale,
complex projects and expected to bring this acquired expertise into senior
management positions in due course. Our intensive classroom training,
interspersed with block release project work, was akin to a modern-day
apprenticeship. This was largely an operational role and I was involved in a
number of major transport projects, including, for example, redefining the
“letter flow’ into and out of Scotland to minimise manual handling and
maximise quality of service. This was a typical MNI project and involved a
major change in logistics mode from rail to air/road, which had significant
commercial benefits. I worked all over the country (Belfast, Carlisle, Glasgow,
Edinburgh and London) and advised local managers on logistics and mails

circulation requirements.

11.Following a temporary promotion in November 1988, dealing with the
aftermath of major industrial action in the South of England, I was promoted

in August 1989 to my first substantive senior management role in the York

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Area, part of the Northern Territory of RML.

12.My initial role was Area Planning Manager for the York Area, where I was
involved in planning and change management as well as technical projects,
such as the programming of sortation systems. In 1991 I became Area
Processing Manager, where I line managed the York and Hull automated mail
centres, as well as their linked delivery offices. During this time, we developed
the materials handling systems in York which are still used today throughout
Royal Mail and we pioneered new technology systems, working closely with

Toshiba engineers.

13. In September 1992 I moved to RML Headquarters (“HQ”) in London to be the
Personal Assistant (“PA”) to Peter Howarth, then Managing Director of RML.

I stayed in this role until July 1994.

14.1 was then promoted to become Distribution Director of Anglia Territory in
RML, where I ran the transport fleet, co-ordinated quality uplift programmes

and oversaw major building projects for the Territory.

15.1 worked in this role until February 1996, when my General Manager (John
Modd) was promoted to become COO of RML, and he offered me a role as
his Operations Design Director. In this role I was responsible for developing
the Royal Mail operational strategy, including the application of new
technologies to core processes. Royal Mail’s engineering and technology
function reported to me at the time and I reported to the COO of RML, until

September 1999.

16.On 27 September 1999, as part of a major business restructuring, I joined the
Post Office Network (“PON”) (one of three business units which previously

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made-up Post Office Counters Ltd). PON was a separate business to RML

and I had had very little previous exposure to it.

17.1 transitioned into the role of Operations Director at PON, where I reported to
David Miller who was Managing Director of the business unit. I initially
managed operational support services and developed new processes, but
without line accountability for the day to day operations, which lay with three
Regional Directors (Eric Logan, John Main, Jon Millidge), or Horizon

deployment which lay with the Automation Director (David Smith).

18.When I started in this role, there was an underlying view that the Post Office
was in trouble, as there were major financial difficulties. The business had
been slow to modernise, so I quickly got involved in business development
areas, to try to bring in new business processes and revenue streams, new
retail partnerships and more effective branch formats. At that time the Post
Office was also subject to a Cabinet Office (Performance & Innovation Unit)
review led by Charles Clarke MP and my team contributed significantly to its
report (Counter Revolution: Modernising the Post Office Network), which was

published in June 2000 with a foreword by Prime Minister Tony Blair.

19.In mid-2001, I had to cover for David Miller for approximately 5 months. On 1
October 2001, POL was created, merging various business units back into a
single company and formally replacing Post Office Counters Ltd which had
been reduced to an umbrella entity for the previous two years. POL remained
a subsidiary of RMG but it had its own memorandum and articles of

association, board, etc.
20.Following the restructure, I was initially employed as Major Change & IS

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Director, although this was not a formal directorship registered with
Companies House. I initially reported to Paul Rich who was the temporary
CEO until David Mills was recruited in April 2002, but I also had a dotted
reporting line to the RMG CIO (Les Graney then David Burden), with whom I

met on a regular basis.

21.This role was fundamentally different from my previous one, as I was given
responsibility for major change co-ordination across the entire business. As
Horizon had now been fully rolled out as PON’s core operating system, it was
also at this point that I took responsibility for the management of Horizon, as
all subsequent changes would need to be implemented through this newly
automated system, and for the commercial relationship with Fujitsu (see
paragraph 62).

22.In September 2002 my job title was changed to IT Director by David Mills and
I was formally appointed as a board member with Companies House. In terms
of my day-to-day role nothing changed and I remained in charge of co-
ordinating the approach to change across PON and managing the relationship

with Fujitsu.

23.As IT Director, four people reported directly to me: Mike Wells, who was the
Information Systems Director and had a strong technical background; David
Smith, the Delivery Director, who had lengthy experience of dealing with
Fujitsu at this stage, having been the Automation Director during roll-out and
involved in the initial procurement; Delwar Kang, the Change Portfolio

Manager; and lan O'Driscoll, the Commercial Director.
24.In terms of my qualifications for my various roles, I had considerable

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experience in managing major technology companies and procurements. I
had been involved in a number of aspects of technology for a number of years,
and I had significant relevant experience in change management, portfolio

management, and supplier management on a global scale.

25. However, I have always had enough self-awareness to understand where the
limits of my expertise lay and would regularly take steps to fill gaps in my
knowledge, often by seeking out relevant training. For example, when I
became Major Change & IS Director, I asked the RMG senior management
development lead to find me the best course to assist me in preparing for this
role. In the summer of 2001, immediately prior to taking up the role, I took part
in an immersion course run by Gartner in the US, which was effectively a ClO
bootcamp. I attended other executive development courses at key moments
in my career, at recognised education establishments such as Harvard (USA),
IMD (Switzerland) and IESE (Spain), and Royal Mail were active from the
outset in developing my senior manager change disciplines and qualifications,
for example through PRINCE 2 project management accreditation, European
Foundation for Quality Management accreditation and Certification in
Professional Competence (transport). I also made sure that I had subject
matter experts around me who were knowledgeable in the areas where I did

not have specific expertise.

26.1 was IT Director until May 2004, when I returned to RML as Operations
Support Director (subsequently changed to Operations Strategy & Design
Director to reflect the primary focus of the role) to work on the Royal Mail

modernisation strategy, optimisation planning, technology application,

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systems procurement, equipment design, fleet management and property
infrastructure rationalisation. David Smith took over my role at POL as interim
IT Director, pending the recruitment of Ric Francis, as he was the most

experienced of my direct reports.

27.Adam Crozier had by then become the CEO of RMG as well as Managing
Director of RML and, as the latter business was losing approximately £1m a
day, failing quality targets and getting very bad press, he wanted to bring
together a new team to find some solutions. He came to me and asked me to
join the team to lead on planning and strategy development. I also became

Royal Mail’s media spokesman, a role I had also carried out for POL.

28. Overall, it was a bigger job and it was one that I wanted as I felt I had
unfinished business back in RML. I ultimately remained in this role until my
departure from RMG in October 2008, having embedded the modernisation
strategy and completed the £1.2bn procurement of the enabling technologies
to deliver it.

