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Witness Name: Benjamin Andrew Foat
Statement No.: 0200
Dated: 21 June 2023
THE POST OFFICE HORIZON IT INQUIRY
Second Witness Statement of Benjamin Andrew Foat on behalf of Post Office
Limited in the Post Office Horizon IT Inquiry
1. 1, Benjamin Andrew Foat, of 100 Wood Street, London EC2V 7AN, say as
follows:
Introduction
2. The facts in this witness statement are true, complete and accurate to the best
of my knowledge and belief. Where I refer to my beliefs, these beliefs, and my
knowledge contained within this statement, are informed by Herbert Smith
Freehills LLP (“HSF”) and Peters & Peters Solicitors LLP (“P&P”), who are both
instructed by Post Office Limited ("POL"), and colleagues at POL, including in
particular POL's Central Investigations Unit ("CIU"). I have been assisted in
preparing this witness statement by P&P and HSF, who act on behalf of POL
in the Post Office Horizon IT Inquiry (the "Inquiry").
3. This witness statement has been prepared in response to a request made by
the Inquiry pursuant to Rule 9 of the Inquiry Rules 2006, dated 5 June 2022
(the "Rule 9 Request") ("Request No. 44").
4. Where I refer to specific documents in this statement, copies of those
documents are exhibited to this statement (as set out in the index below).
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5. I am POL's Group General Counsel. This is my Second Witness Statement to
the Inquiry.! I am the appropriate person to give this witness statement on
behalf of POL, particularly in the light of the fact that:
a. I made the First, Second, Third and Fourth Interim Disclosure
Statements (to which I refer in this statement), and as explained in the
above Interim Disclosure Statements, I am ultimately responsible for
instructing HSF and P&P in respect of POL's response to each of the
requests made to POL by the Inquiry under Rule 9 Requests (or under
Section 21 of the Inquiries Act 2005, as the case may be), based on the
instructions that I and POL's in-house lawyers, under the supervision of
POL's Inquiry Director, receive from our colleagues in the business and
ultimately the POL Inquiry executive steering committee and Board; and
b. POL's CIU is responsible for conducting the internal investigation that I
refer to in this statement, and CIU ultimately reports to me in my role as
Group General Counsel.
Background to the documents that are subject of Request No. 44
6. On 10 April 2023, POL received the following request for information pursuant
to the Freedom of Information Act 2000 from Eleanor Shaikh
(FO12023/00205):2
Please can you disclose documents which detail the Quality and
Compliance Assurance processes for Investigations which were
implemented by the Post Office Security Team 2008-2011. Please
‘ The First Foat Statement was prepared in response to a Notice dated 16 March 2023 issued by the
Inquiry pursuant to Section 21 of the Inquiries Act 2005.
2 https://www.whatdotheyknow.com/request/post_office_investigations compl#incoming-2308208
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include reports which evidence any improvement in the quality and
professionalism of investigation standards eg Investigations Standards
Audits.
7. As part of the process for considering FOI2023/00205, POL identified eight
documents, including the documents referred to in paragraphs 1 and 3 of
Request No. 44. These documents were previously used by POL's security and
investigation team ("Security Team") in investigations and the assessment of
compliance with case file standards. These eight documents were disclosed in
response to FOI2023/00205 on 19 May 2023.
8. On 27 May 2023, POL issued the following public statement:>
Post Office does not tolerate racism in any shape or form. The language
used in this historic document is completely abhorrent and condemned
by today’s Post Office. We fully support investigations into Post Office’s
past wrong doings and believe the Horizon IT Inquiry will help ensure
today’s Post Office has the confidence of its Postmasters and the
communities it supports.
9. On 30 May 2023, POL produced to the Inquiry the eight documents that were
disclosed in response to FOI2023/00205 (together with two other documents in
the same document family, namely a cover email and excel spreadsheet which
were identified by P&P following the disclosure by POL in response to
FOI2023/00205) to the Inquiry pursuant to Rule 9 Request No. 14 dated 15
June 2022 ("Production 164").
3 https://corporate.postoffice.co.uk/en/media-centre#/news/post-office-statement-release-of-historical-
document-via-recent-freedom-of-information-request-467497
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10. Production 164 included a document with file name "Appendix 6 — Identification
Codes" and production number POL-0115834 [Inquiry URN POL00115674]
(which is referred to in paragraph 3 of Request No. 44) (together with earlier
versions of the same document, "Appendix 6") which contained seven identity
codes that described racial origins. Appendix 6 contained racially offensive and
outdated terminology.
