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Witness Name: Robert George Wilson
Statement No.: WITN04210100
Dated: 11 MAY 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ROBERT GEORGE WILSON
I, ROBERT GEORGE WILSON, will say as follows:
1. 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 14" April
2023 (the “Request”). The statement covers private prosecutions taken by
Post Office Ltd (“POL”) and conducted by the Criminal Law Team (“CLT”) the
subject Inquiry.
Relevant background
2. I qualified as a Solicitor on 1st October 1980 following which I spent a short
period of time as a Court Clerk in a Magistrates’ Court before becoming a
Prosecuting Solicitor for the Northumbria Police Force. When the Crown
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Prosecution Service was created, I was transferred into the Service as a Crown
Prosecutor. I next joined the CLT of POL as a Prosecuting Solicitor in mid-1986.
. In May 2002 I was appointed Head of the POL CLT. I was responsible for
advising the Business on criminal issues concerning compliance with all
relevant laws and regulations together with updating and advising on the impact
of prospective legislation. It was also my responsibility to advise and represent
the Business. My main role was the responsibility for all criminal prosecutions
brought on behalf of the POL. This involved managing and supervising a team
of lawyers, legal executives and support staff. I was tasked with ensuring that
the CLT were up to date with current legislation including any necessary training
of the team e.g. Proceeds of Crime Act 2002. The CLT received prosecution
case files relating to criminal investigations that had been conducted by the
Security Team. I was responsible for the advice and the conduct of each case
until its conclusion. My role included ensuring that cases submitted by the
Security Team for advice were dealt with in a timely fashion and advice provided
was clear with appropriate charges if a decision to prosecute was advised. I
was also responsible for the daily management of the individuals in my team
and their performance. The CLT relied on a number of agents who were
instructed to undertake advocacy at court hearings in the Magistrates Court.
The team also relied upon Counsel who represented POL in the Crown Courts
throughout England and Wales. It was my responsibility to ensure that both
Agents and Counsel were properly instructed and supported in their respective
courts. I was also responsible for providing advice to the Business and Security
Team covering the policies and procedure that should be adopted concerning
all private prosecutions commenced by POL. I did not have any other relevant
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roles whilst I was Head of the CLT.
4. On 1st April 2012 I left POL and moved into Royal Mail.
The role of the Criminal Law Team
5. The CLT’s role so far as the policies and practices relating to the prosecution of
Sub Post Masters (SPM), managers, assistants and Crown Office employees
was to assess the evidence obtained, independently and consider whether the
evidence was reliable and credible. The role also included looking at whether
other material might affect the sufficiency of evidence and providing advice.
Where there was a realistic prospect of conviction of the suspect the advice
would address whether the prosecution was in the public interest. That advice
was prepared by the CLT for consideration by the decision maker. The essential
guidance relied upon by the CLT was that provided in the Code for Crown
Prosecutors. Each lawyer in the team was provided with an up-to-date copy of
the Code. The advice would be copied to the Security Team and authority would
be obtained from the decision maker within POL to authorise a criminal
prosecution. I believe that the role, policies or procedures changed significantly
following the inception of the Crown Prosecution Service and the publication of
the Code for Crown Prosecutors in 1986. The Code provided clear guidance
on the general principles that should be followed when making decisions on
prosecutions. In addition, the current prosecution policy and procedures would
at the time of providing the advice be adhered to in order to maintain a
consistent approach to each prosecution decision. In 1997 the Post Office
Internal Prosecution Policy was published (POL00030659). The policy related
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to employees and agents of POL. The policy was the first real step to place ina
single document the prosecution policy. I believe that when I first came into the
CLT the decision to prosecute was taken by Senior Investigation Managers in
the Security Teams. The 1997 policy refers to the decision maker as being from
the Personnel Department of each Business Unit following advice from the CLT.
This later changed to a nominated representative in the Business and was
contained in the Post Office Ltd-Security Policy Fraud Investigation and
Prosecution Policy of 4" April 2010 (POL00030580). The Royal Mail
Prosecution Decision Procedure in January 2011 (POL00030598) specified the
decision maker as being the Senior Security Manager for POL.
The rationale behind the practice of bringing private prosecutions
6. Royal Mail Group Ltd (before the separation of the Post Office) and later POL
(after the separation) had a practise of bringing private prosecutions against its
agents and staff where they were suspected of financial crime rather than
referring matters to the police and the CPS. Historically the investigation and
prosecution of crime in Royal Mail Group can be traced back as far as 1683.
(See “A Brief History of Investigations, Prosecution and Security in Royal Mail
(LCAS0000124)). The Attorney Richard Swift was appointed Solicitor to the
General Post Office. It is likely that he would have had some involvement in the
prosecution of offenders in his thirty-year career. Since Richard Swift retired the
various businesses that evolved from the General Post Office have continued
to conduct private prosecutions. When the Crown Prosecution Service was
created by the Prosecution of Offences Act in 1985 I understand that it remained
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the position that an individual or entity had a right to conduct a private
prosecution and that this should continue in relation to POL investigations.
Investigators were often recruited from counters staff because of their familiarity
with accounting documents and procedures. It was felt that such in-house
knowledge of the accounting systems, practises and procedures was difficult to
acquire overnight by police officers who had no knowledge of the workings of
POL. It was therefore not felt appropriate to pass the investigation of crime
within POL to the Police. Indeed, there were a number of occasions where a
police officer had commenced an investigation into a POL related crime for
example where a SPM had reported to the police a theft by one of their
employees. More often than not contact would be made with one of the POL
investigation teams and the case requiring investigation was handed over to a
POL investigator. Similarly, where an investigation was conducted by a police
officer and had been forwarded to the Crown Prosecution Service I recall that
the CLT usually was asked by the Crown to accept their papers and take over
the conduct of the prosecution. I do recall having to attend Court and take over
the prosecution following an arrest and charge of an offender.
POL ceased the practice of bringing private prosecutions after I left its
employment.
Policies governing prosecution decisions and the conduct of prosecutions
8.
I have seen and considered a number of policies that were implemented during
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the course of my tenure as Head of the CLT from May 2002 to 1st April 2012. I
have referred to some of those policies below. Any policy implemented outside
this period would not have received any input from myself.
9. POL drafted a number of policies governing the investigation of crime impacting
on POL, the prosecution process and related areas. The policies were owned
in the main by the respective Security Directors at the time of implementation.
