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Witness Name: Simon Hutchinson
Witness No: WITN11820100
Dated: 5 December 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF SIMON HUTCHINSON
I, Simon Hutchinson, will say as follows.
INTRODUCTION
1. lam acurrent employee of Post Office Limited (“POL”) and have worked within
the business since 11 February 2013.
2. I have made this witness statement to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) with the matters set out in the Rule 9 Request addressed to me
and dated 12 November 2024 (the “Request”).
3. I confirm that I have received legal assistance from Ashfords LLP when drafting
this statement.
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BACKGROUND
4. I gained a Human Resource Management Degree from the University of Ulster,
graduating in 2011 and subsequently gained a post graduate Diploma in
Human Resource Development in 2012, giving me Associate Membership of
the Chartered Institute of Personnel and Development (“CIPD”) - Certified
Security Management Professional (“CSMP®”) Level 6 Accredited Diploma
and Member of ‘The Security Institute’, (“MSyl”).
5. Prior to joining POL I worked part-time for a cash in transit delivery company,
where I was responsible for the secure transportation of cash between
locations. It was during this role, through word of mouth, that I learned of an
upcoming vacancy at POL as a Security Manager for the Northern Ireland
Region. This information was passed to me by Keith Gilchrist, who at that time
was the current Northern Ireland Security Manager dealing with Physical
Security, but would be stepping into a Team Leader role. I applied to POL to
step into Keith Gilchrist's Security Manger role when he vacated it, and was
successful in my application. From memory, the interview process involved a
written application, including my CV and an interview with Dave Pardoe and
Suzanne Winter.
6. I officially started in POL as a Security Manager in Brent House Post Office in
Belfast on 11 February 2013 and was responsible for the Northern Ireland
region. This role entailed the following:
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i. Ensuring the physical security of POL’s personnel, branches and assets,
including cash in transit. This was mainly achieved through
implementing target hardening tactics such as improving and
maintaining security alarm, safe and surveillance systems.
ii. Conducting investigations into alleged crimes against the business, for
example, theft and fraudulent activities that caused a monetary loss to
POL.
7. On 19 August 2013, I stepped into a temporary Team Leader role in the POL
Security Team. I recall that Keith Gilchrist had left POL around this time and
another Security Manager, Kevin Ryan, had briefly stepped into the Team
Leader Role, but then stepped back to a Security Manger role after a couple
of months. I then stepped into the Team Leader Role after Kevin Ryan, but
also moved back to the role of a Security Manager after 5 months. Following
this, Helen Dickinson took on the role of Team Leader.
8. Atthe time that I took on a temporary Team Leader role I had not been working
at POL for very long and therefore I had little experience of POL investigations.
It was therefore agreed within the team that my role as Team Leader would
focus more on Physical Security, which meant that I was out on the road for a
lot of my first year in the business, dealing with physical security matters at
individual branches. This concerned all law enforcement crime and critical
incidents such as robberies and burglaries and assisted in the management of
ongoing POL and police investigations by reporting the progress of the
investigations to senior security management at the monthly case review
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meetings. When it came to matters concerning POL investigations, it was
agreed that I could rely on Suzanne Winters (another Security Manger) to
assist me with this. From recollection, I believe Suzanne Winters had over 20
years’ experience in POL investigations and therefore it was deemed suitable
for her to support me in this way.
9. In addition to the roles I carried out as a Security Manager (as described in
paragraph 7 above), my role as Team Leader involved carrying out one-to-
ones and providing supervision to other Security Managers in POL’s Security
Team. This included: Robert Daley, Kevin Ryan, Suzanne Winters, Chris
Knight, Andrew Wise and Steve Bradshaw. I was Team Leader for the North
of the UK which covered Northern Ireland, Scotland and the North of England.
There were robberies and/or burglaries nearly every day in Post Offices across
my region and so my main responsibility was making sure that these were dealt
with appropriately by Security Managers. There was also a monthly case
review conference which was held in London and chaired by John Scott, POL
Head of Security. However, my involvement in this was simply to collate and
deliver updates from Security Managers and I did not have a direct role in
decision-making or investigations.
10.1 reverted back to being a Security Manager on 20 January 2014 and have
remained in this role since, although there have been some name changes to
the job title over the years. Currently my title is “Regional Network Crime and
Risk Support Manager, Northern Ireland & Scotland”. To avoid any confusion,
I will refer to the role as “Security Manager’ throughout this statement.
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Although the title of the role has changed, the role itself has remained the same
apart from in around 2014, when Suzanne Winter left, I took on the
management for what had been her investigations. At this time, there was a
freeze on prosecutions.
11.Initially when I reverted back to a Security Manager I still only covered the
Northern Ireland region, but my remit changed to both Northern Ireland and
Scotland in the summer of 2024.
12. I do not think I have had any active involvement in disciplinary matters in both
my roles of Security Manager and Team Leader at POL. While it may have
been within my responsibilities as Team Leader to manage disciplinary matters
involving those reporting to me at the time, I do not believe any such issues
arose during my brief time in the role. In terms of disciplinary matters involving
Sub Post Masters (“SPMs’”), this has not ever been my role. As far as I am
aware, this is a Contract Manager's role. I do vaguely recall an occasion a long
time ago where a Contract Manager asked for my view on whether they should
suspend a SPM after an incident and I remember informing them that it wasn’t
within my remit to make that decision. Unfortunately I cannot remember when
this was or the specific details of the case. Whilst Security Managers did not
make decisions to suspend SPMs, I do think on occasion they would provide
relevant information to Contract Managers to assist them with coming to a
decision. This information might include background to an incident being
investigated and facts about the branch itself, such as whether it has been
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operating well. I am not now able to recall a specific occasion where I may
have done this.
13. In terms of carrying out interviews under caution, this did fall within my role as
a Security Manager in cases where POL carried out internal investigations.
However, in the majority of interviews I have attended, I sat as the Second
Investigator, meaning my role was simply to assist the Lead Investigator with
setting up the interview, and perhaps asking some further questions to the
interviewee to seek clarification on matters, if I felt it would assist with my own
understanding about the case, or that it may help the Lead Investigator. I
believe it is only on one occasion that I took on the role as a Lead Investigator
in an interview and this was for the former SPM in Belcoo, Northern Ireland.
From memory, this concerned an audit shortage of around £102,000, which
the SPM admitted to stealing.
14. Often investigations and prosecutions did not directly concern a SPM but a
branch staff member who was not a SPM. For example, it was not uncommon
for SPMs to be business owners who had staff to run the branches. Where
losses concerned these staff members, POL would advise the SPM to inform
the Police Service of Northern Ireland (“PSNI”) and they would lead the
investigation. POL would subsequently liaise with the PSNI to provide
information as and when required. POL would not be carrying out the
investigations but simply liaising with PSNI to assist with their investigations.
We called these Police Liaison cases. The Public Prosecution Service for
Northern Ireland (“PPSNI”) would then take over once a decision to prosecute
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had been made. I do not recall having any involvement with the PPSNI
although I understand that POL did provide them with details in respect of
Horizon as and when asked. Separately, POL did carry out the prosecutions
where they concerned the actual SPM. I have provided more details about the
process of prosecutions in developed nations later in my statement.
15. With regards to disclosure in criminal proceedings, I believe that the gathering
of relevant documents ready for disclosure would have fallen into my remit as
a Security Manger, but only if I was the Lead Investigator in a POL internal
investigation and a decision had been made to take the case forward for
prosecution. I vaguely remember there being lists that needed to be completed
for sensitive or non-sensitive disclosure in this instance. However, I would like
to flag to the Inquiry that I have never had to complete this task because as far
as I can recall, no case that I have personally investigated as a Lead
Investigator has ever reached the relevant stage in a prosecution where I was
required to produce disclosure. In the event that any of my cases had reached
that stage, whilst I would have been responsible for gathering relevant
disclosure and completing the disclosure lists, I do not think I would have had
responsibility for directly disclosing the documents to the Defence or the Court.
As far as I am aware, we would have been required to submit disclosure to our
Team Leader to check over, then they would submit this to the Security Team’s
Central Hub (who dealt with administrative matters, such as case allocation
and case file formatting), who I suspect would then forward this on to POL
lawyers, or any other external legal team representing POL in the case, to
disclose out accordingly. However, I cannot recall any cases when I was Team
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Leader where I had to do this. In fact, apart from passing on documents to
investigating officers as and when requested, I cannot recall ever being
involved with disclosure.
16.1 would like to flag that where investigations into alleged offences against POL
were led by the PSNI, Security Managers may be approached by the police
investigating officer to ask for documents to assist them in their investigation.
However, I believe it would be the investigating officer in the PSNI who would
be responsible for disclosing to the Defence and the Court in the event the
case proceeded to that point in a prosecution.
17.In terms of disclosure in civil proceedings, I do not think I had any role in
relation to this. I am not sure what the disclosure process was in such cases.
18.1 do not believe I have ever had a role in relation to litigation case strategy in
both my capacity as Team Leader or Security Manager. This seems to be
something that POL legal teams would be responsible for, perhaps in liaison
with Senior Management in POL Security, but I am unable to say for certain.