29.From January 2009 until April 2011, I set up as a freelance change agent,
advising TNT Post (now Post NL) on a potential acquisition, Royal Mail on an
induction programme for new Directors and from September 2009, alongside
my freelancing role, I started working for HM Passport Office. I initially worked
there for 3 months advising them on recovering a major IT project (the National
Identity Card) and then stayed on for a year as interim Operations Director to
manage the subsequent changes. I left this role in August 2010.

30.In April 2011 I joined International Post Corporation (IPC), a collaborative

venture owned by leading postal operators, including Royal Mail, in Brussels

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as Director of Operations and Technology. Through this role, I also became
the independent chair for a number of International eCommerce
collaborations. I continued in these roles until July 2017 when I returned to the
UK.

31. After I left IPC, I took a break and spent some time with my family in Scotland.
Then, from November 2017 until June 2019 I refocused to become a senior
advisor on sustainable logistics for a number of companies, including
Transport for London (“TfL”).

32.In June 2019, I started working for TfL as a Senior Advisor on eCommerce &
Urban Logistics. They wanted assistance with their sustainability programme,
specifically in the area of urban logistics and last-mile parcel delivery, but
ultimately due to Covid-19, the company was unable to progress any of its
projects due to the severe financial impact of the pandemic.

33.In June 2020, I was asked by TfL to set up my own company to take forward
the main sustainability project identified during my time there, so I founded
Delivering London Limited which I currently chair. I am also the chair of Stamp
Free Limited. I also act regularly as a moderator and speaker at major industry
events in Europe.

The POL board

34.As PA to the Managing Director of RML, I was given good insight into the
development of strategy and business plans, and the monitoring of
deployment and performance management within a major business. Although
I co-ordinated the activities of the Royal Mail executive committee and any

proposals taken to the RMG board, I would not have put the information

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together myself and did not participate in RMG board meetings. However, I
believe this experience prepared me well for my future role on the POL board.

35.As HM government was the sole shareholder of POL, I was aware that POL
had to agree the overall business objectives, strategies and delivery plans with
the government. The business was also likely to be ultimately reliant on
government as a source of funds. I was also mindful of the ethical obligations
on a company wholly owned by the government.

36.1 started to attend some POL board meetings from the outset, i.e. before I was
formally appointed as a director, but it was following my appointment at
Companies House in September 2002 that I developed a keener sense of the
fiduciary responsibilities of a director and an awareness of their financial
obligations as RMG provided specific instructions and training in this area. The
initial POL board meetings were dominated by a single issue: whether POL
was a going concern or not. Dealing with this critical risk required a number of
guarantees and funding assurances to be put in place by the parent company
RMG and by HM government, with personal assurances being provided at the
time by the Secretary for State in the Department of Trade and Industry,
Patricia Hewitt MP.

37.More generally, my view is that the board is responsible for developing the
business strategy, taking into consideration the operating context, developing
a business plan to deliver the strategy and for ensuring that the right resources
are in place to ensure delivery to plan.

38.1 was clear that if I was a director, then I needed to take responsibility for the

decisions being made and direct strategy. Therefore, when it came to IT, I felt

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it was my responsibility to manage that area.

39.POL board meetings were held on a bi-monthly basis, although we would also
have executive meetings in the interim, where we would discuss strategy,
which then needed to be signed off by the board.

40.POL board had reserved powers, which meant that certain things required
further signing off by the RMG board. One example of this is the fact that POL
board only had authority to agree contracts up to a value of £10m, so for
example the Fujitsu contract needed to be approved by RMG board.

41.The POL board was well structured and my view is that matters were taken
seriously, papers were properly prepared and authorised, and any
presentations were checked over. Discussions were very open and board
members were encouraged to air their views. In particular, after Sir Michael
Hodgkinson joined the board, he encouraged open debate about relevant
topics.

42.Personally, I would have had some executive input at the board. At a high
level, I had oversight of POL’s IT at that time, including some of the business's
major priorities such as Network Banking deployment and the Fujitsu contract
renegotiation. Ultimately, my role was managing the IT contracts to deliver
against their requirements, as well as any major changes or problems post
sign-off.

43.Although the members of the board were not technical experts per se,
everyone would have had some awareness of systems management and
many would have had experience of managing commercial contracts. I was

the change co-ordinator, so I had experience in managing systems and

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suppliers, but I was not an out and out technologist. I would have relied on the
people reporting to me who had deep technology experience, such as Mike
Wells, Clive Reid and Paul Homan, who were all pure technicians, to fill the
gaps in my knowledge and advise as required. However, they would not have
been in the room during board meetings, unless a specific topic required it.

44.Various reports were submitted in advance of board meetings. These would
have been dealt with by the various department representatives, so as IT
director, I would have been responsible for the IT report. I would have invited
members of my team to contribute to the report, which would have contained
updates on significant IT changes, as well as on the team’s objectives and
priorities.

45.The other executive reports that regularly went to the board were as follows:
Operations (David Miller), Finance (Peter Corbett), Sales and Marketing
(Gordon Steel), HR (John Main, then lan Anderson), Banking (Graham
Halliday) and Cash Handling & Distribution (Byron Roberts). Then the
assigned governance groups, eg project or programme boards, would assist
the board with the implementation of the various business programmes.

46. If members of the board were unable to attend a meeting, they would still have
provided a report subject to it being relevant to the agenda. If necessary, a
substitute would have been brought in to put forward the paper on their behalf,
and they would have had permission to sit in on the meeting. Personally, I
don’t believe I ever missed a board meeting.

47.If I had specific issues that I wished to raise at board level, I first would have

raised these, either in my monthly one to one meeting with David Mills, or in

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his weekly informal executive team meeting, and then we would have decided
whether we should flag the issue to the board. I may also have raised any
issues when the POL executive team met as a group on a monthly basis. I
would always flag up any problems at this stage and would have had no
concerns addressing these at board level.

48. Throughout my time at RMG and POL, I was never directly involved with any
criminal prosecutions brought in the name of the company. I did not know the
required procedures around such prosecutions, although I was aware that
there was a legal department in RMG. I am confident I was not involved in any
discussions in relation to bringing prosecutions against sub-postmasters.

49.1 did not have any oversight of civil litigation brought by or against the
company, and I do not recall litigation being specifically mentioned during my
time at RMG or POL, although it does not (and would not) have surprised me
that the business was involved in litigation given the nature and scale of its
operational activities, including the cash intensive nature of the business.

50.In my time at PON and POL I had oversight of some of the systems, including
Horizon, used to collate individual transactions, cash and stock declarations
etc. used for the purposes of preparing management and statutory accounts,
although many of the reports generated at the time were still reliant on manual
input, either in the branch or in TP. I was aware that it was the board’s
responsibility to make sure the accounts were correct and sound before
signing them off.