My role was to advise the Security Director and critique the content of those
policies. I was also required to review the existing policies and advise on any
changes that may be needed. Each policy that was developed was reviewed
annually but was not necessarily changed each year. I was responsible for
seeing that any stipulations included in the policies were adhered to.
10.The POL prosecution policy is a guide setting out the criteria to be considered
before undertaking a prosecution together with the roles and responsibilities
applicable to investigators, the CLT and decision makers within the various POL
teams. The purpose of the policy is to make it clear that acts of dishonesty where
property or assets are acquired illegally may result in a criminal prosecution
when the criteria for prosecuting offenders is met. The Post Office prosecution
policy appears to have evolved over a considerable period of time with little
formal evaluation or review until 1997 when the then Security Director
implemented the Post Office Internal Prosecution Policy (POL00030659). The
rationale behind the prosecution policy is to set out the general principles that
should be followed when making decisions on prosecution cases. The policy
states that “the Post Office’s policy is normally to prosecute its employees or
agents who commit acts of dishonesty against the Post Office property or assets
or the property or assets of Post Office customers and clients while in Post
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Office custody and where it is deemed to serve the public interest.” When I
joined POL in 1986 the decision to prosecute was taken by the Security Team
on advice from the CLT. The final decision to prosecute remained with the
Security Team. This changed at some point prior to me becoming the Head of
the CLT. The decision to prosecute became the “nominated representative in
the Business with consideration to the advice provided by the CLT”. This change
can be seen in The Royal Mail Group Ltd Criminal Investigation and Prosecution
Policy dated 1st December 2007 (POL00030578). A further change in
responsibility for making the decision to prosecute can be seen in the Royal Mail
Group Prosecution Policy created in September of 2008 updated in April 2011
(POL00030800) where the Head of Human Resources or their representative
became the decision maker. Another change to the policy was made “in the
event of any disagreement with prosecution advice or prosecution and conduct
decisions anywhere in the UK the Head of Criminal Law Team and the Head of
the Investigation Team will consider the case and provide guidance and advice
to ensure that Royal Mail maintains a consistent prosecution policy”. Following
this policy, the Royal Mail Security Procedures and Standards-Prosecution
Decision Procedure of January 2011 (POL00030598) determined that the
Senior Security Manager in POL would be the prosecution decision maker. So
far as the criteria on which to base a prosecution was concerned this has
remained in place since the inception of the Crown Prosecution Service. The
Code for Crown Prosecutors requires that there must be sufficient evidence to
prosecute the defendant and the prosecution must be in the public interest.
These principles are followed in each of the prosecution policies.
11. The Post Office’s approach to suspected theft, fraud and false accounting was
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to normally prosecute where appropriate. See above RMGP (POL00030578),
and RMS-PandS-PDP (POL00030598). The Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy of Nov 2010 (POL00031008). The Post
Office Ltd Anti-Fraud Policy of February 2011 (POL00104855) stated that POL
would not accept "any level of fraud...” or misappropriation and will actively
investigate with appropriate intervention being undertaken. The CLT
approached each case of theft, fraud and false accounting by first assessing
whether there is enough evidence against a suspected offender. The lawyer
advising would need to consider whether that evidence could be used in court
and was reliable and credible and ascertain whether there was any other
evidence that might affect the sufficiency of evidence. Further the lawyer would
need to be satisfied that there was a realistic prospect of conviction.
Consideration would then need to be given as to whether it would be in the
public interest to prosecute.
12.I was appointed Head of the Criminal Law Team in May 2002. At that time I had
a compliment of lawyers in the team made up by a qualified Barrister and
Solicitors. The team also had a number of support staff dealing with purely
administrative work. At some point I was able to acquire two qualified Legal
Executives. During my tenure the grade of Principal Lawyer was introduced
which resulted in two of my lawyers being promoted into the grade.
13.The CLT was responsible for overseeing the conduct of all criminal prosecutions
from the inception of the case to its conclusion. This involved advising on the
sufficiency of evidence and drafting the appropriate charges for consideration
by the designated decision maker. In cases where a decision could not be
determined the lawyer would be required to itemise other lines of inquiry and
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evidence that was needed whether it pointed toward a prosecution or away from
a prosecution. If advice was that prosecution was the appropriate course of
action then following authorisation being granted to prosecute the conduct of
the case would remain the responsibility of the CLT until its conclusion. This
included serving advance information on the defence solicitors and Magistrates’
Court, service of committal papers on these parties if appropriate and instructing
counsel to advise on evidence and draft the indictment in the Crown Court.
14.The role of the Financial Investigation Unit was to identify and restrain assets
and proceeds of crime with a view to commencing confiscation proceedings
where appropriate. The Financial Investigator (“FI”) would become involved if
the Security Team investigating criminal offences believed that there was
evidence of assets being available.
15.From my recollection the only teams that were involved in criminal prosecutions
within the Post Office were the Security Team and the Financial Investigation
Unit.
16.1 was responsible for supervising or reviewing the conduct of the CLT
prosecutions.
17.1 had no specific training or qualifications in the role of reviewing the conduct of
the CLT prosecutions other than my experience as a qualified solicitor.
18.There was no supervision of the private prosecutions by any outside body. At
the conclusion of each case I would receive a report on the outcome of the
proceedings from the person attending court in the CLT office area. I would also
receive a report from my agents in the agents area. Prosecuting counsel would
also report the outcome of proceedings. Where any comments were made by
Magistrates or a Judge I would ask for a full note of the comments or if
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necessary obtain a court transcript. In the event the defendant was acquitted
following trial I would contact prosecuting counsel and ask for a full report with
a view to understanding the reason for the acquittal. Any adverse criticism of
any aspect of the private prosecution would be dealt with by me. I cannot recall
receiving any major criticism emanating from a Crown Court Judge or
Magistrates’ court that required me to address the issue in writing with the
complainant Court.
19.There was no independent oversight exercised in respect of the conduct of
prosecutions.
20.The Post Office prosecution policies did not differentiate between Crown Office
employees and Sub-Postmaster (SPM’s) and their managers. This remained
the position throughout my role as Head of the CLT.
21.When I left POL on 1st April 2012 I moved into RMG and thus I ceased to have
a role in respect of the POL prosecution policy. The separation resulted in the
requirement to generate a separate prosecution policy for each business.
