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Witness Name: Graham David Brander
Statement No.: WITN08300100
Dated: 30 October 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF Graham David Brander
I, Graham David Brander, 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 03 October 2023
(the “Request”).
BACKGROUND
2.
i) My education qualifications are “A/O” Level Mathematics and “O” Levels (or
equivalent) in Mathematics, English Language, Physics, Economics, Geography and
History.
ii) I joined Post Office Limited (POL) in March 1984, working as a counter clerk at a
Crown Post Office (now known as Directly Managed Branches). This role involved
serving customers relating to various POL transactions and services. At that time,
there was no computer system and weekly balancing was conducted manually.
3. Whilst employed in the counter clerk role, there was a period of time in which I
also trained new subpostmasters in respect of serving customers and balancing.
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This was done on an ad hoc basis, as and when required.
4. At some point after 1984, I was promoted to Assistant Branch Manager but I
cannot recall when this was. This role involved a mixture of completing admin work
as well as serving customers. In that role, I would also support both the Branch
Manager and the rest of the team.
5. In January 1997 I was promoted to Branch Manager, a position I held until August
2000. My main responsibilities were to support and develop my team, ensuring that
our customers received an excellent service. I would conduct regular one to ones’
with each member of my team as well as writing yearly appraisals.
6. In August 2000 I took up a role as a Security Manager within POL having
successfully applied for this position.
7. Prior to attending a residential training course, which I think lasted approximately 2
weeks, I was supplied with some pre-course work, which related to a number of
modules that would be covered as part of my training. I cannot recall all the modules
but believe they included The Theft Act and some sections (three I believe) relating
to the Police and Criminal Evidence Act 1984 codes of practice.
8. I seem to recall that I completed the pre course work over a period of
approximately 2 weeks, immediately prior to attending the residential course. During
this time, the Horizon system was being installed and operated on at the Post Office
branch that I managed. I wasn’t heavily involved in this due to the amount of time I
needed to complete the security training pre-course work. I have a vague
recollection that my team and I completed classroom training on operating the
Horizon kit prior to it being installed. The team would then have received a period of
onsite training once Horizon had gone live at our branch.
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9. I only have a vague recollection of the Security Manager training course that I
attended. I can recall that we completed a test at the beginning of the course, based
on the pre-course work. During the course we went through the various modules in a
classroom environment. The only exception that I can recall is when we attended
what I believe was a police training facility whereby we had some training on
searching a house. I can recall that at the end of the training, we had to complete a
test, which required achieving a certain score in order to pass the course. I achieved
the required score and passed the course.
10. Following completion of the training course I began work as a Security Manager,
operating from a room above Eastleigh Crown Office, which was not far from where I
lived. I was the only Security Manager operating from that office, as typically, we
were spread across the country, although there were some locations that
accommodated a number of Security personnel.
11. I can remember that it was a steep learning curve in regards to understanding
and gaining experience into criminal investigations, as well as elements relating to
physical security, particularly as I was isolated to a certain extent. I cannot recall
particular details around this time but I would have been supported by my team
leader and new colleagues, including shadowing and sitting in on a number of
interviews as a witness.
12. Whilst in my role as a Security Manager the role varied in that there were times
when it was classed as multi skilled, which involved both physical security as well as
investigations into suspected criminality. There was a period, not that long after I
joined the Security Team, when I was in a small national team that predominately
dealt with post robbery incidents. I cannot recall much detail regarding this role, other
than that I would visit PO branches after a robbery incident, liaise with the police and
submit a report that detailed the incident.
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13. Throughout my time as a Security Manager, I would say that for the most part, I
dealt with suspected criminal investigations. The types of cases that I would have
investigated would for example, include audit shortages, Crown Office losses,
pension and allowance fraud etc.
