WITN11780100
WITN11780100
Witness Name: Gary Robert
Hickinbottom
Statement No.: WITN11780100
Dated: 29 October 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF GARY ROBERT HICKINBOTTOM
I, Sir Gary Hickinbottom, will say as follows.
INTRODUCTION
1. 1am Chair of the Post Office Overturned Convictions Independent Pecuniary
Loss Assessment Panel (the “IAP”) under the Post Office Overturned
Convictions Pecuniary Loss Scheme (the “OC Scheme’) .
2. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 Request dated 2 October 2024
(the “Request”).
PROFESSIONAL BACKGROUND
Page I of 24
WITN11780100
WITN11780100
3. I have been asked to set out my educational and professional qualifications.
4. I attended Queen Mary’s Grammar School (1967-74), before University College
Oxford (1975-78) from where I graduated with a First Class Honours in
Jurisprudence (BA 1978, MA 1982). I obtained the Chartered Institute of
Arbitrators’ Diploma in International Commercial Arbitration (DipICArb) in 1996.
5. I passed my Law Society Part Il Exams in 1979, and became a Solicitor in 1981
and a Solicitor Advocate (All Courts) in 1997. I am a Fellow of the Chartered
Institute of Chartered Arbitrators (1995) and a Mediator registered with the
Academy of Experts (1991).
6. In terms of my professional and judicial career, I attach a short curriculum vitae
(WITN11780101).
OVERTURNED CONVICTIONS SCHEME: BACKGROUND
7. Before I deal with the specific questions raised in the Request, it would be helpful to set
out some background to the OC Scheme and IAP.
8. The IAP was set up as part of the OC Scheme by the Post Office with input from
claimant representatives to facilitate the resolution of the pecuniary loss claims of
claimants whose convictions had been overturned by the courts, by providing an
independent assessment of any heads of pecuniary loss in dispute between a
Page 2 of 24
10.
11.
WITN11780100
WITN11780100
claimant and the Post Office following the lodging of a claim, a response/initial
offer by the Post Office and without prejudice discussions/counteroffers. The
procedure before the IAP is itself without prejudice, non-binding and confidential,
so that, after the assessment, either party may resort to other forms of alternative
dispute resolution or formal litigation if they do not accept the assessment.
The OC Scheme (and therefore the work of the IAP) does not cover (i) claims of
claimants whose convictions have been overturned by statute (rather than by the
courts) which are the subject of a separate redress scheme, or (ii) claims for non-
pecuniary losses which I understand are being assessed and negotiated
separately on the basis of an Early Neutral Evaluation by Lord Dyson. The OC
Scheme is limited to the pecuniary loss claims of claimants who were convicted of
offences allegedly arising out of their work at post offices whose convictions have
been overturned by the courts.
There are currently 111 claimants in the OC Scheme. Because of the Post Office
(Horizon Systems) Offences Act 2024, which generally overturned convictions of
relevant offences, this is likely to be a closed cohort, i.e. it is unlikely that any
further claimants will have their convictions overturned by the courts and therefore
be added to that number.
Following discussion with the Horizon Compensation Advisory Board (the
“HCAB’), the former Minister of State for Enterprise, Markets and Small
Businesses, Kevin Hollinrake MP, who was the Minister responsible for Horizon
redress, commissioned a report from each on the redress schemes with the
Page 3 of 24
WITN11780100
WITN11780100
intention that the reports should be produced and published monthly. My first
report on the progress of the OC Scheme was in July 2024. With the change of
Government, the reports have become quarterly. I attach the July Report
(WITN11780105); and a draft of the October 2024 Report which has yet to be
published (WITN11780106). These set out figures for the number of claims in the
Scheme and the stage that they have reached, as well as a narrative in which I
include particular concerns I have had about factors which may slow future
progress of claims.
OVERTURNED CONVICTIONS SCHEME: SPECIFIC QUESTIONS
12. I will now deal with the specific questions about the OC Scheme raised in the Request,
in turn. I will use the paragraph numbers in the Request.
