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Witness Name: Paul Whitaker
Statement No.: WITN05050100
Dated: 08 October 2023
POST OFFICE HORIZON IT INQUIRY
First Witness Statement of Paul Graham Whitaker
I Paul Graham Whitaker, will say as follows:-
INTRODUCTION
1. I ama former employee of Post Office Limited (POL) and held the position
of Investigation Manager (later renamed Security Manager).
2. This witness statement is made to assist the Post Office Horizon IT inquiry
(the “Inquiry”) with matters set out in the Rule 9 Request dated 31 August
2023 (the “Request”)
3. Firstly, in preparation to providing this statement I was told that under
certain circumstances POL could provide legal assistance to members of
POL staff required to give evidence to the inquiry. I have been told that I
meet the criteria for such legal assistance however I am yet to approach
any legal firm in respect of this and make this statement without any legal
assistance.
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Secondly, on receipt of the Rule 9 request dated 31 August 2023 I noted
that a response was required by 28 September 2023. I immediately
informed the inquiry that during that period I would be out of the country
for much of September and unable to securely access the information
sent to me by the inquiry to support my statement, nor have facility to
write my statement. In all I have ‘lost’ 19 days. I had also made the inquiry
aware of this when they had firstly asked for my ‘dates to avoid’ some
weeks before.
Whilst I thank the inquiry for the seven-day extension granted to me, I feel
that I must point out that this statement has been prepared under those
circumstances.
BACKGROUND
6.
I joined Royal Mail in July 1985 as a postal cadet in Sheffield. From 1986
to 1994 I worked as a postman delivering and processing mail within the
Sheffield area. Between 1994 and 1998, within the Royal Mail Letters
function and based in Sheffield, I worked in a section of the organisation
which dealt with the function, administration, and inspection of postal
franking machines.
In September 1998 I joined the Post Office Security and Investigation
Service (POSIS) as an Assistant Investigation Officer and was placed to
work in its Parcel Group (North) section which was based in Royal Mail
premises in York Place, Leeds.
At that time Royal Mail was essentially operating as three separate
entities (Royal Mail Letters (RML), Post Office Limited (POL), and
Parcelforce) under a Royal Mail Group corporate head. RML and POL
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each had their own investigation function, but Parcelforce did not. As such
at that stage, as well as dealing with corporate investigations, POSIS had
Parcel Group sections which dealt with investigations into crime within the
Parcelforce network.
9. Onjoining POSIS I recall that I had an initial period of induction training
which covered relevant aspects of investigation, e.g., law, principles of
investigation, evidence gathering, PACE etc, before being assigned to an
established officer for ‘on the job’ training. Further training modules were
completed over the following year in subjects such a witness interviewing,
and suspect interviewing etc. As I recall I received no specific training to
do with POL work at this time, as, within parcel group I was not expected
to undertake or assist with any POL investigations.
10. In 1999 Parcelforce introduced its own investigation function, and in
September of that year POSIS Parcel Group (North) was disbanded. Its
operational staff in Leeds were then compulsorily transferred to different
Royal Mail investigation functions. Some staff went into Parcelforce, and
others to Royal Mail Cashco (the Royal Mail Groups cash carrying
function). Despite having a background in mails work and no previous
POL experience, I was sent to work for POL, initially based at their
regional headquarters in Leeds in September 1999.
11. [had no say whatsoever in where I was placed at this time.
ROLE & HEIRARCHY
12. IIworked as an Investigation Manager (later named a Security Manager)
for POL from that time until around 2009 or so when I briefly, (a matter of
two months or so), took over as Temporary Team Leader for the South
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Investigation team of POL Security before soon returning to my role as
Investigation manager. I left POL in January 2012 and took up a job as an
Investigation Manager with RML.
Shortly before I joined I understand that POL Security had recently split
into three operational areas (East, West and North). Working within the
North Area, staff at the Leeds office generally dealt with investigations in
the North Eastern counties of England. I joined an investigation team with
another assistant investigation officer (John Downie, though we had both
now been renamed Investigation Managers) and an Investigation
Manager (John Hart) who was more senior in experience. The Leeds
office also contained some investigation support staff. I recall that a
further investigation manager was based in Tyneside, and they assisted in
work in that area. We were all expected to undertake and lead
investigation cases of our own as well as assist colleagues in cases that
they were leading.
Above us in the hierarchical scale was a team leader, Les Thorpe, based
in Peterlee whom I and the other investigation managers reported to. I
believe that he then reported to a senior investigation manager based in
Glasgow (Rashid Sarwar), who then reported to the North area Head of
Security, (Duncan McFadyen) who was also based in Glasgow.
At that time the Security Department within POL was split into Physical
Security and Investigation Departments. Physical Security being
responsible for the provision of external security apparatus at Post
Offices, (Safes, alarms, barriers, security audits etc.) with the Investigation
department responsible for the investigation of suspected criminal losses
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to POL. Until very late in my time at POL which I will touch on later in this
statement I performed duties only within the Investigation team and do not
recall with any certainty the hierarchy within the physical security team
from this early period.
Soon after I joined POL, perhaps around a year later, the security function
within POL began a period of rapid change. The investigation function
was streamlined and tinkered with a number of times. There were
numerous geographical boundary changes and changes of management
personnel and structure. I recall that in terms of hierarchy during the
period around 2000 to 2007 or so, Tony Marsh headed the POL security
function with Phil Gerrish as his Head of Investigations. Below Mr Gerrish
was a regional (north/south) Senior Investigation manager and below
them were localised team leaders. At the bottom of the pyramid were,
Investigation Managers of which I was one.
Throughout this time, I was based in Sheffield and worked on
investigations in the North of England. Alongside me in the Sheffield office
around this time was Helen Dickinson, Kim Abbotts and latterly Helen
Hollingworth (Rose). We tended to work together leading our own
investigations and supporting each other where required.
During this period the team based in Sheffield saw a number of changes
of manager, none of whom were based with us on site but we saw them
regularly and remained in contact via email and telephone. Two of the line
managers I recall from this time were Trevor Lockey, and Paul Dawkins.
Around 2007 or thereabouts I recall that Tony Marsh moved from Post
Office Limited to become Head of Royal Mail Group Security and soon
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afterwards Phil Gerrish left to join Royal Mail Letters as Head of
Investigation. John Scott who had been Head of Physical Security at Post
Office Limited became Head of Security. Mr Scott oversaw a period of
change in Post Office Security as he tried to bring the investigation
functions and physical security functions together to streamline the
department. During this period, a number of investigation colleagues left
POL, many of whom followed Mr Gerrish to Royal Mail Letters. I feel Mr
Scott replaced these people with members of staff with more of an
expertise in physical security, with staff displaced from other POL
departments, or with staff recruited from outside of POL.