Request for information on productions
11. The first three paragraphs of Request No. 44 request information about POL's
previous productions in response to Rule 9 Requests. These are addressed in
turn in this section. The information in this section has been provided to me by
HSF and P&P who were involved in the relevant productions to the Inquiry.
The Rule 9 No. 11 and Rule 9 No. 14 productions
12. Paragraph 1 of Request No. 44 requests the following information:
1. Please explain why the version of the Guide to the Preparation
and Layout of Investigation Case Files apparently dated from
2008 (disclosed under FOIA 2023 0025 and reported in the Times
on 27 May 2023) wasn't disclosed under Rule 9(11) or Rule 9(14)
until 30 May 2023?
13. I have assumed that question 1 of Request No. 44 seeks clarification in respect
of the entire suite of eight documents disclosed under FOIA 2023/0025 and
produced to the Inquiry in Production 164.
14. I am informed by HSF and P&P that copies of two of the eight responsive
documents in Production 164 were previously disclosed to the Inquiry:
15.
16.
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a. Appendix 3 is a guide to the preparation of suspect offender reports. A
copy was disclosed to the Inquiry on 14 April 2022 with the document
reference: POL-0027763 [Inquiry URN POL00038452], and a near final
version of it was disclosed to the Inquiry on 22 August 2022 with the
document reference: POL-0080841 [Inquiry URN POL00105216]; and
b. Appendix 7 is a circular advising Security Team managers on changes
in the requirements for summarising taped recorded interviews. A copy
was disclosed to the Inquiry on 2 December 2022 with the document
reference: POL-0094323 [Inquiry URN POL00094200].
I explain in the following paragraphs, based on the information provided to me
by HSF and P&P, why the other six documents disclosed under FOIA
2023/0025 were not disclosed under Rule 9 No. 11 or Rule 9 No. 14 until 30
May 2023. In doing so, I also explain why versions of Appendix 3 and Appendix
7 were disclosed, but the other appendices (that appear to belong to the same
suite of documents) were not disclosed.
Requests No. 11 and No. 14 sought POL policy and procedure documents
relating to POL’s conduct of criminal investigations and prosecutions. To
identify such documents, P&P and HSF ran search terms across a Relativity
database which I will refer to as the CCRC database. Those searches were
designed to identify responsive documents in a database that contains millions
of documents. The CCRC database is hosted on Relativity by POL's
eDiscovery provider, KPMG, together with other databases that hold POL
documents. The CCRC database contains materials collated for the purposes
of the criminal appeals. Searches were and are run across this database for the
purposes of disclosure in accordance with POL’s post-conviction disclosure
17.
18.
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obligations, to conduct document reviews, and to identify and produce
documents to the Inquiry (amongst other purposes).
POL-0027763 [Inquiry URN POL00038452] (Appendix 3) was responsive to the
search terms run by HSF across the CCRC database for the purpose of
Request No. 11. The other appendices were not produced for the following
reasons:
a. Copies of Appendices 1, 2, 4 and 5 (disclosed in response to FOIA
2023/0025) belonged to the same "family of documents" as POL-
0027763 [inquiry URN POL00038452] (i.e., appendices 1 to 5 were all
contained in a zip, along with other documents, that was attached to an
email dated 7 March 2013 that was sent by a POL Security Team
manager). Although they belonged to the same “family of documents",
Appendices 1, 2, 4 and 5 were not produced at the same time as POL-
0027763 [inquiry URN POL00038452] because they were not
responsive to the search terms and so they were not reviewed for the
purpose of responding to Request No. 11; and
b. Appendices 6, 7 and 8 were not responsive to the search terms and were
not within the "family of documents" and it was not apparent at the time
that they belonged to the suite of documents.