Paragraph 5
13. I have been asked: Please describe how and when you came to be appointed to
as Chair of the IAP for the Overturn Convictions Scheme (“the OC scheme”).
14. Iwas contacted by the Solicitors to the Post Office (Herbert Smith Freehills LLP, “HSF”)
in October 2023 with a request to chair the IAP. I understand that I was nominated by
the claimant representatives and that nomination was agreed by the Post Office. I
agreed to chair the Panel.
Page 4 of 24
WITN11780100
WITN11780100
15. Although my role was to be independent, I was to be formally retained (and paid) by the
Post Office. I began work in post as Chair immediately, but my formal appointment was
not finally signed off by the Post Office until February 2024.
Paragraph 6
16. Ihave been asked: Please describe your involvement, if any, in the creation of the
IAP and its composition. Please include any delays of which you were aware in
relation to the creation of the relevant pecuniary principles, your appointment as
Chair and the appointment of the other specialist panel members. Please include
your views as to the cause of the delays and any steps that could have been
taken to expediate the process.
17. had no involvement in establishing the OC Scheme. There are four main documents
underlying the OC Scheme, namely (i) Overturned Convictions Pecuniary Assessment
Process (the “Process Document” WITN11780102’), (ii) Terms of Reference for the
IAP the “Terms of Reference” WITN11780104), (iii) Overturned Convictions
Principles Underlying Offers of Pecuniary Compensation (the “Principles Document’
or just the “Principles”) and (iv) Without Prejudice Application to the IAP (the
“Application Form’ POL00448909). By the time I was approached in October 2023,
these documents were in all but final form. I do not know how long they took to be in
that form or why that finalisation took the length of time it did, but I understand the
documents were the subject of six months’ consultation by the Post Office with the
claimant representatives.
Page 5 of 24
18.
19.
20.
WITN11780100
WITN11780100
On 11 October 2023, I was sent the Process Document and Terms of Reference, in
HSF’s words, “to give you a broad sense of what you and the Panel will be asked to do,
so as to ensure that you are comfortable with your role”. I was asked for any comments
by 18 October 2023 as, subject to final Post Office governance procedures, the
documents were due to go to the Post Office Board on 31 October 2023. I submitted a
few, minor comments which were generally incorporated. I was sent an updated
version on 27 October 2023. These documents were duly approved by the Post Office
Board and published on the Post Office’s website when the IAP was publicly
announced. I attach a copy of each document in its current form. There have been no
significant changes to either.
On 27 October 2023, I was also sent the final version of the Principles Document and
Application Form. I was told that the former had been the subject of consultation and
that: “It is not formally agreed, but instead sets out Post Office’s proposals for a
negotiated framework for compensation which incorporates and takes account of
comments by claimant representatives”. My understanding was that the Principles were
intended to ensure fair compensation for each claimant by setting out principles that
were at least as generous as those of the general common law and in places more
generous, both in scope and evidential proof requirements.
Annex D of the Principles Document sets out the principles and processes to be applied
in the assessment of the claimants’ legal and professional fees which, under the OC
Scheme, were to be borne by the Post Office in any event. Such fees were to be
agreed by the parties or, failing agreement, to be assessed by either the IAP Chair or a
separately appointed Costs Adjudicator. In assessing costs, we were to have regard to
Page 6 of 24
21.
22.
23.
24.
WITN11780100
WITN11780100
“legal principle and practice”, i.e. how costs are assessed under the Civil Procedure
Rules including such issues as whether the rates claimed were reasonable for the work
done, whether the work had been done at the lowest reasonable level of seniority and
whether there is unnecessary duplication of work. In the October 2023 version of the
Principles Document, Annex D was incomplete.
