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Witness Name: Zarin Homi Patel
Statement No.: WITN11430100
Dated: 6 September 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ZARIN HOMI PATEL
I, ZARIN HOMI PATEL, will say as follows:
INTRODUCTION
1. This witness statement has been prepared in response to a request from the Post
Office Horizon IT Inquiry (“the Inquiry”) pursuant to Rule 9 of the Inquiry Rules
2006, dated 23 July 2024 (“the Rule 9 Request”). I have been assisted by my legal
representatives, Kingsley Napley, LLP, in the preparation of this witness
statement.
2. The Inquiry has provided The Times article “Postmasters on Post Office board
‘ignored and unwanted” (RLIT0000201) dated 19 February 2024, which I have
been asked to consider in my Rule 9 Request. To assist me in responding to the
Rule 9 Request, I have also sought disclosure from Post Office Limited (“POL”) in
respect of various documents. Given the short turnaround time I have been given
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to produce this witness statement, I cannot be certain that I have been disclosed
all relevant material from POL, however, I have done my utmost in the time
available to review the material disclosed to me by POL and exhibit any
documents I deem key to the issues raised in my Rule 9 Request. I am reassured
that the Inquiry is not seeking disclosure of documents beyond that which have
already been provided to me and are instead seeking my candid account in
relation to the topics addressed in the Rule 9 request. Where I have been able to
source relevant additional documents, these have been exhibited to this witness
statement.
3. I was appointed as Non- Executive Director (“NED”) of POL on 26 November 2019
and held the position until 13 March 2023.
PROFESSIONAL BACKGROUND
4. I am a qualified Chartered Accountant and a Fellow of the Institute of Chartered
Accountants in England & Wales. I have a BSc in Economics from The London
School of Economics and Political Science.
5. I trained as a Chartered Accountant with Peat Marwick Mitchell (now KPMG) in
London and worked there from 1982, qualifying in 1984, until 1997, a period of 15
years. I worked in corporate audit, tax and corporate finance as well as a wide
range of business sectors in my time there.
6. I joined the BBC in June 1998 as Group Financial Controller. I became Head of
Revenue Management in 2001 and then became its Chief Financial Officer in
2005, a position I retained until 2013 when I left the BBC. I joined Grass Roots
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Group PLC in August 2014 as Chief Operating Officer (“COO”) and left in October
2016.
I have been an independent NED since 2006 (alongside my executive roles) and
am now a full time NED and/or Trustee in consumer facing, business services,
utilities, central government and charitable sectors.
As set out in paragraph 3, I joined the POL Board on 26 November 2019 as a NED
and left on 13 March 2023. I was initially interviewed by POL’s headhunter,
Russell Reynolds, on 28 August 2019 followed by a panel interview on 3
September 2019 directly with the POL Board which comprised of the Chair,
Timothy Parker, Kenneth McCall, Thomas Cooper as the UKGI Shareholder
Representative and Carla Stent. From the outset of my tenure at POL, I was a
member of the Audit, Risk & Compliance Committee (“ARC”) and also attended
the Historical Remediation subcommittee of the Board from its inception in August
2021 until I left POL in March 2023. I also informally took on the role of interim
Senior Independent Director from 26 January 2022 up to the date of my departure
to cover a temporary vacancy until the appointment of a new Chair was completed
following the retirement of Timothy Parker in 2022.
I have been asked to summarise my understanding of and experience with the
Horizon IT system. As part of my preparation for my application to the POL Board
in 2019, I carried out desktop research into the issues concerning the Horizon IT
system and the prosecution of SPMs which had been widely covered in the press.
I also reviewed reports of Fraser LU’s Common Issues Judgement (“ClJ”) of 15
March 2019 and was aware that publication of the Horizon Issues Judgement
(“HIJ”) was imminent (it being published on 16 December 2019). I was also aware
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that POL had asked for Fraser LJ to recuse himself during the Common Issues
Trial in March 2019. I understood that these matters were very serious and would
require POL to make a fundamental change to its culture and its processes and
systems to win back the trust and confidence of its SPM community and wider
stakeholders. I also had access to POL’s Annual Report and Accounts on the day
they were published on 3 September 2019 which set out some of the issues
relating to the litigation.
10. Horizon was a matter I brought up with the interview panel of the POL Board on 3
September 2019. I recollect saying something along the lines that “POL was
losing public trust and confidence and needed to re-think whether it was acting in
the public interest”. The point was acknowledged by the interview panel but due,
I believe, to confidentiality of the legal process there was no substantive
discussion on that day.
11. My first Board meeting which I attended as an observer prior to my formal
appointment was on 26 November 2019 (POL00021572). There was a discussion
about exploring mediation with the Group Litigation Order (“GLO”) claimants. The
Board was briefed by Ben Foat, the General Counsel, and Alan Watts of Herbert,
Smith Freehills LLP as the Board’s legal adviser. I did not take part in this
discussion as it was my first POL Board meeting and it was important to listen at
this stage.
EXPERIENCE ON THE POL BOARD
12. I have been asked to summarise the nature of any training and induction that I
received on my appointment to the POL Board. I recall that my induction was
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13.
14.
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extensive. It was organised by the Company Secretary, Veronica Branton, and
included meetings with members of the POL Board and the Executive team. I also
received an induction briefing document, (POL00112763), which provided a
summary of the Group Litigation, the ClJ and HIJ as well as a direct briefing from
Ben Foat regarding the same issues.
As part of my induction, I was able to meet directly with three SPMs at local post
offices in my area and they helped me understand how they used Horizon, the
training they received and the level of on-going support they required. I was also
able to speak with POL’s retail management team to understand how the business
worked and what the key processes and controls were. This proved a useful
backdrop when the Board began to consider the systemic process and culture
changes that were required following the ClJ and HlJ.
