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Witness Name: John Legg
Statement No: WITN05810100
Dated: 11 July 2023
POST OFFICE HORIZON IT INQUIRY
First Witness Statement of John Legg
I, John Legg, will say as follows...
1. I was employed by The Post Office/ Post Office Counters Ltd (POCL)/ Post
Office PLC for over 34 years from February 1975 until October 2009 when I
retired at age 60. I started as a graduate entrant at PEC level and ended my
career as a Senior Manager at Band 8 level.
2. From 1975 to 1987 I worked in a variety of management roles in the mails
side of the business until the creation of POCL as a separate entity. At that
point I began working in North London Counters District until, as best as I can
recall, 1995, when the business reorganised again and I moved to POCL’s
HQ and began to work on the contracts for services between POCL and
Subpostmasters.
3. My HQ roles (variously named over the years) were all focussed on the
overarching status, at law, of the Subposimaster contracts, with particular
regard to National Insurance Contributions, VAT, Employment Protection
Legislation and Competition Law. The legal status of Subpostmasters in
these areas was complex, and of very considerable financial significance to
the business. Challenges at Employment Tribunal, and VAT Tribunal were not
uncommon and were all successfully defended. The proactive management
of National Insurance Contributions to ensure POCL did not pay more than it
was required to was also my responsibility. I was also, amongst others in HQ,
responsible for the provision of expert advice to other parts of the business,
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as appropriate, to ensure that any new proposals, initiatives or policies did not
jeopardise the status quo in these critical areas.
4. My overarching contractual role did not involve any detailed knowledge of,
ownership of, deployment of, management of, or in any other way,
involvement in, any of the issues upon which I have been asked to give
evidence to this Inquiry save for any possible input I may have had to protect
the very nature of the contracts as described at para 3, above.
5. [can assure the Inquiry that I have scrutinised, in detail, all of the documents
referred to me. In particular, I have considered the following categories of
documents, which formed the basis of the Rule 9 request to which this
statement responds (which I list below for ease of reference):
Documents to which I was referred in the Inquiry’s Rule 9 request for_a witness
statement
a) Documents relating to the appointment of subpostmasters, including, but
not limited to, [POLO0088903] (“Brief summary of certain sections of the
subpostmasters contract’), [POL0088900] (Template letter “Assessment
for the position of subpostmaster’) and [POL00005765] (“Appointment of
Temporary Postmaster Policy”);
b) Documents relating to the contractual liability of subpostmasters for
shortfalls, including, but not limited to, [POLO0083939] (“Losses at
SPSO’s: Guidelines on responsibilities and recovery arrangements”,
[POL00088904] (“Losses and gains policy within the POCL agency
network’), [POL00086845] (“Post Office Ltd — Security Policy: Accounting
losses policy for agency branches”), [POL00088867] (“Post Office Ltd —
Security Policy: Liability for losses policy (for agency branches”), and
[POLO0030562] (“Post Office Ltd Losses policy -— overarching
(branches)”);
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c) Documents relating to my role and the policies or practices in place
relating to error notices, transaction corrections, transaction
acknowledgements, branch discrepancies, “corrective action” taken
against SPMs and recovery of agents’ debt, including, but not limited to,
[POL00083939] (“Losses at SPSO’s: Guidelines on responsibilities and
recovery arrangements”), [POL00088904] (“Losses and gains policy within
the POCL agency network”), [NFSP00000169] and [NFSP00000043] (draft
policy’Debt recovery — Horizon related errors”, enclosed under cover of
correspondence between the Post office and the National Federation of
Subpostmasters), [POL00085794] (“Debt Recovery Processes under
Branch Trading”), [POLO0030562]‘Post Office Ltd Losses policy —
overarching (branches)” and [POL00083951] (“Appendix 3 - Process for
awaiting TC (Transaction Correction) ~ Multiples”) and [POL00083952]
(Appendix 4 - Process for awaiting TC (Transaction Correction) —
Singletons’);
d) Documents relating to suspension and termination of subpostmasters,
including, but not limited to, [POL00000304] (“Postmaster Contract
Termination Policy”), [POLO0038051] (“Postmaster Guide to Policies”),
[POL00084993] (“Contract Advisor Process - Audit Discrepancy”),
[POL00086044] (“Subpostmaster suspension”), [POLO0005856] (“Post
Office Limited: Appeals Handbook”), [POL00086358] (“Managing
Shortages at Audit: Process and Policy Guidelines”), [POL00086828]
(‘Subpostmaster Appeal Panel Process Review”), [POL00086116]
(‘Guiding Principles for Suspension”) and [POL00000325] (“Postmaster
Support Policies: Termination Decision Review Policy’).
