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Witness Name: Jan Robert Holmes
Statement No.: WITN04600200
Dated: 27 JANUARY 2023
POST OFFICE HORIZON IT INQUIRY
SECOND WITNESS STATEMENT OF JAN ROBERT HOLMES
I, JAN ROBERT HOLMES, will say as follows:
1. I have been asked to provide a Rule 9 Witness Statement in regard to my
involvement in the Cleveleys Post Office incident. The request also asked me to
identify the individual in Pathway who became responsible for audit data
extractions and associated witness statements after the responsibility passed
from me in May 2000. Finally, the request asked for me to set out any matters
that I would like to address to the questions posed by Mr Edward Henry KC
during my hearing. I was also asked, at my hearing on 16'" November 2022, to
provide any further Witness Statements that I had produced while I was in post.
2. I shall deal with Cleveleys first, the other Witness Statements next and the other
matters at the end of this Statement.
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Cleveleys (August 2003 to August 2004)
. My first involvement with Cleveleys was via an email from a Pathway colleague,
Peter Sewell who worked in Security, asking if I would be able to take on the
task. The email, dated 15"" August 2003, included preliminary emails from Kevin
Parker (POL) and Jim Cruise (POL) (Email from Peter Sewell to Jan Holmes re:
Cleveleys, WITN04600201).
. On 21% August 2003 I responded to Jim Cruise with our preliminary observations,
including a statement of what we could do to help (Email from Jan Holmes to Jim
Cruise re: Cleverleys — Horizon Equipment, WITN04600202).
. Nothing further was heard until 6" February 2004 when we received a letter from
Post Office Limited (POL) containing a copy of the Expert’s report (Note : I do not
have a record of this report). On 12" February 2004, following a discussion with
Jim Cruise (POL), who was critical of the Expert’s report and was looking to
challenge it, I produced a review of the report for internal Fujitsu Services Post
Office Account consumption (Note re: Pathway internal response to Expert’s
report, WITN04600203). This would form the basis of a more formal response to
POL issued by Colin Lenton-Smith (Pathway Commercial and Financial Director),
sent to Keith Baines (POL Contract Manager) on 20!" February 2004 (Letter from
Mr Colin Lenton-Smith to Mr Keith Baines re: Post Office Counters Ltd v Mrs
Julie Wolstenholme, FUs00121512 ). Keith Baines asked if he could share our
response with the Expert, which we agreed to, but as can be seen it did not alter
his opinion (Email from Jason Coyne to Weightman Vizards re: Post Office
Limited v Mrs J Wolstenholme, FUs00121535 ). A further response was
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produced by me for Fujitsu Services Post Office Account dated 12" March 2004
(Note re: Response to The Expert's Reply to Fujitsu Services’ Submission,
WITN04600206) but my understanding is that this was not forwarded to the
Expert as explained in the Jim Cruise email of 19" March 2004 (Email from Jan
Holmes to Colin Lenton-Smith re: Cleveleys Update, Fuso0121571 ). Keith
Baines was made aware of this.
. Nothing more was heard until 6" April 2004 when Jim Cruise provided an update
(Email from Jan Holmes to Colin Lenton-Smith re: Cleveleys PO Mrs J
Wolstenholme, FUs00121602 ) regarding POL’s latest offer to the PM. Again, all
went silent so I made my own enquiries with POL in June 2004 and was
surprised to hear that Jim Cruise had taken early retirement and the case was
being handled by Mandy Talbot (Email from Jan Holmes to Colin Lenton-Smith
re: Cleveleys, FUs00121637 ). Mandy was herself critical of the Expert’s report.
. Aconference Call was held on 3 August 2004 (Email from Jan Holmes to Keith
Baines re: Actions post Conference Call - Cleveleys, FUs00121686 ) involving
POL, Pathway and Pathway’s lawyers Masons where a series of actions were
accepted by Pathway to provide information relevant to the forthcoming court
case. On 4" August 2004 Keith Baines provided a POL statement as to how
they, POL, assured themselves that Horizon was ‘Fit For Purpose’ (Email from
Keith Baines to Mandy Talbot re: Wolstenholme case, WITN04600211 and Note
re: How Post Office Confirmed that Horizon was fit-for-purpose, WITN04600212).
I was not involved in the production of that document and it describes the ‘what’
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of POL’s assurances about ‘Fit For Purpose’. I was not privy to the full extent of
POL’s actions so cannot comment on their efficacy.