Although, subject to Annex D (see paragraph 25 below), I had no opportunity to
comment on the Principles, (i) I understand there had been extensive consultation on
them with the claimant representatives, and (ii) under the Process Document, it was
open to claimants to refer to the IAP disputes as to the Principles themselves, and their
application; and, as such issues were resolved, the Principles might be updated. The
Principles were without prejudice and confidential as between the parties unless the
parties agreed otherwise. They consequently have not been published.
The Application Form (which was and is also a confidential document) is simply a
process document to ensure that applications to the IAP contained the necessary
information to enable the IAP to do its work.
I was therefore not significantly involved in establishing the Principles under which the
IAP was to operate.
Nor was I involved in the creation of the IAP or its constitution. In October 2023, I was
asked whether I had any objection to the appointment to the IAP of Mike Harper
(accountancy expert) and Stephen Bassett (retail expert). I had no objection — nor did
Page 7 of 24
25.
26.
27.
WITN11780100
WITN11780100
the claimant representatives — and Mr Harper and Mr Bassett were duly appointed by
the Post Office Board on 31 October 2023.
Shortly afterwards, to assist with any costs issues, Peter Hirst (former Senior Costs
Judge) was appointed Costs Adjudicator under the Scheme. Mr Hirst and I were asked
to comment on Annex D of the Principles Document and our comments (on process)
were taken into account in an amended version of the Principles Document in January
2024.
Because I was not involved until October 2023, I cannot comment on any delays in the
setting up of the OC Scheme and IAP. The formal appointment of the IAP members
(including me) were not made until February 2023, I understand because of (i)
difficulties in some members of the Panel obtaining appropriate insurance and (ii) delays
in the Post Office governance procedures for signing of the appointments. However,
this did not cause any delay in the functioning of the IAP, which began its work in
October 2023 and was in practice unimpeded by the absence of formally signed off
appointments.
Given the nature of the work to date, the other members of the IAP and Mr Hirst have
not as yet had any substantive part to play in the IAP, although it is proposed that Mr
Harper and Mr Bassett will sit with me when the IAP hears the intended future loss claim
referrals referred to below.
Question 7
Page 8 of 24
28.
29.
WITN11780100
WITN11780100
I have been asked: Please set out the terms of reference for the IAP as you
understand them to be.
The Terms of Reference are attached (WITN11780104).
Question 8
30.
31.
32.
33.
I have been asked: Please describe the process for assessing a claim upon receipt
of a summary referral.
The assessment process on referral to the IAP is set out in the Process Document
attached (WITN11780102).
The following points may assist in respect of process more broadly.
First, it is important to note that a referral to the IAP is the “final resort’ in the process
designed to result in a voluntary, full and final settlement of the pecuniary claims of a
claimant who has had a conviction overturned. The steps in that process are set out in
the Process Document and include the assessment by the Post Office of a submitted
claim on the basis of the principles set out in the Principles Document, an offer by the
Post Office and discussion/negotiations between the Post Office and the claimant. The
process and principles encourage the parties to agree heads of claim which can be
agreed, and for the Post Office to make full payment of the losses so agreed by way in
interim payment. A referral to the IAP is only necessary if, in relation to a particular head
Page 9 of 24
34.
35.
WITN11780100
WITN11780100
of loss, that process fails to result in a compromise; and is restricted to the heads of loss
upon which a compromise has not been reached. Given both the complexity and likely
value of future loss (including pension claims), it has always been recognised that it is
likely that most referrals will be restricted to heads of future loss.
Second, on 18 September 2023, the Department of Business and Trade (the “DBT”)
announced an offer to the claimants within the cohort of this scheme that they could
accept £600,000 “up front’, in full and final settlement of their claims, without the need to
lodge or purse a claim for their actual losses (often referred to as “the initial offer’).
Claimants have been encouraged to take legal advice on whether this option should be
chosen, and a further sum of £20,000 (excluding VAT and pre-approved expert fees) is
available for a claimant to take legal advice so that they can take an informed decision
on whether they should accept this offer. Whilst there is no time limit on this offer, the
offer lapses if a full claim is lodged or pursued. It has been made clear to claimants that
this offer is entirely optional, and if a claimant does not wish to accept it, then they can
pursue any other means available to recover their losses including a particularised claim
under the OC Scheme or court proceedings.