19.As far as I can recall, I would generally liaise with the following POL
departments in respect of the progress of cases:
i. POL Audit Team —- auditors would usually be the first individuals to
discover a loss during an audit at a POL branch, and therefore they
would instigate a potential investigation into a matter by informing POL’s
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Security Team about the loss. As a Security Manger I may have chased
up auditors involved in the particular matter to seek relevant information
to assist me with progressing an investigation. For example, to gather
information about what the auditor discovered on the day, and request
an account of their interactions with the SPM, including whether any
explanations were provided by the SPM in relation to the loss
discovered.
POL Security’s Central Hub — the Central Hub would allocate new
investigation cases out to Security Managers, so I may have had
interactions with this team where a case had been allocated to me. I also
may have had interactions with the Central Hub in my capacity as Team
Leader, as I recall that where an investigation was carried out internally
by POL, a case file would be completed by a Security Manger, who
would first pass it on to their Team Leader to review, who would then
pass it on to the Central Hub for processing (to ensure it had been
formatted correctly) and they then send it on to Senior Management
within the Security Team to consider whether to take the case forward
for prosecution. However, given that I focused on Physical Security
during my time as Team Leader and relied on Suzanne Winters in
relation to matters concerning Investigations, it may be that I did not ever
do this — I just cannot recall for certain.
POL legal teams — on occasion, POL’s internal legal team may have
approached me to seek information on cases I was involved in or to ask
questions to help them with progressing a matter they were pursuing in
respect of a case.
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PROSECUTIONS IN DEVOLVED NATIONS
20.1 became involved in the investigation and prosecution of POL cases in
Northern Ireland when I took on the Security Manager role for the Northern
Ireland Region on 11 February 2013. However, as explained above, within my
first year at POL I also temporarily stepped into a Team Leader role from 20
August 2013 to 20 January 2014, and in this role I worked mainly on POL’s
Physical Security matters as opposed to POL investigations. Looking back
now, I believe that even in the 6 months prior to me temporarily stepping into
the Team Leader role I was more involved in Physical Security than POL
investigations, because as explained above, the Security Manager role I took
on was to replace Keith Gilchrist, who as far as I am aware, dealt mostly with
Physical Security. Therefore, my work load as a Security Manager in my first
few months naturally revolved more around Physical Security. I believe it was
Suzanne Winters who dealt mainly with the investigations side in the Northern
Ireland region during this early period, and where I had any involvement in
investigations during this time, it would have been to shadow her on cases to
learn how POL cases were conducted, in terms of both internal investigations
and in police liaison cases.
2
.I do not believe that I was ever involved in the investigation and prosecution of
POL cases in Scotland. I believe it was Robert Daley who had this role, as he
was the Security Manager for the Scotland Region. However, I do recall having
to travel to Scotland on one occasion to assist in an interview of a SPM, but
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only as the second interviewer. I believe this was simply due to staff shortages
or unavailability, and under POL’s procedures, there had to be 2 interviewers
present, so I was asked to step in and help. I cannot remember when this was
or the specific details of that case.
22.With regards to the training I received at POL in relation to the Northern Ireland
legal system, I can recall undergoing a 4 week informal induction when I first
started as a Security Manager in February 2013, where I shadowed Suzanne
Winters on her cases, and sat down with her to go through how POL dealt with
cases in Northern Ireland. I do believe when running through the process
around police liaison cases, that Suzanne would have covered the Northern
Ireland legal system with me. I can also recall receiving a lot of training from
Cartwright King on issues such as notebook entries, disclosure matters,
cautions and carrying out interviews under caution.
23.In terms of the Scottish Legal System, I do not think I have ever received any
formal training from POL on this either before or after my delegation. However,
I do recall briefly reading up on it when I was required to step in as the Second
Investigator during an interview of a SPM in Scotland, as mentioned in
paragraph 22 above.
24. I have been asked to describe the process by which Post Office cases were
investigated and prosecuted in Northern Ireland and Scotland and in particular,
how the process differed from England and Wales, and any ways in which the
process changed. My understanding is as follows:
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Northern Ireland - when I first joined POL as a Security Manger, I
believe that all ongoing cases in Northern Ireland were investigated by
Suzanne Winter. Once these had been approved to proceed to
prosecution by POL Head of Security, they would be submitted to the
PSNI Central Process Office. The PSNI Central Process Office played a
purely administrative role to check that the proper process and
procedures for the investigation had been carried out. They did not re-
investigate the cases but essentially played a quality assurance role.
Separately, cases that involved Post Office staff, who were not SPM’s
would be referred to the PSNI to investigate, who we would liaise with to
answer any queries that they had in relation to the case. In terms of the
POL investigations process, when a POL auditor discovered a loss ina
Northern Ireland branch, the matter would be referred to POL’s Security
Team and the case allocated out to a Security Manger within the region
to conduct an investigation. The Security Manager, along with a Second
Investigator, would likely conduct and interview under caution with the
accused, and also gather relevant documents to assist with the
investigation, for example Horizon print outs from the auditor, eye
witness testimony from those present during the audit etc. They would
then produce a case file of their investigation and pass it to their Team
Leader for review. Eventually the file would be passed on to Senior
Management within Security to consider (via POL Security Teams
Central Hub). A decision would then be made as to whether the case
should progress to prosecution by Senior Managers in the Security
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Team, I suspect with the input from POL’s legal team as to the relevant
charges.
England and Wales — I did not get involved in any Post Office cases in
England and Wales, but I believe that all cases in this region were private
POL investigations, carried out internally. I therefore believe the process
in England and Wales would have been the same or similar to what the
process became in Northern Ireland when cases increasingly became
investigated internally.
Scotland - Other than the one occasion where I sat in on an interview
as a Second Investigator in a case in Scotland, I cannot recall being
involved in Post office cases in Scotland other than to provide
information as and when required. From disclosure, I can see an email
dated 4 October 2013 [POL0033497] where I forward on details of a
Scottish case to Andy Hayward for escalation. Prior to receiving this
disclosure, I could not recall this case and I do not remember what
happened following this email chain. However, my assumption is that it
would have been dealt with by Andy Hayward and I would have had no
further involvement. Due to my limited involvement in Scottish cases I
cannot recall the specifics of how Post Office cases were investigated
and prosecuted in Scotland. However, I can see from [POL00164215],
an email dated 3 September 2013, that I was forwarded on ‘Agreed
Scottish Prosecution process’. This would have been for information
only.
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25. I have also been asked to provide details of the individuals I worked with on
cases in Northern Ireland and Scotland. In Northern Ireland, I would have
worked with PSNI officers investigating the case in any police liaison cases, to
the extent they requested further information from me in relation to an
investigation they were running. I cannot recall the details of every police
investigating officer that I may have worked with on cases, but the documents
provided to me with the Request do illustrate that I was in liaison with Constable
Alan Gordon in one case (see [POL00333552], [POL00333555] and
[POL00333558}).
26.When POL cases in Northern Ireland became investigated internally by POL, I
would have worked with POL’s legal teams more often if I was a Lead
Investigator, for example, if I was asked to assist them with any queries or
matters they needed to pursue in relation to the case. For example, this is
evident from various email correspondence provided to me with the Request
relating to the prosecution of Peter Damian McCartan. I would like to clarify at
this stage that I was not actually the Lead Investigator in the Prosecution of
Peter Damian McCartan - this was Suzanne Winters, but due to Suzanne
leaving POL, I was allocated the case to manage going forward. By this point
her initial investigations had already been conducted and the case had already
reached the prosecution stage. I provide more detail in relation to this case
under the following heading below: PROSECUTION OF PETER DAMIAN
MCCARTAN.
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27.1 do not believe that I would have worked on POL cases in Scotland, or
collaborated with anyone else in relation to any Scottish cases. As mentioned
above, I believe the only involvement I had in a Scottish case was when I sat
in as a Second investigator to assist another Security Manager due to staff
shortages and availability. As far as I can recall. I did not carry out any further
work on that case myself, or to assist anyone else.
WHEN THE SERVICES OF MCCARTAN TURKINGTON BREEN (“MTB”)
SOLICITORS WERE SECURED BY THE POST OFFICE AND FOR WHAT
PURPOSE
28.1 have reviewed the following documents:
ii)
il)
iv)
v)
vi)
[POL00108203] (Tab “All Live” - Row 17; Tab “North” — Row 9) (April
2013) Summary of Cases Spreadsheet
[POL00126931] (June 2013) One to One Meeting Record of Suzanne
Winter (Line Manager: Keith Gilchrist)
[POL00105032] (28/06/2013) One to One Meeting Record - Simon
Hutchinson (Line Manager Kevin Ryan)
[POL00165675] (02/04/2015) Email from Dave Posnett to Post Office
Security and Helen Dickinson re: Case closure Ballynafeigh
[POL00029744] Interim Report into alleged problems with the Horizon
System
[POL00029849] (09/04/2015) Initial Complaint Review Mediation
Scheme: Second Sight Briefing Report - Part
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vil) [POL00294584] (28/01/2016) Post Office Security Operations
Investigation Governance Meeting Action Points
29.1 cannot recall from memory when the services of MTB solicitors were first
secured by POL. I believe that it was before the time I joined POL in February
2013, as I can see there is mention in a one-to-one meeting between Keith
Gilchrist and Suzanne Winters (which covers the period of 13 April 2013 to 30
May 2013), that Ernie Waterworth (solicitor for MTB) was now the official legal
advisor for POL’s Security Team in Northern Ireland, and that he was meeting
with the DPP to establish if the police (meaning the PSNI) could be taken out
of the handing over process (see [POL00126931]).