In addition to the above, my induction also involved:
(i) Meeting with the Heads of Mails and Retail, Financial Services,
Insurance, Telecoms and Digital Identity Division to get a better
understanding of the business strategies;
(ii) Meeting with Alisdair Cameron, Chief Financial Officer, Tom Lee,
Group Financial Controller, Johannes Appel, Head of Internal Audit
& Risk and external auditors, Price Waterhouse Cooper, to better
understand POL’s financial strategy, business plans, financial
systems, performance reporting and controls;
(iii) I Attending POL’s Sponsor department, the Department for Business,
Energy and Industrial Strategy, (“BEIS”), (now the Department of
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Business and Trade), (“DBT”) training sessions for NEDs to
understand how government finances work as well as the
requirements of Managing Public Money as per HM Treasury's
official guidance;
(iv) I Meeting with Nick Read, who had joined two months prior to me, to
understand his perspective on the issues arising from the ClJ and
HIJ and what changes needed to happen to reset POL’s relationship
with SPMs and the culture of POL more generally. Nick Read also
helped me understand the long-term business issues SPMss faced with
increasing competition from logistics carriers, the decline of cash usage
and closure of bank branches being some examples;
(v) Meeting with Jonathan Hill, Director of Risk and Regulatory
Compliance, to gain an insight into the regulatory and legal
obligations for each line of the business and how codes of conduct
operated including whistleblowing processes;
(vi) With regards to technology, I met with the newly appointed Chief
Information Officer, Jeff Smyth, as well as the Chief Information
Security Officer, Tony Jowell, to understand current technology as
well as the technology risks POL faced;
(vii) With regards to People and Culture, I met with the Chief People
Officer, Lisa Cherry, and the Head of People and Culture, Amber
Kelly, the Head of Marketing and Brand, Emma Springham and
Company Secretary, Veronica Branton.
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15.
16.
17.
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Finally, I completed relevant compliance training in areas of cyber training and
data protection and reviewed POL’s Code of Conduct.
In my opinion POL had an extensive and thorough induction process which
enabled me to build a reasonably well-rounded picture of how the organisation
operated. There was always an open invitation to continue deepening my
understanding in any area either through meeting specialists or getting detailed
briefing papers. The Company Secretarial function would recommend pre-briefing
meetings ahead of key board papers and would also arrange for any further
briefing that each NED on the POL Board requested.
I have been asked to address the briefings I received in relation to the issues
addressed by the Inquiry, before or on joining the Board. As noted in paragraph
12, I received a written briefing, POL00112763, on the ClJ and HlJ findings, the
past prosecutions of SPMs and the GLO. I also had a verbal briefing with General
Counsel, Ben Foat, to ensure I understood the legal issues and could ask any
questions I had, (I do not have any notes of this discussion as these would be
stored on the Diligent Board Pack App- which I no longer have access to). I had
access to current POL Board papers and there was also an open invitation to ask
for more detailed briefings as and when they were needed from the Company
Secretarial function. I therefore have no concerns about the depth and quality of
these briefings and those that continued throughout my time on the Board. In
addition, I recall reading the summary findings for both the ClJ and HIJ which were
publicly available documents. I recall that in my induction I was focused on the
nature of the changes that would be required in my time on the POL Board.
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18.
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In terms of the adequacy and effectiveness of POL’s corporate governance
arrangements that were in effect during my tenure as a NED I have the following
reflections:
A. POL’s corporate governance standards were broadly in line with the FRC’s
2018 UK Corporate Governance Code (“CG Code”) and the Corporate
Governance Code for Central Government Departments. There was an
independent chair and a majority of NEDs on the Board. It had a
professional and experienced Company Secretary and the usual
committees covering audit, risk and compliance, remuneration and
nominations. Board papers were usually well prepared and available in
reasonable time for detailed consideration. There was an annual process
to review the performance of the Board as well as that of the NEDs. This
annual performance review was I believe reported up to BEIS and UKGI
annually. In addition, there was regular engagement between the Chair
and DBT to discuss performance of POL.
B. The appointments process was formal and with open competition to bring
the most experienced and talented people to the Board. I observed
particular care being taken by the Chair, Timothy Parker, to find people who
had the most relevant expertise in their fields. Some examples that
demonstrate this are:
(i) Expertise in distribution and logistics: this is a critical area for POL
in its relationship with Royal Mail and other parcel carriers. Both
Kenneth McCall and Brian Gaunt brought specific expertise in this
area;
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(ii) Experience of major technology implementations: recognising that
Horizon would need a substantial program of work as the long-term
contract with Fujitsu was approaching its end, the Board appointed
Lisa Harrington who had various senior roles at BT Group PLC as
Group Chief Customer Officer, Chief Information Officer, Managing
Director of Technology Transformation as well as being a Managing
Director at Accenture UK working on organisational and systems
transformations;
(iii) I Substantial and senior legal experience was needed as the program
to compensate SPMs for the loss and pain they had suffered began
to take shape and so the Board appointed Benjamin Tidswell, an
experienced lawyer, in July 2021. As a partner in the London
Disputes practice at Ashurst since 2000 he had worked on a wide
range of commercial litigation and regulatory matters and was the
Global Chairman of Ashurst from 2013 to 2021 when he retired; and
(iv) Experience of financial services and the related compliance
regimes: Carla Stent had considerable experience in banking at
Barclays Bank plc and investment management firms as well as
Thomas Cook Group PLC.
POL’s Annual Report and Accounts included detailed reporting in line with
the CG Code to enable the Shareholder to effectively assess the quality of
the company’s governance process;
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An extra layer of governance was provided by UKGI as the Shareholder
Representative for DBT. This role oversaw the government's 100%
shareholding in POL, held a seat on the Board and its various committees
and took part in the approval of POL’s long-term business strategy,
executive and non-executive appointments, as well as remuneration policy.
The UKGI team supporting the Shareholder Representative monitored
financial and operational performance through detailed consideration of
monthly financial and network performance data provided by the executive
team at POL and held the business to account in delivering its commercial
and policy objectives. Whilst as NEDs we did not have the benefit of seeing
the detail of these monitoring activities by UKGI, the Board was, as I recall
it, given occasional insight into the matters discussed by Thomas Cooper
as the Shareholder Representative;
POL’s purpose and long-term sustainability were at the heart of the Board’s
work during my tenure. Following the ClJ and HlJ I observed deep
reflection by the entire Board, both executive members and NEDs, on what
the organisation needed to do to restore the public's trust and put right the
harm done over many years to its most critical stakeholders - the SPMs
who are the beating heart of POL up and down the country;
The Chair was careful to ensure that diverse voices were heard and
decisions made with care for all stakeholders. There were annual internal
and external (every three years) Board effectiveness reviews that tested
that the Board was effectively chaired. Independent Audit Ltd conducted
one external board effectiveness review in the year ending 31 March 2021
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19.