Prosecution and charging decisions
22.During my tenure as the Head of the Criminal Law team the process that was
applied in relation to prosecution and charging decisions following the
preparation of the advice and drafting of charges was firstly to send the advice
to a single point within the Personnel Department of each Business unit so that
a decision to prosecute could be considered (see above POIPP (Dishonesty)
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POL00030659). The role of decision maker changed within POL (but not Royal
Mail) (see above RMGP POL00030598) to the Senior Security Manager. I
believe that RMGPP (POL00030800) nominated the decision maker in Royal
Mail as the Head of Human Resources. I understand that following the advice
being sent to the decision maker in POL they were required to consider whether
it was in the public interest to initiate a prosecution, issue a caution or take no
further action. The decision maker was required to consider the Code for Crown
Prosecutors when determining the public interest test. The decision was
required to be made within 5 working days and put in writing, returning the
papers to the casework management team who would then initiate criminal
proceedings if authorised to do so. In the event that the decision maker did not
reply within the stipulated 5 days a further letter would be written to the decision
maker informing them that in the event a decision had not been reached within
a further 5 working days then the decision to prosecute would follow the CLT’s
advice. In the event of advising a caution or no further action the case work
management team would instruct the investigator to deal with this aspect of the
case. This process was encapsulated in the RMSPandS (POL00030598). In
April 2011 The Royal Mail Group Prosecution Policy (POL00030685) added an
additional process in the event that the decision maker disagreed with the legal
advice prepared by the Criminal Law Team. In this situation the Head of the
CLT and the Head of the Investigation Team would be required to consider the
case and provide guidance and advise to the decision maker with a view to
endeavouring to ensure that the prosecution policy was applied consistently.
This change had been included in the policy because in a small number of cases
the advice provided by the CLT to prosecute a suspected offender on criminal
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charges had been rejected and the suspect had been returned to duty. In such
circumstances a prosecution could not proceed.
23.When I first took over the role as Head of the CLT I believe that nominated
representatives in the business made the charging decisions in respect of
SPMs’ managers and assistants alleged to be responsible for shortfalls shown
on the Horizon IT system. The role of decision maker changed for POL and
moved from being the Head of Human Resources (see RMGP POL00030800)
to the Senior Security Manager (see RMSPandS POL00030598). My
understanding is that this change was put in place to ensure consistency in the
decision-making process.
24.The decision to prosecute and charge the alleged offender was taken at the
same time. I do not believe that this changed during my role within the CLT. The
legal advice to prosecute and charge was prepared by lawyers in the CLT.
However due to a reduction in the number of the lawyers in my team and the
absence of a lawyer who had been granted special leave, I was authorised to
outsource POL legal advice on prosecutions to a firm who already dealt with the
advocacy of some of our cases in the agent area. Messrs Cartwright King
agreed to receive investigation files directly from investigators, prepare the
advice, draft charges and submit the files for authorisation. Following the
charging of the offender, the firm acted as our representatives in the
Magistrates’ Court and Crown Court until the conclusion of the case. I cannot
recall when Messrs Cartwright King commenced this work for POL.
25.Legal advice on prosecution and charging decisions was prepared by Solicitors
or Barristers employed in the CLT. No one else was authorised to provide such
advice until the need to outsource some of this work to our agent Messrs
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Cartwright King. New recruits to the CLT were supervised by a senior lawyer
before being allowed to sign off on any advice that they had prepared. This
period of training was usually for 6 months, and supervision of the new recruit
would be rotated between a number of different senior lawyers within the CLT.
Only qualified lawyers within the CLT were entitled to provide legal advice in
relation to prosecution and charging decisions during my tenure as Head of the
CLT with the later exception referred to above when Cartwright King undertook
prosecutions on POL’s behalf.
26. The qualifications held by those providing legal advice were those applicable to
a solicitor or barrister. There was no specific training provided relating to
preparing legal advice on prosecution and charging decisions other than for new
recruits to the team.
27.The test applied by those making the prosecution and charging decisions was
that contained in the Code for Crown Prosecutors. The decision maker was
supplied with an up-to-date copy of the Code. The factors to be considered in
relation to the evidential test included whether the evidence was relevant,
admissible, reliable and credible so that it was sufficient to provide a realistic
prospect of conviction. The decision maker was not required to consider the
evidential test. An advice from the CLT would only be sent for a decision to be
made if there was deemed to be sufficient evidence to justify a prosecution. The
decision maker would be required to reach a decision in relation to the public
interest test. So far as the public interest test was concerned a number of factors
may weigh in the decision maker's mind. Those factors included the seriousness
of the offence, whether there was a breach of trust, the size of any loss to the
Business and whether other parties such as members of the public had
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suffered. In addition, there may be factors concerning the offender that would
be pertinent to consider such as their age and any health considerations. ( see
RMGLCandPP POL00030578, Royal Mail Group Prosecution Policy Oct 2009
POL00031011, POSPFIP 4th April 2010 POL00030580, see RMSPandS
POL00030598, see RMGPP POL00030685, see RMGP POL00030800).
28.1 note that policies were developed in November 2013 and January 2016. I was
not employed in POL on either of these dates.
29.1 have considered a number of documents relating to legal advice I provided to
the Security Team in 2010 and 2011. (letter dated 19th May 2010
POL00015014, letter dated 25th May POL00047155, letter dated 17th May
POL00047158, letter dated 21st May 2010 POL00047159, Draft Charge
POL00047160, letter dated 10 January 2011 POL00008792, Schedule of
Charges POL00008793, letter dated 21 March 2011 POL00017656, Schedule
of Charges POL00017657, letter dated 6 June 2011 POL00009413, Schedule
of Charges POL00009414, letter dated 5 July 2011 POL00056596, Schedule of
Charges POL00056597, letter dated 21 July 2011 POL00009537, letter dated
6 June 2011 POL00009413, Schedule of Charges POL00009538, letter dated
7 September POL00011337, and Schedule of Charges POL00011338). Other
advices were prepared by myself in 2010 and 2011 that were similar to the
examples above but that were pertinent to the particular evidence being
considered by me.
30.1 provided such advice to the Security Team throughout my period as Head of
the CLT.
31.The Code for Crown Prosecutors was a document that a decision maker had a
copy of and was required to consider when making the decision to prosecute.
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The successive prosecution policies all referred to the need to consider whether
it was in the public interest to prosecute. I would consider that it was in the CLT’s
role to provide advice on the public interest stage of the prosecution test. The
references in my advice to the sums of money in issue in support of prosecution
as weighing against a caution as an alternative were intended to assist the
decision maker so far as the public interest test was concerned. As a matter of
policy, the prosecution decision-maker was expected to consider the public
interest test themselves with guidance from my advice and be determined from
the nature of the charges accompanying the advice. I do recall providing training
at some point to decision makers but accept that it was not always possible to
include every individual who took on the role in such training. Had a prosecution
not been in the public interest I would have explicitly drawn this to the decision-
makers attention and recommended alternative action or no action to be taken.