6. I have also been asked about my recollection of a number of specific criminal
and civil cases.
7. In reviewing the documents and cases listed above, together with other
provided by the Inquiry, I have learned a lot I never knew and have refreshed
some memories that the long intervening years have erased. However, with
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ail due respect to yourselves and to the Subpostmasters who have suffered
so badly during this whole sorry saga, I can add no more.
Statement of Truth
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Index to the First Witness Statement of John Legg
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URN
Document Description I Control
' Number
POL00088903
Brief summary of certain I POL-0085961
sections of the i
subpostmasters contract (17
December 2004) I
POL00088900
Template letter “Assessment , POL-0085958
for the position of I
subpostmaster” (August
2005)
POL00005765
Appointment of Temporary —_I VIS00006833
Postmaster Policy (version
10, 2 February 2014)
“POL00083939
Losses at SPSO’s: POL-0080007
Guidelines on responsibilities I
and recovery arrangements
(understood to have been
issued in 1988)
POL00088904
Losses and gains policy I POL-0085962
within the POCL agency I
network (version 1, 20
November 1998)
POL00086845
Post Office Ltd — Security POL-0083903
Policy: Accounting losses
policy for agency branches ;
(version 1, February 2003)
POL00088867
Post Office Ltd — Security POL-0085925
Policy: Liability for losses
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I
policy (for agency branches
(version 1.7, September
2003)
8
POL00030562
i
Post Office Ltd Losses policy
~ overarching (branches)
(version 9, effective date April
2006)
POL-0027044 —
NFSP00000169
Draft policy “Debt recovery —
Horizon related errors”,
enclosed under cover of
correspondence between the
Post office and the National
Federation of
Subpostmasters (18
November 2004)
VIS00007617
10
NFSP00000043
Letter circulated to
Negotiating Committee for
Horizon debt recovery (18
November 2004)
VIS00007491
a
POL00085794
12
POL00083951
Debt Recovery Processes
under Branch Trading
(October 2005)
POL-0082852
~~ I Post Office Ltd Losses policy
— overarching (branches):
Appendix 3 - Process for
awaiting TC (Transaction
Correction) — Multiples
POL-0081009
“13
POL00083952
Post Office Lid Losses policy
— overarching (branches):
Appendix 4 - Process for
POL-0081010
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~ awaiting TC (Transaction
Correction) — Singletons
14
POL00000304
Postmaster Contract
Termination Policy (version
I 3.0, undated)
vis00001299 I
15
POL00038051
POL00084993 ©
: Postmaster Guide to Policies
I (version 1.2, undated)
POL-0034986
Contract Advisor Process -
Audit Discrepancy (undated)
POL-0082051
17
POL00086044
Subpostmaster suspension
(undated)
POL-0083102
}
18
POLO0005856
Post Office Limited: Appeals.
Handbook (19 June 2008)
rvisooo0s924
19
; POLO0086358
Managing Shortages at Audit:
Process and Policy
Guidelines (25 July 2011)
POL-0083416
20
POL00086828
Subpostmaster Appeal Panel
Process Review (March
2012)
POL-0083886
21
POL00086116
Guiding Principles for
Suspension (2 November
2012)
POL-0083174
22
POL00000325
Postmaster Support Policies:
Termination Decision Review
Policy (version 2.3, 30 March
2021)
VIS00001299
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