14. In respect of criminal investigations, I would analyse documents and Horizon
data, conduct tape recorded interviews under caution, conduct searches of suspect's
abode, prepare reports and case files for the Criminal Law Team, obtain witness
statements and conduct certain activities in relation to prosecutions e.g. obtaining
and issuing a summons to attend court, the preparation of a committal bundle etc.
15. In 2008, for a period of approximately 3 to 4 months I was asked to perform as
acting Team leader, due to a recent vacancy. I cannot recall much detail but seem
to recall that I retained my existing case load whilst performing line manager duties,
such as completing one to ones and chairing team meetings. As acting Team
Leader, I would have been responsible for allocating cases to members of the team,
although I cannot recall any specific cases. When the team leader role was filled
on a permanent basis, I reverted to my role as a Security Manager.
16. During my time as a Security Manager I would have worked with numerous
colleagues and had several different line managers. I initially worked in what was
known as the South West Security Team, as well as working in the South East
Team. From what I can recall, I would have regarded all colleagues that I worked
with as both competent and professional.
17. In March 2012 I applied for and was appointed as a Network Transformation
Field Change Advisor (FCA). The Network Transformation Programme had secured
significant investment from the government to transform a large portion of
it's Sub Post Office network into modern new models, with larger branches modelled
as a Main and smaller ones’ as either a Local or Local Plus.
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18. Sub Post Offices received a fixed annual payment as well as fees (commission)
for the transactions that they conducted. With the new models, the postmaster would
only receive variable fees, relating to the transactions that they conducted. Mains
model branches received higher fee rates for certain transactions due to the fact that
they had to employ a number of staff to operate from the dedicated Post Office
counters. A Local had a small Post Office service point, sometimes referred to as a
combi, which was usually installed at the end of the retail counter. Postmaster’s
converting to one of the new models would have received a conversion payment.
19. Under Network Transformation, postmasters also had the option to leave the
business with a leaver’s payment, subject to a new model solution being installed,
either at the existing premises, or somewhere suitable within the local search area.
At the start of the programme, postmasters also had the option to stay as is. Some
rural Post Offices were effectively the only shop in the village and a number of these
were afforded community status, effectively meaning that they remained on their
existing contract and terms i.e. remained as a Sub Post Office.
20. When I became an FCA I received some training, but I can’t specifically recall
where this was, or how long the course lasted. My training would have covered the
two new models, the options available to postmasters, what the new counters looked
like and their footprint i.e. how much space they would take up.
21. My role as an FCA was to establish new model branches within my geographical
area. I would be supplied with fees estimates on what postmasters could expect to
ear as well as estimated conversion and leavers payments. I would receive batches
of postmasters to contact and to arrange visits and go through the options. My role
would oversee the end to end process up until a branch went live and primarily
support Postmasters on their journey.
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22. I worked with numerous colleagues within the Network Transformation Team and
had a number of line managers, all of which I believe to have been both competent
and professional.
23. In 2017 the Network Transformation programme was nearing completion and my
role as an FCA simply came to an end. Numerous personnel, including myself were
offered voluntary redundancy. As there were very few suitable job opportunities
within POL at that time, I decided to take the redundancy offer and left POL in
September 2017.
24. After more than 30 years of continuous employment with POL I was looking
forward to a break, although at that time I had no real plans of what else I wanted to
do, or how long before I sought alternative employment.
25. Sometime in late 2018 I was asked by an ex Post Office line manager if I was
interested in a role, contracted to a company called CBRE, in which I would
effectively be seconded to POL in order to help deliver Post Office projects for the
final quarter of that financial year. I was subsequently interviewed by someone in
CBRE and offered a fixed term contract as a Project Delivery Manager (PDM). I
accepted this, and performed that role from towards the end of December 2018 until
the end of March 2019.
26. I completed some online training modules in December and in early January I
attended a training course, led by a senior Post Office Property Manager. I believe
the course ran for 2 to 3 days and it covered things like the paperwork completion for
installing a Post Office in a premises as well as using software to draw the premises
layout and include items such as the Post Office counter, signage, safe etc. It was a
steep learning curve, re-integrating myself into the work place after more than a year
away and getting to grips with the paperwork and drawing tool.
