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Witness name: Christopher Granville Knight
Statement No: WITN08290100
Dated: 23 November 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF CHRISTOPHER GRANVILLE KNIGHT
I, CHRISTOPHER GRANVILLE KNIGHT, will say as follows;
1. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
“Inquiry”) with the matters set out in the Rule 9 request dated 23 October 2023
(the "Request").
2. I can confirm I was assisted by the Post Office (PO) in confirming insurance
coverage for support in preparing my statement. I have also been assisted by
DAC Beachcroft LLP in the preparation and drafting of my statement.
Background
3. I am a current employee of Post Office Limited (POL) having joined in January
1983. I have set out a summary of my career at POL including the positions I
have held, the dates I held them and a brief description of what each role
entailed:
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a. Jan 1983 — April 1984 - Working for POL as a Postal Assistant grade in
PO Stores Branch, located in a Head Post Office. I was responsible for
distribution forms and stationery to Head Office departments that were
located within the building and also to Crown Post Office branches within
the geographical area.
b. April 1984 — 1987 — Working for POL as a Postal Officer grade on the
Head Office Counter. This was pre-Horizon, or any other
electronic/computer system, and was all manual paper-based
transactions. I was responsible for serving customers with all Post Office
transactions that were available at the time. We used to balance our own
tills weekly.
c. 1987 — 1993 — During this time the Post Office underwent a business
restructure/change and Royal Mail Letters and Post Office Counters
became two separate entities. I remained working for the Post Office as
a Postal Officer grade working in the Cash Remittance Unit (CRU) in the
Head Office building. The role involved processing business cash
deposits and sending cash and stock (stamps) to PO branches within
the catchment area of the Head Office. It also involved receiving cash
and stock from PO branches within the catchment area of the Head
Office.
d. 1993 - 1997 — Working for Post Office Investigation Branch (POID) as a
Postal Officer grade. I was predominately responsible for pre-
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employment checks of staff applying to join Post Office, Royal Mail or
Parcelforce by checking applications against a database of previously
debarred staff as well as general admin duties.
. 1997 — 2000 — I applied and was promoted within POID to an Assistant
Investigation Officer (AIO), a manager grade. I underwent the initial
internal training, which I believe was three weeks, delivered by two
experienced POID Investigators. This covered the process of
investigating suspected criminal offences against Royal Mail (theft of
mail). The role involved complying with the Police and Criminal Evidence
Act (PACE). I used POID Investigative forms during investigations. The
forms included: Friends at Interview, Legal Advice for Persons being
Interviewed, Searches (person, car and property) and the Health &
Safety and Treatment of Investigators and Suspects and Witnesses
during an Investigation. There were a number of teams within POID at
that time. After training I was assigned to one of these teams and an
experienced Investigation Officer (10), who was a grade above me,
acted as my mentor. We investigated counterfeit/re-used postage
stamps, usually by persons external to the business.
During this period (1997 — 2000) POID underwent a structure change
and also changed its name to Post Office Security and Investigation
Service (POSIS). I moved into a team investigating the theft of Special
Delivery mail bags/items within the Royal Mail nationwide pipeline. We
covered handover points within the network; railways stations, airports
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and the Travelling Post Office (TPOs) trains. This team consisted of
established Investigators and so was a good learning opportunity.
2000 — 2003 — Following a business re-organisation staff were given a
preference exercise to select which business unit they would prefer to
work in. Due to my experience of working in the Rem Unit (now known
as Cash Centres) I opted to move to the newly formed business unit
"Cash Handling & Distribution" that was an amalgamation of CashCo
(the in-house Cash in Transit (CViT) service) and the Cash Centres.
Back in those days the CViT used to service both Post Office branches
and also small businesses collecting banking deposits from businesses
and taking them to our Cash Centres to be processed and banked.
I was initially the lead investigator, conducting investigations into
possible criminal offences involving CViT and cash centre staff,
conducting PACE interviews and compiling case papers and files for
prosecutions which were then submitted to PO Legal Team for advice. I
would then obtain Summons’ and attend Court as necessary. On
occasions it was necessary for me to report the offences to the Police
and liaise with them as required during their investigation providing
specialist business knowledge.
The role soon became one of physical security as well as the team
aligned to the current Security Managers. This was both security
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equipment as well as processes and procedures within the CViT and
Cash Centre environments.
g. Approx 2003 — 2016 — I worked in POL with established investigators
investigating possible criminal offences within the network. This related
to both Directly Managed Branches (DMB), formerly known as Crown
Branches, and also the branch network. I was responsible for conducting
investigations and all that was involved, as mentioned in my previous
roles as an AIO. This role was the same grade, just a different job title,
Investigation Manager. There was also an element of physical security,
again as mentioned previously.
2016 to date — Working in the Intelligence (Intel) Team within the Post
Office Security Team. We are the point of contact for POL for Law
enforcement. We have no involvement in internal investigations.
4. The Inquiry has asked me to provide details in relation to my positions as an
Investigator, Investigation Manager and my role within the Fraud Team. These
were slightly different titles for the same role but in different sections/functions
of the business. The business has gone through numerous re-organisations of
the reporting line and structure, but the role of ‘investigator’ remained
predominantly the same as what I have set out below.
5. The Inquiry has asked me to provide further details in regard to my role as an
Investigator within the Security Team. I became an Investigator in 1997 and
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worked in the Post Office Investigation Department (“POID”). I undertook an in-
house three-week training course (as I recall) that covered the Police & Criminal
Evidence Act 1984 Codes of Practice (“PACE”) and the relevant POID forms
that were used during an investigation ensuring adherence to PACE. The forms
included, but this is not an exhaustive list, the Explanation of a Person’s Legal
Rights, Witness Statements and Undertaking a Search.
6. The course also included training on report writing in the context of
investigations, how to complete a tape transcription, the structure of case
papers and the appendix envelopes associated at the rear of the case papers;
Appendix ‘A’ — Witness Statements; Appendix ‘B’ — tape transcripts and
evidential items; Appendix ‘C’ — Miscellaneous.
7. I recall that towards the end of 1999 I started an NVQ Level 4 in Investigation. I
remember I started it while I was working in POID and then when I moved to
CH&D in 2000, I continued with it but for some reason I did not finalise it even
though I completed all of the sections. I think the assessor left the business.
8. When I moved into CH&D (2000) there was a mandatory CViT crew training
course to complete (1 week) in order to obtain a Security Industry Association
(SIA) licence, a requirement to work in the CViT industry. There was also other
training in security equipment; vehicles, security equipment and processes
within both Cash Centres and CViT Depots.
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9. When I moved to POL in 2004, I initially worked with established POL
investigators. As far as I recall a lot of the investigations were regarding
Pension & Allowance fraud. As I remember these cases were usually raised
by the Department for Work and Pensions (DWP) and there was a lot of
liaisons with their Fraud Team.
10. During this time, although I cannot recall exactly when, I attended
Chesterfield future Walk building to receive counter training. The training
would have given a basic understanding of Horizon i.e., how the system
performed transactions, not data analysis. There was also a refresher course
where we were tasked with working in the DMBs for 3 days during the
Christmas period and again when we were tasked with covering strike action
in the DMBs (possibly 2006-2008, I cannot recall exactly). We also received
training on security equipment at various times when I was within POL as the
role covered both investigative and physical security. I also recall Cartwright
King giving specific training which covered notebook use, interviewing and
disclosure to solicitors at interview.
11. The forms used as part of an investigation were numbered and prefixed by the
relevant business unit. For example, the Legal Rights Form 001 was numbered;
1D001, GS001, CS001 and POLO001. My understanding/recollection of these
codes being the Investigation Dept, Government Services, Corporate Security
and Post Office Ltd.
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12. My role was to investigate possible criminal offences within the specific
business unit I was working in at the time. I was a manager by grade but did
not have anyone working to me. I had a Line Manager who would have been
the grade above me and who changed over the years and as I moved business
units. The Line managers I can recall are Charlie Bint (POID), Danny Boles
(POID), Chris Lawrence (CH&D), Manish Patel (POL), Lester Chine (POL),
Keith Gilchrist (POL), Andrew Daley (POL), Alison Drake (POL), Helen
Dickinson (POL).
13. I always found my colleagues to be professional and competent and never had
any doubts about working with them. My Line Managers were again
professional and competent. Some of my Line Managers had been
investigators within the Royal Mail/POL whereas others may not have had
internal investigative experience but had worked in law enforcement. Some
had skills relevant to the business unit I was working in at the time. This would
have been physical security and not investigative knowledge.
14. As an Investigator we did not cross into the discipline sphere, that would be
either HR, a Senior Manager or in the case of the Network a Contract Manager.
15. As part of a criminal investigation there would be the general disclosure made
by the Lead Investigator using the forms 006 (A, B, C & D). These would be
verified by the Legal Team.
