WITN06120100 Alison Bolsover - Witness Statement

Evidence on official site

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Witness Name: Alison Bolsover
Statement No: WITN06120100
Dated: 05/05/2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF ALISON BOLSOVER

I, Alison Bolsover, will say as follows:-
INTRODUCTION

1. I am a former employee of Post Office Limited.

2. This witness statement is made to assist the Post Office Horizon IT Inquiry (the

“Inquiry”) with the matters set out in the Rule 9 Request dated 3 April 2023

(the “Request’).

BACKGROUND

3. I have been asked to set out my professional background, dates worked in the

Financial Services Centre (“FSC”) and roles I held.

4. I was employed by Post Office Ltd (“POL”) for 36 years from 1985 until 2021

when I retired.

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5. [held various positions during my career in POL, from Administration Grade to
Senior Manager, dealing initially with checking of supporting documents for the
savings stamps product at an administration grade, to then management roles
dealing with: reconciliation of accounts and managing the introduction of the
Lottery in 1994; I went on to manage two teams in London: Data Processing
reconciliations for cheque processing and facilities management for the site
(POL processed the cheques from Branches in Data Central in London) and
three Exceptions teams in Chesterfield, issuing error notices for TV Licences,
Automated Payments and Personal Banking. I was not working in 1999/2000
(sick leave / maternity leave) and then on maternity leave late 2000/2001. I then
returned to a Decision Support role managing budgetary costs, and then onto
an operational support role to reduce costs and make efficiencies with respect
to process improvements and staff reduction, I am unable to remember the

exact timeline for all the roles I held.

6. In 2004 to 2007 I was promoted to a senior manager role called Operation
Manager. There were twelve managers in the area managing two Exceptions
areas and Data preparation teams (teams were dealing with enquiries and
issuing error notices and keying Cash accounts and supporting document) until
the Impact Programme automated the Horizon and Client feeds in 2005 and

TCs were then issued.

7. From 2007 to 2018 - with the exception of 2015 when I was seconded to a

Recruitment project and another person temporally managed my area - I was

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the Senior Debt Recovery manager within Product and Branch Accounting
(P&BA) then the FSC. The role did have various tiles during that time but for
ease I will refer to it during this statement as the Senior Debt Recovery

Manager. At this time, I was primarily managing the following areas.

a) Current and Former Agents Debt /Multiple Agents Debt Teams (latterly

known as Agent Accounting Team (“AAT”) (From 2007 to 2018).

zs

Fraud and Conformance Team (From 2007 to 2012). The team was split

in 2012 and some of the work moved to the Security Team. The team
reviewed various areas for abnormal patterns, non-conformance or high
overnight cash holdings, and escalated to various area within the
business Network, Security and The Cash Inventory team.

c) Vehicle Excise Recovery (VER) (From 2012 - 2014) recovery of unpaid

cheques for the DVLA for Car Tax — this work was passed back to the

DVLA.

a

Accounts Receivable (From 2014 -— 2016) (Client invoice debt).
Managing Invoices to Client for transaction charges for their products.
This work moved into another area in FSC.

e) Open Item and Enquiry Teams (From 2016 — 2021) Open item Teams

that led to the issue of TC’s and Enquiries from Branches and Clients.

. In 2018 the Current and Former Agents Team were transferred to another area

within the Network Operational Support Team.

. As the Senior Debt Recovery Manager, within P&BA/the FSC from 2007 to
2018, my key responsibilities were:

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a) Managing a Team of up to 4/5 Managers;

b) Managing and reporting the level of debt and recoveries each month;

c) Aged debt profiling and financial provisioning;

d) Sign off on losses or write off within my delegated authority;

e) Liaising with Network Contracts Team for branches FSC were unable to
contact or were refusing to pay a debt and gaining sign off on
repayments/repayment plans;

f) Liaising with internal / external legal teams on individual Debt cases to
gain input and recommendation of next steps for the pursual of debt;

g) Managing the sign-off of controls within the team with respect to
processes, reconciliations budgetary costs, staffing and HR policy

deployment.

From 2016

h) Managing and reporting the aged open items;

i) Managing and reporting Open Banking and AP Enquiries;

From 2018

j) Managing and reporting TCs Issued;
k) Completing a monthly score card for key performance indicators within

the area.

10.From 2018 until I retired in 2021, I was a Senior Manager within the Network
Operations Support Team; the FSC was split and the area I then managed was
renamed Branch Reconciliation Team (BRT) but I will continue to use FSC

throughout this statement to help with flow and reading. From 2018 I was

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managing the following areas which dealt with enquiries, issued TCs and

ensured TA delivery to the Branches:

A) The Enquiries Team: Received enquiries from Branches and Clients for
Automated Payments (bill payment) Banking and Bureau transactions.
These enquiries were generally for miskeyed transactions in branches. If a
miskey was reported by the Branch the team would liaise with Clients/
Banks. The Clients / Banks would discuss the miskeyed transaction with
their customers and if the customer agreed to the repayment of a miskeyed
transaction they informed the FSC Enquiry team, and a credit TC would be
issued to branch and the settlement to the Client adjusted. If the customer
did not agree, then the Branch would be informed by the FSC Enquiry Team
that the customer refused to refund the money, this would leave the loss in
the branch. This team also managed TAs and Enquiries for Paystation.

B) The Open Item teams x 3 These were for open item general ledgers where
two streams of data (Horizon data from branches, and Client/Supplier data)
were matched and TCs issued. The matched products were:

i. Cash remittances

ii, Bureau remittances

ii. ATM

iv. Lottery Prizes Matching account (TA for Scratch Cards and Online
Game)

v. Cheques to processing and Cheques held at site (Cheques held in
branch and not dispatched for processing)

vi. I Unpaid cheques, Cheques returned by Banks as an unpaid item. If

the Branch had followed the correct procedure and annotated the

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reverse of the cheque with the product details, the values were
deducted from the settlement with the Client and the cheques sent
onto the client to reinstate the Bill or chase their customers for
payment. If the branch had not annotated the reverse of the cheque,
the FSC would investigate, but if they were unable to confirm the
Client then a TC would be issued.

vii. Debit cards

viii. I Moneygram

ix. Control Account Management for: Local Suspense, Loan to PO,
Cash Holdings (declared vs generated cash figure)

x. Missing cheques, these were chased with the Customers for

payments after liaising with the Branch

After investigation, an unmatched item could lead to a transaction correction
(‘TC’) being issued to the branches. I will return to explain this more, below. I
will use paragraph headings in this statement to assist with clarity and for ease

of reference.

Contractual liability

11.1 have been asked to address my recollection of the contractual liability of
subpostmasters for shortfalls. I have been referred to the following documents,
which I have read for the purposes of this statement. I had no knowledge of
the documents listed at a — e below at the time of my employment, as these

was prior to my tenure in the Senior Debt Recovery role in 2007.

