WITN11510100 Laura Thompson - Witness Statement

Evidence on official site

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Witness Name: Laura Thompson
Statement number: WITN11510100

Dated: 5 November 2024

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF LAURA THOMPSON

I, LAURA THOMPSON, will say as follows:

1. I have been employed by the Shareholder Executive (“ShEx”) / UK Government
Investments (“UKGI”) at various points during my career, which I set out below. I am

currently employed as an Assistant Director at UKGI and have been since June 2021.

2. This statement is made in response to a Rule 9 Request made by the Inquiry dated 20
August 2024. I have sought to address all of the questions posed by the Inquiry in a
format that I hope will aid understanding of my involvement. This statement is made to
the best of my knowledge and belief. If I have referred to a fact that is beyond my own
personal knowledge, I believe it to be true. Where I refer to my knowledge being derived
from others, I have sought to identify the source and to include this in my statement. I
have also referred to relevant contemporaneous documentation in support of my
response, to the extent that I considered this was likely to be of assistance, and I have
exhibited those documents as requested. In making this statement, I have been

assisted by instructed Counsel and Eversheds Sutherland (International) LLP, the

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recognised legal representative for UKGI, a Core Participant (as defined in paragraph

5(a) of the Inquiry’s Protocol on Witness Statements) in the Inquiry.

3. I would like to start by acknowledging the profound impact that the issues relating to
the Horizon system have had on subpostmasters (“SPMs”) and the many other
individuals who have been affected by this scandal. I welcome and support the work of
the Inquiry in investigating these events, and am grateful for the opportunity to try to

assist the Inquiry in this vital work.

Background / Work History

4. I joined the Civil Service in September 2008 on the Civil Service Fast Stream, a
graduate programme. I was appointed to a role in the Department for Business,
Enterprise and Regulatory Reform (“BERR”), which subsequently became the
Department for Business, Innovation and Skills (“BIS”) during my tenure, both of which
are predecessor departments to what is now the Department of Business and Trade

(collectively referred to hereafter as the “Department").

5. My first role in the Department was in the central finance function; after a year in that
post, I moved to a role working on automotive sector policy, where I remained for a
further year. In August 2010, I accepted my first role within the Shareholder Executive
(“ShEx”) as an Assistant Bill Manager for the Postal Services Bill (“the Bill”), later the

Postal Services Act 2011.

6. My role in the Bill team was largely one of coordination and project management, and
I was not directly responsible for any policy advice relating to Royal Mail, Post Office or
the wider provisions of the Bill. To perform my role effectively, it was nevertheless

important for me to understand the provisions of the Bill and the wider policy relating to

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Royal Mail and Post Office, to allow me to both advise on legislative strategy (such as
Parliamentary handling and concessions) and support the team in responding to
queries from Ministers during the legislative process, including during Parliamentary
debates. I therefore worked with colleagues across both the RMG and POL teams
within ShEx, as well as colleagues in other parts of the Department such as those
dealing with the regulatory regime. My manager was Leonie Lambert, a Grade 7 within
the Bill team in ShEx. The Bill team was led by Jo Shanmugalingam, a Grade 5, and

Susannah Storey was the responsible Director for RMG and POL including the Bill team.

The Ministers I worked with and provided advice to were: the Rt Hon Sir Edward Davey,
who at the time was the junior Minister in the department responsible for postal affairs
and was the lead Minister taking the Bill through the House of Commons; and Baroness
Wilcox (now retired from the House of Lords), who was the Lords Minister in the
Department taking the Bill though the Lords. The Secretary of State (the Rt Hon Sir
Vince Cable) had less involvement in the day-to-day work of the Bill during its passage
and beyond helping to draft his speech for the Commons Second Reading debate, I

personally did not engage with or advise the Secretary of State directly at this time.

In around July 2011, following Royal Assent of the Act, I left ShEx to take up a position
as Private Secretary to the Secretary of State for BIS, the Rt Hon Sir Vince Cable.
There are several private secretaries in the Secretary of State’s office and the work of
the Department is divided into separate portfolios for each one. My portfolio, which
remained largely the same during my time in the role, included responsibility for ShEx
in general, but specifically did not include Royal Mail and Post Office, which due to the
size of the policy area sat in the portfolio of another private secretary, as it had done
prior to my arrival in the team. As such, during my time in the Secretary of State’s office,
I had very little direct involvement in or sight of any advice relating to the Post Office or

wider postal affairs. I remained in this role for a little over a year, which is a common

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tenure for a private secretary. For the final month of my time in private office
(September 2012), I stepped in to cover a vacancy by acting as Senior Private
Secretary to the postal affairs Minister. This was initially Norman Lamb MP, but a
Ministerial reshuffle took place very shortly after I joined the office, and the role was
taken over by Jo Swinson MP. I covered this private secretary role until a permanent
replacement was able to start in late September. I do not recall anything relating to

Horizon arising during my short time in that office.

Having completed four postings within the Fast Stream programme, I successfully
applied for a Grade 7 role within ShEx in September 2012 to work as a senior policy
advisor for the software and ICT sectors. As part of this I was involved in the
Government's strategic relationship management of three companies — Microsoft, HP
and IBM. This did not include Fujitsu and to the best of my recollection I had no
meetings with Fujitsu representatives as part of this role. During this period of
employment in ShEx, I had no role in relation to Post Office or wider postal affairs and

had only a general awareness of the work of the RMG and POL teams at this time.

In November 2013, I moved to the Department of Energy and Climate Change (“DECC”)
on a secondment from BIS to take a dual role as Strategic Policy Advisor and Senior
Private Secretary to the Strategy Directors, a Grade 7 role. The role of Strategy Director
was held by Susannah Storey and Jo Shanmugalingam, who were then working as a
job-share. Ms Shanmugalingam was my line manager during my time at DECC. I was
aware at this time of Ms Storey’s role as the Shareholder NED on the POL Board, but
my responsibilities within her office related only to her DECC role. I had no engagement
with Post Office or ShEx, or sight of any emails or papers relating to her POL role. My

role at DECC had no relation to postal affairs.

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Late in 2014, I applied for an Assistant Director (Grade 6) role on promotion within ShEx
to be part of the POL Shareholder Team (the “POL Shareholder Team”), and having
been successful, returned to BIS to take up this role on 26 January 2015. The hiring
manager was Richard Callard, who became my line manager. My responsibilities in

this role are set out in the following section.

In the autumn of 2015, I was asked to work on the legislation to enable the sale of the
Green Investment Bank (“GIB”), and split my time between my POL and GIB
responsibilities. My role on the GIB legislation came to an end in March 2016 with Royal
Assent of the Enterprise Act 2016. Thereafter, I continued in my role on POL while also
working on some other projects including joining the shareholder team for Highways
England (now National Highways) for a short period. In July 2016, I was asked to return
to the team tasked with the sale of the GIB, this time with responsibility for managing
the transaction, a role which I carried out from July 2016 until the GIB transaction
completed in August 2017, although I remained involved in post-transaction matters on
GIB until approximately December 2017 or early 2018. Throughout this period, I

continued my role in the POL team alongside this GIB work.

In September 2017, I joined the shareholder team for HM Land Registry (“HMLR"),
initially continuing my POL role alongside this. Around February / March 2018, I was
temporarily promoted to Executive Director to cover a period of maternity leave in the
HMLR shareholder team, and given this increase in responsibility, in around April 2018,
I handed over my remaining work on POL to Stephen Clarke in the POL team. My

involvement in POL matters therefore ended at this time.

In February 2019, I left UKGI and took up a role at Macquarie Group, as a senior lead
for Government Affairs for Europe, the Middle East and Africa (“EMEA”), based in

London.

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15. In June 2021, I returned to UKGI as an Assistant Director to work on the establishment
of the UK Infrastructure Bank, a role that I carried out until October 2023. Between
November 2022 and January 2024, I was also UKGI’s head of resourcing as maternity
leave cover and from March 2023 until August 2024 worked in the shareholder team
for the Atomic Weapons Establishment plc. My current roles are in the shareholder
team for Ordnance Survey, which I have done since November 2023, and working for
the Department for Energy Security and Net Zero on the establishment of Great British
Energy, since July 2024. Since my return to UKGI in 2021, I have had no direct
involvement in postal affairs or the POL Shareholder Team, although I do line manage
one individual who works for part of his role as a Manager in the POL Shareholder
Team, and my own line manager is an Executive Director who works as part of his role

in the POL Shareholder Team.

Role in the POL Shareholder Team

16. I applied for my role in the POL Shareholder Team around November or December
2014. At the time there were two roles being advertised: one a Grade 7 role with
responsibility for issues relating to the Post Office network and the relationship with the
National Federation of Subpostmasters (“NFSP”), envisaged as a largely full-time role;
the other a Grade 6 role with responsibility for issues relating to POL’s Government
Services business as well as wider governance matters within the POL Shareholder
Team, with this envisaged as taking around 50% of a full time role and with the
remainder of the time to be spent on other projects to be determined. This approach
was common within ShEx and I was familiar with the model of working on multiple
projects. Richard Callard was the hiring manager for both roles, as the head of the POL
Shareholder Team. I successfully applied for the Grade 6 role and started this role on

26 January 2015.

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Prior to starting in the role, Richard Callard and I discussed what areas I would take
responsibility for within the team. Alongside the government services work that had
been advertised in the job description, we agreed I would also cover appointments and
remuneration matters including the upcoming recruitment of a new Chair of the POL
Board, and that I would take on the work relating to Project Sparrow, which was a term
originated by POL and was used by UKGI to refer to matters relating to complaints
about potential issues with the Horizon system, including the Mediation Scheme. This
work had previously fallen to Peter Batten prior to his departure from the POL team in

late 2014.

My role had been advertised as spending around 50% of my time in the POL
Shareholder Team and with the remainder on other ShEx projects. Initially I spent my
time working almost 100% on POL matters, which was partly a factor of me getting up
to speed in the team, and partly due to there being a number of areas of work which
required an increased time commitment, particularly the public appointment process for
the POL Chair, making progress in establishing POL as a ‘front office for government’
which was a key Ministerial priority, and matters relating to Project Sparrow. I therefore
spent the majority of my time from January 2015 to around September 2015 working
on POL. From September 2015, I reduced my time commitment down to closer to the
previously envisaged 50%, and took on the role on the GIB legislation as set out in

paragraph 12 above.

The ShEx / UKGI model is one of bringing together people with expertise from both the
public and private sectors to enable the provision of sound commercial advice for the
stewardship of public assets, which takes into account the public sector context in which
Ministers and officials operate. At the time I joined, the POL Shareholder Team was no

different. Richard Callard as head of the POL Shareholder Team and the Shareholder

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NED on the POL Board brought private sector expertise, as did Tim McInnes, another
Assistant Director in the team, whose role was primarily focused on POL’s financial
performance and its mails and financial services businesses. I brought experience of
working in government, with Parliament and with Ministers through my previous roles,
and in March 2015 Michael Dollin joined the team in the Grade 7 role set out in
paragraph 16 covering the POL network, also with a civil service background. The team
was supported by James Baugh who covered POL funding and managed
correspondence and similar issues (such as Parliamentary Questions and briefing
requests), and Jessica Willliams who also assisted on correspondence. Director
oversight of the team was provided initially by Anthony Odgers, and later by Justin

Manson.

While team members had their own areas of responsibility, we kept each other updated
and sought advice from each other where another team member's advice or
perspective would be valuable. We would often discuss issues collaboratively, either
informally in the office or in regular team meetings. In addition, each team member
would meet regularly with Richard Callard, as head of the POL Shareholder Team. I
consider Mr Callard to be a good leader of a team, ensuring team members have
individual areas of focus and autonomy while ensuring he retains managerial

responsibility and oversight.

The appointment of a new POL Chair was a particular focus during the early months of
my employment. This was a public appointments process, regulated by the
Commissioner for Public Appointments. My role was to support the appointment panel,
by facilitating the panel's meetings, taking notes of the discussions and producing
factual submissions to update the Minister that would enable them to take decisions.
Mark Russell, ShEx’s CEO, was a member of the appointment panel and provided the

shareholder view. In July 2015, Tim Parker was selected by the Minster and he took up

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the role in October. He remained as Chair of POL throughout the remainder of my time
in the POL Shareholder Team. The Inquiry has also asked whether I had any
involvement in the appointment of POL’s CEO, but by the time I joined the POL
Shareholder Team the CEO (Paula Vennells) had already been in post for three years

and she remained in post throughout the period of my involvement in that team.