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16. I was not involved in any Litigation Strategy. I would assume this would be
done by much more senior people within the business.
17. I would liaise with other Post Office departments when progressing a case.
This could be the Contract Team, HR and/or the Finance Service Centre, which
had various teams within it e.g., the Lottery Team, Cheque team, Postal Order
Team etc. I am sure there were other teams I liaised with, but I cannot recall
them now.
The Security team’s role in relation to criminal investigations and prosecutions
18. From what I can recall, the Head of Security was John Scott. Below him was
his Lead Team which I think was Andy Hayward, Dave Pardoe, John Bigley
and possibly others. They were responsible for ensuring the teams strategy
remained in line with the business strategy. Below that there would be Team
Leaders / Senior Managers then the Security / Investigation Managers and a
small number of admin grade staff. There were Physical Security Managers and
Investigators, and their roles did not cross at first. As I recall, as I had both
Physical Security and Investigative knowledge, from my Cash handing and
distribution CH&D days I would perform these functions when required as
CH&D, which changed its name to Supply Chain when it came under POL, so
we were their Security Team (both Physical Security and Investigative).
19. As the years moved on the Post Office had various re-organisations which
affected other teams not just the Security Team. This usually meant a head
count reduction. There was one re-organisation where everyone had to work
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from a ‘hub’ (which were the main POL locations). I know this affected some
staff and due to the hugely increased travelling distance they left the Security
Team. Sometime after we had an intake of approximately six new members all
recruited externally. I think this would have been around 2011 to 2013 but I
cannot recall the exact dates.
20. The Inquiry has asked me to explain my role in the development and/or
management of any polices within the security team. I can confirm that I did
not have any involvement in the development or management of any policies,
and this would have been done by more senior members in the team.
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. The Inquiry has also asked me what role I had in the development and/or
management of any policies, taking into consideration POL00104909
(Separation Project — Criminal Investigations Policy for Post Office Ltd),
POL00123309 (Email from Dave Posnett dated 09/07/2014) and
POL00123310 (Royal Mail Group Security Investigation Communication 6-
2014 — Joint investigation protocols RMGS and PO Ltd security), POL00123311
(RMG 2.2. Joint Investigation Protocols - RMGS and PO Ltd Security July
2014), POL00123312 (MOU on joint investigation protocols post independence
involving Royal Mail and Post Office Ltd security) and POL00126976 (Email
from Dave Posnett dated 11/09/2013), within POL post-separation. Again, I
can confirm I did not have any involvement in the development or management
of these policies, or any policies post separation other than POL0012243 which
I am listed as author. That was something I was asked to create but it never
came to fruition and so was never used.
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22. The Inquiry has also asked me what legislation, policies and/or guidance
governed the conduct of investigations conducted by the Security team during
the period you worked within it. The Police and Criminal Evidence Act 1984
(PACE) was the main legislation as all our investigative forms were designed
to adhere to this. The Regulation of Investigatory Powers Act (RIPA), which
was for any CCTV, and the Criminal Procedure and Investigation Act (CPIA)
were also key pieces of legislation.
23. The Inquiry has asked me what the process was for dealing with complaints
about the conduct of an investigation by the Security Team. I not sure of the
process or if there was one. I would expect if a SPM had an issue with an
investigation, they would raise it with their contract manager or the National
Federation of Sub Postmasters (NFSP) who would then follow up the issue with
the senior management in the Security Team.
24. The Inquiry has asked me what supervision there was over criminal
investigations conducted by Security Managers. From what I can recall
between 2004 to 2007 senior managers would view case papers that were
submitted for Legal Advice via our Casework Team and would add comments
or give advice to the Investigator. I believe this then grew into the Case
Compliance process. This was a check list setting out a list of actions to ensure
everything had been completed correctly. In addition, during my latter years as
an Investigator there was a monthly Cases on Hand meeting where Security
Managers would provide updates on their cases and what actions were needed.
The team leaders would discuss and come back with any recommendations. In
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general, I could always ask my team leader or a peer for advice on a current
investigation. But my memory of how things changed over the years is not
complete.
25. As far as I can recall, the investigation and prosecution of SPMs, assistants
and Crown Office employees was the same. I think that around 2011 or 2012
there was a change and SPM assistants were not prosecuted. Instead, the
SPM was advised to report them to the Police. This would have come down
from the Lead Team.
26. The Inquiry has asked me to review POL00123743 (Email from Elaine Spencer
dated 31/07/2015) and POLO0123840 (Email from John M Scott dated
20/01/2016). These documents are dated 2016 by which time I had moved to
the Intel Team with my colleague Andrew Wise under Elaine Spencer. I was
not involved in any investigations at this time and by then the appetite for
prosecution had ceased as it had been slowing down from about 2013. As I
recall any investigation cases on hand were being closed as NFA (No Further
Action). I believe this was around the time of the Group Litigation Order.
Cartwright King were the Solicitors at the time, instead of POL Legal Services
which was just Jarnail Singh.
27. From what I recall, sometime between 2013 — 2016 (although I am unsure of
the date), the investigators were told by John Scott that we would be
prosecuting again once an SME (Subject Matter Expert) was found and had
been appointed. This never came to fruition.
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Audit and Investigation
28. In my experience an investigator would attend an audit with the auditors if the
audit had been requested by the investigator as part of an investigation where
a PM or branch staff would potentially need to be spoken to. Alternatively, an
investigator may attend during an audit if this was a general scheduled audit,
and a large loss was discovered. I believe that as part of the auditor’s process
they had to inform a number of people if a large loss was discovered in branch,
one being the Security Team Leader for the geographical area of the branch.
The investigator would not take an active part in the audit but would attend to
understand the outcome and to follow up with an investigation if necessary.
29. In the early 2000s an investigator was more likely to get called to an audit to
enable them to approach the SPM and/or staff and arrange further enquiries.
In later years this approach diminished as auditors were instructed to write
down any significant comments made by the SPM or staff. The auditors were
trained in this and the fact that they should not solicit comments as they should
not get into an interview scenario. This relates to adhering to PACE (Cautioning
someone before they were asked or if they were starting to admit to a crime).
30. In order to determine if an investigation was to take place the information would
be given to an investigator by the Team Leader. It is my understanding that the
decision would be made if the loss reached a threshold (from memory I think
this was £5,000) or there was suspected/admitted dishonesty. If the matter was
being dealt with by the Contract Team and there was no suspected criminality
an investigation case would not be raised.
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31. In my experience the recovery of debt was not decided at the outset of an
investigation. As above, if there was no criminal investigation the matter would
have been dealt with by the Contracts Team and my understanding is that they
would deal with the branch and any debt. This process was not part of the
Investigation Team’s remit.
32. Once a criminal investigation had been concluded the Legal Team would
advise of any charges and if there would be a claim for compensation. I’m not
sure when but at some point, the PACE was utilised when there was a
conviction. I cannot recall when but over the years POL had some senior
investigators (Ged Harbinson, Paul Southin, David Posnett, Graham Ward and
Helen Dickinson) who underwent training to become accredited Financial
Investigators. During the investigation of a case the decision as to what crime
(Theft or False Accounting), if any, had been committed and the points to prove
would have to be covered. The relevant information would be passed to the
Legal Team who would have the final decision on whether a case should
progress to court.
33. When I received a case for investigation, I would start by understanding the
background including the audit result and why the audit had taken place.
Usually, the branch was targeted for audit as the branch had come to the
attention of the Branch Analysis Team (BAT) due to anomalies or concerns.
For example, this may be because the branch had not returned cash when
asked to do so or had completed suspicious transactions such as a large
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number of reversals or excess spoiled postage. I would also obtain the last 3
months of Credence data to view the updated data in relation to concerns raised
by BAT. If necessary, further archive data may have been needed via the ARQ
process.
34. I would also obtain a Police National Computer (PNC) person check and a
credit check. The PNC would be used to complete the Planned Operation Risk
Assessment (PORA) for when a suspect is to be approached and a location is
due to be visited.
35. I would speak to the relevant Contracts Manager to ensure they know I am
dealing with the case and the point of contact should we need to update each
other. As the investigation progressed engagement with the Financial
Investigator (Fl) may be required dependant on the case.
36. Once the interview had been conducted, I would seek Legal Advice on what
further action was required. For example, further interviews or statements may
be needed where more information or clarification was required.
37. I would also arrange for Human Resource (HR) data to be provided giving me
detail of the PM and any assistants, including their Horizon User IDs.
38. NBSC (Helpline) call logs were also requested to understand if the branch had
been reporting issues that related to the enquiry.
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39. Following the interview, we would ask for authority to obtain bank statements
directly from their bank. Other financial details (loans, mortgage) would also be
request at this time.