32.The CLT did provide advice to the Security Team on investigation steps prior to
the decision to prosecute being reached. This may include reasonable lines of
inquiry to be taken. ( letter dated 18 May 2011 POL00046228, letter dated 5
July 2011 POL00046230, letter dated 5 July POLO00056596).
33. There were occasions when counsel’s advice was sought prior to a decision to
prosecute being reached. The CLT did not seek advice from external lawyers.
Seeking advice from counsel on certain matters continued throughout my role
in the CLT. Such advice was occasionally sought in complex cases.
The conduct of prosecutions
34.A number of pieces of legislation governed the conduct of POL prosecutions
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including The Magistrates’ Court Act 1980, The Police and Criminal Evidence
Act 1984, The Prosecution of Offences Act 1985, The Criminal Procedure and
Investigations Act 1996, The Regulation of Investigatory Powers Act of 2000,
The Proceeds of Crime Act 2002 together with the relevant codes of practice.
The Code for Crown Prosecutors was a document that was central to the
governing of the conduct of criminal prosecutions along with the succession of
Royal Mail Group Prosecution Policy’s and Royal Mail Group Procedures and
Standards.
35.Prosecutions were conducted by POL throughout England and Wales. When I
was appointed the Head of the CLT the lawyers in the CLT conducted advocacy
in London and the South East of England. Solicitor Agents were employed
solely to conduct advocacy in the Magistrates’ Court in the remaining areas of
England and Wales not covered by the CLT. Occasionally in a sensitive case or
where there was some other need identified, a lawyer in the CLT would
prosecute in a court outside the office area. Where the defendant was
committed for trial at Crown Court counsel would be instructed to represent POL
until the conclusion of the case. In the agents area the lawyer responsible for
the case would send to the agent the committal papers, a copy of the draft
indictment and a copy of instructions to counsel. The instructions to counsel
would request that advice be provided on the evidence and that counsel would
settle the Indictment. The agent would attend counsel to assist at each hearing
in the Crown Court until the conclusion of the case. The agent would report the
outcome of the proceedings to the instructing lawyer. The CLT also used a set
of chambers in London to conduct advocacy in the Magistrates’ Court when the
team was short of lawyers to cover hearings. At some point during my tenure
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as head of the CLT we had a deficiency of lawyers in the team to cover all of
our cases. Due to this deficiency a decision was made to approach a set of
agents to undertake prosecutions on behalf of POL. Discussions took place with
our agents Messrs Cartwright King who agreed to assist the CLT. Following the
agreement Cartwright King received files directly from investigators in the agent
area and provided advice, drafted charges for the decision makers
consideration and in the event of a prosecution ensuing conducted the
prosecution case to its conclusion in the Crown Court. (letter dated 16th
November 2010 POL00047197, Back sheet of Counsel’s Brief POL00051459,
letter dated 19th May 2010 POLO0015014, letter dated 21st May 2010
POL00047159, letter sending Advance In formation to Clerk to the Justice’s
POL00054985, letter dated 15 October 2010 POL00055567, letter dated 29th
September 2010 POL00055298, and letter dated 12 August 2010
POL00055162).
Disclosure
36.No guidance in relation to disclosure obligations was given in any prosecution
policy documents. I believe that the Policy and Standards team within POL
security were responsible for providing written guidance and training with input
from myself. It was felt that as the Code for Crown Prosecutors did not provide
guidance on disclosure that this should be dealt with in a separate document.
37.The POL disclosure obligations on the prosecutor were to disclose to the
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accused material which has not previously been disclosed to the accused and
which might reasonably be considered capable of undermining the case for the
prosecution against the accused or of assisting the case for the accused. There
was also a duty to serve on the defence solicitors a schedule of non-sensitive
unused material and provide copies of the listed material where practicable.
38.My role concerning disclosure of material relating to cases I had conduct of was
to keep disclosure under review throughout the life of the case. The
investigation manager with conduct of the case, or I believe in some
circumstances another investigator not involved with the investigation, would
assume the role of disclosure officer. The lead lawyer would never be the
disclosure officer. (Schedule of Non-Sensitive Unused Material POL00055495).
39.1 provided advice to the disclosure officer in relation to disclosure at each step
of the prosecution case following a not guilty plea or election for Crown Court
trial. Once witness statements and a copy exhibit bundle had been prepared, I
would receive a schedule of non-sensitive unused material from the disclosure
officer listing all relevant material which was not the subject of the trial papers.
The material listed would also be copied if practicable. In addition, there may be
material described as capable of assisting the defence or undermining the
prosecution. In this instance the defence solicitors would be notified of such
material and the schedule of non-sensitive material would be served with trial
papers. Occasionally I would be told that there was sensitive material in
existence. From my memory I believe that such material was not always shown
to me but that I may be informed of its nature. Where such sensitive material
was determined to undermine the case or assist the defence a decision would
be taken to discontinue the proceedings. The notification regarding disclosure
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and service of any schedules would be dealt with prior to trial when exhibit
bundles and witness statements were served on the defence and Court. The
standard procedure at this stage would be to ask the defence solicitors to serve
a defence statement which when received would be copied to the disclosure
officer so that disclosure could be reconsidered. Advice would be provided to
the disclosure officer if necessary. If this generated further material requiring
disclosure then this would be complied with, and a further schedule of non-
sensitive material would be prepared by the disclosure officer which again would
be served on the defence solicitor together with any copies of such material if
practicable. All of the schedules would be copied to counsel having conduct of
the case. The position of disclosure would be continually reviewed until the
conclusion of the case and the disclosure officer would be reminded of this
obligation in writing. (see above POL00047159, POL00009537, letter dated 12
October 2010 POL00047166, letter dated 15 October 2010 POL00055546,
letter dated 28th April 2011 POL0008525).
40.Advice would be provided by the CLT on evidence that should be obtained in
the initial advice when charges were drafted. On receipt of witness bundles,
copy exhibits and disclosure schedules further advice on evidence would be
given if appropriate.
4
-Counsel was instructed to advise on evidence once the case was committed for
trial to the Crown Court. External Lawyers were not used by the CLT (except for
Messrs Cartwright King as referred to above). Occasionally where the case was
complex or for any other reason, counsel would be instructed at a preliminary
stage to provide advice on the investigation or more detailed advice addressing
any issues in the case. (Instructions to Counsel POL00055527, Instructions to
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Counsel POL00055521, letter dated 12 October 2010 POL00055526, Back
Sheet of Brief to Counsel POL51459).