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27. During my time as a PDM I visited a number of premises that had completed the
Post Office application process and were now ready for the counter etc to be
installed. I would discuss the works required with the incoming postmaster and
ultimately schedule dates for each install element including a go live date. I would
take photos, complete the relevant paperwork and submit this to the relevant Post
Office support team, who would then place the works orders with the relevant
contractors.
28. Later in 2019 I became aware of a vacancy within POL for the role of a Change
Manager (now called Network Provision Lead (NPL)) that covered an area in and
around where I lived. I successfully applied for the position and re-joined POL in
November 2019.
29. I don’t recall receiving any specific training for this position, as I believe it was felt
that I had performed similar roles in the past and had lots of relevant experience. As
such, it was case of seeking guidance and support from my line manager and
colleagues for anything that I was unsure of.
30. My role as an NPL primarily involves managing the Network Numbers (Post
Office branches open) within a geographical area. If a branch closes within my area,
then subject to business need, I would look to re-establish a service within that
community. This may mean a like for like replacement, which would be advertised on
the Run a Post Office website, or seeking to create an outreach, or to add as a stop
on the schedule of one of the mobile vans operating within my area.
31. Whilst employed by POL as a Security Manager, once I had interviewed a
suspect under caution, in addition to the report that I would submit to the Criminal
Law Team (via the Security Casework Team), I would also produce a separate, but
similar report for the relevant Contracts Manager. I believe that they used this in
conjunction with other documents e.g the auditor's report, to assist them with
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any decisions relating to disciplinary matters.
32. When submitting a case file to the Criminal Law Team, it would contain the
suspect offender report, taped interview summaries and any relevant
correspondence e.g. memos from the solicitor and relevant emails, further reports
etc from the Security Manager. The case file would also include 3 appendices and I
seem to recall that Appendix A was for witness statements (usually obtained after
legal advice), Appendix B was for copies of evidence and Appendix C for copies of
certain unused material.
33. If a case progressed to a Committal Hearing, then I seem to recall that the
Security Manager would produce a committal bundle, which comprised of copies of
Statements, evidence, and unused material. If there was a lot of unused material
then it may be that the items were listed but not copied, and that the defence could
arrange to view these documents if they so wished. The committal bundle would be
sent to the Criminal Law Team and they would be the ones who would disclose the
material to the defence.
34. Prior to an interview under caution, and if the suspect had legal representation, I
would disclose to the solicitor, details of the suspected offence and any documents
that I would be producing at that time.
35. I have no specific recollection of any dealings with the Civil Litigation Team,
although it may be that I was contacted by someone from that team from time to
time, in respect of a criminal case that I had investigated. I have no knowledge of the
disclosure policy within the Civil Litigation Team and do not know what the Litigation
Case Strategy would have been.
36. During my time as a Security Manager, I would have dealt with other
departments, for example, requesting personnel files form our Human Resources
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team. I have no recollection of specifically liaising with other Post Office departments
in respect of the progress of cases, although this may well have happened on a case
by case basis.
