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Witness Name: Alan Bates
Statement No.: WITN00050100
Dated: 29 February 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ALAN
BATES
I, ALAN BATES of I
SAY AS FOLLOWS:
INTRODUCTION
I held the position of Subpostmaster (“SPM”) of the Craig-y-Don Post Office, 21
Queens Road, Craig-y-Don, Llandudno, North Wales, LL30 1AZ, FAD code
4616146 (the “Branch’”) from 31 March 1998 to 5 November 2003.
2. This Witness Statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 Request dated 19 December
2023 (the “Request’).
3. I have been asked by the Inquiry to respond to a number of questions. Those
questions, my responses and any relevant documents, including those which the
Inquiry asked me to refer to are detailed within this Witness Statement.
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4. My solicitors, Freeths LLP, have assisted me in the drafting of this statement.
This being said, I can confirm that this statement is written in my own words and
has been approved by myself as being complete and accurate.
Question 1 - Please set out your professional background, including before and
after your time as a sub- postmaster (“SPM”).
5. My professional background, prior to becoming SPM of the Branch, involved a
career in the heritage and leisure project management sector over a 12-year
period. I developed experience in the Electronic Point of Sale systems (“EPOS”),
the development of site-specific business software and the provision of staff IT
training. Following the cessation of my time as a SPM, I have not returned to a
full-time career as I have dedicated years to campaigning for justice for SPMs.
Question 2 - Please summarise the positions or roles you have had in relation
to the campaign for, amongst other things, access to justice and financial
redress for SPMs relating to the Horizon IT System. Please note that more
detailed questions are asked below. It is intended for the response to this
paragraph to be an introductory summary.
6. Prior to and since my termination from the Branch, I have spent the last 23 years
campaigning to expose the truth, and justice, not just for myself, but for the entire
group of wrongly treated/wrongly convicted SPMs. I have dedicated this period
of my life to this cause which, sadly, has been necessary since Post Office
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Limited (“POL”) has spent this entire period denying, lying, defending, and
attempting to discredit and silence me and the group of SPMs that the Justice
For Subpostmasters Alliance (“JFSA”) represents. I also became a member of
the ‘Working Group’ on behalf of the JFSA which oversaw the running of the
Initial Complaint Review & Mediation Scheme set up at the request of Members
of Parliament in relation to this matter in 2012.
TIME AS A SPM
Question 3 - Please describe the background to your appointment as an SPM.
Please set out the process by which you became an SPM.
7. I decided that I wanted to work as an SPM as I had thought that it would bring
secure employment, based upon the fact a Post Office branch provides a
community service and was an established brand in the community. I was also
encouraged by the fact that I could run a secondary business, such as a retail
shop, alongside the Branch.
8. From around 1997, my partner, Ms Suzanne Sercombe, and I began searching
for an available branch. We learned that the Craig-y-Don Branch was available,
and I was particularly interested because it was being sold together with a
haberdashery and general retail business, which was known as ‘The Wool Post’,
and had substantial residential accommodation above it. I knew the location to
be a large community in which a branch was likely to remain an essential service.
9. Suzanne and I arranged for a visit to the Branch via lan Free, a Business Transfer
Agent, who had been instructed by the former owners, Mr and Mrs Savage. The
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10.
11.
12.
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fundamentals of the business were reasonably clear from the accounts and what
we were able to observe from our visits, there being nothing particularly
complicated about the nature of the business. During our visits, Mr Savage
broadly spoke positively and in general terms about his experience of running a
Post Office branch.
Mr and Mrs Savage agreed to sell the Branch to us (subject to me being
appointed SPM), and on 15 December 1997, Suzanne and I entered into a
Memorandum of Agreement [WITN00050101] for the purchase of the premises
and business at the price of £175,000 and paid the required deposit of £8,000.
This was a major investment for Suzanne and me. It was a large amount of
money, but we were willing to invest it in this way because we were sure there
was a large measure of security in running a POL branch, which was, to our
mind, a relatively safe investment upon which we would likely receive a return.
Having entered into the Memorandum of Agreement, I then looked to making a
formal application to POL for the SPM position. I recall that the process in this
respect involved the current or outgoing SPM tendering his resignation, at which
point POL would then accept applications for the role.
I am unable to recall the precise date, but shortly after I submitted my application,
I was invited to interview, which took place at POL’s regional office in Bangor. I
was interviewed by Mr Jones, and Suzanne also attended, as this was to be a
joint business venture.
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13. On 31 March 1998, I received a letter from Mr Jones confirming that my
application had been successful [POL00041768]. I signed and returned this on
the same date.
Question 4 - Please set out your recollection of the installation of the Horizon IT
System in the Post Office you managed.
14. In October 2000 POL introduced Horizon at my Branch and imposed upon me a
requirement that I use it to record transactions at the Branch and to submit
Branch accounts. To the best of my recollection, Horizon was installed from 2
October 2000. I remember that the Branch was closed around this time to allow
for this.
15. I did not have any involvement in discussions about the introduction of Horizon,
and I had no choice but to accept and accommodate this variation. Obviously,
this was also a huge change in how I operated the Branch, as many of the
previous processes that I had been trained on and had operated at the Branch
were made obsolete not only for me, but also for my assistants.
Question 5 - What were your initial impressions of the Horizon IT System?
16. When Horizon was introduced, given my background with EPOS systems, to
which I refer above, I regarded the introduction of Horizon, at first, as a positive
innovation. However, I did not expect there to be any apparent discrepancies
shown on the system that I was unable to identify the cause of and resolve, either
by myself or with support or information from POL. Certainly, I did not expect
discrepancies to occur for which POL would try to hold me liable without the
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cause being investigated and established. To that point, I had been preparing
accounts manually, using the Capture system.
Question 6 —- Please describe your experience of the following matters whilst
you were a SPM:
a. Your day-to-day working relationship with the Post Office (“POL”) and your
avenues of communication with the company.
17. From around 13 December 2000 onwards POL stated that my Branch accounts
showed a discrepancy of £1,182.81 (which was later revised to £1,041.86).
Therefore, almost immediately after the installation of Horizon, I began
experiencing significant issues with the system.
18. I had been led to believe that SPMs were working in partnership with POL, and
if POL wanted me to measure up to the standards they required, I expected them
to do the same for me. However, over time, it soon became evident that the
‘partnership’ was very one sided, and it really was a question of “you will do as
you are told and if you don’t like it, you can’t complain and there is no redress on
this, and you just get on and keep your mouth closed” — that's how it works.
19. Inaletterdated 13 February 2002 [POL00004590], that I wrote to Glenn Chester
to explain to him, as I had explained to my previous line managers, why I
continued to roll through ‘losses’ and ‘gains’ from week to week without resetting
the system, which in my view would have meant I was accepting the figures the
Horizon system produced without allowing me full access to check the figures
that my staff and myself had entered. Then, following discussions with Mike
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Wakely the latest of my POL Line Managers (the fifth in 3 years) in early April
2003, he wrote to me on 14 April 2003 [page E1/50/41 of POL00004598] to
‘cease with this current practise of rolling over any losses and gains’. In my
response to him on 16 April 2003 I informed him that this had been the practice
ever since the system had been installed at the office and many POL staff knew
of this. I also explained to him why this way of working was being followed, and
that I had explained the reasons in previous correspondence with POL. Following
further correspondence between POL and myself, on 4 June 2003
[POL00004629] POL threatened to terminate ‘my contract’. Such interaction with
various POL staff members clearly exhibits that my working relationship with POL
was extremely strained and it was rare that any communication with POL ever
benefitted me or gave me the impression that I could trust them to support me.
b. Any training you received in relation to the Horizon IT System.
20. In or around September 2000, POL provided a 1.5-day training course of which
my assistants were permitted to attend the first day. I attended on both days. The
training took place at the Imperial Hotel, Llandudno, and was delivered by a third-
party service provider, Knowledge Pool and was attended by approximately 150
other SPMs and assistants at the same time. The introduction of Horizon and its
effect on SPMs and the operation of their branches, and POL’s requirements as
to the use of Horizon were too vast to be covered adequately or at all in the time
given.
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21.
22.
23.
24.
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The training did not adequately cover how the cause of any discrepancy between
Branch account information shown on Horizon and cash and stock in the Branch
could be investigated or ascertained by SPMs. It also did not inform me that I
would be required to make good any apparent discrepancy in order to be able to
commence any new Cash Account week.
Furthermore, the training did not inform me that I would be required to make good
any apparent discrepancy even if it had not been shown by POL that I had been
at fault or that one of my assistants had been at fault, and/or even if it represented
no economic loss or detriment to POL. It also did not cover how, in practice, POL
would support me when apparent discrepancies arose, investigate them or deal
with any doubt or dispute as to the cause of the same.
Despite my prior experience of EPOS systems, the training provided by POL was
inadequate for the purpose of informing me as to the proper and reliable use
and/or operation of Horizon in the Branch, and enabling me to ascertain the likely
cause of any apparent discrepancy between cash and stock in Branch and the
position as shown on Horizon and ascertaining whether an apparent discrepancy
shown on Horizon was an actual loss and, if so, the likely cause of the same.
In relation to any further training received, on the date of the first weekly balance
of Branch accounts following the introduction of Horizon at the Branch, two of
POL’s Retail Network Managers, one of which was Idris Jones, attended the
Branch. POL’s representatives were no more familiar with Horizon than I was, as
the system was new to them also. If and to the extent POL will say this
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attendance amounted to training, I deny that it was adequate, or that it in any
way addressed the inadequacies of the previous training.
25. On two further occasions, on dates I cannot presently recall, POL provided two
half day support sessions at the Branch, which related to the use and/or
operation of Horizon. This support was provided by POL’s auditor Mr Selwyn
Berry and a Horizon Support Officer, Ms Ki Barnes. This support did not in any
way address the inadequacies of the previous training received.
c. Any support or other advice and assistance that was available to you
concerning the Horizon IT System (including via Horizon Field Support
Officers, contract managers, the Fujitsu helpline or the NBSC).
26. [donot recall any support which fundamentally helped me with any issues.