51.In terms of the accounting systems themselves, if there was a fundamental

problem affecting the integrity of the accounts, then it should of course have

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been investigated and remedied. I felt that, as the systems were there for the
entire organisation, there was a collective responsibility from the entire board
to ensure they were adequately managed.

52.1 had no oversight of the company’s compliance with the Race Relations Act
1978, and I do not know what specific measures were put in place. The HR
Director would have had oversight of this.

The RMG Board

53.When POL was created in October 2001 as a complete business, it had its
powers revised by the RMG board, but I do not recall precisely when this
occurred, although I believe it was shortly after it was reconstituted. There was
a direct link between POL and RMG through the board as David Mills,
Jonathan Evans, Allan Leighton and Sir Michael Hodgkinson were also on the
RMG/RMH boards. There was therefore quite an overlap and awareness of
what was happening both in POL and RMG and there were opportunities to
make the other board aware of any issues as they arose.

54.1 attended RMG board on numerous occasions when I was at RML, mainly to
gain authorization for technology procurements or strategy propositions, and
on a couple of occasions when I was at POL, such as when I took the authority
to extend the Fujitsu contract through the POL board in September 2002, and
subsequently got it signed off by RMG board.

55. The RMG board's structure was similar to the POL board. It was quite formal
and included a number of non-executive directors. Everyone would have had
some experience in managing technology and RMG’s CIO was always a pure

technician.

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56.1 had a dotted line relationship and regular meetings with the Group ClO
(Duncan Hine, then Les Graney and finally David Burden) in a number of my
roles in RML and POL. They would have advised me on anything which
needed to go to the RMG board and I would have apprised them of progress

in relation to major IT projects, including any issues encountered.

My role as Operations Director

57.As Operations Director in PON (i.e. between September 1999 and September
2001), I was effectively responsible for all the main support functions to the
operations, except the line management and the deployment of Horizon. I
understood that my role as Operations Director was to critically examine the
operations processes (e.g. accounting flows), the profitability of certain
aspects of the operations (specifically the Post Office directly managed
branches) and provide input in terms of how we wanted things to look in the
future.

58.When I first became Operations Director, the business’ primary focus was on
managing the roll-out of Horizon. It was a steep learning curve: we were
introducing Horizon to 300 offices a week, which put the business under
considerable stress.

59.My role as Operations Director also involved dealing with safety and security
in branches. Shortly after I joined PON, I recruited Tony Marsh (“Tony”) as
Head of Security; I knew him well from Royal Mail and knew him to be a high
calibre individual. Tony reported to me for approximately 18 months. During
this time, we worked together on new formats for post office branches. It was

felt that the standard ‘fortress’ style set-ups in branches was neither conducive

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to optimising security nor was it the optimum format for integrating post offices
into partner retail operations. It was seen as a barrier to future partnerships
and therefore the future success of the Post Office network.

60. In terms of security, we took steps to improve the physical security of
branches, in particular to protect both the people that worked there and the
significant amount of both cash and value stock (e.g. stamps, vehicle licenses)
managed in those environments. At the time PON was experiencing annual
cash losses of over £6m through external crime and the number of robbery
incidents was increasing, so this was a major area of focus.

61.In terms of any internal investigations carried out by the Security team, Tony
would have come to me if he had felt that there was something I needed to be
made aware of, but I do not recall this happening during my time in this role. I
believe it is more likely that any such issues would have been dealt with by
the retail line, and specifically the three territorial directors who managed the
Post Office branches as the investigations structure was aligned to and
embedded within those geographic structures. When the POL structure was
created in October 2001, Tony's reporting line switched to the COO David
Miller.

62.As part of the Horizon project, there were two main back-office functions that
were impacted throughout the roll-out: Transaction Processing (“TP”) and
Network Business Service Centre (“NBSC”). As Operations Director, I became
responsible for both TP which was a long-established back-office function, and
NBSC which was effectively a live transitional project.

63.Sometime previously, Post Office Counters Ltd had established NBSC as a

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major project to be introduced in parallel to Horizon roll-out (1999-2001),
merging seven regional helplines into one dedicated centre at Dearne Valley
near Barnsley. NBSC operated these helplines as well as the related service
management systems which were initiated to ITIL (industry best practice)
guidelines plus the external helplines for customers. It was established and
developed over the first two years following phased transfer from the manual
network and refined thereafter. Once fully operational NBSC was expected to
deal with over 1m internal (post office branches) calls per annum and over
3.5m external (customer) calls per annum.

64.NBSC represented a considerable investment and had to be scaled up in
parallel to the roll-out of Horizon, i.e. as branches transferred from a manual
methodology to the automated system. The monitoring system for the roll-out
of Horizon was managed by the central contract team, but the operational use
and errors were picked up by both TP and NBSC as the first points of contact
for branches.

65.1 recall that the NBSC was expected to deal with over 75% of calls at first line,
although more complex and difficult issues would be referred to second and
third line experts. It also dealt with logging, categorising and filtering the
feedback from branches so that trends and problems could be identified and
remedial action taken as deemed appropriate.

66. I would have had some oversight of any problem management function as
part of the set-up phase of NBSC, but not direct involvement in its detailed
activities. The problem management team would have been able to access

any part of the business it considered capable of addressing identified

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problems, depending on the nature of each problem. This would include
Fujitsu if the problem related to the functioning of the Horizon system.

67.Separately Fujitsu ran a technical helpline which fielded issues relating to the
operation of the Horizon software or hardware. I believe this also dealt with
over 1m calls per annum from branches, so it was a considerable operation.
They too identified, logged and categorised individual instances of issues
encountered by sub-postmasters and were therefore in a position to identify
trends or recurring problems which required intervention.

68.When my responsibilities changed on the creation of POL in October 2001,
responsibility for TP transferred to the Finance Director, Peter Corbett, as it
was essentially a back-office accounting and reconciliation function. NBSC
transferred to the COO, David Miller as it was a live support function to the
retail branches.

69.1 had no understanding at the time I joined POL or RMG of what risks and/or
compliance issues could arise from the prosecution of SPMs for theft and false
accounting, and the pursuit of civil litigation against SPMs to recover alleged
shortfalls in branch accounts.

70.1 had no direct knowledge of and/or involvement in the oversight of the
investigation and prosecution of SPMs for theft, fraud and false accounting for
alleged shortfalls in branch accounts. I also had no direct knowledge and/or
involvement in the oversight of the pursuit of SPMs for the recovery of alleged
shortfalls in branch accounts, including through the use of civil proceedings

71.1 had no knowledge of the policies, guidelines, and practices followed by Post

Office (Stat. Corp.), POL, RMH and / or RMG when pursuing a civil action or

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criminal prosecutions against an SPM, including disclosure documents.