Decisions about prosecution and criminal enforcement proceedings
40. Once the investigator had concluded the investigation or got to a point where
legal advice was needed, the case file would be passed to the Legal Team who
would decide if a case was to be taken to Court. The Designated Authority
Manager (DAM), a Senior member of the Security Team, would give the final
consent to continue to prosecution. The Contract Manager would also be aware
that a criminal investigation was taking place and would manage the contractual
process. As far as I am aware, the Contract Manger did not have any input into
the decision making but I do not have a full knowledge of their process.
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. The Inquiry has asked me what test was applied by those making prosecution
and charging decisions and what factors were considered at the evidential and
public interest stage. The evidential and public interest decision would have
been made by the Legal Team. My understanding is there were two parts; was
the evidence strong enough and was it in the public interest. Once the Legal
Team had advised of the decision to prosecute, they would supply details of the
offences to be charged to the Investigator by a memo added to the case papers
which were returned to the Investigator.
42. The Inquiry has asked me to confirm the circumstances in which steps were
taken to restrain a suspect's assets by criminal enforcement methods, such as
confiscation proceedings, and when and who decided to pursue these methods.
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The decision to restrain a suspect’s assets by criminal enforcement methods
would be made by the Financial Investigators. In later years they were notified
at the start of investigations that had a large loss.
Training, instructions and guidance to investigators within the Security Team
43. Every interview regarding a criminal offence was governed by PACE. To that
end every interview of this nature regardless of whether it was a SPM, SPM
Assistant or Crown Employee suspected of a criminal offence would follow the
same format. The interview process has been fundamentally the same since I
had my initial training in 1997 to be an Investigator.
44. Since my initial training in 1997 there were a number of refresher/additional
courses dealing with interviewing and taking statements. I don’t recall exactly
when these took place. I remember one piece of training which explained an
interview strategy called TEDS PIE which is an acronym for ‘Tell me, Explain
to me, Describe to me, Show me, Precisely, In detail, Exactly.’
45. I recall, but cannot fully remember, that there was some specific training for
taking witness statements, in addition to the original training I undertook in
1997. There were various models that were taught for example the ‘Peace
Model’ and ‘Pelt’. These acronyms stood for Plan, Engagement, Account
(clarify and challenge), Closure, Evaluation and People, Event, Location, Time.
46. As with interviews, searches were guided by PACE and there were specific
forms to use that would ensure compliance with PACE. The rules when I was
initially trained required there to be three people (PO Security staff) at a search.
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This was later relaxed to two. The search PO Security Rules stated that the
subject could have a PO friend present. That person had to be a PO employee,
not involved in the inquiry, or a representative from a recognised union. This
was later extended to include a friend or neighbour for house searches.
47. Investigators had a duty to investigate a case fully. During an investigation any
evidence / information that came to light would be looked and assessed and
reported, whether it pointed to or away from the suspect. Also, every line of
enquiry that was reasonable would be followed. I would have been aware of
this process through the polices that were in place and training that was
provided although I can no longer remember the specifics.
48. In regard to obtaining evidence in the course of an investigation usually a
branch would have come to the attention of the Branch Analysis Team due to
abnormal transactions or cash levels that were increasing and a branch not
returning excess cash when requested, excess spoiled labels or other issues. I
would check the data requested which usually was the last 3 months of
Credence to confirm these potential issues. I would also check for suspicious
transactions, which I had seen previously, such as excessive reversals or
spoiled postage. In order to have information as evidence a statement would
need to be obtained in order for it to be allowed in Court. The Legal Team would
advise if there was something specific needed to satisfy the requirements for
building a case for prosecution. Fujitsu supplied archive data (ARQ) for data
older than three months as that could not be obtained from Credence. With a
request for ARQ data there was a provision that Fujitsu would provide a witness
statement for the data produced if needed for Court. PO Security had a process
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where this could be requested by completing a PO form and submitting it to
Fujitsu. I would have been aware of how and where to gather relevant data for
an investigation from my initial training and through knowledge shared by my
colleagues.
49. As mentioned previously in this statement the investigator disclosure obligation
would be by discharged by completing the various PO SEC disclosure forms
006 A, B, C & D. I would have been aware of the disclosure forms from the
policies that were in place although I can no longer remember the exact policy
in place during my time in the team. I also received training when I joined the
team as well as guidance from the Legal Team.
50. In regard to drafting investigation reports the investigator would complete a
Suspect Offender Report that was in essence a template which needed various
information completed i.e., the first page needed to be completed with the
suspect's details and the preamble and then other various points. After the
report was complete it would be paginated in the green jacket case file with
other items such as the typed interview summary and the appendix folders A,
B and C at the rear. This ‘green jacket’ would have a red label attached that
signified it was urgent. It would then be passed to the case file team and on to
the Legal Team for their advice. Then at some point it would be returned to the
investigator for either further enquiries, closure (NFA) or to obtain a Summons
and continue with the prosecution.
51. The Inquiry has asked me whether I was provided with the Casework
Management document for either 2000 POL00104747 (Casework
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Management Policy (version 1.0, March 2000)) or 2002 POL00104777
(Casework Management Policy (version 4.0, October 2002). In relation to
POL00104747 I do not recall seeing it, but I do recall some of the details. I can
see POL00104777 covers the practice of preparing two reports, a Legal report
and a Discipline report. I am familiar with this process so I believe I would have
seen this document although I cannot recall when.
The inquiry has asked me about what I understood to be the
instructions/guidance given in the second, third and fourth bullet points on page
2 of the 2000 version (POL00104747) and the first, second and third bullets on
page 2 of the 2002 (POL00104777) version and whether I understood this to
be relevant to PO's disclosure obligations in relation to information about
Horizon bugs, errors and defects. My understanding of these points is that they
cover security operational procedures and ensuring weaknesses in
transactions and/or procedures were not publicised as this could allow similar
offences to be committed before a fix was put in place. For example, if there
was a physical security weakness with something like a door then we would not
want that to be in the public domain. My understanding is that these points were
about the products and ensuring that they were protected. At no time was I
aware of any Horizon, bugs, errors or defects so I would not have disclosed
anything relating to that. I would assume that disclosure would have been made
by someone in the relevant area if they were aware (Legal Team or Fujitsu) of
any Horizon, bugs, errors or defects.
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53. I cannot recall when compliance checks began for investigations. I seem to
remember there was a case file compliance check in the early days when I
joined the POL Security team (after 2004) and then on a number of occasions
and subsequently the process was reviewed and updated. The purpose, I
believe, was to ensure there was a common standard that all case files were
presented in the same way across the team. I don’t recall having any role in
the development, management or amendment of the compliance documents
referred to in the email from David Posnett dated 23 May 2011 (POL00118096).
54. The Inquiry have asked me for my understanding of paragraph 2.15 of the
document entitled "Guide to the Preparation and Layout of Investigation Red
Label Case Files — Offender reports & Discipline reports" (POL00118101). My
understanding of paragraph 2.15 relates to products that are transacted on the
counter, such as Car Tax, Mail, Banking etc. I do not believe this distracted from
POL’s obligation of disclosure or the Offender report template as, to me, it
related to products/supervision and not the Horizon system. As I mentioned
previously, I would expect any Horizon bugs, errors and defects to be disclosed
at a more senior level.
55. The Inquiry has asked me about the appropriateness of the identification codes
("IC") described in the Identification Codes document (POL00118104). The
document shows IC codes 1 to 7 which as far as I am aware were used by all
Law Enforcement. The descriptors contain words that are outdated and
offensive. I do not know where this document originated from or the author. The
Security Team investigators had to fill in a form NPAO1 - NON-POLICE
AGENCIES (Notification of Proceedings to Police) that I believed mirrored the
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Police’s process for when someone is arrested and taken into Custody at a
Police Station. The form had a number of other identifiers; height, whether the
person was left or right-handed, their build and any scars, marks or tattoos. This
form would have been completed with the Antecedents Form following the
completion of a tape-recorded interview with the person. In addition, the IC code
was always shown on the 1st page of the Suspect Offender Report.
Analysing Horizon data, requesting ARQ data from Fujitsu and relationship with
Fujitsu
56. During my time in the Security Team before the GLO, I do not recall a SPM,
SPM assistant or Crown Office employee attributing a shortfall to problems with
Horizon. Usually, the reason for an audit would have come from another team
that had found some anomaly with the branch’s transactions, for example,
abnormal reversals or unusual Mail transactions, or how the branch was
managing their cash, for example, cash in pouches not being despatched, cash
not being returned when instructed or cash being requested when a branch was
showing as holding sufficient cash.
57. When required, credence data would more than likely be used as that showed
exactly the same information as ARQ data. As a rule, I am unsure if Horizon
data (ARQ or Credence) was provided to the SPM as a matter of course,
notwithstanding the disclosure obligation during a prosecution. As far as I recall
my direct contact with Fujitsu was very little. Any request for ARQ data would
have been via our Casework team.