27. I was first notified about the Post Office Helpline, as opposed to the Fujitisu
Helpline (which I rarely used), in my Appointment Letter dated 30 March 1998
[POL00041768]. It gave the Helpline number and said that this is “the first point
of contact”. The Induction Booklet, which Steve Hughes, my trainer from POL,
gave to me on 8 May 1998, also gave information about the Helpline. The
Induction Booklet described the Helpline as an “excellent service at all outlets”
and explained that Helpline staff would provide “speedy, accurate information
and support to staff, agents, client and the public on all Post Office Counters
enquiries and services’ and would handle “complaints in an efficient and
unbiased manner’.
28. In my experience, none of this happened in practice for me.
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29.
30.
31.
32.
33.
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My understanding was that the Helpline was a service provided by POL as part
and parcel of their investment into the relationship and the support that they were
meant to provide to me. Looking back, I clearly regarded it as such when
complaining to Graham Harbord of POL by letter on 27 September 2001
[POL00004643] about the service I had received.
POL’s Helpline records which have been disclosed to me indicate that between
21 February 2000 and 23 November 2003, my assistants and I made 507 calls
to the Helpline, 85 of which specifically related to Horizon and balancing
problems, 16 were complaints and 106 related to Branch office processes.
I found that the Helpline was frequently unavailable and/or my calls often went
completely unanswered, without any information as to why, or whether the call
would be answered. Also, different Helpline staff would give different answers to
the same queries. The Helpline staff even gave incorrect advice at time, including
by way of illustration, advice given in November 2003 which resulted in an
incorrect entry of £600 relating to foreign currency being wrongly entered on
Horizon.
I was unable to contact the same person who had been handling my enquiry
which wasted time, increased the incidence of inconsistencies in the advice
given, and deprived me and the relevant Helpline operator(s) of the obvious
advantages of following through an issue to its conclusion.
See paragraph 45 below which refers to this.
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34. As for the other support and advice which was available, it was not effective in
supporting me.
d. POL’s approach to dispute resolution when a discrepancy was identified in
branch accounts.
35. I was not willing to put any cash into the Branch to balance the alleged
discrepancy showing after the 13 December 2000 balance as I did not accept
liability for it, given my (then) understanding of Section 12(12) of the SPM
contract. Due to the way that Horizon worked in practice, it was impossible for
me, as SPM, to accurately track and interrogate and understand transactions
that had taken place and, therefore, determine whether an actual discrepancy
had occurred and satisfy myself that it had arisen due to my negligence,
carelessness or error of me or my staff. I therefore asked Gerry Hayes, in my
letter of 19 December 2000 [page E1/50/134 of POL00004598], to advise me
on how to treat the alleged discrepancy showing on the balance and whether I
should roll over the discrepancy. I never received a response to that letter.
36. I corresponded with Gerry further on this issue and he arranged for Selwyn Berry
of POL to attend my branch on 8 June 2001 to assist with the "resolution of
accounting errors". Although I cannot recall the dates, I do remember that Selwyn
Berry and Ki Barnes came to my Branch in relation to this problem on separate
occasions. However, they were not able to access the system in any further detail
than I could, and their visits did not provide any answers.
37. I was not going to let this issue remain unresolved and took it up further in
correspondence with POL throughout the remainder of 2001. I explained, in
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38.
39.
40.
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particular, my concerns that the Horizon reporting was "made so complex and
lacks the ability to interrogate the system when you know the information is
inside" (my letter to Sue Perry dated 7 June 2001).
By a letter from Gerry Hayes dated 16 July 2001 [POL00004586], POL conceded
that "neither the visits from Selwyn Berry and Ki Barnes nor the pension &
allowance checks carried out for the problematic weeks, revealed specific
reasons as to how the resultant loss of £1041.86 initially occurred" but, despite
this, continued to demand my "proposals to now make good the loss" as a matter
of urgency. I corresponded further with POL via my line manager, Glenn Chester,
in early 2002.
Finally, by letter dated 6 March 2002 [WITN00050102] I was notified that "Post
Office ...has decided to take no further action in respect of the loss" at my Branch
and that this will be written off. No reason was given, but I have since seen a
copy of a "Write Off Authority" voucher disclosed by POL which gives the reason
for the write off as "Disputed Horizon Cash Account Shortage".
The letter of 6 March 2002 also said POL had taken time to respond because "...
it has been necessary to formulate a consistent response to all such cases". I
take from this that POL was aware at the time of many such complaints. I also
take from the fact that POL was willing to write off the considerable apparent
discrepancy I had disputed that my complaints were valid, and that POL was
aware that was the case and wished to avoid controversy on this matter, given I
was willing to assert my legal rights.
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41. It was clear to me from this point that there were problems with the Horizon
system. Not only was I unable to access the information that I needed to fully
track transactions, but I also did not trust that the system processed transactions
accurately.
e. The availability and / or quality of support from the NFSP.
42. I spoke to the local Branch Secretary of the Federation of SPMs (the “NFSP”),
Dave Foster, about my concerns and was told that many other SPMs were
experiencing similar issues.
43. The NFSP were the only organisation that POL had decided it would recognise
to ‘represent Subpostmasters’, but the fact that they continually failed to provide
real support for SPMs in Horizon matters was widely known. To the best of my
knowledge, the NFSP has never once supported a SPM in any court case where
issues surrounding the Horizon system have been questioned. In point of fact,
the NFSP has actively supported POL in their Horizon position on many
occasions. I received a letter from Colin Baker dated 13 January 2004
[POL00215384] where he said that he had spoken to POL about all of this, and
he said everything was fine.
44. Within the Common Issues judgment, Fraser J found that:
a. “the NFSP is not an organisation independent of the Post Office...The Post
Office effectively controls the NFSP” paragraph 596, [2019] EWHC 606 (QB)
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Question 7 - Please consider POL00004598 (correspondence provided further
to a subject access request) and POL00107462 (correspondence concerning
shortfalls and termination).
a. Please describe your experience of using the Horizon IT System as an SPM.
45. One of my fundamental concerns when Horizon was introduced, which I clearly
communicated to POL through various letters, was the lack of transparency and
control available to me in reviewing transactional data that I and my staff had
entered. I could not fully access data that I needed to in order to properly track,
and if necessary correct, transactions. My concerns about this first became
evident in December 2000, following a particularly difficult balance. I was
therefore clearly dependent upon POL for this sort of information and, therefore,
in order to ascertain the cause of any apparent discrepancy and whether it was
in fact a real loss.
46. I contacted the Helpline seeking support and help as to why this apparent
variance had occurred. They were unable to assist in any meaningful way. I tried
to investigate the matter myself. I printed various reports from two of my three
counter terminals. I left the third terminal for use to serve customers as we were
very busy in the Branch, with customers queuing out the door.
47. Though I understand that Post Office later moved to monthly balancing, during
my tenure I was required to produce weekly cash accounts, which meant that I
had to conduct a balance on a weekly basis, on a Wednesday. When carrying
out this balance on Wednesday 13 December 2000, the Horizon system showed
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48.
49.
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that there was an unexplained variance of over £6,000 which I eventually tracked
down to Giro deposits.
Using the limited reports, I was able to print, which was a time consuming and
difficult exercise, I ascertained that around £5,000 of the alleged discrepancy
related to Giro items, which had become wrongly duplicated on Horizon. These
reports were in the form of lengthy, multiline, narrow till receipts and were many
metres long, making them difficult to review in any event. At the time, I believed
that a majority of the remaining alleged discrepancy, being £1,182.81, was also
attributable to Giro transactions. However, I was unable to track these potentially
smaller sums in the absence of proper reporting functions on Horizon.
Therefore, far from being within my knowledge, I was unable to ascertain the root
cause of the apparent discrepancy at all. I also called my Retail Network
Manager, Gerry Hayes, the following day to inform him and ensured to follow up
with a letter dated 19 December 2000 [POL00112664_001]. In the absence of a
proper response from POL, I carried over the apparent discrepancy from that
week's cash account to the following week's cash account, by transferring it to a
suspense account, which was visible to POL.
I recall that there had been an overnight software update to the Horizon system
during that cash account week, and at the time I could only think that this process
had been the source of the problem. I concluded that there must have been an
error within the system software due to the number of duplicate entries that had
eventually been found and had been removed. Giro transactions were frequently
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undertaken by all the staff at the Branch and were a simple transaction to
process. The scope of staff error on this was therefore small.
b. Please describe how POL dealt with any discrepancies that arose in your
branch accounts.
51. Please see my comments above in response to this question.
c. Please explain to what data you believed you needed access in order to
determine the cause of discrepancies in the Horizon generated branch
accounts.
52. As detailed in the extensive correspondence with POL, I required access to all
data, even in a read-only format, held on the system in relation to all input by me
and my staff which happened at my Branch. However, in respect of verifying
information regarding those transactions, or the accounts that they ultimately
formed a part of, I could only check transaction logs that were available on
Horizon for limited periods of time or use the limited range of information and
reports I had access to, and which could be printed from Horizon terminals,
comparing those to stock in the Branch. I had no real way of checking information
held in Horizon that came from Post Office itself, or from its clients such as
Camelot or indeed the way in which those had been reconciled with transactions
in the Branch.
d. What response did you receive from the Post Office when raising concerns
about Horizon at this time?
53. Please see my responses above.
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e. Please consider page 22 of POL00004598 and the sentence “The Horizon
system at Craig y Don Post Office has been reviewed and interrogated in
response to your complaints, and the reports from both the Horizon Field
Support team and the NBSC have confirmed there is nothing inherently wrong
with the Horizon system installed at the branch”. What was your view of this
aspect of POL’s response?
54. Whilst the position as stated in the letter is that they had reviewed and
interrogated and concluded that there was nothing ‘inherently wrong with the
Horizon system’, I had seen no evidence of the apparent review and interrogation
that they had claimed to carry out. I was still without the data which I had been
requesting for a number of years. Nor had they discussed their findings with me.
I do not believe that there was any investigation or evidence that the purported
investigation had taken place.
f. What technical IT support had you received in response to your complaints
regarding Horizon?