72.With regard to the conduct of audits of sub-postmaster’s branch accounts, my
recollection is that audit was part of the finance function. Although I am likely
to have been aware that audits were happening, I do not believe that I would
have been directly involved with this at the time.

73.1 did not deal with any disciplinary matters during my time at PON or POL. In
terms of practices and policies adopted by POL in respect of suspending or
terminating sub-postmasters’ contracts, I had no direct involvement in or
knowledge of any case where there was termination. I was not aware of
criminal prosecutions and civil proceedings arising from alleged shortfalls in
branch accounts based on Horizon data and I do not believe these were
discussed at executive committees whilst I was at POL. I have not been shown
any documents which leads me to believe otherwise. I had no oversight or
contact with the group legal department.

Horizon

74.My overarching view from my early exposure to Horizon was that the system
and the residual operational processes were too complex: Fujitsu had
automated the front end of the system (i.e. what was happening in the actual
post office) but the back-end processes (i.e. the interface with TP and the
activity within TP itself) had not been re-engineered.

75. The initial roll-out was an important starting point, however my view was that
we had just automated the existing procedures instead of restructuring and
simplifying them. This left us with automated but still complex processes in the

post office branches and a convoluted and cumbersome interface with the

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back office. Another critical issue with the system was that it was deemed too
expensive, both to run and to introduce change into due to its complexity.

76.The technology itself provided a great opportunity for development and
modernisation, but I was aware (from when I first became involved, in
September 1999) that there was a difficult and strained relationship between
Fujitsu and POL due to the intense political and commercial dynamics
encountered in the procurement phase and particularly due to the fallout from
the very late decision to terminate the Benefits Card functionality. The Fujitsu
solution represented a black box, fully outsourced change to the front-end
process which POL was not in control of and Fujitsu were highly defensive, no
doubt as a result of the extreme pressure brought to bear on them. It was clear
to me at the time that the decision to use Horizon could not be revisited,
therefore once the Horizon system was in place, we would need to take stock
and see what could be done to improve it from there.

77. \n the period I was Operations Director (from September 1999 to September
2001) David Smith, as Automation Director, was responsible for the roll-out of
Horizon and the relationship with Fujitsu.

78.1 was not involved in the design of Horizon nor in the original contract
negotiations as I joined POL after the pilot had taken place and just after the
contract had been signed, however I was involved in its later development
stage, post implementation. I was also impacted by its roll-out, specifically with
regard to the effect on workload in NBSC and TP.

79. During roll-out, as Operations Director, I was responsible for TP and my team

closely monitored errors that were reported by TP on a regular basis and

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categorised by them based on level of risk. I also initiated a risk register in my
team, where people could add issues which needed to be monitored and could
be reviewed on a regular basis (e.g. at monthly team meetings). As previously
indicated, if I felt these needed to be escalated, I would have discussed this
with my line manager and determined what, if anything, should be flagged to
the board.

80.1 have been asked to consider Horizon Error Root Cause Project Final Report
— Completed by Joyce Daggett — Horizon Error Root Cause and Reduction
Manager (POL00334154). Although I sponsored this report, I do not now recall
it or my reflections on its conclusions, but I do recall the fundamental issue. If
a piece of work is being presented to the board, then it needs to be sponsored
by a board member. Given that I was responsible for TP as Operations
Director (i.e. from September 1999 — September 2001), it was in my interest
to understand what the problem was, and I assume that is why I was the
sponsor of this report. If we had not taken action, then TP would at that stage
have been buried with the level of error reporting.

81.As this was a high profile issue impacting one of my operational units, I believe
I would have read this report at the time. I would not necessarily have
understood every detail, in particular the technical detail, but I would have
been aware that the problem was understood, actions were being taken and
that we would follow up to ensure that this had been effective.

82.1 recall that, upon roll-out, the accounting errors that emerged from the field
increased on implementation of Horizon and caused a rise in error rates. It

was expected that error reporting would go up with the roll-out, but the levels

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were higher than planned, perhaps not surprisingly, given that in this case
60,000 people, using 40,000 counter positions in over 18,000 locations were
being introduced to an entirely new way of working and technology. This was
a challenge for many sub-postmasters, many of whom had little or no
experience with using computers for either business or for personal use at the
time.

83.A significant part of the roll-out was looking at the root causes of these
accounting errors so we could address them. It was a particular focus for me
and my team, as increased errors resulted in increased workload for TP who
would have to resolve them. The team therefore required some sort of analysis
to understand why this was the case. Clearly there were trends that were
concerning to us which no doubt explains why this report was commissioned.
The ultimate aim was to manage the level of errors and understand and learn
from the cause of the problem, with the aim of returning to the baseline (or
below baseline) level of errors post Horizon roll-out.

84.If we consider this document alongside POL Business Service Management
— Draft Summary Report for NRO Board (POL00393956), dated 8 December
2000 we can see that progress was made. This report would have been looked
at by the NRO board, which tracked the roll-out of Horizon. The NRO board
was an important governance group for approximately 18 months, from
September 1999 until roll-out was completed by mid-2001.

85. In this report, we can see that the baseline error rate pre-Horizon was 0.63,
which had then risen to 1.47 in the early part of the roll-out, hence the initial

alarm bells. However, it seems there was a subsequent decrease in levels of

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error reporting, following the publication of POL00334154. The error rates
were reduced to a more manageable 0.84 at the peak of the roll-out. My view
now, and would have been the same at the time, is that this is an encouraging
statistic and it shows us that accounting errors were brought under control,
and that there was a good chance that once it was completed the error rate
would end up below the manual baseline of 0.63%, which was the objective.

86.On page 24 of POL00334154, there is a list of the top 10 errors as well as
recommendations for how to deal with them, whether that is through training
or system changes. Some of the errors would be dealt with at source, whilst
others would require changes to Horizon, so I believe that we were trying to
find a way to systematise the solutions and certainly to address them on a
pareto basis.

87.1 do not specifically recall what measures were taken to implement the
recommendations of the report, but I am confident they would have been
followed through, particularly as I can see now there was a significant
improvement in the level of errors. These recommendations would have been
taken very seriously and clearly by the autumn the levels of errors were far
less alarming. Reading this report now, I can see that it contains good
recommendations and analysis.

88.Following roll-out, and upon transition to my role as Major Change & IS
Director in POL from October 2001, my involvement in Fujitsu and Horizon
revolved primarily around two mission critical imperatives for POL: delivering
network banking capability to plan and delivering a major annual saving on the

cost of the Horizon contract. Both of these priorities were highlighted as being

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central to the achievement of our strategic plan.