42.In the event that a discrepancy between Horizon generated cash and stock
positions and the actual physical position determined by branch office staff was
discovered by an audit and charges of theft, fraud and/or false accounting were
contemplated on this discrepancy all relevant information or evidence would be
sought from the investigator. No direct contact or provision of information was
provided to those parties advising on the Horizon IT system. Where a
discrepancy was discovered, the Investigator would seek evidence to prove the
loss which may entail acquiring evidence from transaction logs, ARC, back up
files or any other applicable data. Any evidence establishing which counter clerk
was responsible for the relevant transaction would also be obtained.
43. Further information about the Horizon IT system would be requested by external
solicitors or counsel from time to time. Where the defence were seeking to clarify
issues the CLT would endeavour to co-operate. I have seen a memo seeking
three civil litigation files which a defence team had specifically requested in
order to gain a “flavour” of the Horizon issues in those cases. I believe these
files would have been obtained and copied to the defence team. ( letter dated
10th November 2009 POL00053481).
44.1 preferred to use counsel who were familiar with Horizon procedures in POL
prosecutions. Having conducted previous trials counsel would understand the
issues more readily and consequently be able to advise on points raised by the
defence more easily that counsel with no knowledge of the system. It meant that
counsel could discuss the technical side of the case in conference with the
investigator and provide an informed advice on the prosecution without the need
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to have to explain basic principles of the Horizon system. ( letter dated 2 June
2011 POL00021335). When the Horizon IT system was first implemented, I
instructed senior counsel who had undertaken a number of prosecutions for
POL to provide an advice for the CLT applicable to the new system. I understand
it included specific wording to cover the production of computer records ( S69
of the Police and Criminal Evidence Act 1984), and wording to cover the
production of business records (S 11 of the Police and Criminal Evidence Act
1984). Counsel instructed had also received training on a computer terminal
that would be used by SPM’s, counter clerks and staff conducting transactions
with members of the public. I cannot now recall the full extent of the advice
prepared by counsel but recall that it was a detailed advice.
45.Following the receipt of the Defence Case Statement in order to ensure
compliance with disclosure obligations I would first consider the statement and
where any clarification of the content was required, I would write to the defence
solicitor seeking a better understanding of any issue. In the event the statement
was clear, a copy of the defence statement would be forwarded to the disclosure
officer and where appropriate draw to their attention any key issues, provide
advice and seek a review of any material that was previously determined to be
not relevant to the investigation. A copy of the defence statement would be
forwarded to counsel instructed and agent, if an agent was instructed. In the
event that the defence statement identified further disclosure material then an
additional schedule would be prepared and served on the defence solicitor.
Copies would also be sent to prosecuting counsel and any agent instructed. (
letter dated 8 November 2010 POL00055718, letter dated 8 November 2010
POL00055717, letter dated 8 November 2010 POL00055720, email dated 18
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November 2010 POL00055783, letter dated 18 November 2010 POL00047168,
letter dated 29th September POL00055298).
46.Where it is alleged in a Defence Case Statement that a discrepancy was as a
result of the Horizon IT system then the investigator would be required to identify
who in Fujitsu could address the issue and obtain relevant evidence to explain
the discrepancy. If the issue had concerned ARQ, which I believe was the record
of keystrokes made, then these logs would be obtained and disclosed on the
defence.
47.An allegation in a Defence Case statement that there was a discrepancy in the
Horizon IT system would trigger an obligation to disclose any known bugs,
errors or defects in the Horizon IT system.
48.1 have considered a number of documents relating to the case of R v Seema
Misra. The letters and emails relate to various stages of the prosecution but do
not give a complete picture of the case (letter dated 29th September 2010
UKG100014627, email dated 22/12/2009 POL00053723, letter dated 5th March
2010 POL00054303, Attendance note of 15th July 2010 POL00054999, email
dated 16/03/2010 POL00054430, email dated 21/10/2010 POL00055590).
49.Where applications for disclosure concerned “a huge amount of Horizon data”
my view would have been that such a request should be complied with. From
my recollection whilst there were a number of challenges to the veracity of the
Horizon IT system and the amount of data being disclosed was voluminous CLT
would endeavour to ensure that disclosure requests were complied with. The
only case I can recall where the extent of the defence requirements for
disclosure was such that it was referred to a Judge because of the volume and
I believe, the relevance of some of the requested material, was in the case of R
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v Seema Misra. As far as my own view is concerned applications for data were
not resisted by the CLT unless as in the Seema Misra case I believe it was
considered that some of the data falling within the application was not relevant,
which is why CLT sought a hearing before the Crown Court Judge dealing with
the case for a ruling on the issues raised.
50.1 do not know why Penny Thomas was reluctant to authorise Gareth Jenkins to
talk to the Defence expert. I am also unaware of the reason why this should
have impacted on the relationship between PO and Fujitsu. (Attendance note in
the case of Seema Misra POL00054999).
Experts
51.The guidance given to expert witnesses called on behalf of POL was the same
as that of a non-expert witness namely that the witness statement should be
truthful and if it were proved otherwise, they could be liable to prosecution.
Experts are obliged to provide objective, impartial, unbiased, evidence on the
matters within their field of expertise. The duty of the expert is to the court and
not the party who is instructing them. The expert witness statement declaration
of truth is the same as contained in a witness statement. The declaration being
“This statement is true to the best of my knowledge and belief, and I make it
knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have
wilfully stated in it anything which I know to be false or do not believe to be true.”
Clearly this declaration is self-explanatory in that it signifies the meaning and
importance of their declaration and of the content of their witness statement.
52.The CLT did not prepare a generic witness statement for expert witnesses. I
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cannot recall comparing witness statements generated by anyone at POL or
Fujitsu for use in criminal cases so am unable to say whether a generic
statement had been developed by either POL or Fujitsu for their witnesses.
(email dated 16/06/2009 POL00051927).
53.1am unaware of any policies or guidelines being in place regarding the provision
of evidence by employees of Fujitsu whist I was in the CLT. (email dated
16/6/2009 FUJ00122670).