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a) “Losses at SPSO’s: Guidelines on responsibilities and recovery
arrangements” (understood to be issued in 1988) (POL000839339) (in
particular, paragraph 2);

b) “Losses and gains policy within the POCL agency network” (version 1,
20 November 1998) (POL00088904) (in particular paragraph 3.1);

c) “Post Office Ltd - Security Policy: Accounting losses policy for agency
branches” (version 1, February 2003) (POL00086845) (in particular,
section 1 and section 3);

d) “Post Office Ltd —- Security Policy: Liability for losses policy (for agency
branches)” (version 1.7, September 2003) (POL00088867) (in particular,
section 1 and section 3);

e) “Post Office Ltd Losses policy — overarching (branches)” (version 9,
effective date April 2006) (POL00030562) (in particular, section 2);

f) “Policy document - Operators’ in service debt” (version 1.0, 18
September 2013) (POL00113670) (in particular, sections 4 to 6), as well
as the policy’s later iterations at POL00086868, POL00088579,

POL00090357 and POL00088312.

I had no knowledge of the documents listed at a — e above at the time of my
employment, as these was prior to my tenure in the Senior Debt Recovery role

in 2007.

12.Due to my role as Senior Debt Recovery Manager, I was involved in the input
and review of the policy “Operators’ in service debt”. I recall working on this,
primarily with my colleagues Paul Inwood and then Ravi Chauhan (Contracts
and Policy Advisor), John Breeden, Lin Norbury and Andrew Carpenter (The

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Network Contracts Managers). The policy was developed and used with the
Network Contact Managers, and I referred to this policy in review meetings with

Network Contract Managers.

13.My understanding of Postmasters’ Contract Liability for shortfalls was that the
Postmaster was liable for any losses of Post Office cash and stock incurred
through negligence, carelessness or error by themselves or their Post Office

assistants.

14.1 have been asked about the Post Office policy on the responsibility of
employees within Crown Offices for shortfalls or “losses” identified in a Crown
Office, and whether that differed from the policy on the responsibility of SPMs
for shortfalls for “losses” identified within their branches. I have been referred
to the documents below, but I have no recollection of needing to refer to them
at the time of my employment (as they related to Crown Offices), These Policies
were written by the Security Team and FSC were not engaged in the writing or
deployment of the polices as far as I am aware:

a) “Mandatory Losses & Gains Policy Crown Office Network” (September
2008) (POL00088124);
b) “Mandatory Losses & Gains Policy Crown Office Network” (version 1.0,

24 April 2013) (POLO0088124).

15.The FSC debt recovery area I led and had responsibility for did not act to
recover debts from Crown Branch employees. The losses and transaction

corrections for Crown Branches were accepted in Branch and posted directly

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to profit & loss accounts and managed by the Network Finance

Analysts/Network Teams and the Security & Investigations Team.

Role of the Financial Services Centre (FSC)

16.1 have been asked about the role of the Financial Services Centre and the
policies / practices in place when I worked within it. I have been asked to
address the role which the FSC played and the policies / practices in place
relating to error notices/transaction corrections (“TCs”), transaction
acknowledgements (“TAs”), branch discrepancies and recovery of debt from in
service and former SPMs. I have been referred to the following documents:

a. “Losses at SPSO’s: Guidelines on responsibilities and recovery
arrangements” (understood to be issued in 1988) (POL000839339) (in
particular, paragraph 15.1.15);

b. “Losses and gains policy within the POCL agency network” (version 1,
20 November 1998) (POL00088904) (in particular, the table under
paragraph 3.1);

c. The draft policy “Debt recovery — Horizon related errors” dated 18
November 2004, enclosed under cover of correspondence between the
Post office and the National Federation of SubPostmasters
(NFSP00000169 and NFSP00000043) (in particular, section 3);

d. “Debt Recovery Processes under Branch Trading” (October 2005)
(POL00085794);

e. “Post Office Ltd Losses policy — overarching (branches)” (version 9,
effective date April 2006) (POL00030562) and appendices 3 (‘Process

for awaiting TC (Transaction Correction) — Multiples’ at POL00083951)

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and 4 (‘Process for awaiting TC (Transaction Correction) — Singletons’
at POL00083952);

f. “Post Office Limited - Process documentation — Branch Correction
Process (TCs)” (version 2.0, undated) (POL00003060); vii) “Transaction
Correction / Debt.

I had no real knowledge of the documents listed at a — e above at the time

of my employment, as these was prior to my tenure in the Senior Debt

Recovery role in 2007.

17.By way of background first, pre 2005, nothing in relation to the cash account
was automated in branches. The Postmaster completed a paper cash account
and sent materials in hard copy in a pouch to Chesterfield and the branch
received paper error notices. On the implementation of the Impact Programme
in late 2005, an automated service was introduced whereby the branches
completed a branch trading statement on Horizon and received electronic
transaction correction (TCs) directly to the Horizon terminal. Transactions were
summarised daily and fed into vendor accounts in the SAP system (POLSAP)
to pay the Clients for transaction completed in branch for their products. Some
of the products also fed an Open Item general ledger from Horizon and were
matched in the SAP system (POLSAP), i.e. the data from Horizon was matched

to the Client / supplier data.

Transaction Corrections (“TCs”) - overview

18.A Transaction Correction, “TC” is an electronic message with a narrative as to

the reason for the accounting correction. A branch would have entered their

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transactions into Horizon; these were summarised by branch, daily, and that
information fed into the POLSAP system, using unique product IDs. These
accounts for matched items were known as open item accounts. TCs were
issued on these accounts by postal officer grades, i.e. FSC staff (based in
Chesterfield) to correct differences in the accounts balance if there were

mismatches.

19.The open item accounts were fed by two streams of data, one from the Branch
via Horizon and the other stream from a Client, Cash Centre or Supplier that
processed items, such as the Cash Centres, Camelot, ATM, Cheques, Debit
Cards and Moneygram. The open items accounts were matched daily, any
mismatched or unmatched amounts were investigated to give evidence and

narrative for a TC to be issued.

20.When TCs were generated, the narrative as to the reason for the TC would be
given, as well as a name and contact number of the issuer, should the branch
wish to discuss the TC further. If there was evidence available to a TC, this was
sent to the branch by post or email to support the TC. The narrative for Cash

and Bureau remittances were provided by the Cash Centre Teams.

2

.TC’s could be both credits and debits, and approximately 125,000 were issued
per year. TC’s could be issued individually to branches or to multiple branches
via a bulk upload in POLSAP. TC’s for cash remittances were the highest

volume for remittances from the branch, these were for both shortages and

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surpluses and the Cash Centres provided the narrative for the TC with respect

to the reason for the TC.

Transaction Acknowledgments (“TAs”) - overview

22.Transaction Acknowledgements (“TA’s”) were introduced around 2012, and the
introduction was known internally as the ‘ping project’. I was not managing the
open item teams at this time. TA’s were introduced to reduce the number of
TC’s that were being issued for equipment (kit) not linked to Horizon. TAs would
be used, for example, for the Camelot Lottery terminal/Paystation terminal

transactions.