The team in Sheffield were relocated to POL premises in Future Walk
Chesterfield in around 2009. Mr Scott had ordered that all localised teams
should be brought together into POL premises and the premises the team
used in Sheffield were owned by RML. As such around 2009 we who had
been in the Sheffield office joined POL Investigation Manager, Chris
Knight in Chesterfield. At that time, again there were many changes to
personnel in the wider department, and as I didn’t work in Physical
security I cannot recall with certainty the hierarchy under Mr Scott at this
time.
I recall that Mr Scott had a number of Senior Managers, but their remits
and jobs changed regularly. Some of the senior managers I recall from
this time were John Bigley, Tony Newman, Andy Hayward, lain Murphy,
and Dave Pardoe however, as said, I do not recall their specific roles at
specific times, as they often quickly changed.
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Around the time Mr Scott headed the department the geographical remit
changed again and I along with other investigation managers began to
work on investigations across the whole of the country, into Scotland and
Northern Ireland.
I feel that Mr Scott focused more on bringing to POL Security a data
driven model to proactively analyse and seek out risk and loss within post
offices as opposed using the POL investigation team to investigate losses
reactively. Mr Scott brought in much more data analysis in his loss
management strategy and set up a dedicated team to do this, I recall
Helen Rose being part of that team but unfortunately cannot recall other
names.
Mr Scott also brought in a team to try to recoup losses through the
proceeds of crime act and some investigators were trained as financial
investigators. From memory, I recall that these included Ged Harbinson,
Graham Ward, Helen Dickinson and Paul Southin.
Shortly before I left POL, perhaps around 2011 I recall that Mr Scott
stated that he was making the role I was in a dual skilled role combining
aspects of both physical security management and investigation. I
considered myself to be an investigator, I enjoyed that type of work and
the world of physical security did not so much appeal to me, so when a
role was advertised I left POL in 2011 and moved across to Royal Mail to
work as an Investigation Manager.
Throughout my time with POL, I viewed that my role was to investigate
potential criminal offences committed against POL or through POL. This
consisted, in the main, of investigating theft and or fraud offences that had
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been facilitated through a post office. Often by an employee or agent of
POL but occasionally not. Potential offences were mainly facilitated
through Subpostoffices, but occasionally Branch Offices or Cash Centres.
I am not aware of any policies regarding if or how POL treated Crown
Office Employees differently when it came to investigating potential
offences. As far as the work I was asked to do, everyone was treated the
same, be that if they worked in a branch or crown office .
I felt that within the tenure of Mr Marsh as Head of Security I found the
line management within POL investigation to be supportive and
experienced, with many of the mangers having come through ‘the ranks’
as it were. They knew the Investigators role and the challenges it brought.
However, I feel that when Mr Marsh, and others left POL, my line
management under the leadership of Mr Scott, though reasonable
insomuch as they were someone to manage staff, many lacked the
experience and understanding within the investigation and criminal justice
fields. Managers I remember and consider in respect of that statement
were Andrew Daley and Alison Drake.
Immediate line mangers were involved day to day and knew such things
as your general whereabouts, your caseload, and what work you had on
at any given time. As said more often than not my manager worked
remotely from me but we met regularly in Team meetings (probably once
a week) to discuss what work was scheduled for that week, and also I
would phone/email them and they would phone/email me should anything
crop up which either party felt was relevant. I would say that my line
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manager had good oversight of what I was doing though left me to
progress my work day to day.
Cases were regularly discussed with line managers and idea's relating to
the progress of cases were exchanged not only with line managers, but
also amongst my peers within the immediate team. Often reports and
paperwork were sent to a manager for review before submission.
In regard to complaints about the conduct of an investigation by POL
security I do not specifically recall the process by which it would be dealt
with. I do recall there being accountability though I am unsure of the
actual process.
TRAINING
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At the time of joining POSIS I had no formal specific investigation
qualifications. However, whilst working for POL, around 2006 I completed
a Level Four National Vocational Qualification in Investigation
Management. Most of my training to that point was ‘on the job’ shadowing
and being supported by a more experienced colleague. Before I left POL
in 2010 I had begun a Post Graduate Diploma in Security and Risk
Management at Leicester University which I subsequently completed
whilst working for Royal Mail.
Whilst in POL I feel that the training in respect of the investigation role
was adequate, and we were trained to a reasonable standard in
investigation skills, and any specific major change to the law, policy, or
techniques would be dissipated through training courses. As said, many of
the skills were developed using ‘on the job’ training as initially you were
normally placed with a more senior colleague who would assist and guide
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you through your early investigations. Through time and experience you,
needed them less and less before you then became the colleague who
would assist others.
The specific investigation training I had received and used in POL had
been given to me whilst I was in POSIS parcel group. This had consisted
of class room training modules spread across my first year with practical
applications as I used the skills taught in my day-to-day work. I recall
attending training courses covering suspect interviewing, witness
interviewing, searching, and report writing. Throughout my time with POL I
recall the odd ‘refresher’ training course on these matters and others.
Further comment, specifically on disclosure training and assembling files
for crown court use is discussed later in this statement.
As said, when I assumed my role in POL investigations I had no previous
experience of working behind the counter at a post office. Soon after I
joined POL I recall being placed on ‘counter clerks’ training, which was a
couple of weeks training on an induction course designed for new entrant
POL counter clerks. The course was for people to familiarise themselves
with the counter clerk role and the working practices of POL prior to
working in a post office. At that time Horizon was yet to be introduced and
on the course I learned about post office stock balancing using a cash
account book. I never considered myself an expert in this work as I, had
no background in counter work, did not use the methods enough, and I
always felt that anyone who used the systems and practices on a daily
basis would have far more expertise in them than I would.
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Specifically in respect of Horizon training, I recall going on a training
course over a week or so as the system was being introduced. I cannot
recall any other training I received on the system. I do recall however that
the course I attended was not specifically for investigation staff as I
remember being on the course with other post office staff, including some
Subpostmasters.
In regard to policies within the POL Security function. I can state that I
was not involved at all in the development, setting, or management of
policy. This was done at a more senior level than that which I was
throughout my time with POL.
Also, I don’t recall there being a ‘central repository’ or such where
investigators could specifically view policies. The dissemination of
information contained within policy, as I recall and understand, was mainly
through, training, team meetings, and special directives called
‘Investigation Circulars’ which would be sent via email to investigation
staff.
A number of pieces of legislation governed my role as an investigator.
These included POL policies but also such things as the Police and
Criminal Evidence Act codes of practice, the Criminal Procedures and
Investigations Act, Human Rights Act, and as time went on in POL the
Proceeds of Crime Act.
In the run up to the separation of POL from the Royal Mail Group I do not
recall being involved in the development of investigation policies for post
separation.