89.My first objective was to get network banking in place. This programme was
already running when POL was created in October 2001, but it was in trouble.
POL needed to introduce a basic banking service to 6 million people by March
2003, but there were serious concerns about whether we would be able to
deliver this. My first clear priority was to remedy this as over 30% of our
revenue was dependent on having this capability in place.

90. I had taken responsibility for delivering this in October 2001 and there was a
great deal to do in 18 months and the timeframe was fixed. Ultimately, we
wanted to ensure that network banking was simple, with an enabling link to
universal banking in the future. Fujitsu was the natural choice for a supplier,
given the need to integrate into the Horizon system. We also looked at IBM
but integration into the Fujitsu front-end would be problematic and risky,
especially with an unwilling incumbent supplier.

91.Network banking was also part of the contractual framework under which
negotiations with Fujitsu were also taking place, and once we had the network
banking agreement secured, we could go on to renegotiate the contract with
Fujitsu for Horizon as we would have defined the network banking scope.

92.My second objective was the renegotiation of the Fujitsu contract itself.
Specifically, the board had decided that every key line in POL’s cost base
needed to be reduced. For me, this meant that IT costs should be brought
below 15% of total revenue, meaning that we needed to save at least £15m
per annum in the contract with Fujitsu. As IT Director, this was my personal

responsibility and therefore I personally led these negotiations.

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93.1 have been asked to consider the Memo from David Mills to Note to file, cc’ing
Alan Barrie and Peter Corbett - Re Meeting with Richard Christou, Chief
Executive Fujitsu (RMG00000194), Post Office Limited Board Meeting
Minutes of 26/09/2002 (POL00021480) and Letter from Liam Foley to Alan
Barrie RE: Horizon Next Generation — Framework for moving forward
(POL00104615), which pertain to the contract renegotiation from October
2001. Before I became involved in the contract extension negotiations, POL
had considered, and indeed had received legal advice regarding options for
the Fujitsu contract: one of them was to extend the contract, which then had 3
years to run until 2005. Another option was to terminate the contract, but that
would have caused issues, especially in terms of penalty fees as well as a
requirement to potentially repeat the difficulties POL had in the procurement
and deployment phases. I can see from the Electronic memo from Keith K
Baines to Dawn Howe; re: Horizon Post 2005 (POL00104333) that these
options were subject to an analysis and evaluation in March 2001 which
identified contract extension as the best option.

94. Initially, we put an RFI to the market asking for other companies, other than
Fujitsu, to put forward alternative proposals. IBM and EDS responded
enthusiastically to the challenge. This led Fujitsu to become very defensive.
POL was after all their number one customer and they were POL’s number
one supplier. By the date of completion of the contract term in 2005, Horizon
would already be 10 years old in design terms, which was light years in terms
of technological development at that time. However, I believe that, following

the analysis as set out at page 11 of POL00104333, it was decided by the

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RMG Board that the best option was to renegotiate the contract.

95.This was a difficult negotiation due, I believe, to the damage done to the
relationship in the procurement phase, immediately followed by the stress of
the roll-out phase which was a huge undertaking. Fujitsu were of course willing
to extend the contract, but before we dealt with that, we had to resolve the
network banking issue as the clock was ticking. For a time, Fujitsu were
working at risk on network banking, i.e. carrying out the development without
a contract in place, and before we had concluded the negotiations. This would
have been very uncomfortable for them as they were commercially exposed.

96.In early 2002 we ultimately awarded Fujitsu the network banking work, but
with some strict conditions attached which included a direct dependency on
the successful outcome of the contract renegotiation. We also made a number
of changes to the technical architecture of network banking to reduce the
development risk and our overall dependency on Fujitsu, bringing in other
parties to deliver critical elements of the solution with proven technologies. To
deliver network banking we ultimately needed to co-ordinate a group of
suppliers involving Fujitsu, IBM, EDS, Citibank and the LINK organization. As
this was the number one priority for POL at the time I decided that POL should
act as systems integrator (rather than Fujitsu) and that I should lead the
delivery programme personally.

97.Although we were going through tough negotiations, I felt that we needed to
emerge with a more progressive relationship with Fujitsu given the fact that
we had no choice but to work together then, and for some time going forward.

However, my primary objective was to reduce the costs of the contract to

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below 15% of revenue as this was a business imperative.

98. Initially the relationship did get worse: I had to be firm in negotiating with them,
particularly regarding the delivery of network banking. Eventually, I managed
to create a relationship of mutual respect with David Courtley, the COO of
Fujitsu. We looked at three particular aspects of the relationship, namely
people, commercial and technology, and agreed that all three needed to
change. I wanted to get to a position where the deal would be good business
for both companies, allowing us to develop a positive way of working which
was essential given the change demands on POL.

99.In the summer of 2002, once Richard Christou got involved as documented in
RMG00000194, matters were brought to a head and we were able to conclude
the renegotiation quickly and successfully. We addressed 3 main levers to
reduce cost: (1) the duration of the contract, as any increase would allow
Fujitsu to spread its investment; (2) the service levels which drove cost and
could be adjusted to a more normal level following the completion of roll-out;
and (3) changes to the technical infrastructure which took advantage of the
rapid technical evolution since the original design of Horizon. Together these
changes produced savings of £20m per annum and brought IT spend to under
12.5% of total revenue. It also provided a sound platform from which we could
revisit the overall relationship.

100. In September 2002, the renegotiation of Horizon was finalized and we
received authority from the POL board, followed by the RMG board, to agree
the contract. Fujitsu were no longer working at risk on network banking which

reduced tension considerably and network banking was_ successfully

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introduced on time and within budget in March 2003.
101. Subsequently, in early 2004 we felt able to open up a discussion into

next generation Horizon, as we had strong views that the current system was
over-expensive and over-engineered, a view confirmed by the Fujitsu CEO
Richard Christou in his discussion with David Mills. It would take a number of
years to re-architect and deploy a replacement for Horizon, but the contract
extension had provided the headroom for this to be done. We certainly would
not have considered agreeing to the next generation if we believed there were
underlying integrity problems. Having initiated the discussion in April 2004, I
left POL the following month, so was not party to what followed.

102. As part of my role managing the contractual relationship with Fujitsu, I
was also responsible for the service management agreement (“SLA”) within
the contract. The IT department acted as the interface team with Fujitsu: They
were the point of contact between the business and the supplier, and my team
would meet with their counterparts in Fujitsu on a regular basis to discuss
performance against the SLA, which was made up of 76 individual
performance metrics, and look to remedy any issues.

103. Subsequently, following the renegotiation of the Fujitsu contract and the
successful implementation of network banking, we were in a position to
consider the next stage of IT development and specifically the opportunity to
pursue the potential to simplify end to end processes, using the opportunity
provided by Horizon now being fully deployed.