23.A TA was different to a TC in a number of respects. TAs were issued by
Atos/Accenture (the IT supplier), not by the FSC. The TA’s were generated
and issued by the IT supplier from a file received from the Post Office Client,
for daily transactions by branch by product type I.e. for the Lottery the branch

would get two TAs one for on-line sales and one for scratchcard activations.

24. The purpose of the TA was for the branch to confirm / acknowledge the value
transacted by the branch was correct; the branch could check the values of the
transactions on the Lottery terminal by day before accepting a TA in Horizon

and putting the cash into the till to balance.

Error Notices - overview
25.Error notices were issued by postal officers (based in Chesterfield), pre 2005.

My general knowledge of the process was as follows.

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26. The branches sent in a weekly paper cash account and supporting documents
in a pouch to Chesterfield. The cash account was keyed to the system, the
supporting documents were checked and also keyed to the system, any
mismatches were investigated and a paper “Error notice” was sent to the
branch. The branch accepted the error notice by entering the error notice on
the cash account (known as bringing the error to account), Once the cash
account with the error notice on had been keyed, it would clear the differences

from the system.

Disputes:
27.A branch could dispute an Error notice, and later a TC, raising this with the

issuer. A branch could dispute a TA, raising it via the NBSC to the FSC teams.

The IMPACT programme

28.1 have been asked for my recollection of matters connected to the IMPACT
Programme. I was not involved in the design of the Impact Programme. The
Impact Programme primary objectives, I believe, were to automate the
accounting / Back-office processes and to reduce costs. It involved the
introduction of a new ‘end to end’ accounting process via Horizon and
reconciliation of the account being completed on a new SAP system (POLSAP).
I have been referred to the following documents:

a) the witness statement of Susan Harding at WITN03980100, paragraphs

23 to 32);

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b) ‘Losses and gains policy within the POCL agency network’ (version 1,
20 November 1998) (POL00088904) (in particular, section 1, part 2
‘Authority To Hold Losses In Unclaimed Payments’);

c) ‘Post Office Ltd - Security Policy: Accounting losses policy for agency
branches’ (version 1, February 2003) (POL00086845) (in particular,
section 3 — ‘Authority to Hold Losses’);

d) ‘Post Office Ltd - Security Policy: Liability for losses policy (for agency
branches)’ (version 1.7, September 2003) (POL00088867) (in particular,
section 3 — ‘Authority to Hold Losses’);

e) The letter at page 2 of NFSP00000169.

I am unable to comment on items b — e as these were prior to my tenure in the
Senior Debt Recovery role in 2007. Another Senior Manager in FSC would have
been involved in these and the management of disputes and Debt Recovery

(Jenifer Robson and then Marie Cockett).

29.When the automation via the Impact programme was introduced, it was not a
smooth transition. There were many issues flagged to the Programme and a
team of Managers/consultants called the ‘Red Team’, managed by the
Programme, were brought into FSC to support the resolution. Issues such as
products being mapped to the wrong accounts were identified and then
resolved. FSC at the time (2005) was running a dual system, closing down the
Exceptions from the Cash Account process and working on the new accounts

in the new SAP (POLSAP) system.

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30.Susan Harding (WITN03980100 para 23,24,31) states that the local suspense
account which had previously been available to SPMs to hold losses until they
removed them, is said to have been removed. The Local suspense is actually
still available to branches to use when they complete their daily / weekly
balance, but it is not available to hold losses or surpluses for long periods of

time or on a permanent basis as branches may have done previously.

31.The change in 2005 by the Impact Programme was that the local suspense
needs to be cleared at branch trading, creating a Branch discrepancy with the
option to the branch to declare the shortage / surplus as a branch discrepancy
and Settle Centrally (if over £150) or to make good by Cash or Cheque (for
Shortages) or remove Cash (for Surpluses). Local suspense does feed into the

POLSAP accounts.

32.A reconciliation of the local suspense accounts is completed by FSC after the
branch trading date. The reconciliation would only establish if there were any
values left in local suspense. If values were left in local suspense, this of itself
would indicate that the branch had not completed their branch trading.

It was at this point that FSC would investigate or even refer to another area with
relevant responsibility. The investigation purpose would be to assess why there
was a value left in local suspense, and/or why a branch had not completed

branch trading. FSC Investigation/escalation would be focussed on:

a. Escalation to the Network Teams to enable branch training to complete

the branch trading statement;

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b. Understanding if there was a fundamental problem with the Horizon kit
in branch and the branch was closed, e.g. had it been permanently
damaged in branch (by a fire);

c. If the Horizon kit had been removed from the branch due to problems
with the terminal and balances had not been completed. (FSC would not
be involved in the reason why the kit had been removed or have
instigated its removal);

d. Establishing if the branch had unexpectedly closed without balancing

and Network support or intervention was required.

33.1 have been asked about my recollections as of October 2005 (this is by
reference to the date of the guidance “Debt Recovery Processes under Branch
Trading” at POL00085794). I believe this was sent out to the branches as a
communication. I will address in more detail than above TCs and the process

involved for disputes.

TC's — process for disputes

34.A branch was provided, where available, evidence with a TC and so were able
to review any evidence they had in branch, around the transaction. For TC’s,
the first avenue for support or resolution would normally be for the branch to go

to the issuer of the TC, using the contact detail /name on the TC.

35. If a postmaster received a TC that they did not understand and they wanted
further explanation, they could call the issuer of the TC whose details were on
the TC or call the NBSC for support and guidance or escalation to FSC.

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36.If a postmaster wished to dispute a TC they received after speaking to the
issuer, they were advised by the issuer to do so first in writing to the FSC
Relationship Manager (Andrew Winn held this post I believe from 2008 to
2016). I am unable to remember the date this advice was introduced, but I
believe that there was a communication to branches around 2008/9 with
respect to this. The Relationship Manager role was put into FSC to ensure
someone other than the TC issuer or their manager reviewed all disputes, to
ensure an unbiased review was completed and a response was given to the
Postmaster in writing. The dispute was requested to be sent in writing to ensure
the Relationship Manager understood the reason for the dispute and if needed
gain further clarity by talking to the postmaster. A postmaster could dispute a
TC even if they had accepted/settled centrally the TC, which would usually have
been due to Branch Trading time constraints. The Relationship Manager would
then “block the debt’ (if the postmaster had settled centrally) and then complete
an investigation with respect to the dispute. The FSC Relationship Manager
would correspond with the Postmaster on the outcome, all letters received, and
the responses were held in a file (hard copy) and later a central computer drive
(Sharepoint) in FSC. If a call was made to the NBSC on the branch trading day
to dispute the TC, the TC would need to be accepted to allow the branch to
complete branch trading. The branch - albeit being required to accept and
settle centrally - within the document POL00085794 it states that if this was
done, a reference number was then passed to FSC who would block the debt
whilst an investigation was completed. I am unable to confirm or remember
details with respect to the branch being supplied with a reference number in

2005 as I was not in the Senior Debt Recovery Role at that time. For cash

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remittance disputes the Relationship Manager would contact the Cash Centres
who were able to review camera footage of the remittance and validate the
error. If Branches still did not believe that there was a shortage in the
remittance, a request could be made for the Branch to view the footage of the

remittance being counted in the Cash Centre.