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Regarding development of policy, I have been asked to consider,
Separation Project- Criminal Investigations Policy for Post Office Ltd,
(POL00104900), and Activity Plan for POL separation project - Criminal
Investigations Policy, (POLO0105191), in my reply. Looking at the
documents it appears that I was part of a working group looking at ‘inputs
and outputs for investigation procedures’ post separation. Whilst I vaguely
recall being part of a focus group with the other people named on the
document, I don’t recall anything specifically discussed within it, nor how
many focus group meetings I attended.
Audit and Investigation
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In respect of Audit and Investigation, I have been asked to describe my
involvement with ‘Second Sight’. I can state that I am not aware of what
that is so can only conclude that I have not been involved in any way.
Though separate departments with POL the Investigation team worked
very closely with the Audit team.
I never worked for the Audit Team so cannot fully describe their remit
however I understand that the Audit team were there to verify reported
POL assets within a post office against what was actually there. As I
understand it the audit team had a schedule of post offices they would
visit. This schedule was based on auditing each post office over a period
of time, but I understand that they also used a risk matrix within that to
bring audits of particular offices forward if necessary. Also, investigators
could contact the audit team scheduler in order to request an audit of a
particular post office if required. As I understand it subpostmaster’s or
branch managers never knew when the auditors would attend.
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I recall that there were probably two reasons for an investigator to attend
an audit. Firstly, when the lead auditor of the attending audit team had
identified an issue with the audit they were performing at a post office.
Usually this would be a difference or expected difference in what the
auditor had verified in the post office account as to what had been
declared by the person completing the account balance. I cannot recall if
there were specific amount triggers in regard to whether the auditor would
call or not. I do recall that towards the end of my time in POL Security
there was a trigger that we would not investigate losses below £10,000,
but do not recall precisely when that came in.
In such an instance where there was a significant shortage, on discovery,
the auditor, or members of the audit function would make phone calls to a
number of people, including the investigation team.
In practical terms from my experience this would probably mean that the
audit team called the investigation team local to where they were
conducting the audit and reported that a shortfall was to be expected in
the post office accounts of the branch they were at. This information was
quickly disseminated to the respective investigator by their line manager
who had designated them to investigate. If it was me I would then call the
auditor, who was still on site to discuss their reported findings, and as a
result, if the situation had not been resolved, then more than likely I would
attend the Post Office.
Also, as we worked closely with the audit teams often they would call us
directly to discuss their findings. I would then upwardly report what I had
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been told to my line manager before travelling to the affected post office if
I felt it necessary.
On these occasions, on attendance, if I was the designated lead
investigator I would generally speak with the auditor to establish if there
had been any developments since their phone call to me and then speak
with the Supostmaster or whomever was in charge of the post office. I
would explain who I was, what my role was, and why I was there.
Once it had been established that evidence from the audit suggested a
criminal offence may have been committed I would try to establish a
potential suspect. To do this I would try to gather evidence to verify who
had produced the most recent office balance, (perhaps the one from the
day before) or cash declaration and who had signed the previous office
balances. From examining previous cash accounts held on site I may try
to look to see approximately when the declared cash holdings of the post
office had been close to what POL said they should be. This might be an
approximate indicator of a date when things perhaps could have started to
go awry at the post office.
Depending on the individual situation, such as size of the office, amount of
people there, their demeanour, room behind the post office counter etc. I
would then either observe proceedings or leave the office to get out of the
way. My intention at that point would have been to let the auditors get on
with the audit until they had finished. I would not take part or assist in the
audit in any way, as that was not my role.
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Though not always, many times, using the process described in the
preceding paragraphs it was the Subpostmaster whom I felt I had
reasonable grounds to suspect may have committed a criminal offence.
Investigators, in such circumstances, were encouraged by POL Security
to gather evidence by way of an early interview of the suspect. As such I
would invite the subpostmaster to give an early account of the
circumstances as to why their office was found to be short.
In order to do this, I would invite the person suspected to an interview and
explain the circumstances of the interview. I would explain that they were
suspected of committing a criminal offence. We carried portable interview
tape recorders and copies of the Police and Criminal Evidence Act codes
of practice, and the interviews were carried out on the premises or in the
home of the subpostmaster, (though always somewhere private).
Before commencing the interview, I would explain that during the interview
they were entitled to have a solicitor present should they wish and also
they could have a ‘Post Office friend’ present which could be the local
National Federation of Subpostmasters representative or other official of
the recognised union for the grade/position that they were.
The interview was always voluntary. Present always was the lead
investigator and another investigator who was the support (second)
officer.
I tended to use a script in order to ensure that I accurately covered off the
criminal caution and suspect's legal rights once the interview tapes were
running. Sometimes solicitors would attend, or arrangements would be
made to postpone the interview until a time a solicitor was available,
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however my experience was that in the majority of interviews the suspect
chose not to have a solicitor present. I would not give the suspect any
advice in regard to whether they had a solicitor or not.
Similarly, sometimes the local representative of the National Federation of
Subpostmasters attended and sat in on the interview. Whomever was or
wasn’t present it did not affect how I undertook the interview.
In the interview I attempted to obtain evidence in regard to the
circumstances of the loss and gather any relevant evidence which had a
bearing on the investigation. I would present the suspect with what was
known at that time and the tapes would record their evidence. I’d ask for
an initial account of why the auditors had found such a discrepancy and if
appropriate challenge the answers given.
After the interview, its content would be reviewed, and reasonable lines of
inquiry identified and investigated further before the case and evidence
were submitted for a charging decision. I recall that we were bound by
timescales for completion of a casefile, and though I can’t recall the
specific timescale I seem to remember it may have been two weeks or
thereabouts from interview to the expected date that the file was
submitted for charging advice.
The second reason I would have attended a Post Office was if I'd asked
the auditors to attend a particular post office as it was under investigation .
In order to gather evidence, I may have required an audit of the Post
Office accounts.
If this was the case I would schedule the audit for the morning after the
office had produced a balance and arrange for the audit team and
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members of the investigation team to meet somewhere close to the post
office beforehand in readiness to attend the post office before it opened
for business the following day.
In such cases I would have briefed the audit team as to any suspicions I
may have had in regard to potential places of discrepancy within the post
office account.
Once at the post office I would introduce myself, other investigators, and
members of the audit team. I would tell the subpostmaster, or person in
charge, that I had called the audit of the office and ask that they give the
auditor their attention for the time being and I would speak with them at
the end of the audit.
Again, I would not take part in the auditing process at all, but once the
audit was completed, the process for interviewing a suspect, if necessary,
tended to be the same as noted in the previous paragraphs.
Other than the identification of potential suspect(s) I was not involved in
further decision making beyond reporting my findings whilst at the post
office. If anything of significance happened whilst at the office I would try
to inform my line manager and, if relevant, the Subpostmasters line
management as they were the ones who would be making decisions
regarding the provision of service to the public from the affected post
office branch.