Third, a claimant within the OC Scheme cohort may apply for interim payments on
account of their losses. The Post Office at first offered an initial interim payment of
£163,000 on account within 28 days of receiving an application for it. Given that a
claimant can accept the full and final settlement initial offer of £600,000 referred to
above, I could not see why this initial interim payment should be so low where a
claimant has lodged a full claim; and, as Chair of the IAP, at a meeting of the partes, I
formally recommended that it be increased to £450,000 in those circumstances. That
Page 10 of 24
36.
WITN11780100
WITN11780100
recommendation was accepted and implemented by the Post Office. I have also
indicated that I consider the IAP has the power to consider referrals in respect further
interim payments where the Post Office has refused an application for such payment.
No such applications have yet been made, but (i) several potential applications have
been indicated to me, and (ii) the Post Office has now made several substantial interim
payments in particular cases.
Fourth, I have had regular meetings with the parties (i.e. HSF and the claimant
representatives) together to discuss any concerns any party may have, and ways in
which barriers to settlement might be removed and the settlement process be speeded
up. For obvious reasons of confidentiality, individual claims are not discussed at such
meetings. These meetings have had some success. For example:
(i) I Myrecommendation with regard to a minimum interim payment after a claim has
been lodged arose out of one of these meetings.
(ii) I They have identified issues with assessment and payment of claimant
representative costs, which have been resolved.
(iii) They have resulted in a proposal that individual claims be selected from those in
which future loss claims are very unlikely to be compromised without assistance,
with a view to early referrals being made in these claims. Future loss claims are
notoriously fact-specific; but I consider that, if the IAP were to consider several
future loss claims together, we may be able, not only to make recommendations in
Page 11 of 24
WITN11780100
WITN11780100
respect of those individual claims, but also to give some anonymised guidance
drawn from those cases for the assistance of the parties in other claims. It is
proposed that there is liaison with other Horizon redress schemes where similar
issues arise, so that maximum value can be obtained across all schemes from the
consideration of these claims by the IAP. I have a further meeting with the parties
in November at which this proposal will be discussed further with a view to
referrals coming on for hearing by the IAP in early 2025.
37. Fifth, although there have as yet been no completed references to the IAP, upon
appointment as Chair, I indicated to the parties that I considered that the documents
which established the OC Scheme and IAP enabled me, as chair of the IAP, to case
manage individual cases by issuing case management directions to the parties after
considering their representations and, if necessary, after a case management hearing.
This power had proved valuable. In addition to the meetings with the parties referred to
above, where a party — usually, but not always the claimant — considers that a claim if
not proceeding as quickly or effectively as it might, or that directions from me might
assist the parties towards settlement (or a speedier settlement), they have made an
application for directions which has either resulted in the parties agreeing directions for
the more speedy/efficient resolution of the claim or my giving directions to similar effect.
Occasionally, extensions of time have been later sought; but generally, there has been
compliance with those directions. In my view, that has been the most important role of
the IAP to date.
Question 9
Page 12 of 24
38.
39.
40.
WITN11780100
WITN11780100
I have been asked: The Inquiry understands that the IAP have not been asked to
make a recommendation regarding a disputed head of loss. If this correct, are you
able to offer any explanation as to why?
I am unsure about the scope or intent of this question; but, if it a reference to the fact
that there has as yet not been any completed referral to the IAP, I refer to what I say
about process above (paragraphs 32 and following). A referral is effectively the last
resort of the scheme, and to date considerable progress has been made in the
settlement of individual cases without any referral of an individual claim running its
course. The figures are set out in the attached OC Scheme Reports. As at 30
September 2024, of the 111 claims within this cohort, 60 have been fully and finally
settled (54 at the initial offer sum of £600,000 and six at a different (higher) sum).