TA's — process for disputes
37.If a TA was disputed — e.g. for Camelot - the FSC could request evidence from
Camelot with respect to the activity on the lottery terminal. Generally, these
disputes, in my experience, were caused by the lottery summary on the terminal
in branch being printed prior to the close of business (and transactions

happening after printing but before closing).

Error Notices pre 2005 — process for dispute.

38.The Error Notices could still be disputed and/or discussed with the issuer. I am
unable to clarify or give further details of the process for disputing an error
notice as the debt recovery process / disputes resolution sat with another

Senior Manager pre-2005, I believe it was Jennifer Robson.

Postmaster discovery of deficiency/surplus — support available and process

39.1 should add that, in addition to a TC or a TA, which were means of notifications
to a branch, if a postmaster discovered a deficiency or surplus in the amount of
cash held when balancing the branch account, they were able to escalate the
issue and discuss this by contacting the NBSC for guidance, support and help
in the first instance. I am unable to expand on what the staff in the NBSC would

do next and their processes. I am also unable to confirm what actions the NBSC

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took If a branch rang the NBSC about a discrepancy that they believed to have

been caused by Horizon therefore input would be needed by NBSC on this.

40.The Branch in 2005 also had access to a Retail Network Manager to gain

support.

41.If the discrepancy amount was over £150, the branch did not have to seek
authority to ‘settle centrally’ (see further below) and the discrepancy recorded
and settled centrally could all be done in branch. I cannot expand or explain
why the amount was set at £150. I was not involved in these processes or
decisions around setting the £150 amount for Settle Centrally as I was not in

the Senior Debt Recovery managers position in 2005.

Settling Centrally

42.1 have been asked about the process for “Settling Centrally” and referred to the
document dated 14 November 2008 entitled “TC/Debt Recovery Review” at

POL00026854.

43.“Settling Centrally” was a process that enabled branches to set aside
debit/credit TC’s and branch discrepancies / shortages and surpluses over
£150, and not put the cash in the till or take surpluses out to balance the
account. The values when settled centrally were allocated to a customer
account that was specific to the branch and postmaster. If a branch chose to
settle centrally it did not always signify an acceptance of the debt. If a debit TC
or branch discrepancy shortage leading to a debt was settled centrally, the

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branch could still dispute when ‘Dunning letters/statements’ were sent to the
branch and the debt blocked for further investigation. (Dunning letters were
part of the ‘Dunning process’, a standard functionality in SAP for chasing
outstanding debt). The comment in the document POL00026854 were made by
the legal team with respect to “Settle Centrally” in this document it stated,
“Settle Centrally signifies acceptance of debt liability, forcing TC acceptance on
the same day as receipt through branch trading requirements would probably
be regarded as unreasonable by a court of law and cause a related claim to
fail”.

Actions were put in place with the FSC TC issuing teams after this meeting for
the TC issuer to check the date of branch trading and not issue TCs on a
Tuesday that would arrive at the branches on the branch trading day unless this

was requested by the branch.

If a debt/credit had a blocking code assigned in POLFS, the amount would not
be chased via the Dunning Process and the system distinguished blocked items

from open items on the customer accounts.

Branch discrepancies

44. In the simplest form, the phrase “branch discrepancy” was used to explain the
situation when the value of transaction did not accurately equate or record the
cash taken from or given to the customer. Effectively a shortage or surplus in

cash in the branch vs the transactions the Branch had completed on Horizon.

45.Branch discrepancies could be /occur in the following circumstances:

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a. A miskeyed transaction is entered, for example a deposit for £100 is
keyed as £1000; this would equate to a £900 shortage/discrepancy;

b. An Incorrect product icon is selected in branch e.g. a customer requests
a £500 withdraw of cash but the branch completed a deposit for £500
into the customer's account. This would equate to a £1000 shortage;

c. Incorrect change is given to a customer;

d. Incorrect value of cash is noted in a remittance back to the cash centre;

e. A remittance of cash received in branch was booked in on Horizon but
the pouch was in the safe and not counted as part of the balancing
process.

Branch discrepancies could also occur due to TC/TA processes, when:

e. ATC is accepted but the cash is not put in the till;

f. A TAis accepted, and the cash is not put in the till.

System issues raised by Branches to NBSC

46.FSC worked with the NBSC if multiple branches raised the same queries. Some
of these were referred to as system issues, and these would be escalated to
the POL IT service desk and onto the IT suppliers (ATOS/Accenture) for
investigation. Examples of these could be
a) Non arrival of TAs in branch for lottery / paystation. This could be as a
result of a failure to send the file out to branches by the IT supplier, as
they may not have received the file from the client; or the file format sent
by the client was in the wrong format and would need to be resent. The
FSC would have visibility of this in the general ledger and control checks
were in place to check TAs had been sent to branches daily.

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b) Duplicate TA’s issued for the same dates. I have only known of this on
one occasion whilst managing the Open item teams (from 2016): the IT
supplier, Accenture loaded and sent duplicate/triplicate TA’s for the
lottery. As they had been loaded and sent to the branches, the solution
was to issue correcting credit TC’s to offset the duplicate / triplicate
values.

c) Duplicate TC’s for the same value. I recall these were caused by human
error on two occasions whilst I managed the open item teams, when an
upload file of TC’s was sent out twice. These were corrected by

compensating TC’s and additional controls and training was put in place.

47.Although the above scenarios were rare, a “memo view” was sent on Horizon
to the affected branches, informing them of the issue and corrective action
taken to resolve the issue. A memo view is simply an electronic message
posted onto Horizon. Memo views would have to be agreed first with the

communications team before sending to the branch.

48.The examples I have given above are examples of “system issues” that were
not Horizon system errors, bugs etc. The examples I have given above are
more those that were caused by IT suppliers/Clients for TA’s, and human error

for TC's.

49. There were only a few occasions that I can remember that I came across branch
trading problems due to what may now be referred as a Horizon bug (although

I do not remember it being called a Horizon bug at the time). I believe these

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were for Receipts and Payments mismatches issues. I am however afraid that
I cannot recall the details of these as the issues were managed by Rod Ismay
(Head of FSC) and Andrew Winn (FSC Relationship Manager). I was not aware
of widespread issues or names for Horizon bugs at the time. The iT Service
Management helpdesk would need to be contacted to give details of these

issues, there specific cause and the resolution that was supported by the FSC.