Furthermore, in terms of later decision making, I believed my role to be
one of evidence gatherer. I was not involved in decision making in regard
to criminal charges, prosecution, or accepting a plea at court. I was not
aware of any test which may have been used, or what legal advice was
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available to people making such decisions. I presented the evidence I had
gathered from various sources, provided some analysis of that evidence
in my report, and sent it off to others for further decision making. I had no
‘final say’ in what happened with the case.
68. Neither was I involved in the termination or not, of subpostmasters
contracts. I recall that on completion of an interview, and submission of a
case file I would have to provide a ‘discipline’ report which essentially was
the report that I had produced for the prosecution decision but with just
the facts detailed, and no unsubstantiated observations. The contracts
manager then made their decision on contract issues using this discipline
report and whatever else they wished to use.
69. Towards the end of my time with POL security it encouraged used of the
Proceeds of Crime Act in order to recoup losses. Most of the work done in
respect of this was by POL’s in house Financial Investigators who would
pursue this aspect of cases. Practically for investigators such as me it
would mean such things as completing an authority signed by the account
holder for the release of information from their bank, through to performing
a search when attending the subpostoffice in order to identify possible
assets, bank accounts, property, and the like.
70. Such searches were always performed with the signed written consent of
the suspect and documented accordingly.
INSTRUCTIONS/ GUIDANCE GIVEN TO INVESTIGATORS
71. In respect of the Casework Management Document (version 1.0, March
2000), (POL00104747) and Casework Management Document (version
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4.0, October 2002), (POL00104777), I do not recall being provided with
either document.
My understanding of the 2000 guidance on page 2, at the second, third,
and fourth bullet points is that POL Lawyers would have the ultimate say
on disclosure. Secondly, that as an organisation, within disclosure, care
should be taken as evidence and unused material may contain perhaps
commercially sensitive information that should not be in the public
domain. An example of which, and relevant at the time the guidelines
were produced, was the Benefits Agency and POL processes for payment
and checking of benefits payments through a post office. This was
commercially sensitive and perhaps should not have been in the public
domain. This sort of thing, I feel is what the phrase within the guidance
‘maintaining good industrial relations’ perhaps refers to. POL provided
services and an access point for many secure products and services, and
I feel that the guidelines refer to consideration of this when taking cases
though court.
I do not however feel that this was relevant to it commercial relationship
with Fujitsu in respect of any known bugs, failures, or glitches in the
Horizon system. I strongly feel that these should have been disclosed at
as soon as they were known of.
In regard to case file compliance, from the outset of my time investigating
for POSIS compliance in regard to cases which would require a
prosecution decision was strongly advocated by POL Legal Services and
senior members of staff.
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My understand was that these files should be complaint as they presented
the evidence for consideration of criminal offences and were the basis of
cases which may end up being progressed through the criminal courts.
Compliance ensured that required information was set out in the files
uniformly across POL, and Royal Mail, and that particular items within the
file were in a common place where they could be routinely found by others
processing the file.
Towards the end of my time with POL I recall there being a push on
compliance, I do not specifically recall the precise reason, and I do not
recall being involved in the development or introduction of the process,
however I can only think that compliance in respect of files submitted for
prosecution decision may have slipped to an unacceptable level, bringing
in this renewed push.
I recall that in this process a compliance check list was sent out and files
were scored against the check list by a compliance manager, whom I
recall to be Ged Harbinson at the time. Mr Harbinson would score the file
and would send the file back to the investigator if it did not attain the
required compliance percentage score. I recall that the investigators line
manager would also be copied in to Mr Harbinson’s findings. I do not now
recall what the required score compliance percentage score was.
In regard to my understanding of Para 2.15 of Guide to the Preparation
and Layout of investigation Red Label Case Files, (POLO0118101) I would
say that any failing of the types identified in the document should be
drawn to the attention of the prosecution decision maker in the report by
the investigation manager highlighting them in bold type.
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Similarly, should a matter be progressed through the criminal courts it
would be reasonable to expect that matters highlighted in this way would
be included on the relevant disclosure schedule. If there was evidence of
Horizon system bugs errors or defects I feel that this evidence would
clearly be relevant to the case and would pass the disclosure test in that it
would be reasonably considered capable of undermining the prosecution
case or assisting the defence.
Moving to my consideration of the document ‘Identification Codes’
(POLO0118104). I was not involved in drafting that document nor have
any idea who did. I don’t recall seeing that document prior to its recent
inclusion in the public inquiry documents. Many of the terms used in that
document appear to me to be offensive and outdated.
I recall as an investigator being required to include identity codes in
casework reporting and always believed it to be a requirement of POL or
Royal Mail Groups obligations as a non-police criminal investigation body
in recording of crime data and statistics to the police. We were also asked
to provide antecedent information about suspects which I viewed in the
same way as a form of ancillary information we were required to obtain for
an outside party.
I recall that in order to provide the identity code information required for
reporting there was a document I used listing established Police ‘IC’
codes, but that document was not POL00118104, nor did it contain the
terms listed in POLO0118104.
I recall that in order to provide that information, after an interview I would
tell the interviewee that I had some administration tasks to complete and
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84.
85.
86.
87.
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ask some basic antecedent questions. I would show them the document I
used listing the codes or go through its contents verbally and ask them
what they considered themselves to be from the list of Police IC codes. I
would then record their answer for use in the report.
It is difficult to state what analysis was done by investigators of Horizon
data when someone attributed a shortage to Horizon. It depended on
what had been said during the interview. If someone had stated that a
loss had just appeared and offered nothing else, it was difficult to begin to
find a place to start any analysis.
I can’t specifically recall the steps I would have taken but if the
subpostmaster could provide any relevant information about the loss
being as a result of a particular product, or transaction, then I feel that
some analysis would have been done in the area named.
In regard to analysis, I always viewed that my personal role was not to
provide intricate analysis of systems and usually I would ask someone
better qualified, perhaps a representative of a particular product within the
National Business Support Centre, a POL security analyst, or on
occasions Fujitsu representative to perform analysis.
I would do some basic analysis such as comparing cash on hand figures
from previous cash accounts or declarations, examination of error notices,
looking at transaction corrections, or when it was relevant, physically
counting pension and allowance dockets against the declaration and the
like, but beyond this level of analysis I recall that I would tend to seek
expertise from elsewhere. If required I would then ask that this evidence
was presented in a statement.
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88.
89.
90.
91.
92.
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I recall that early on after Horizon was introduced we had to send away for
Horizon information though I can’t recall who would provide it. However,
towards the end of my time at POL, remote access to Horizon information
via a portal on our computers was introduced where information could be
downloaded directly to us.
Through my career with POL, I did not hold positions where I was privy to
the contractual arrangements between POL and Fujitsu.