POL-0080841 [Inquiry URN POL00105216] (an earlier near final version of
Appendix 3) was responsive to the search terms run for P&P across the CCRC.
database. None of the other documents disclosed in response to FOIA
2023/0025 were responsive to these search terms. POL-0080841 [Inquiry URN
POLO00105216] was a standalone version of the document and did not have
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any family documents. Copies of Appendix 3 exist in duplicate, and near
duplicate form in the CCRC database. Unlike POL-0080841 [Inquiry URN
POLO00105216], some of those duplicate versions of Appendix 3 have family
documents (including the other appendices disclosed in response to FOIA
2023/0025). The duplicate versions of Appendix 3 were tagged as “Duplicate”
by POL's eDiscovery provider, KPMG, and so they were considered
unnecessary to review.
19. POL-0094323 [Inquiry URN POL00094200] (Appendix 7) was identified as a
standalone document through a review of hardcopy materials and it was not
apprehended at that time that it belonged to a suite of documents.
Documents previously produced to the Inquiry
20. Paragraph 2 of Request No. 44 requests the following information:
2. Please explain the following in detail.
(i) whether the identification codes contained in the version
that was disclosed under FOIA 20230025 were contained
in a full version of the documents disclosed as POL-
0080434 [Inquiry URN POL00104794], POL-0027763 and
POL-0080841 [inquiry URN POL00105216]; and
(ii) If they were, why they were not included in the disclosure.
21. I have assumed that question 2 of Request No. 44 seeks clarification as to
whether POL-0080434 [Inquiry URN POL00104794], POL-0027763 [Inquiry
URN POL00038452], and/or POL-0080841 [Inquiry URN POL00105216]
formed part of a suite of documents that included Appendix 6.
22. 1am informed by HSF and P&P of the following:
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a. POL-0027763 [Inquiry URN POL00038452] and POL-0080841 [Inquiry
URN POL00105216] (versions of Appendix 3) each contain a reference
to "Identification Code" on page 5 but do not set out the identification
codes referred to in Appendix 6. The circumstances by which these
documents were reviewed and produced to the Inquiry is set out in my
response to question one above. Although there were duplicate versions
of Appendix 3 that included Appendix 6 as a family document, Appendix
6 is not a family document of either POL-0027763 [Inquiry URN
POL00038452] or POL-0080841 [Inquiry URN POL00105216], and it
was not apprehended at the time that these documents were produced
that they might form part of a suite of documents that included Appendix
6. This was only later apprehended and led to the response to FOIA
20230025 and Production 164; and
b. POL-0080434 [Inquiry URN POL00104794] does not contain any
reference to identification codes and does not have any family
documents. It therefore does not appear to form part of a suite of
documents that includes Appendix 6.
The production of Appendix 6 to the Inquiry
23.
24.
Paragraph 3 of Request No. 44 requests the following information:
3. Why was POL-0115834 provided to the Inquiry for the first time
on 30 May 2023 and why was no explanation provided for its late
production?
With reference to paragraphs 16 to 19 above, the reasons why Appendix 6 was
not identified and disclosed to the Inquiry at an earlier point in time is because
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Appendix 6 was not responsive to the search terms applied by HSF and P&P
to the CCRC database. In addition, I note that Appendix 6 was not a family
document of POL-0027763 [Inquiry URN POL00038452], POL-0080841
[Inquiry URN POL00105216] or POL-0094323 [Inquiry URN POL00094200]
which were disclosed to the Inquiry.
25. _HSF provided to the Inquiry a cover letter with the 30 May 2023 production. I
am informed by HSF that this letter did not contain the explanation that is set
out above because, as at 30 May 2023, the reasons why these documents had
not been previously identified and disclosed were still being investigated, and it
was considered preferable to produce the documents without any further delay.
No discourtesy was intended in disclosing the documents without any
explanation as to why they had not been disclosed any earlier.
POL's fact-finding investigation into Appendix 6 and related issues
The Inquiry's requests relating to Appendix 6 and related issues
26. Paragraphs 4 and 5 of Request No. 44 request the following information:
4. Please set out, in detail, the product of POL’s investigation into
the origins of the identification codes contained within that
document. This should include, but not be limited to, the following
insofar as it is possible to ascertain the information:
(i) when and why the term “N* Types” first appeared in any
guidance documents;
(ii) who was responsible for its inclusion; and
(iii) I when the term was removed, why and who was involved
in its removal.
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5. If and insofar as the Post Office are aware of any similar language
being used in guidance, policy or equivalent documents relevant
to the Inquiry’s terms of reference, to provide further detail.