Risk Reporting

22. A task undertaken by the POL Shareholder Team was updating the ShEx risk register
for POL as an asset in the ShEx portfolio. There would be a risk register maintained for
each portfolio asset, which considers key risks to the asset from a shareholder
perspective. During my time in the POL Shareholder Team, the risk registers were
updated on a monthly basis, and this would involve the team considering each risk on
the register, determining whether there were any changes to reflect to the nature of the
risk, its likelihood or impact, or any mitigating actions, and briefly summarising the
current status of the risk or actions. I was responsible for updating the risks assigned
to me which included a single risk on Project Sparrow, and Richard Callard would
review the updated risk register as a whole before it was submitted to the central team
within ShEx or UKGI responsible for coordinating risk reporting. The risk process
evolved during the period of my involvement: after ShEx became UKGI in 2016, a
system of ‘risk reviewers’ was put in place, which assigned a peer within UKGI
(normally at the Manager or Assistant Director grades) from a separate team to provide

further peer review and challenge of risk registers.

23. Alongside the risk register, there were additional, complementary tools to report key

issues relating to portfolio assets and assess their overall performance and risk,

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including a dashboard and a series of ‘traffic lights’ looking at key performance and risk

metrics.

I understood that these products — the risk register, dashboard and traffic lights — would
be centrally coordinated and considered by the ShEx / UKGI Executive Committee and
Board. This was handled by a separate team and I do not recall ever being involved in
providing any additional risk reporting relating to POL or Project Sparrow. The risks in
relation to POL that would have been fed into that process would have been drawn

from the asset-level risk register that I contributed to.

In addition to the monthly risk register updates, ShEx / UKGI also regularly held portfolio
reviews for each asset in the portfolio. For POL these were held quarterly. These
reviews, led by an experienced Director or Executive Director and with a panel of
colleagues from outside the POL Shareholder Team, provided challenge and advice
on the team’s work and in particular the management of key issues and risks facing the

asset.

At the time that I joined the POL Shareholder Team in January 2015, the nature of the
risk in relation to Project Sparrow was considered to be reputational and financial. By
this stage, Second Sight had produced its interim report and I understood that this had
not identified any systemic issues. The Mediation Scheme was also in place, and my
understanding at the time was that Second Sight, supported by POL, was continuing
to investigate the cases of individual SPMs. As such, when I first updated the risk
register for POL in February 2015 (UKGI00003437) I agreed with the previous
assessment that the primary risks in relation to Project Sparrow were reputational,
financial and people: the work underway to resolve the issues raised by individual
SPMs had the potential to continue to generate negative commentary in the press and

Parliament, to increase costs to POL through the continued funding of the Mediation

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Scheme, and overall to impact upon POL’s relationship with its wider SPM population.
I did not include in the risk register the risk that Horizon might have bugs, errors or
defects (“BEDs’”) that could affect the integrity of branch account data, because that did
not appear to be a significant risk at the time given the amount of investigation that had
taken place. From a risk register perspective, our concern was to highlight the risks that
we were seeing arising from POL's current actions and the potential impact of these

risks on the shareholder.

The same can also be said as to why I did not initially include the risk that POL may
have secured unsafe convictions. At the time, such a risk would only have been
apparent to me if systemic issues with the Horizon system had been identified or POL
had made us aware of legal advice to that effect. However, as can be seen from the
risk register that I updated in late March or early April 2015 (1 am unable to identify from
the document precisely when) (UKGI00004091), in light of the Department receiving a
request to preserve information in relation to the cases that had been referred to the
Criminal Cases Review Commission (CCRC), I changed the nature of the risk to ‘legal’
and updated the status of the risk to recognise this development and that advice was

being taken.

In relation to all of the risk registers that I have been asked to review in preparing this
statement, I think it is also important to bear in mind two points of more general
application. First, the asset-level risk register is a snapshot of the risk issues as they
are perceived to be at that point in time. Whilst the risk of BEDs within Horizon might
therefore have been perceived as a significant risk at another point in time (for example
in 2012 when these issues were raised with Ministers) and therefore merited inclusion
within the register, by the point that I joined the team these risks were viewed as less
significant as a result of Second Sight’s work, its continued investigation of individual

cases and interim findings. Secondly, the risk registers are a means of recording and

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reporting on the current and most significant risks and issues in relation to an asset,
rather than the sole tool with which we manage risk. The fact that a specific risk, such
as the risk of unsafe convictions, might not appear within a specific risk register does
not therefore mean that we did not have any sight of or perspective in relation to that
issue. The work of the POL Shareholder Team was much broader than the few lines
recorded in the risk register and our awareness of issues that were affecting or might
potentially impact an asset was therefore much greater than may be suggested by

reference to the risk registers alone.

29. The Inquiry has also asked me to review several risk registers and documents labelled
“POL team planner” which predate my joining the POL Shareholder Team in January
2015. I am unable to comment on these as I was not involved in their preparation. I do
not recall ever contributing to a “POL team planner” and believe this to be an internal

team product no longer in use by the time I joined in 2015.

Introduction to Project Sparrow

30. I As explained above, shortly before I joined the POL Shareholder Team, Richard Callard
asked me to assist him with the work in relation to Project Sparrow, describing this to
me as an issue which would require ongoing political advice and handling. As I had
good experience of working with and briefing ministers, including an understanding of
the importance of their Parliamentary responsibilities and accountability, and the
general workings of government, he considered this area would be well suited to me,

requiring a public sector view and not just a commercial perspective.

31. I did not have any awareness of the issues raised in relation to the Horizon system prior
to being informed of them by Richard Callard. I did not recall any matters relating to

Horizon coming up during my previous role on the Postal Services Bill including during

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any Parliamentary debates during the Bill’s passage, or during my time working in the
offices of the Secretary of State or, briefly, Jo Swinson. As part of my introduction I did
some desk-based research, including reviewing previous press coverage such as
articles in newspapers and on BBC programmes where some affected SPMs had
shared their stories. I had not seen any of this coverage prior to joining the POL

Shareholder Team.

I did not have a handover discussion with Peter Batten, who had previously been
dealing with Project Sparrow, as he had already left the Department for a new role, but
I did have a number of discussions with Richard Callard concerning the background

and the Government's position on the matter.

In December 2014, just prior to my joining the POL Shareholder Team, there had been
a Westminster Hall debate on the matter which the Minister, Jo Swinson MP, had
attended and responded to for the Government. (POL00030457) As part of building my
knowledge on the issues raised relating to Horizon, I read the Hansard for this debate,
as well as the Hansard record for the Minister's statement from July 2013 in relation to

the Mediation Scheme (UKGI00001820).

In my first week in the role, I assisted with the redrafting of a letter for the Minister, Jo
Swinson MP, to send in response to correspondence that had been received from Sir
Alan Bates on behalf of the Justice for Subpostmasters Alliance (“JFSA”). My brief was
to reflect the Minister's steers on tone. I also attended the BIS Select Committee
evidence session relating to Horizon which took place on 4 February. I cover both these
points in more detail later in my statement. Both provided me with further opportunity
to understand the issues being raised and the Government's position. Alongside this, I
read previous briefing notes and submissions, the content of the JFSA’s website, and

other material available in the public domain.

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Communication with POL

35. The work of the POL Shareholder Team required us to have an effective working
relationship with POL. This involved regular communication, including formally through
structured meetings such as the Quarterly Shareholder Meetings (“QSMs”) held with
POL senior management, as well as more frequent and informal discussions including
face to face meetings held either in the ShEx / UKGI offices or POL head office,
telephone calls and emails. This was the case not only in relation to Horizon matters

but across the work of the POL Shareholder Team.

36. In addition, Richard Callard’s role as Shareholder NED on the POL Board provided a
mechanism to receive information on POL’s business and activities, and to raise issues
directly. Mr Callard would receive the full set of Board papers and these were shared
with members of the POL Shareholder Team, with a Non-Disclosure Agreement in
place with POL to give them sufficient comfort to share the Board papers with

individuals who were not directors of the company.

37. Members of the team would read any Board papers, and accompanying documents,
relevant to their area of specialism. I would usually read the majority of the pack to
ensure I was aware of the range of issues discussed by the Board and to provide
support to Richard Callard as part of his preparation for Board meetings. I would flag
any points of interest from my review to him, either verbally or via email, for him to
consider raising. In particular, I would ensure I had reviewed fully any Board papers
relevant to POL’s government services business, to matters of appointments and

remuneration (noting these would normally be for the Nominations or Remuneration

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39.

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sub-committees), and Project Sparrow. Often, updates on matters relating to Project
Sparrow would be included within the CEO’s report rather than as standalone papers.
I recall that on several occasions it was noted that the Project Sparrow update would

be provided verbally in the meeting.

Richard Callard also sat on the Sparrow Subcommittee (“Subcommittee”) of the POL
Board. I did not attend any of these meetings, but had access to any papers provided
to Mr Callard as part of the Subcommittee. I recall the Subcommittee only meeting a
small number of times during my tenure, with updates going to the main POL Board

thereafter.

As I set out below, I considered at the time that we had regular and effective
communication with POL at working level on matters relating to Project Sparrow, and
this was reflected in the reports I received back from Mr Callard on what had been
discussed at the Board. As far as I was aware, there was nothing provided to the Board
by way of updates on Project Sparrow during my time in the POL Shareholder Team

that I had not been made aware of through my working level contacts.

The POL Board papers were not shared with Ministers. If the Board papers contained
matters which we considered needed to be shared with the Minister, or if such matters
were raised during Board discussions, we would either inform the Minister by way of a
written submission or an update in a meeting, or ask POL to provide a written update.
POL senior management also met with Ministers directly, either for regular updates

(once or twice per year) or to discuss specific issues.

In terms of formal set-piece meetings with POL, there were the four QSMs held each
year between the POL Shareholder Team and POL management, including the CEO

and CFO. The agenda for these meetings would usually include an update on financial

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and operational performance and a discussion on key issues facing the business. I do
not now recall specifically the extent to which Project Sparrow was discussed in these
meetings, but I can say that at the time I felt we had sufficient avenues to discuss any
matters relating to Project Sparrow. In the months between QSMs, there would usually
be a monthly meeting focused on financial performance, attended by POL senior
management but not normally the CEO. Materials for these meetings were prepared
by POL. Given the focus on financial performance, these would not usually involve any

matters relating to Project Sparrow.

Oversight of POL’s activities

42. The team’s communications with POL and the access we had to POL Board papers
gave us a degree of oversight over POL’s activities. Whilst Richard Callard would have
been more familiar with the details through his attendance at POL Board and
Subcommittee meetings, I felt at the time that I had a good working knowledge of the
issues that came up during my tenure and that I had access to the information and

support that I needed to perform my role within the team.

43. I have been asked by the Inquiry to set out the degree of oversight the POL Shareholder
Team and I had over: criminal prosecutions brought by POL; civil litigation brought by

or against POL; and POL'’s IT infrastructure and services.

44. Oversight of criminal prosecutions brought by POL was not a function of the POL
Shareholder Team during my tenure (2015-2018). I understood, fairly soon after joining
the team, that the number of prosecutions brought by POL had tailed off over recent
years and had effectively stopped by the time that I joined the team. Indeed, I recall
being shown some statistics to this effect at my request (UKGI00004680,

UKG100004682, and UKGI00004684). I also recall asking POL the rationale for this

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and being informed that prosecutions had stopped, not because there were concerns
about the safety of the evidence that had led to convictions, but for more presentational
reasons, namely that POL did not consider it appropriate to be seen to be bringing
prosecutions at a time when it was facing public criticisms concerning Horizon and it

was seeking to resolve SPM disputes within the Mediation Scheme.

Having been provided with documents by the Inquiry, I can see that I was sent an email
by Richard Callard on 2 February 2015 (UKGI00003155), very shortly after I joined the
team, forwarding a short update note from Mark Davies to the POL Board which
concerned a question raised by the Board in relation to the CCRC (UKGI00003156).
At the end of this note there is a reference to a review of criminal cases having
previously been conducted by Brian Altman KC and that POL were providing this to the
CCRC. I do not recall feeling any particular concern about this reference at the time,
and note that the tone of the document is reassuring. Since I understood there were no
active prosecutions by this point, I am not sure I would have considered a review that
had taken place some time ago to have been of particular significance to my ongoing
role, particularly when it was set out in the note that the Board had already been
updated on the review and the note itself says that “we have not identified anything
through the Scheme to suggest a conviction is unsafe”. A similar impression was
conveyed by Richard Callard’s covering email, which said that: “POL remain confident
that there is nothing in this, and the Board felt this might even be helpful as it could

close one line of questioning down”.

Indeed, it was not until this Inquiry that I became aware that the rationale for stopping
prosecutions had been due to concerns about an expert witness, Gareth Jenkins. To
my knowledge, this point never came up during my tenure, and if it had, I am confident
I would remember it. I can also say the same in respect of each of Simon Clarke’s

advices (POL00006357) and (POL00129453) and Brian Altman KC’s reviews

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(POL00022619) and (POL00006581) and any other advices produced by those
individuals: to my knowledge I never saw any of these documents at the time and have
only now seen them in the context of this Inquiry. I was also unaware at the time that
Cartwright King Solicitors had carried out a review of past convictions and post-
conviction disclosure. While it is difficult to say now how I might have reacted if I had
learned that at the time, I am confident that issues surrounding the credibility of an
expert witness would have prompted concerns and I would have considered this

something on which Ministers should be briefed.