55. Very little. The Helpline was of no assistance in furthering my understanding of
the causes of apparent discrepancies. The seven calls that I made when having
problems with balancing on 13 December 2000 is but one example.
56. Further, POL were able to communicate directly with Fujitsu and obtain
transactional data and, more generally, any other information on Horizon that
may have been relevant to my Branch or the products/services which I offered. I
had to rely on POL acting as a middleman in this respect and it is choosing
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whether to share any information with me. I still do not know whether POL even
asked Fujitsu about my transactions.
g. Please set out your recollection of the process leading up to and of the
termination of your SPM contract.
57.
58.
By my letter to POL of 13 February 2002 [POL00004590], I expressed my
concerns at POL's suggested approach that weekly balancing be achieved by
either taking money from the Branch or putting it in so that cash and stock
reconcile. My concerns were that it would amount to acceptance of liability for
discrepancies without there being report writing functions to assist me in
ascertaining the cause, and secondly the lack of a record on Horizon of any
shortage or over in a given week. Effectively, what was recorded on Horizon
would not reflect what had happened in real life.
Given these concerns, when I experienced discrepancies, I adopted the practice
of ‘rolling over’ those discrepancies into subsequent accounting periods. I
received a letter from Mike Wakley, my Retail Line Manager at the time, dated
14 April 2003 [page E1/50/41 of POL0004598] regarding that practice. Mike had
not been involved in my previous correspondence with Post Office, to which I
refer above. By his letter, Mike stated that I had to stop rolling over my accounts
and that I had to make good discrepancies without delay. Rather than repeat
myself, I referred him back to my previous correspondence and repeated my
position that it was "totally unreasonable to expect me to accept the liability from
uncheckable data".
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59.
60.
61.
62.
63.
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Mike maintained the position that I now know to be taken by POL in its Losses
and Gains Policy, which was that Section 12(4) and 12(12) required that "in the
event of any losses occurring" I had to make them good without delay. I refer to
his letter to me dated 2 May 2003 [POL00040363]. This is not the understanding
that I had of Section 12.
I set out my position again in my letter dated 15 May 2003 [POL00004618], which
records my understanding of Section 12 at the time. As I refused to concede this
point, POL threatened termination of my appointment (see the letter from Mike
Wakley dated 4 June 2003 [POL00004629]. I refer to my letter in response to
this threat, dated 12 June 2003 [POL00040398].
Prior to contracting I expected this sort of issue to result in POL offering me more
training or support, or at least trying to find out what was going wrong. I did not
expect to be left with these problems, as was in fact the case.
I received a letter from Mike Wakley dated 5 August 2003 [page E1/50/30 of
POL00004598] stating that “in accordance with Section 1, Paragraph 10 of [my]
Contract for Services” POL were issuing me with “three months’ notice of
termination of your Contract for Services”. The letter simply stated that this would
take effect on 5 November 2003 and gave no explanation for the decision to
terminate. I was shocked that POL considered that it had the power under the
terms of my engagement to terminate with no reason or explanation.
When I first applied to be a SPM, I was not aware, nor made aware, that the
contract with POL could be terminated in such a way. If I knew that such a term
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existed, I would have sought legal advice on this before making such a
substantial investment and most likely would decide to steer clear.
h. Please set out your recollection of POL’s pursuit of the £1,407.38 alleged to
be outstanding in the letter of 21 May 2004 (page 21 of POL00107462).
64. Following my termination, POL conducted a closing audit at the Branch on 6
November 2003. My appointment had been terminated and I was no longer in
the Branch, so I was unable to verify the auditors’ findings. Nor did I oversee
them carrying out the audit, as I was not permitted access. POL alleges that the
final cash account showed a discrepancy of £1,227.61. At the time, I recall that I
was expecting the balance to be short by approximately £200, but certainly not
to the value that POL alleged, it was entirely unexplained and impossible for me
to verify.
65. I received a number of letters from POL chasing me for payment for the sum of
£1,407.38. Those letters continued for a number of months following the
termination of my contract by POL. It is not clear why this figure increased from
the £1,227.61 allegedly discovered at the closing audit and again I had no means
of verifying the cause of any of this. POL said that I am responsible for the alleged
discrepancies "under the contract or services" and that my "responsibility for the
losses does not cease when [my] appointment as Sub Postmaster finishes".
66. For all the reasons I have previously explained above, as I understand the
position, the terms of my contract only imposed liability on me where there is
negligence or error on my part. That had not been established and it is not
possible for me to investigate the matter. I therefore did not respond to any of
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POL’s letters, despite their threatening tone. I did not pay this alleged sum to
POL.
67. I certainly never thought that I was responsible for any supposed discrepancies,
regardless of whether they were real or why they had happened. Certainly no
one told me that before I was appointed.
CAMPAIGNING AFTER TERMINATION OF SPM CONTRACT
Question 8 - Save as set out in response to the above, please describe your
work in seeking (a) to expose the failings of the Horizon IT System and (b) to
obtain redress for the SPMs suffered as a result of those failings up to the start
of 2009. In so doing, please address the following issues:
a. The nature or extent of any support you received in this work, and the
adequacy of the same.
b. Any challenges you faced in this work.
c. What strategy or policies you believed POL adopted in response to your
work.
d. Whether you believe that POL or Fujitsu sought or did in fact obstruct your
work.
68. In 2003, having been issued the termination letter and during my 3 months’ notice
period, I set up the www.postofficevictims.org.uk website. I believed I was not
the only SPM in this situation, and I was trying to connect with others to
understand whether their experience was the same as mine.
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69.
70.
71.
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By letter dated 27 August 2003 [POL00040354], POL made threats about using
POL imagery on the website.
Following the receipt of the notification of the termination of my contract by POL,
I wrote to enlist the support of my MP, who at that time was Mrs Betty Williams.
I also wrote to Allen Leighton Chairman of Royal Mail Group. The response from
the Chairman's office was predictably to ignore the content contained within all
the copies of the correspondence that I had sent him (comprising of
correspondence already part of this submission) and then failing to have the real
issues investigated. It was the usual box ticking letter exercise, entirely from
POL’s perspective. However, the string of correspondence to and from my MP
and her notes of dealing with POL reveal the approach and attitude of POL with
my case and their arrogant and dismissive way of dealing with SPMs.
I first wrote to Mrs Williams about my case on 27 October 2003 [WITN00050103],
and in turn she raised it with POL and the Minister. Eventually she received a
letter dated 5 January 2004 [POL00040345] from POL informing her that they
had taken a decision to “review the case in its entirety’. But again, this was
carried out behind closed doors and without bothering to contact me. Further to
that letter, POL wrote to my MP again on 19 January 2004 [POL00040368], after
the ‘review’, in which Richard Barker, POL General Manager, finished his letter
stating, “/t is my view that the best interest of all involved with this matter would
be best served by considering the matter closed”. It was at this point that my MP
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wrote to me to inform me that there was nothing further she could do on my
behalf.
72. Yetthe reality of what actually took place during the ‘review’ only became evident
once I had received the documentation about me in response to a Subject
Access Request I made under the Data Protection Act, that is, unless there was
other documentation that was not included.
73. Throughout all the ensuing correspondence and discussions of my case, not
once did anyone contact me to discuss the issues involved, everything was
carried out behind closed doors without me being offered the opportunity to be
heard. Again, it was a case of POL acting as judge, jury, and executioner in
breach of Articles 6 & 7 of the European Human Rights Act, i.e., by denying me
a fair and impartial hearing and inflicting punishment without access to the law
by use of their financial might.
74. Iwas not aware of Fujitsu doing anything to obstruct me.
Question 9 - Please set out any views you have on the nature and extent of the
support and representation available to SPMs, counter managers and counter
assistants alleged to be responsible for shortfalls shown by the Horizon IT
System through the NFSP and / or the CWU during this period (i.e. to 2009).
75. The CWU were not involved during this period, as I recall. The NFSP, in the letter
from Colin January 200 dated 13 January 2004 to me [POL00215384], stated
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that there were no ‘real problems’ with the Horizon IT System. There was minimal
support provided to me, and certainly none from the NFSP.
The following questions are not intended to limit your answers to the prior ones.
Question 10 - In respect of the website address www.postofficevictims.org.uk
you registered:
a. Please set out the background to this website, its development and whether
it was linked to a campaigning body.
76. I developed this website solely by myself to explain what had occurred, the
attitude of POL and to offer a point of contact for anyone else who had suffered.
I believed I was not alone in my experiences and therefore I wanted to reach out
to others affected in the same way.
b. If it was linked to a campaigning body, please set out the aims of the body,
its membership and its governance structure.
77. \t was not linked to a campaigning body.
Question 11 - Please consider POL00107538 (correspondence file) and
POL00040345 (letter from Richard Barker to Betty Williams MP on 5 January
2004).
a. Please consider the letter at page 11 of POL00107538. Did you contact Betty
Williams MP concerning the closure of Craig y Don Post Office in 2003?
78. I contacted Betty Williams MP in regard to my concerns around the closure of
my Branch.
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b. Please set out your views on the adequacy of support provided to you by
your MP in respect of the issues arising from the Horizon IT System.
79. With what was known at the time, I doubt Betty Williams MP could have done
much more. I do not have any complaints about the adequacy of the support
provided by Betty Williams MP, considering the knowledge at the time.
80. Please see my response to Question 8 above for further details in regard to my
communication with Betty Williams MP.
The JFSA
Question 12 - Save as set out in response to the above, please describe your
work in seeking (a) to expose the failings of the Horizon IT System and (b) to
obtain redress for the SPMs suffered as a result of those failings from the start
of 2009 to the present day. In so doing, please address the following issues (and
the questions below):
81. My work in seeking to expose the failings of the Horizon IT System and to obtain
financial redress for the victims’ group has been and still is a full-time
campaigning post.
82. To give the Inquiry a feel for the extent of work that proved necessary, I would
estimate that, on average from 2009, I will have spent 30-40 hours a week on
campaigning. This includes weekends and bank holidays as my work never
stops.