The Security team’s role in relation to criminal investigations and prosecutions
37. I have been asked by the Inquiry to consider the following documents, which I
may find to be of assistance when answering the questions set out below:
i) Casework Management Policy (version 1.0, March 2000) ([POL00104747]) and
(version 4.0, October 2002) ([POL00104777]);
ii) Rules and Standards Policy (version 2.0, October 2000) ([POL00104754));
iii) “Investigation Procedures Policy (version 2.0, January 2001) ([POL00030687));
iv) Disclosure Of Unused Material, Criminal Procedures and Investigations Act 1996
Codes of Practice Policy (version 1.0, May 2001) ([POL00104762));
v) "Royal Mail Group Ltd Criminal Investigation and Prosecution Policy" (1 December
2007) ([POL00030578]), which appears to be substantially the same as the policy of
the same date with a variation on the title at ([POL00104812]) (see, in particular,
section 3);
vi) "Royal Mail Group Security - Procedures & Standards - Standards of Behaviour
and Complaints Procedure" (version 2, October 2007) ([POL00104806));
vii) "Royal Mail Group Crime and Investigation Policy" (version 1.1, October 2009)
([POL00031003)});
viii) "Post Office Ltd - Security Policy - Fraud Investigation and Prosecution Policy"
(version 2, 4 April 2010) ([POL00030580));
ix) "Post Office Ltd Financial Investigation Policy" (4 May 2010) ([POL00030579));
x) "Royal Mail Group Security - Procedures & Standards - The Proceeds of Crime
Act 2002 & Financial Investigations" (version 1, September 2010) ([POL00026573)):
xi) "Royal Mail Group Security - Procedures & Standards - Initiating Investigations"
(September 2010) ([POL00104857));
xii) "Royal Mail Group Ltd Criminal Investigation and Prosecution Policy" (version
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1.1, November 2010) ([POL00031008));
xiii) Post Office Ltd Financial Investigation Policy (version 2, February 2011)
([POL00104853)):
xiv) Post Office Ltd Anti-Fraud Policy (February 2011) ([POL00104855));
xv) "Royal Mail Group Policy Crime and Investigation S2" (version 3.0, April 2011)
([POL00030786));
xvi) “Post Office Ltd PNC Security Operating Procedures” (August 2012)
([POL00105229)):
xvii) "Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement (with flowchart)", (October 2012) ([POL00104929));
xviii) "Undated Appendix 1 - POL Criminal Investigations and Enforcement
Procedure (flowchart)", (October 2012) ([POL00105226));
xix) The undated document entitled “POL — Enforcement & Prosecution Policy”
([POL00104968));
xx) "Post Office Limited: Criminal Enforcement and Prosecution Policy" (undated)
([POL00030602)});
xxi) "Conduct of Criminal Investigations Policy" (version 0.2, 29 August 2013)
([POL00031005));
xxii) "Conduct of Criminal Investigations Policy" (version 3, 10 February 2014)
([POL00027863});
xxiii) "Conduct of Criminal Investigations Policy" (September 2018)
([POL00030902)).
38. I have no recollection of any of the documents listed above. It may be that I had
previously seen some, or all of these documents but I have no recollection. I would
have thought that policy documents would have been stored on some sort of
database, in which someone could access if required.
39. The organisational structure of the Security team did change over time. I cannot
recall specific changes or when they occurred but typically, there would be a Head of
Security, under which were Senior Security Managers that headed up certain strands
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of security and the teams within each strand. For example, I seem to recall that the
Security Managers were in the Fraud strand, but it may have been called something
else at different times. Under the Senior Security Manager would be a number of
Team leaders and under them, a number of Security Managers. When I first joined
the Security Team I seem to recall that there were around 5 to 6 teams of Security
Managers. Within each team I recall that there were typically around 6 to 8 Security
Managers. Over time, following various restructures within the Security Team, the
numbers of teams and personnel would gradually decline. When I left the Security
Team there were just 2 teams of Security Managers, a North Team and a South
Team. I seem to recall that it had been just the 2 teams for quite some time.
40. I have no recollection of any of the documents listed in paragraph 38 above and
would say that it is extremely unlikely that I would have had any involvement in the
development and / or management of them.
41. I have no specific recollection as to what legislation, policies and / or guidance
governed the conduct of investigations conducted by the Security team during the
period that i worked within it, other than that I can recall the names of certain
legislative acts e.g. The Theft Act, The Fraud Act and that investigations were
conducted in accordance with the Police and Criminal Evidence Act 1984 codes of
practice. From memory, the codes of practice covered the interviewing of suspect
offenders and conducting searches. I have a vague recollection that any key
changes to relevant legislation or any new acts e.g the Fraud Act, would have been
communicated to Security Managers, possibly via the Criminal Law Team.