The involvement of the CCRC was not a fact which I considered concerning in and of
itself. I was informed by POL that no appeal had been made by any SPM against their
conviction and based on my very general understanding of the commission's role, I
considered the involvement of the CCRC to be the normal and appropriate route by
which any person who felt their conviction was unsafe could apply to have it overturned.
I felt it was important that existing legal routes were utilised by individuals who had
concerns regarding their convictions and was reassured that POL understood their
duties regarding post-conviction disclosure and their duties to the CCRC. I also took
steps to ensure that ShEx / UKGI and the Department complied with its own duties to

the CCRC including the preservation and disclosure of material (UKGI00004453).

In relation to civil litigation, again, this was not a specific oversight function of the POL
Shareholder Team. Nevertheless, we would have sight of updates of material litigation
through POL’s reporting to its own Board. Prior to the Group Litigation Order
proceedings (“GLO”), I cannot recall any specific cases coming to my attention via POL
Board papers or in any of the discussions we had internally or directly with POL’s staff
In relation to Project Sparrow, I was however aware that group action had been
intimated previously by the JFSA. When we became aware in November 2015 that the

JFSA intended to bring civil litigation, and when POL received notice of a claim from

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Freeths on 13 April 2016, we sought to ensure that we were kept updated on the
progress of the litigation and the potential impact on the business. I set out further detail

on the GLO later in this statement.

49. As the POL Shareholder Team, we did have some oversight and involvement in
discussions concerning POL’s IT infrastructure and services, although this was dealt
with by other members of the team. I recall from internal discussions at the time that
the main focus was on how and when the Horizon system might be replaced and in
particular, whether funding from HM Treasury could be secured to do so, rather than
how the existing IT infrastructure was operating. In reviewing POL Board papers, I may
have also come across other issues relating to POL’s IT, but I do not recall any of

particular prominence.

Working Relationship with POL’s Senior Management

50. In general terms, my working relationship with POL’s senior management was
collegiate and professional. At the time, I had no reason to doubt that they were acting
in anything other than an upfront and transparent way with me. On each of the areas
in which I worked, not just relating to Horizon, I felt that our requests for information
were generally met willingly and comprehensively, with POL generally providing
responses to questions that appeared detailed and considered, and which I had no
reason to suspect were inaccurate or misleading. I would test the information I received
by ensuring I could understand it, that it met the purpose for which it had been
requested, that it appeared complete and consistent, and did not raise unanswered
questions. If I felt it was necessary, I would ask for further supporting information or

evidence.

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51.

52.

53.

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Paula Vennells was POL’s CEO throughout my time in the POL Shareholder Team. I
considered her to be an engaged and accessible CEO who was willing to interact with
ShEx and the Department. Indeed, I felt I could contact her directly rather than her only
engaging with Richard Callard or more senior staff and on the occasions I did, I found

her responsive and approachable.

The Inquiry has asked me to describe the concerns that had been raised about Ms
Vennells’s suitability as POL CEO. I became aware shortly after joining the POL
Shareholder Team that there were mixed views within ShEx on her effectiveness, and
I understood that the negative views of her ability related predominantly to her grasp of
the commercial and strategic challenges that were facing the business, particularly
around growing revenue and reducing reliance on Government subsidy. I did not
disagree with this. My perspective on the matter at the time however was balanced by
my impression that Ms Vennells seemed an enthusiastic advocate for POL and the
importance of the Post Office network, and appeared to take seriously her
responsibilities and accountability to Ministers, the Department, and Parliament. In
relation to Project Sparrow and the complaints raised about Horizon, she struck me as
being committed to doing the right thing. I considered these to be important qualities
for someone at the head of a publicly accountable business with a social aspect to its
work as well as a commercial one. I also considered that, pragmatically, it would be
very difficult to find a very strong commercial CEO who could also display these
qualities for the remuneration that was on offer, which was demonstrably within the

lower quartile of private sector businesses of a similar scale.

Through the work of the Inquiry I have been made aware of a 2014 paper to the ShEx
Risk & Assurance Committee, that also touches on Ms Vennells’ competence as a CEO
(UKGI00042677). This paper predates my time on the POL Shareholder Team and I

do not believe I saw it on joining the team.

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54.

55.

56.

57.

58.

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In terms of my relationships with other senior management within POL, the individuals

I engaged with most frequently were Mark Davies, Tom Wechsler, and Patrick Bourke.

Mark Davies was POL’s Communications and Corporate Affairs Director and I engaged
with him on a range of matters including Project Sparrow. Before joining POL, Mr
Davies had been a former Special Adviser to the Rt Hon Jack Straw MP and so he
understood how the relationship between officials and Ministers generally works. We
would therefore regularly be in contact, particularly if an issue of Parliamentary or press
handling came up. I would describe our working relationship as open, proactive,
constructive, and collaborative, which I consider important when working with an Arm’s

Length Body that generates regular press and Parliamentary interest.

Tom Weschler performed the Chief of Staff role for Paula Vennells, and I was in contact
with him several times a week on matters relating to Project Sparrow and more broadly.
I was aware that he had previously worked in the Civil Service and also understood the
context in which Ministers and officials operate, which allowed him to support his POL
colleagues to respond effectively to shareholder requests. I would describe my working
relationship with him as similar to the one I had with Mark Davies. Mr Wechsler was my
main contact for matters relating to the Mediation Scheme and Project Sparrow more

broadly, until around August 2015.

Around August 2015, my main point of contact relating to Project Sparrow became
Patrick Bourke. Again, at the time I felt that we had a good working relationship and

found him to be responsive and helpful.

I occasionally met or engaged with other senior executives in POL, including Alisdair

Cameron as CFO, Jane Macleod as General Counsel, and Alwen Lyons as Company

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Secretary. I would also work with other staff who worked in their teams, including Mark
Underwood, Jane Hill, and Rodric Williams. My contact with these individuals was less
frequent and would often come about when my regular points of contact were
unavailable. I do not recall having any concerns about engaging with them, or feeling

that they were withholding information from me.

With the benefit of hindsight, and on the basis of some of the evidence I have seen and
heard during the Inquiry, I have reflected more critically on the views that I formed of
some of these people at the time. In particular, I recall observing that the attitude of a
number of POL staff to matters relating to Horizon was very defensive. This did not feel
unreasonable at the time, in the context that POL had been responding to the
complaints made about Horizon for several years, and I could empathise that this could
easily cause people to feel defensive. However, reflecting now, I consider that this
defensiveness may well have also manifested itself in a degree of bias or blindness
against emerging evidence that there were genuine problems to address relating to the

Horizon complaints.

It is also clear to me now that information provided by POL during my tenure in relation
to allegations about the Horizon system to us as the POL Shareholder Team, to the
POL Board, and to Ministers and other stakeholders including Parliamentarians, was
incomplete, inaccurate and misleading. As I have noted above, at the time, I felt that
we received detailed and considered responses to our questions relating to Project
Sparrow, and this was also reflected in information provided to the press and to
Parliamentarians. I had no reason to doubt its veracity. I do not know whether this
incomplete, inaccurate and misleading information was presented knowingly, or
whether the individuals were acting in good faith with what they believed to be true.
Similarly, there are several key developments of which I have become aware through

the work of the Inquiry relating to Project Sparrow which were not communicated to me,

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to others in the POL Shareholder Team, or to Ministers. Again, I cannot tell whether

this was deliberate or accidental, but either way its impact was material.

Communication with BIS / Ministers

61. At the time I worked in the POL Shareholder Team, there was no team in the
Department covering policy relating to Post Office. This was the case both when ShEx
was part of the Department and from the creation of UKGI. There was a small team in
the Consumer and Competition Policy directorate within the Department who had some
policy responsibilities related to postal affairs, mostly regarding the regulatory regime
for mail (which affected Royal Mail and parcel delivery companies more than POL),
with whom we would engage occasionally where required, but it was clear this team
did not have any specific policy responsibility relating to the Post Office network. As I
understood it, the policy for Post Office was relatively simple — there should be a
network, it should exist at a size larger than commercially viable to ensure communities
had access to postal and other services, and there should therefore be subsidy to
enable POL to operate a network of that scale. Where Ministers had a policy interest
relating to Post Office, such as during the Coalition Government when there was a
desire to have POL be a ‘front office for government’, this was typically therefore picked

up by the ShEx team.

62. I ShEx provided advice and briefing to Ministers on matters relating to Post Office, and
this arrangement continued largely unchanged when ShEx became UKGI, with the
approach governed by a memorandum of understanding between UKGI and the
Department. As the POL Shareholder Team, we would provide written advice or
briefings to Ministers, attend meetings with them either for general updates or to
discuss specific matters, and support them in meetings with stakeholders (including

POL management) by providing briefings and attending the meetings. As well as

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63.

64.

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providing briefings for Ministers, we would also keep their private office updated on key
issues and discuss with them when and how Ministers should be updated. We operated
on a similar basis with Special Advisors and with the Permanent Secretary, and their

private offices.

I prepared the vast majority of written submissions and advice on Project Sparrow
during my time in the POL Shareholder Team. As the head of the POL Shareholder
Team, Richard Callard reviewed and approved each submission I wrote, or if he was
unavailable (such as being on annual leave) I would seek review and approval from the
Director (Anthony Odgers or Justin Manson), or from Mark Russell as CEO if required
in their absence. If a submission was particularly controversial, I would ensure the
relevant Director or Mr Russell had a chance to see it and comment on it before it was
submitted, even if Mr Callard had approved it. Mr Callard and I would always discuss
whether a submission was required, what it should contain and what our
recommendations should be. We would take each other's suggestions on board to
prepare balanced advice which took into account our different experience and

perspectives.

All Departments have a submissions process which will include the requirement to seek
approval from various functions across the Department including the Legal, Finance
and Communications teams. The vast majority of submissions would be copied to the
both the junior Minister and the Secretary of State, although the Secretary of State’s
office would not necessarily show every submission to the Secretary of State — this
would be agreed between private offices, and if unsure they would seek a view from
the submission author. If another Minister's office had an interest in the issue, they
would also be copied — this was often the case where the responsible Minister was a
Lords Minister, as there would ordinarily be another (Commons) Minister in the

Department ‘shadowing’ the policy area such that they could respond to any Commons

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business. The Permanent Secretary’s office would also be copied on all submissions,
although similarly, they would use their judgement as to whether the Permanent
Secretary was provided with every submission received. Where required, submissions
might be shared in draft with the Permanent Secretary or with Special Advisors before
being finalised for Ministers. Submissions were always copied to those involved in its
drafting and clearance including the Finance, Legal and Communications teams as
appropriate. In most cases, we would copy the relevant Director (Anthony Odgers or
Justin Manson) and Mark Russell into the emails enclosing submissions, but this was
for information and it was not my expectation that they would necessarily read every

one.

For most submissions relating to Horizon during my time in the POL Shareholder Team,
the primary audience was the junior Minister responsible for postal affairs. When I first
joined the team in January 2015 this was Jo Swinson. After the 2015 general election,
Baroness Neville-Rolfe took over the responsibility, and then following the July 2016
Ministerial reshuffle, Margot James took over the role until January 2018. She was
succeeded in post by Andrew Griffiths, but as this largely coincided with the point at
which I handed over my POL responsibilities to others in the team, I do not recall that I
provided any briefing to Mr Griffiths. As well as the junior Minister, we also occasionally
provided advice specifically to the Secretary of State (initially the Rt Hon Sir Vince
Cable, later the Rt Hon Sajid Javid and then finally the Rt Hon Greg Clark) or to the
Secretary of State’s Special Advisers. Less frequently, we also provided advice to No.
10 or to the Rt Hon Sir Oliver Letwin, as Minister for Government Policy in the Cabinet
Office. On each of these occasions, I approached the task in the same way as I did for
the Department's Ministers, save that I was even more conscious of the need to be
succinct and direct. None of the submissions to the Secretary of State or to No.10 led
to me attending a meeting with them to discuss Project Sparrow (or any other Post

Office matters) and the only contact I had with the Rt Hon Sir Oliver Letwin in relation

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to Post Office matters was sitting in on a telephone call that he had with Baroness

Neville-Rolfe, of which I was requested to take a note (UKGI00005910).