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83. The steps I have taken are very well documented and publicised through the
various Judgements, for example. These actions have included but are not
limited to:
i. Pre-JFSA: communications with MPs, Ministers, POL, SPMs, lawyers and
other campaigners, media.
ii. Establishing JFSA: building its activities over time.
iii. Extensive ongoing attempts to engage POL to, unsuccessfully, on a voluntary
basis on the part of POL, achieve positive action by them.
84. Taking all necessary steps to progress the legal claim that ultimately proved
necessary.
a. The nature or extent of any support you received in this work, and the
adequacy of the same.
85. Apart from the valuable support from the small number of SPMs with whom I had
been in contact with, there was no external support in the setting up of the JFSA
in November 2009.
86. As time moved on, some valuable support was obtained from people including,
but not limited to, Kay Linnell, MPs and Politicians such as James Arbuthnot and
others, Second Sight and legal support once matters escalated in that way.
b. Any challenges you faced in this work.
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87.
Cc.
88.
d.
89.
90.
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The challenges were faced at every step of the way since POL would obstruct
me. The gravity and the enormity of the problem was not recognised by others
in power including Government. And it became clear that the only way to achieve
progress was through a formal legal route which has its own challenges, including
obtaining the necessary funding for this route.
What strategy or policies you believed POL adopted in response to your
work.
POL used their financial might to control the narrative, they would not address
issues openly and honestly. They wanted to answer the questions that they
brought rather than other people’s queries. I would refer once again to the
findings and comments made by Judge Fraser in the GLO High Court
proceedings which give a very clear picture as to the type of policies and
strategies which POL adopted in response to my work.
Whether POL or Fujitsu sought or did in fact obstruct your work.
The primary objective of the JFSA and myself has always been to expose the
truth and achieve justice for the SPMs. POL has sought to, and has in fact,
contained the achieving of that objective, not only in relation to my own work but
also many others including Second Sight and the MPs. One way in which this
has manifested itself has been POL’s approach to disclosure.
I have not had full visibility on Fujitisu’s position in the scandal, so I certainly
cannot rule out that they caused or contributed to some of POL’s seemingly
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obstructive behaviour, and I note Judge Fraser's comments in the GLO High
Court proceedings in regard to Fujitsu’s disclosure of documents to POL.
Question 13 - Please set out any views you have on whether nature and extent
of the support and representation available to SPMs, counter managers and
counter assistants alleged to be responsible for shortfalls shown by the
Horizon IT System through the NFSP and / or the CWU changed during this
period (i.e. from the start of 2009 to the appointment of Second Sight).
91. In my view, it was non-existent. I did not receive any support from the NFSP or
CWU myself and do not believe that substantial support was available for other
SPMs. We often felt as if we were alone in our experiences and the supposed
support available was completely non-existent.
Question 14 - Please describe the background to and the process of founding
the JFSA. Without limiting your answer, please address the following:
a. Your reasons for creating the JFSA, its aims and objectives.
92. My main objective for creating the JFSA was to expose the truth. I wanted to
create a body of former and current SPMs and Branch Assistants which could
provide a community for all those going through the same experiences with POL.
I knew that I was not alone in my dealings with POL and the JFSA was set up in
order to ensure that other people in the same situation as myself knew that they
too were not on their own. As mentioned above, there was a complete lack of
support from POL, and I believe those in similar circumstances required support.
b. The membership, including how individuals became members.
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93. Anyone who reached out to me could become a member of the JFSA. I would
receive phone calls and emails, hence the reason why my work never stopped
during weekends and holidays as I always made myself available to others. The
people who reached out to me would then become members by attending our
meetings.
c. The structure of the JFSA (whether body corporate or unincorporated
association) and its governance.
94. The JFSA was set up as a loose association, it had no formal standing.
Therefore, the JFSA comprised current or former SPM and some assistants,
anyone who was affected by POL or had suffered due to the Horizon system. It
was set up to provide support and so had no formal governance. We would make
decisions via a show of hands.
d. Any sources of funding.
95. There was no funding when the JFSA was initially set up, we relied on the
members to contribute in the ways they could, by bringing food for the members
during our meetings, for example.
Please set out any material changes to the above at the appropriate point of
your witness statement.
Question 15 - Please describe how the JFSA operated from 2009 onwards. In
particular, but without limiting your answer, please address the following
issues:
a. Who was entitled to represent the JFSA and how it made decisions binding
on the association.
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96. Myself and our volunteer professional advisor, Kay Linnell were entitled to
represent the JFSA. All major decisions were taken to group meetings and were
sanctioned by a show of hands from those attending. Although, much of the time,
decisions were dictated by circumstances.
b. The nature and extent of any support and / or representation the JFSA
provided to its members or non-member SPMs.
97. Having formed as a group, the JFSA offered advice to individuals and organised
the group meetings and took forward the campaign to expose the truth. I always
made myself available to all members if they required support or assistance,
whether this be whilst they were still in tenure or after having left their branches.
c. The nature of JFSA’s work in seeking (a) to expose the failings of the Horizon
IT System and (b) to obtain redress for the SPMs suffered as a result of those
failings.
98. The JFSA corresponded with MPs and acted as a central network for support.
Our main work consisted of, but was not limited to, supporting, collaborating and
campaigning. We had set out to move the issue forward however we could,
whether this be by contacting the media, MPs or other individuals of power. We
had legal representation for those who were in the early stages of their dispute
with POL, those who were close to termination or suspension.
The following questions are not intended to limit your answer to the above.
Question 16 - Please consider POL00041564 (11 May 2009 Computer Weekly
article by Rebecca Thomson). Please explain how you came to be interviewed
by Ms Thomson. What were your thoughts on the article?
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99. I initially wrote to Computer Weekly in 2004 following Computer Weekly receiving
a further letter from Lee Castleton, the editor, Tony Collins, assigned Rebecca
Thomson to contact those involved. I worked closely with her, and we identified
a small number of others which became the basis of her article. I never actually
met Ms Thomson having only spoken to her on the phone. The Computer Weekly
article was useful as it was the first time a number of cases had been combined
into one article. It showed that people were not alone, and there was clearly an
issue with Horizon.
Question 17 - Please consider UKGI00016119 (your letter to Edward Davey MP
dated 20 May 2010).
a. Please set out the background which led you to send this letter.
100. I thought it appropriate to make the Minister for Postal Affairs aware of the setting
up of the JFSA and the issues faced by the former and serving SPMs who had
suffered because of POL.
b. Please consider: “Over the years I have personally submitted written details
of all this to the select committee of the DTI, and then on two other occasions
to that of BERR, and, put simply, the information has either been buried or
disappeared”. Please set out the submissions you made to the Select
Committee and HMG (exhibiting any relevant documents to your witness
statement).
101. Please refer to my letters to the Chair of the Select Committee, Martin O’Neill,
dated 9 September 2004 [WITN00050104], 9 October 2004 [WITN00050105]
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and, 5 January 2005 [WITN00050106] which sets out my submissions made to
the Select Committee. I did not receive a response to these letters.
102. In my letter to Mr O'Neill dated 9 September 2009, I explained ‘/ am hoping, in
providing this file to your committee, that you will be able to obtain answers to
the questions Post Office Limited have spent so much time ignoring, they do
need asking and they certainly need answering. They refused to answer them
to my MP, they refused to answer them to the Minister, but at the end of the day
Post Office Limited operates with Government approval, and that includes
approval of the way they operate and run the business.’
Question 18 - Please consider UKGI00016099 (your letter to Edward Davey MP
dated 8 July 2010):
a. If you have a copy of Mr Davey’s letter of 31 May 2010, please exhibit it to
your statement.
103. I exhibit a copy of the letter.
b. Please set out why you considered the response to be disappointing and
offensive.
104. It was disappointing because they had not read or taken into account anything
which I had said in my previous correspondence. It appeared to be a standard
template response. I took offence at the phrase ‘arm’s length’ as detailed in my
response dated 8 July 2010.
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Question 19 - Please provide details of any meeting you had with Edward Davey
MP on or around 7 October 2010. Without limiting your answer, please describe
who attended, what was said and what the outcome of the meeting was. Please
exhibit any notes you have of this meeting to your witness statement.
105. I do not recall the details of this meeting and I do not have any notes of the
meeting.
Question 20- Please set out to what extent you were involved in the intimation
of possible legal proceedings by Shoosmiths on behalf of several SPMs. For
the avoidance of doubt, you are not requested to provide information over
which you or another SPM could claim legal professional privilege.
106. Shoosmiths were instructed by 70 SPMs and former SPMs. They wrote four
Letters of Claim to POL on behalf of four separate SPMs, and I was not one of
the four concerned.
Question 21 - Please set out to what extent you were in contact with Lord
Arbuthnot (then James Arbuthnot MP) and Oliver Letwin MP prior to the
appointment of Second Sight.
107. I did not have any contact with Oliver Letwin MP and had the briefest of contact
with James Arbuthnot, and this would have mainly been about the arrangement
of Second Sight.
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Question 22 - Please consider POL00107331 (your letter to Norman Lamb MP on
25 February 2012) and UKGI00016112 (Mr Lamb’s response). Please set out a
full account of any meeting you had with Norman Lamb MP. Without limiting
your answer, please describe who attended, what was said and what the
outcome of the meeting was. Please exhibit any notes you have of this meeting
to your witness statement.
108. From what I can recall of the meeting, myself, Norman Lamb and one of his
officials attended. I felt it was positive and for the first time had found the minister
who seemed to actually listen to what he was being told and was concerned with
the situation. As he was replaced shortly after the meeting, I had wondered
whether his concern with the Horizon IT System had contributed to his removal.
I do not have any notes from the meeting.
Second Sight Appointment
Question 23 - Please describe to what extent you or the JFSA were involved in
discussions that led to the appointment of Second Sight.
109. We were not involved with the appointment of Second Sight; however, MPs
through James Arbuthnot were keen to seek our approval of their appointment.
Question 24 - Please set out what your initial views were as to the appointment
of Second Sight.