42. I have no recollection as to what process was in place for dealing with complaints
about the conduct of an investigation by the Security team? I have no
recollection of any complaints made either against the way that I conducted an
investigation, or any that were conducted by any of my colleagues.
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43. In terms of supervision over criminal investigations conducted by Security
Managers, the Team Leader would be aware of all cases being conducted by their
team and these would be discussed at one to ones and team meetings. I believe that
cases would also be discussed at Senior Security Meetings that the Team Leaders
would also attend.
44. I do not recall there being any difference in Post Office policy and practice
regarding investigation and prosecution of Crown Office employees in relation to any
policy and practice regarding investigation and prosecution of Sub Postmasters, their
managers and assistants.
Audit and investigation
45. I have been asked to consider the document “Condensed Guide for Audit
Attendance” (version 2, October 2008) [POL00104821]:
I have no recollection of this document. As far as I can recall, there would have
been situations in which Security Mangers would attend a Post Office Branch whilst
an audit was in progress, or had just been completed and there was a large shortfall
in the accounts. There would have been some occasions whereby Security Mangers
would attend at the same time as auditors. This may have been if there were existing
concerns that there may be a significant shortfall in the accounts. In my experience
and recollection, the Security Manager would not actively participate in the audit.
46. From recollection, investigation cases would be generated by the Security
Casework Team. They may have been asked to raise a case by the Security Team
Leader, although there may have been some situations whereby cases were
instigated by other Security personnel but I have no specific recollection of this. I
have no recollection of something called the Financial Services Centre or how debts
were recovered from postmasters in relation to shortfalls that weren't the subject of a
criminal investigation. I have no recollection as to what involvement a Contracts
Manager would have in relation to the policy for postmasters repaying debts due to
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shortfalls in their accounts.
47. I cannot recall what the triggers / criteria were for raising a fraud case following
the identification of a shortfall / discrepancy in a branch? I do not believe that there
were separate triggers / criteria for raising a theft case in relation to a false
accounting case. My recollection is that these would simply be raised as audit
shortfall cases.
The process followed by Security team investigators when conducting a criminal
investigation following the identification of a shortfall at an audit
48. Once a decision had been made to conduct a criminal investigation, a case
would be allocated to a Security Manager by the Team Leader. The Security
Manager would conduct initial enquiries relating to the type of case and ultimately
arrange to conduct an interview under caution with anyone who was suspected of
having committed a criminal offence.
49. For example, if the case related to a significant audit shortage that had been
brought to the Security Team's attention by an auditor at the time of the audit, then
subject to availability and other priorities, members of the Security Team may attend
the Post Office in question that same day. This would be to gather PO accounting
documentation and potentially seek to conduct searches and interview at that time.
50. Prior to attending the Post Office subject to the audit deficiency, the Security
Manager may have analysed some Horizon data that was available on a what was
known as Credence. From recollection, this was a management information
database relating to Horizon transactions and other entries that were conducted at
Post Offices. I cannot recall when Credence came into existence, or over what
period the Security Team had access to this. I recall that Credence only held data for
a relatively short period of time, possibly 2 to 3 months, but I can’t be certain of this.
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51. When attending a Post Office branch, the Security Managers would introduce
themselves to the postmaster or manager and show their ID cards. This would also
apply to any post office assistants or Post Office employees that were to be involved,
either as suspects or witnesses.
52. To use an audit shortage case as an example, if there was evidence of a criminal
offence and that someone was suspected of having committed that offence, then it
would normally follow that they would be invited to attend an interview and that
searches of premises and vehicle would be requested. In that situation, the suspect
would be cautioned and their legal rights explained. This was covered on form
CS001 (at some point called GS001 I believe) and the suspect was invited to
indicate on the form as to whether they required legal representation at that time.