22
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58. I have been asked by the Inquiry to what extent I considered Gareth Jenkins to
be acting as an expert witness, whether I understood the rules governing
independent expert evidence and who advised me in this regard. My
understanding of Gareth Jenkins was as someone who would provide a witness
statement on behalf of Fujitsu when ARQ data was required for court. He was
the ‘expert witness’ and his statements went into detail of how the Horizon
system operated which was far above my knowledge of the Horizon system or
computers in general.
59. The Security Team would request the ARQs where necessary for an
investigation and if a statement was required one would be provided by Fujitsu.
That was as far as my understanding of an ‘expert witness’ went. I am not aware
of any specific guidance given in regard to expert witnesses. The only other
term I remember hearing, but in later years, was SME (Subject Matter Expert),
which I took to be the same as expert witness as the Security team were told
that once one had been located POL would continue with prosecutions. This
would have been around 2014 (possibly) but I am unsure due to the passing of
time.
60. The Inquiry has asked me about my understanding of the issues in Craigton
branch and have referred me to the following documents FUJ00157001 (Email
chain dated June 2018), FUJ00170865 (Email chain dated June 2018) and
FUJ00170869 (Email chain dated June 2018). I do not believe I had any
involvement in this matter other than I was copied into the email from Robert
Daily (FUJ00170865). At that time, I was working in the Intel Team and along
23
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with my colleague Andrew Wise would be in essence the admin function for the
Security Team. We would have requested ARQ data from Fujitsu when required
and therefore would have contacts at Fujitsu to email for any questions or
requests like this. My understanding of the Scottish Legal system is that they
refer to Witness Statements as Certificates. In this case it appears there was a
Certificate that had been laid out in a different format to the usual Witness
Statements I have seen supplied by Fujitsu when they produce ARQ data.
6
=
. The Inquiry has provided me with document POL00141218 (Email chain dated
July 2010) and asked me to explain my understanding of the issue concerning
duplication of transactions in the ARQ data and any involvement I had in
addressing this issue. POL00141218 is an email sent from Jane Owen and
forwarded on by Andrew Daley, the North Team Leader at that time. I do not
recall the email and the branches were not ones I was involved in. From reading
the document and the email from Penny Thomas my interpretation would be
that the ARQ data could contain duplicate information and not the actual
Horizon data.
62. The Inquiry has asked me to describe my responsibilities in respect of data
handling processes. I did not have any responsibilities in respect of the data
handling processes other than those of everyone who had a responsibility to
safeguard the physical ARQ discs.
63. My role in the ARQ Disc handling process was only to explain to Moynd Uddin,
Information Security Advisor, who was reviewing the POL Security Team
24
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WITN08290100
process for managing the ARQs, what our green jacket process was and the
way ARQ discs were handled. It was not to explain the data or what was
contained on them (POL00122769 - Email chain dated September 2013). The
Inquiry has provided me with the following documents POL00122770 (Process
for secure storage and management of exhibits obtained in the course of an
investigation conducted by Post Office Limited), POL00122771 (Security
Investigations Manager's Data Handling Process — Fujitsu Horizon Data
Request), POL00122773 (Email chain dated September 2013), POL00122774
(Security Investigations Manager's Data Handling Process — Fujitsu Horizon
Data Request), POL00122928 (Email chain dated October 2013) and
POL00105222 (Security Investigations Manager's Data Handling Process —
Fujitsu Horizon Data Request dated 20 September 2013) which also appear to
relate to this process and the review by Moynd Uddin.
64. The Inquiry has also provided me with four other documents related to ARQ
data; POL00123286 (Email chain dated May 2014), FUJ00169529 (Email chain
dated July 2016), FUJ00169557 (Email chain dated July 2016) and
FUJ00170186 (Email chain dated December 2016). I cannot recall
POL00123286, dated 02 May 2014 from Jane Bradbury, or POL00105222
(noted above). I am aware due to my current role in the Intelligence Team of
the process for requesting ARQ data and the annual allowance laid down by
the contract between POL and Fujitsu. I believe that in 2014
investigations/prosecutions were on the decline if not ceased because the SME
had not been found and investigations that were open were being closed as No
Further Action (NFA). I recall I had one investigation where I was due to obtain
a Summons but was instructed not to continue. I cannot recall which case this
25
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was. From speaking to other investigators at the time they were experiencing
this also. FUJ00169529, FUJ00169557 and FUJ00170186 are emails from my
current role and relate to my team’s responsibility of requesting ARQ data from
Fujitsu.
65. The Inquiry has asked me to consider POL00121881 (Email chain dated July
2012) and describe my understanding of Jane Owen’s concern that POL was
failing in its process for the retention and destruction of ARQ requests. My
understanding is that this was about the physical discs and not the data they
contained.
Relationship with others
66. I cannot recall exactly when but around 2014 POL outsourced their Criminal
Law team to Cartwright King. Previously Mr Jarnail Singh was the last
remaining POL Lawyer. Therefore, any advice on criminal cases that would
have gone to Mr Singh now went to Cartwright King. I dealt with Mr Martin
Smith mainly. This was usually if I needed advice on a case or if he needed
clarification on a statement or some additional information.
67. Over the next few years Cartwright King supplied training at their Birmingham
offices for the Security Team. I believe some of the training was Interviewing,
dealing with Solicitors at interview and notebooks. There were probably other
training topics, but I can no longer remember them. Cartwright King would also
provide barristers for cases when needed.
26
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68. The Inquiry has provided me with document POL00129192 (Email from Allison
Drake, dated 14 January 2012) in which Alison Drake notes that I will act as a
stand in to support with training by Cartwright King. I can no longer recall this
email or the specific training but as I worked in Future Walk, a POL HQ building,
where there is a counter training classroom, I would have possibly arranged
training for Cartwright King with a trainer and/or I would have greeted them at
reception and taken the classroom. I would not have delivered any training.
Involvement in Criminal Case Studies
Prosecution of Peter Holmes
69. My involvement in this case was as 2" Officer. This role was one of support
to the lead officer (18 Officer). Depending on the 1%" Officer the 2"4 Officer may
manage the tape machine and perhaps deal with or check that the relevant
paperwork has been completed at each stage of the interview to adhere to the
rules of PACE.
70. During the interview the 2" Officer listens to the questions and replies to ensure
both are communicating efficiently. For example, an answer being given by the
interviewee may need clarification or lead to another question that the
interviewer has not picked up on.
71. I did not normally work with Mr Robert Daily due to him being based in
Scotland. I believe this was a rare occasion for me to be assisting him. I would
have been made aware of the location, date and time of the interview and would
have attended accordingly.
27
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72. As Iwas only the 24 Officer, I did not have any dealings with the case prior to
interview or subsequently post interview, other than to provide a witness
statement (POL00047290) as to my involvement on the day.
73. The Inquiry has asked me for my reflections on the way the investigation and
prosecution of Mr Holmes was conducted by Post Office with regard to the
Court of Appeal Judgment in Josephine Hamilton & Others v Post Office
Limited. From what I can recall I did not have any concerns with the way the
investigation was run at the time and as 2" Officer I would have had limited
involvement in the investigation.
Prosecution of Allison Henderson
74. I do not recall how I first became involved in the case. The usual procedure
was for a case to be given to an Investigator by the Security Team Leader.
Following an audit shortage, the decision to conduct a criminal investigation
into the loss would be taken by the Security Team leader and the Contracts
Team. It would then be allocated to an Investigator.
75. In this case I was what was known as the 1°! Officer or Lead Investigator.
Various data would have been obtained from Credence, which gives the same
data as ARQ but is immediately accessible to download rather than having to
request from Fujitsu. Credence data covers the 3-month period prior to the
current date. It’s also easier to read than the ARQ data as the ‘Item Long name’
is shown rather than just an item ID. From Credence you can obtain
transactional data and event data (back-office items).
28
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76. The Investigation Report (Legal) (POL00047152) would have been written
after the interview, from which a typed summary was_ produced
(POL00129785). An investigation report (Discipline) would also have been
produced. The typed summary and discipline report were passed to the PM by
the Contract Team.
77. With any investigation there would be a number of things that had to be
completed one being the ‘person not to be employed’ form. This would have
been emailed to Royal Mail for them to record on their system. This list would
have been checked by HR for future applicants. I am unsure of the process
other than completing the form.
78. I do not recall the call but from the Investigation Report (POL00047152) it
makes reference to me having a telephone call with Ms Henderson inviting her
to a tape-recorded interview and explaining what that meant, including her right
to have a Solicitor present. I suggested she speaks with her NFSP
representative, this was their union as she could have a representative present
at the interview. After the call I posted a letter to her detailing what I had
explained on the telephone. This would have been standard practice.