Interim payments have been made in the remaining 51 cases. The rate of progress of
settlements can be gauged by the fact that, in the three month period 30 June and 30
September 2024, 12 further cases were settled.
The remaining 51 cases broadly comprise (i) cases in which claimants are considering
whether or not to accept the initial £600,000 offer which, in some cases, is nota
straightforward decision and one which requires both expert and legal input; and (ii)
cases in which claims are still being prepared or have been lodged and are being
considered by the Post Office or are being negotiated. Itis likely that, by the beginning
of 2025, there will be very few if any claimants who have not accepted the initial offer or
lodged a full claim and the focus of the IAP’s work can be concentrated exclusively on
how most effectively and efficiently the future losses in the remaining claims can be
considered, if necessary assessed, and settled. As Chair, I am currently attempting to
Page 13 of 24
WITN11780100
WITN11780100
put claimants into the position where they can make an early decision on the initial offer;
and, if a claim is made, then the parties can consider how future loss claims can be
efficiently and effectively dealt with under the scheme. The proposal for guidance cases
early next year is one proposal towards that end.
Question 10
41. Ihave been asked: Please describe any other occasions, unrelated to a pecuniary
assessment, where the IAP have made a recommendation or given any direction
as to how a claim may proceed.
42. \have effectively dealt with this question elsewhere in this statement. Examples
include (i) my recommendation as Chair of the IAP that a minimum interim
payment of £450,000 of made to any claimant who has lodged a full claim (see
paragraph 35 above); (ii) directions I have given in cases in respect of the cost
assessment process designed to speed up that process (paragraph 36(ii )); (iii) the
proposal that guidance future loss claims are referred to and considered by the
IAP as a priority (see paragraph 36(iii)); and (iv) directions in individual cases
designed to speed up the assessment process (see paragraph 37) above).
Question 11
43. Ihave been asked: Please provide your view as to whether the OC scheme offers
full and fair compensation.
Page 14 of 24
44.
45.
WITN11780100
WITN11780100
Most of the claims which have settled on a full and final basis have done so
because the claimant has chosen to accept the initial offer of £600,000. As I have
indicated, under the Scheme, the claimant is entitled to up to £20,000 legal costs
and in addition expert costs necessary to come to an informed view as to whether
to accept that offer. I have seen nothing to suggest that any claimant has accepted
that offer other than on an informed and voluntary basis, as an exercise of
unrestricted free-will. I have seen no evidence of undue pressure being placed ona
claimant to accept the offer, nor of claimants considering that they may be under
such pressure; there is no time limit on the offer; interim payments are available to
assist a claimant during the period they are considering the offer; and there is
evidence from the claimant representatives that claimants are seeking legal and
expert advice in appropriate cases and are considering the offer very carefully
before deciding to accept or reject it. The inference is that the OC Scheme is
affording those claimants appropriate redress.
More generally, although the Principles have not yet been tested before the IAP,
they have been drafted by the Post Office with input from the claimant
representatives on the basis that they incorporate common law principles or
principles that are more generous with regard to scope of heads of claim and
evidential requirements of proof. As a fall back, if any claimant considers the
Principles fall below that standard, then they can refer relevant principles and/or a
particular claim involving those principles to the IAP which can then make a
recommendation for a change to the Principles. On the basis of past experience,
the Post Office is very likely to agree to implement any such recommendation by
amending the Principles.
Page 15 of 24
WITN11780100
WITN11780100
46. There is therefore no evidence that I have yet seen which suggests that the OC
Scheme offers less than full and fair compensation.
Question 12
47. \have been asked: Please set out any steps that you consider would improve the
administration of the OC scheme.
48. I have set out in my Reports (attached) my concerns about factors which slow progress
of claims and about the OC Scheme more generally.