The establishment of Project May
27. Following the identification of Appendix 6 as part of responding to
FOI2023/00205, and in recognition of the very serious nature of the content and
the issues arising from the document, POL took steps to set up a fact-finding
investigation to look into the key concerns arising from the document and the
racially offensive terms contained in it. The fact-find was commissioned on 30
May 2023 and is referred to as Project May. POL has instructed external
counsel, Jeremy Scott-Joynt of Outer Temple Chambers, to assist and advise
on, and oversee, Project May.
28. The CIU is responsible for conducting sensitive or complex internal
investigations within POL and it has been tasked with the conduct of Project
May. The information about Project May set out in this statement has been
provided to me by CIU, including John Bartlett, the Head of CIU, and other
members of his team.
29. A group has been established that is made up of representatives from various
teams within POL to ensure Project May and all related action is coordinated.
POL is in the process of formalising an arrangement with a non-profit
organisation, ETICA Global, to act as an independent monitor to Project May.
30. I set out in this section of my statement:
a. Project May's current terms of reference;
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b. A summary of the investigative steps Project May has already taken as
at the date of the deadline for responding to Request No. 44 (i.e., 13
June 2023) and its preliminary findings; and
c. The further investigative steps that are in train.
31. I Project May remains ongoing. It is due to report its first set of findings by 23
June 2023. The preliminary findings set out in my statement are based on the
information that has been gathered to date. They are therefore subject to the
further investigative steps that are in train and may be subject to revision/
change.
Project May's terms of reference
32. The period under examination in Project May currently starts from 2012 when
POL was established as a separate entity from the Royal Mail Group ("RMG")
through to the present. It may be necessary to look back before 2012 and, in
this regard, to liaise with RMG as appropriate.
33. In relation to Appendix 6, Project May's terms of reference are:
a. To determine how Appendix 6 came to be created and/or how this
description of identification codes was present in POL’s document
library;
b. To determine when and why the term “N* Types” first appeared in any
guidance documents, who was responsible for its inclusion, and when
the term was removed, why and who was involved in its removal;
c. To determine if the descriptors used in the document originated from the
Home Office or other department of State and if so when they were in
use in public services; and
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d. To understand, if the descriptors were once provided by the State, why
changes in the language used by external public sector investigators
during the relevant period to describe racial identification codes were not
reflected in POL’s investigation team document library.
34. In relation to the use of identity codes (such as those contained in Appendix 6),
Project May's terms of reference are:
a. To determine whether any similar language is being, or has been, used
in guidance, policy or equivalent documents relevant to the terms of
reference of the Post Office Horizon IT Inquiry;
b. To establish a time period during which identity codes were present
and/or used from the establishment of POL in 2012 to date;
c. To establish whether the identity codes were actively used on POL
investigation or prosecution documentation and to what purpose;
d. To identify the rationale for using identity codes if they were used;
e. To identify any legislative purpose or requirements for the use of
identification codes e.g., under Section 95 Criminal Justice Act 1991;
f. To establish whether there were any additional investigative or
prosecution documents used by POL during the relevant time that
contained race identification codes; and
g. To establish what training on the use of identification codes was provided
to POL investigation and prosecution staff.
35. Depending on the findings of the investigation, the terms of reference may be
amended/expanded as appropriate, and the timeframe for reporting findings will
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be updated accordingly. In formulating the terms of reference set out above,
the CIU has had specific regard to paragraphs 4 and 5 of Request No. 44 to
ensure that these requests fall within scope.
Investigative steps and preliminary findings
36. Initial investigative meetings with current POL employees who were former
Security Team members suggest that RMG possessed a version of Appendix
6 prior to the formation of POL. Following separation from RMG, it is believed
that RMG transferred investigation documents to the newly established POL
Security Team for use in investigations and the assessment of compliance with
case file standards by the Security Team members.
37. The review of emails to date (see below at paragraph 44) tends to corroborate
the hypothesis that Appendix 6 was (along with seven other documents)
imported from RMG and then disseminated to members of the investigation
compliance team. However, this is not yet clear and is still being tested. Of the
eight documents in question, seven were rebranded as POL documents, while
Appendix 6 remained as a plain Word document.
38. Unlike most POL forms, Appendix 6 does not contain reference to the version
of the document that was used which can usually be found at the bottom of
each page for forms in use at the time.