79. In order to progress the investigation, the next step was to interview Ms
Henderson. The timing of the interview is down to the Lead Investigator. It was
standard procedure to have a 2"4 Officer at all interviews. In this case it was my
colleague Mr Paul Whittaker. I can see that in Ms Henderson's witness
statement (WITN01460100) she states, ‘/ was allowed to bring my Federation
29
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rep, but he was not allowed to speak during the interview.’ As part of PO rules,
a person being interviewed can have someone from the union present, this is
only to act as an observer. They are told at the start of the interview of their
role. They may be permitted to speak if it helps facilitate the interview.
80. Disclosure would only be made to a solicitor not the suspect so that the solicitor
could advise their client.
8
=
. The Inquiry has asked me to consider POL00047155 (Memo from Rob G
Wilson to Maureen Moors dated 25 March 2010) and POL00044501 (Memo
from Chris Knight dated 20 April 2010 (Ms Allison Henderson)) and explain why
I considered Ms Henderson would have been aware of the loss when
completing her branch trading statement on 6 January 2010. I considered Ms
Henderson would have been aware because previous cash declarations had
shown an initial loss which was similar to the final loss at audit, but no difference
was shown.
82. The Inquiry has asked me to provide details of any legal advice I obtained
during the course of the investigation. Legal advice was sort as part of the
investigation case file submission to progress the case to prosecution. It may
also be requested if other enquiries were required. This file would have been
submitted to the Legal Team so they could advise if further actions were
required or if not then, to see if there was sufficient evidence to charge. On
some occasions, although I do not believe in this case, legal advice would be
sort if a situation arose whereby the investigator needed legal advice on a
specific problem. For example, this could be advice on getting a person
arrested, or what to do if a person refused to sign an investigation form.
30
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83. The charges in this case were provided by the Legal Team, as was the
charging decision in any investigation case. If the advice from the Legal Team
was to continue to prosecution, then the DAM decision would be sort and if that
was given then the investigator would obtain the Summons.
84. In order to obtain a Summons, I would contact the nearest Magistrates Listing
Office and explained I was looking to book a Court date for a private
prosecution. I would be given a date approximately six weeks ahead. Once a
date was booked, I would post the Summons (3 copies; Defendant copy, File
copy and a Court copy), an Information Sheet and a covering letter. All of these
documents were from templates created locally, not Court produced templates.
85. As noted above, from memory I considered Ms Henderson would have been
aware of the loss before the audit as there had been cash declarations for the
previous month which showed a similar loss figure to that found in the
subsequent audit. In response to Rob Wilson’s memo POL00047155 (Memo
from Rob G Wilson to Maureen Moors dated 25 March 2010) I replied to him
on 20 April 2010 (POL00044501- Memo from Chris Knight dated 20 April 2010
(Ms Allison Henderson). In my report I refer to the fact that the branch is only
open 3 days a week and that the transactions are small with the largest being
£400. From the previous Branch Trading (BT) on 6" January 2010 to the audit
on 10" February 2010 the loss of £12k had occurred if Ms Henderson was to
be believed that the BT was correct on 6!" January and not falsified.
86. I considered Ms Henderson had adjusted balancing figures hiding a loss and
was there by false accounting. From the defence statement (POL00047195)
31
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there was an acceptance of false accounting although the revised Defence
Statement did not mention this (POL00044503). I cannot recall if I had sight of
either one or both of the defence statements.
87. There is mention in Rob Wilson’s email date 16 November 2010
(POL00055783) that he had ‘taken instruction from Chris who has confirmed
that he would be happy to proceed on this basis.’ I cannot recall the
conversation or email exchange, but I would have taken this from Rob Wilson
as merely a courtesy and not him requesting legal advice, a business decision
or similar from me.
88. In most investigation cases unless there was a trial, I would not attend Court
hearings or sentencing. I have done on occasions, but this was in the early days
of becoming an investigator to gain experience. My role as an investigator was
to provide information/evidence that enabled a case to progress to Court. POL
Legal would manage the liaison with external Solicitors as seen in this case and
decisions on charges or pleas would be down to those parties.
89. Once a case had been finalised at Court, and the appointed Solicitor/Law firm
reported the final outcome, POL legal would send the result on the usual
template as a memo (POL00047170- Memo, dated 16 December 2010, (Ms
Allison Henderson)).
32
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90. The debt (branch shortage) would have been sent to the Agent Debt team from
the audit and they would hold the loss against the PM for the branch. In this
case the debt was paid. I would not be involved in this process.
91. The Inquiry has asked me for my reflections on the way the investigation and
prosecution of Ms Henderson was conducted by post office with regard to the
Court of Appeal Judgment in Josephine Hamilton & Others v Post Office
Limited. From what I can recall I did not have any concerns with the way the
investigation was completed at the time.
Prosecution of Alison Hall
92. I do not recall how I first became involved in this case and assume it was
through the usual process where a case would be given to an investigator by
the Team Leader. This process followed an audit shortage where the decision
to conduct a criminal investigation into the loss had been taken by the Security
Team leader and the Contracts Team. It would then be allocated to an
Investigator.
93. In this case I was what was known as the 1° Officer or Lead Investigator. That
means that you lead on the enquiry and build the case up to the point where it
is submitted for legal advice. This role includes conducting interviews, gathering
intelligence (banking information, credit checks), searches (if required) and
taking witness statements.
94. From the audit the loss would be known and any comments of why there was
a loss may have been told to the auditors by the PM. As lead investigator it
33
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would be my job to look at those comments and also see if there was an
explanation.
95. In this case I can see from the Investigation Report (legal) (POL00091063)
that after writing to Miss Hall to arrange a tape-recorded interview and
explaining her legal rights she phoned me and said she would like a Solicitor. I
advised her to contact a criminal law solicitor, A week later Mr Paul
Normandale, Solicitor with Inesons of Cleckheaton, called me and we arranged
to conduct the interview at his office.
96. The decision to interview Miss Hall would have been mine and as with all
interviews it was standard procedure to have a 2" Officer. In this case it was
my colleague Mr Paul Whittaker.
97. There would have been no pre-interview disclosure to Miss Hall, but her
Solicitor would have had the disclosure.
98. Miss Hall comments in her Witness Statement (WITN01450100) “the
Investigators were Christopher Night and Paul Whittaker, they were not
interested in my material and refused to look at it?” From the typed tape
summary (POL00090842) just after the time marker 42:27 I refer to some
paperwork that Miss Hall had brought but I was not in a position to look at but
would take it away. From the email from Neil Throneycroft dated 14 October
2010 (UKG100001595) he mentions he has “just finished discussing Hightown
with Chris Knight’. I do not recall this conversation but from the date of the
34
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interview with Miss Hall and the date of this document I would assume I asked
Mr Thorneycroft about the paperwork Miss Hall supplied at interview.
99. I contacted NBSC to see if Miss Hall had made contact for help with losses or
scratchcards because if she was having problems with them, as she had said,
I would expect some calls reporting this and/or asking for help. However, there
were none.
100. I contacted a member of the Product & Branch Accounting Team’s Lottery
Team, Neil Thorneycroft, as Mr Thorneycroft dealt with transaction correction
and other issues between branches and the Lottery product. He was very
knowledgeable about Lottery transactions and so was the best person to liaise
with to get information that would assist my understanding of issues that may
have caused the shortage in branch as Miss Hall had suggested.
101. I cannot recall if I was aware that the branch had been attended by an Area
Intervention Manager but having read the document POL00091122 (Area
Intervention Manager Visit (Ms Alison Hall)) if I had I would not have been a
concerned as although the branch had an issue, they had received some
support and the matter was rectified. The total visit time 35mins. Although the
‘details of visit’ show ‘horizon problem’ this appears to be a user issue on the
Horizon system.
102. As with all investigation cases the Contract Team Manager dealt with the
contract side. In this case it was Mrs Sue Muddeman (POL00091104- Case
notes for conduct suspension cases (Ms Alison Hall)). From the date of the
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document, 15 October 2010, I would consider that this had no bearing on the
investigation case.
103. I cannot recall the details of this investigation but as with all investigation
cases this case would be sent to POL’s Legal Team at the point when the lead
investigator was seeking advice, which was usually advice on charges. The
charges would then be decided by the Legal Team.
104. Once the Legal Team had advised that the evidence was sufficient for the
charges the case would be referred to the DAM for a decision on whether to
proceed with the prosecution. I had no input.
105. If there was advice for prosecution, I would await any questions or tasks (i.e.,
further statements) from the Legal Team. I would obtain a Summons from the
relevant Court and serve this, usually by post.
106. As mentioned previously in this statement the investigator would comply
with their disclosure obligation by completing various PO SEC disclosure
forms specifically, 006 A, B, C & D.