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110. We had real concerns as they had been chosen by POL. We were concerned as
to whether they would undertake a whitewash and were in POL’s pocket in a
similar way to that of the NFSP.
Question 25 - To what extent were you or the JFSA consulted on Second Sight’s
Terms of Reference?
111. Ido not recall being involved in the Terms of Reference.
Question 26 - What did you think of POL’s approach to the complaints made by
SPMs concerning the Horizon IT System at the point Second Sight was
appointed?
112. I was suspicious of POL at this point and the whole Scheme in general. After
having engaged in countless communications with POL over a long period of
time, all of which were sent with the hope of receiving some support from POL,
no one felt as if we could trust POL in all of this.
Question 27 - Please consider POL00107174 (email from Ron Warmington to
Susan Crichton and Simon Baker on 4 July 2012). Please consider “Apparently,
AB had commented along the lines that “this all seemed to be moving rather too
quickly”. Did you make this, or a similar, comment? If so, please set out what
you meant by it.
113. I do not recall whether I made this comment.
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Question 28 - Please consider POL00096817 (email chain on 17/18 July 2012)
POL00096961 (email from James Arbuthnot to lan Henderson on 13 September
2012). Please explain the concerns you had regarding POL’s investigation of
Horizon with Second Sight and how you sought to address these.
114. The idea was, as I recall, that the investigation was due to look at only historic
cases. However, at the same time, the JFSA was receiving information about
live cases, and we wanted these included as well. We believed it would be easier
for Second Sight to investigate live cases, as they would be able to obtain up-to-
date data for the purpose of their investigation. As per my letter dated 13 July
2012 to James Arbuthnot [WITN00050107], I outlined the way in which we had
hoped the investigation would be carried out. This included looking at both
historic and live cases so that Second Sight could perform an accurate
investigation into the current errors which were still occurring.
The run up to the first interim report
Question 29 - Please provide an account of your involvement with Second
Sight’s initial investigation. Without limiting your answer, please address the
following issues:
a. Your role and the work you carried out (whether on your own behalf, on
behalf of the JFSA or of specific SPMs). Please describe the nature or
extent of any support you received in this work, and the adequacy of the
same.
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115. My role was to provide information which I had built up over the years and liaising
with Second Sight on cases when requested. I would assist people throughout
the process (when requested) and ensure they were involved with the
investigation at the appropriate time. If the SPMs were having problems, then
they could come to me, but I was not working with them to formulate their claims.
I would act as a connection between Second Sight and the SPMs.
b. Your working relationship with Second Sight, Lord Arbuthnot, other MPs and
POL.
116. I would liaise with Second Sight, James Arbuthnot, other MPs and POL as and
when required by them.
c. Please summarise the extent of your communications with POL and / or Her
Majesty’s Government.
117. My communications with POL and Government were very occasional, I cannot
recall exact details of these.
d. Your impression of Second Sight’s independence and its ability to carry out
the review. adequately.
118. My impression of Second Sight improved from initial contact with them, I felt more
confident in their ability and could see them operating more independently from
POL. My main reservation at the start had been the fact that they had been
selected by POL, however, I came to see that they were keen on working as an
unbiased third party which improved my confidence in them as an investigating
body.
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e. Your impression of POL and Fujitsu’s approach to the investigation. Please
state to what extent, if at all, you considered POL or Fujitsu sought to or did
in fact obstruct the investigation. Please provide reasons for your answers.
119. Whether intentional or not, POL and Fujitsu’s approach to the investigation was
very slow and seemed obstructive at times. This was due to the lack of access
to documents, which worsened as the Mediation Scheme went on.
Question 30 - Please consider POL00098315 (your email to Ron Warmington
dated 12 May 2013, and others).
a. Please explain what you understood the difference between “system
errors” and “systemic failures” to be.
120. ‘System errors’ might be something like a certain combination of transactions
which may cause the system to interpret the action in a way that was not
expected, and hence might only affect one branch at any time. Then at the other
end of the scale it might be something far more complex resulting from a network
communication failure and an incomplete recovery of a transaction at a particular
office. Ultimately, these could be described as bugs in the system.
121. ‘Systemic failures’ on the other hand could be described as fundamental flaws
across the network which also applies to the way in which POL dealt with matters
in relation to the Horizon IT System.
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b. Please consider “However, I do believe that the investigations you have
undertaken so far have exposed a better route that should be followed”. Can
you please explain what you meant when you said the investigation
exposed a “better route”?
122. This comment was made after the selected cases had been decided for
investigation and before the Initial Mediation Scheme. I thought that they needed
more investigation rather than trying to draw a line under the whole thing with the
Interim Report.
Question 31 - Please consider POL00098418 (your email to Paula Vennells on 21
May 2013). Why did you feel the need “to ensure that [Ms Vennells] have been
receiving the full details of what has been occurring with the 2"¢ Sight
investigation’? Please provide full details of any meeting you had with Ms
Vennells following this letter but prior to the first interim report.
123. There was a concern that perhaps the information was not getting through to Ms
Vennells, as I did not think her staff were feeding back to her. I was concerned
that she was not being told the full story and so I wanted to ensure that she was
being accurately informed of the whole situation. This was, perhaps, a failure in
the way that Ms Vennells handled the situation in that I did not feel confident that
she had been receiving accurate updates and was truly invested in the
investigation and the subsequent events.
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124. I considered it appropriate to approach matters in this way because Paula
Vennells had told me she would be personally overseeing the process and, as
far as I could tell, her involvement had been very limited.
The interim report
Question 32 - Please consider POL00099004 (your email chain with Paula
Vennells on 4 July 2013), POL00115961 (Paula Vennells email of 6 July 2013)
POL00099037 (email chain with Paula Vennells on 6 July 2013)
a. Please set out your interactions with Second Sight and POL in the run up
to the release of the Second Sight Report.
125. As I had seen a copy of the Report, I had concerns about the word ‘systemic,’ I
knew perfectly well that failing to use that in the Interim Report, POL would pick
up on that. I did tell Second Sight this and the MPs, but nothing was done.
b. Please consider the following in POL00115961: “It is worth emphasising
that AB’s main issue is not ‘the computer’ but the human aspect: how in
his view Post Office failed to support and help vulnerable and ‘muddle
headed’ [sic] Spmrs”. Did this accurately reflect your position in
telephone calls with Paula Vennells?
126. They were both an issue, both the computer and human aspect had issues. POL
could have contained issues had they done something about the issues when
they were initially flagged.
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127. After the end of the investigation, it was a question of where do we go from here,
which is why I had a phone call with Ms Vennells. There were then subsequent
phone calls in regard to this, to try and figure out where to go next following on
from the investigation.
Question 33 - Please consider POL00099063 (Second Sight’s interim report),
POL00099091 (email chain between you and Paula Vennells of 7 July 2013) and
POL00029664 (note of meeting at Houses of Parliament on 8 July 2013).
a. Please set what your views were of the interim report. Did these differ from
other members of the JFSA?
128. I am not sure how many of the group saw the Report or whether it was discussed.
Overall, the Interim Report was positive in general as it showed that there were
issues occurring, but we had a real concern over the Interim Report stating that
there were no ‘systemic’ flaws.
b. Please set out what actions you think POL should have taken in response
to the interim report. Did that differ from what POL did in fact do?
129. POL should have launched an investigation into the findings to prevent further
cases from occurring. They needed to show a genuine intention to want to find
solutions. I do not believe that POL showed a genuine intention to attempt to deal
with the conclusions found in the Report. Had it not been for the perseverance
of myself and the JFSA, it is unlikely that POL would have done anything further.
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c. What actions did you take as a result of the release of the Interim Report,
and why?
130. I did not take any actions purely due to the Interim Report. My aim had and
always has been to expose the truth and I endeavoured to continue in my efforts.
d. Please describe your recollection of the meeting with POL representatives
on 8 July 2013.
131. This meeting was where it came up for the first time about there being 20 trained
investigators on the case, I do not recall this meeting being particularly special.
The purpose of the meeting was to comment about the findings of the Interim
Report. There is not a lot I can add, aside from what is in the minutes. I recall
that it did not result in any major step changes.
e. Do you consider POL00029664 to accurately reflect the meeting on 8 July
2013? If so, why did you feel restricted in what you could say because
POL were present?
132. As mentioned in paragraph above, I cannot add anything further other than what
is in the minutes for this meeting.
Initial Complaint Review and Mediation Scheme (‘The Mediation Scheme’)
Question 34 - Please consider the following documents when preparing the
section of your witness statement on the Mediation Scheme:
a. POL00026625 (minutes of the Working Group meeting on 25 October 2013),
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b. POL00043641 (minutes of the Working Group meeting on 31 October 2013),
c. POL00043622 (minutes of the Working Group meeting on 7 November 2013),
d. POL00043623 (minutes of the Working Group meeting on 14 November 2013),
e. POL00043624 (key points and actions of the Working Group meeting on 28
November 2013),
f. POL00043625 (key points and actions of the Working Group meeting on 5
December 2013),
g. POL00026666 (key points and actions of the Working Group meeting on 12
December 2013),
h. POL00026638 (key points and actions of the Working Group meeting on 3
January 2014),
i. POL00026639 (standing agenda for Thursday calls and note for 16 January
2014 meeting),
j. POL00026640 (note of Working Group Meeting on 23 January 2014),
k. POL00026635 (note of Working Group meeting on 6 February 2014),
I. POL00026636 (note of Working Group meeting on 20 February 2014),
m. POL00026637 (note of Working Group meeting on 27 February 2014),
n. POL00026656 (note of Working Group meeting on 7 March 2014)
o. POL00026643 (note of Working Group meeting on 13 March 2014),
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p. POL00026642 (note of Working Group meeting on 20 March 2014),
q. POL00026644 (note of Working Group meeting on 27 March 2014),
r. POL00026633 (note of Working Group meeting on 1 April 2014),
s. POL00026652 (note of Working Group meeting on 17 April 2014),
t. POL00026653 (note of Working Group meeting on 24 April 2014),
u. POL00043627 (note of Working Group meeting on 6 May 2014),
v. POL00026657 (note of Working Group meeting on 15 May 2014),
w. POL00026662 (note of Working Group meeting on 20 May 2014),
x. POL00026667 (note of Working Group meeting on 29 May 2014),
y. POL00026668 (note of Working Group meeting on 5 June 2014),
z. POL00026664 (note of Working Group meeting on 12 June 2014),
aa. POL00026673 (note of Working Group meeting on 16 June 2014),
bb. POL00026665 (note of Working Group meeting on 26 June 2014),
cc. POL00026672 (note of Working Group meeting on 10 July 2014),
dd. POL00026671 (note of Working Group meeting on 17 July 2014),
ee. POL00026683 (note of Working Group meeting on 24 July 2014),
ff. POL00026676 (note of Working Group meeting on 28 August 2014),
gg. POL00026679 (note of Working Group meeting on 4 September 2014),
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hh. POL00043628 (note of Working Group meeting on 25 September 2014),