50.1 do have recollection of instances when the FSC was engaged by NBSC / iT
Service Management Helpdesk. If a problem was reported by the branch with
respect to a specific transaction issue that would need intervention by Fujitsu,
these were managed by the iT Service Management Helpdesk FSC would be
engaged and would review if there was a financial impact on the branch prior
to giving agreement for Fujitsu intervention. I believed that this was a controlled
process that had to have sign off from Post Office before any intervention by
Fujitsu. Iam unable to remember the details of these scenarios, or their cause
and detailed input would be needed from Rod Ismay (Head of FSC), Andrew
Winn (Relationship Manager) and the iT Service Management Helpdesk Team
who were involved and managed these issues with Fujitsu. As mentioned
above, to the best of my knowledge these were not referred to as ‘Horizon bugs’

at the time.

51.1 have been asked to consider if it was satisfactory that SPMs were required to

“settle centrally” even where they disputed a TC / TA/ discrepancy.

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52.Settled Centrally was in place due to how the Horizon system operated with
respect to balancing the branch. By settling centrally, the branch would not have
to put in the cash for losses or hold any surpluses; once settled centrally the
branch could still dispute the debt. I believed that this was satisfactory as if this
had not been in place the TCs and discrepancies could have been held in

branch and they could potentially have been ignored.

53.1 have been asked if I agree that the process for challenging TCs / TAs /
discrepancies meant that a deficiency or “loss” was assumed to have been
caused by an error or wrongdoing on the part of an SPM, unless they proved

otherwise.

54.1 did believe that a discrepancy was caused by an error within the branch, and
these could be both losses and surpluses, as I always believed that Horizon
was accurate and there was not the ability for external influence or changes in
the branch account unless via a managed and controlled change re para 50
above. I did not believe that all occasions were “wrongdoing”, but some may

have been.

55.1 have been asked to set out the role played by FSC when a SPM challenged
aTC/TA/ discrepancy through the NBSC helpline and referred to the following
document: paragraph 3.11 of the “Working agreement — ‘Finance Service

Centre and Network” (version 2.12, undated) at POL00088897).

56.1 have covered many of the interactions with the NBSC in the above
paragraphs.

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57.If NBSC sent a query via email or by calling the FSC for a challenged TC/TA
FSC would investigate and respond to the branch or back to NBSC within a

targeted 10 working days.

58.1 have covered system issues raised to the NBSC at para 46-50.

59.Additionally covered in the working agreement POL00088897, FSC also
supplied data to the Network Team of all TCs issued in the month, also
highlighting the branches with the highest number of TCs. This was supplied to
the Network Team to enable them to address non-conformance in the branches

or give support and training.

60.FSC supported NBSC with the knowledge base scripts used by the NBSC
advisors when taking calls from branches to ensure they accurately reflected

the products.

Recovery of Debts

61.1 have been asked about the Recovery of Current and Former agents’ debts.

In doing so I have been referred to:

a) “Losses at SPSO'’s: Guidelines on responsibilities and recovery
arrangements” (understood to be issued in 1988) (POL00083939) (in
particular, paragraphs 15 to 28);

b) “Debt & Losses Reduction - FSC Process Flows” (undated)
(POL00088656) (see, in particular, section 1.9 —- Agents Debt);

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c) “Former Subpostmaster End to End Debt Review” (version 0.5, December
2009) (POL00084977);

d) Presentation on “Former Agents Debt” by Alison Bolsover (undated)
(POL00086338);

e) Working agreement — “Finance Service Centre and Network” (version 2.12,
undated) (POL00088897) (see, in particular, paragraph 3.7);

f) “Fraud & Conformance Team Handover Document” (3 March 2012, revised
July 2012) (POL00002086);

g) “Former Agents Debt Management” (version 1.0, 4 December 2014)
(POL00087471);

h) “Policy document - Operators’ in service debt” (version 1.0, 18 September
2013) (POL00113670 (in particular, sections 6, 7 and 11), as well as the
policy's later iterations at POL00086868, POL00088579, POL00090357

and POL00088312.

Current agent process

62.A “Current Agent” is a postmaster in branch today. Recovery from current
agents was managed and undertaken by the Current Agents Team - a team I

managed from 2007 to 2018.

63.TC’s and branch discrepancies that were settled centrally in branch and created

a debt or surplus were assigned to a customer account in POLSAP. The

customer account was specific to the branch and postmaster.

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64. Branches were placed in different trading groups over a 4 week period, group
A being the first week, group B the second week, group C the third week and

group D the fourth week in the month.

65. Monthly, one week after the branch trading group had completed their balance
(Branch Trading Statement) the Current Agents Team ran a ‘Dunning process’
for the trading group. The Dunning process is automated in POLFS and
generates letters and statements for outstanding debt that has not been

blocked. The Dunning process takes things in stages.

66. The first letter and statement issued under the Dunning process would be sent
one week after branch trading. The first letter/statement would ask for payment,
or the postmaster to contact the team the Current Agents Team to discuss / pay

the debt.

67.If the postmaster did not contact the Current Agents Team, a second

letter/statement would be sent, 3 weeks after branch trading.

68. If no contact was made by the Postmaster, calls would then be attempted to
contact the branch and speak to the postmaster. Four calls would be attempted
if the debt was over £1000. Two calls would be attempted if the debt was under

£1000.

69.For debts under £1000, if the team were unable to contact the branch after two

call attempts, then a third letter was sent to advise the branch that the debt

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would be taken from postmaster remuneration, either in one go or taken in
instalments. Repayment would not be taken for the whole of the debt if it
equated to more than 25% of the Postmaster's remuneration hence why
instalment plans were set up. Any letters sent advising that payments were
being taken would include contact numbers, so the branch could call prior to

any deductions from remuneration being taken.

70.For debts over £1000, If the team were unable to contact the branch after four
call attempts, the debt and recovery of it was escalated to the Network Contract
Managers, to discuss the debt with the Branch and agree a repayment or
payment plan by instalments. Only after liaison with branch by the Network
Contract Managers and confirmation of this to FSC would
deductions/repayment plans be set up. FSC then notified the branch in a third

letter (as above) that the repayments / instalment payment plans had been set

up.

71.\f a branch just refused to pay any level of debt these were also referred to the

Network Contracts Managers following the above process at para 70.

72.Once a deduction from remuneration was completed, the credits would be sent
to the team via HR and were entered onto the customer account to clear the

debt.

73.From the feedback from the postmasters, many of the debts on the customer

accounts were seen by branches as a way of managing their cash flow and

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paying the outstanding amount monthly. If a postmaster had someone
managing the branch, they would have clear visibility of all TCs accepted and
Settled Centrally along with any branch discrepancies. They were then able to

pay off the debt and challenge their staff in Branch if needed.

74. If postmaster did not have the cash to settle the debt created by a TC or Branch
discrepancy, settle centrally would enable them to defer payment until the end

of the month.

Disputed debts

75.During the processes described above, if the postmaster called, or the team
contacted the branch and the postmaster disputed the debt, the debt would be
blocked within POLSAP, given a blocking code to denote dispute. This
suspended The Dunning Process, and an investigation was passed to the TC
issuing team. The debt would not be unblocked or chased until a response had
been given to the branch. If it was a branch discrepancy, it would again be
blocked and passed to NBSC tier 2 to support the branch in finding out how the

discrepancy had occurred.