107. The Inquiry has asked me to explain the circumstances in which a plea was
offered and any discussions within the Post Office in respect of whether the
plea was acceptable. The Inquiry has also asked me to confirm any
involvement I had in this decision and any conditions that were attached. I
have reviewed document POL00019111 and can see I was contacted by
Adrian Chaplin (by phone). I do not recall this conversation but assume he
would have contacted me because he could not get hold of Mr Wilson. It was
36
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unusual for me to speak to a barrister direct and I would not have authority to
negotiate or agree any charges, or any conditions related to those charges. I
can only presume that I would have been aware of the agreed position that
had been taken by POL and would have confirmed that with Mr Chaplin when
he contacted me. Document POL00091374, a letter to Mr Wilson from
O'Garras (writing on behalf of Adrian Chaplin), appears to be an update
following the Court appearance. This again notes the conversation I had with
Mr Chaplin. Although it appears in the letter as though I have agreed the plea,
I would not have been involved in this decision. I expect I would have been
made aware of the decision by Rob Wilson and so when Mr Chaplin
telephoned me, I would have reiterated POL's position. I would have had no
involvement in making this decision. I have never had any involvement in
making a plea deal or applying conditions to such a deal and this would be
outside of my remit as an investigator. I note that in the previous case with Ms
Henderson, and in document POL00055783 (Email chain, dated November
2010 (Ms Allison Henderson)), Mr Wilson notes "Clearly if there were to be a
plea to false accounting but on the basis that the Horizon system was at fault
that would not be an acceptable basis of plea for the prosecution." I was
copied into this email and expect I would have had a similar knowledge in this
case as Mr Wilson is likely to have kept me aware of progress with the
prosecution.
108. The Inquiry has asked me to explain my involvement in any enforcement
proceedings brought in this case. I can confirm that any enforcement
proceedings, be that recovery under the Proceed of Crime Act or by civil
37
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action, would have been dealt with by our Financial Investigator in conjunction
with the legal team or the Agent Debt Team respectively. I would have no
involvement.
109. Once the verdict of the court case had been communicated to me, I would
have closed the investigation file with no further action on my part.
110. The Inquiry has asked me for my reflections on the way the investigation
and prosecution of Ms Hall was conducted by post office with regard to the
Court of Appeal Judgment in Josephine Hamilton & Others v Post Office
Limited. From what I can recall I did not have any concerns with the way the
investigation was completed at the time
General
111. I have been asked to consider FUJ00190471 (Email chain dated January
2017) and explain my understand of the issue being discussed and any
involvement I had in relation to this issue. I can confirm I am not aware of this
document, or the subject discussed within it. I would suggest that the email
dated 24 January 2017 from David M Jones to a number of people and cc’d to
others does not include myself. Due to the layout of the emails, I would suggest
that the cc's are ‘Jay, Christopher’ and then ‘Knight, Miriam’. Due to spacing it
does look like I am a recipient ‘Christopher Knight’. My email address is actually
Christopher G Knight.
112. The Inquiry has asked me to explain the purpose of POL00114558 (Memo
from Christopher G Knight to training team (undated)) and the reasons why I
38
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wrote it. This document was written when I was working in Cash Handling &
Distribution (CH&D). I do not remember writing it due to the passage of time
(circa 2000-2004) but the content and focus appears to be to enhance Cash
Value in Transit (CViT) crew training as I seem to recall we were always
reiterating the need to check the integrity of cash pouches collected from both
Post Office branches and (at that time) retail premises. The cash pouches had
a tamper proof seal that if there was an attempt to pull it apart it showed the
word ‘void’. Sometimes when sealing the pouch, the person did not align the
seal and would try and lift and reseal, this could make the word ‘void’ appear.
So, the crewman collecting pouches was to check the serial number and also
to check the seal and general integrity of the pouch.
113. The checking of the pouch and seal was also taught to the Cash Centre staff
who ultimately opened the pouch to process the contents. As part of their
compliance, they were supposed to cut open the pouch at the opposite end to
the seal. They were also not supposed to just pull (rip) the pouch apart.
114. I have been asked by the Inquiry to consider POL00141237 (Email chain
dated September 2010) and explain whether I considered theft and false
accounting to be alternative charges and why I considered that it would make
things simpler to accept a guilty plea to false accounting and drop the theft
charge. In relation to document POL00141237, an email exchange between
Juliet McFarland and myself, I can see I am asking if it would be easier to accept
a False Accounting charge as the PM admitted this and had repaid the
discrepancy. The choice of charges was always made by the Legal Team.
39
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115. I have been asked by the Inquiry to consider POL00145852 (Email from Dave
Posnett to Jarnail Singh dated 7 August 2013) and describe the discussions I
had with the Barrister in question about 'Horizon issues’ and whether I had any
discussions with POL about this issue. In relation to the document, I do not
recall the conversation(s) with the Barrister. This was a Police investigation and
so I am assuming it is a CPS Barrister. In the document I mention advising the
Barrister to look at 2"¢ Sight reporting about Horizon matters. The email goes
on to say I was meeting the Barrister. I would have put him in touch with Jarnail
Singh, PO Legal Team and / or Martin Smith, Cartwright King, as issues with
Horizon / 2"4 Sight report were out of my sphere of knowledge.
116. I do not recall being aware of any robust challenges to Horizon (other than
the GLO). I dealt with a number of people who admitted their dishonesty and
so the integrity of Horizon was not at the forefront of my mind. The business
message was consistent that Horizon was robust so there was never any doubt
in my mind. I remember that latterly (approx. 2010/2011) that we (the
investigators) were advised that if someone we were interviewing said the loss
was due to Horizon, we were to ask how this manifested and obtain details from
them. We were also asked to cover in the interview what training they had
received.
117. There are no other matters I consider to be of relevance to the Inquiry’s Terms
of Reference.
Statement of Truth
I believe the content of this statement to be true.
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41
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Index to First Witness Statement of Christopher Granville Knight
No.
URN
Document Description
Control Number
1
POL00129261
CV of Christopher G Knight
POL-0134971
2
POL00127128
One to One Meeting Record
12/09/2013
POL-0133353
POL00127129
One to One Meeting Record
30/10/2013
POL-0133354
POL00127237
One to One Meeting Record
12/03/2014
POL-0133427
POL00104747
Casework Management Policy
(version 1.0, March 2000)
POL-0080887
POL00104777
Casework Management Policy
(version 4.0, October 2002)
POL-0080417
POL00104754
Rules and Standards Policy (version
2.0, October 2000)
POL-0080394
POL00030687
Investigation Procedures Policy
(version 2.0, January 2001)
POL-0027169
POL00104762
Disclosure Of Unused Material,
Criminal Procedures and
Investigations Act 1996 Codes of
Practice Policy (version 1.0, May
2001)
POL-0080402