30.1 would like to clarify to the Inquiry it was not me who engaged MTB Solicitors.
I have a vague recollection of it potentially being Kieth Gilchrist in his capacity
of Team Leader who contacted and lined up the services of MTB solicitors, on
the instructions of Senior Management within POL Security. As such, it was
not me personally who considered that the involvement of Northern Ireland
solicitors was necessary, when previously Security Managers had submitted
cases directly to the PSNI Central Process Office. I also would not have been
involved in seeking any legal guidance from POL’s legal department before
MTB solicitors were contacted. I do not know if Keith Gilchrist sought such
advice or guidance, but I imagine he may have done so, probably on the
direction of Senior Management in POL Security. However, I cannot confirm
this for certain.
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31.1 have been asked to consider [POL00126931] and to confirm:
i. what was the purpose of EW meeting “DPP to establish if police can be
taken out of the handing over process and EW deal directly with DPP’?;
ii. why did the Post Office want to remove the involvement of the police?;
and
iii. I who was involved in making this suggestion?
To assist the Inquiry with this I believe it would be useful to set out the following
further context: I think the services of Ernie Waterworth of MTB Solicitors had
to be lined up simply because the PSNI were terminating the existing
arrangement whereby POL previously submitted cases directly to the PSNI
Central Process Office. This was before I joined and so I cannot say for definite
but I believe that it was PSNI Central Process who took the decision to bring
their services to a close, not POL.
32.As far as I understood it, MTB Solicitors were to review and scrutinize cases
investigated in Northern Ireland going forward, and to advise whether they
were appropriate for onward referral to the PPSNI. In light of this, I believe MTB
Solicitors were effectively instructed in Northern Ireland to replace the former
function of the PSNI Central Process Office, to act as a buffer and conduit
between an individual investigating a matter and the PPSNI.
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33.1 cannot recall ever having any discussions with a DPP representative about
Northern Ireland cases. As such, I am unable to provide details of any such
representatives.
34.1 am not sure how the role of MTB solicitors differed from the role of the POL
Criminal Law Team in relation to Northern Ireland criminal investigations. My
understanding of MTB Solicitor’s is summarised above. I’m not sure if it is just
the case that the POL’s Criminal Law Team carried out this same function but
in relation to cases brought in England in Wales, before they were sent on to
the CPS.
35.In terms of the work being conducted by Second Sight, I do recollect being
aware that Second Sight had been engaged to look into alleged problems with
the Horizon IT system that had been raised by SPMs, but that was the extent
of my knowledge. I do not recall having any specific knowledge of what those
alleged problems may be.
36.1 can see in a document provided to me detailing a one-to-one meeting I held
with Suzanne Winters in September 2013 where there is mention of Second
Sight’s review (see [POL00127136]). This indicates that I may have been
informed about the existence of Second Sight’s interim report and I believe this
would have been by Senior Management in a POL Security Team briefing.
However, I do not recall when this may have been and I do not believe I was
ever told of the specific content of such report. The first time I have ever seen
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and read Second Sight’s interim report was when it was provided to me with
the Rule 9 Request.
37.1 have no knowledge as to whether MTB solicitors’ initial engagement by the
Post Office was influenced by the Horizon issues being investigated by Second
Sight. From memory I do not think this was the case — rather, my understanding
as to why MTB Solicitors were engaged is set out in paragraphs 30 to 35 of
this statement.
38.1 do not know if or when MTB Solicitors were made aware of the Second Sight
investigation or their interim report. I do not recall ever being initiated to
communicate with MTB Solicitors about this at any point. I would suspect this
is something that someone more senior within POL Security would have
communicated with MTB Solicitors about, but I have no knowledge of whether
this did occur or when.
39.1 am not aware of MTB Solicitor’s role changing at any point after they had
been engaged.
40.1 have been asked to consider [POL00294584] (which appears to be minutes
of a POL Security Meeting held on 28 January 2016 that I did not attend), and
to confirm the following:
i. what was the purpose of setting up a conference “03 To arrange
conference call with Ernie Waterworth, [Simon Hutchinson], [Martin
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Smith] & [Helen Dickinson] to discuss pending PSNI cases and potential
Horizon issues” ?; and
ii. my understanding of the potential Horizon issues as at 2016.
41.1 think the only role I may have had here was to assist in setting up the
conference call between Ernie Waterworth (MTB Solicitor), Martin Smith
(Cartwright King) and Helen Dickinson (my Team Leader), and perhaps be
there to listen and take note if any of the cases to be discussed were being
managed by me. However, I cannot recall this POL Security meeting taking
place, or the abovementioned conference call that may have arisen out of it.
As such, I am unable to comment on what the purpose was of setting up the
conference call.
42.In terms of my understanding of the potential Horizon issues as at 2016, I
believe I was aware that some SPMs were alleging that there were potential
issues with the Horizon System, and this was being pursued as a defence in
their case, however, I had no knowledge about any of the specific bugs or
errors being alleged. For example, I can see in my email update on 23 March
2015 at [POL00326019] provided to Martin Smith, Lucky Thandi and Helen
Dickinson, I set out my current case load for Northern Ireland (per Martin's
request), and make reference to “possible horizon issues here” with regards to
the Drumantee case (which was a police liaison Case) and also mention that
in the Ballynafeigh case (an internal POL investigation) the SPM intimated that
a shortage discovered at his branch during an audit may be something to do
with Horizon.
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43.As far as I can recall, still at this stage we were told to continue with our
investigatory role as Security Mangers because Horizon was robust. This
message would be relayed to us in POL Security Team briefings by Senior
Management in the Security Team. I do also recall going to Birmingham on
one occasion with other Security Mangers to receive a briefing from POL’s
former CEO, Paula Vennells, who confirmed that Horizon was a robust system
and that we could continue with our everyday work. Unfortunately I cannot
recall exactly when this was.
THE STEPS TAKEN BY THE POST OFFICE AND THE APPROACH OF THE PSNI
IN RELATION TO NORTHERN IRISH CASES FOLLOWING THE PUBLICATION OF
SECOND SIGHT’S INTERIM REPORT ON 8 JULY 2013
44.1 have reviewed the following documents:
i. [POL00146123] (27/08/2013) Email from Communications Team to
Richard Polson, Richard Poulton, Richard R Weaver & Ors RE: Strike
Contingency Plan - Tuesday 27 August
ji. I [POL00164215] (03/09/2013) Email chain from Kevin Ryan to Simon
Hutchinson RE: Agreed Scotting Prosecution process
iii. [POL00126976] (11/09/2013) Email from Dave Posnett to Aftab Ali,
Andrew Daley, Andrew S McCabe and others re: RMG MOU-
Memorandum of Understanding and Royal Mail Group Joint
Investigation Protocols
iv. [POL00127136] (17/09/2013) One to One Meeting Record between
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Suzanne Winter and Simon Hutchinson (Line Manager) for period of
02/08/2013-17/09/2013
v. [POL00299454] (17/09/2013) Email from John M Scott to Angela Van-
Den-Bogerd CC'd Rob King, Andy Hayward and others RE;Horizon &
Investigations
vi. I [POL00333497] (04/10/2013) Email chain from Simon I Hutchinson to
Andy Hayward RE: Scottish protocol and emails from the Crown — Andy
was my line manager as a Team Leader.
vii. I [POL00127133] (12/10/2013) One to One Meeting Record with Robert
Daily and Line Manager: Simon Hutchinson
viii. [POL00127134] (05/12/2013) One to One Meeting Record with
Suzanne Winter and Line Manager Simon Hutchinson from 20/10/2013
- 05/12/2013
ix. [POL00105134] (26/04/2014) One to One meeting Record between
Simon Hutchinson and Helen Dickinson - Review of 2014
x. [POL00105145] (14/03/2014) Performance Development Review for
Robert Daily (POL Security Manager) 2013/14 year end PDR
xi. [POL00326019] (23/03/2015) Email from Simon I Hutchinson to Martin
Smyth, Lucky Thandi and Helen Dickinson RE: Case File Governance
Northern Ireland AA
xii. [POLO0333532] (28/05/2015) Email from Simon I Hutchinson To:
Elaine McCabe RE: 1.NOT PROTECTIVELY MARKED-All Networks:
Post Office Fraud Rita O Reilly- Derrylin
xiii. I [POLO0326121] (15/07/2015) Email from Simon Hutchinson to Martin
Smith RE: Horizon Statement
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xiv. [POL00333536] (04/08/2015) Email from Elaine McCabe to Simon I
Hutchinson re 1.NOT PROTECTIVELY MARKED-All Networks: RE:
Derrylin Post Office Investigation —
xv. [POL00333541] (03/11/2015) Email from Simon Hutchinson to Helen
Dickinson RE: Drumantee
45.As mentioned earlier in this statement, I believe that I may have been
informed about Second Sight’s interim report existing by Senior Management
in a POL Security Team briefing, but I do not recall ever seeing or reading the
content of that report at the time. I am not sure if I was made aware of Second
Sight’s other report at [POL00029744]. I believe the first time I have ever
seen and read its content was when it was provided to me with the Request.