104. I have been asked to consider RE: Document on the IMPACT

Programme — improving the end-to-end branch accounting processes

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(POL00334434), which relates to the IMPACT programme. This programme
was set up following the deployment of Horizon then network banking with a
view to focusing on and dealing with the known issues surrounding the end-
to-end branch accounting and reconciliation processes, and specifically
simplifying and changing the systems, both at branch level (Horizon) and in
the support functions (TP and Finance).

105. It was deemed necessary because the existing accounting and
reconciliation systems were outdated and POL needed to update and
systematize the processes. Specifically, the interface between the front-end
and the back-end of the accounting process was convoluted and required a
great deal of checking. It was clear following Horizon roll-out that further work
was required to modernise and simplify the end-to-end accounting system,
which is what this programme sought to address.

106. The programme was to be carried out in stages, following PRINCE 2
project management methodology which was now used in various parts of the
business: first the principles, aims and scope of the project were designed and
initiated, then a business case was created to allow the work to be done. Then
a plan was set up, and resources and scheduling were created for delivery.
Ultimately this process would lead to some form of implementation. I was
involved in the set up and the initiation phases of the overall programme in
late 2003/early 2004, but I left POL at that point, so I was not involved in the
deployment phases of IMPACT.

107. The IMPACT programme was authorised in September 2003 and, as it

had modernisation of core business accounting systems at its heart, it was led

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by the Finance Director, Peter Corbett, who was the senior executive and
initiative sponsor under PRINCE 2 who was responsible for putting the
business case to the board. Under this project management methodology, the
Finance Director and the COO were also identified as the ‘senior users’ for the
programme as requirements would be driven by Finance and Operations, as
they were the functions most impacted by the end-to-end changes. The IT
team were the conduit for the changes, setting the technological specification
to deliver the business requirements, making me the ‘senior supplier’ in
PRINCE 2 terminology. My team would have had responsibility for
implementing the system changes so that the objectives of the IMPACT
programme were met. The HR Director, lan Anderson was also identified as
a ‘senior supplier’ as it was envisaged that the IMPACT programme would
result in a_ significant headcount reduction with significant training
requirements for remaining back-office staff when we introduced accounting
systems such as SAP accounting, which would bring in industry best practice
accounting methods along with up to date systems.

108. The key objective for this programme was to simplify the system, both
from the perspective of the sub-postmasters in the branches and for the
business, especially in TP.

109. I do not recall specifically which new processes were being considered
for implementation under IMPACT other than SAP accounting and I left POL
before any of the phased changes were implemented, so I am unaware if the
benefits were realised. I knew from my time as Operations Director, that we

had fairly inefficient processes at the time, so there was a significant

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opportunity in redefining those. Overarchingly, my recollection is that the
IMPACT programme had genuine potential to modernise the accounting and
reconciliation processes right across POL.

BEDs

110. During my time at POL, as with any significant IT system, the Horizon
system did periodically experience technical faults in both hardware and
software. However, there was a process to deal with them, as I set out below.
I note that these are referred to as “BEDs” in the Rule 9 Request and I refer
to them as such below, however as far as I recall, this is not terminology that
was in use at the time.

111. During the pilot and roll-out phases (from 1999 to 2001), the
Automation Team would have dealt with BEDs. My team took responsibility
for this once POL was created in October 2001. By this time Horizon had been
fully deployed and we moved into the normal running phase of its operation.

112. Once I became responsible for Horizon I mainly recall attempting to
resolve issues relating to the resilience of the system (i.e. where there were
hardware or network failures which prevented the Horizon system from
operating effectively at branch level). I do not recall the detail of specific BEDs
at the time, but I am clear that identified technical bugs, errors or defects were
the contractual responsibility of Fujitsu to resolve. Some were dealt with
through software patches (repairs) whilst others would be designed out of the
system as part of major software releases. At the time, I do not recall being
made aware of any BEDs affecting the fundamental and ongoing integrity of

the data.

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113. Generally, my team would liaise with Fujitsu on a regular basis about
BEDs. POL technical staff did not have access to the Horizon system,
therefore we were reliant on Fujitsu to monitor and fix issues. If a BED first
became apparent at branch level, POL may have triggered an investigation,
which would have led Fujitsu to categorise the BED according to whether it
was business critical or not. If Fujitsu simply patched, remedied or found
workarounds to a BED, this would be considered business as usual at this
stage.

114. I believe there were some tensions around the speed with which Fujitsu
remedied some of these issues and also that this caused some tension
between Fujitsu and their technology partner Escher who supplied significant
elements of the middleware critical to the operation of Horizon at branch level.
I believe there should be a record of how long Fujitsu took to fix things, and
overall it was considered that it was not done as quickly as we would have
hoped. We believed this to be a function of the Horizon architecture complexity
and saw this as a strategic issue moving forward, as it adversely impacted our
speed to market. I do not recall specific circumstances, but ultimately it was
considered inevitable that there would be some problems, as with any system
on this scale. My view at the time was that it was important that we dealt with
such issues in a structured manner, and that this was generally achieved, but
at no time was it brought to my attention that there might be something more
fundamental, or structurally wrong with Horizon.

115. If there were more structural issues which would require pieces of work

to be done, then this could be initiated. I believe that the contract and the

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service level agreement required Fujitsu to make us aware of any structural
issues so that we could discuss them at a joint service management forum
where Fujitsu would tell us how they intended to fix them. I would not have
been directly involved in these meetings. I did however, meet quarterly with
David Courtley from 2003, following the contract renegotiation and we would
look at progress with regard to resolution of high priority bugs in this context.

116. I would have expected issues to be escalated to me if a particular BED
was likely to affect business continuity or if it affected the integrity of what the
business does on a daily basis.

117. I was frequently out in the field visiting post offices or attending sub-
postmaster forums in the context of major changes being implemented. At the
town hall forums or other events, I was always keen to hear from sub-
postmasters and they in turn were always keen to get their views or concerns
over to me. Generally speaking, I found that sub-postmasters understood the
benefits Horizon could bring, but if they were having issues they would tell me.
The issues being flagged to me at the time were mainly around the complexity
of the in-branch processes and the resilience of the system, particularly in
relation to communications, screen-freezes and hardware reliability. The
problems put forward at this time were, as far as I can recall, sporadic rather
than systematic and I do not recall any feedback about issues concerning the
fundamental integrity of the system.

118. If there was a problem with account balancing, I understand that the
sub-postmaster would have called NBSC in the first instance i.e. if they could

not resolve the problem themselves using their Balancing with Horizon

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(POL00089733) guide and, most of the time, NBSC would have helped them
to resolve the problem. If difficulties continued it was likely that the Retail Line
Manager or Horizon Field Support Officer could be called in to assist.