When I joined the POL Shareholder Team, Jo Swinson MP had been in post as the
Minister for more than two years (save for her period of maternity leave) and had been
involved in matters relating to complaints about Horizon throughout that time, including
making a statement to Parliament in 2013 regarding the Mediation Scheme. As such,
there was already an established government position in relation to Project Sparrow:
essentially, that the matter had been taken seriously by Ministers and by POL,
investigated carefully including by Second Sight who had published an interim report
and were continuing to investigate, the Mediation Scheme had been set up and had
been done so in a way that was independent of government, and it was right to allow
those processes to be completed in an attempt to resolve the long-running disputes.
As the work had not identified any systemic issues with Horizon, it seemed clear that
the important point was to enable the resolution of the individual complaints and
concerns raised by the 134 applicants to the Mediation Scheme. If I had thought this
position was wrong, I would not have had any concerns about raising this with Richard
Callard or others within ShEx, but it seemed sensible to me. I think it is important,
however, to properly contextualise the work that I undertook: I did not advise on the
initial position taken by the Government at the point these matters were first brought to
Ministers’ attention and, as such, my advice from joining the role and thereafter was
based upon the position established and whether there was any reason to change that

approach.

Following the 2015 General Election, a new Conservative government was formed that
replaced the Coalition Government that had been in place since 2010. This led to a
reduction in the number of Ministerial roles within the Department and as such, the

portfolio previously held by Jo Swinson was distributed between the other junior

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Ministers. This took some time and so it was not until June 2015, a month after the
election, that it was agreed that Baroness Neville-Rolfe would hold the postal affairs
brief. Baroness Neville-Rolfe had been a Minister in the Department previously. When
initially briefing the Minister, we saw no reason to recommend a change to the
previously agreed position in relation to complaints about Horizon, but recognised that
it was always within the prerogative of Ministers to change approach. I recall that
Baroness Neville-Rolfe was initially content to adopt the same approach that had been

taken previously.

At a later point, Baroness Neville-Rolfe wished to look further into the issues and take
a slightly different direction. From my perspective, it was ShEx’s role to implement the
decisions of Ministers, and to provide advice to them faithfully, as I explain elsewhere
in this statement. During my tenure, I do not believe that I or the rest of the POL
Shareholder Team were resistant to any changes in approach that were suggested by
Ministers, but provided our advice on doing so in the usual way. I recall, for example,
having a long discussion with Anthony Odgers (I believe this was around June or July
2015, and at a time when Richard Callard was on annual leave) to seek his guidance
on what more we could do to support the Minister and the advantages or disadvantages
of potential options. Fundamentally, however, it appeared to us that the evidence base
had not changed at this stage and therefore we considered the extant position
remained valid. We were also mindful that there were existing processes in train — the
Mediation Scheme and the review by the CCRC — which were the right avenues to
resolve issues and required further time to be completed. What we as a shareholder
team therefore considered was required at the time, was greater assurance that all of
the issues had been examined carefully, and we weighed up various options to do so.

This is what ultimately prompted the review by Tim Parker, which I discuss further below.

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69. The following sections set out some of the key milestones and issues on which I
provided advice to Ministers and I address the advice provided in each section below.
As a general point, my approach to briefing Ministers and writing submissions has
always been and continues to be that you should be clear and candid, provide the
Minister with advice that you think accurately reflects the facts as you understand them,
never withholding material information, and that you should make a recommendation
to Ministers on the best approach. Ministers are always able to disagree with your
recommendation, and that should not be seen as a failure of your advice. I have worked
with a number of Ministers who have been very happy to receive well-reasoned advice
with a recommendation with which they do not agree, and it is well-established that the

ultimate responsibility and accountability lies with Ministers.

Responding to departmental correspondence

70. The Inquiry has asked me to describe my involvement in responding (or advising others
on the response) to complaints made about Horizon from SPMs, MPs or journalists.
The primary mechanism for this was through the Departmental correspondence
process and various examples are provided in the documents identified by the Inquiry

for my review.

71. Government departments receive a very large volume of correspondence on a variety
of matters, some of which is sent directly by members of the public, businesses or
representative organisations, and some of which comes from Parliamentarians. There
are established processes within and between Departments on agreeing which
Department's remit a piece of correspondence falls within, which team should be
tasked with preparing a response, and from whom the response should be sent. An

example of this can be seen in (UKGI00003198). Throughout my time in the POL

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72.

73.

74.

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Shareholder Team, we followed the Department's processes for correspondence,

regardless of whether we were ShEx or UKGI.

Often, the same or similar issues are raised on a topic, and to assist with providing
timely responses to correspondence, teams prepare ‘standard line’ responses to
correspondence which can then be tailored appropriately to any specific points raised.
This ensures that separate internal clearances do not need to be obtained for every
piece of correspondence and also ensures that a consistent government message is

delivered.

Within the Department there was a separate correspondence team, who would allocate
correspondence to the relevant team. For matters relating to Post Office these would
be sent to James Baugh and Jessica Williams, who would either prepare a response
themselves utilising existing lines, or pass the correspondence on to the relevant
individual in the POL Shareholder Team to advise on a response. As the lead in the
team on Project Sparrow, I would either prepare or approve the response to any
Ministerial correspondence received relating to complaints about the Horizon system.

Where appropriate, I would also clear this through Richard Callard.

On joining the team in January 2015, I reviewed and made some minor changes in
style and tone to the standard lines used in response to complaints about Horizon, but
as noted above I saw no need to change the established position. When responding to
individual correspondence, my approach was to be as helpful as possible to the
correspondent, while being clear on the Government's position, and in the case of

complaints received about Horizon, reiterate that the Mediation Scheme had been

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established to be independent of government. This was the case whether we were

preparing a response to come from the Minister or to be sent by an official.

75. We would not share details of individual correspondence received with POL, but if
necessary would reach out to POL to ascertain whether an individual had a case in the
Mediation Scheme or not, and if they did, how far the case had progressed within the
Scheme, so that we could provide an appropriate response. In most cases, this
included an offer to the MP that POL would be happy to discuss the matter with them
directly and contact details for the appropriate person for them to contact. As can be
seen in documents shared with the Inquiry, we also therefore updated POL on the MPs

to whom that offer had been extended.

Involvement in Ministerial Meetings with Stakeholders

76. My role in providing advice to Ministers in relation to Project Sparrow included preparing
briefing for meetings held by the Minister with stakeholders. It is common practice for a
Minister to be accompanied by one or more officials to support them in a meeting, and
usually one of their private secretaries as well. Generally the role of the official in the
meeting is to note down actions and take a minute of the meeting, and occasionally
contribute to the meeting when requested to do so by the Minister, usually to remind

them of a point of detail rather than to offer a view or steer the discussion.

77. I attended a number of such meetings in relation to Project Sparrow and wider POL
matters, as meetings would often cover a range of topics even if scheduled for a specific
purpose. For the most part, I was the official attending, but I recall one or two where
Richard Callard would have attended either with me or instead of me. I no longer have

access to my diary for the time period in question so cannot give a full list, but recall a

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78.

79.

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number of meetings and these are supported by some of the documents provided by

the Inquiry.

For example, I attended a meeting between Baroness Neville-Rolfe and James
Arbuthnot (now the Rt Hon the Lord Arbuthnot of Edrom) in September 2015, which
was arranged following the meeting convened between Baroness Neville-Rolfe, POL
and MPs (discussed further below). In this meeting the Minister updated Lord Arbuthnot
on the proposed review by Tim Parker. I prepared the meeting briefing, drawing on the
support of my colleagues within the POL Shareholder Team for any additional
information that I required (UKGI00005898). I also requested, and attached separately
to the briefing paper, some information from POL on key areas of concern raised by
Lord Arbuthnot and POL’s response to them (UKGI00005899). I cannot recall
specifically whether I attended a pre-meeting briefing with the Minister in this case, but
such briefings would often be organised to give a Minister the opportunity to clarify any
aspects of their brief or discuss handling in advance. While I did attend the meeting
itself, beyond the normal introductions, I do not recall being called on to make any
contributions or points of substance. Following the meeting, I provided an update to my
colleagues within the POL Shareholder Team and will have liaised with the Minister's

private office on how to take forward any follow-up actions.

I recall attending a meeting held by Baroness Neville-Rolfe with Ron Warmington and
lan Henderson of Second Sight in October 2015. As above, I prepared the briefing
paper (UKGI00006179), met briefly with the Minister before her guests arrived to
enable her to ask any questions, and attended the meeting. In this case, Mr
Warmington had indicated that Second Sight would like the meeting to take place ‘off
the record’, so I did not take extensive notes but did prepare a brief file note

(UKGI00039477) to share later with Richard Callard, who I recall was not in the office

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80.

81.

82.

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that day. Again, beyond introductions and pleasantries, I do not recall being called on
to contribute to the discussion in this meeting. I do recall the impression I formed in this
meeting was one of reassurance that the approach we were taking (allowing the
Mediation Scheme to proceed, awaiting the CCRC work, and commissioning Tim
Parker's review) was the right one, and noted that Second Sight had not raised any

new concerns or points to investigate.

In July 2015 I attended a meeting that Baroness Neville-Rolfe held with Andrew Bridgen
MP and Kevan Jones MP following the June 2015 adjournment debate on Horizon,
which was also attended by Mark Davies and Patrick Bourke of POL. This meeting
required more planning than most given the known difference of views between the
parties (the MPs on one hand and POL on the other), and the briefing I prepared
reflected this (BEIS0000012). In the meeting itself, I recall that beyond providing a
couple of points of clarification to the Minister, I did not participate in the discussion, but

did take a record of the meeting (UKGI00013954).

Where Ministers met with POL management, I would typically have a greater
involvement in the discussion, usually to facilitate effective use of the time or to draw
out points of particular interest or relevance to the Minister, as well as noting any actions.
For example, as part of George Freeman MP’s preparation for the June adjournment
debate (where Mr Freeman, as the Commons ‘shadow’ Minister for POL was required
to respond on behalf of the Government), I attended a meeting between Mr Freeman
and Patrick Bourke and Jane Hill of POL who were present to provide information and
key facts to the Minister, who had less background on the policy area than Baroness

Neville-Rolfe.

I attended a briefing meeting in August 2015 arranged for Baroness Neville-Rolfe where

Paula Vennells, Jane MacLeod, and Mark Davies gave a detailed update on Project

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Sparrow, the work undertaken by POL to address the concerns raised, and the

progress of the Mediation Scheme.

83. I attended several meetings held between Baroness Neville-Rolfe and Tim Parker from
the time of his appointment as POL Chair until Baroness Neville-Rolfe moved
ministerial role. I cover some of these in more detail in the section on the Parker Review

later in this statement.

84. Although I had some involvement in preparing responses to correspondence from Sir
Alan Bates on behalf of the JFSA, I do not recall any occasion during my tenure in the
POL Shareholder Team when Ministers met with him. Indeed, to my knowledge I have
never met him. I was also not in post when Second Sight’s Interim Report was
published in 2013 and so I would not have had any involvement in any meetings which

he or others may have had with the Minister concerning that issue at the time.

85. To the best of my recollection, I did not attend any Ministerial meeting where the issue

of POL reviewing its criminal convictions was discussed.

Position on Project Sparrow in early 2015

86. On3 February 2015, there was a BIS Select Committee evidence session on the Post
Office Mediation Scheme, at which a number of people gave evidence including Paula
Vennells, Angela van den Bogerd (one of the key senior individuals within POL dealing
with the Mediation Scheme), Sir Alan Bates of the JFSA, and George Thomson from
the NFSP (UKGI00003231). The Communication Workers Union (“CWU”) was
represented by both its then-Assistant General Secretary, Andy Furey, and Mark Baker

who was part of the smaller Postmasters Branch of the CWU. Richard Callard and I

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87.

88.

89.

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attended this session from the public gallery. I recall I was introduced by Richard

Callard to Paula Vennells and to George Thomson briefly, after the hearing was finished.

Attending this evidence session helped me build further my understanding of the
complaints made in relation to Horizon, the purpose and progress of the Mediation
Scheme, the aspects of most interest to MPs (via the questions asked by the
Committee) and the positions of the various stakeholders involved. I recall that one
impression I formed from the evidence of George Thomson and Andy Furey in
particular was that the issue seemed not to be that there was a widespread problem
with Horizon, but to establish what went wrong in the individual complaints raised by
SPMs. I recalled both the NFSP and the CWU as key stakeholders during the passage
of the Postal Services Act a few years prior and believed their representatives would
not have shied away from harsher criticism of POL on this matter if they felt it justified,

so I thought this notable.

I had also undertaken some background reading to bring myself up to speed with the
issues that were likely to be raised, and in particular, had read the Hansard from the
Westminster Hall debate that had taken place on 17 December 2014. From that record,
I recall learning about the allegation that it was possible for Fujitsu to remotely access
SPMs'’ branch accounting terminals to alter the accounting records, and I understood
that following the debate POL had provided a detailed explanation to refute the claim.
As Second Sight were continuing to conduct their investigation, I expected that if they
were to find any evidence to support that allegation, they would share it with the

individual SPMs and POL.