20.
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and the outcome was reported in POL’s Annual Report and Accounts (see
page 27 of this published report available online);
G. Finally, the most important change was the appointment of two experienced
SPMs to the Board in April 2021 - Saf Ismail and Elliot Jacobs - to bring the
voice of SPMs right into the heart of POL’s strategy and decision making.
Both were important and influential voices as POL endeavored to rebalance
the interests of the SPMs and the service provided to them. I believe that
it was the first time in POL’s history that SPMs were right at the top of the
organisation and able to bring their direct and lived experience to the Board.
I, as a NED, valued their insight into the daily realities and challenges that
SPMs faced and I believe I was better able to contribute to shaping the
Board’s decisions as a result of hearing their voices directly. I have
addressed this in further detail at paragraphs 30 — 31 of my statement.
I have been asked to describe the culture of POL at Board level and my reflections
as to the ways in which the culture had changed following the findings arising from
the ClJ and/or resulting from evidence arising in the Inquiry.
Following Nick Read joining POL as CEO in September 2019, he introduced a
structured programme targeted at making changes to reform the business
relationship with SPMs in line with the ClJ and latterly, in 2020, changes to Horizon
itself in line with the HlJ. Throughout 2020 — 2023, the Board would receive
regular, detailed updates that monitored the progress being made in implementing
these changes. To instill confidence in this programme, the changes proposed
were audited by POL’s Internal Audit team who would consider whether the
actions were fully implemented and embedded, followed by an independent
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external review by KPMG for HlJ-related changes (i.e. the technical changes
implemented to the Horizon system) and by Norton Rose Fulbright LLP for
reviewing conformance with the ClJ (i.e. in respect of contractual reform for SPMs
etc.). There was therefore a degree of confidence from the Board that change was
beginning to be addressed and new ways of working being embedded. These
changes to process and systems were complex and detailed and necessarily took time
and resource to implement -— they were not overnight fixes. The programme of change
was initially led by POL’s Operations Director and in or around May 2021 the POL
executive established the Improvement Delivery Group chaired by Daniel Zinner,
POL’s Chief Operating Officer at the time.
The first area of operational and cultural change had commenced sometime
between March 2019 and April 2020 and was intended to make changes to SPM
support, contracts and operational services to address the findings of the ClJ. The
ClJ was highly critical of the way in which POL previously managed its
relationships with SPMs through its contracts. Specific issues related to shortfalls
and discrepancies which were routinely reclaimed via deductions from
remuneration; suspending SPMs without payment prior to re-instatement or
termination and not providing sufficient training or ongoing support. These were
key issues — all of which needed to be addressed. An Operational Improvements
plan, (which latterly became known as the Improvement Delivery Group), was
developed with dedicated leadership and reported on action taken to the POL
Board at various times. Examples of such reports to the Board feature in the 8
April 2020 Board papers (POL00448823) and the 3 June 2021 Board papers
(POL00448825). These reports showed that key processes were documented
and brought in line with the ClJ requirements before being independently
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assessed by Norton Rose Fulbright LLP. Separately, the HIJ had identified that
there were 15 separate issues relating to bugs, errors and defects in the Horizon
system and there was a similar operational plan to begin to fix these technical
issues. KPMG independently reviewed the changes made to Horizon to ensure
they accurately captured the changes needed to conform with the HIJ. The Board
monitored these actions to ensure they worked for SPMs and instilled confidence
that change was really happening and beginning to be embedded. This process
was complex, hence the use of independent firms like KPMG and Norton Rose
Fulbright LLP.
The ARC also commissioned internal audit reviews of the effectiveness of
implementation (to validate that the changes had actually been made and to
assess whether the programme of change was progressing to schedule). POL’s
Internal Audit team reported to ARC, often identifying where implementation was
not as effective as planned, which enabled the ARC to hold executives
accountable. Examples of internal audit reviews reported to ARC are as follows:
(i) July 2021: Internal Audit validated the changes made for
conformance with the ClJ and HIJ as being delivered, alerting ARC
that progress was constrained by availability of technical resources
from Fujitsu and that the Executive was considering alternative
solutions to address the gap. I produce an extract from the July 2021
ARC minutes at POL00448826;
(ii) September 2021: Internal Audit validated changes as complete in
120 out of 126 ClJ conformance actions in Phase 3 and had
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23.
24.
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identified 6 actions which needed remedial action, which the ARC.
then asked the Executive to complete. I produce an extract from the
September 2021 ARC minutes at POL00448829;
(iii) I July 2022: Internal Audit validated the technical changes in the HlJ
phase 2 programme and highlighted that progress was slower than
planned due to availability of technical resources (POL00114796).
In summary, there was considerable oversight by POL’s Executive and the Board
over the changes being made to conform to the ClJ and HIJ with independent
testing and challenge and transparent reporting of issues to those charged with
governance. This regular oversight meant that the POL Board were able to see
firsthand that POL staff were genuinely and thoughtfully making progress towards
a SPM centric culture.
The second area of change was the development of new SPM Support policies
which aimed to set out clearly each key policy that enabled SPMs to effectively
run their post offices. These policies provided guidance, set down principles,
highlighted areas of risk and ensured that POL could support SPMs compliantly
and effectively. There were 12 policies covering matters such as Account Support,
Accounting Dispute Resolution, Transaction Corrections, Complaint Handling,
Training, Onboarding, Contract Performance, Contract Suspension and
Termination. Each policy set out clearly its purpose, the key expectations of each
party, the detailed processes underpinning it and key performance indicators.
These SPM policies were shared with the National Federation of Sub Postmasters
(‘NFSP”) and their feedback incorporated. Each policy was independently
reviewed annually by POL’s Head of Compliance to identify any control
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25.
26.
27.
28.