46. Until I started following the oral evidence given in the Inquiry, I believe that I
had no previous knowledge of the Helen Rose Report existing. The first time
I have seen and read it was when it was provided to me with the Request.
47.I have no knowledge as to what POL may have informed MTB Solicitors, PSNI
or PPSNI about the Second Sight reports or the Helen Rose report, or
whether they were even made aware of these reports by POL.
48. I am also not aware of these reports being filed in any court proceedings in
Northern Ireland, or being served on the defence.
49.1 am not able to comment on whether these reports had any impact on POL’s
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investigation or prosecution strategy, for example, prosecutions or
investigations being terminated as a result. Conversations about the reports
and the impact they may have on POL'’s investigations or prosecutions
strategy would be something senior management within POL Security,
potentially in liaison with POL’s legal teams, would discuss. If then necessary,
Security Mangers would be briefed on any change in investigation or
prosecution strategy in team briefings. However, I cannot recall any particular
briefing on changing POL’s investigation or prosecution strategy. I can,
however, see in an email dated 27 August 2013 at [POL00146123] that the
publication of the Second Sight Interim resulted in a mediation scheme being
set up to address concerns raised by SPMs. I had no involvement in this and
the email would have been for information only.
50.1 do vaguely recall that a group of more senior individuals within POL Security
were allocated to address any Horizon related matters and they did have
Horizon related conference calls. I cannot recall who in particular made up
this group, but I can confirm that I was not part of it and I did not attend such
calls. From my review of the documents, I believe that it would be within these
meetings where topics such as the potential impact of the reports by Second
Sight or Helen Rose on prosecution or investigation strategy may have been
discussed. For example, the email from John Scott (Head of POL Security)
to Angela Van-Den-Bogerd at [POL0029945] (which copies in others from the
Security Team) illustrates that Dave Posnet had been allocated as a point of
contact for ‘new Second Sight cases, queries, spot lights etc.’ and that he co-
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ordinated Wednesday morning Horizon conference calls.
51.1 do not know exactly when PSNI was first made aware of Horizon issues with
the potential to impact upon prosecutions. I can see from my email to Ben
Beabey (Senior Legal Counsel at POL) on 8 October 2019 [POL00043066]
that I mention to him the following: “we have a generic letter from Mark
Raymond (attached) that I pass to all Police investigating officers connected
with a POL criminal investigation and I verbally inform, normally at our first
meeting, that there is ongoing civil litigation which involves Horizon and other
business matters.” I can see that the generic letter signed off by Mark
Raymond is at [POL00333578], but there are earlier versions signed off by
Amy Quirk dating back to 2016 and 2015 at [POL00333553] and
[POL00333548]. To confirm, Amy Quirk and Mark Raymond were Senior
Managers in POL Security. I can also see that a version of this letter was
provided to me and others in the Security Team by Helen Dickinson via email
on 9 December 2015, with an instruction to offer it for every case that is
currently with the CPS, PF or PSNI (see email chain at [POL00322903)).
From these documents it appears that I would have been passing across the
information in this generic letter to the PSNI from as earlier as 9 December
2015, at least up until 8 October 2019. I do not think I would have been
sending these letters directly to the PPSNI, as I would have expected this to
be done by any PSNI investigating officer dealing with a case that I sent it to.
52.1 can then see from an email chain at [POL00043157] on 21 October 2019
that Ben Beaby attached further update letters setting out POL’s position in
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relation to Horizon issues. He informed in such email that these were drafted
and approved by POL legal and external POL lawyers, with an instruction for
these to be sent out by POL Security Managers to the relevant prosecutors.
The specific letter that I was tasked to sign off and send out is at
[POL00333601], which provides more detailed and specific information in
relation to Horizon issues being raised by SPMS in group litigation, and
answers questions posed from the Defence about Horizon issues in the case
of Andrea Gourley. It appears from the email chain at [POL00333600] that I
sent this out to the PSNI investigating officer dealing with the case, Thomas
Ross, on 20 October 2019. It appears he then passed this on to the PPSNI
on 21 October via email. The PPSNI representative, Cathy McGaile, then
chose to contact me directly on 23 October 2019 (as opposed to liaising with
me via the PSNI, which was the usual process) to inform that she had
responded to the questions posed by the Defence in accordance with the
responses contained in my letter, but that she did not disclose the letter in its
entirety to the Defence as she was satisfied that the unreliability issues raised
relate to the preceding Horizon IT system, which was not relevant to this case.
I deal more with this topic under the following subheadings of this statement:
“LEA LETTER’.
53.1 do not know if any cases in Northern Ireland were reviewed in light of the
interim Second Sight report. I can recall carrying out general case reviews of
ongoing cases, to ensure they were all being conducted in order and case
files being completed correctly. However this was just standard procedure,
and not carried out in a Horizon issues context. If there were case reviews of
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Northern Ireland cases specifically in light of Second Sight’s interim report,
this may have been carried out by the group of senor individuals within POL
Security who had been allocated to address any Horizon related matters and
held Horizon related conference calls (as mentioned in paragraph 53 above).
However, this is just speculation and I cannot confirm this for certain.
54.1 have been asked to confirm how I line-managed Suzanne Winters in light of
Second Sight’s interim report, and what advice I gave her in relation to
prosecutions in Northern Ireland. From memory, I do not think I gave any
recommendations or advice to Suzanne in respect of this. I can see in a one
to one I had with her on 17 September 2013, in my brief time as a Team
Leader (see [POL00127136)) that it says the following under the subheading
‘understanding priorities’ — “The significant impact the SS review may have
on my POL cases and for future investigations”. I have no recollection of
discussing this with Suzanne. This priority may be something that Suzanne
has determined solely by herself following briefings from Senior Management
within POL Security following the publication of Second Sight's interim report,
but as far as I can recall, all briefings I received by Senior Management in
POL Security, was to carry on as normal as Horizon was robust.
55. Although I cannot recall any changes to the way investigations were carried
out, I do recall that things got busier after the publication of the Second Sight
report as I think that more SPMs were raising questions and queries based
on the findings in the Second Sight report. This recollection is in line with the
record of a one-to-one meeting I had with Helen Dickinson on 26 February
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2014 (by which point she was Team Leader), that next to a subheading of
‘Team Leader Role’, I mention the following: “/ have been acting as temporary
Team leader of Sec Ops Team North. This has come at an exceptionally busy
time with significant impact to daily investigations into theft/ fraud of POL
assets, regarding the recent 2" Sight Report into POL Horizon (...)” (see
[POL00105134}).
56.As far as I can remember, I do not think I made any particular changes to my
own approach to investigations or prosecutions shortly after the publication of
the Second Sight interim report, however, I can see much later on 1 July 2015
that I informed a PSNI officer dealing with the case involving Rita O’Reilly and
Derrylin Post Office, that POL were of a mind to close the case as Ms O'Reilly
had mentioned a Horizon Defence, and Post Office were some time away
from employing a subject matter expert to appear in Court to help POL oppose
claims of such defence. As such, it appears that there was some change to
the approach in prosecutions in that we appeared to now need expert
evidence in Northern Ireland cases where there were issues being raised in
respect of the Horizon IT system. As mentioned above, I do not think expert
evidence was ever used previously in any Northern Ireland cases.
57.1 do not know if or when the PSNI was informed about the Second Sight
interim report. I also do not remember the approach being taken by the PSNI
ever changing in relation to Northern Ireland POL cases following the
publication of Second Sight's interim report. However, as shown in an email
chain of 6 July 2016 at [POL00333558] I did speak to PSNI about Horizon’s
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integrity and offered to put PSNI in contact with a POL senior manager in case
they wanted to discuss the matter further. However again, [POL00333536]
indicates that there was some change to the approach by July 2015, in that
POL would need to be able to produce expert evidence in Northern Ireland
cases where a Horizon Defence was raised, in order for the PSNI to proceed
with the case.
58. Other than the letters and information mentioned in paragraphs 52 and 53
above, I do not know how else the PSNI were kept updated in respect of
Horizon issues following the Second Sight interim report. I was not ever
tasked to update them regularly in any way about this. I do recall on occasion
that PSNI officers may approach me to seek further information about Horizon
issues in cases they were dealing with, but this was much later on, particularly
following release of the BBC Panaroma documentary in 2015 (for example,
see my email chain with Constable Alan Gordon at [POL00333558] in July
2016 — I deal with this chain in further detail below).
59.1 am unsure if there were any specific requests made of POL by PSNI for
evidence, expert or otherwise, attesting to the operation in the Horizon system
and how this was resolved.
60.1 am not aware of Cartwright King’s role in relation to reviewing cases in
Northern Ireland. I can see from [POL00326019] that I email Martin Smyth
details about my case load in Northern Ireland, following a request for this by
him. However, I was not involved in any wider role of instructing Cartwright
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62.
63.
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King or setting out the ambit of their role so I don’t know any further detail
about this.
.Iam not sure if MTB Solicitors reviewed any Northern Ireland cases in light of
Second Sight’s interim report, or if they were ever instructed to do this. I have
set out what I believe MTB Solicitors were specifically engaged for earlier in
this statement.