ii. POLO0026684 (note of Working Group meeting on 2 October 2014),
jj. POL00040475 (note of Working Group meeting on 17 October 2014),
kk. POL00043629 (note of Working Group meeting on 30 October 2014),
Il. POL00043630 (note of Working Group meeting on 14 November 2014),
mm. POQL00043631 (note of Working Group meeting on 8 December 2014),
nn. POL00043633 (note of Working Group meeting on 14 January 2015),
00. POL00043634 (note of Working Group meeting on 13 February 2015).
Question 35 - Please set out your involvement in the establishment and running
of the Mediation Scheme (including the Working Group). Without limiting your
answer, please provide the following details;
a. What did you understand the nature and purpose of the Mediation Scheme
to be?
133. The purpose of the Mediation Scheme was to address SPMs complaints and
individual cases so that there could be an exploration into the way they had been
treated, with a view to finding a solution for the SPMs which was likely to involve
compensation. It was also set up to establish what had been the truth behind the
circumstances.
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b. Whether you believed the Working Group and/or Mediation Scheme could
fulfil the purpose.
134. At the outset, we thought that the Mediation Scheme might well achieve the aims
it had set out, provided POL would enter it in good faith. We entered into this this
process as we did not have any alternative option at the time.
c. What role did you and / or the JFSA have in setting the terms of references
or the appointment of the Chair?
135. The Chair was a suggestion that emanated from the JFSA, in particular Kay
Linnell. We did not have any major role in the setting of the terms of references.
d. Please explain how the Working Group operated. In particular, please
explain how often the group met and what was discussed. What role did
the different attendees play (i.e. POL representatives; Andrew Parsons of
Womble Bond Dickinson, Sir Anthony Hooper as the Working Group
Chair).
135. The Working Group met face-to-face on a monthly basis and I recall having
fortnightly conference calls in between those face-to-face meetings.
136. The main function of the Working Group was to monitor the progress of cases
through the various stages and to seek to identify and resolve any stumbling
blocks with the progression of cases.
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137. Unfortunately, the financing of the Scheme came from POL and so it provided
the secretariat and admin support which were supposed to be independent.
However, we were not aware at that time that Belinda Crowe was also a member
of POL’s covert project Sparrow team as was POL’s General Counsel as
indicated by the minutes from the Project Sparrow meeting which took place on
9 April 2014 [POL00006565).
138. Anthony Hooper was involved right at the outset, and he was the independent
Chairman. Andrew Parsons was the lawyer for POL and was on the POL side of
the room.
e. Please summarise the work you and / or the JFSA carried out as part of
the Working Group. Please describe the nature or extent of any support
you received in this work, and the adequacy of the same.
139. The JFSA and I represented the claimants, we acted as a voice for the group in hoping
to ensure that the Working Group acted in the best interests of each of the members of
the JFSA.
f. What was your impression of POL’s approach to the Working Group and
/ or the Mediation Scheme. Please provide reasons for your answers and
state whether POL’s approach changed. over time.
140. I was concerned from the outset that POL had no intention of using this as a way
to get the truth out, but we did not know how genuine POL were being. They
would find ways to delay disclosure on claims which furthered my concern in the
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genuine nature of the Mediation Scheme. But it was the only thing we had, so
we had no choice but to give it a go.
g. What was your impression of POL’s policy or strategy in responding to
claims made by SPMs concerning the adequacy of the Horizon IT System
or seeking redress for shortfalls. From your experience, what challenges,
if any, did SPMs face in seeking to obtain redress from POL and what
might some of the causes of those challenges have been.
141. There was a complete lack of engagement or acceptance of any issue from POL.
Disclosure of documentation was the major issue and POL continually extended
deadlines for reporting on cases.
h. Please explain what you thought were the positives and negatives of the
Mediation Scheme and Working Group. To whom did you communicate
that feedback?
142. It was a process which brought together a lot of cases and a lot of information,
which was positive. But on the other hand, it also exposed some of POL’s
reluctance to engage fully in such Schemes.
Question 36 - Please consider POL00026641 (minutes of Working Group
meeting on 30 January 2014). Please explain the nature of the disagreement on
the scope of the Working Group and to what extent this was resolved.
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143. Shortly after the appointment of Christopher Aujard, there was a real change in
POL’s approach to the Mediation Scheme. I am under the impression that he
was brought in to halt any developments. He wanted to change the Terms of
Reference and I said to him that this is not what the Mediation Scheme is about.
I wrote to him after that meeting via email on 8 February 2014 [WITN00050108]
with the Terms of Reference copied in explaining what we believed the Scheme
was about.
Question 37 - Please consider POL00022683 (letter from JFSA to Jo Swinson
MP of 16 April 2014), POL00043627 (referred to above (tbc)
a. Please set out the background to your making these criticisms at this point
in time.
144. Please see my email to Christopher Aujard, mentioned at paragraph 143 above,
which sets out my criticisms of the Mediation Scheme at this point.
b. What, if anything, changed as a result of this communication.
145. In my letter dated 16 April 2014, I set out to Jo Swinson MP how the Mediation
Scheme was meant to work and went on to explain how the Scheme actually
works. I expressed concern at this and how POL had not finalised a single case
report to the point where it is ready for the Working Group to consider its
suitability for being sent to Mediation. I also stated that the main hold up was with
POL. There were no changes, as I can recall, as a result of this.
Question 38 - Please consider POL00026672 (minutes of Working Group
meeting on 10 July 2014).
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a. Please describe the background to and purpose of your proposal to change
the agreed process in respect of decisions to mediate.
146. It never was agreed that the Working Group would discuss individual cases and
make decisions on whether to mediate, it was down to Second Sight to decide
this, then there was the Mediation Scheme which would undertake the process
of mediating between POL and the SPMs. However, two example cases were
discussed prior to Second Sight starting to produce reports, but only to agree a
format in which case reports were to be produced.
b. What were your views on POL’s and the Working Group’s approach on
determining which cases to mediate?
147. I did not believe it was part of the Scheme that the JFSA would be making
decisions on actual cases. My thoughts were that it was down to Second Sight
to make the decisions based on the review of the claimant's case and POL’s
case.
c. What was the outcome of this discussion?
148. I refused to take part, they decided to try and carry on, but I did not want to take
part in this set up. It was wrong for us to try and represent the individuals without
knowing about the cases put forward.
Question 39 - Please consider POL00026685 (Minutes of the Working Group
meeting on 16 September 2014).
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a. Please set out your views on Sir Anthony Hooper’s decision that the Working
Group still had a role to play where Second Sight advised that a case was
suitable for mediation.
149. It was not for the Working Group to make such a decision; we were unable to
make decisions when we had not seen the case in its entirety, nor had we
discussed it with the SPM involved. Second Sight had been working on the case
for a short while and so had the information necessary in order to make such
decisions, and they had also discussed the case with the SPM
b. Please consider “JFSA registered a standing vote to mediate all cases
where Second Sight so recommended and declined to participate in
discussions on those cases”. Please explain the reasoning for this
decision.
150. I did this so that all cases went to mediation, since we could not make the
decision on whether they could or could not without having seen the case in its
entirety, it would have been unjust. Second Sight had the benefit of having
reviewed the cases and so were in the best position to make a decision on
whether mediation was necessary.
c. Please set out why the JFSA did not contribute to debates of cases where
Second Sight did not recommend mediation.
151. As above
d. Please explain why the JFSA nearly left the meeting but decided to stay.
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152. Officially the JFSA did leave the meeting because I refused to attend and discuss
individual cases. We did not stay in the meeting. They recognised this at the time,
and I came into meetings when they were not discussing individual cases, save
for the two trial cases.
Question 40 - Please consider POL00107151 (the JFSA’s letter to Sir Anthony
Hooper dated 10 November 2014). Please explain the background that led to the
JFSA sending this letter. What, if anything, changed as a result of sending it?
153. It had been agreed at the outset we would discuss cases where there was
insufficient information to investigate and only in these cases JFSA would
discuss the individual cases. I sent this letter with a view of clarifying the position,
saying that in certain circumstances, the JFSA would provide some comment.
The Scheme was terminated shortly after this (9 March 2015) so there is little to
say in regard to change following my sending of this letter.
Termination of Second Sight and the Working Group
Question 41 - Please explain to what extent, if at all, you or the JFSA were
consulted by POL on the decision to terminate Second Sight’s contract and / or
close the Working Group.
154. The JFSA was not consulted by POL on the decision to terminate Second Sight’s
contract, we should have been, but we were not.
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Question 42 - What was your view of the decision of POL to agree to mediate all
cases within the Mediation Scheme.
155. Once they terminated the Scheme, it was entirely up to them whether a case
would be mediated, the Scheme had ended so it was up to POL if they wanted
to continue to mediate without the Scheme being in place.
Question 43 - What is your understanding of the circumstances that led to the
termination of the Second Sight contract?
156. I am not aware; it was a decision by POL without any consultation with the JFSA.
Question 44 - Why do you think the Mediation Scheme failed?
157. I believe the Mediation Scheme failed as it was part of the cover up by POL, I
expect POL discovered things that they did not like and did not want to come out.