39. Several of the other descriptors used in Appendix 6 were also outdated, even
archaic, as at 2012 e.g., "Siamese" instead of "Thai". This tends to indicate that
the content of Appendix 6 is archaic in nature.
40. Email searches have so far identified 23 occasions on which Appendix 6 was
sent as an attachment within the Security Team between 2012 and May 2019.
13
41.
42.
43.
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Appendix 6 was never formally updated or replaced. Appendix 6 was stored in
the Security Team archive on SharePoint.
Open-source searches reveal that identification codes used by law
enforcement may have historically contained the derogatory/offensive term
"n****q" but modem-day identification codes use non-offensive wording and
contain additional detail. Enquiries with the College of Policing and three police
forces have thus far failed to identify the terminology that was used to describe
identification codes between 2008 and 2011. Identification codes are used by
law enforcement agencies, amongst other things, to create and conduct Police
National Computer record checks. To support these aims, all law enforcement
and prosecuting authorities provide an identification code with investigative and
prosecuting papers. I am informed by CIU that, as a prosecuting authority, it is
possible that POL was required to provide identification codes for persons
charged and summoned to the Magistrates Court so as to enable the entry of
data relating to these persons into the Police National Computer.
Whilst the fact-finding carried out to date has confirmed that numerical
identification codes appear in case files, there is currently no evidence that
suggests that Appendix 6 itself or the language therein was in fact used by POL.
Initial investigative meetings with current POL employees who were former
Security Team members (yet to be independently corroborated) indicate that
Security Team members were advised as to applicable identification codes by
Security Team colleagues, that Security Team members built up knowledge as
to the applicability of the numerical codes, and when in doubt about what
ethnicity a given numeric code referred to, carried out searches on the internet.
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44. An examination of emails obtained from the historic Security Team’s archive
has been carried out. The following documents have been identified and are
exhibited to this statement:
a. An email dated 23 May 20114 from Dave Posnett (Security Team) to the
Security Team attached a zip file of Appendices (including Appendix 6)
which were being re-branded from RMG to POL to be used in the
assessment or compiling of Security Team investigation case files (the
"Case File Appendices"). An initial examination of this version of
Appendix 6, which as noted above in paragraph 37, was an unbranded
word document rather than a form, suggests it was created in 2003 and
“modified” in 2011. It is not yet clear what (if any) modification was made.
The other Case File Appendices were forms to be used in assessing or
compiling case files.
b. An email dated 31 August 2011 from Andrew Wise (Security Team)
forwarding the Case File Appendices to Michael Stanway (Security
Team).>
c. An email dated 30 October 2012 from Andrew Wise sending the Case
File Appendices to Security Team members.® The email indicates that
the Security Team members were to use the Case File Appendices,
including presumably Appendix 6, in the preparation of their case files.
41am informed by CIU that a native version of this email has not so far been collected, but an email
which forwarded this email (which is referred to in paragraph 44.b) has been identified and is
exhibited to this statement.
5 URN: POL00118096
6 URN: POLO0118110
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d. An email dated 28 July 2016 from Andrew Wise to Helen Dickinson
(Security Team) attached 4 investigation standards documents and
Appendix 6.” The metadata of this version of Appendix 6 suggests it was
amended in 2013.
e. An email dated 23 May 2019 from Helen Dickinson to Andrew Wise
attached a zip file of 14 documents which included investigation
standards documents and training material, including Appendix 6.8 The
email indicates that these documents had been, or were to be, shared
with Womble Bond Dickinson (UK) LLP ("WBD"), POL’s then external
legal advisors, possibly for the purpose of conducting a review of the
Security Team’s investigation documentation.
Further investigative steps in train
45. The following further investigative steps are in train as part of Project May:
a. The collection and review of documents including (but not limited to)
emails and other material held by the Security Team on their SharePoint
site.
b. Enquiries with the College of Policing and three police forces are
ongoing to understand the descriptors that were used across time.
c. Further investigative meetings will be held with current POL employees,
including those who were former Security Team members, as
necessary.
7 URN: POL00118129
8 URN: POL00118137
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d. Contact will be made with former POL employees.
e. Engagement with RMG in order to ascertain the use of identity codes
within RMG, and in particular to seek to establish any knowledge and
use of the derogatory term "n*****d" — I have been informed by CIU that
RMG is conducting searches of its systems for this and the other
offensive terms contained in Appendix 6 with a view to understanding if
they were used within RMG.
f. An external, forensic examination of available metadata of Appendix 6.
