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Witness name: Kevin Rennie
Statement No.: WITN12000100
Dated: 17.03.2025
THE POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF KEVIN RENNIE ON BEHALF OF POST
OFFICE LIMITED IN THE POST OFFICE HORIZON IT INQUIRY
1 I, Kevin Rennie, of 100 Wood Street, London, EC2V 7ER, will say as follows:
INTRODUCTION
2 I am the Inquiry Director at Post Office Limited (“Post Office”). I am giving this
witness statement in a corporate capacity on behalf of Post Office, in response
to the Rule 9 request dated 14 February 2025 ("R9(67)"). I am aware of the
steps Post Office has taken to respond to this R9(67); as such, I am the
appropriate person to give this witness statement on behalf of Post Office.
3 I have aimed to include within this witness statement evidence relating to
R9(67) insofar as the relevant facts are within my own knowledge. The facts in
this witness statement are true, complete and accurate to the best of my
knowledge and belief. Where my knowledge and belief, as set out in this
witness statement, has been informed by another person or by documents that
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I have reviewed, I acknowledge that person or those documents. I have been
assisted in preparing this witness statement by Burges Salmon LLP and
Fieldfisher LLP (together "BSFf"), who act on behalf of Post Office in the Post
Office Horizon IT Inquiry (the “Inquiry"). I have also been aided by KPMG for
technical analysis.
BACKGROUND
4 The Inquiry previously issued a notice pursuant to section 21(2)(a) and (b) of
the Inquiries Act 2005 dated 29 November 2024, and varied on 4 December
2024 (“s.21(36)”), which required that (amongst other things) Post Office
provide all notices sent by the Criminal Cases Review Commission to Post
Office up to 1 January 2020, pursuant to section 17 of the Criminal Appeal Act
1998 (“Section 17 Notices”), together with an index of the same. Post Office
produced these documents to the Inquiry ("PROD161") and provided an
accompanying index on 13 December 2024 (the “First Index”). The Inquiry’s
R9(67) provides a revised version of this index which includes a new column of
unique reference numbers ("URNs") and other amendments shown in yellow
highlight (the “Second Index”). Post Office is asked to check the accuracy of
the information in the First Index against the information highlighted in the
Second Index and to exhibit an Updated Index to this statement.
UPDATED INDEX
5 Firstly, I understand that in the Second Index the Inquiry has (as indicated in
yellow highlight) replaced the Bates Numbers of 19 documents. As these are
substantively the same documents to those referred to in the First Index, Post
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Office is content for the Inquiry to refer to its preferred versions. We have used
the Inquiry's preferred Bates Numbers in the Updated Index exhibited to this
statement (POL00462740).
6 Secondly, upon further consideration of both the First and Second Indices, Post
Office identified five documents within the First Index where the Bates Number
does not correspond to the document description. These are at: rows 33, 43,
44, 47 and 48.: Post Office instructed KPMG to consider the matter further and,
as a result, KPMG identified a minor technical issue with PROD161. In
summary, I understand that when finalising PROD161 KPMG made a change
to the metadata in the s.21(36) coding field and then re-ran the production. This
caused the order of the documents in PROD161 to slightly shift, resulting in five
documents having different Bates Numbers. Unfortunately, due to a manual
error by KPMG, the Bates Numbers on BSFf's Relativity platform were not
reconciled with the Bates Numbers in the PROD161 export. To draft the First
Index BSFf relied upon the Bates Numbers on Relativity which recorded
incorrect Bates Numbers for the five documents.
7 I set out in a table below the five affected documents:
Line Incorrect Bates Number (as I Correct Bates Number (as in the
in the First Index) production export received by
the Inquiry)
‘In the Second Index, the Inquiry has highlighted data in each of these rows for Post Office's attention, save for Row 33
? By way of example, the Section 17 Notice at line number ‘44’ referenced in the First Index with Bates Number ‘POLBSFF-161-
0000008’, was instead produced to the Inquiry under Bates Number ‘POL-BSFF-161-0000007’.
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44 POL-BSFF-161-0000008 POL-BSFF-161-0000007
47 POL-BSFF-161-0000009 POL-BSFF-161-0000008
48 POL-BSFF-161-0000010 POL-BSFF-161-0000009
33 POL-BSFF-161-0000011 POL-BSFF-161-0000010
43 POL-BSFF-161-0000007 POL-BSFF-161-0000011
8 The Bates Numbers for the above five documents have been corrected in the
Updated Index (POL00462740). Further, KPMG has conducted checks across
all BSFf productions and confirmed that this Bates Number mismatch was due
to an isolated manual error and has not occurred in any other BSFf production.
For the avoidance of doubt, Post Office confirms that this was a numbering
issue only and the correct documents were produced to the Inquiry.
Statement of truth
I believe the content of this statement to be true.
Date: 17 March 2025
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Index to the First Witness Statement of Kevin Rennie
No.
URN
Document Description
Control Number
POL00462740
Updated Index for Section 17
Notices
POL-BSFF-163-
0000001
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