119. I had no knowledge of Fujitsu's ability to insert, edit or delete transaction
data or data in branch accounts without the knowledge or consent of sub-
postmasters, and if I had, then it would have been an absolute deal breaker.
We plainly should not have had people having unauthorized and unmonitored
access to a system, with an ability to change things, save for in exceptional
and strictly regulated circumstances.

120. POL00089733 was issued following feedback from the pilot phase of
the roll-out. I do not recall precisely what else would have been done to
address the dissatisfaction with the training given on Horizon. We did survey
branches shortly after individual Horizon implementations and I recall that
most were satisfied with their training and had settled down fairly quickly into
using Horizon, so any response would have needed to focus on the significant
minority who were having continuing difficulties. I was not part of the roll-out
team, so I did not lead on the training side, however I do recall that
contractually Fujitsu was responsible for delivering training in the roll-out
stages. POL would have had an input into it if there was a shortfall, and
specifically David Smith and the Automation Team would have been
responsible for monitoring the effectiveness of the training.

121. I do recall a decision made at the outset of Horizon roll-out to augment
the retail line with a significant additional business change resource in the form

of experienced Horizon Field Support Officers (approximately 350 managers),

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recognising that despite the training, the availability of support materials and
the ability to call NBSC some sub-postmasters would still have difficulty in
adapting to an automated environment. This was a major change programme
and the challenges were significant. Once Horizon was rolled-out and it was
business as usual, I believe POL would have taken over responsibility for
ongoing training needs.

Board level knowledge of BEDs

122. RMH, RMG and POL would only have discussed BEDs if raised to them
as an issue, however when I was at POL, the vast majority of BEDs would
have been dealt with by the Service Management Team following the process
described at paragraph 113, and I cannot recall any systemic issues being
raised with me.

123. If I was aware of a problem reaching a certain level, such that it would
affect the service we provided to our customers, undermine the integrity of the
business or branch level finances or result in reputational damage to the
business, this would be considered a business risk, and I would have made
David Mills aware at the very least, and ultimately, depending on the nature of
the issue, the Board.

124. However, I did not have any fundamental concerns about the integrity
of the system. My main concerns were with the complexity, overengineering
and the cost and speed of managing and delivering change on Horizon, which
I certainly did bring to the attention of the board. I cannot recall specific board
meetings where the fundamental integrity of the system was discussed and I

note that one of the conclusions of the Post Implementation Review Board —

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Horizon Implementation (POL00334118) in March 2002 was _ that
“Operationally Horizon has proven to be reliable and robust” and this was
consistent with the view expressed by Fujitsu CEO Richard Christou in
RMG00000194 in August 2002 that “it (Horizon) was fully meeting the
specification and gave us a 100% ‘lights on’ position”. Generally speaking,
there were BEDs on an ongoing basis, but they were under management and
I believe this would have been dealt with in the context of the normal
relationship with Fujitsu.

125. As I was not alerted to any underlying concerns about the reliability of
the data in Horizon, I was not in a position to pass information on to anyone
at board level. The one exception would have been the specific incident
relating to the loss of data.

126. I have been asked to consider Letter from Keith Baines to Colin Lenton-
Smith, re: Lost Data & Audit Requests (FUJ00176295), Letter from Colin
Lenton-Smith to Keith Baines, re: Lost Data & Audit Requests
(FUJ00176297), Letter from Keith Baines to Colin Lenton-Smith, re: Lost Data
& Audit Requests (FUJ00176655), Letter from Colin Lenton-Smith to Keith
Baines, re: Lost Data & Audit Requests (FUJ00176298) and Fujitsu Letter
from Colin Lenton-Smith to Mike Hannon, re : Lost Data and Audit Trail
(FUJ00176300). I have limited recollection of the specifics surrounding this,
but I do remember the data loss incident. It was flagged to me as being
serious, and I recall it was regarded as so serious that some considered it had
the potential to lead to a termination of the contract with Fujitsu. I recall that a

number of people were angry about the data loss, but that we ultimately

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accepted Fujitsu’s explanation and concluded that it was an unfortunate one-
off incident.

127. I have no recollection of the specifics of what was discussed in the
meeting with Stephen Muchow on 3 September 2002 other than what can be
found in the letter at FUJ00176300. This incident happened two weeks before
I went to the board for the approval of the extension so the timing of the
incident was very unfortunate indeed. At this stage, a termination of the
contract, however, would have meant that we would be unable to complete
the network banking project and would have therefore lost over 30% of our
revenue. Having concluded that it was a one-off incident, therefore,
terminating the contract would have been very difficult and in my view
inappropriate. I believe that we felt that we had to bring Fujitsu to account
(including by way of settlement payment) and obtain assurances that there
would be no repeat of the incident. There was also much at stake for Fujitsu:
by this stage, they had been working on network banking at risk for six months
and the contract extension was all but agreed, but I do not recall whether or
not this incident influenced the conclusion of the contract negotiation in any
way.

128. I do not believe that we would have extended the contract with Fujitsu
had we believed there to be an underlying problem with the integrity of the
data nor would we have considered the long-term replacement of Horizon until
any current issues had been successfully resolved in the current system.

129. Had I believed there to be a fundamental problem with the Horizon

system, my relationship with David Mills was such that I would not have had a

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problem going to him and telling him that I had serious concerns about Fujitsu.
In addition to David Mills we had Sir Mike Hodgkinson, Allan Leighton, Adam
Crozier and David Burden (who were all on the RMG board) to call on and
these were all people who, had they believed that the system was not working,
would have said it would have to be fixed or an alternative supplier sourced. I
would have been comfortable telling them that we should no longer be using
Fujitsu if I believed there were irreparable reliability issues.
Consideration of other specific documents

130. I have been asked to consider Lee Castleton Civil Case study. Problem
Management Report — Product related problems including Marine Drive PO —
FAD 213337 — Spmr Suspended (POL00142496). This document relates to
an NBSC problem management report for week commencing 3 May 2004.
In light of the date of the report (I returned to Royal Mail around this time) and
the way the report is written, it is highly unlikely that I would have ever seen
this report.

131. NBSC was outside my area of responsibility at that time and, from my
reading of the document, it appears that their view at the time was that the
problem was with the sub-postmaster and his staff rather than the system. On
this basis, it is unlikely that they would have immediately alerted the IT Director
to this issue.

132. Had I still been at POL, I would not have expected this issue to be raised
with me unless my team had first raised the matter for investigation by Fujitsu
and ascertained, at the time, that there was a technical issue with the

underlying system. If Fujitsu was convinced and convincing that it was not a

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systemic problem then I think it unlikely that there would have been any
escalation.