8. On 11" August 2004 I received a draft Witness Statement from Suzanne
Helliwell at Weightmans, which was based on a draft document sent to her by me
that described the four levels of support offered by the Horizon solution (Draft
Witness Statement of Jan Holmes for Post Office Counter Ltd v Mrs Julie
Wolstenholme, WITN04600213) which I subsequently signed and returned
(Email from Jan Holmes to David Barker re: Cleveleys WS - Final,
WITN04600214) notifying Masons. I do not recall any conversations with POL
regarding the production of this statement.
9. I attended court but was not required as POL had made an increased offer to the
PM and she had dropped her case. My email to Bill Mitchell, the then Security
Manager at Pathway on 16" August, effectively closed this down from my
perspective (Email from Jan Holmes to William Mitchell re: Cleveleys,
WITN04600215). I was not briefed as to my ‘witness role’ which I assumed to be
providing oral evidence in support of the written Witness Statement.
10.1 think it’s fair to say that I was exasperated with POL and their handling of this
issue, not Cleveleys per se but their handling of their Expert witness and their
lack of communication, including a 3 year delay in involving us. POL, specifically
Jim Cruise and Mandy Talbot had both verbally expressed concerns about
precedent should the Expert’s report become common knowledge and had asked
for our assistance in challenging it. We expended considerable time and effort
into assisting them, I was in contact with Pathway Customer Services Help Desk
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staff, Reconciliation staff and Technical Support to provide relevant information.
However, POL did not subsequently pass on our final response and offer of on-
site assistance to the Expert for his consideration.
Camberwell Green (January 2001)
11.In January 2001 I was asked to provide a Witness Statement for an investigation
that was being conducted at Camberwell Green. This was at the request of POL
(Consignia) under Change Request CR0214 raised by Charles Leighton, then
Internal Crime Manager, Post Office Network, PON Security, on 20 December
2001 (ICL Pathway Change Request (CR0214): ICL Pathway to provide evidence
in a Consignia prosecution case, WITN04600224). The request was subject to a
Change Control Note (ICL Pathway Change Control Note (CCN 910): ICL Pathway
to provide evidence in a Consignia prosecution case, WITN04600216). The
resultant Witness Statement (Witness Statement of Jan Holmes re: Camberwell
Green, WITN04600217) was produced but I do not know what happened to it post-
production or if it ever found its way into Court.
Department of Works & Pensions (January to March 2003)
12.In January 2003 I was notified by Graham Ward (POL) of a series of Audit Data
Extractions that were required by the Department of Works and Pensions to
support a number of investigations in the Coventry region (Email from Jan
Holmes to Colin Lenton-Smith re: Recent DWP Prosecution, WITN04600218).
The resultant Witness Statement (Witness Statement of Jan Holmes re: DWP,
WITN04600219) was produced but as with Camberwell Green I do not know
what happened to it or if it was used.
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Holderness Road (June 2003)
13.On 16" June 2003 a Detective Constable Allen wrote to Peter Sewell (Pathway
Security) requesting assistance with a criminal investigation into the outlet on
Holderness Road, Hull. I do not know how DC Allen obtained Peter’s contact
details but I suspect we accepted the task on the grounds that it was a Police
matter. The resultant Witness Statement (Witness Statement of Jan Holmes re:
Holderness Road, FUJ00121873 ) was despatched to DC Allen under cover
letter (WITN04600219) on 24" June 2003. As with Camberwell Green and the
DWP work I do not know what happened to it or if it was used.
Additional Matters
14.When I left Pathway in May 2000 my responsibilities in all Audit matters,
including audit data extractions, passed to Brian Mooney. When I returned in
2001 Brian Mooney had left and I retained all Audit matters apart from audit data
extractions. This activity had passed to Customer Services, headed by Stephen
Muchow, under the Security function, then managed by Graham Hooper. The
individual conducting audit data extractions and producing supporting Witness
Statements in that unit at that time was Jane Bailey.
15.In the matter of Mr Henry KC. I was under the impression that this Inquiry was
about finding the facts about what happened back in the 1990s and 2000s. This
was reflected in my Witness Statement and questions from Counsel which were
based on my knowledge and the facts applicable to me and my role at the time. I
was not expecting to be taken down a string of ‘what-if’ scenarios that I could not
possibly answer without applying hindsight or speculation, which could raise
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doubts about the decisions and actions actually taken at that time. My knowledge
of the facts at that time were as they were and that cannot be re-written.
16. There were a number of areas where I felt that he used terminology that
devalued what we provided to POL and our efforts in providing it. For example, I
did not “deride” the Expert’s opinion in my Cleveleys report. Scrutiny of
documents (FUJ00121512 & WITN04600206) will show that we expended a
considerable amount of time and effort putting together a challenge to some of
his assertions. An activity that we were asked to do by POL (WITN04600203 &
FUJ00121637 ).