54.The only witnesses we were able to use to obtain evidence in support of the
prosecution where a defendant was attributing a discrepancy on audit to
problems with the Horizon IT system were Fujitsu employees. I believe that
Fujitsu owned and had control of the data. I do not recall that Gareth Jenkins
who was held out to be an expert witness on the Horizon IT system was ever
challenged about his credentials as an expert or whether he should be allowed
to be called by POL as an expert because of his employment role within Fujitsu.
I understand that some experts emanate from bodies who employ and pay the
expert. Gareth Jenkins was aware that his duty was to the court and not to the
CLT who instructed him or Fujitsu who paid him.
55.1 believe that where there was a challenge to the Horizon data a statement from
Fujitsu would be obtained. The only witness I recall providing such expert
evidence was Gareth Jenkins. I do not recall however whether he gave
evidence in other cases following him giving evidence in the Seema Mistry case
but believe he probably did. ( letter dated 19th August 2010 POL00055189).
56.1 do not recall how common it was for the prosecution and defence experts to
meet to produce a joint report to narrow the issues following the Seema Misra
case but believe that it did happen where the Court dealing with the case were
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aware that experts were involved, and it was felt that issues in the case could
be narrowed. I understand that a joint report would normally be ordered at a
Plea and Case Management hearing. ( email dated 21 September 2010
POL00015953).
Plea negotiations
57.There are examples in a number of prosecutions where plea bargains were
struck before trial whereby the PO would offer no evidence on a charge of theft
in exchange for a guilty plea on a charge of false accounting. (email dated
16/11/2010 POL00055772, letter dated 17 November 2010 UKG100014698,
letter dated 17 November 2010 POL00055781, letter dated 18th November
2010 POL00055807, letter dated 16 December POL00055896).
58.1 did not draft charges of theft in order to put pressure on defendants to offer
guilty pleas to charges of false accounting. Charges of theft were only drafted
when the evidence was such that it was believed that there was a realistic
prospect of conviction of the offender in relation to the theft charge.
59.1 considered that a plea to false accounting would not be acceptable if it was put
on the basis that the Horizon IT system was at fault because I did not believe
that this was true and as such felt such a plea could not be properly accepted.
(email dated 17/11/2010 POL00055783).
60.1 do not recall how many cases were settled where a shortfall had been repaid.
However, I do not believe it to have been a common occurrence. ( letter dated
29th September 2010 POLO00055298, letter dated 5 November 2010
POL00055704, letter dated 1st December 2010 POL00055854, letter dated 2
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December 2010 POL00055858, letter dated 15 December POL00055890).
Criminal enforcement proceedings
61.1 have considered a number of relevant documents (see point 7), regarding
criminal enforcement proceedings.
62. Steps to restrain a suspect's assets were taken where there were reasonable
grounds for suspecting that the person had benefitted from their criminal
conduct, a criminal investigation had been started and there was a real risk that
the asset would be dissipated if a Restraint Order was not obtained. (Post Office
Ltd Financial Investigation Policy 4th May 2010 POL00030579, Royal Mail
Group Security-Procedures and Standards September 2010 POL00026573,
Post Office Ltd Financial Investigation Policy 2nd February 2011
POL00104853).
63. The decision to take criminal enforcement proceedings was taken following a
discussion between the Financial Investigator (“Fl”) and a lawyer in the CLT.
The factors under consideration included whether there were reasonable
grounds to believe that a person had benefitted from criminal conduct or, it was
thought that the defendant had been or would be convicted or committed for
sentence in a Crown Court for a criminal offence from which the defendant had
benefited. In addition, a provable loss to the business, or personal benefit to a
suspect offender exceeding £5000 in value was required. In addition, there
would have to be indications that the defendant had assets that could be used
to service any future Confiscation Order.
64.Once a decision was reached to pursue a financial investigation the Fl would
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serve a S18 POCA 2002 “Request for Information” on the defendant either
contained within a Restraint Order or upon conviction in the Crown Court. Any
response to the s18 request would be analysed with any information known at
that time. The Fl would consider the need for any further financial information
and pursue any appropriate course of action. A decision would be reached as
to whether the defendant benefited from a “Particular” or “General” course of
criminal conduct. The Fl would then prepare a Prosecutors Statement of
Information pursuant to s16(3) for general criminal conduct or s16(5) for
particular criminal conduct. In the event that the defence solicitor’s respond to
the s16 statement the Fl may decide to prepare a response. The next step in
the process would be to prepare confiscation forms, a compensation order and
a discharge of restraint (where applicable). The Fl would attend the confiscation
hearing at the Crown Court with the confiscation forms and make application for
a confiscation order. The CLT would advise and assist the Fl once a decision
had been reached to pursue this course of action. The CLT would instruct
counsel and advise agents where appropriate and liaise with the Crown Court.
In addition, any developments would be communicated to all relevant parties to
ensure the application for confiscation was dealt with as expeditiously as
possible. (Flow chart POL00084988, Security & Investigation Debt Process
POL00084989, letter dated 6th May 2009 POL00051382, letter dated 17th
February 2010 POL00054145, letter dated 17th February 2010 POL00054147,
email 30/06/2010 POL00054927, email dated 3 June 2011 POL00018884, letter
dated 10 December 2010 POL00055877, letter dated 1st November 2010
POL00016273).
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Relationship with the Civil Law Team
65.1 have had sight of a number of emails sent between the Civil Law Team and
the CLT where the integrity of Horizon IT was under consideration. (email dated
01 December 2006 POL00069892, email dated 05 December 2006
POL00070166, email dated 04 December 2006 POL00070175).
66.The CLT and Civil Law Team were separate teams. Any liaison between the
two teams was rare and on a superficial basis only. The CLT would not disclose
any witness statements or records of interview on the Civil Law Team however
where there was a simple request asking the CLT to confirm whether the team
was prosecting in relation to a particular Sub Post Office we would confirm if
this were the case. Bearing in mind the duties on the CLT in respect of
confidentiality in relation to any criminal prosecution there was no sharing of
evidence with the Civil Litigation Team. ( letter dated 10th November 2009
POL00053481).
67.My understanding of the case against Mr Castleton is that this was a civil action
to recover unauthorised losses in the sum of 26k which were missing from the
Bridlington SPSO between January and March 2004. I was contacted by
solicitors representing the PO in the civil action as Mr Castleton had alleged that
the losses were fictitious and caused as a result of problems with the Horizon
IT system. Mr Castleton intended to call a witness, Mr Singh, who had been
prosecuted by the CLT. The case was concluded when no evidence was offered
against Mr Singh. This course of action was taken because a number of exhibits
had been removed from the papers by another agency and they could no longer
be traced. The lack of the missing exhibits resulted in a decision being taken to
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offer no evidence against Mr Singh. The solicitors acting on behalf of POL in the
civil proceedings against Mr Castleton had requested that I attend court to
explain why the prosecution had not been proceeded with. I agreed to attend
court although I was not required to do so. This case therefore had no impact
on any assessment of the integrity of the Horizon IT system. Accordingly, it had
no impact in relation to later prosecutions as it had simply involved missing
exhibits. (see above POL00053481).