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weaknesses, process inefficiencies and to confirm that they continued to be legally
appropriate in line with ClJ.
The intention was to keep an active level of oversight by the ARC over these key
policies which were at the heart of resetting POL’s relationship with SPMs. Around
July 2022, the recently appointed Interim Group Compliance Director, Anshu
Mathur, commenced work on building a permanent control framework for on-going
and continued assurance that all SPM related operating processes were
demonstrably working fairly, that lessons were continuously being learnt and
action being taken to prevent repetition of the failures of the past and similar issues
emerging again.
The third area of change was in relation to putting SPMs at the very heart of
strategy and decision making at POL. I address this in further detail at paragraphs
30-31 below.
Before my departure from the Board, the Inquiry had heard Phases 1 — 3, in
addition to two hearings regarding compensation. The Board, Senior Executives
and other senior personnel would attend the Inquiry to hear the evidence — which
was particularly important in Phase 1 and the Human Impact Hearings. The Board
also considered the Inquiry Chair's Statements on Compensation dated 21 March
2022, 9-10 May 2022, 15 August 2022 and 9 January 2023 in detail to ensure the
Executive team were dealing with compensation and addressing the issues
raised.
I have been asked if the culture at POL supported the building and maintaining of
trust between POL and SPMs, managers and assistants. My understanding of
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29.
30.
31.
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“managers and assistants” relates to those working in Post Offices under the
direction of the SPM and I have answered the question on that basis.
It was recognised by the Board that the journey to resetting the relationship with
SPMs and the culture, processes and systems would take time and persistence
and would need to be done in a genuinely open and humble way and with a
complete absence of any defensiveness. I observed colleagues on the Board
acknowledging the mistakes of the past and being determined to make POL
change. As I demonstrate above, the Board worked tirelessly and went into the
detail of the changes being made to give itself confidence that the Executive was
addressing all of the issues raised in the ClJ and the HlJ and that the culture of
the organisation was responding accordingly. As I note in paragraphs 20 and 21,
POL’s executive team took an active role through continued evaluation, to ensure
that the failings of the past would not happen again.
A key component of that cultural shift was the appointment of the two SPM NEDs
to the Board in June 2021 which marked a sea change in the attitudes of the
organisation. The SPM NEDs’ appointment was instigated by Nick Read who,
early on in his tenure as CEO, was determined to ensure the voices of SPMs were
put at the heart of decision-making within the organisation and this was supported
by the Board.
The appointment of Saf Ismail and Elliot Jacobs made a substantial difference to
the deliberations and decisions of the Board. By way of example:
(i) Saf Ismail’s and Elliot Jacobs’ operational experience was
instrumental in changing the way that the POL Executive team went
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about implementing key changes so that everything was considered
with SPM’s experience at the heart of any change. Examples where
this resulted in a change in approach were the wholesale change of
ATM machines in post offices in 2022; the development of new
desktop equipment in post offices such as printers, screens and
scanners and the implementation of an online service hub to make
it easy for SPMs to order and receive services. These were
important changes to the culture so that the SPM was able to shape
day to day services and not have it imposed from a central
operations team as had happened in the past. Elliot Jacobs joined
the ARC as a member from December 2022 which enabled him to
have much more detailed oversight over controls;
(ii) Secondly, an issue fundamental to SPMs was the ability to create
sustainable and thriving post offices whilst getting a fair share of
remuneration for the postal services they provided. Both SPM NEDs
brought a strong voice to these deliberations and were able to
influence change for the better. This included developing ideas for
growing the number of services which would lead to higher
remuneration levels, for example servicing the customers of logistics
operators other than Royal Mail to diversify income streams for
SPMs;
(iii) I Thirdly, as POL diversified its services to widen the distribution
network to reduce the over-reliance on Royal Mail, the SPM NEDs
were instrumental in helping the Executive understand the
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operational and logistical challenges for post offices in dealing with
multiple carriers.
The Executive team and the Board were serious and determined in effecting
cultural change and putting SPMs at the heart of the organisation and everything
it did. In addition to what I have already set out, examples of how Post Office went
about this (and as reported in POL’s Annual Reports and Accounts for 2019/20,
2021/22 and 2022/23) included:
A. Launching a SPM consultation in September 2020, which included
questions on SPM participation in decision-making;
B. Aserving SPM being appointed to a new full-time SPM Director role on the
Executive, with responsibility to lead on day-to-day engagement with
SPMs;
Cc. The introduction of an annually conducted SPM research survey providing
an important channel through which the Executive team and the Board
could understand SPM’s needs and aspirations;
Dz. POL embedding a range of SPM engagement forums to enable SPM voices
to be clearly heard and their feedback acted upon. These included
Regional Forums across the country, a national Postmaster Advisory Group
as well as a number of SPM working groups to collaborate on key topics
such as better IT and marketing support. Senior managers hosted around
a hundred local engagement events;
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33.
34.
35.
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E. The CEO regularly met with SPM’s as a group on a formal and informal
basis and ensured that he was directly hearing their perspective on issues
such as remuneration which were critical to the long-term sustainability of
SPM’s businesses; and
F. Senior managers were encouraged and expected by the CEO to regularly
visit with, and meet SPM’s as a group or individually, to properly understand
and build empathy for the role that SPM’s play in our society.
In my judgement, the voice of individual SPMs was heard clearly and
systematically acted upon and monitored by the Board. However, a culture that
was at least thirty years in the making cannot be transformed overnight - it takes
time, persistence and consistent change from the very top to permanently
transform the culture to one that is in service of, and trusted by, SPMs. Therefore,
my view when I left the Board was that significant progress had been made and
that continual focus was needed to maintain the new culture.
I believe that if the Executive continues to be given the space and time to effect
this change in a collective mindset to put SPM’s at the very heart of POL - and is
held properly accountable by the Board and its shareholder, DBT- it will succeed
in embedding that change permanently.
I have been asked to summarise my understanding and experience of the POL
Board's relationship with key stakeholders.