I cannot recall arrangements between POL and Fujitsu in respect of the
provision of ARQ requests, though I do not feel that they were provided as
a matter of course for losses attributed to an unexplained Horizon
shortage. I vaguely recall also that Fujitsu may have charged POL for
provision of some ARQ information after a certain number of requests,
however I don’t not recall what the number of requests before that cost
began. Also, I don’t recall that I ever consciously considered this in any
ARQ request I might have made.
I recall that ARQ data might be required if a case was committed for trial
following a ‘not guilty’ plea at magistrates court. It may have been
requested at this stage perhaps by the reviewing lawyer in their advice. If
this ARQ data was part of the evidence then I feel that it would be
disclosed to the Subpostmaster’s legal team at the relevant point prior to
the trial as part of the evidence.
That said I feel that in investigating cases, if it sufficed, I often would be
satisfied with a ‘catch all’ statement to say that that the Horizon system
was in good working at the time and did not throw up anomalies. If then
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93.
94.
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directed to obtain something in more detail by Legal Services I would go
ahead and obtain whatever they had requested.
In regard to contact with individual Fujitsu personnel I recall that requests
in to Fujitsu from POL security were facilitated initially by a single point of
contact. From reading documents provided I remember from my time with
POL, Andy Dunks being a representative of Fujitsu who would be called
on to assist in prosecutions, however beyond this I cannot recall any other
Fujitsu employee name.
lam aware of Gareth Jenkins name, but again this would be through the
documentation provided by the inquiry. I do not recall any specific
dealings I had with him or if he gave evidence to support any investigation
or prosecution I was part of whilst working for POL.
RELATIONSHIP WITH OTHERS.
95.
96.
97.
I recall dealing with Cartwright King Solicitors in their role as a prosecuting
agent of POL in the midlands area. I think they prosecuted a case I had
taken over after an investigator in the Midlands had left POL. This case
was prosecuted through Birmingham Magistrates court, and I cannot
recall anything about it other than this. That, I believe, was my only
interaction with Cartwright King.
As touched on earlier in my statement, I had regular engagement on a
one-to-one level with local representatives of the National Federation of
Subpostmasters when they represented their members in criminal
interviews that I was part of.
Their reps regularly sat in on interviews involving federation members.
Quite often they would speak with their members beforehand and/or
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98.
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during a break in the interview. I never promoted or facilitated these
meetings, however I did not object to them taking place if they and the
suspect wished to confer.
I was never present during these exchanges and would always excuse
myself from the room or let them use another room if available until their
private conversation was over. Following this, on restart of the interview I
would explain on tape what had happened in the interview break and
resume the interview.
POL v Lee Castleton
99.
100.
101.
102.
From memory I do not recall any involvement with events surrounding Lee
Castleton. The documents I have been asked to consider Marine Drive
Post Office Summary of Events, (LCAS0000699), Audit report Marine
Drive Post Office, (POL00082391_004), Letter from Cath Oglesby
confirming Mr Castleton’s suspension, (POL0082391_002), and witness
statement of Cath Oglesby (LCAS0000609) indicate that I spoke with
Catherine Oglesby in regard to shortages Mr Castleton was experiencing
at the Marine Drive post office in early 2004.
It looks like Ms Oglesby contacted me for advice, and I told her that, as Mr
Castleton had engaged with retail line management from an early stage,
declaring losses to her, and working alongside her to establish a cause for
the losses, I felt this was not a matter for criminal investigation.
As said I do not recall this exchange, but it appears consistent with advice
which I may have given.
Based on what is contained within the provided documents, if this
information was disclosed to me by Ms Oglesby at the time I feel that my
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decision would have been based on the fact that as soon as things
appeared to have begun to go awry in the accounts of his Subpostoffice
Mr Castleton immediately contacted his line manager, gave full disclosure
of events, invited her scrutiny, and began an open dialogue with her in
order to attempt to resolve the issue.
103. In doing so it appears that there was no ‘mens rea’ or ‘actus reus’ in
respect of his actions, and this is what I may have explained to Ms
Oglesby at the time leading to her report of our conversation.
104. In respect of the conduct of this situation, from the reports provided it
appears that Ms Oglesby explored Mr Castleton’s reasons for the
shortages in his branch and attempted to work with him. She put in
measures to try to establish the cause of the losses and if another
subpostmasters using the same hardware would experience the same
results. When that didn’t happen, and I am presuming Ms Oglesby was in
receipt of the conventional thinking of the time within POL that Horizon
was robust and infallible, her decisions and actions appear reasonable on
the balance of probabilities, under the known circumstances at the time.
105. Concerns I have about the conduct of this matter now are that the
Horizon system was not robust, nor infallible so Mr Castleton’s claims of
spurious transactions were sadly not believed, and he and his family
suffered tremendously as a result.
PROSECUTION OF ALLISON HENDERSON
106. From memory I have little recollection of the prosecution of Allison
Henderson other than I recall travelling to Norwich with Christopher Knight
towards the end of my time with POL in order to assist as support officer
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107.
108.
109.
110.
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during an interview with a subpostmaster. On reading the supporting
documents provided by the inquiry, I can state that:-
I may have been aware of the case through general chat in the
investigation office in Chesterfield where we were all based. Mr Knight
was the lead officer for this case and would have probably asked the other
investigators present in the office to assist in his interview of Ms
Henderson.
I don’t specifically recall the event but presumably Mr Knight would have
made the decision to interview Ms Henderson as it was normally the lead
investigators decision to do so.
I would have volunteered to support him for no other reason than I had
time in my schedule. I don’t think I would have been directed by
supervision to assist Mr Knight, nor do I feel that it was it felt I was any
more qualified or experienced to deal with the matter than anyone else. It
would have been simply that I was free to do it.
As support officer in the interview (sometimes called second officer), my
role was to support the lead officer on the day, and particularly in the
interview. I don’t recall a specific remit for support officer, but they may be
called upon to set up the interview equipment, perform introductions in the
interview, cover certain points or subjects within an interview, monitor the
tape recordings and timings, take notes if required, basically anything that
the lead investigator instructed them to do. Different lead investigators
asked different things of their support officer and I don’t specifically recall
anything Mr Knight asked of me.
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111.
112.
113.
114.
115.
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Prior to the interview with Ms Henderson, I do not recall being involved in
the case at all. That said, generally the lead officer and support office
would have a briefing of some kind beforehand in regard to an interview,
and I would imagine that this happened, however I do not specifically
recall it.
I do not recall was said in the interview at all however I do not dispute
what is detailed about the interview in the Investigation Report
(POL00047 152) Witness statement of Christopher Knight (POL00055458)
or Record of the Taped Interview Summary (POL0054407)
During the interview I don’t recall what was shown to Ms Henderson,
however I do not dispute the record of POL0054407 and Investigation
POL0047152 both of which were written closer to the interview date and
both of which detail items shown to her. That said, with POL0054407
being only a summary of the interview I cannot say if what is listed on
there is absolutely everything shown, or not.