There definitely was an element of not wanting to accept fault. I believe POL had
no intention whatsoever of getting to a mutually acceptable and fair decision, if
anything it seemed as if POL had been using the Scheme as a fishing expedition
to see what evidence SPMs actually had about Horizon.
The Group Litigation
None of the following questions is intended to elicit information over which you
or another SPM could claim legal professional privilege.
Question 45 - Please set out the background to the decision to issue
proceedings against POL. Without limiting your answer, please provide the
following details:
a. When was the decision made to investigate bringing the proceedings?
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158. I was considering bringing proceedings during the Mediation Scheme, and the
deliberation continued thereafter.
159. We had spent time with Edwin Coe, exploring how we could bring a case,
although we eventually found Freeths LLP who were not only able to assist with
getting the litigation off the ground, but also helped us to secure the funding we
required. Therefore, the ability to issue proceedings was a lengthy one that
involved perseverance culminating in Freeths LLP succeeding in launching the
claim after they fully investigated the claims and decided that the SPMs and
former SPMs had reasonable causes of action to bring.
b. Why was it considered necessary to bring such proceedings?
160. It was necessary to bring such proceedings since everything else had failed, it
seemed the only way forward. It was clear by then that what was required was
for the Court to force POL to do whatever was needed to expose the truth. I
believe that a body of power needed to step in since a voluntary process, such
as the Mediation Scheme, did not provide an adequate solution to those affected
by POL’s actions.
c. What, if any, support did you have from other bodies such as the NFSP, CWU
etc.
161. I do not believe that we had any meaningful support. The CWU did try to provide
some support in offering information but there was a limit to what they could
actually do. I did not receive any support from the NFSP, but I recall Freeths LLP
wrote to the NFSP seeking disclosure of certain correspondence and I recall the
requested documents were not provided.
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Question 46 - Please set out your views on POL’s approach and general strategy
to the group litigation. Without limiting your answer, please address the
following issues:
a. To what extent did you feel that POL had complied with disclosure
obligations?
162. By way of example, from the very start, Freeths LLP were writing to request
copies of the Known Error Logs and Womble Bond Dickinson said they were not
even sure if such a thing existed. This was disingenuous at best. Regarding
Peaks, these were instances of system failure and we/our expert stumbled
across the fact that they existed, and POL had not volunteered this information,
so we had to push for their disclosure as well. Hundreds of thousands of
documents were provided which was no doubt a deliberate attempt to drown us
in documents, and then key disclosure was being provided right up to and
including the trial which could have derailed it and was extremely frustrating.
Andrew Parsons was asked to prepare a number of witness statements
explaining why disclosure orders had not been complied with. POL made it
incredibly difficult.
b. What was your view of the witness and expert evidence led by POL?
163. Their witness evidence was consistent with everything POL had done over the
years, they protected POL from the truth being revealed at any cost.
164. In Fraser J’s Common Issues Judgment ([2019] EWHC 606), he noted the fact
that POL made use of Mr Abdulla’s computer experience as he had obtained the
title of ‘Computer Champion.’ Mr Abdulla went on to say that ‘it was just his title,
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and did not mean he was an IT expert’ (paragraph 226). Given that POL relied
so heavily on Mr Abdulla’s assertions, despite he himself admitting that he could
not be described as an IT expert, demonstrates the fact that supposed expert
evidence provided by POL was not dependable by any means.
165. Furthermore, Mr Carpenter of POL informed the Court that he had encrypted an
interview between himself, and Mrs Stockdale and the encryption key had been
lost. Fraser J stated that he was ‘sceptical of such an explanation given that POL
had supposed IT experts at their disposal and that POL had instructed a digital
forensics consultancy (paragraph 293). This clearly demonstrates the lack of
reliability of the POL supposed experts and furthers the idea that POL were
reluctant to expose the truth.
c. What was your view of POL’s decision to issue an application for Fraser J to
recuse himself?
166. My view of the decision to issue an application for Fraser J’s recusal was that it
was made out of desperation. The application had immediate ramifications and
it seemed as if POL were trying to delay everything so that we would run out of
money. It was a truly irresponsible decision; a responsible corporate would not
do this.
167. The Court of Appeal, in their decision to refuse permission for POL to appeal the
decision not to allow Fraser J’s recusal stated that ‘the recusal application never
had any substance and was rightly rejected by the judge (paragraph 50, PTA
A1/2019/0855). Such a statement furthers the notion that POL brought this
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application simply to cause delay and that their decision was completely
irresponsible.
Financial and other redress
Question 47 - Please set out in detail your account as to the events leading up
to the settlement of the litigation insofar as you consider it relevant to the
matters being investigated by the Inquiry (and only insofar as you consider you
are able to without eliciting information over which you or another SPM could
claim legal professional privilege).
168. It is public knowledge that POL knew we had funding for the litigation, they will
have known that we had access to a finite pot of money, and the harder they
fought, the more that funding would be depleted, in my opinion this was a very
cynical approach. The Steering Committee and I were advised by Leading
Counsel and Freeths LLP that it was in the best interests of the Claimant Group
as a whole to settle the proceedings at that time. POL had effectively outspent
the 555 Claimants and the risks of continuing with any litigation without adequate
funding, and possibly without ATE insurance, was not a risk which any of the
Claimants should have taken, given they have suffered to much already at the
hands of POL.
169. It was hoped, at the time of the settlement, that the judgments we had secured
would prove to be a foundation for further steps, which, thankfully, has proven to
be the case with the overturned convictions and, more recently the ex-gratia GLO
compensation scheme. We had achieved what we set out to achieve which was
to expose the truth and this was to be the key to all that has followed.
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Question 48 - Please set out the extent of your involvement with seeking
financial redress since the GLO proceedings were settled.
170. Following conclusion of the GLO proceedings, I invoiced the Government for the
cost of the legal action, which included everything from the £58 million settlement
which was not available for payment to the Claimant group. I did so because it
was a case which the Government was responsible for, being the sole
shareholder and it had fallen down on its role to properly oversee and manage
POL. Since then, I have sustained continual political pressure to secure support
for the SPMs and I and others have sought financial redress for SPMs as a whole
which Government eventually realised we were entitled to and in March 2022,
DBT (known as BEIS at the time) announced a scheme would be set up to ensure
the GLO group received full and fair financial redress to put them back in a
position that they would have been in were it not for POL and its Horizon IT
System failures.
Question 49 - To what extent, if at all, do you believe that POL has properly
delivered upon its commitment to improve relations with the SPMs? Please
provide reasons for your answer.
171. I am not aware that it has achieved this as I have not seen any evidence of a
commitment from POL to improve relations with SPMs and assistants.
Question 50 - If you have applied for compensation pursuant to one of the
schemes, please set out your views on the process of making such a claim. In
particular, please identify any positives or negatives about the process.
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172. The process for compensation of financial redress of the monies SPMs are
rightfully owed is taking far too long, not just for myself. A key component was
Post Office disclosure which has been at the root of this delay.
General
Question 51 - Who and / or what do you think is to blame for the Horizon IT
scandal?
173. This is a question for the Inquiry, I have some views on this, but it is more relevant
what the Inquiry’s view is.
Question 52 - Is there anything further relevant to the Inquiry’s terms of
reference of which you think the Chair should be aware?
174. I do not have anything further to add.
Statement of Truth
I believe the content of this statement to be true. I understand that proceedings for
contempt of court may be brought against anyone who makes or causes to be made,
a false statement in a document verified by a statement of truth without an honest
belief in its truth.
Full Name: Alan Bates
Dated: 29 February 2024
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Index to First Witness Statement of Alan Bates
No.
URN
Document Description
Control Number
POL00041768
Letter from Idris Jones to Alan
Bates dated 30 March 1998
POL-0038250
NI>
POL00004598
Letters and correspondence
between Mr Alan Bates and Mr
Mike Wakley
VISO0005666
POL00107462
Letters between Gerry A Hayes,
Alan Bates and C.W_ Burton
regarding losses and gains
POL-0105770
POL00107538
Letter from Alan Bates to Alan
Leighton dated 7 August 2003
POL-0105846
POL00107538
Letter to Mr A Leighton regarding
Termination of Subpostmaster
Contract
POL-0105846
POL00040345
Letter from Richard Barker to Betty
William regarding Horizon
POL-0036827
POL00040345
Article titled “Bankruptcy,
prosecution, and disrupted
livelihoods - Postmasters tell their
story” By Rebecca Thompson
POL-0038046
WITNO0050104
Letter from Alan Bates to Martin
O'Neill re: Post Office Limited
attempt to alter terms of contract
dated 9 September 2004
WITNO0050104
WITNO0050105
Letter from Alan Bates to Martin
O'Neill MP re: no acknowledgement
of letter month ago dated 9 October
2004
WITNO0050105
10.
WITNO0050106
Letter from Alan Bates to Martin
O'Neill MP re: FOI request for all
details of Craig-y-don Post Office
dated 5 January 2005
WITNO0050106
11.
UKGI00016119
Letter to Edward Davey MP
regarding Meeting request
UKGI026912-001
12.
UKGI00016099
Letter to Edward Davey MP
regarding Justice for
Subpostmasters Alliance
UKGI026892-001
13.
POL00107331
Letter from JFSA to Norman Lamb
MP requesting a meeting and
enclosing a survey
POL-0105639
14.
UKGI00016112
Letter from Norman Lamb MP to
Alan Bates regarding arranging a
meeting
UKGI026905-001
15.
POL00107174
Email from Simon Baker to Rod
Ismay and others regarding the
feedback on meeting with MPs
POL-0105482
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16.
POL00096817
Email from Paula Vennells to Alwen
Lyons, Theresa lles, Susan
Crichton in regard to printed
Subpostmasters and Second Sight
POL-0096400
17.
WITNO0050107
Letter from Alan Bates (on behalf of
JFSA) to James Arbuthnot re: 2nd
Sight dated 13 July 2012
WITNO0050107
18.
POLO0096961
Email from James Arbuthnot to lan
Henderson and Ron Warmington
regarding Post Office Cases
POL-0096544
19.