Cases against SPMs
68.1 have commented on the case of Alison Henderson having had sight of some
of the correspondence. I cannot recall the case at all. I do however recall some
details of the Seema Misra case and trial. My recollections relate to the requests
concerning disclosure which ultimately resulted in the matter being placed
before a Judge where an order clarified the extent of the prosecutions disclosure
duties and disclosure was complied with. I also recall being informed of some
details of the trial as it progressed through the Crown Court. I have no other
recollections of any of the persons named although some of the names are
familiar to me although I do not now have a recollection of their case.
69.1 do not recall any other particular cases in which I had a role which I consider
relevant to the matters being investigated by the public inquiry.
70.Looking back I did not have any concerns about any criminal cases in which I
was involved.
Knowledge of bugs, errors and defects in the Horizon system
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71.1 have seen an email chain POL00055410, from Alan Simpson to myself dated
8th October 2010 and timed at 14.16 hours. The email requested that I dial into
a meeting that afternoon. At the time I understand I was in an office meeting
and accordingly was unable to dial into the telephone meeting. At the end of the
office meeting I saw the email and copied the email to two colleagues in the
CLT. I do not recall the email or recall what actions I took following the
conclusion of the office meeting. I do however believe that I would have followed
up the email and contacted Mr Simpson.
72.1 do not know what the issue was that had been reported by Fujitsu and
concerned Mr Simpson.
73.1 do not know what the repercussions in future prosecutions Mr Simpson
envisaged.
74.1 cannot recall whether the concerns resulted in any change to the investigation
and disclosure in Horizon data cases.
75.1 have seen instructions drafted by me on 12th October 2010. There is no
reference in those instructions to the Fujitsu report referred to in Mr Simpson's
email of 8th October. I cannot recall whether counsel was made aware of the
recent report from Fujitsu. (see above POL00055521).
Wider challenges to the integrity of Horizon
76.I have seen an exchange of emails in February to March 2010 in which it is
suggested that there should be a ‘general’ due diligence exercise on the
integrity of Horizon. ( email dated 08 Mar 2010 POL00054371). I believe the
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report that was published in August 2010 prepared by Rod Ismay the Head of
Product and Branch Accounting for POL was the outcome of the exercise on
the integrity of Horizon. The report was entitled “ Horizon in Response to
Challenges Regarding System Integrity.” (POL00026572). The report stated
that Horizon (both Legacy and Online) was robust and that prosecutions which
had given rise to adverse comments were cases in which “we remain satisfied
that this money was missing due to theft in the branch.”
77.1 understand that the IT magazine article on Horizon may have been attached
to the string of emails referred to in the answer to paragraph 75 above. In this
event I would have seen the magazine article but cannot now recall my reaction
to it. I assume that it was as a result of this article and from other concerns that
were being raise about the Horizon IT system that Rod Ismay produced his
report in August 2010. (POL0054371).
78.1 have considered the report prepared by Rod Ismay “Horizon Response to
Challenges Regarding System Integrity.” The report in essence vindicates the
past prosecution of offenders by CLT and whilst expecting further challenges to
the Horizon IT system does not anticipate that those prosecutions should desist.
Rod Ismay considers that his report was an objective report. The report
maintains that £1000’s of pounds were discovered missing at audit nevertheless
the author remained satisfied that this money was missing due to theft at the
branch. It is not believed that the account balances against which audits were
conducted were corrupt. Emphasis is placed on tamper proof logs, real time
backups, and absences of “backdoors”. This last reference is explained as data
entry being at branch level that was tagged against the logon ID of the user.
The ownership of accounting was assessed as being “truly” at branch level. An
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independent IT consultancy described the Horizon on-line architecture as “first
rate”. The report maintains that failures do occur, but POL had controls over
these failures. Transaction backups were in place on a backup server updated
as each transaction was completed. Further, branch balancing was securely
recorded and was traceable. The Horizon infrastructure was robust from a
security point of view and access prospective. Horizon was resilient as it was
able to continue customer service and hold data in a queue in the event of
incidents. The report considers that known IT issues had not arisen in any legal
cases. The report refers to three Landmark cases namely Clevelleys in 2001,
Castleton in 2004, and Alderley Edge in 2010. It is noted that third party experts
had been involved in the Horizon design, testing and roll out. Whilst maintaining
that the majority of branch audits were satisfactory it is conceded that there was
a 0.01% correction level per month with 230 million transactions taking place in
that period. Consideration was given to obtaining an independent report, but
this was discounted. Following consideration of the report I did not have any
concerns about the contents. The report in my view vindicated the continuing
prosecution of offenders where appropriate.
79.1 cannot now recall the three “landmark cases” describe in Rod Ismay’s report.
The first case on the list in 2001 took place when I had a 2 year spell in a team
that was not involved in any way with the prosecution of offenders.
80.1 do not believe that challenges to the integrity of Horizon changed my advice
regarding any approach to investigation and disclosure of Horizon data cases.
I endeavoured to maintain a consistent approach by adhering to requirements
contained within POL prosecution policies and guidance, legislation and their
codes and the Code for Crown Prosecutors.
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Reviewing decisions to prosecute and Post Office investigations
81. My role in reviewing a decision to prosecute following representations made by
MP’s would be to consider all of the case papers independently and fully apply
the principles as set out in the Code for Crown Prosecutors whilst following the
POL prosecution policy guidelines. Any decision I would reach would be free
from any improper or undue pressure or influence from any source. (Letter to
MP POL00007640).
82.1 was not involved in any investigations carried out by Cartwright King, Simon
Clark, Brian Altman KC or Jonathan Swift KC.
Other matters
83. There are no other matters that I would wish to draw to the attention of the Chair
of the Inquiry.
Statement of Truth
I believe the content of this statement to be true.