As far as I am aware, it was not usual for POL to have direct dealings with
PPSNI. In terms on myself, I would usually liaise with PSNI investigating
officers in Police Liaison cases, who would then onward liaise with PPSNI. As
already mentioned above, there was one occasion where a PPSNI
representative contacted me directly in the case of Andrea Gourley (see
[POL00333600)). I have also had direct contact with PPSNI earlier this year,
but this concerned a compensation order which came to POL. I think that POL
legal representative had direct dealings with PPSNI in matters which were not
Police Liaison cases I did not have any regular contact with them.
I have been asked to review [POL00333541] (an email update I have sent to
Helen Dickinson in respect of the Drumantree case on 3 November 2013) and
to comment on how PPSNI were made of the Horizon integrity issues raised
in this matter. From reading this email update, it appears that I had spoken
with PSNI Detective Constable Mary Campbell, who must have been the
Investigating Officer dealing with this case. My interpretation of this email
update is that Mary Campbell informed the PPSNI of any integrity issues
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being raised by the defense, and had told me she had done so.
64.1 do not believe I was ever made aware of the advices of Simon Clarke dated
15 July 2013 [WITN06740105] and 2 August 2013 [POL00006799] and I do
not know who these advices were distributed to. I also do not believe that
anyone communicated any views to me taken by POL in relation to such
advices. As far as I am aware, the first time that I have seen and read these
advices was when they were provide to me with the Request. I do however
recall receiving training from Simon Clarke on the topic of Disclosure, which
particularly concentrated on the need to retain documents. I cannot recall
exactly when but this would have been early on in my career.
65.1 am not aware if any action was taken by POL as a result of Simon Clarkes’
advice in respect of prosecutions in Northern Ireland.
66.As far as I am aware, Gareth Jenkins did not produce any expert evidence in
respect of any Norther Ireland prosecutions.
67.1 have reviewed the following documents:
i. [POL00333552] (06/06/2016) Post Office and PSNI emails re Mossley
PO - SPM _ - pleaded not guilty and trial commencing April 2016;
attaching POL Horizon letter.
ii. I [POL00333553] (01/06/2016) Post Office letter re disclosure for PPS in
light of BBC Panorama programme.
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iii. I [POL00333554] (20/06/2016) PSNI email to PO re Mossley PO (Liza
Coleman) case- re what issues Horizon's defects will cause for the
case.
iv. [POL00333555] (22/06/2016) Email chain from Simon Hutchinson to
Alan Gordon RE: Mossley Post Office
v. [POL00333558] (06/07/2016) Post Office and PSNI emails re Mossley
PO (Liza Coleman) case - PO confident in Horizon's integrity.
vi. [POL00333565] (17/01/2017) PSNI email to PO re Dumintree PO -
seeking report on Horizon glitches and whether discrepancies were
reported in the branch before 2014.
vii. I [POL00333569] (21/02/2017) Post Office and PSNI emails re
Dumantree PO - postmaster pleaded guilty to fraud by false
representation and false accounting.
viii. I [POL00248785] (21/03/2017) Email from Mark Raymond to Rodric
Williams and Jane MacLeod
ix. [POL00333575] (06/04/2017) Email chain from Mandy Campbell to
Simon Hutchinson RE: Drumantee Post Office
x. [POL00248682] (19/04/2017) Email from Mark Raymond to Rodric
Williams, CC Simon I Hutchinson and Helen Dickinson re: FW: Horizon
Issues- Strangford case
xi. [POL00333584] (04/10/2019) Email chain from Simon Hutchinson to
Paula Mcgale RE: Cabragh Investigation
xii. I [POL00293025] (28/01/2020) Email chain between Nick Vamos and
Ben Beabey cc: Rodric Williams and others re: Legal
privilege/confidential - POL criminal matters - Cabragh and Howard
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Street [PP-DOCS.FID119697]
68. I note in the email chain at [POL00333558], Constable Alan Gordon (PSNI)
wrote to me on 1 July 2016 that “...prosecutors feel they are in the dark
regarding this, bearing in mind the standard of proof required then further
clarification is needed”. I do not know why prosecutors felt that they had been
left in the dark and I do not know what was done to seek the clarification which
was considered necessary nor what further steps were taken by PPSNI. I also
do not think I hold any further documents or correspondence with the PPSNI
in relation to this to assist the Inquiry further. From looking at the email chains
at [POL00333552], [POL00333554] and [POL00333555] it looks like I sent
over the generic LEA letter setting out POL’s position on Horizon issues
signed off by Amy Quick at [POL00333553] to Constable Alan Gordon and
asked him to provide it to the PPSNI in relation to the case involving Mossley
Post Office. As a result, it looked like the PPSNI wanted to seek further
clarification on Horizon issues. The responses that I provide to address this
query in the email chain at [POL00333558] repeats the message being
delivered to Security Managers by Senior Management within POL Security
about POL’s stance on Horizon issues and the Horizon system. I can see that
my emails to Constable Alan Gordon don't explicitly state what the specific
Horizon issues are, and the generic LEA letter I asked him to pass to PPSNI
doesn't either. As such, perhaps prosecutors felt they were left in the dark
because they didn’t have clarity on what the alleged flaws or defects
specifically were. From my recollection, I don’t believe that I ever understood
or knew myself what the specific technical issues being alleged were.
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69.1 have been asked on what basis did I hold and express the belief that I was
“confident with Horizon integrity’ and that Post Office Ltd were “confident in the
integrity of the Horizon system”, in light of the Second Sight reports, Helen
Rose report, and the Simon Clarke advices. Firstly, as mentioned earlier in this
statement, although I knew that Second Sight were engaged by POL, I do not
think I ever actually had sight of those reports or knew about their specific
content. In terms of the Helen Rose Report and Simon Clarke's advice, I do
not believe I had any knowledge of these at all. In light of this, these statements
I made would not have been based on any reports. Rather, I believe that they
simply reflect the message being delivered to Security Mangers by Senior
Management within POL Security during Team briefings. This was also the
message I remember receiving during a briefing in Birmingham from Paula
Vennels.
70.As far as I can recall, I have never attended Court as a POL witness for the
PPSNI, whether in the Strangford case or otherwise. In an email chain at
[POL00248682] it is indicated that I was summonsed to attend Crown Court
in relation to the Strangford case, but I do not think this went ahead. I can also
see from this email chain that I was seeking advice from my Team Leader,
Helen Dickinson, in relation to having a business legal response, should
Horizon Issues be raised by the defence in court. It appears that she and
Mark Raymond (Head of Security Operations) took my query to Rodric
Williams in POL Legal to seek further advice. I think this illustrates further that
any statement I ever made in relation to myself and POL being confident in
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the integrity of Horizon, would have been a reflection of what the agreed
position of the business was, as communicated to me by more senior
members of POL’s Security Team, who may have sought further input on this
from POL legal.
THE STEPS TAKEN BY THE POST OFFICE AND THE APPROACH OF THE
CROWN OFFICE AND PROCURATOR FISCAL SERVICE (“COPFS”) IN
RELATION TO SCOTTISH CASES FOLLOWING THE PUBLICATION OF
SECOND SIGHT’S INTERIM REPORT ON 8 JULY 2013
71.1 have reviewed the following documents:
i. [POL00127133] (12/10/2013) One to One Meeting Record with Robert
Daily and Line Manager: Simon Hutchinson
ii, [POL00333579] (p.271) (12/12/2013) Post Office Ltd Rosemary
Stewart Gorbals Post Office-Emails, request for write off
72.1 was not responsible for the Scotland Region as a Security Manager, as this
was Robert Daily's region. In light of this I do not feel able to provide any
detailed account of the steps taken by POL and the approach of the COPFS
in relation to Scottish cases following the publication of Second Sight’s interim
report on 8 July 2013.
73.1 have no awareness of when COPFS was first made aware of Horizon issues
with the potential to impact upon prosecutions, nor what COPFS was told and
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by who.
74.1 do not know what cohort of Scottish cases were reviewed in light of the
interim Second Sight report. I appreciate within the meeting record of the one-
to-one I held with Robert Dailey on 12 October 2013 (see [POL00127133])
there is mention of case reviews, but I cannot recall discussing this with
Robert at all. Whilst I would have line managed Robert Daley in my short time
as a Team Leader, I believe that Suzanne Winters took more of a lead with
supporting him in his role. As previously mentioned, my role as a Team
Leader was more focused on Physical Security, and I would rely on Suzanne
for assistance in relation to investigation matters.
75.1 cannot recall giving any advice to Robert Daley in relation to the integrity of
Horizon data in the prosecutions in Scotland. If I did give such advice, it would
have been whatever messages were being relayed to me in Team briefings
by Senior Management within POL Security.
76.1 do not know what role BTO Solicitors had in relation to reviewing Scottish
cases. I can only rely on the one-to-one meeting document at
[POL00127133], which states that Robert Daley, in full consultation with
Jarnail Singh, “secured the services of Brechin Tindall Oatts to advise on all
casework within Scotland. Advising BTO and Crown Office Procurator Fiscal
(COPFS) over cases previously submitted in view of the Second Sight report”.
Any discussions around these services would have been dealt with by senior
management and so I do not feel able to comment on why they were
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engaged.
77.1 do not know if BTO Solicitors, or Laura Irvine from that firm, were ever made
aware of the Second Sight Investigation or their reports.