10
POL00030578
Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy"
(1 December 2007)
POL-0027060
11
POL00104812
Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy"
(1 December 2007)
POL-0080444
12
POL00104806
Royal Mail Group Security -
Procedures & Standards - Standards
of Behaviour and Complaints
Procedure" (version 2, October 2007)
POL-0080438
13
POL00031003
Royal Mail Group Crime and
Investigation Policy" (version 1.1,
October 2009)
POL-0027485
14
POL00030580
Post Office Ltd - Security Policy -
Fraud Investigation and Prosecution
Policy" (version 2, 4 April 2010)
POL-0027062
15
POL00030579
Post Office Ltd Financial Investigation
Policy" (4 May 2010)
POL-0027061
16
POL00104848
Royal Mail Group Security —
Procedures & Standards: “Appendix 1
to P&S 9.5 Disclosure of Unused
Material & The Criminal Procedure &
Investigations Act 1996” (Version 1,
POL-0080480
42
WITNO08290100
WITN08290100
July 2010)
17
POL00104837
Royal Mail Group Security —
Procedures & Standards: “Committal
& Summary Trial Papers &
Processes” (Version 1, July 2010)
POL-0080469
18
POL00026573
Royal Mail Group Security -
Procedures & Standards - The
Proceeds of Crime Act 2002 &
Financial Investigations" (version 1,
September 2010)
POL-0023214
19
POL00104857
Royal Mail Group Security -
Procedures & Standards - Initiating
Investigations" (September 2010)
POL-0080489
20
POL00031008
Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy"
(version 1.1, November 2010)
POL-0027490
21
POL00104853
Post Office Ltd Financial Investigation
Policy (version 2, February 2011)
POL-0080485
22
POL00104855
Post Office Ltd Anti-Fraud Policy
(February 2011)
POL-0080487
23
POL00030786
Royal Mail Group Policy Crime and
Investigation S2" (version 3.0, April
2011)
POL-0027268
24
POL00105229
Post Office Ltd PNC Security
Operating Procedures” (August 2012)
POL-0080854
25
POL00104929
Post Office Limited: Internal Protocol
for Criminal Investigation and
Enforcement (with flowchart)",
(October 2012)
POL-0080561
26
POL00105226
Undated Appendix 1 - POL Criminal
Investigations and Enforcement
Procedure (flowchart)",
(October 2012)
POL-0080851
27
POL00104968
The undated document entitled “POL
— Enforcement & Prosecution Policy”
POL-0080600
28
POL00030602
“Post Office Limited: Criminal
Enforcement and Prosecution Policy"
(undated)
POL-0027084
29
POL00122143
“Security Operations” (version 1.0,
December 2012)
POL-0128387
30
POL00122142
Email from Andrew Daley to
Christopher G Knight 20/02/2013
POL-0128386
31
POL00031005
"Conduct of Criminal Investigations
Policy" (version 0.2, 29 August 2013)
POL-0027487
32
POL00027863
“Conduct of Criminal Investigations
Policy" (version 3, 10 February 2014)
POL-0024504
33
POL00030902
“Conduct of Criminal Investigations
Policy" (September 2018)
POL-0027384
34
POL00104900
Separation Project — Criminal
POL-0080532
43
WITNO08290100
WITN08290100
Investigations Policy for Post Office
Ltd
35
POL00123309
Email from Dave Posnett dated
09/07/2014
POL-0129508
36
POL00123310
Royal Mail Group Security
Investigation Communication 6-2014
— Joint investigation protocols RMGS
and PO Ltd security
POL-0129509
37
POL00123311
RMG 2.2. Joint Investigation
Protocols - RMGS and PO Ltd
Security July 2014
POL-0129510
38
POL00123312
MOU on joint investigation protocols
post independence involving Royal
Mail and Post Office Ltd security
POL-0129511
39
POL00126976
Email from Dave Posnett dated
11/09/2013
POL-0134075
40
POL00123743
Email from Elaine Spencer dated
31/07/2015
POL-0129929
a
POL00123840
Email from John M Scott dated
20/01/2016
POL-0130023
42
POL00104821
“Condensed Guide for Audit
Attendance” (version 2, October
2008)
POL-0080453
43
POL00129302
“Security Team Training and
Development Policy” (draft, undated,
version D1.2)
POL-0135198
44
POL00129192
Email from Allison Drake, dated 14
January 2012
POL-0135120
45
POL00129306
Email from Helen Dickinson to you
and others, dated 11 March 2013
POL-0135200
46
POL00129310
Email from Dave Posnett to you and
others, dated 22 March 2013
POL-0135204
47
POL00129311
Email invite from Dave Posnett for
Cartwright King Training Day
POL-0135205
48
POL00122419
Email from Andrew Scott to you and
others, dated 19 April 2013
POL-0127444
49
POL00122860
Email from Andrew Wise to you and
others, dated 20 September 2013
POL-0129089
50
POL00123042
Email from Andrew Wise to you and
others, dated 11 November 2013
POL-0129259
51
POL00127215
Email from Toni Sless to you and
others dated 10 March 2014
POL-0133412
52
POL00123282
Email from Andrew Wise to you and
others, dated 25 April 2014
POL-0129485
53
POL00122163
The Grapevine Analysis and Support
Team slides
POL-0128406
54
POL00118096
Dave Posnett’s email dated 23 May
2011
VIS00012685
55
POL00118108
Security Operations Team — Case
VIS00012697
44
WITNO08290100
WITN08290100
Compliance
56 I POL00118109 I Guide to the Preparation and Layout I VISO0012698
of Investigation Red Label Case Files
— File construction and Appendices A,
B&C.
57 I POLOO118101 Guide to the Preparation and Layout I VIS00012690
of Investigation Red Label Case Files
— Offender reports & Discipline
reports
58 I POLO0118102 Offence Form VIS00012691
59 I POL00118103 I Offence Form VIS00012692
60__I POL00118104 _I Identification Codes ViS00012693
61 POL00118105 Summarising of Tape Recorded VIS00012694
Interviews Guidance
62 POL00118106 Notebooks Guidance VIS00012695
63 I POL00118107 Electronic Casework document VIS00012696
64 POL00121881 Email chain dated July 2012 POL-0128140
65 I FUJ00169529 Email chain dated July 2016 POINQ0175710F
66__I FUJ00169557 Email chain dated July 2016 POINQ0175738F
67 __I FUJ00170186 Email chain dated December 2016 POINQ0176367F
68 I FUJ00187984 Email chain dated December 2016 POINQ0193701F
69 I FUJ00206093 Email chain dated April 2019 POINQ0211814F
70 FUJ00154984 Email chain dated December 2010 POINQ0161179F
71 FUJ00224959 Email chain dated January 2010 POINQ0231074F
72__I FUJ00226002 Email chain dated June 2012 POINQ0232119F
73 I POLO0055189 I Memo from Rob G Wilson to POL-0051668
Christopher G Knight dated 19 August
2010
74 FUJ00157001 Email chain dated June 2018 POINQ0163196F
75 I FUJ00170865 Email chain dated June 2018 POINQ0177046F
76 _I FUJ00170869 Email chain dated June 2018 POINQ0177050F
77 __I POLO0141218 I Email chain dated July 2010 POL-0143659
78 I POLO0122769 Email chain dated September 2013 POL-0128998
79 I POLO0122770 Process for secure storage and POL-0128999
management of exhibits obtained in
the course of an investigation
conducted by Post Office Limited
80 I POLO0122771 Security Investigations Manager's POL-0129000
Data Handling Process — Fujitsu
Horizon Data Request
81 POL00122773 Email chain dated September 2013 POL-0129002
82 I POLO0122774 Security Investigations Manager's POL-0129003
Data Handling Process — Fujitsu
Horizon Data Request
83 I POL00122928 I Email chain dated October 2013 POL-0129156
84 I POLO0105222 Security Investigations Manager's POL-0080847
Data Handling Process — Fujitsu
Horizon Data Request dated 20
45
WITNO08290100
WITN08290100
September 2013
85 I POL00123286__I Email chain dated May 2014 POL-0123286
86 POLO00060805 Audit report of 18 September 2008 POL-0057284
(Mr Peter Holmes)
87 I POLO0050208 Transcripts of the interviews on 19 POL-0046687
September 2008 (from 14:11 to
14:56) (Mr Peter Holmes)
88 I POLO0050847 Transcripts of the interviews on 19 POL-0047326
September 2008 (from 15:06 to
15:50) (Mr Peter Holmes)
89 I POL00050334 I Investigation report (legal), dated 6 POL-0046813
October 2008 (Mr Peter Holmes)
90 I POLO0128950 Investigation report (legal), dated 30 POL-0134173
January 2009 (Mr Peter Holmes)
91 POL00050255 Suspect offender reporting form (Mr POL-0046734
Peter Holmes)
92 I POLO0050997 Schedule of Charges (Mr Peter POL-0047476
Holmes)
93 I POLO0047290 Witness statement of Christopher POL-0043769
Knight, dated 19 May 2009 (Mr Peter
Holmes)
94 I POL00054727 Financial Investigation Events Log POL-0051206
(Mr Peter Holmes)
95 I POLO0054790 Case closure reporting (Mr Peter POL-0051269
Holmes)
96 I POL00113278 I Judgment of the Court of Appeal in POL-0110657
Josephine Hamilton & Others v Post