Dated: 11th May 2023
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Index to First Witness Statement of ROBERT GEORGE WILSON
No. I URN Document Control Number
Description
1 POL00030659 __I Post Office Internal Prosecution POL-0027141
Policy 1997
2 POL00030580 Post Office Ltd-Security Policy POL-0027062
Fraud Investigation and Prosecution
Policy April 2010
3 POL00030598 Royal Mail Prosecution Decision POL-0027080
Procedure 2011
4 LCAS0000124 ‘I A Brief History of Investigations, VIS00010364
Prosecutions and Security in Royal
Mail
5 POL00030578 Royal Mail Group Ltd Criminal POL-0027060
Investigation and Prosecution Policy
2007
6 POL00030800 Royal Mail Group Prosecution Policy I POL-0027282
2008
7 POL00031008 ‘I Royal Mail Group Ltd Criminal POL-0027490
Investigation and Prosecution Policy
8 POL00104855 The Post Office Ltd Anti-Fraud POL-0080487
Policy 2011
9 POL00030685 Royal Mail Group Prosecution Policy I POL-0027167
2011
10 POL00031011 Royal Mail Group Prosecution Policy I POL-0027493
11 POL00015014 Letter dated 19" May 2010 POL-0008206
12 IPOL00047155 I Letter dated 25"" May POL-0043634
13 I POL00047158 __I Letter dated 17"" May POL-0043637
14 POL00047159 Letter dated 215' May 2010 POL-0043638
15 POL00047160 Draft Charge POL-0043639
16 POL00008792 Letter dated January 2011 POL-0001984
17 I POLO00008793 _I Schedule of Charges POL-0001985
18 POL00017656 Schedule of Charges POL-0010848
19 IPOLO00017657 _I Schedule of Charges POL-0010849
20 I POL00009413 I Letter dated 6 June2011 POL-0002605
24 POL00009414 Schedule of Charges POL-0002606
22 I POLO0056596 I Letter dated 5 July 2011 POL-0053075
23 POL00056597 Schedule of Charges POL-0053076
24 I POL00009537 __I Letter dated 21 July 2011 POL-0002729
26 POL00009538 Schedule of Charges POL-0002730
27 POL00011337 Letter dated 7 September POL-0004529
28 I POL00011338 I Schedule of Charges POL-0004530
29 POL00046228 Letter dated 18 May 2011 POL-0042707
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30 POL00046230 Letter dated 5 July 2011 POL-0042709
32 POL00047197 Letter dated 16° November 2010 POL-0043676
33 I POL00051459 _I Back sheet of Counsel's Brief POL-0047938
36 POL00054985 Letter sending Advance Information I POL-0051464
to Clerk to the Justice’s
37 POL00055567 Letter dated 15 October 2010 POL-0052046
38 POL00055298 Letter dated 29°" September 2010 POL-0051777
39 I POL00055162 I Letter dated 12 August 2010 POL-0051641
40 I POLO0055495 ‘I Schedule of Non-Sensitive Unused I POL-0051974
Material
41 POL00047166 Letter date 12 October 2010 POL-0043645
42 I POL00055546 __I Letter dated 15 October 2010 POL-0052025
43 POL00008525 Letter dated 28" April 2011 POL-0001717
44 I POLO00055527 _I Instructions to Counsel POL-0052006
45 POL00055521 Instructions to Counsel POL-0052000
46 I POL00055526 _I Letter dated 12 October 2010 POL-0052005
47 POL00053481 Letter dated 10" November 2009 POL-0049960
48 POL00021335 Letter dated 2 June 2011 POL-0014527
49 I POLO0055718 _I Letter dated 8 November 2010 POL-0052197
50 POL00055717 Letter dated 8 November 2010 POL-0052196
51 I POL00055720 _I Letter dated 8 November 2010 POL-0052199
52 POL00055783 Email dated 18 November 2010 POL-0052262
53 POL00047168 Letter dated 18 November 2010 POL-0043647
55 UKGI00014627 I Letter dated 29'" September 2010 UKGI025420-001
56 POL00053723 Email dated 22/12/2009 POL-0050202
57 I POL00054303 __I Letter dated 5'" March 2010 POL-0050782
58 POL00054999 _I Attendance note 15" July 2010 POL-0051478
59 I POL00054430__I Email dated 2010 POL-0050909
60 I POLO0055590__I Email dated 21 October POL-0052069
61 POL00051927 Email dated 16/06/2009 POL-0048406
62 I FUJ00122670 I Email dated 16/6/2009 POINQ0128884F
63 POL00055189 Letter dated 19" August 2010 POL-0051668
64 I POL00015953 I Email dated 21 September 2010 POL-0009145
65 POL00055772 Email dated 16/11/2010 POL-0052251
66 I UKGI00014698 I Letter dated 17 November 2010 UKGI025491-001
67 I POL00055781 I Letter dated 17° November 2010 POL-0052260
68 POL00055807 Letter dated 18th November POL-0052286
69 I POL00055896 __I Letter dated 16 December POL-0052375
71 POL00055704 Letter dated 5 November 2010 POL-0052183
72 I POL00055854 I Letter dated 1s December 2010 POL-0052333
73 I POLO0055858 _I Letter dated 2 December 2010 POL-0052337
74 _IPOLO00055890 I Letter dated 15 December POL-0052369
75 IPOL00030579 I Post Office Ltd Financial POL-0027061
Investigation Policy 2010
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76 IPOL00026573 ‘I Royal Mail Group Procedures and POL-0023214
Standards 2010
77 IPOLO00104853 ‘I Post Office Ltd Financial POL-0080485
Investigation Policy 2011
78 I POLO0084988 I Flow Chart POL-0082046
79 I POL00084989 I Security & Investigation Debt POL-0082047
Process
80 I POL00051382 I Letter dated 6'" May 2009 POL-0047861
81 POL00054145 Letter dated 17" February 2010 POL-0050624
82 I POL00054147 I Letter dated 17" February 2010 POL-0050626
83 I POL00054927 I Email dated 03/06/2010 POL-0051406
84 I POL00018884 I Email dated 3 June 2011 POL-0012076
85 I POL00055877 I Letter dated 10 December 2010 POL-0052356
86 POL00016273 Letter dated 1S! November 2010 POL-0009465
87 POL00069892 Email dated 01 December 2006 POL-0066455
88 POL00070166 Email dated 05 December 2006 POL-0066729
89 I POL00070175 I Email dated 04 December 2006 POL-0066738
90 I POL00055410 I Email dated 8" October 2010 POL-0051889
91 I POL00054371 I Email dated 08 March 2010 POL-0050850
92 IPOL00026572 I “Horizon in Response to Challenges I POL-0023213
Regarding System Integrity”
93 _IPOL00007640 I Letter to MP POL-0000832
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