PROSECUTION OF PETER DAMIAN MCCARTAN
78.1 have reviewed the following documents:
i) [POL00141654] (22/11/2013) Record of taped interview - Peter
Damian McCartan — SW was a perfectionist.
ii) [POL00325844] (12/05/2014) Email form Ernie Waterworth to
Jarnail Singh, Martin Smith CC'd to Lesley Jennings RE;FW:
prepared statement
iii) [POL00326019] (23/03/2015) Email from Simon I Hutchinson to
Martin Smyth, Lucky Thandi and Helen Dickinson RE: Case File
Governance Northern Ireland AA
iv) [POL00326065] (14/04/2015) Letter from Ernie Waterworth to Mr
John Scott re: Peter Damian McCartan
v) [POL00326064] (19/05/2015) Email from Rob King to John M Scott
and cc'd Simon I Hutchinson and Martin Smith re: BALLYNAFEIGH
- MTBRef:1040590004 Post Office v Damian McCartan
vi) [POL00274689] (pp. 4-5) (29/05/2015) Email from Post Office
Security to Denis Reid, Amy Quirk, Andy Hayward and others
(Case closure Ballynafeigh)
vil) I [POL00165675] (01/06/2015) Email from Dave Posnett to Post
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80.
vil)
ix)
x)
xi)
xii)
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Office Security and Helen Dickinson re: Case closure Ballynafeigh.
[POL00132405] (17/06/2015) Subpostmaster Debt Claims.
Checklist of documents to be provided by former agent debt team
(Chesterfield) to External lawyers (Bond Pearce & Beachcroft) (in
particular Case closure Ballynafeigh dated 09/06/2015)
[POL00274689] (p.1) (28/07/2015) POL FAD File RE: Ballynafeigh
Post Office Branch (Letter from Simon Hutchinson to Peter
McCartan) — my closure letter to Damian
[POL00274689] (p.55) (11/06/2018) POL FAD File RE:
Ballynafeigh Post Office Branch (email from Peter McCartan to
Simon Hutchinson)
[POL00112224] (10/05/2019) Email from Ben Beabey to Josh
Harris cc Ben Beabey re: Draft Email Re Ballynafeigh - civil
recovery case of Peter Damian McCartan former PMR at Northern
Irish branch Ballynafeigh 168704
[POL00112259] (17/05/2019) Email chai from Ben Beabey to
Larissa Bayliss, re Agent Debt Matter - Mr Damian McCartan and
Ballynafeigh
I could not recollect all the details of the prosecution of Peter Damian
McCartan, nor what my specific involvement was in the case, until I reviewed
the documents mentioned in paragraph 79 above. From these documents I
can see that this was a POL internal Investigation in Northern Ireland and
not a police liaison case, and it was initiated just prior to me joining POL.
Suzanne Winters was the Lead Investigator in this case, but it was
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81.
82.
83.
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eventually passed over to my caseload when Suzanne left POL in 2014 and
then I was involved thereafter. I also assisted with bringing the case to a
close.
I can see that the investigation related to a cash shortage of £45,555.22 in
the office accounts at the Ballynafeigh Post Office Branch in Belfast, which
had been identified at an audit on Thursday 03 January 2013.
It appears that I first became involved in this case when a second interview
under caution was conducted with Mr McCarten on 22 November 2013. A
record of this interview is at [POL00141654]. I attended as a Second
Investigator to assist Suzanne as Lead Investigator. I believe it was POL’s
standard procedure to have 2 Security Managers present in an interview.
My role in the interview would have been to help Suzanne set up, and also
ask any further questions of Mr McCarten that I thought might help with
gaining clarity on matters during the course of the interview. I can see that I
did ask Mr McCarten some questions towards the end of this interview, but
from reviewing the transcript I believe I asked these questions purely for my
own benefit to get clarification on matters. At this stage in my POL career I
was still very new to POL investigations and this interview was still a learning
experience for me.
Other than sitting in as the Second Investigator in the interview with Mr
McCarten on 22 November 2013, I do not think I had any further involvement
in the initial investigation stages. I may have made a statement for the case
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84.
85.
86.
87.
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file following me sitting in the second interview, but I do not know for certain.
By the time the case was passed to me when Suzanne left, the case was at
the prosecution stage.
I could not recall from memory any allegations made by Peter McCartan
relating to the reliability of the Horizon IT system. I note that it is indicated in
various documents listed in paragraph 79 above that Mr McCarten asked
his union representative following the second interview whether he should
raise the horizon issue now, and he was advised not to at that stage. I cannot
recall this, but if I had witnessed this myself, it would probably be confirmed
in any witness statement I completed for the case file, put together by
Suzanne as part of her investigation.
I_am not sure who authorized the prosecution of Peter McCartan, or who
made the charging decision in this case. I suspect it would have been John
Scott (Head of Security) in both instances, but in liaison with POL Legal
teams.
I do not know if any Horizon data (in particular ARQ logs) were requested
from Fujitsu in this case. I can remember Suzanne Winters would request
Horizon data in cases, but I am not sure whether she did here, or if she did,
whether it was ARQ logs. As far as I am aware, I did not request any Horizon
data, including ARQ logs, in this case after it was passed to me to manage.
As Lead Investigator, I believe that Suzanne Winters would have been the
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88.
89.
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disclosure officer in this case. I don’t think I had any role in disclosure in this
case at any point. I should flag that although Suzanne’s caseload was
passed to me when she left, they were all completed and my role was simply
to manage the outcome of them. I cannot recall having any involvement in
disclosure.
I do not believe at the interview on 22 November 2013 (or at any time
thereafter), that I had any concerns about the integrity of Horizon. As
previously explained in this statement, the message I recollect being
conveyed to Security Mangers was that the Horizon system was robust and
there was nothing to be concerned about.
Whilst the case closure form at [POL00165675] states I attended, I do not
remember attending a meeting with John Scott, Rob King and Ernie
Waterworth on 2 April 2015 in Belfast. If I did attend, I have no recollection
of what was discussed before the following decision was made: “regarding
the unresolved Horizon issue concerning any prosecution in this case....
[dJue to Human Rights (ECHR) issues surrounding the potential delay to trial
it has been recommended to close the case at this time.” It is likely that I
may have assisted with setting up this meeting, given that the case had been
passed to me following Suzanne Winters leaving POL. However, I do not
think I would have played any active part in the discussions had or decision
making that took place- rather, I believe this would have been a meeting
between a POL lawyer (Ernie Waterworth) and two senior POL security
managers (John Scott and Rob King) to decide a way forward for the case.
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90.
91.
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From my review of pages 24 and 25 of [POL00132405] (an email update from
myself to Dawn Colclough in POL’s debt recovery team) it appears that my
understanding as to why Mr McCartan’s case was closed on the ground of
“Human Rights (ECHR) issues surrounding the potential delay to trial”, was
as follows: Ernie Waterworth’s advice to POL was that a Horizon subject
matter expert would need to address and resolve the Horizon issues being
raised by Mr McCarten, before the case could proceed to a trail. However,
the identification of an appropriate expert by POL and any report they could
provide to deal with this was not forth coming. I do vaguely recall that POL
had previously lined up a University Professor from England to be their
Horizon subject matter expert, but this didn’t materialize and I was not
involved in any discussions around experts. I can see that Ernie Waterworth
had stated it could take a further 6 to 9 months before a specialist report from
a Horizon expert would be available, by which point the case had already
been running for over 2 years. His advice seemed to be that it would a breach
of Mr McCartan’s human rights (particularly Article 6 of ECHR, a right to a fair
trial) to impose such further delays to his trail. This was because Article 6
ECHR includes the right to have a public hearing within a reasonable time .
I have been asked to confirm what my understanding was when Ernie
Waterworth mentioned that a “specialist report would be needed as the
“Horizon issue remains unresolved”, and what my understanding was on the
need to obtain a “specialist report” on Horizon. I believe that my personal
understanding would have simply been that a report was needed by someone
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92.
93.
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who was an expert on the Horizon IT system so that during the trial POL could
effectively respond to and clarify any points being raised by the Defence in
respect of any alleged Horizon integrity issues. My recollection was that there
was always an expert who spoke to Horizon issues from Fujitsu.
I don’t think that Ernie Waterworth’s comment that it may take “a further six to
nine months before a specialist report will be available’ caused me to have
any concerns about the integrity of Horizon data. As previously mentioned in
this statement, the message I recall being delivered to Security Managers is
that Horizon was robust and that there was nothing to be concerned about.
Looking back, I think I would have probably just thought that lawyers would
be looking into matters when Horizon integrity issues were mentioned by the
Defence in cases, and unless I was explicitly informed directly by those
lawyers or through Senior Management within POL Security that serious
problems existed, I wouldn’t have suspected there was anything to be
concerned about.
I don’t recall having any concerns when POL continued to enforce the
judgment in default against Mr McCarten in 2018 after he had two serious car
crashes. Nevertheless I did feel great empathy towards him and his
circumstances.
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EXPERT EVIDENCE ABOUT THE HORIZON SYSTEM IN NORTHERNIRELAND
94. As faras I am aware, I do not think that POL instructed any experts to provide
evidence or testimony relating to the Horizon IT system or the reliability of
information extracted from it, in Northern Ireland. I am not entirely sure why
this was not considered important. One potential reason could be that, as far
as I can recall, the majority of prosecutions brought in Northern Ireland were
not based solely on Horizon data. There was other relevant evidence being
relied on in order to pursue a prosecution, with the primary evidence being
ARQ data and admissions either during the audit or at interviews under
caution.