NFSP
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36. Relationships with the NFSP were largely handled by the Executive team and the
Board received annual updates on any key matters, such as setting annual
budgets. As I have noted in paragraphs 18G, 30, 31 and 32 there were many
wider, deeper and more direct forums for engagement with SPMs, all ably
supported by Saf Ismail and Elliot Jacobs as SPM NEDs and the SPM Director
within the Executive team.
Communications Workers Union (“CWU”)
37. Relationships with the CWU were largely operational matters handled by the
Executive team. The Board received occasional updates on any key issues, such
as annual pay awards, safety during COVID 19 and health and safety issues. In
addition, there was Executive engagement with CWU on their workers’ rights case
at an employment tribunal in March 2022. The point being that the Board had
more direct and wider SPM feedback through various fora, including SPMs on the
Board.
Fujitsu
38. As a critical supplier of technology whose long-term contract for services was
approaching its end, there was considerable debate at the Board on Fujitsu's
performance, on how POL managed the end of contract risks and how POL would
safely move its operations and data centers in-house or to a new external provider
alongside the replacement and modernisation of branch technology and services.
The Board’s role was to ensure that the technology strategy was well thought
through as the risk of changing technology at scale was complex and highly risky.
UKGI
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39. I UKGI acts as DBT’s Shareholder Representative and their role is to oversee the
Government's 100% shareholding in POL, hold a seat on the Board and its various
committees, take part in the approval of POL’s long-term business strategy,
Executive and Non-Executive appointments and POL’s remuneration policy. The
UKGI team supporting the Shareholder Representative monitors financial and
operational performance holding the business to account in delivering its
commercial and policy objectives. This was a necessary role and added an extra
layer of governance and brought deep commercial experience on behalf of
Government.
40. In my view I believe the UKGI role works well across Government's commercial
bodies and acts as a bridge between political and policy considerations and the
needs of a commercial business that needs to grow a sustainable living for SPMs.
Inevitably it adds to the workload of the Executive team as they have in essence
three bodies overseeing performance: DBT as ultimate shareholder, UKGI as their
representative and of course the Board. When aligned, this works well and needs
an authoritative Chair of the Board who is able to engage properly with Ministers
and UKGI.
Department of Business and Trade (“DBT”):
41. I POLis wholly owned by the Secretary of State for DBT who holds a special share
in the company. DBT does not have day-to-day involvement in the running of the
company, but monitors performance, compliance with the minimum network
access criteria and the provision of specified services. DBT issued the
Shareholder Relationship Framework Document in April 2020 (available online at
DBT website) which described the parameters within which POL is expected to
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42.
43.
44.
45.
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operate, certain obligations with which POL is expected to comply and how POL,
DBT and UKGI as the Shareholder Representative are expected to interact with
each other.
Annually the Minister for Postal Affairs would attend the Board to directly share
their views and listen to the Board’s perspective.
With respect to compensation for historical matters, which was funded directly by
the taxpayer, there was, of necessity, considerable and detailed oversight of the
policy and implementation of compensation schemes.
In summary, the POL board took account of different perspectives and balanced
these in making decisions and judgements in the best long-term interests of POL
and its SPMs and within a funding structure that recognised that the British
taxpayer provided a significant subsidy to support POL.
I have been asked for my view as to the current composition of the Board with
regards to experience, expertise and abilities. I can only comment for the period
of my term of office between November 2019 to March 2023. As I have already
noted in paragraph 18B, the composition of the Board was considered carefully
by the Chair, UKGI and DBT to ensure that it included not only SPM NEDs but
also experienced business people who had sector or functional expertise in
relevant areas such as:
+ Mail distribution and logistics;
+ Strengthening and growing the branch network through retail hosted hubs;
+ Banking, financial services, insurance;
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47.
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* Government Services;
+ Digitally enabled services and seamless customer experience;
* Delivering a lean, competitive cost base; and
* Technology transformation of legacy POL systems.
The appointments process was open and transparent and supported by
experienced external headhunters. Role specifications were thorough and
detailed to ensure prospective candidates understood the nature of the
organisation and its business strategy and detailed references were sought.
Candidates were interviewed by all members of the Board and together with UKGI
and an independent Assessor (required for all public appointments in Government
owned bodies) there was an element of independent challenge and scrutiny. The
preferred candidates also required the approval of both the Secretary of State for
DBT and I believe, The Prime Minister's Office.
The process of Board composition and selection is thorough, in line with corporate
best practice and with sufficient independent oversight by UKGI and DBT.
I have been asked my view on the desirability of SPM representation on the Board,
legally qualified Board members and Board members with IT experience. I believe
the Board struck the right balance in terms of its composition during my term of
office between November 2019 to March 2023. I have already noted the critical
importance of having influential and experienced SPMs on the Board and so will
not repeat this here. I concurred with the appointment of Benjamin Tidswell, a
highly experienced lawyer, who was an asset to the Board’s strength in legal
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49.
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matters. Finally, the transformation of the legacy technology required experience
and the Board appointed Lisa Harrington in 2020 to add to the Board’s experience
in this area. In my view, it is desirable that the Board continues to have a legally
qualified board member, in addition to those with technology experience.
I have been asked to comment on whether the culture in POL actively encourages
whistleblowers to speak openly and honestly about their concerns. At the time I
joined the Board in November 2019, POL had an existing Whistleblowing Policy
in place with the General Counsel and Head of Financial Crime, Sally Smith, as
the owners of this policy. The policy dated July 2020, (POL00030903) as drafted
was generally in line with good practice but the Executive believed that after the
ClJ and the HlJ findings it needed to be strengthened so that SPMs, staff and
members of the public were able to report any concerns and trust that these would
be investigated with care and issues arising acted on. The Whistleblowing Policy
was updated on two further occasions during my tenure as a NED, produced at
POL00413444 and POL00091478 respectively.
During my time on the POL Board there began a continuing programme of work
to fundamentally shift POL’s whistleblowing practices, procedures and systems to
be in line with best practice. That programme took place in four broad phases and
was overseen by ARC on behalf of the Board as follows:
(i) PHASE 1: Two external benchmarking reviews using PROTECT’s
Whistleblowing best practice diagnostic tool in February and
November 2021. PROTECT are the UK’s leading whistleblowing
charity and their diagnostic self-assessment tool was used by POL to
improve “speaking up” arrangements. Both self-assessment findings
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are exhibited at POL00423542 and POL00423615. These reviews
demonstrated that POL’s whistleblowing policy was well articulated
but that the organisation needed to significantly strengthen training
of staff, wider communication and engagement to make people
aware of how to raise whistleblowing concerns, operational maturity
and reporting trends and themes to those charged with governance.