Former Agents Process

76. “Former agents” refers to someone who has left, or for whatever reasons is no
longer in charge of branch at the time of dealing with the debt. For instance, it
could be that the postmaster had been suspended, was ill, had died, or had

simply moved on. Customer accounts were specific to a branch and the

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postmaster. A new account would be in place for every change of individual

postmaster in the Branch.

77.\n the scenario of a branch debt that had been settled centrally by branch, or
posted by the audit team after a shortage/surplus was found, a process similar
to that used for current agents would be followed. The postmaster would be
sent two letters and a statement of the debt. and asked to contact the Former
Agents Team to arrange repayment. If there was no response a third letter
would be sent to advise the postmaster that civil recovery may be instigated.
Recouping the debt from renumeration was not possible for former agents as

they are simply not in post.

78.The hard copy file for the former agent would hold all details of the former
postmaster, any tracing that was needed, or confirmed forwarding addresses

and their tenure in branch.

79.Evidence in support of the debt would be collated into a bundle, with all the
details of the case and any/all relevant evidence. Each case would be
assessed by the team manager, and a decision made on the viability of
recovery. If viable to pursue, a bundle was prepared by the Former Agents

Team.

80. That bundle was then sent to an external solicitor. Prior to when Royal Mail and
Post Office Ltd business split, the case was sent to Royal Mail Internal Legal
Team (I recall Mandy Talbot). It was for the legal team contact to make initial

contact with the postmaster, requesting payment. After the split from Royal Mail

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further steps taken would depend upon the value of the debt and guidelines
were set on actions to be taken with respect to the cost implications of civil
recovery and internal Legal teams would also be engaged in the cases. I am
unable to remember the agreed steps and values, but these were set out within

a document in the FSC.

Relief from accounting losses / write off

81.1 have been asked to consider the availability of Relief from accounting losses

/ Write off process and referred to the following documents:

a) “Losses and gains policy within the POCL agency network” (version 1, 20
November 1998) (POL00088904) (in particular, section 5 and appendices J
and L);

b) “Post Office Ltd - Security Policy: Accounting losses policy for agency
branches’ (version 1, February 2003) (POL00086845) (in particular, section
4 and section 5);

c) “Post Office Ltd —- Security Policy: Liability for losses policy (for agency
branches)” (version 1.7, September 2003) (POL00088867) (in particular,
section 4 and section 5);

d) “Post Office Ltd Losses policy — overarching (branches)” (version 9,
effective date April 2006) (POL00030562) and appendix 5 “Process for
seeking relief on losses — singletons” (POL00030562);

e) “Product and Branch Accounting — Write Off Process” (version 2.1, July

2009) (POL00087409);

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f) “Policy document - Operators’ in service debt” (version 1.0, 18 September
2013) (POL00113670) (in particular, section 2 — “Write offs”), as well as the
policy's later iterations at POLO0086868, POL00088579, POL00090357

and POL00088312.

I am unable to comment on items a- d as this was prior to my tenure in the

Senior Debt Manager role.

82. The terminology of ‘relief’ being given was prior to my role and not used as far
as I am aware by FSC. The FSC would receive requests for write off and this
could be for example for a newly appointed Postmaster via the Network
Contracts Managers for Postmaster that had only been in post for 6 weeks

which could be class under the relief terminology.

Write off Requests

83.Write off requests could be submitted to FSC by all areas of the business as

documented in the write off policy (POL 00087409).

84.Each write off would be documented with the reason for the write off request

and authorised at the appropriate level. There could be many scenarios for write

off requests. The following areas may request a write off for the following
scenarios:

a) Network Contract Managers/Head of Network, for settled centrally debt

following an escalation;

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b) Security/Financial Investigators, for debt not recovered after their
investigation or criminal proceedings had ended;
c) Network Audit teams, if there had been issues at the audit of a branch;
d) FSC teams for:
I. Aged items that had not been issued as TC’s to branches in a
timely manner;
Il. Aged enquiries from clients
Ill. I TC disputes that after investigation were accepted;
IV. Low value open items;
V. Current and Former agent cases for debt not recovered;
e) Product or Client manager;
f) Cash centres (these were posted directly by the cash services team to
POLSAP);

g) Directors.

not by write off)

85.1 have been asked for my knowledge of options available and chosen by POL

to proceed for the recovery of debts, so when a write off route has not been

chosen or is not appropriate.

86.FSCs role was to liaise with internal / external lawyer in the recovery of

postmasters debt. Prior to the segregation of Post Office and Royal Mail I recall

dealings with Mandy Talbot (from Royal Mail Internal legal team) and then Chris

Darvill and Rodrick Williams in the Post Office Legal Team. External solicitors

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instructed were Beachcrofts, Bond Pearce/Womble Bond Dickinson. I cannot

recall who matters were referred to for Scottish and Irish debt recovery cases.

87. Civil litigation options that were taken, dependant on the value of debt, were:
e Seeking a county court judgment for the debt to be determined;
e Attaching a charge on property to recover the debt once set;
e Applying for an attachment of earnings order (this was rarely done, so

far as I am aware).

88. Civil recovery actions for recovery of postmaster branch debt would not have
been progressed if there was an internal investigation — by Security /Financial

Investigators - or if Criminal Proceedings were taking place.

89.The Current and Former Agent's teams in FSC were not the only teams that

completed debt recovery activities.

90.The Security and Investigations Team also recovered debt via their
investigations and criminal prosecution cases. Input would need to be sought
from the Security and Investigations Team with respect to these cases and the

recovery options available to them for Postmaster and Crown Employees.

91.The decision on whether to take such proceedings with respect to Criminal

Proceeding fell to the Security and Investigation Team.

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92.1 did not have, nor did FSC, have a role in the decision making relating to

whether Criminal proceedings were progressed.

93. If, as a result of Criminal prosecution case, recoveries / repayments were made
for debt on a postmasters Customer Account, the FSC would be responsible
for recording (‘posting’) the credits to the postmaster customer account. If no
debt was held by the FSC team, Security and Investigators, or their Finance
Analyst, would post the recoveries within their business area and to a Security

cost centre which fed to the profit and losses accounts.

Debts where underlying Horizon issues were involved

94.1 have been referred to the emails at POLO0073012, POL00057991,
POL00058295, POL00073165, POL00086835, POL00061561, POLO0065615,

POL00087648, POL00079022 and the note at POL00085749.

95.1 shall address my knowledge of what approach was taken to instigate or

continuing with debt recovery proceedings against SPMs / former SPMs
a) who had raised issues about Horizon; and / or

b) whose cases were going through the mediation scheme / being

reviewed by Second Sight

and what were the key considerations which informed decision-making in this

respect.