95. I have no knowledge as to whether PPSNI was ever made aware of the
advices of Simon Clarke dated 15 July 2013 ([WITN06740105]) and 2 August
2013 ([POL00006799)). As explained earlier in this statement, I do not think
I even had any previous knowledge myself of the Simon Clarke advices until
they were provided to me with the Request.
“LEA” LETTER
96. I have reviewed the following documents:
i) [POL00322903] (09/12/2015) Email from Christopher G Knight to
Andrew Wise re: FW: Confidential - Horizon Notification
ii) [POL00322904] (09/12/2015) DRAFT RELEASE TO CPS —
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il)
iv)
v)
vi)
vii)
viii)
ix)
x)
xi)
xi)
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[POL00333548] (11/12/2015) Letter from Post Office to XXX RE;
Disclosure for CPS
[POL00294584] (28/01/2016) Post Office Security Operations I
nvestigationGovernance Meeting Action Points
[POL00333553] (01/06/2016) Post Office letter re disclosure for
PPS in light of BBC Panorama programme
[POL00333578] (30/05/2017) 30/05/2017 Letter from Mark
Raymond RE: Disclosure for CPS
[POL00334091] (04/10/2019) Disclosure for CPS
[POL00043066] (08/10/2019) Email chain from Simon Hutchinson
to Ben Beabey, Helen Dickinson, Mark Raymond and others re
Confidential FW: Solicitors Enquiry -
Pond Park Investigation - legal privilege / confidential / do notshare
[POL00043157] (21/10/2019) Email chain between Simon
Hutchinson, Ben Beabey, Helen Dickinson and others RE: Update
Letter to Prosecutors on Horizon - Legal Privilede/confidential / do
not share
[POL00333601] (22/10/2019) Letter from Post Office to Public
Prosecution Service (Belfast) RE: Andrea Gourley
[POL00333600] (23/10/2019) Email from McGalie Cathy to Simon
I Hutchinson CC'd Thomas Ross RE;OFFICIAL-SENSITIVE
[CRIMINAL JUSTICE PARTNERS]: RE: RE: Andrea Gourley -
Case Ref No; 988883 [OFFICIAL]
[POL00333601] (22/10/2019) Letter from Post Office to Public
Prosecution Service (Belfast) RE: Andrea Gourley
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xiii) I [POL00292987] (28/01/2020) Email chain between Christopher G
Knight, Ben Beabey and Mark Dinsdale cc: Mark Raymond and
others re: CoH Spreadsheet - legal privilege/confidential/do not
share this email
xiv) [POL00293011] (28/01/2020) Email from Ben Beabey to Eamon
McCarthy-Keen, Nick Vamos c.c. Rodric Williams
97. I believe that “LEA” stands for “Law Enforcement Agency”, which is an
overarching term for the PSNI, PPSNI, CPS, Police and COPFS. To confirm,
“LEA Letter’ was the description given to the letters which Security
Managers were instructed to send out to Law Enforcement Agencies, as I
have described in paragraphs 54 and 55 of this statement.
98. I think the purpose of the LEA letters was to formally lay out POL’s message
to the PSNI, PPSNI, CPS, Police and COPFS in relation to Horizon Integrity
issues, as questions around this were in the public domain following the
2015 BBC Panorama programme and because in some prosecutions
challenges, were being raised by defence teams about this.
99. I have been asked to confirm whether I considered there was an urgency in
sending out “LEA” letters to the prosecution authorities in Northern Ireland
and Scotland in each case, following Helen Dickinson's instructions on 9
December 2015 (see [POL00322903)). Firstly, I would like to clarify that I
did not send any LEA letters out in respect of cases in Scotland. I believe
this would have been Robert Daley's responsibility as Scotland was his
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region. In terms of Northern Ireland, I can’t recall feeling any urgency as
such in respect of any cases, but from a professional stand point, I would
always deal with a task swiftly if I was instructed to do something.
100. I have considered [POL00294584] (28/01/2016) Post Office Security
Operations Investigation Governance Meeting Action Points, where it states,
“[oJngoing circulation and recording of disclosure notice to inform LEA’s
about the potential Horizon issues with prosecutions. All submissions to be
reported to Casework to be logged on a central register including date sent,
to whom, any response, etc”
101. I can see that I did not attend this Post Office Security Operations
Investigation Governance Meeting. I can only assume that the purpose of
ongoing circulation and recording of who LEA letters were sent to was just
to ensure that POL’s position of Horizon Integrity issue was formally
communicated to the relevant Law Enforcement Agencies in all cases, and
that POL could keep track of this.
102. I do not know for certain who kept the central register which included a
record of date sent, to whom, any response, etc. Perhaps this was kept by
the POL Security Admin Team, which I believe was made up of Chris Knight,
Andrew Wise and some other assistants.
103. I am not aware of which public authorities that LEA letters were sent to in
Scotland, as I was not responsible for sending them out in Scotland. In
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Northern Ireland, I sent LEA letters to the PSNI, with a request for them to
be sent on to the PPSNI in cases.
104. I recall that the criteria for sending out LEA letters in Northern Ireland was
just to send them out to all PSNI Investigation Officers working on POL
cases.
105. I do not know when public prosecution authorities in Northern Ireland and
Scotland were made aware of the specific Horizon issues referred to in these
“LEA’ letters.
106. I am not entirely sure who drafted the earlier LEA letters signed off by Amy
Quirk and Mark Raymond (see [POL00333548], [PO00333553] and
[POL00333578]). I note that when Helen Dickinson instructed us to send
LEA letters out on 9 December 2015, she also stated in her email that Rodric
Williams in POL Legal was our contact, and we were to address any legal
queries with POL legal in the first instance. Perhaps this means that Rodric
Williams had some involvement in drafting them.
107. In terms of the update letter I was tasked to send out specifically to the PSNI
officer dealing with the case of Andrea Gourley in 2019 (see
[POL00333601]), I can see from the documents provided to me that Ben
Beaby (POL Legal Counsel) informed me that POL Legal were drafting it.
108. I have been asked to explain why the “LEA” letters were sent through 2016,
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2017, 2018 and 2019 (up to October 2019) to the police officers, but not to
the prosecution authorities (e.g. PPSNI in Northern Ireland or the Crown
Office in Scotland) on an institutional level. I am not able to comment in
respect of Scotland, but in terms of Northern Ireland, it would be usual
practice for a Security Manager to send the LEA letters to the relevant
investigating officers on POL cases in the PSNI, who would then send them
on to the PPSNI if the case had been submitted to them. I do not believe
there was a protocol in POL which would have required me to go directly to
the PPSNI in police liaison cases. It would not make sense to me to bypass
a PSNI officer when something needed to be passed on to the PPSNI,
because in police liaison cases the PSNI Investigating officer was the
individual responsible for the investigation.
109. I do not know why it was not until late 2019 that “the December 2019 letter
went generically to CPS Area Offices”. I also do not know why there were
changes in sending the letters to “CPS Area Offices” instead of the police
(see [POL00293011]). This would likely have been a decision discussed and
made at a much more senior level to me in POL Security, and I would not
have been involved in making those decisions. To be clear, I had no dealings
with the CPS or the police here as this was in England and Wales.
110. I do not recall having any concerns when PPSNI decided not to disclose the
letter entitled “Post Office Group Litigation — Horizon” to the Defence? (see
[POL00333600] and [POL00333601)). It is clear that Cathy McGaile from
PPSNI had carried out her own review of POL’s response and was satisfied
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that the case against Andrea Gourley could proceed as the Horizon
unreliability issues related to the old Horizon system (Horizon Legacy) and
was therefore not relevant in this case because the IT system used by POL
at the time of the alleged offences was Horizon Online. There is also more
context here, in that the case of Andrea Gourley was not one where the
prosecution was relying solely on Horizon data. I believe this is why Cathy
McGaile states the following in here email at [POL00333600): “/ expect that
the Defence are aware of the issues with the preceding IT system in an
event and that they may be asking these questions in order to provide a
distraction from the evidence presented in this case against their client”
GENERAL
111. As explained earlier in this statement, although I was aware of some cases
where an accused SPM had stated that there were issues with the Horizon
system, the message I always recall being delivered to Security Managers
from Senior Management within POL’s Security Team, as well as in briefings
from Paula Vennels, was that Horizon was a robust system and there was no
need to be concerned about its integrity. I relied on this message and I don’t
think I ever thought there was a need to scrutinise it, especially when it was
being delivered from CEO level down. In light of this, I do not think it ever
crossed my mind that a challenge to the integrity of Horizon in one case may
be relevant to other ongoing or future cases.
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112. I have followed the Inquiry and feel a lot of anger about what has come out
from it and the fact the legal process was abused with disclosure not being
properly following which has resulted in miscarriages of justice.
113. Other than the matters set out in this statement, there are no other matters
that I would like to bring to the attention of the Inquiry Chair.
STATEMENT OF TRUTH
I believe the contents of this statement to be true.
Dated: 5'" December 2024
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INDEX TO THE FIRST WITNESS STATEMENT OF SIMON HUTCHINSON
No
URN
Document Description
Control Number
POL00333552
Post Office and PSNI emails
re Mossley PO - SPM
pleaded not guilty and trial
commencing April 2016;
attaching POL Horizon letter.