(ii) PHASE 2: More regular oversight via a Whistleblowing Champion
NED (addressed in further detail at paragraphs 53 and 54).
(iii) PHASE 3: A further external review of the entire disputes,
investigations and whistleblowing teams by KPMG known as Project
Birch in August 2021. The Project Birch Review was commissioned
by General Counsel to ensure it was well organised, led by qualified
and professional experts, and was open, transparent and
accountable in its operations. Whistleblowing investigations were
covered in this review to enable the Executive to ensure that all
disputes and investigation teams operated to the same high
standard of best practice. I address the actions arising from this
review at paragraphs 55-56.
(iv) PHASE 4: A further external review specific to whistleblowing
practices was commissioned around 1 September 2022 from Ernst
& Young’s Forensics and Integrity Services (“EY”). Correspondence
setting out the Terms of Reference for this review and the Terms of
Reference themselves are produced at POLO0448820 and
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POL00448819. This was commissioned for the Executive by John
Bartlett, who had joined POL in February 2022 as Head of the newly
created Central Investigations Unit (“CIU”) which had been
recommended by the KPMG Review in August 2021. However, my
recollection is that this review was delayed to March 2023 due to the
team’s workload, and just before I left the Board in March 2023, I
was interviewed by this EY team on 9 March 2023.
The ARC, on behalf of the Board, had primary responsibility for monitoring the
adequacy and effectiveness of whistleblowing systems and controls. Progress
updates were taken at the ARC and any significant issues were escalated to the
Board’s attention by the Chair of the ARC. The ARC considered whistleblowing
practice at its meetings on the following dates:
e 28 January 2020: This consisted of a brief update on the supporting system
contract which had ended and the need to move to a new case management
and whistleblowing hotline provider, Convercent, (UKGI00044221) which was
implemented in July 2021;
¢ 27 July 2020: The Whistleblowing Policy from July 2020 was reviewed in line
with usual practice and only minor administrative changes were made that did
not affect the policy (POL00030903);
¢ 30 March 2021: (POL00030930) An action plan for improving and maturing
whistleblowing policy, processes and culture was agreed as follows:
(i) The Executive team carried out a self-assessment benchmarking
exercise supported by PROTECT. This report dated February 2021
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(POL00423542) showed that POL’s written policy was in good order
but that the areas of training, communications and engagement,
operational maturity and transparent reporting needed to be
significantly strengthened to ensure that people could raise their
concerns and trust they would be dealt with properly and any issues
addressed. The benchmark was set against financial services
organisations which generally have very high standards for
whistleblowing practice. A follow up self-assessment was completed
in November 2021 (POL00423615) and improvement was noted but
also that further work was needed to improve reporting of outcomes
and trends, training of line managers and raising awareness.
(ii) The appointment of a NED as a Whistleblowing Champion. I agreed
to carry out this role and I address in detail the oversight I provided
on behalf of ARC, at paragraphs 53 and 54 below. This role allowed
the ARC to be satisfied that detailed oversight of whistleblowing was
being exercised regularly by a senior member of the Board.
(iii) I The appointment of a dedicated and experienced Whistleblowing
Manager to oversee the policy and strengthen its operation in
practice. This appointment was subsequently made in March 2021
when POL recruited an experienced Compliance and Integrity Manager,
Jenny Brady. Jenny Brady commenced her role on 4 May 2021. She
had previously worked as a Business Integrity Officer and had direct
experience of ethics and compliance and especially whistleblowing best
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practice. I believe this was the first time that POL had a dedicated leader
and team to support effective whistleblowing.
(iv) I Amandatory whistleblowing training program for employees and line
managers was to be put in place for all staff to raise awareness of
whistleblowing and how to report and deal with concerns.
The ARC in September 2021, undertook a further interim review of the
whistleblowing procedures, controls and key trends and themes from
whistleblowing reports in the fiscal year 2020/21. It also noted the progress made
in improving policy and processes since the last benchmarking review conducted
with PROTECT in February 2021, (POL00423542) as well as discussing what
further improvements were needed. The key improvement noted from the
PROTECT benchmarking was to appoint a dedicated whistleblowing investigation
manager which was actioned. The review also noted that there were no
whistleblowing complaints related to the ClJ and HlJ. In my judgment, following
the focused effort I have described above, I was satisfied that the culture in POL
was starting to actively encourage whistleblowers to speak openly and honestly
about their concerns. I had no doubt though that whistleblowing practices needed
to continue to mature and therefore the further work noted in paragraphs 55-56
was important.
As to my personal contribution to improving POL’s culture to encourage
whistleblowers to speak openly and honestly about their concerns, I was
appointed the Whistleblowing Champion from April 2021. The Terms of Reference
for this role were set out in the Whistleblowing Policy dated March 2022
(POL00091478) and included the following:
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(i) A positive whistleblowing culture is proactively encouraged;
(ii) Current arrangements are challenged and assessed for areas of
continuous improvement and best practice;
(iii) I Whistleblowers are always supported and protected when raising a
concern;
(iv) Barriers to speaking up are uncovered and addressed;
(v) The whistleblowing teams, senior managers and leaders receive
training on the importance of whistleblower support; and
(vi) I Root cause analysis is undertaken for all cases and issues so that
continual improvements can be made in the relevant areas.
54. In becoming Whistleblowing Champion I carried out the following activities to
deliver regular oversight:
(i) I undertook training on effective whistleblowing practice from
PROTECT and The Institute of Business Ethics and read journals
and articles from professional bodies to keep up to date;
(ii) I met on a quarterly basis with the Whistleblowing teams which
included Sally Smith, Head of Financial Crime, Jenny Brady,
Compliance and Integrity Manager and John Bartlett, Head of CIU.