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96.1 believe the first issues raised with respect to Horizon were via the Justice for
Sub postmasters Alliance (JFSA) and then by Second Sight. A list of these
cases was sent to FSC by the POL Legal Team. If hard copy files were held on
these cases, they were copied and supplied to the legal team, the files copied

had an orange cover to denote they had been sent to the Legal Team.

97.From the Email POL00073165 it appears that there were 23 cases with respect
to JFSA. For the cases that had a debt, I discussed these during a visit from
Susan Crichton (General Counsel) and Alwen Lyons (Company Secretary) and
recommendation to proceed was initially made, but during the discussion with
Susan she requested a risk /cost analysis be completed. This was produced by
Emily Springford (Royal Mail Legal Services Team) (POL00085749). A paper
was suggested to gain Susan’s authority to proceed (POL00073165). I am
unsure if Susan had then left the Business as Chris Darvill / Rodrick Williams
were copied into these cases (POL00058295) along with Angela Van Den

Bogerd and Alwen Lyons. (POL00057991).

98.The instruction to freeze recovery actions for JFSA and Second Sight cases

was given by Rodrick Williams in May 2013 POLO0061561.

99.POLs internal policy on managing any civil proceedings was suggested to
Rodrick Williams by Andrew Parsons from Bond Dickinson in October 2013
(POL00086835). With respect to Mediation cases and where Postmasters had
made an application to the Mediation Scheme

e Pre-action recovery would be suspended;

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e Live civil litigation will be stayed;
e Judgment /enforcement action would not be pursed (unless there
was a credit risk and then POL may seek a charging order to secure

its judgment).

I was not however copied into this email. Rodrick stated that he would run it
past me and gain a view on the approach and impact it may have on debt

recovery but I unable to remember this or give any further details.

100. Meetings were held with the internal legal team (Rodrick Williams),
(POL00087648/POL00079022) the Mediation Scheme lead (Mark Underwood)
and external solicitors to seek input with respect to the cases that were in the
categories above at Para 102 and next steps that should be taken. Each case

would be summarised as:

a) Cases outstanding

b) Time barred

c) Resolved cases

d) No debt held or previously written off
e) Bankrupt/IVA

f) Limitation deadline dates

101. Instructions with respect to next steps (i.e. keep the cases on hold or continue
with BAU recovery) were given by Rodrick William, Mark Underwood
POL00087648) and Angela Van Den Bogerd, as I would not necessarily have all

the details of the background discussions on these cases. My role was to input into

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the meetings with regards to the above a - f and instruct the FSC team to either

keep the cases on hold or proceed with BAU debt recovery.

102. If a postmaster that had debt on their customer account had raised issues
about Horizon, this should have been flagged to the Former Agents’ team in FSC,
and the debt either blocked or confirmed by POL Legal that FSC should proceed
with BAU recovery actions (POL00087648). The information received in FSC with

respect to the challenges was from POL Legal Team and Mediation Team for:

a) Mediation Cases.

b) Cases referred to CCRC.

c) Cases raised by Second Sights.

d) Cases raised by JFSA (Justice for Sub postmasters Alliance)
e) Cases raised via MPS

f) Cases held by The Security and Investigation Team

103. Meetings were held (POL00087648) with the internal legal team, Rodrick
Williams, and the Mediation Scheme lead (Mark Underwood) along with external
solicitors to seek input with respect to the cases that were in the categories above
at Para 102 and next steps that should be taken. Each case was summarised as:

a. Cases outstanding

b. Time barred

c. Resolved cases

d. No debt held or previously written off

e. Bankrupt/IVA

f. Limitation deadline dates

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104. Instructions with respect to next steps (i.e. Keep the cases on hold or continue
with BAU recovery) were given by Rodrick William, Mark Underwood and Angela
Van Den Bogerd as I would not necessarily have all the details of the background
discussions on some of these cases. My role was to input into the meetings with
regards to the above a - f and instruct the FSC team to either keep the cases on

hold or proceed with BAU debt recovery.

105. If the FSC team were given information during the review of a case holding
Debt that could indicate Horizon issues these were flagged to Rodrick Williams.
POL00065615 was a Criminal Prosecution case where, after gaining an order
under the Proceeds of Crime Act, the Postmaster applied to set it aside and the
case was adjourned pending the outcome of referral to the Criminal Case Review
Commission. FSC would not have been progressing Civil recovery actions on this

case as it sat within the Security Team.

106. The approach advised by Rodrick Williams (POLO0079022) for Current
Agents that claimed that Debt was due Horizon issues, in 2015, was that FSC

responded to the postmaster:

e That no evidence has been put forward to support allegations that

Horizon caused branch Losses
e Ask the Agent to provide specific details of the allegation e.g.,
transaction type, date and value plus any supporting documentation; but:

e Inthe absence of anything material, the debt is payable.

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Knowledge of bugs, errors and defects on the Horizon system

107. I have been asked about matters relating to knowledge of bugs, errors and
defects in the Horizon system. I have been referred to the email chain at
POL00095547, I am unable to recall this incident and questions with respect to this
Email and it referring to a bug. I feel it would be better to direct any questions on

this to Doug Brown and Michael Howarth.

108. I have been referred to document POL00098016. I believe this is referring to
the Receipts and Payments mismatch that I have briefly covered in para ,49 above
and any questions on this could be better directed to Rod Ismay (Head of FSC and

Andrew Winn (Relationship Manager).

109. After Horizon was introduced my understanding, at the time, was that there
were very few bugs within the Horizon system. However, I and FSC would not have
been involved and aware of all such issues as the issues could/would have been
raised to the NBSC, raised to Auditors, raised to the Security and Investigations
Team and the Network Contract Managers. I have no knowledge of the escalation
process for these areas with respect to claims that there was Horizon bugs. FSC
was simply not always engaged on these incidents. If any issues raised (as in para
49 - 50) FSC would be engaged in the investigation to understand the issue, next

steps and resolution.

110. I have been referred to section 6 of the “Post Office Ltd —- Security Policy:

Accounting losses policy for agency branches” (version 1, February 2003) at

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POL00086845) and the same section in the “Post Office Ltd —Security Policy:
Liability for losses policy (for agency branches)” (version 1.7, September 2003)
(POL00088867). I am unable to comment on these 2003 policies as I was not in
the Senior Debt Recovery role at this time. I have no recollection of these policies

or ever having to refer to them.

111. I have been referred to the email (POL00097787) which refers to Horizon
reversing a transaction that was raised by Second Sight and the postmaster.
Reading the email, it is suggested this was due to a connectivity issue, i.e. when
the Horizon kit lost connectivity and a transaction was not confirmed or failed. As
far as I was aware, a recovery process was in place for branches with respect to
recovery after connectivity issues and the steps the Branch needed to take. Fujitsu
should have been able to confirm and evidence the connectivity issue. It appears
due to no budget being held by FSC, evidence via a report was not requested from
Fujitsu at the time of Andrew Winn’s response to the postmaster. The budget for
such reports was held within the Security team. The email was sent to Gareth
Jenkins within Fujitsu for a response but there is no response within the bundle of
evidence I have been given. As far as I can see from the email I have been referred
to, the matter was addressed by my colleague Andrew Winn, writing to the
postmaster by letter of 14/12/2012 and a response to Second Sight is suggested
via the Legal Team (Rodrick Williams). I have no sight of either the letter to the
Postmaster or the response given to Second Sight. I am therefore unable to

comment further on this email and the scenario addressed.