In respect of Ms Henderson’s allegations about the reliability of the
Horizon system, to the best of my knowledge I was not aware of any
issues brought up by her beyond what is report in the aforementioned
documents. Also, again to the best of my knowledge I was not involved in
any decision making in respect of Ms Henderson, nor did I have further
involvement in this case.
In regard to the investigation of this case appears to be the same as other
cases from around that time and taken forward based on what was
accepted at the time. The way it appears to have been investigated and
prosecuted does not differ from many others from that period. Based on
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the evidence at the time, false accounting charges were admitted with no
evidence offered on other charges. Following the discovery that the
Horizon system was not robust and accurate this case, as with others, has
subsequently been overturned or quashed. I fully support this course of
action and express regret at the treatment Ms Henderson and her family
experienced from POL as a result of these events.
PROSECUTION OF ALISON HALL
116.
117.
118.
119.
Similarly, to my comments in regard to the prosecution of Alison
Henderson, from memory I have little recollection of the prosecution of
Allison Hall. I recall travelling to a solicitors office in Cleckheaton with
Christopher Knight in order to assist as support officer during an interview
with a subpostmasters but little else.
On reading the supporting documents provided by the inquiry, I can state
that Mr Knight may have asked me, or I may have volunteered to attend
as his support officer, I do not believe I was attached to the case through
any particular knowledge or perceived expertise that could be specifically
useful in the matter.
I do not recall being involved in the case at all beyond my attendance as
support officer in the interview. Normally the lead officer in the case
makes the decision on who to interview, so I would surmise that Mr Knight
made the decision to interview Ms Hall.
Again, I do not particularly recall the interview, nor what was shown to Ms
Hall during it however, I do not dispute the transcript of interview on 28
September 2010 (POL00021252), Investigation Report (POL00091037)
and List of Exhibits (POL00091065) which details such items.
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120.
121.
122.
123.
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In respect of Ms Hall’s allegations about the reliability of the Horizon
system, to the best of my knowledge I was not aware of these at the time.
Also, again to the best of my knowledge I was not involved in any decision
making in respect of Ms Henderson, nor did I have further involvement in
this case, beyond making the statement shown at page 13 of the Witness
List (POL000911149) which I would imagine Mr Knight would have asked
me to provide.
Considering paragraph 12 of Alison Hall’s Statement (WITN01450100) I
would observe that I cannot recall being present at an interview with Ms
Hall, Sue Muddeman and Mr Knight at Leeds Post Office headquarters
and the investigation team would not normally attend meetings such as
the one described. The interview Mr Knight and I undertook with Ms Hall
was recorded and documented in POL00021252 at her solicitors office,
and can only feel that Ms Hall may be mistaken in respect of the
attendance of Mr Knight and I.
In regard to the investigation of this case appears to be the same as other
cases from around that time and taken forward based on what was
accepted at the time in regard to the Horizon system. The way it appears
to have been investigated and prosecuted does not differ from many
others from that period. Evidence relating to False accounting charges at
the time was admitted, with no evidence offered on other charges of theft
and the like.
Following the discovery that the Horizon system was not robust and
accurate, convictions from this case, as with others, have rightly been
quashed, and once again I fully support this course of action. As with Ms
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Henderson and indeed all persons affected I express regret at the
treatment Ms Hall and her family experienced from POL as a result of
these events.
Prosecution of David Blakey
124.
125.
126.
127.
128.
Due to the length of time since these matters my recollection is limited.
However, from memory and examination of the provided documents
relating to this matter I can state:-
The document Investigation report dated 25" May 2004 (POL00044818)
describes the circumstances in which I first became involved in Mr
Blakey's case. My role was that of officer in the case, or lead investigator
in the case, and to the best of my knowledge I don’t recall any
involvement with the case prior to the phone call I received on the
morning of 13 May 2004.
I attended Riby Square post office that morning, as, based on what I'd
been told, I suspected a criminal offence may have taken place and it was
part of the remit of my job to investigate this matter.
I do not specifically recall the content of any conversations with the
auditors that morning beyond what is reported in POL00044818.
I would have made the decision to interview David Blakey more than likely
based on information I had received from the auditors, namely the
anomalies in the accounting at the subpostoffice, and the brief statement
Mr Blakey had provided to them that morning where he admits to knowing
of the loses, and covering them up in the accounts. It appeared to me that
a criminal offence had been committed and I had reasonable grounds to
suspect Mr Blakey of committing it.
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129. Though I cannot specifically recall what documentation I considered
before interviewing Mr Blakey it would appear from POL00044818 that I
considered previous cash accounts, and the written statement which Mr
Blakey had given to the auditors that morning.
130. I am content that the records of Mr Blakey's interviews on 13 May 2004
(POL00044830 and POL00044831) detail what documents were shown to
Mr Blakey in his interview. I have no recollection beyond this.
131. I was not aware of specific allegations made by Mr Blakey relating to the
reliability of the Horizon system. During his interview Mr Blakey said that
losses at Roby Square had been steadily climbing and he was unaware of
a specific reason, but he had been covering up the losses in the office
accounts that had been submitted to POL. As far as I recall , he did not
directly call into question the reliability of the Horizon system at that time.
132. As documented in POL00044818 and the Summary of Key Points from an
interview with Gillian Blakey (POL0044830) Along with Helen Dickinson,
Investigation manager, I interviewed Gillian Blakey immediately after
interviewing Mr Blakey. I cannot recall specifics of the interview, and do
not recall anything further than that detailed in POL0044830, but I have no
reason to question the details of the interview contained in those
documents.
133. I do not recall interviewing Shirley Blakey however POL0044830 indicates
that on 24 May 2004 Helen Dickinson and I spoke with her. I am content
that what is reported reflects the content of the interview.
134. Similarly, I have vague recollections of conducting interviews with other
Riby Square staff during the course of the investigation, however I cannot
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135.
136.
137.
138.
139.
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recall specific details of what was discussed. These interviews are
reported and summarised in POL0044830, and I have no reason to
question the information contained within the report.
As detailed in POL0044830 I made enquiries in to Mr Blakey’s finances in
order to investigate a line of inquiry in respect of his recent financial
position. I was investigating what I thought at the time to be a significant
loss of money from POL and perhaps felt it reasonable to approach his
bank for information.
I cannot recall if I made enquiries at Grimsby Police Station in regard to
Mr Blakey case. Occasionally enquiries would be made with the police for
all sorts of reasons, but without further information in re spect of this case I
would not know if the police in Grimsby were approached.