49. Matters which do not currently appear to be slowing progress of claim resolution
include:
(i) I Other Horizon redress schemes have a claims facilitator built into the scheme, and
that appears to have been beneficial in those schemes. I have discussed the
possibility of including a claims facilitator into the OC Scheme. No party considers
that that would assist; and I agree. I do not consider that it would add to the
efficiency or speed or resolution of claims in this scheme, in which the number of
claimants who do not accept the initial offer of £600,000 is likely to be relatively
small and the remaining, disputed heads of claim are likely to be challenging
future loss claims.
Page 16 of 24
(ii)
WITN11780100
WITN11780100
At present, the claimant representatives say (and I accept) that resource capacity
is not a factor affecting speed of preparation of claims etc. That will need to be
kept under review, as the same claimant representatives and experts are likely to
be involved in the new redress scheme for claimants whose convictions have
been overturned by statute.
50. Matters which may be adversely affecting the progress of claims include the following.
()
Whilst the general picture is that claimant representatives are progressing claims
reasonably quickly, it is clear that they face a myriad of challenging
circumstances. Especially important, some claimants are traumatised or
otherwise suffering from mental health issues (often as a result of the
convictions themselves), which means that it is often a challenging and
time-consuming task for their legal representatives to take instructions
particularly on future loss claims, including the particular claimant's version
of historical events and their view of the counterfactual (i.e. what would
have happened but for the conviction). Some clients are extremely
distrusting, and sceptical of all aspects of the process (including, in some
cases, their own representatives). For some, late disclosure of (e.g.) their
Post Office pension arrangements has required a recalculation of part of
their schedule of loss. Some claimants live abroad and have complex tax
arrangements. The challenges faced by those representing the claimants
should not be underestimated. I consider that regular, careful and sensitive
case management of the individual cases, as outlined above, is the best
way to progress these claims.
Page 17 of 24
WITN11780100
WITN11780100
(ii) Some delays can be put at the door of the Post Office. Whilst I understand
the challenges of finding information relating to events years and
sometimes decades ago, and although more recently this appears to have
become less of an issue, there have been times when the Post Office has
not been as quick as it might in disclosing information relevant to the
formulation of a claim. Furthermore, as well as being slow in responding to
disclosure requests, there have been suggestions from the claimant
representatives that the Post Office has been overdemanding in the
particulars of claim it seeks before making an offer on a claim. Those too
seem now seem to be less.
(iii) I However, the Post Office’s governance procedure is lengthy and slow, so
that anything requiring approval takes longer than it should and longer that
prescribed in the Process Document. So, the Post Office seeks to respond
to a full claim with an offer within 40 business days (i.e. 8 weeks); but it
seems that that is sometimes extended to 10 or even 12 weeks. Even
where a loss schedule is straightforward, an offer is rarely made in less
than 40 days. Approval of claimant expenditure on expert evidence
required to formulate a claim is sometimes slow. Whilst it is not entirely
clear whether, or the extent to which, delays are the result of governance
procedures in the Post Office or the DBT or both, the evidence suggests
that is mainly the Post Office procedures that result in delay. Speeding up
these procedures would result in a more effective claims process.
(iv) I See also paragraphs 60 and following below.
Page 18 of 24
WITN11780100
WITN11780100
The HCAB
Questions 13 and 14
51.
52.
53.
54.
I have been asked: Please set out your role and/or involvement in relation to
meetings of the HCAB? Please set out your view as to whether the HCAB are
effective at instigating change to the administration of the OC Scheme.
I do not have any involvement in the HCAB, except that I have indicated to the HCAB
that I will regularly report to them and respond to any particular queries they have or
update they may seek.
I keep the HCAB up-to-date by sending my draft and final reports to the Chair of the
HCAB (Dr Christopher Hodges) for circulation to HCAB members, by joining meetings
of former Minister Hollinrake and the HCAB and updating them (and answering any
questions they may have) at those meetings, and regularly reporting to the Chair of the
HCAB usually by Teams call.