In relation to Second Sight’s work, I was aware that they had been looking at the
Horizon system and SPM complaints for some time. The decision to appoint Second

Sight had been taken long before I took up my role within the POL Shareholder Team

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and I was not therefore involved in that decision and did not provide any advice in
relation to their engagement. My understanding, upon taking up my role, was that
Second Sight had been tasked with investigating the complaint raised by the JFSA that
there existed systemic errors — bugs or glitches — in the Horizon system that had caused
discrepancies in SPM’s accounts and led to them being held liable for the repayment
of losses. I did not understand them to be reviewing the Horizon system and wider
operating environment as a whole. The amount of time spent on this review by Second
Sight and the sense I was given on the level of detail being considered was comforting.
My understanding at the point that I joined the POL Shareholder Team was that they
had not found any evidence of systemic issues. I cannot now recall whether I read
Second Sight’s Interim Report in full upon taking up my role, or whether it was
summarised to me by my colleagues, but I do remember being aware of it and of POL’s

response to it, which it had published on its website.

In addition, I recall being told at some point (I cannot recall precisely when) that Deloitte
had also looked at the Horizon system in the past, since the complaints had been raised,
but I did not know this was called ‘Project Zebra’ and I was not told that they had
identified anything of concern. I did not see any of the work or advice provided by
Deloitte and as far as I recall it was not suggested to me by anyone that I should read
it as part of my induction into my role. My understanding was that the complaints about
Horizon had first been raised by the JFSA with Alice Perkins and Paula Vennells, and
then with Rt Hon Sir Edward Davey, as the junior Minister responsible in 2012, and that
each Minister thereafter had taken the matter seriously and wanted to ensure that the
complaints were investigated fully, and to be reassured that there were no major
problems with the Horizon system. I understood that view to be shared by POL, who
were similarly invested in verifying that the system that underpinned their business was
functioning correctly. It was therefore my understanding that a lot of work had already

been undertaken prior to me joining the team, including Second Sight's involvement.

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91. Around the time of my appointment, I also recall being informed that POL’s relatively
new General Counsel, Jane MacLeod, had upon joining the business looked closely at
the matter and SPM’s complaints and had relayed the outcome of that review to the
Minister. I therefore took comfort from the fact that this issue had the attention of the

right senior people within POL including the CEO, Chair and General Counsel.

Mediation Scheme

92. I had no involvement with the design or establishment of the Mediation Scheme, as it
was already in place when I joined the team. I understood it had been announced in
Parliament by the Minister (Jo Swinson MP) and advertised widely by POL, attracting
150 applicants in the application window (which had closed by the time I joined the
team). The Government position on the Mediation Scheme had therefore already been
agreed before I joined, and in summary, was that the Mediation Scheme had been put
in place with the support of SPMs (including the JFSA) and MPs such as Lord Arbuthnot,
and was working through the individual cases, which was taking some time. The agreed
position was that the Mediation Scheme was independent of Government and the
details of the specific cases would not be shared with officials or Ministers, reflecting

this independence.

93. There was a Working Group in place, run by an Independent Chair, Sir Anthony Hooper,
whose role was to agree which cases were suitable for mediation, and to oversee the
progress of the Scheme. Mediations themselves were overseen by the Centre for
Effective Dispute Resolution (“CEDR”), with POL providing funding for applicants to

obtain legal support for the mediation process. The Government was relying on the

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94.

95.

96.

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independence of the Mediation Scheme, and the fact that it had been created with input
from all interested parties including POL and the JFSA, to provide resolution to the

individual complaints raised.

When Second Sight therefore prepared their case reports for the Working Group, these
were not shared with Government. I understood this to be the position agreed between
all parties - POL, JFSA and Second Sight — and from my perspective, this made sense
in terms of independence and also because details of the individual cases might include

sensitive information about a SPM or other private individuals.

I was aware at the point that I joined the POL Shareholder Team that concerns had
already been raised regarding the Mediation Scheme from a number of parties. One of
my first tasks relating to Project Sparrow was to assist with the redrafting of a response
to Sir Alan Bates which noted concerns he had about the Mediation Scheme
(UKGI00019587 and UKGI00003111). I was also made aware of the press release
from Lord Arbuthnot expressing that he had lost confidence in the Mediation Scheme
(UKGI00002767). I understood the main tenor of these complaints to be the approach
being taken by the Post Office as to whether cases should be mediated or not, the
amount of time taken for each case to be investigated, and that where compensation
was being offered following mediation, it was lower than the applicants had anticipated.
I understood Sir Anthony Hooper had also expressed some concern around the slow

progress of cases (UKGI00002768).

POL had reported to us that there was a disconnect between the expectations of the
applicants in the Mediation Scheme as to what mediation would entail and what was
achievable from it, particularly in terms of compensation. POL were also concerned
about the length of time taken by Second Sight to undertake their reviews of cases,

including what POL perceived to be excessive requests for information (and noting that

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97.

98.

99.

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in some cases in the Mediation Scheme the issues had occurred more than ten years
ago), and that there were often differences of opinion within the Working Group on

whether cases should proceed to mediation or not, which also delayed the process.

My recollection of my perspective at the time on these issues is as follows. On the
criticism that POL was taking a legalistic approach to mediation, I noted the position
which was supported by CEDR at the time, that mediation is a process which is
improved with legal support and it is ultimately a legal process. I understood that some
applicants appeared to believe they were participating in a compensation scheme
rather than a mediation scheme, which may have affected what they thought they
thought the outcome of the process might be. I was not surprised that investigation of
cases had taken longer than expected given what I understood of the complexity of

some of the issues.

However, as mentioned above, the Government's position was that the Working Group
should remain independent and so the concerns were to be addressed by the Working

Group rather than being for Government to resolve.

We would receive updates from the Working Group directly (such as in letters from Sir
Anthony Hooper to the Minister) or from POL. CEDR was also monitoring the Mediation
Scheme, and wrote a report halfway through it, containing an assessment of the
mediation process. I would describe these updates as status reports, providing
statistics about the progress of cases within the Mediation Scheme, rather than details
about individual cases or outcome of mediations including levels of compensation being
sought or agreed. I also recall one occasion when Sir Anthony Hooper, as Chair of the
Working Group, provided an update to Adrian Bailey MP as Chair of the BIS Select
Committee ahead of the February 2015 evidence session, where ShEx received a copy

of that letter for its information.

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100. In general, these updates were helpful as they allowed Ministers to provide an up-to-
date response to correspondence that they would regularly receive from MPs and other
stakeholders. At the time, receiving this nature of update felt like the appropriate way
to maintain independence and the confidentiality of individuals whilst enabling a degree
of transparency for Ministers as to the progress of the Mediation Scheme, given it had

been announced by Jo Swinson herself in Parliament.

101. As these updates were focused on process, it was not until August 2015 when POL
management met with Baroness Neville-Rolfe and presented a detailed update on the
Mediation Scheme, that I had any meaningful idea about the levels of compensation
that were being discussed within the Mediation Scheme. With hindsight, I now feel it
may have helped to know more about the way in which POL was approaching individual
mediations, particularly if they were dealing with the quantification of losses and the
need for evidence to support claims in an overly legalistic way. Although I had been
aware of these sorts of criticisms in general terms at the time, I had taken some comfort
from the involvement of CEDR in the process, which had given me reassurance that
any inappropriate conduct would have been identified and reported back to the Working
Group, who could then have raised it with the Department if they had considered
appropriate to do so. Ministers had also invited Sir Anthony Hooper to meet with them
to discuss the issues and he had declined to do so, and I recall thinking at the time that

if he had any concerns to raise he would have taken the opportunity to do so.

Decision to disband the Working Group

102. In late February 2015, Richard Callard informed me that the Sparrow Subcommittee
had been considering a modification to the Mediation Scheme that would result in a

presumption of all cases, except those involving a criminal conviction, proceeding to

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103.

104,

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mediation, as a means to remove some of the delays to the mediation process. The
effect of this would be that there would no longer be a need for the Working Group,
whose remit had been to determine which cases were suitable for progressing to
mediation. On 2 March 2015, I was then sent a copy of the papers on this topic that
were being provided to the POL Board in support of the Subcommittee’s
recommendation (UKGI00003470). I began some early work on a submission to the
Minister on the premise that the proposals would be agreed by POL, including taking
Richard Callard’s view on the tone of the advice and whether this was a submission ‘for

information’ or ‘for decision’.

On 4 March 2015, Richard Callard sent me an email explaining that the Board had
approved the Subcommittee’s recommendation and raised certain points with me,
including around the submission to the Minister to update her and whether the change
might be announced via a written Ministerial statement (“WWMS”) (UKGI00003503).
Later that day, having forewarned the Minister's private office, I sent the submission to
the Minister, Jo Swinson MP, concerning the changes that POL had decided to make
(UKGI00000032). These points were also discussed in emails with Tom Wechsler at

POL (POL00102298).

On 5 March 2015, the Minister's office wrote back noting the proposed changes and
seeking clarification of certain points relating to the non-mediation of cases involving
those with criminal convictions (UKGI00003525). I recall discussing with POL, likely
Tom Wechsler or Mark Davies, that it would be appropriate on a matter such as this for
them to communicate directly to the Minister, in a format that she might then share with
Parliament, and on 9 March 2015, Paula Vennells as CEO wrote to the Minister in
relation to the Mediation Scheme and POL’s intention to disband the Working Group
(POL00119795). On the basis of our advice and having had sight of Ms Vennells’s

letter, the Minister agreed the wording of a WMS to be laid before both Houses of

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105.

106.

107.

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Parliament (UKGI00003581). The advice was also copied to the office of Baroness
Neville-Rolfe as the Department's Lords Minister, to support her in making the WMS in

the Lords.

The public announcement of closure of the Working Group was made on 10 March
2015. We were aware that there might be a negative stakeholder reaction to the
disbanding of the Working Group and in the days leading up to the announcement, we
therefore prepared for the possibility that a question would be asked in Parliament,
including at Prime Minister's Questions (“PMQs”) (UKGI00003670). This did indeed
happen, and I prepared a submission to Jo Swinson MP immediately following PMQs
enclosing a draft letter to Lord Arbuthnot, who had raised the matter, since
commitments made in Parliament to write should usually be fulfilled within 24 hours

(UKG1I00000053).

On the day of the announcement, the Minister's office also received an email from Sir
Alan Bates on behalf of the JFSA in which he challenged POL’s decision to disband
the Working Group, saying that the decision should not have been made by POL and
was for the Working Group itself to make. Sir Alan Bates also expressed the view that
POL had “attempted to gag Second Sight’ to stop their final (Part 2) report being
published. A copy of his correspondence was shared with ShEx by the Minister's private
office and later that day I prepared a draft response, which I sent to the Minister with

the same advice regarding the letter to Lord Arbuthnot (UKGI00003694).

On the 12 March 2015, I spoke to one of the Minister's private secretaries who informed
me that the Minister felt she had not been made aware that POL would be terminating
Second Sight's engagement. In fact, confirmation relating to the termination of Second
Sight’s engagement had been included in ShEx’s original advice to the Minister

(UKGI00000032) and I explained this to her office (UKGI00003785).

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108.

109.

110.

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At the time, the decision to move to a presumption of mediation did not appear to me
to be an unreasonable step to take, as it was designed to accelerate the rate at which
disputes would be considered and hopefully resolved. While POL had identified an end-
point for the engagement of Second Sight on this matter, they had ensured that Second
Sight would complete all the individual case reviews and their final report, which would

be provided to applicants

Reflecting now, I am struck by the speed at which this decision was taken and
implemented, and that the parties involved including the JFSA, Second Sight and Sir
Anthony Hooper will likely have felt ‘bounced’ by the announcement. I understand, and
understood at the time, this to be a factor of the mistrust between the JFSA and POL.
While I believe POL did try to ensure that the messaging around the announcement
presented the key details that this was designed to improve the pace of the Mediation
Scheme for applicants and that Second Sight were still engaged to produce their final
report, it is not surprising to me that this message was received poorly and is highly
likely to have exacerbated the dissatisfaction that the JFSA felt with the Mediation

Scheme.

The pace at which some of my advice was prepared on this matter is also something
on which I have reflected, and submissions such as my submission of 11 March 2015
(UKGI00000053), written, approved and sent in the space of a couple of hours to
respond to the issue raised by Lord Arbuthnot at PMQs, now read uncomfortably to me
with the benefit of hindsight and on reflection are more robust and direct in tone than

they might have been had I considered them more fully.