A typical agenda would cover: management information on
whistleblowing issues, actions progressed according to the ARC
approved plan following the two PROTECT self-assessments in
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2021 and increasing the effort to actively promote whistleblowing
internally to increase engagement and build trust that concerns
would be taken seriously;
(iii) I The improvement of management information (“MI”) to provide data
accurately and efficiently. This did take time to develop, and the
most recent MI report before I left, dated February 2023, gave a
comprehensive view of cases, trends and themes and root cause
analysis for executive action. I produce this document at
POL00448821. Effective reporting was a key area of my challenge
to the whistleblowing team;
(iv) I The instruction of KPMG to review how POL investigations should
be organised so that resources relating to whistleblowing were not
taken up by complaints that should be made via alternative
channels;
(v) I promoted my role in overseeing whistleblowing via communications
as well as introducing the training online course.
(vi) Where a case was complex I would act as a sounding board to the
team to ensure that the investigation process was thorough and that
POL’s reports back to the whistleblower were helpful to them.
I now turn to KPMG’s independent review of POL’s disputes, investigations and
whistleblowing (“Project Birch”). This was commissioned by Ben Foat in August
2021 to ensure that this area was well organised, led by appropriately qualified
and professional experts to the appropriate investigation standards to achieve a
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fair and objective outcome and that it was open, transparent and accountable in
its operations. Whistleblowing investigations were covered in this review to enable
the POL Executive to ensure that all disputes and investigation teams operated to
the same high standard of best practice. As Whistleblowing Champion I went
through the results of this review and worked to ensure that the recommendations
as they related to whistleblowing were actioned promptly. The majority of the
findings of this review concerned areas outside the whistleblowing team’s
activities but nevertheless the review’s recommendations on best practice were
relevant and I agreed with Ben Foat that the whistleblowing team should move
under the new leadership of the CIU to ensure that there was consistency of
operations, increased availability of experts working to the same professional
standards and access to more experienced, professional and senior leadership of
this area. I produce two pages from the draft version of the Project Birch Report
as I have not been given access to a final version at POL00448827 and
POL00448828 respectively.
These actions included a consistent standard for all investigations, a consistent
triage process, a consistent approach to training and quality assurance over
investigations, limiting the use of area and line managers in investigations to
increase independence and capability and bringing more rigor to root cause
analysis and lessons learnt.
In September 2022, John Bartlett as Head of the CIU, recommended an update
to the terms of reference for the Whistleblowing Champion role (now known as the
Speak Up Champion) and this added contextual detail but did not change the
purpose of the role itself (POL00448822).
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58.
59.
60.
61.
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In my role as the Whistleblowing Champion on behalf of the ARC I consider that I
fulfilled my role with diligence and care and thereby enabled POL to actively
encourage SPMs, employees and members of the public to speak honestly and
openly about their concerns.
I believe that the extent of the work summarised above reset the entire
whistleblowing culture, practice and awareness. Whistleblowing reports grew in
this time which is I believe a sign that people, whether employees, SPMs or the
public, were beginning to trust in the effectiveness of whistleblowing and speaking
honestly and openly about their concerns. The Executive started to have better
access to whistleblowing themes and trends so they could incorporate
improvements in process as a result.
By the time I left POL in March 2023 I was confident that the changes in senior
leadership of whistleblowing and the accountability to the Board had shifted in the
right direction and that the regular external best practice reviews would continue
to ensure that focus was continually maintained in this area. I do note that the
increase in whistleblowing reports and their complexity, as they covered issues
such as financial crime and significant money laundering, meant that investigatory
resources were stretched, and investigations were taking considerably longer to
complete. I ensured that my successor as Senior Independent Director, Benjamin
Tidswell, had my perspective on this issue so he could keep this under review.
I am aware of one matter where someone had blown the whistle to POL since the
findings of Fraser LJ in a matter directly relevant to the issues being explored by
the Inquiry. This matter arose sometime between June and July 2022 and
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62.
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involved a whistleblower making a report directly to the CEO alleging the POL
Security Team had historically been financially incentivised to pursue criminal
prosecutions against SPMs to recover sums in excess of what POL was due in
compensation. Due to the seriousness of this complaint and the need for an
independent, external investigation, POL commissioned Peters & Peters LLP to
conduct an investigation. I am aware Peters & Peters LLP’s report and
conclusions were voluntarily disclosed in criminal appeal proceedings as well as
to this Inquiry. The whistleblower was informed of the outcome of that
investigation by POL’s Speak Up team as it was considered to be a whistleblowing
event, albeit independently investigated.
At the 30 March 2021 ARC meeting, the whistleblowing team had also reported
their analysis of all whistleblowing reports from April 2013 to January 2021 to
identify non-conformance with the ClJ and HIJ and whether any detriment had
been suffered (POL00030930). A total of 163 reports received since 2013 were
reviewed and summarised for the ARC, showing a possible 15 cases that could
have suffered detriment but which the Executive considered were justified in the
circumstances and 21 cases where issues with ClJ conformance were identified
and were being dealt with by the team addressing the Historical Shortfall Scheme
and related remediation.
I believe there are two reasons for why there appeared to be few whistleblowing
reports directly related to the ClJ and HIJ matters in my time on the POL Board
from November 2019 to March 2023. First, as I note in paragraphs 18G, 30, 31
and 32 above, the extensive engagement with SPMs via various fora gave
immediate and direct feedback to the Executive of any issues; and second, the
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new SPM Support Policies allowed disputes to be reported much more easily and
quickly and taken into a much improved resolution process earlier.
64. I have been asked to address my understanding of Legal Professional Privilege
(“LPP”) and the extent to which such information may be shared with the Board of
a company. I am not legally qualified. I understand that LLP protects certain
confidential communications between lawyer and client from disclosure without
the client's permission. Based on my limited understanding of legal professional
privilege I had no concerns over the sufficiency of the provision of legal information
to the Board and the relevant mechanisms for doing so.
DEPARTURE FROM THE POL BOARD
65. __I was due to finish my three-year term of office in December 2022 following the
appointment of Henry Staunton as Chair of the POL Board. I agreed to stay
beyond my term to 13 March 2023 to enable continuity whilst my successor was
appointed.