I am unable to say if ARQ logs were sought in this case. I do not
remember making the request or not making the request. At the time, I do
not think it was a matter of course to request them in cases such as this.
Nor were we as investigators instructed to obtain them in pursuing
prosecutions. At the time, and 2004 was shortly after the full roll out of
Horizon, I and other investigators believed that Horizon was robust. This
is what we had been told and continued to be told. The certainty of the
message from POL in this regard may have coloured our judgement in
matters surrounding Horizon.
I cannot recall any further involvement I had with Mr Blakey's case prior to
the decision to charge him and was not involved at all in that decision.
Regarding disclosure, without really knowing it I was the disclosure officer
in the case. Within POL investigations, if you were the officer in the case,
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you were also, disclosure officer, exhibits officer, report writer, witness
liaison, and all the other roles combined to support an investigation. As
such, when it came time to review evidence and produce disclosure
schedules for a criminal prosecution it was down to each investigator to
do this.
140. An issue with that I feel there was, was that there was no regular refresher
training on the subject, often the line managers were equally as poorly
equipped to deal with disclosure, and because as POL cases were rarely
committed for trial, consideration and production of schedules was
something that investigators rarely did. I can recall in my time at POL
investigators with substantial service who had never assembled what was
known as a ‘committal file’ and therefore had never produced disclosure
schedules.
141. To expand, obviously rules in respect of this have now changed, however
in the past POL would charge a person for example with theft and they
would appear at magistrates’ court for a first hearing. Invariably, because
of the amounts of money involved the magistrates would send the case to
crown court to be dealt with there. At this point, ordinarily, all that an
investigator had submitted by way of reporting was whatever was in the
file that had initially submitted at the end of the investigation when it had
been reported to the designated prosecution manager and Legal
Services.
142. If the defendant pleaded not guilty and the matter was sent for trial it was
only at this point that a full file, (which was known within POL investigation
as a ‘committal file’) was assembled.
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143. Many of POL’s cases attracted a guilty plea so committal files were not
deemed necessary and not produced, and as such I feel that performance
in respect of tasks involved in producing a committal file, such as
disclosure, may have suffered.
144. Looking at the date of Mr Blakey's prosecution, I would not be surprised to
learn that in regard to my time with POL this may have been the first time
that I had put together a ‘committal file’ and produced Disclosure
Schedules.
145. I recall that my technique to deal with disclosure at the time was to assign
each case I was working on a plastic box container that I would keep ina
locked cupboard in my office. As files were paper based at that time, any
relevant item from the case I would deposit in this container, if necessary
having firstly printed it off from a computer. When instructed to assemble
a ‘committal file’ I would then simply go through the items in the box and
list as I saw fit.
146. Though I cannot specifically recall undertaking the exercise for Mr
Blakey's prosecution I believe I would have approached disclosure in this
way and produced the Draft Schedule of Non-Sensitive Unused material
(POL00044817) using this process.
147. This, along with other documents (witness list and copies of statements,
exhibit list and copies of exhibits etc.) would then have been sent to legal
services for review by the reviewing lawyer. Unfortunately, I don’t know in
this case who the reviewing lawyer was, Jarnail Singh looked to have held
the case for legal services, but do not know if it was he who was actually
the reviewing lawyer.
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148.
149.
150.
151.
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On reflection I feel my lack of training and or experience in disclosure is
evident in document POL00044817, with the descriptions being
particularly poor. Under those circumstances I am as confident as I can be
that I fulfilled my remit in that all items that had been gathered as unused
evidence in the case were considered and documented accordingly, and
that what I produced in terms of schedules for review was accurate.
However I feel that if I was to do the disclosure exercise in respect of this
case again, or if a more experienced disclosure officer would have done
the exercise at the time, it may have produced different results . Also, I do
not recall that the reviewing lawyer ever questioned my disclosure
schedules.
Via Jarnail Singh’s memo to S&A casework dated 23 June 2004
(POL00044835) I would have been notified of the prosecution decision in
respect of Mr Blakey however, I had no input into the process other than
perhaps to perform any of the tasks identified by Mr Singh on the
document to support the prosecution, though I cannot specifically recall
doing any of these. It was also my responsibility to lay the information at
court in order to obtain summons, and I would have used the information
from the document POL000448335 to assist in this.
In respect of the prosecution decision, at the time, I probably would have
felt that it was a fair reflection of the evidence that had been presented in
the investigation.
I do not recall any further involvement I had in this case. I would have
probably served summons on Mr Blakey. I would have then attended
court hearings as the officer in the case to support POL’s local
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152.
153.
154.
155.
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prosecution agent as it was common practise for POL investigators to do
so at the time.
Reflecting on the investigation and prosecution of Mr Blakey knowing
what I know now, I express regret at the treatment Mr Blakey and his
family experienced as a result of these events but offer the following by
way of explanation for my actions.
My role as an investigator was to gather evidence to investigate the loss.
From the outset, after his confession firstly to auditors, and then within his
interview, Mr Blakey admitted that he was fully aware that cash was
missing from the post office and that it had been for some weeks.
However instead of raising the alarm to POL he had falsified accounts to
disguise the fact. I accept that he said he wanted to shield his wife from
events, but I did not think this was reasonable course of action as the
losses continued to mount up to the figure they stood at when the auditors
arrived at Riby Square post office that morning.
Early in his interview, under caution, Mr Blakey had admitted that he was
fully aware of the amount of cash shortage that the auditors had found
that morning, he had covered these losses up, and in entering inflated
figures into the account to make a balance, he had known his actions
were dishonest. I feel that it may have been these admissions of
dishonesty which led me to subsequently diminish and dismiss his claims
that he was unaware of how the losses had occurred in the first place.
I accept that within his interview Mr Blakey repeatedly denied having any
responsibility for the losses, however as an investigator in such
circumstances I felt that it was reasonable for such an account to face
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156.
157.
158.
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challenge. As Mr Blakey offered no explanation to me that would allow
focused scrutiny of a particular area of loss within the account, as the
person who was admitting covering it up I felt it reasonable to explore
possibilities that he had taken it. Mr Blakey had admitted means and
opportunity in respect of the loss and I felt it reasonable and appropriate
to explore a motive.
At this time, when I challenged Mr Blakey saying that I didn’t believe his
explanation, I note that he actually told me that he didn’t know if he
believed it himself. That said, he did continue to stress that his
explanation, that the losses appeared out of nowhere, was the truth.
After the interview I felt that I took relevant and suitable steps to progress
the case. I made appropriate inquiries with other people who had access
to cash and stock and gathered further evidence from witnesses. Of
course, all of this was within a narrative that I and others had at the time
where it was unquestionably believed within POL that the Horizon system
was not capable of producing an unexplained loss within a post office. It
was normal at this time to obtain a statement to say as such, however I
have not seen such a statement within documents disclosed to me at this
time. Perhaps with Mr Blakey’s case not going to trial this may not have
been obtained.