POL00098315
Email from Simon Baker to Alwen
Lyons re Alan Bates Letter
POL-0097898
20.
POL00098418
Email from Theresa Lies on behalf
of Paula Vennells to Alwen Lyons
regarding the Printed Horizon
Inquiry and JFSA concerns
POL-0098001
21.
POL00099004
Email from Paula Vennells to Martin
Edwards and Mark Davies
regarding Monday Meeting
POL-0098587
22.
POL00115961
Email from Paula Vennells to Alice
Perkins, Neil McCausland and
others regarding SS 5 July update
POL-0116963
23.
POL00099037
Email from Alan Bates to Paula
Vennells regarding the proposed
way forward
POL-0098620
24.
POLO0099063
Signed Interim Report into alleged
problems with the Horizon system
POL-0098646
25.
POL00099091
Email from Alan Bates to Paula
Vennells regarding the Draft
statement
POL-0098674
26.
POL00029664
External Meeting Minutes of 8th
July 2013 at Houses of Parliament
POL-0026146
27.
POL00043641
Working Group for the Initial
Complaint Review and Mediation
Scheme - Key Points and Actions
from Meeting- 25th October 2013
POL-0023266
28.
POL00043622
Working Group for the Initial
Complaint Review and Mediation
Scheme - Key points and Actions
from Meeting - 31st October 2013
POL-0040144
29.
POL00043623
Working Group for the Initial
Complaint Review and Mediation
Scheme - Key Points and Actions
from Meeting - 7th November 2013
POL-0040125
30.
POL00043624
Working Group for the Initial
Complaint Review and Mediation
Scheme - Key Points and Actions
POL-0040126
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from Meeting - 14th November
2013
31.
POL00043625
Working Group for the Initial
Complaint Review and Mediation
Scheme - Key points and actions
from Meeting - 28th November
2013
POL-0040127
32.
POLO0026666
Working Group for the Initial
Complaint Review and Mediation
Scheme- Key points and actions
from Meeting - 5th December 2013
POL-0040128
33.
POL00026638
Working Group for the Initial
Complaint Review and Mediation
Scheme- Key points and actions
from Meeting - 12th December
2013
POL-0023307
34.
POL00026639
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Amended
Minutes - 3rd January 2014
POL-0023279
35.
POL00026640
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Standing
Agenda - 16th January 2014
POL-0023280
36.
POL00026635
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Standing
Agenda for Thursday Calls - 6th
February 2014
POL-0023276
37.
POL00026636
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Standing
Agenda - 20th February 2014
POL-0023277
38.
POL00026637
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Standing
Agenda - 27th February 2014
POL-0023278
39.
POLO0026656
Initial Complaint Review and
Mediation Scheme Meeting - 7th
March 2014
POL-0023297
40.
POL00026643
Working Group for the Initial
Complaint Review and Case
Mediation Scheme- Standing
Agenda - 13th March 2014
POL-0023284
41.
POL00026642
Working Group for the Initial
Complaint Review and Case
Mediation Scheme- Standing
Agenda - 10th April 2014
POL-0023283
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42.
POL00026644
Working Group for the Initial
Complaint Review and Case
Mediation Scheme — Minutes- 27th
March 2014
POL-0023285
43.
POL00026633
Initial Complaint and Mediation
Scheme Working Group Minutes -
1st April 2014
POL-0023274
44.
POL00026652
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Minute - 17th
April 2014
POL-0023293
45.
POL00026653
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Minute - 24th
April 2014
POL-0023294
46.
POL00043627
Initial Complaint Review and
Mediation Scheme Working Group -
Minute of meeting- 6th May 2014
POL-0040130
47.
POLO0026657
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Minutes of
case conference call- 15th May
2014
POL-0023298
48.
POL00026662
Meeting Minutes of the Initial
Complaint Review and Mediation
Scheme Working Group- 20th May
2014
POL-0023303
49.
POLO0026667
Meeting Minutes for the Working
Group for the Initial Complaint
Review and Case Mediation
Scheme- 29th May 2014
POL-0023308
50.
POLO0026668
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Working Group
Minute- 5th June 2014
POL-0023309
51.
POL00026664
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Meeting
Minutes - 12th June 2014
POL-0023305
52.
POL00026673
Minute - Initial Complaint Review
and Mediation Scheme Working
Group — 16th June 2014
POL-0023314
53.
POLO0026665
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Minute of
Working Group Call- 26th June
2014
POL-0023306
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54.
POL00026672
Minute - Working Group for the
Initial Complaint Review and Case
Mediation Scheme - 10th July 2014
POL-0023313
55.
POL00026671
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Minutes of the
Working Group Call- 17th July 2014
POL-0023312
56.
POL00026683
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Meeting
Minutes- 24th July 2014
POL-0023324
57.
POL00026676
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Meeting
Minutes — 28th August 2014
POL-0023317
58.
POL00026679
Working Group for the Initial
Complaint Review and Case
Mediation Scheme _ -Meeting
Minutes — 4th September 2014
POL-0023320
59.
POL00043628
Standing Agenda for Thursdays
calls - Working Group for the Initial
Complaint Review and Case
Mediation Scheme - 25th
September 2014
POL-0040131
60.
POL00026684
Minute - Working Group for the
Initial Complaint Review and Case
Mediation Scheme — 2nd October
2014
POL-0023325
61.
POL00040475
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Meeting
Minutes- 17th October 2014
POL-0036957
62.
POL00043629
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Meeting
Minutes- 30th October 2014
POL-0040132
63.
POL00043630
Working Group for the Initial
Complaint Review and Case
Mediation Scheme - Meeting
Minutes- 14th November 2014
POL-0040133
64.
POL00043631
Working Group for the Initial
Complaint Review and Case
Mediation Scheme- Meeting
Minutes- 8th December 2014
POL-0040134
65.
POL00043633
Working Group for the Initial
Complaint Review and Case
POL-0040136
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Mediation Scheme- Meeting
Minutes- 14th January 2015
66.
POL00043634
Agenda for the Working Group for
the Initial Complaint Review and
Case Mediation Scheme — 13th
February 2015
POL-0040137
67.
POL00026641
Initial Complaint Review and
Mediation Scheme Working Group
— Meeting Minutes — 30th January
2014
POL-0023282
68.
WITNO0050108
Alan
Aujard
Bates to
dated 8
Email from
Christopher
February 2014
WITNO0050108
69.
POL00022683
Letter from Alan Bates to Jo
Swinson re: Justice for
Subpostmasters Alliance, _ Initial
Case Review & Mediation Scheme
POL-0019162
70.
POL00026685
Working Group for the Initial
Complaint Review and Case
Mediation Scheme Meeting
Minutes- 16th September 2014
POL-0023326
71.
POL00107151
Letter to Sir Anthony Hooper
regarding raising concerns about
the position and direction of the
Initial Case Review & Mediation
Scheme
POL-0105459
72.
POL00004607
Subpostmaster Induction Booklet
VIS00005675
73.
POLOO006565
Project Sparrow Meeting Minutes
dated 9 April 2014
POL-0017844
74.
POL00040368
Letter from POL to Betty Williams
MP dated 19 January 2004
POL-0036850
75.
WITNO0050101
Memorandum of Agreement - Alan
Bates and Suzanne Sercombe sale
of Llandudno Post Office to Peter
and Joan Savage
WITNO0050101
76.
POL00004612
Letter from Alan Bates to Mike
Wakley dated 16 April 2003
VIS00005680
77.
POL00004649
Letter from Alan Bates to Mike
Wakley dated 12 June 2003
VIS00005717
78.
POL00327682
Letter from Alan Bates to Sue Perry
dated 7 June 2001
POL-0175078
79.
POL00004590
Letter from Alan Bates to Glenn
Chester dated 13 February 2002
VIS00005658
80.
POL00004595
Letter from POL regarding
application for SPM dated 6
January 1998
VIS00005663
81.
POL00040354
Letter from Ria MacQueen to Alan
Bates dated 27 August 2003
POL-0036836
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82.
POL00040370
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Letter from Mike Wakley to Alan
Bates dated 14 April 2003
POL-0036852
83.
POL00040401
Letter from Alan Bates to Glenn
Chester dated 13 February 2002
POL-0036883
84.
POL00004629
Letter from Mike Wakley to Alan
Bates dated 4 June 2003
VIS00005697
85.
POL00041768
Letter from Idris Jones to Alan
Bates dated 31 March 1998
POL-0038250
86.
POL00004643
Letter from Alan Bates to Graham
Harbord dated 27 September 2001
VIS00005711
87.
POL00215384
Letter from Colin Baker to Alan
Bates dated 13 January 2004
POL-BSFF-0053447
88.
WITNO00050103
Letter from Alan Bates to Betty
Williams MP re: previous contact
and follow up dated 27 October
2003
WITN00050103
89.
POL00328107
Letters between POL and Betty
Williams MP
POL-0175659
90.
POLO0026667
the
and
Initial
Case
Meeting
Working Group for
Complaint Review
Mediation Scheme
Minutes- 29 May 2014
POL-0023308
91.
POLOO006565
Project Sparrow meeting minutes
dated 9 April 2014
POL-0017844
92.
POL00040368
Letter from POL to B Williams MP
dated 19 January 2004
POL-0036850
93.
POL00040345
Letter from POL to B Williams MP
dated 5 January 2004
POL-0036827
94.
POL00112664_001
Letter from POL to A Bates dated
19 December 2000
POL-0110130_001
95. Letter from POL to Alan Bates re
Aged shortage - Horizon Case
WITNO0050102 Write-Off dated 6 March 2002 WITNO0050102
96. Letter from M Wakley to A Bates I VISO0005697
POL00004629 dated 4 June 2003
97. Letter from M Wakley to A Bates I POL-0036845
POL00040363 dated 2 May 2003
98. Letter from G Hayes to A Bates I VISO0005654
POL00004586 dated 16 July 2007
99. Letter from A Bates to M Wakley I VISOO005686
POL00004618 dated 15 May 2003
100. Letter from A Bates to M Wakley I POL-0036880
POL00040398
dated 12 June 2003
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