17.His assertion that if Bob Martin was requesting 200 data extractions to
investigate a population of 18,000 outlets and that it must equate to a 1% failure
rate which would be ‘reputationally disastrous to Fujitsu’ is simply incorrect. His
conclusion is invalid since we had no knowledge of what Bob Martin’s
investigations might be about. It could have been missing pencils following a
stocktake.
18. There was a suggestion from him (and from Counsel) that perhaps
I/Pathway/Fujitsu could or should have done more to challenge or query the
volume of POL’s audit data requests, and the use they were being put to. We
were not there to run due diligence over POL’s various litigations and
prosecutions and I’m certain that had we tried we would have been told where to
go in no uncertain terms.
19. Finally, he wanted to take issue with what Pathway provided to POL in terms of
data retrievals and the presentation of data from the audit solution. In June 1998,
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I
in the absence of any lead from POL, I had to instigate correspondence with POL
Internal Audit (and BA who were still involved at that time) in an attempt to get
them to articulate what they wanted and what they were expecting to see in their
retrievals (Letter from Jan Holmes to Hilary Stewart re: Audit Data Retrieval
Scenarios, WITN04600222). Their general inability to specify form, content or
volume, meant we had to make certain assumptions. The retrieval requirements
were eventually captured in the document IA/REQ/002 (ICL Pathway Audit Data
Retrieval Requirements IA/REQ/002, WITN04600223) and included such
information as had been received from POL and BA. His assertion that, and I
paraphrase, ‘we gave the customer what we wanted to give them as opposed to
what they wanted’ is unwarranted and does not reflect the efforts made to
understand what it was they actually wanted.
Statement of Truth
I believe thacSontent.of this.statament to be true.
cm GRO
Dated : 27 foc (2623
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Index to Second Witness Statement of Jan Robert Holmes
No I URN Document Description
1 WITN04600201 Email from Peter Sewell to Jan Holmes re:
Cleveleys
2 I WITNO4600202 Email from Jan Holmes to Jim Cruise re:
Cleverleys — Horizon Equipment
3 I WITN04600203 Note re: Pathway internal response to Expert’s
report
4 I Fusoo121512 Letter from Mr Colin Lenton-Smith to Mr Keith
Baines re: Post Office Counters Ltd v Mrs Julie
Wolstenholme
5 I Fuso0121535 Email from Jason Coyne to Weightman Vizards re:
Post Office Limited v Mrs J Wolstenholme
6 WITN04600206 Note re: Response to The Expert's Reply to Fujitsu
Services’ Submission
7 ‘I FUs00121571 Email from Jan Holmes to Colin Lenton-Smith re:
Cleveleys Update
8 FUJ00121602 Email from Jan Holmes to Colin Lenton-Smith re:
Cleveleys PO Mrs J Wolstenholme
Q I FUs00121637 Email from Jan Holmes to Colin Lenton-Smith re:
Cleveleys
10 I Fusoo121686 Email from Jan Holmes to Keith Baines re: Actions
post Conference Call - Cleveleys
11 I WITN04600211 Email from Keith Baines to Mandy Talbot re:
Wolstenholme case
12 I WITN04600212 Note re: How Post Office Confirmed that Horizon
was fit-for-purpose
13 I WITN04600213 Draft Witness Statement of Jan Holmes for Post
Office Counter Ltd v Mrs Julie Wolstenholme
14 I WITN04600214 Email from Jan Holmes to David Barker re:
Cleveleys WS - Final
15 I WITN04600215 Email from Jan Holmes to William Mitchell re:
Cleveleys
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16 I WITN04600216 ICL Pathway Change Control Note (CCN 910): ICL
Pathway to provide evidence in a Consignia
prosecution case
17 I WITN04600217 Witness Statement of Jan Holmes re: Camberwell
Green
18 I WITN04600218 Email from Jan Holmes to Colin Lenton-Smith re:
Recent DWP Prosecution
19 I WITN04600219 Witness Statement of Jan Holmes re: DWP
20 I FUs00121873 Witness Statement of Jan Holmes re: Holderness
Road
21 I WITN04600221 Letter from Jan Holmes to DC Allen re: Holderness
Road
22 I WITN04600222 Letter from Jan Holmes to Hilary Stewart re: Audit
Data Retrieval Scenarios
23 I WITN04600223 ICL Pathway Audit Data Retrieval Requirements
IA/REP/002
24 I WITN04600224 ICL Pathway Change Request (CR0214): ICL
Pathway to provide evidence in a Consignia
prosecution case
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