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BIS Select Committee letter

111. On 17 March 2015, the Secretary of State received a letter from the Chair of the BIS
Select Committee, which contained the Committee’s recommendations relating to the
evidence it had heard on the Mediation Scheme (described above) (UKGI00003919).
This was in lieu of a full report on the matter, not least because Parliament was shortly

to be dissolved ahead of the pre-election period for the 2015 general election.

112. Onreceipt of the letter, I was asked to provide advice on a reply with an urgent deadline,
such that it could be sent before the Committee disbanded. Minsters generally wish to
accept Select Committee recommendations where they are able to do so and, as such,
there is a high bar to meet if Ministers are going to be advised to decline a
recommendation. One recommendation from the Committee was that the Secretary of
State should be provided with a copy of Second Sight’s final report once it had been

prepared.

113. It is important to note that at the time the report was only intended to be shared with
POL and with Mediation Scheme applicants. Richard Callard and I discussed the
implications of accepting this particular recommendation. We were concerned that the
Government formally receiving a copy of the report would create the expectation that
the Government would be required to respond to the findings and any
recommendations, and that this would undermine the established independence of the
Mediation Scheme from the Government. That is not to say that the Minister would
never have seen or been briefed on the report once it was finalised, but there seemed
at the time an important presentational distinction. We therefore recommended to
Ministers that they decline this element of the Select Committee’s recommendations
(UKGI00003968). As the subsequent response from the Minister's office in the same

email chain shows, Ministers decided that they should accept the recommendation to

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receive the report and responded to that effect to the Select Committee. This decision
was also communicated to POL, who acted upon it accordingly, once the Second Sight

final report had been completed.

114. Onreflection, I think this was a finely-balanced decision and ultimately a judgement call
for the Minister. As I explained earlier, as an official, when giving advice you should
make a recommendation and set out your reasoning for it. It is always in the prerogative
of Ministers to disagree. I think the reasoning I set out in the advice against receipt of
the report is still valid, but with the benefit of hindsight and reflection I would now accept
that that the advantage of transparency and greater accountability does tip the balance

towards accepting, rather than rejecting, this particular recommendation.

Final Second Sight Report

115. The final Second Sight report was issued in late April 2015. It should be noted that this
was during the pre-election period ahead of the May 2015 general election. I recall in
the weeks preceding the report being issued that some individuals at POL had some
advanced sight of its content, and had given me the impression there was likely to be
some disagreement with some of the comments and findings made by Second Sight in

their report. I did not have any advance sight of the report myself.

116. I was aware that POL were considering preparing a document to accompany the
Second Sight report, to send to Mediation Scheme applicants (the primary audience
for the Second Sight report) to address points with which it disagreed. POL had taken
a similar approach previously with the preparation of a relatively short document which
set out their responses to some points raised by Second Sight in their interim report,

which was publicly available on the POL corporate website. While I was aware that

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117.

118.

119.

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POL were preparing a response document, I can confirm that I did not have any

advance sight of it before it was published.

I was on annual leave at the time the report was issued on 21 April 2015, so Richard
Callard and Tim Mcinnes had agreed to pick up in my absence any immediate actions
relating to the report. I did not see the Second Sight report, POL’s response to it, or any

press coverage until my return to the office at the beginning of May.

I cannot recall exactly when I read the final Second Sight report and POL’s response
document but believe it will have been in the week commencing 4 May when I returned
from leave. I recall finding both documents (the Second Sight report and the POL
response) long, highly technical and unclear. I reviewed the Second Sight report
looking for new issues or problems raised, and in particular, for findings that there were
systemic issues (bugs or glitches) with Horizon which had not previously been identified
and which were capable of causing the accounting issues raised. I recall at the time
noting that the final Second Sight report had set out 17 thematic issues, each affecting
a relatively low number of cases (out of the total approximately 130 cases), across a
broad range of aspects of Horizon and the work of a SPM, but with noissues identified

as universal across all users.

I noted the part of the report (paragraph 26.8) which stated that, “...we have described
in this report the results of our investigations (some of which are incomplete) into the
issues and concerns raised by multiple Applicants. As we have previously stated, when
looking at the totality of the ‘Horizon experience’ we remain concerned that in some
circumstances Horizon can be systemically flawed from a user's perspective and Post
Office has not necessarily provided an appropriate level of support”. I considered this
to be a carefully worded reference to “systemic issues”, but given that it was clear this

applied only ‘in some circumstances”, I felt it did not change the position that the

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individual cases raised by SPMs should be addressed individually, through mediation,
and where SPMs felt they had experienced one of these thematic issues, they could

raise this through the mediation process.

120. I recall being surprised at the length of the POL response document and the level of
detail it contained. I considered it to be very defensive, and not particularly effective as
a communications tool. I understood that POL had felt it necessary to rebut some of
the issues identified by Second Sight and would have assumed that POL believed its
content to be truthful, accurate and supported by evidence. Some of the issues raised
by Second Sight, such as lack of access to information from POL, we felt had already
been addressed by the assurances given by Paula Vennells to the BIS Select
Committee in February, and echoed to us as the POL Shareholder Team, that Second

Sight would have access to all the material they required.

121. As we were in the pre-election period at the time I read the report, there would have
been a very high bar for providing advice to Ministers. I did not think there was anything
in the report that required an urgent change of approach, and this was supported by
the fact that, in the two weeks that had elapsed between the report issuing and my
reading it, no other urgent concerns had been identified by my colleagues. As such, I
decided that it should form part of updating Ministers post-election where it was
reasonably expected there would be a different Minister to brief. The only other
immediate consideration was ensuring that POL had fulfilled the request from the
Secretary of State in relation to the BIS Select Committee recommendation that
Ministers should be sent a copy of both reports by POL, and that had already been

fulfilled.

122. As noted above, it was several weeks after the General Election before it was confirmed

that Baroness Neville-Rolfe would be the Minister responsible for postal affairs. In

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preparing briefing for her on this matter, Richard Callard and I agreed that there was
no reason to change our recommended approach, which was that the matter had been
comprehensively investigated over several years, no systemic issues had been
identified, and so we did not think further investigation would be value for money or in
the public interest. Second Sight had not advanced any evidence as far as we were
aware to suggest that any of POL’s prosecutions for either false accounting or theft
were unsafe, POL had a duty to disclose new material and we knew they were aware
of these obligations as they had mentioned them on several occasions. We also
understood that the CCRC was considering some applications for review that had been
submitted by SPMs, in response to which both the Department and POL had agreed to

preserve any relevant data.

123. I recall that the Minister agreed with this position and took comfort from the involvement
of the CCRC. We endeavoured to keep her updated on the progress of the CCRC’s
work and the timeline for any conclusion to their review, relying on POL for our updates
on this as they were in more regular contact with the CCRC. We were often informed
that the CCRC had said that it would be “a few months” before an update would be
provided. This was borne out by the fact that the CCRC did not come into UKGI to
review its files until October 2016, more than 18 months after the Department had been
asked to preserve its records, and at the point I left the POL Shareholder Team in early

2018 had not yet announced any conclusion to its work.

The Adjournment Debate

124. On 29 June 2015 there was an Adjournment Debate in the House of Commons tabled
by Andrew Bridgen MP, and George Freeman MP responded for the Government as
the ‘shadow’ Commons Minister. As noted previously, we had provided briefing for the

Minister beforehand (BEIS0000012). The Minister stated in his closing speech that:

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“Second Sight produced two independent reports—one in 2013 and the other earlier
this year—both of which found there was no evidence of systemic flaws in the system”.
This reflected what we believed to be the position at the time, based on our review of

the final Second Sight report (as noted above).

125. Immediately prior to the Adjournment Debate, George Freeman spoke to me as we
waited to go into the Commons chamber and said that he would like to offer to host a
meeting with Andrew Bridgen and other interested MPs to discuss the issues further,
having spoken to some colleagues in the division lobby that evening. I agreed that
would be sensible and suggested he consider whether it would be best hosted by him
or by Baroness Neville-Rolfe, and that it could include representatives from POL. The

Minister subsequently made this offer during the debate.

126. Following the Adjournment Debate, I provided advice to Baroness Neville-Rolfe and
George Freeman on how to fulfil this commitment, and Ministers subsequently agreed
that a meeting should be hosted by Baroness Neville-Rolfe between MPs and POL,
and that this should not include the JFSA or Second Sight. As I noted above, I attended
this meeting to support the Minister and took a readout (UKGI00013954). In that
meeting, Andrew Bridgen MP suggested to Baroness Neville-Rolfe that she should
meet Lord Arbuthnot, who had recently stood down as an MP and was soon to be
ennobled, as he had been one of the main Parliamentarians campaigning on this issue.
The Minister agreed to do so, and a meeting was held in September 2015, which I also

attended (as I have noted above).

127. Also following the Adjournment Debate, Ron Warmington of Second Sight wrote to
George Freeman MP, to Andrew Bridgen MP (who passed his email to Baroness
Neville-Rolfe) and to the Prime Minister to raise concerns about George Freeman’s

statement during the debate (as cited above), highlighting a number of paragraphs from

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the final Second Sight report which he felt contradicted that statement. I recall reviewing
the paragraphs in question ahead of advising Baroness Neville-Rolfe on a response,
and was surprised that Mr Warmington had highlighted them, as I did not see them

contradicting the position that there were no systemic flaws.

128. On 19 October 2015, I attended a meeting held between Baroness Neville-Rolfe and
Ron Warmington and lan Henderson of Second Sight. This meeting was at the
suggestion of Lord Arbuthnot when the Minister had met with him, and while we as the
POL Shareholder Team noted POL’s concerns about her doing so, we considered on
balance it was the right approach and recommended that she do so. It was a small
meeting, attended only by the Minister, Mr Warmington, Mr Henderson and myself — I
think on this occasion a private secretary did not attend. At Second Sight’s request, the
meeting was held ‘off the record’. This was an opportunity, therefore, for Second Sight

to raise concerns confidentially and discreetly, had they wished to do so.

129. I recall clearly ending the meeting with a feeling of reassurance, which I expressed to
the Minister, and believed at the time that she had been similarly reassured. The
concerns raised by Second Sight were of the nature of ‘things could have been better’
or ‘took a while to be fixed’. While respecting that this meeting was “off the record”, I
prepared a short file note for Richard Callard’s benefit with my main recollections from
the meeting, which covered points that I considered interesting or new
(UKGI00039477). The reassurance I took from this meeting cannot be overstated — I
felt that if there had been a serious issue that we had missed as shareholder, it would

have been raised in this forum.

Panorama

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130.

131.

132.

133.

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At the time we provided introductory briefing to Baroness Neville-Rolfe in early June
2015, we had been made aware by POL that the BBC Panorama programme was
looking to broadcast a programme concerning the complaints raised about Horizon,
which was originally scheduled to air on 22 June 2015. We notified the Department's
press office about this and included updates on it in our subsequent briefings for the
Minister. Our only source of information on this matter came from POL, and I am not
aware that the Department was ever approached by the BBC regarding this programme.
POL initially intended to provide a senior individual to appear on the programme and
were working with the BBC on the issues to be raised. POL, via Mark Davies, kept us
updated on the timings for the programme to be broadcast, which was initially delayed

by a week and subsequently further delayed to August.

POL also explained to us that, as time elapsed, they had concerns with the approach
and tone to be taken by Panorama and had made the decision not to field a senior
person for the programme, instead providing a written spokesperson quote. POL
continued to pass on updates about the likely content of the programme, including
which former SPMs were going to appear on it, and that a former Fujitsu employee was
also expected to appear. We shared this information with Ministers and the
Department's press office through regular submissions (UKGI00004632 and

UKGI00039487).

I recall watching the Panorama programme when it was broadcast. From my
perspective, the only new issue raised in the programme was the interview with Richard
Roll, a former employee of Fujitsu, in which he stated that Fujitsu were able to access

and alter branch accounts remotely and without the knowledge of the SPM.

At the time, we did not consider this to be a new complaint. I was aware that the

December 2014 Westminster Hall debate had included the allegation that this kind of

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remote access was possible and understood that POL had already looked into the
matter at that time and confirmed it was not the case. POL also provided a detailed
response to Ministers in relation to the interview with Mr Roll, explaining why this was
not possible. I felt this was sufficient at the time; with the benefit of hindsight, however,
I accept that the fact that this matter was being raised by a former Fujitsu employee
(i.e. someone who will have used the system directly, rather than a visitor to the Fujitsu
office who is reporting what they have heard about its functionality), should have led to
POL and in particular its Board seeking greater assurance from Fujitsu as to the
substance of the allegation, and as the POL Shareholder Team we should have

required them to do so.

Tim Parker review

134. There had been a relatively high level of Parliamentary interest in complaints about
Horizon since our initial briefing to Baroness Neville-Rolfe in June 2015, which included
the Adjournment Debate, correspondence from Andrew Bridgen MP and interest from
the Rt Hon Sir Oliver Letwin MP. The matter had been raised by Mr Bridgen at PMQs
as well and with the Leader of the House of Commons. As I have noted above, the POL
Shareholder Team felt that the evidence still pointed to this matter requiring resolution
of individual cases through the Mediation Scheme and the work of the CCRC, but
nevertheless, we had been considering whether anything further was required including

to provide support and reassurance to the Minister.