POL-0180992
POL00333532
Email from Simon I
Hutchinson To: Elaine
McCabe RE: 1.NOT
PROTECTIVELY MARKED-
All Networks: Post Office
Fraud Rita O Reilly - Derrylin
POL-0180971
POL00333555
Email chain from Simon
Hutchinson to Alan Gordon
RE: Mossley Post Office
POL-0180995
POL00333558
Post Office and PSNI emails
re Mossley PO (Liza
Coleman) case - PO
confident in Horizon's
integrity.
POL-0180998
POL00108203
Summary of Cases
Spreadsheet
POL-0106332
POL00126931
One to One Meeting Record
of Suzanne Winter from
13/4/13 - 30/5/13
POL-0134071
POL00105032
One to One Meeting Record
— Simon Hutchinson
POL-0080664
POL00165675
Email from Dave Posnett to
Post Office Security and
Helen Dickinson re: Case
closure Ballnafeigh
POL-0161031
POL00029744
Interim Report into alleged
problems with the Horizon
System
POL-0026226
10.
POL00029849
Initial Complaint Review
Mediation Scheme: Second
Sight Briefing Report — Part
Two
POL-0026331
11.
POL00294584
Post Office Security
Operations Investigation
Governance Meeting Action
Points
POL-0170663
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12.
POL00126931
One to One Meeting Record
of Suzanne Winter from
13/4/13 — 30/5/13
POL-0134071
13.
POL00127136
One to One Meeting Record
between Suzanne Winter and
Simon Hutchinson (Line
Manager) for period of
02/08/2013-17/09/2013
POL-0133361
14.
POL00326019
Email from Simon I
Hutchinson to Martin Smyth,
Lucky Thandi and Helen
Dickinson RE: Case File
Governance Northern Ireland
AA
POL-0173122
15.
POL00146123
Email from Communications
Team to Richard Poulton,
Richard R Weaver & Ors RE:
Strike Contingency Plan —
Tuesday 27 August
POL-BSFF-0005250
16.
POL00164215
Email chain from Kevin Ryan
to Simon Hutchinson RE:
Agreed Scottish Prosecution
process
POL-0159571
17.
POL00126976
Email from Dave Posnett to
Aftab Ali, Andrew Daley,
Andrew S McCabe and
others re: RMG MOU-
Memorandum of
Understanding and Royal
Mail Group Joint
Investigation Protocols
POL-0134075
18.
POL00299454
Email from John M Scott to
Angela Van-Den-Bogerd
CC’d Rob King, Andy
Hayward and others
RE;Horizon & Investigations
POL-BSFF-0137504
19.
POL00333497
Email chain from Simon I
Hutchinson to Andy hayward
RE: Scottish protocol and
emails from the Crown
POL-0180934
20.
POL00127133
One to One Meeting Record
with Robert Daily and Line
Manager: Simon Hutchinson
POL-0133358
21.
POL00127134
One to One Meeting Record
with Suzanne Winter and
Line Manager Simon
Hutchinson from 20/10/2013
— 05/12/2013
POL-0133359
22.
POL00105134
One to One meeting Record
between Simon Hutchinson
POL-0080762
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and Helen Dickinson —
Review of 2014
23.
POL00105145
Performance Development
Review for Robert Daily (POL
Security Manager) 2013/14
year end PDR
POL-0080770
24.
POL00326121
Email from Moss Lane to
Martin Smyth. RE: Horizon
Statement
POL-0173144
25.
POL00333536
Email from Elaine McCabe to
Simon I Hutchinson re 1.NOT
PROTECTIVELY MARKED-
All Networks: RE: Derrylin
Post Office Investigation
POL-0180975
26.
POL00333541
Email from Simon
Hutchinson to Helen
Dickinson RE: Drumantee
POL-0180980
27.
POL00029744
Interim Report into alleged
problems with the Horizon
System
POL-0026226
28.
POL00043066
Email chain from Simon
Hutchinson to Ben Beabey,
Helen Dickinson, mark
Raymond and others re
Confidential FW: Solicitors
Enquiry — Pond Park
Investigation — legal privilege
/ confidential / do not share
POL-0039548
29.
POL00333578
Letter from Mark Raymond
RE: Disclosure for CPS
POL-0181018
30.
POL00333553
Post Office Letter re
disclosure for PPS in light of
BBC Panorama Programme
POL-0180993
31.
POL00333548
Letter from Post Office to
XXX RE; Disclosure for CPS
POL-0180987
32.
POL00322903
Email from Christopher G
Knight to Andrew Wise re:
FW: Confidential — Horizon
Notification
POL-BSFF-0160953
33.
POL00043157
Email chain between Simon
Hutchinson to Ben Beabey,
Helen Dickinson, and others
RE: Update Letter to
Prosecutors on Horizon —
Legal Privilede/confidential /
do not share
POL-0039639
34.
POL00333601
Letter from Post Office to
Public Prosecution Service
(Belfast) RE: Andrea Gourley
POL-0181041
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35.
POL00333600
Email from McGalie Cathy to
Simon I Hutchinson CC’d
Thomas Ross RE;OFFICIAL-
SENSITIVE [CRIMINAL
JUSTICE PARTNERS]: RE:
RE: Andrea Gourley — Case
Ref No; 988883 [OFFICIAL]
POL-0181040
36.
POL00333558
Post Office and PSNI emails
re Mossley PO (Liza
Coleman) case — PO
confident in Horizon’s
integrity.
POL-0180998
37.
WITN06740105
Appellants’ note for directions
hearing on 18/12/20 in
Hamilton & Ors — disclosure
of Clarke advice
WITNO6740105
38.
POL00006799
Advice on Disclosure and the
Duty to Record and Retain
Material
POL-0017591
39.
POL00333554
PSNI email to PO re Mossley
PO (Liza Coleman) case — re
what issues Horizon’s
defects will cause for the
case.
POL-0180994
40.
POL00333555
Email chain from Simon
Hutchinson to Alan Gordon
RE: Mossley Post Office
POL-0180995
a1,
POL00333565
PSNI email to PO re
Dumintree PO — seeking
report on Horizon glitches
and whether discrepancies
were reported in the branch
before 2014.
POL-0181005
42.
POL00333569
Post Office and PSNI emails
re Dumantree PO —
postmaster pleaded guilty to
fraud by false representation
and false accounting.
POL-0181009
43.
POL00248785
Email from Mark Raymond to
Rodric Williams & Jane
MacLeod RE: Drumantee
Post Office
POL-BSFF-0086848
44,
POL00333575
Email chain from Mandy
Campbell to Simon
Hutchinson RE: Drumantee
Post Office
POL-0181015
45.
POL00248682
Email from Mark Raymond to
Rodric Williams, CC Simon I
Hutchinson and Helen
POL-BSFF-0086745
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WITN11820100
WITN11820100
Dickinson re: FW: Horizon
Issues — Strangford case
46.
POL00333584
Email chain from Simon
Hutchinson to Paula Mcgale
RE: Cabragh Investigation
POL-0181024
47.
POL00293025
Email chain between Nick
Vamos and Ben Beabey cc:
Rodric Williams and others
re: Legal
privilege/confidential - POL
criminal matters - Cabragh
and Howard Street [PP-
DOCS.FID119697]
POL-BSFF-0131088
48.
POL00333579
Post Office Ltd Rosemary
Stewart Gorbals Post Office-
Emails,request for write off
POL-0181019
49.
POL00141654
Record of taped interview —
Peter Damian McCartan
POL-0143038
50.
POL00325844
Email form Ernie Waterworth
to Jarnail Signh, Martin Smith
CC’d to Lesley Jennings
RE;FW; prepared statement
POL-0172990
51.
POL00326065
Letter from Ernie Waterworth
to Mr John Scott re: Peter
Damian McCartan
POL-0173272
52.
POL00326064
Email from Rob King to John
M Scott and cc’d Simon I
Hutchinson and Martin Smith
re: BALLYNAFEIGH —
MTBRef:1040590004 Post
Office v Damian McCartan
POL-0173271
53.
POL00274689
POL FAD File RE:
Ballynafeigh Post Office
Branch
POL-BSFF-0112752
54.
POL00132405
Subpostmaster Debt Claims.
Checklist of documents to be
provided by former agent
debt team (Chesterfield) to
External lawyers (Bond
Pearce & Beachcroft)
POL-0121676
55.
POL00112224
Email from Ben Beabey to
Josh Harris cc Ben Beabey
re: Draft Email Re
Ballynafeigh — civil recovery
case of Peter Damian
McCartan former PMR at
Northern Irish branch
Ballynafeigh 168704 —
whether POL should accept
reduced recovery amount
POL-0109768
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WITN11820100
56.
POL00112259
Email chai from Ben Beabey
to Larissa Bayliss, re Agent
Debt Matter — Mr Damian
McCartan and Ballynafeigh
POL-0109791
57.
POL00322904
Draft Release to CPS
POL-BSFF-0160954
58.
POL00334091
Letter from Mark Raymond to
Sir / Madam RE: Disclosure
for CPS
POL-0181367
59.
POL00292987
Email chain between
Christopher G Knight, Ben
Beabey and Mark Dinsdale
cc: Mark Raymond and
others re: CoH Spreadsheet
— legal
privilege/confidential/do not
share this email
POL-BSFF-0131074
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