66. Asis normal for NED appointments, both the company and individual makes a
decision to either leave the Board or recommit for a further term of three years. In
my case I had both personal and professional reasons for deciding not to take up
a second term.
67. My personal reasons are that my sister had a stroke in October 2021 and her
husband had advanced Alzheimer’s at the same time and therefore I wanted the
time to provide care and support for both of them.
68. My professional reason was that of necessity. POL’s business strategy had
changed since I joined and there was little call for business, customer and digital
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transformation skills and experience which is the primary reason I was appointed
in 2019. Moreover, at the time of my appointment, POL’s strategic priorities were
to deliver a lean, competitive cost base; strengthening and growing the branch
network through a continued shift to retail hosted hubs and driving growth in
financial services through digitally enabled customer propositions. The strategy
had changed as the Shareholder was unable to provide financing for restructuring
and re-shaping the retail network or investing in digitally enabled services. In my
judgment, that meant that the Board needed to focus even more on safeguarding
its position as the UK’s foremost letters and parcels retailer and that strategy
needed NEDs with extensive mails distribution and logistics experience. This was
an area of strong competitive challenge and why the strategy needed to be
reframed going forward. I therefore chose not to commit for a further three years
as my skills would be more relevant elsewhere.
69. I did explain my reasons in an exit interview arranged by the new Chair on 1 March
2023 before my departure. I believe the interview was with Wil James of EYLane4.
I sought disclosure of this document from POL but have been advised it could not
be located.
KEY EVENTS
70. I have been asked to explain my understanding of the matters raised in The Times
article “Postmasters on Post Office board ‘ignored and unwanted” (RLIT0000201)
dated 19 February 2024. As I left the Board on 13 March 2023 and thereafter had
no access to the Board’s business after that date, I am unable to assist with this
specific query. However, as noted in paragraphs 18G, 30, 31 and 32 of my
statement, I have referred to my firsthand observations as to the fundamental
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importance of the SPM NEDs and their influence on the Board. In my time at POL
I did not observe anything that would have led to the statement allegedly made by
Elliot Jacobs that he and Saf Ismail were “ignored and seen [...] as an annoyance”.
71. I had a good working relationship with all members of the Board, including Elliot
Jacobs and Saf Ismail. I was aware they felt, at times, that the Executive were
not as responsive to SPM-related changes as they would have liked. Inevitably
not every single operational point they made could be actioned with speed by the
Executive, because there was so much to do on so many fronts, with the most
critical mission being to correct the miscarriages of justice and make financial
redress to SPMs. That had to be the Executive and the Board’s primary focus.
Notwithstanding this, I observed firsthand that both SPM NEDs openly shared
their points of view with the Board, were heard and their points of view acted upon,
which is demonstrative of the fact their perspectives were respected and reflected
on by the Board during my time as a NED.
72. AsIhad left the POL Board on 13 March 2023 I have no information to share with
the Inquiry regarding the dismissal of Henry Staunton as Chair on 27 January
2024.
73. AsIhad left the POL Board on 13 March 2023 I have no information to share with
the Inquiry regarding the resignation of Alisdair Cameron on 25 June 2024.
Statement of Truth
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I believe the content of this statement to be true.
Datea:_G Deplembel 224
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Index to First Witness Statement of Ms Zarin Patel
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No. URN Document Description Control Number
News article from TheIRLITO000201
Times titled 'Postmasters
1 RLIT0000201
on Post Office board
‘ignored and unwanted’
Meeting minutes: meeting I POL0000105
minutes for Board
2 I POL00021572
meeting held on 26th
November 2019
Induction briefing I POL-0110200
3 POL00112763 document provided by
POL Company Secretary;
POL - Board Report: }POL-BSFF-WITN-043-
Operational Improvement I 0000001
4 I POL00448823
Plan - Author: Julie
Thomas
Post Office: Improvement I POL-BSFF-WITN-043-
Delivery Group: Monthly I 0000005
5 I POL00448825
Update - 3 June 21:
Board Noting Paper - V. 1
Tab 3.4 Internal Update - I POL-BSFF-WITN-043-
6 I POL00448826
Audit, Risk
0000006
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and Complaint Committee
POL00448829
POL Internal Audit
Update - Tab 3.3. -
BoE Note Circulation
Scheme & IDG
Assurance Phase 3.
POL-BSFF-WITN-043-
0000009
POL00114796
Post Office Limited.
Minutes of a
Meeting of the Audit, Risk
and
Compliance Committee -
12th July
2022.
POL-0113902
POL00413444
Post Office Limited -
Group Policies -
Whistleblowing Policy
POL-0193906
10
POL00030903
Post Office Group
Policies -
Whistleblowing Policy v5
5 July 2020
POL-0027385
11
POL00091478
Post Office Group
Whistleblowing
Policy - Version V7
POL-0091041
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12
POL00423542
360 Benchmark Report
18/02/2021
POL-BSFF-0238357
13
POL00423615
Benchmarking report
POL-BSFF-0238430
14
POL00448819
PowerPoint Slide Deck -
Forensics and
Integrity Services -
Whistleblowing
Assurance Review -
Confidential.
POL-BSFF-WITN-017-
0047913
15
POL00448820
Email from John Spencer
to Claire
Hamilton, John Barlett
CCing others
RE: EY/Post Office
POL-BSFF-WITN-017-
0047914
16
UKGI00044221
Post Office Limited Audit
Risk &
Compliance Committee
Reports
UKGI052758-001
17
POL00030930
Post Office Ltd Audit,
Risk &
Compliance Committee
Report,
Whistleblowing Policy
Review &
POL-0027412
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Report, Sally Smith - 30
March 2021
POL CIU MI Report
POL-BSFF-WITN-017-
18 I POL00448821
0048224
KPMG Current State POL-BSFF-WITN-043-
19 I POL00448827 Assessment by 0000007
Incident Type Register.
Whistleblowing - POL-BSFF-WITN-043-
20 I POL00448828 Overview of current 0000008
Investigation Process
The Speak Up Champion I POL-BSFF-WITN-031-
21 I POL00448822 Terms of 0011458
Reference
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