135. I understood that the Minister was feeling concerned about the level of political interest
and had sought the involvement of more senior members of the POL Shareholder Team.
I had already been discussing this with Anthony Odgers, who was the Director at the
time, and we began to develop some options for further work, ahead of a planned

meeting with the Minister. We also planned to bring in POL, including CEO Paula

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Vennells, to meet the Minister and provide her with more information on the work they

had been doing on the Mediation Scheme.

136. I have reviewed correspondence from the time provided by the Inquiry and note that I
was informed by the Minister's office that she had asked for a senior official outside of
ShEx to attend the meeting with officials mentioned above. I recall speaking to the
Minister’s private secretary and informing her that, beyond the Permanent Secretary,
there was no-one outside of ShEx with policy interest in or responsibility for Post Office
matters, but suggested that Patrick Kilgariff who was a Director in BIS Legal, or a
member of his team, could attend, as we had been keeping them updated on this matter,
particularly the involvement of the CCRC. I understood at the time that this was
acceptable to the Minister and have only been made aware through the Inquiry that the

Minister was dissatisfied with the advice provided to her by ShEx.

137. It was through this meeting, attended by Anthony Odgers and Richard Callard of ShEx
as well as myself, with press office, Special Advisors and BIS Legal, that the idea of
asking Tim Parker as incoming POL Chair to review the matter came about. I
considered this to be a sensible idea, noting that Tim Parker was an established Chair,
respected former Chief Executive, was well-regarded within Government and would be
able to approach the matter with a fresh pair of eyes, unbound to any of the decisions

taken prior to his tenure.

138. Tim Parker was to take up post on 1 October 2015. We arranged a call prior to this for
the Minister to speak to Tim Parker and ask him to look at the matters relating to Horizon,
with this request then followed up in a letter. Mr Parker was happy to do so and
undertook to update the Minister again once he was in post. Baroness Neville-Rolfe
communicated this to Rt Hon Sir Oliver Letwin MP, who was very supportive of the idea,

and to Rt Hon Lord Arbuthnot, who I recall also agreed it would be a helpful step.

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139. The letter tasking Tim Parker to look into the matter did not set any terms of reference
for the work; on reflection, this was something we should have considered further, but
at the time we felt it was important that the work was shaped and led by Mr Parker. The
early updates we received on the approach he was taking gave reassurance to both
the POL Shareholder Team and to the Minister, particularly that Mr Parker had
appointed Jonathan Swift KC to support him in the work and was arranging to speak to
key parties such as Lord Arbuthnot and Second Sight. We arranged that Tim Parker
would meet Baroness Neville-Rolfe on regular occasions to provide an update on the
work, and were clear that at its conclusion, its findings should be communicated publicly

to interested parties.

140. During this period, there were several update meetings between the Minister and Tim
Parker, and my impression was that Mr Parker was driving the review, supported by a
small number of staff within POL including Patrick Bourke. One such update meeting
took place on 26 January 2016 with the meeting note, prepared by the private office
and reviewed by me, confirming (on page 1): “TP updated on the HORIZON
investigation. He said that the QC was about to report. He had found no systemic

problem. TP thought the issue might have passed it peak interest.” (UKGI00006482)

141. My general recollection, across the period of his review, echoed by the occasional
updates I would receive from Patrick Bourke at working level, was that there were no
emerging issues causing particular concern, but a few areas had been identified to look
into further, such as training and support for SPMs. This was reassuring. As was normal
practice, I kept Richard Callard informed of the updates from POL, and updated him

following any meetings with the Minister he did not personally attend.

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142. On 4 March 2016, the Minister received an update letter from Mr Parker setting out
some of his findings and areas of further work (POL00024913). The letter confirms (on
page 1): “Once the various strands of work I am pursuing are complete we will need to
find an appropriate method of communicating the results of my review to a wider
audience” and on page 4 “there are no further enquiries which need to be undertaken
into this matter whether by POL or, indeed, anyone else”. This was supported by the
conversation in the subsequent meeting held between Tim Parker and Baroness
Neville-Rolfe, which followed the same lines as the letter. I took significant reassurance

from this.

143. To be absolutely clear, at that time, or indeed at any time during my tenure on the POL
Shareholder Team, I did not see a copy of the report prepared by Jonathan Swift KC
and his junior. The first time I saw a copy of the report was in the context of the Inquiry.
The letter to the Minister, and the updates provided to me at working level by POL, had
given me the clear impression that there were no significant problems and so I had not
thought it necessary to dig further info the details of Mr Parker's review or its supporting
evidence. The letter had also referred to the fact that further work would be carried out
and I had no reason to think that this would not be done. Indeed, when I prepared a
further submission for the Minister ahead of her meeting with Tim Parker on the 27 April
2016, I explained that the purpose of the meeting was to discuss the final stages of his
review, following the letter that he had sent to the Minister on the 4 March. I
recommended that the Minister ask Mr Parker to provide her with an update on his
progress and once the review had been completed, that they should consider what

could be said publicly about his review (UKGI00019374).

144. I have been made aware through evidence shown to the Inquiry of an email chain

between individuals at POL reporting that I, on behalf of the Minister’s office, had

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agreed that POL would not share legal advice that Tim Parker had received from
Jonathan Swift KC, on the basis that this would make it susceptible to disclosure under
the Freedom of Information Act (FOIA), and would therefore send a letter (what became
the 4 March letter) instead (POL00239781). I would like to be clear that this is not the
case. I recall having a conversation on the telephone with Patrick Bourke where he
explained that POL were mindful of the need to draft the letter to the Minister carefully
as it could potentially be subject to release under FOIA, but I do not recall the underlying
legal advice being mentioned nor that it was to be withheld. I was not copied into the
email chain between individuals in POL and I would not have condoned any material
information being withheld or a misleading letter being sent. I would also not have
agreed that material information should not be shared with the Minister and at the very
least I would have expected the Minister, and officials within the POL Shareholder
Team, to have had the full picture communicated in a meeting or over the phone, even
if POL or Tim Parker were reluctant at that point to share anything that was written

down.

145. Having now been made aware of Mr Swift's underlying report, it is clear to me that the
4 March letter did not accurately summarise the advice that POL had received. Had it
done, or if that information been communicated to me in any other way, I would have
included those details in my submissions to the Minister and ensured that the relevant
contacts across Government were aware including the Permanent Secretary and the
Department's legal team. It would almost certainly have led to a change in the
Government's publicly stated position, and would have changed the context within

which we received updates on the group litigation.

Group Litigation Order

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146. In November 2015, we had become aware of a potential class action being brought
against POL by SPMs, via a press notice issued by the JFSA. By January 2016, Freeths
solicitors had indicated that they were representing SPMs in that claim, but no formal
letter of claim had yet been served. At each juncture, we provided updates to the
Minister's office in as timely a manner as possible, noting that in many cases our
information was incomplete, but ensuring that the Minister and her office knew what we

knew.

147. When I attended the meeting between Baroness Neville-Rolfe and Tim Parker on the
26 January 2014 (described above), the Ministerial briefing provided an update on the
proposed litigation to the Minister (UKG1I00000020). The inquiry now has provided me
with a copy of Tim Parker's briefing for the same meeting, prepared by POL
(POL00238744). I do not believe I saw this briefing in advance of the meeting and note
that it refers to a separate note from Jane MacLeod concerning Horizon, which I have

not seen and which I would not have been privy to at the time.

148. On 13 April 2016, I met with the Minister and briefed her on the potential group action,
following an indication from Freeths that a letter of claim would be sent to POL within
14 days. The following day I forwarded the note that I had prepared for this meeting to
the Minister's private office, copying in senior colleagues from UKGI and the
Department, including Patrick Kilgariff of BIS Legal and the Permanent Secretary's
office. Shortly thereafter I received a response from the Minister's office requesting that
an email be sent to No.10 via the Secretary of State’s office to sight them on the
developments. Having received that email, I then sent a proposed draft email for the

Minister's office to consider (UKGI00020236).

149. On 26 April 2016, I provided a further update to the Minister in a submission ahead of

her meeting with Tim Parker the following day (UKGI00019374), which also discussed

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150.

151.

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the progress with Mr Parker's review. I explained that a letter of claim was still awaited
and in the list of points to make at the meeting (set out in the Annex), suggested that
the Minister should ask Mr Parker whether there was any update and how the
management team proposed handling it. As can be seen from the submission, I
highlighted to the Minister that communicating the findings of Mr Parker's review to
interested parties such as Andrew Bridgen MP and Lord Arbuthnot might be
complicated if legal proceedings were underway by the stage and recommended that

the Minister discuss this issue with Mr Parker.

I wrote a further submission updating the Minister on the current position on 3 May
2016 (UKGI00006692), which had been sent to the Special Advisers in parallel to the
Minister, and had also been cleared by the press office and the BEIS legal team. Some
of the contents of that submission were based on information from POL, and some of
the information will have been obtained from the public domain, as we did not have any
direct contact with Freeths, the JFSA, or SPMs. The submission states: “You discussed
this with Tim Parker (Post Office Chair) at your meeting on Wednesday. Post Office’s
Board are due to discuss this at their May Board meeting (24 May). As far as we are
aware the litigation is not affecting the last piece of work underway in Mr Parker's review
of the matter. As you heard on Wednesday that remaining work (with Deloitte) may take

another month or so”.

At this time, the litigation was at a very early stage, and it was far too early to determine
whether Government would be a party to it, although it did not seem likely at the time.
I was reassured that, as set out above, the POL Board was being kept updated and
therefore Richard Callard would be able to share any updates received via the POL
Board, as well as updates from my working level contacts. POL provided estimates of
the timeline for the litigation, and it struck me that there were a large number of

processes and administrative hearings, each taking several months, meaning that this

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152.

153.

154.

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would be a long process and the main priority would be to ensure that Ministers were
kept updated, and that the relevant contacts in the Department's legal team were in

contact with their POL counterparts, which I ensured I put in place.

Tim Parker's review had not been concluded at this point, as noted above. I recall
several conversations with members of the POL legal team, including Jane MacLeod,
Patrick Bourke and Rodric Williams to update us on the work around the litigation. I
recall Patrick Bourke informing me that the advice they had received in relation to the
outstanding areas of enquiry for Tim Parker's review, given the letter of claim received,
was that they should be taken forward through the work that POL was doing to support
the litigation. I believe this position was noted by Tim Parker in his final meeting with
Baroness Neville-Rolfe before her role moved in a ministerial reshuffle, in July 2016.
That approach and advice did not seem unreasonable to me, and I trusted that, should
anything material have emerged from that work, it would have been brought to the
attention of the POL Board, and if appropriate, the POL Shareholder Team. Reflecting
now, I believe I should have been more proactive in requesting updates on how
specifically these follow up actions were being dealt with in the context of the litigation,

such that they could be communicated to Ministers.

As such, when I briefed the new Minister, Margot James MP, on the matter of Horizon,
my briefing reflected that this matter had been investigated thoroughly, including by Tim
Parker, and that with the group litigation underway the appropriate Government line
would be that we should not comment on ongoing legal matters. I recall the Minister

agreed with this position.

From this point until the end of my tenure on the POL Shareholder Team, I received
occasional updates from POL on the progress of the litigation. I passed on key updates

to the Minister, to the Department's legal team, and to press office, particularly where

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these related to events which might generate press coverage (such as where a public
hearing was due to take place). The frequency of updates, and hence my updates to
Ministers, was significantly lower than during 2015 and the first half of 2016 prior to the
letter of claim being received by POL. In early 2018, I formally handed over my role in
the POL Shareholder Team to Stephen Clarke including the provision of updates on

the litigation, and my work on POL ceased at this point.

Reflections at the time

155. During my tenure in the POL Shareholder Team, there were a number of points where
I reflected on the approach we were taking and questioned whether we were missing
something, not least as a result of the perseverance of the JFSA, Parliamentarians and
others, despite what seemed to me to be a lack of evidence supporting there being an
ongoing problem. I discussed these concerns with Richard Callard, and also on

occasion with Anthony Odgers and Justin Manson.

156. At the time, however, I invariably came to the following conclusions: that ShEx / UKGI
had what seemed like an open and transparent relationship with POL at both Board,
executive and working level; that Second Sight had spent a considerable period of time
investigating the Horizon system and the cases of individual SPMs and had not
identified any systemic issue; that the matter seemed to have the attention of POL
management and a commitment to resolving individual SPMs’ cases; and that POL
was consistently providing what seemed to be reasonable and detailed rebuttals to the
allegations raised. I trusted that, should new information emerge that indicated a

problem, POL would be proactive in sharing it and addressing it.