133. I have been asked to consider POL00104333, ICL Pathway Bringing
Technolgy to Post Office Limited October 2001 V.3 (FUJ00116072) and /CL
Pathway Monthly Report — February 2002, version 3.0 (FUJ00116119), and
specifically my concerns surrounding Fujitsu being unable to deliver “more for
less”: to an extent, I was concerned about this. I felt it was possible at a high
level but Fujitsu would need to be both encouraged and pressured into a
position where it was an acceptable deal for them.

134. I was convinced at the time that this was about managing expectations,
and I felt there was the possibility to change the cost dynamic of the
relationship, whilst still making it positive for both businesses. We ultimately
reached a successful conclusion to this renegotiation.

135. I have been asked to consider Email chain from David X Smith to Mark
Burley — Re: Horizon (POL00335610) and POL00334118. I believe this is the
full “lessons learned” summary from the Horizon implementation which was
produced in March 2002. The paper also refers to a ‘Lessons Learned Intranet
Site’ which would have included more detail plus numerous other lower-level
learning points, but the main conclusions should be contained within the post
implementation review paper and its Annexes. Whilst I do not recall
specifically which recommendations would have been implemented, I am
confident they would have been followed through and taken seriously.

136. I have been asked to consider Post Office Ltd Board Minutes of

19/06/03 (POL00021482). I do not specifically recall the discussions had at

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this board meeting, but I can see that an action recorded for me states that
the Chairman had expressed a particular interest in furthering his
understandings of the capabilities and limitations of the Horizon system. I
believe that I would have arranged this personally. I am confident we would
have welcomed the Chairman’s involvement and his interest in the core
systems. If there were specific issues we were experiencing at that time, we
would have put them to the chairman. Sir Michael Hodgkinson was
experienced and a pragmatist so he would have known that the system was
likely to contain BEDs. I do not recall the details of the meeting, but I believe I
would have wanted him to have a full understanding of both the good and the
bad things about the system from the outset.

137. I have been asked to consider Horizon Service Management forum-
Meeting minutes number 9 (POL00394319) and the use of the phrase “drains
up”. I believe this expression meant that I would have wanted them to
categorise the different problems and provide me with some sort of analysis
of how they were dealing with them. I was trying to reshape the relationship
with Fujitsu so I needed to be aware of these things. However, I do not recall
what information was presented to me as a result.

138. I have been asked to comment on Horizon Service Management Forum
Minutes of Meeting No. 10 (POL00394298). I do not specifically recall this
document, although upon reading it now, I believe it is a reference to the Joint
Executive Forum, which may have been the meeting that David Courtley and
I had on a quarterly basis and which I refer to at paragraph 115. I believe that

is where we created the report card surrounding people, technology and

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commercial, as we wanted to be aware of any issues, so we could assess and
drive improvement. We tried to create a structure where there would be
reporting up and down, to ensure matters were escalated appropriately.

139. I have been asked to consider TP Focus — Transaction Processing
edition — November 2003, New bonus scheme for TP (POL00157513) and set
out my reflections. In relation to the proposed introduction of a bonus scheme
based on how long it takes for a debt to be settled. I would have had no
involvement with this proposal as TP was not my area of responsibility at that
time.

140. I have no recollection of gaps identified in the debt recovery disputes
process, particularly the lack of training available and deployed for the dispute
duties as TP was not my area of responsibility at that time.

141. With regard to the debt recovery focus, although I do not recall this, my
view is that debt recovery and reducing the age of debt at a business level are
normal areas of focus for every business. All areas of cost were under
heightened scrutiny whilst POL’s going concern status was under close
examination and debt recovery would have been part of the remit of the

Finance Director, hence the references in TP communications.

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Statement of Truth

I believe the content of this statement to be true.

31 October 2024 I 10:24 AM GMT

Dated:

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Index to First Witness Statement of Alan Barrie

WITN11200100
WITN11200100

URN

Document
Description

Control Number

10

11

POL00334154

Horizon Error Root
(Cause Project Final
Report — Completed by
Joyce Daggett — Horizon
Error Root Cause and
Reduction Manager

IPOL-0181458

POL00393956

POL Business Service
{Management — Draft
Summary Report for
INRO Board

IPOL-BSFF-0220626

RMG00000194

emo from David Mills
‘0. Note to file, cc’'ing
Alan Barrie and Peter
(Corbett — Re Meeting

ith Richard Christou,
(Chief Executive Fujitsu

VIS00013093

POL00021480

Post Office Limited
Board Meeting Minutes
of 26/09/2002

IPOL0000013

IPOL00104615

Letter from Liam Foley to}
Alan Barrie RE: Horizon
Next Generation —
Framework for moving
jorward

IPOL-0104198

POL00104333

Electronic memo from
Keith K Baines to Dawn
'Howe; re: Horizon Post
2005

IPOL-0103916

IPOL00334434

RE: Document on the

IMPACT Programme —
mproving the end-to-end

branch accounting
rocesses

IPOL-0182073

PPOL00089733

Balancing with Horizon

IPOL-0086709

POL00334118

Post Implementation
Review Board — Horizon
mplementation

IPOL-0181532

FFUJ00176295

Letter from Keith Baines
(0 Colin Lenton-Smith,
re: Lost Data & Audit
Requests

IPOINQ0230529F

FFUJ00176297

Letter from Colin Lenton-

IPOINQ0230531F

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12

13

14

15

16

17

18

19

20

21

22

WITN11200100
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Smith, re: Lost Data and
Audit Requests

FFUJ00176655

Letter from Keith Baines
(0 Colin Lenton-Smith,
re: Lost Data & Audit
Requests

IPOINQ0230890F

IFFUJ00176298

Letter from Keith Baines
io Colin Lenton-Smith,
re: Lost Data & Audit
Requests

IPOINQ0230532F

FUJ00176300

Fujitsu Letter from Colin
Lenton-Smith to Mike
Hannon, re: Lost Data
and Audit Trail

IPOINQ0230534F

IPOL00142496

Lee Castleton Civil Case
study. Problem
janagement Report —
roduct related

roblems including
jarine Drive PO — FAD
213337 — Spmr
Suspended

IPOL-0143696

FFUJ00116072

ICL Pathway Bringing
Technolgy to Post Office
Limited October 2001

3.

IPOINQ0122243F

FUJ00116119

ICL Pathway Monthly
Report — February 2002,
ersion 3.0

IPOINQ0122290F

IPOL00335610

Email chain from David
Smith to Mark Burley —
Re: Horizon

IPOL-0181531

PPOL00021482

Post Office Ltd Board
Minutes of 19/06/03

IPOL0000015

PPOL00394319

Horizon Service
janagement forum-
eeting minutes number

IPOL-BSFF-0220989

IPOL00394298

janagement Forum
inutes of Meeting No.
(10

ena Service

IPOL-BSFF-0220968

PPOL00157513

TP Focus — Transaction
Processing edition —
November 2003, New
bonus scheme for TP

IPOL-0145785

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