HCAB have been helpfully supportive by (e.g.) supporting my recommendation of the
£450,000 interim payment (see paragraph 35 above) and generally supporting my case
management approach to the claims within the OC Scheme cohort. Indeed, they have
exhorted increasing use of such powers to drive the claims forward, an approach which
I have been happy to take within the constraints outlined above concerning the fragility
of many of the remaining claimants in the cohort.
Page 19 of 24
WITN11780100
WITN11780100
55. Whilst I cannot speak directly as to the effectiveness of HCAB on instigating change to
the administration of the OC Scheme, I can say that the Post Office appears to listen
carefully to, and take account of, HCAB’s recommendations; and, consequently, I have
greatly appreciated HCAB's support for my recommendations and approach.
Question 15
56. Ihave been asked: Please consider RLIT0000275 — Report of the 14th Meeting of
the HCAB (14 May 2024). Please describe any steps described within paragraph
(1) that were proposed in relation to the OC Scheme, whether any of those steps
have been implemented and if so whether the speed of redress has increased or
likely to increase in the future.
57. Paragraph 1 of the Minutes to which reference is made said:
“The Advisory Board met with Minister Hollinrake and Sir Gary
Hickinbottom on 22 April. They had discussed implementing greater
scrutiny on case management, reviewing evidential requirements, and
other ways to increase the speed of redress. They also raised concerns
about Post Office staff with prior involvement in Scandal events being
involved in compensation and appeals work.”
58. I have effectively responded to this request in paragraphs 33-37 and 59-63 of this
statement.
Page 20 of 24
WITN11780100
WITN11780100
Question 16
59. Ihave been asked: Please set out any concerns that you hold in relation to Post
Office staff who are working on the administration of the OC scheme and whether
any steps have been taken to address those concerns.
60. As indicated above, some claimants are (understandably, given their history) extremely
wary and untrusting of the Post Office. Part of my role has been to ensure that they and
their representatives have confidence that I am independent of the Post Office. Alll
claimant representatives are invited to my joint meetings with the parties. I do not have
any communication with the Post Office direct; and, except for the most mundane
administration (which is usually dealt with through my clerk), I do not communicate with
HSF without copying in the claimant representatives. The claimant representatives
originally selected me to chair the IAP. In my view, their confidence in my
independence, and willingness and ability to drive the progress of claims forward, is key.
61. lunderstand steps have been taken to ensure that those with previous experience of
the Horizon scandal are not involved in the administration of the OC Scheme. However,
the mere fact that the Post Office — and its solicitors, HSF — is administering the OC
Scheme does not assist in the building of the claimants’ confidence in the Scheme; but I
believe that is a challenge that can be overcome. The confidence of the claimant
representatives is vital in that task. I believe I have, and can maintain, that confidence.
62. In appropriate cases, I can take special measures to help allay particular concerns.
Page 21 of 24
WITN11780100
WITN11780100
General
63. Ihave been asked: Please set out any other information that you think is relevant to
the Inquiry.
64. Ido not consider that I can usefully add to this this statement and its attachments; but, if
the Inquiry has any issues which I could usefully clarify, I would be pleased to do so.
Statement of Truth
I believe the content of this statement to be true.
Signed:
GRO
Dated: 29 October 2024
Page 22 of 24
Index to First Witness Statement of Gary Robert Hickinbottom
WITN11780100
WITN11780100
No.
URN
Document
Description
Control Number
WITN11780101
(CV of Sir Gary
Hickinbottom
ITN11780101
WITN11780105
Report -
July 2024 Pecuniary
Losses
ITN11780105
WITN11780106
Draft Report —- October
2024 — Pecuniary
Losses
ITN11780106
WITN11780102
Overturned Convictions
+ Pecuniary Assessment
Process
ITN11780102
WITN1780104
Overturned Convictions
+ Terms of Reference for’
he IAP
1TN1780104
POL00448909
Overturned Convictions
+ Application Form — IAP
POL-BSFF-136-
(0000002
Page 23 of 24
WITN11780100
WITN11780100
Page 24 of 24