Office Limited [2021 EWCA Crim 577
97 I POLO0047152 Investigation report (legal) (Ms Allison I POL-0043631
Henderson)
98 POL00129785 Interview transcript, dated 11 March POL-0123811
2010 (Ms Allison Henderson)
99 POL00047227 Final branch trading statement, dated I POL-0043706
6 January 2010 (Ms Allison
Henderson)
100 I POL00047183 Extract of the transaction report (Ms POL-0043662
Allison Henderson)
101 I POLO0065009_ I ‘Person not to be employed’ memo POL-
011 (Ms Allison Henderson) 0061488 _ 011
102 I POL00044501 Memo from Chris Knight dated 20 POL-0040980
April 2010 (Ms Allison Henderson)
103 I POL00047159 I Memo from Rob Wilson dated 21 May I POL-0043638
2010 (Ms Allison Henderson)
104 I POL00047162 I Memo from Rob Wilson dated 26 May I POL-0043641
2010 (Ms Allison Henderson)
105 I POLO0065009_ I Email from Christopher Knight dated I POL-
010 12 July 2010 (Ms Allison Henderson) I 0061488 010
106 I POL00047193 I Summons, dated 12 August 2010, POL-0043672
(Ms Allison Henderson)
46
WITNO08290100
WITN08290100
107
POL00125643
Committal bundle, dated 27
September 2010, (Ms Allison
Henderson)
POL-0131312
108
UKG100014627
Memo from Rob Wilson to Chris
Knight, dated 29 September 2010,
(Ms Allison Henderson)
UKG1I025420-001
109
POL00055388
Letter from Hugh A Cauthery
solicitors to Rob Wilson, dated 7
October 2010 (Ms Allison Henderson)
POL-0051867
110
POL00055542
Advice on evidence, dated 14
October 2010, (Ms Allison
Henderson)
POL-0052021
111
POL00125641
Summary of facts (Ms Allison
Henderson)
POL-0131310
112
POL00125644
Bundle of witness statements (Ms
Allison Henderson)
POL-0131313
113
POL00125646
List of exhibits (Ms Allison
Henderson)
POL-0131315
114
POL00125639
Antecedents form (Ms Allison
Henderson)
POL-0131308
115
POL00055495
Schedule of Non-Sensitive Unused
Material, dated 24 September 2010
(Ms Allison Henderson)
POL-0051974
116
POL00047195
Defence statement (Ms Allison
Henderson)
POL-0043674
117
POL00055787
Letter from Belmores Solicitors, dated
16 November 2010 (Ms Allison
Henderson)
POL-0052266
118
POL00044503
Amended defence statement (Ms
Allison Henderson)
POL-0040982
119
POL00055783
Email chain, dated November 2010
(Ms Allison Henderson)
POL-0052262
120
POL00047169
Memo from Rob Wilson, dated 18
November 2010 (Ms Allison
Henderson)
POL-0043648
121
POL00055837
Letter from Miss Andrews to Hugh A
Cauthery Solicitors, dated 25
November 2010, (Ms Allison
Henderson)
POL-0052316
122
POL00046148
Factual basis/application for a
Goodyear indication (Ms Allison
Henderson)
POL-0042627
123
POL00055853
Attendance note, dated 1 December
2010, (Ms Allison Henderson)
POL-0052332
124
POL00055890
Letter from Hugh A Cauthery
Solicitors to Rob Wilson, dated 15
December 2010 (Ms Allison
Henderson)
POL-0052369
125
POL00047170
Memo, dated 16 December 2010, (Ms
POL-0043649
47
WITNO08290100
WITN08290100
Allison Henderson)
126 I POL00047155 I Memo from Rob G Wilson to Maureen I POL-0043634
Moors dated 25 March 2010
127 I WITNO1460100 I Allison Henderson's witness WITNO1460100
statement to the Inquiry
128 I POL00127621 Case closure report (Ms Alison Hall) POL-0134386
129 I POLO0019111 Case file event log (Ms Alison Hall) POL-0012303
130 I POL00091063 Investigation report (legal) and audit POL-0090707
report (Ms Alison Hall)
131 I POLO0016001 Legal rights form (Ms Alison Hall) POL-0009193
132 I POLO0090842 Transcript of Ms Hall's interview, POL-0090486
dated 28 September 2010,
commencing at 11:37 (Ms Alison Hall)
133 I POL00091237 Transcript of Ms Hall’s interview, POL-0090881
dated 28 September 2010,
commencing at 12:25 (Ms Alison Hall)
134 I POL00120439 NBSC call log (Ms Alison Hall) POL-0120125
135 I POLO0091307 I HSD call logs (16 May 2005 to 31 POL-0090951
August 2007) (Ms Alison Hall)
136 I POL00021278 I HSD call logs (19 September 2007 to I POL-0014470
23 September 2010); (Ms Alison Hall)
137 I POL00091351 HSD summary (Ms Alison Hall) POL-0090995
138 I POLO0091104 Case notes for conduct suspension POL-0090748
cases (Ms Alison Hall)
139 I POLO0091257 _I Schedule of charges (Ms Alison Hall) I POL-0090901
140 I POL00091014 _I Indictment (Ms Alison Hall) POL-0090658
141 I POL00091065 List of exhibits (Ms Alison Hall) POL-0090709
142 I POL00055290 I Schedule of non-sensitive unused POL-0051769
material (Ms Alison Hall)
143 I POL00091239 _I Antecedents form (Ms Alison Hall) POL-0090883
144 I POL00091200 I Letter from Sue Muddeman to Alison I POL-0090844
Hall, dated 24 September 2010 (Ms
Alison Hall)
145 I POL00091100 Email from Chris Knight to Sue POL-0090744
Muddeman, dated 29 September
2010 (Ms Alison Hall)
146 I POL00091333 I Letter from Chris Knight dated 7 POL-0090977
October 2010 (Ms Alison Hall)
147 I POLO0091106 Interview notes, dated 8 October POL-0090750
2010 (Ms Alison Hall)
148 I POLO0128077 Memo from Maureen Moors to the POL-0134800
Criminal Law Team, dated 3
November 2010 (Ms Alison Hall)
149 I UKGIO0001595 I Email from Neil Thorneycroft, dated UKGI12409-001
14 October 2010 (Ms Alison Hall)
150 I POLO0091103 Letter from Sue Muddeman to Alison I POL-0090747
Hall, dated 15 October 2010 (Ms
Alison Hall)
151 I POLO0090992 I Email chain dated 15 October 2010 POL-0090636
48
WITNO08290100
WITN08290100
(Ms Alison Hall)
152
POLO0090993
Email from Paul Southin dated 19
October 2010 (Ms Alison Hall)
POL-0090637
153
POL00091313
Letter from Alison Hall to Sue
Muddeman, dated 25 October 2010
(Ms Alison Hall)
POL-0090957
154
POL00128079
Memo from Maureen Moors to Chris
Knight, dated 24 November 2010 (Ms
Alison Hall)
POL-0134802
155
UKGI00001593
Email chain dated 30 November 2010
(Ms Alison Hall)
UKGI012407-001
156
POL00091111
Letter from Andy Bayfield to Alison
Hall, dated 22 December 2010 (Ms
Alison Hall)
POL-0090755
157
POL00091260
Memo from Juliet McFarlane dated 31
December 2010 (Ms Alison Hall)
POL-0090904
158
POL00128080
Memo from Maureen Moors to Chris
Knight, dated 5 January 2011 (Ms
Alison Hall)
POL-0134803
159
POL00091000
Email chain dated 5 January 2011
(Ms Alison Hall)
POL-0090644
160
POL00091244
Memo from Chris Knight, dated 25
January 2011 (Ms Alison Hall)
POL-0090888
161
POL00091258
Memo from Juliet McFarlane dated 3
February 2011 (Ms Alison Hall)
POL-0090902
162
POL00091300
Email from Dave Pardoe, dated 9
February 2011 (Ms Alison Hall)
POL-0090944
163
POL00091002
Information document (Ms Alison
Hall), dated 2 March 2011
POL-0090646
164
POL00091264
Memo from Debbie Helszajn to
Maureen Moors (Ms Alison Hall)
POL-0090908
165
POL00091234
Witness statement of Jess Roper
(unsigned) (Ms Alison Hall)
POL-0090878
166
POL00091215
Witness statement of Kimberley
Langley (unsigned) dated 20 May
2011 (Ms Alison Hall)
POL-0090859
167
POL00091045
Witness statement of Chris Knight
(unsigned) dated 23 May 2011 (Ms
Alison Hall)
POL-0090689
168
POL00021311
Memo from Chris Knight to Debbie
Helszajn, dated 26 May 2011 (Ms
Alison Hall)
POL-0014503
169
POL00091011
Email chain dated 23 June 2011 (Ms
Alison Hall)
POL-0090655
170
POL00021333
Email from Adrian Chaplin to Rob
Wilson and Marilyn Benjamin, dated
28 June 2011 (Ms Alison Hall)
POL-0014525
171
POL00021329
Email from Adrian Chaplin to Paul
Southin and Rob Wilson, dated 30
POL-0014521
49
WITNO08290100
WITN08290100
June 2011 (Ms Alison Hall)
172 I POLO0091020 I Note from Adrian Chaplin (undated) POL-0090664
(Ms Alison Hall)
173 I POL00091374 Letter from Tracey Langan to Rob POL-0091018
Wilson, dated 30 June 2011 (Ms
Alison Hall)
174 I POLO0091032 I Memo from Phil Taylor to Post Office I POL-0090676
Security, dated 1 July 2011 (Ms
Alison Hall)
175 I POL00091024 Email chain dated 24 February 2012 POL-0090668
(Ms Alison Hall)
176 I POLO0091077 I Emails chain dated September 2012 I POL-0090721
(Ms Alison Hall)
177_I WITN01450100_I First written statement of Alison Hall WITNO1450100
178 I POL00091122 I Area Intervention Manager Visit (Ms POL-0090766
Alison Hall)
179 I FUJ00190471 Email chain dated January 2017 POINQ0196188F
180 I POL00114558 Memo from Christopher G Knight to POL-0113664
training team (undated)
181 I POLO0141237 _I Email chain dated September 2010 POL-0142623
182 I POL00145852 I Email from Dave Posnett to Jarnail POL-BSFF-
Singh dated 7 August 2013 004979
50