External counsel will manage this process using an appropriately
accredited/experienced digital forensic expert.
g. With reference to paragraph 44.e, engagement with WBD in relation to
the exercise it undertook and whether it identified and reported Appendix
6 as part of that exercise or otherwise.
46. POL is treating this matter with the utmost seriousness and importance. POL
will of course provide an update to the Inquiry on the findings of Project May at
appropriate stages throughout the investigation, and at its conclusion.
Other work being undertaken
47. POL intends to instruct an external ethics organisation to use historic
prosecution and charge data to assist in considering whether the use of identity
codes may have influenced charging or disposal decisions.
48. Separately, in the context of their work for POL on the Inquiry, HSF and P&P
have been instructed by POL's Inquiry team to undertake searches across the
documents and materials they have collected as part of their work in relation to
the Inquiry and the criminal appeals process. It is POL's intention to offer to
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produce any documents that are identified to the Inquiry and also to share them
with CIU.
POL's approach to Diversity, Equality, and Inclusion ("DE&I") today
49. POL takes DE&I very seriously. I am aware (including from information provided
to me by POL colleagues) that DE&I is embedded into POL's organisation and
is reflected in:
a. POL's management structure, where the role of Diversity and Inclusion
Manager has existed since at least 2017;
b. POL's policies, including POL's current Equality, Diversity and Inclusion
Policy, which became effective from 19 November 2018, and POL's
current Dignity at Work Policy which became effective from 1 October
2018. Since the end of 2022, POL has had an Inclusion Playbook for
people managers which was accompanied by inclusion training open to
all employees. POL also recently made changes to its Code of Business
Conduct and reaffirmed its commitment to DE&! — this makes clear that
"Post Office does not tolerate harassment based on the grounds of race,
ethnic or national origin"; and
c. POL's culture, not least through POL's current COMPLEXIONS group
(first established in 2018 under the name POEM), which champions and
advocates DE&l throughout our organisation. POL has also run various
training sessions, including unconscious bias and diversity training
(particularly in the area of recruitment) and awareness training
workshops called ‘Let's Talk About Race’.
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50. It is in that context that I firmly reiterate POL's public statement referred to in
paragraph 8. POL is actively considering, as a matter of urgency, what further
steps need to be taken to address the issues and concerns arising from this
matter.
Statement of truth
I believe the content of this statement to be true.
Benjamin Andrew Foat
Dated: 21 June 2023
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Index to the Second Witness Statement of Benjamin Andrew Foat
No.
URN
Document Description
Control Number
POL00115674
Appendix 6 — Identification Codes
POL-0115834
POL00038452
Appendix 3 — Guide to the
Preparation and Layout of
Investigation Red Label Case Files —
Offender reports & Discipline reports
POL-0027763
POL00105216
Draft version of Appendix 3 — Guide
to the Preparation and Layout of
Investigation Red Label Case Files —
Offender reports & Discipline reports
POL-0080841
POL00094200
Circular advising Security Team
managers on changes in the
requirements for summarising taped
recorded interviews
POL-0094323
POL00104794
Guide to the Preparation and Layout
of Investigation Case Files
POL-0080434
POL00118096
Email dated 31 August 2011 from
Andrew Wise to Michael Stanway
forwarding the Case File Appendices
VIS00012685
POL00118110
Email dated 30 October 2012 from
Andrew Wise to Security Team
members attaching the Case File
Appendices
VIS00012699
POL00118129
Email dated 28 July 2016 from
Andrew Wise to Helen Dickinson
attaching the Security Operations
Team Compliance documents
VIS00012718
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POL00118137
Email dated 23 May 2019 from Helen
Dickinson to Andrew Wise attaching
investigation standards documents
and training materials
VIS00012726
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Witness Name: Benjamin Andrew Foat
Statement No.: 0200
Dated: 21 June 2023
THE POST OFFICE
HORIZON IT INQUIRY
SECOND WITNESS STATEMENT OF
BENJAMIN ANDREW FOAT
Herbert Smith Freehills LLP
Exchange House
Primrose Street
London
EC2A 2EG
Ref: 2066/31048180
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