157. Onatleast one occasion, I also recall speaking with Baroness Neville-Rolfe during one

of my meetings with her and sharing that I had questioned myself as to whether there

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could be any more to investigate here — but explained to her that, as I have noted
already, I had taken comfort from the fact that no systemic issues had been identified
by Second Sight (and no concerning points raised when the Minister and I met them
in-person); that Tim Parker had undertaken a review supported by an external lawyer
and had provided assurances to the Minister and to officials that there were no
significant concerns; and that POL gave every indication of taking the matter seriously
at both executive and Board level. Alongside that, the NFSP, which represented a large
number of SPMs, were assured there was no issue here, and we had the additional
comfort that cases had been raised with the CCRC who would report back if convictions
were unsafe. Together these points therefore provided significant reassurance to me

at the time.

Reflections

158. At various points throughout this statement, I have provided some specific reflections
on individual points and how my approach to them might differ now, were they to arise

again.

159. Looking back, I acknowledge that we, as a Shareholder Team, could have been clearer
with Ministers from the outset, and reminded them of this regularly, that the primary
source of our information was POL, and that our ability to obtain information from
outside sources was limited to information provided to us directly (via correspondence)
or within the public domain. Reviewing documents from the time indicates to me that
there were instances where it would have been ambiguous to Ministers whether the
advice that was being provided to them represented POL’s position, or one reached by
us as Officials. I think this was particularly exacerbated in cases where information and

advice was bring provided to very short timescales.

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160.

161.

162.

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My review of documents from the time, as part of preparing this statement, has brought
to my attention certain occasions where I had asked for information from POL, or asked
a follow up question, and this was not provided. I did not spot this at the time and I
should have done, and pushed for a response, whether the lack of response by POL
was accidental or deliberate. At the time, I trusted that material information would be
provided to me, and that POL would be proactive in highlighting issues. I consider now
that, rather than the open approach to sharing information and updates I felt we had at
the time, Ministers and officials — and the public more generally — were receiving a very
narrow picture which minimised the scale of the potential issues, for example by
referring only to the 40 or so cases in the Mediation Scheme where individuals had
criminal convictions rather than the total number of prosecutions or convictions. That

notwithstanding, as a Shareholder Team we should have been challenging this more.

As a more general reflection, in this situation, we as a Shareholder Team should have
advocated for greater direct engagement, and hence accountability, from POL
management to Ministers. I also feel that the POL Shareholder Team should have
placed greater onus on the POL Board having ownership and sight of the key issues
and POL's response to them. This includes the information being presented from POL
to Ministers and to Parliament and ensuring that the Board were satisfied as to its
accuracy and appropriateness. With hindsight, I should have worked with Richard
Callard as the Shareholder NED to understand and challenge whether the POL Board
was receiving the right frequency and tenor of updates, and were active in key decisions

rather than these being driven solely by the POL executive team.

Reviewing the chronology of my involvement as a whole, I think the main point where I
feel I should have taken a different course of action was around the final Second Sight
report and POL’s response to it. I believe I did recognise at the time that it was

unsatisfactory to have an independent third-party’s review with which POL disagreed

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163.

164.

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so strongly, and I recall feeling a level of discomfort with that fact, but at the time I felt
that the main thing was to proceed with resolving individual cases through mediation.
On reflection, I should at least have identified some further options to resolve that
situation, which could have involved, for example, seeking some other third party with
relevant expertise to review both competing documents and provide advice either to

the POL Board or to the shareholder on whether further work was in fact required.

In terms of information sharing between POL and the Government, I am aware that a
number of witnesses have cited the preservation of legal professional privilege as
having been the reason why certain information was not shared. In the context of my
own involvement, I would say that point was most prominent in relation to Jonathan
Swift KC’s report to Tim Parker. While I think that particular issue could nonetheless
have been resolved within the processes ShEx had in place at the time, I have reflected
that the protocols we now have in place as UKGI with our assets in relation to current
and anticipated litigation, that allow for the sharing of privileged information, have
promoted a general culture of greater information sharing between an asset and the

shareholder.

Finally, I am aware that a number of changes have been introduced by UKGI and
across Government to enhance the governance and oversight of ALBs over the period
since I joined the POL Shareholder Team almost a decade ago. Through my continued
engagement with UKGI working with other ALBs, I have seen these arrangements in
action and consider that they provide meaningful improvement to how we oversee the
bodies in our portfolio. This includes the development of effective and appropriate
templates for shareholder framework documents, and clarification of the role of the
Shareholder NED including that they are members of all Board sub-committees, so that
they have a full vision of all the significant issues that are raised to the Board for

consideration.

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165. I hope that this statement and my reflections are helpful to the Inquiry in their further

consideration of this matter

Statement of Truth

I believe the content of this statement to be true

Signature ..... GRO
Date .... s/ u[ ore a

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Index to First Witness Statement of LAURA THOMPSON

Inquiry URN

Document Description

Inquiry Control

Number

UKGI00003437

The Shareholder Executive Risk

Register - Spreadsheet

UKGI014251-001

UKGI00004091

The Shareholder Executive Risk

Register — Post Office Limited

UKGI014905-001

POL00030457

Hansard Westminster Hall Debate —
‘Post Office Mediation Scheme’

POL-0026939

UKGI00001820

Email chain from Swinson MPST to
Dan York Smith cc Robin Gordon-
Farleigh, Cable MPST and others RE:
Post Office - potential for Urgent
Question

UKGI012634-001

UKGI00004680

Hill to Laura
responses on

Email from Jane
Thompson re FOI
prosecutions

UKGI015494-001

UKGI00004682

Letter from Mark Davies to Matthew
Bardo re: Freedom of Information
Request — FOI201505191153

UKGI015496-001

UKGI00004684

Letter from Anna Gos to Tim Robinson
re: Freedom of Information Request —
FOI201410061556

UKGI015498-001

UKGI00003155

Email from Richard Callard to Laura
Thompson, cc'd Tim McInnes, James
Baugh, re: “Sparrow and the CCRC”

UKGI013969-001

UKGI00003156

Letter by Mark re: Sparrow and the
CCRC

UKGI013970-001

10.

POL00006357

Advice on the use of expert evidence
relating to the integrity of the Fujitsu
Services Ltd Horizon System

POL-0017625

11,

POL00129453

Simon Clarke’s Advice re: Disclosure —
The Duty to record and retain material
— Post Office LTD

POL-0134937

12.

POL00022619

Interim Review of Cartwright King’s
Current Process

POL-0019098

13.

POL00006581

Review of PO prosecutions by Brian
Altman QC

POL-0017666

14.

UKGI00004453

Briefing from Laura Thompson to
Baroness Neville-Rolfe dated 2 June
2015

UKGI015267-001

15.

UKGI00042677

PowerPoint presentation re: Post
Office Ltd Senior Management — Risk
and Assurance Committee — February
2014

UKGI051572-001

16.

UKGI00005910

Email from Laura Thompson to Laura
Thompson re Readout of BNR-OL Call

UKGI016724-001

17.

UKGI00003198

Email chain from Laura Thompson to
Richard Callard__ re: Contribution

UKGI014012-001

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Request — ministerial transfer request
Stephen Hepburn MP

18.

UKGI00005898

Invitation to Baroness Neville-Rolfe
from Laura Thompson, ShEx (x4240)
re: Meeting with James Arbuthnot on
Post Office Horizon Thursday 17
September 15.15 — 15.45

UKGI016712-001

19.

UKGI00005899

Draft Briefing for Minister meeting with
James Arbuthnot re: Key points

UKGI016713-001

20.

UKGI00006179

Letter from Laura Thompson, ShEx to
Baroness Neville-Rolfe re: Meeting
with Second Sight on Post Office
Horizon Monday 19 October 14:30 —
15.00

UKGI016993-001

21.

UKGI00039477

Key points from Second Sight meeting
report

UKGI048372-001

22.

BEIS0000012

Briefing note from Laura Thompson to
Baroness Neville-Rolfe re Meeting with
MPs and Post Office on Horizon
system Wednesday 15 July 13.15 —
14.15

VIS00000906

23.

UKGI00013954

Note of meeting following Adjournment
debate on Post Office Horizon IT
System

UKGI024747-001

24,

UKGI00003231

Oral Evidence: Post Office Mediation
BISC

UKGI014045-001

25.

UKGI00019587

Email chain from Laura Thompson to
Richard Callard RE: Reply to JFSA
letter

UKGI028482-001

26.

UKGI00003111

Letter from Jo Swinson MP to Alan
Bates re Response to letter dated 22
December about the mediation
scheme

UKGI013925-001

27.

UKGI00002767

Report on “MPs lost faith in Post Office
Mediation Scheme”

UKGI013581-001

28.

UKGI00002768

Letter from Sir Anthony Hooper to Jo
Swinson re Initial Complaint and
Mediation Scheme

UKGI013582-001

29.

UKGI00003470

Email chain from Karen Smith to Laura
Thompson Re Sparrow paper for the
Board — action required

UKGI014284-001

30.

UKGI00003503

Email from Richard Callard to Laura
Thompson re: Sparrow

UKGI014317-001

31.

UKGI00000032

Ministerial Submission from Laura
Thompson to Jo Swinson Re Post
Office mediation scheme: revised
approach

VIS00000993

32.

POL00102298

Email chain involving Tom Wechsler,
Richard Callard, Laura Thomspon and
others. Re “Sparrow commitment”

POL-0101881

33.

UKGI00003525

Email chain from MPST Swinson to
Laura Thompson, MPST Swinson
cc’iing MPST Cable and others re:
[Official sensitive: commercial]

UKGI014339-001

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Submission on Post Office Horizon
Mediation Scheme

34.

POL00119795

Letter from Paula Vennells to Jo
Swinson MP regarding the Complaint
Review and Mediation Scheme

POL-0119777

35.

UKGI00003581

Email from Laura Thompson to
Swinson MPST, Neville-Rolfe MPST,
Hannah Franklin-Wallis and others RE:
Submission on Post Office Horizon
mediation scheme

UKGI014395-001

36.

UKGI00003670

Email from Ministerial Advice Team to
Laura Thompson cc Richard Callard re
Post Office core brief for PMQs
tomorrow

UKGI014484-001

37.

UKGI00000053

Ministerial submission from Laura
Thompson to Secretary of State and Jo
Swinson MP re: Post Office Mediation
Scheme: Letters

ViS00001014

38.

UKGI00003694

DRAFT letter from Jo Swinson to Alan
Bates re: response to his e-mail

UKGI014508-001

39.

UKGI00003785

Email from Laura Thompson to Tim
McInnes, James Baugh cc Richard
Callard re: Readout from Jo's office on
Sparrow

UKGI014599-001

40.

UKGI00003919

Letter from Adrian Bailey MP to RT Hon
Vince Cable Secretary of State RE:
Post Office mediation scheme

UKGI014733-001

41.

UKGI00003968

Email from Laura Thompson to Richard
Callard re Post Office mediation:
response to letter from BIS Select
Committee

UKGI014782-001

42.

UKGI00004632

Letter from Laura Thompson to
Baroness Neville-Rolfe re: BBC
Panorama programme on Post Office
Horizon IT system

UKGI015446-001

43.

UKGI00039487

Briefing from Laura Thompson to
Baroness Neville-Rolfe re: Post Office
Horizon: Next Steps

UKGI048382-001

44,

UKGI00006482

Note of meeting with Tim Parker on 26
January 2016 at 9:30am

UKGI017296-001

45.

POL00024913

Letter sent from Tim Parker to
Baroness Neville-Rolfe re Post Office
Handling of complaints made by Sub-
Postmasters review

POL-0021392

46.

UKGI00019374

Meeting note from Laura Thompson to
Baroness Neville-Rolfe re: Meeting
with Tim Parker (Chair, Post Office
Limited) Wednesday 27 April 15:30 —
16.00

VIS00013197

47.

POL00239781

Email from Patrick Bourke to Mark
Underwood, Jane MacLeod and others
re: Draft letter from Tim Parker to
Baroness Neville-Rolfe

POL-BSFF-0077844

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48.

UKGI00000020

Briefing relating to forthcoming meeting
with Tim Parker on 26 January 2016

VIS00000981

49.

POL00238744

Meeting with Baroness Neville Rolfe,
Parliamentary Under Secretary of
State on 26.01.2016

POL-BSFF-0076807

50.

UKGI00020236

Email from Laura Thompson to Neville-
Rolfe, Javid MPST and others re
Submission to Ministers on Post Office
Horizon

UKGI029131-001

51.

UKGI00006692

Briefing from Laura Thompson to
Baroness Nevile-Rolfe re: Post Office
Horizon: update on group legal action

UKGI017506-001

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