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112. I have been asked if there is anything I wish to say, applying what my
understanding now and what I did not know at the time. I would like to say that it
was always my belief that Horizon was accurate and whilst there can be issues
with any computer system, any changes made were always in a control and
managed way with sign off from POL. I was extremely shocked and upset when I
became aware during the Horizon Civil Litigation trial the Fujitsu representative,
Richard Roll said that they (Fujitsu) were making changes to postmaster branch
accounts without any discussion with POL. This puts my belief into the accuracy
of Horizon totally into question, and makes me extremely sad when considering

the potential impact of this.

Statement of Truth

I believe the content of this statement to be true.

Alison Bolsover

Dated: 05/05/2023

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Index to First Witness Statement of Alison Bolsover

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URN

[I Document Description

Control Number

POL00083939

Post Office Ltd Guidance on
Losses at SPSO's: Guidelines on
Responsibilities and Recovery
Arrangements (1 May 1988)

POL-0080997

POL00088904

Post Office Ltd Policy on Losses
and Gains within the POCL
Agency Network (20 November
1998)

POL-0085962

POL00086845

Post Office Ltd Security Policy:
Accounting Losses Policy for
Agency Branches (1 March 2003)

POL-0083903

POL00088867

Post Office Ltd: Liability for Losses
Policy for agency branches (version
2.0, January 2004)

POL-0085925

POL00030562

PO Overarching Losses Policy (1
April 2006)

POL-0027044

POL00113670

Operators’ In Service Debt (18
September 2013)

POL-0112554

POLO0086868

POLICY DOCUMENT- Operators’
In Service Debt (version 1.1, 22
October 2013)

POL-0083926

POL00088579

Postmasters’ In Service Debt
Policy v1.2 draft (8 February 2019)

POL-0085637

POL00090357

Policy document - postmasters'
lifecycle issue, policy issue 8,
(version 2.0, 4 December 2014)

POL-0087326

10

POL00088312

POLICY DOCUMENT-—
Postmasters’ In Service Debt
(version 0.3, 1 April 2017)

POL-0085370

11

POL00088124

Mandatory Losses & Gains Policy
Crown Office Network” (version 1.0,
24 April 2013)

POL-0085182

12

NFSP00000169

Letter circulated to the National
Executive Council enclosing
correspondence regarding debt

VIS00007617

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recovery process (17 December
2004)

13

NFSP00000043

Negotiating Committee for Horizon
debt recovery (18 November 2004)

VvlS00007491

14

POL00085794

Debt Recovery Process under
Branch Trading (1 October 2005)

POL-0082852

15

POL00083951

Process for Awaiting TC
(Transaction Correction) -
Multiples (version 1,15 December
2005)

POL-0081009

16

POL00083952

Process for awaiting TC
(Transaction Correction) -
singletons (version 1, 15
December 2005)

POL-0081010

17

POL00003060

Post Office Limited Process
Documentation - Branch
Correction Process (version 2.0.
Undated)

VIS00004074

18

WITN03980100

WITN03980100 — First Witness
Statement Susan Harding (4
October 2022)

WITN03980100

19

POL00026854

TC/Debt Recovery review - key
feedback issues (Undated)

POL-0023495

20

POL00088897

Working Agreement - "Final" -
Finance Service Centre and
Network (version 2.12, 20
December 2012)

POL-0085955

21

POLO0088656

Debt & Losses Reduction: FSC
Process Flows (Undated)

POL-0085714

22

POL00084977

Post Office, Former SPM End to
End Debt Review (version 0.5, 1
December 2009)

POL-0082035

23

POL00086338

POL Former Agents Debt: Alison
Bolsover (undated, date inferred
from chart) (1 January 2013)

POL-0083396

24

POL00002086

Fraud & Conformance Team
Handover Report (1 July 2012)

VIS00003100

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WITNO6120100
WITNO6120100

25

POL00087471

POL Process Former Agent Debt
created by Michelle Stevens (4
December 2014)

POL-0084529

26

POL00087409

Product and Branch Accounting -
Write off process (1 July 2009)

POL-0084467

27

POL00073012

Email chain between Emily
Springford, Jacqueline Whitham &
Joe Napier, cc Zoe Topham,
Alison Bolsover & Rebekah
Mantle, regarding
Leitrim/Katherine McAlernaey
case (21 September 2011)

POL-0069575

28

POL00057991

Email from Angela Van-Den-
Bogerd to Alwen Lyons; Alison
Bolsover; Chris Darvill, re: MPs
visit (7 June 2012)

POL-0054470

29

POL00058295

Email between Rodric Williams
and Chris Darvill re papers for
Second Sight review (14
September 2012)

POL-0054774

30

POL00073165

Email chain between Sabrina
Jethwa, Chis Darvill, Alison
Bolsover & Emily Springford -
case recommendations (30
January 2012)

POL-0069728

31

POL00086835

Email from Rodric Williams to
Andrew Parsons, Chris Aujard re
civil recoveries and the mediation
scheme (31 October 2013)

POL-0083893

32

POL00061561

Email from Alison Bolsover to Rod
Ismay re suspending civil action
(25 July 2014)

POL-0058040

33

POL00065615

Email from Rodric Williams to
Patrick Bourke, Confidential - FW:
Birkenshaw Mr Khayyam Ishaq
163306 (10 January 2015)

POL-0062094

34

POL00087648

Email from Mark Underwood to
Ailson Bolsover, Andrew Parsons
re recoverable debt assoc with
applicants to the scheme (29 June
2015)

POL-0084706

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35

POL00079022

Email from Andrew Pheasant to
Mark Underwood and Rodric
Williams re debt claims involving
Horizon allegations (28 August
2015)

POL-0075585

36

POL00085749

Claims against subpostmasters
(spmr’s) who have raised Horizon
issues in the past - key benefits
and risks (20 December 2011)

POL-0082807

37

POL00095547

Email from Doug Brown to Andy
Hayward, Sue Richardson, Alison
Bolsover and others re: Scope of
declarations (21 April 2011)

POL-0095130

38

POL00098016

Email from Andrew Winn to Steve
Bansal dated 16/04/13 re:
investigation into receipts and
payments problem in 2010 (16
April 2013)

POL-0097599

39

POL00097787

Email from Andrew Winn to Gareth
Jenkins, Rodric Williams and
others re: SROO1 Strictly Private
and Confidential — Subject to
Legal Privilege — Not for Wider
Circulation (25 March 2013)

POL-0097370

Page 46 of 46