On reflection I recognise that it must have been extremely distressing for
Mr Blakey and his family to hear my dismissal of his now known to be
truthful explanation, but at that time in my experience of investigating
previous criminal losses for POL more often than not the person covering
the loss up in the accounts was found to be the perpetrator of the loss.
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Furthermore, often the motive or motives for the person taking the cash
were ones similar to the reasons that I put to Mr Blakey when challenging
his account. Again, on reflection, perhaps this bias, albeit unconsciously,
may have been in play as I investigated the incident.
GENERAL
159.
160.
161.
162.
It was my honestly held belief during the time I was investigating within
POL that Horizon was robust and would not erroneously produce
spontaneous transactions that were not genuine. That was the over riding
narrative that I was being told and accepted.
In order to support our work, I (and other investigators I worked alongside)
obtained Section 9 statements from people who were considered Horizon
experts. In each case their evidence reported that the system was
accurate. This was the bedrock of any POL investigation and I took those
statements at face value when gathering evidence in my cases. However,
as briefly mentioned in the preceding paragraph, this may have clouded,
not only my judgment and objectivity, but also potentially that of other POL
staff, lawyers, legal advocates, and jury members.
I left POL around the first week of 2012 and at that time I do not believe I
was aware of any successful challenge to Horizon data. I feel that if there
had been one, it would have opened the door to numerous other
challenges and POL’s position in respect of demonstrating the criminal
burden of proof to a court that the Horizon system had integrity would
have rightly been made untenable. Unfortunately, this did not happen.
I am unaware of what POL’s investigation in to ‘bug and errors’ in the
system was, or if it was deemed sufficient. From an investigators point of
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view, when required I simply asked the question of those who should have
known and was always told that the Horizon system was robust.
163. Throughout my time with POL, I was not privy to information which Fujitsu
provided to POL about the operating status of Horizon beyond the content
of statements as detailed in the preceding paragraphs.
164. If anyone within POL or Fujitsu knew that the integrity of the Horizon
system was questionable I feel that this information should have been
provided to the Investigation team without delay. The information
obviously would have majorly impacted any investigation that was being
carried out and completely undermined any criminal or civil proceedings
POL had undertaken, since the roll out of the system.
165. From a personal viewpoint, on reflection I feel that there was an amount of
complacency from POL and others in the investigation and prosecution of
these matters. A similar situation appeared to be regularly played out as
cases progressed through to conclusion.
166. Quite often, as has been evident in some of the cases commented on in
my statement, false accounting was admitted at interview against a
backdrop of the suspect stating they were not aware of the origin of the
loss.
167. Charges were then brought for the admitted false accounting, with an
associated theft charge for the amount of loss.
168. During prosecution, at an early-stage POL appeared keen to take a plea
deal where the false accounting charges were admitted, with the theft
charge not being taken forward. This meant that the evidence in respect
of the theft charge was not tested in court. Often, when it was taken to
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169.
170.
171.
172.
173.
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trial, the defendant was acquitted of theft, however within the same
proceedings they were still convicted of false accounting as following an
admission in interview, evidence of that offence was compelling.
Being convicted of any criminal charge would mean that a
subpostmasters contract was terminated, and their contract said they
were liable for any losses, so POL were able to dismiss the
Subpostmaster and recoup their perceived loss without evidence of the
robustness of the Horizon system ever being truly tested.
I feel that POL were content to secure a conviction of anything, as a
means to an end to achieve this. I feel that complacency may have set in
and negotiation within indictments was widely accepted.
Reflecting on my personal performance during this time I would say that in
comparing the cases I investigated pre-Horizon and those post Horizon
rollout I did not notice a significant increase in the audit shortage type
cases.
Though I was not aware of the whole picture in regard to how many cases
of a similar nature were being pursued by POL, I do not recall any
significant increase in this type of investigation in the period after Horizon
system implementation to that which I experienced before the system roll
out. This may have affected my thinking in respect of my investigations ,
as if I had have noticed a sharp increase in cases after the
implementation of Horizon it may have raised my suspicions that the
Horizon system was not performing as it should have.
The thought that during my time with POL someone within the
organisation may have had knowledge that the Horizon system was
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flawed and did not disclose this information as they should, does not sit
well with me. Particularly knowing that investigations and prosecutions
continued which they must have realised were unsafe as a consequence.
174. I feel anger that under these circumstances, through my investigations I
may have been used as an unwitting instrument of POL and Fujitsu to
perpetuate the myth that Horizon was faultless and brought unnecessary
distress and anguish to innocent people.
STATEMENT OF TRUTH
I believe the content of this statement to be true.
Signature of the witness: : G RO
Date of Signature: 08 October 2023
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Index to First Witness statement of Paul Whitaker
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No IURN Document Description Control
Number
1 POL00104900 Separation Project- Criminal I POL-0080532
Investigations Policy for
Post Office Ltd
2 POL00105191 Activity Plan for POL POL-0080816
separation project —
Criminal Investigations
Policy
4 POL00104747 Casework Management POL-0080387
Document (version 1.0,
March 2000)
5 POL00104777 Casework Management POL-0080417
Document (version 4.0,
October 2002)
6 POL00118101 Guide to the Preparation VIS00012690
and Layout of investigation
Red Label Case Files
7 POL00118104 Identification Codes VIS00012693
8 LCAS0000699 Marine Drive Post Office VIS00010939
Summary of Events
9 POL00082391_004 I Audit report Marine Drive POL-
Post Office
0078954_172
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10 POL00082391_002 I Letter from Cath Oglesby POL-
0078954_170
confirming Mr Castleton’s
suspension
11 LCAS0000609 Witness statement of Cath I VISO0010849
Oglesby
12 POL00047152 Investigation Report POL-0043631
13 POL00055458 Witness statement of POL-0051937
Christopher Knight
14 POL00054407 Record of the Taped POL-0050886
Interview Summary
15 POL00021252 transcript of interview on 28 I POL-0014444
September 2010
16 POL00091037 Investigation Report POL-0090681
17 POL00091065 List of Exhibits POL-0090709
18 POL00091149 Witness List POL-0090793
19 WITN01450100 Alison Hall's Statement WITNO01450100
20 POL00044818 Investigation report dated POL-0041297
25 May 2004
21 POL00044830 and I Mr Blakey's interviews on POL-0041309
and POL-
POL00044831 13 May 2004 0041310
22 POL00044829 Summary of Key Points POL-0041308
from an interview with
Gillian Blakey
23 POL00044817 Draft Schedule of Non- POL-0041296
Sensitive Unused material
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24
POL00044835
Jarnail Singh’s memo to
S&A casework dated 23
June 2004
POL-0041314
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