They would then be invited to sign the completed form and to confirm their
understanding.
53. For voluntary interviews, the suspect could also have what was known as a Post
Office Friend present, which had to be somebody within the business but not
connected to the investigation. So for example, this could be a representative of the
National Federation of Subpostmasters. This entitlement was in addition to having
legal representation, so a suspect could have both a solicitor and Post Office Friend
present during an interview. The Post Office Friend rule was covered on form CS003
(GS003) and the suspect would be invited to read and sign this.
54. The Security Manager may wish to conduct searches of the suspect's premises,
home and vehicle. Unless the suspect had been arrested by the police, then
searches and interviews were on a voluntary basis and that consent was required
from the suspect. I seem to recall that form CS005 (GS005) set out the details of the
search, in what was being searched, the extent of the search and that they could ask
for the search to stop at any time. The suspect would be asked to read and sign the
form, indicating whether they gave consent for searches to take place.
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55. In some cases, the Police were asked to assist, particularly for certain cases
where searches were deemed essential to obtain and preserve evidence. In these
situations, any suspects would be arrested, and searches conducted by the Police
under the relevant sections of the Police and Criminal Evidence Act (PACE).
56. Interviews would be tape recorded and conducted under caution. The suspect
would be entitled to seek legal advice and representation at the interview. The tape
machines supplied to Security Managers would require 2 tape cassettes to be
installed for each interview. I seem to recall that the tapes would run for
approximately 45 minutes. If the interview needed to be continued, then a further 2
tapes would be inserted. Of each set of 2 tapes, one would be signed and sealed
and act at the Master Tape, which may later be produced as evidence and the other
would be used as a working tape, of which copies could be taken.
57. Following an interview, the Security Manager would compile what was referred to
as an Offender Report and paginate it within a green case file. The file would also
contain appendices, and from recollection, any copies of any statements obtained
thus far would go in Appendix A, copies of evidence in Appendix B and copies of
certain unused material items e.g. Post Office Friend form, Personnel record etc
would go in Appendix C. The case file would then be sent to the Criminal Law Team,
via the Security Casework Team, I believe.
Decisions about prosecution and criminal enforcement proceedings
58. The Criminal Law Team may ask for further enquiries to be conducted at that
stage but ultimately would be the ones to advise on and formulate any criminal
charges. From my recollection, the decision to prosecute would be made by a Senior
Security Manager, and this was probably the Head of the Security Fraud Team.
I do not believe that the Contracts Manager would have any involvement in this
decision, but would purely deal with the discipline / contractual element.
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59. I have no knowledge or recollection as to what test was applied by those making
prosecution and charging decisions, or what factors were considered at the
evidential and the public interest stage?
60. I am unaware as to what advice, legal or otherwise, was provided to those
making decisions about whether to prosecute and what charges to bring, other than
that I believe that they would have seen the case file, or at least, the advice from the
Criminal Law Team when considering their decision.
61. I have no recollection regarding in what circumstances, consideration was given
towards any steps taken, in which to restrain a suspect's assets by criminal
enforcement methods, such as confiscation proceedings. I have no recollection as to
who decided whether criminal enforcement proceedings should be pursued and what
factors they considered when making decisions around this. I seem to recall that if
an offender pleaded guilty at court, or was found guilty following a trial, that POL
would ask the court to consider awarding costs and compensation.
Training, instructions and guidance to investigators within the Security team
62. I have been asked by the inquiry about instructions, guidance and / or training
that were given to investigators within the Security team about the following topics
and how was this provided:
i) interviewing a SPM / SPM'’s assistant / Crown Office employee who was suspected
of a criminal offence;
ii) taking witness statements in the course of an investigation;
iii) conducting searches in the course of an investigation;
iv) the duty on an investigator to investigate a case fully;
v) obtaining evidence in the course of an investigation;
vi) whether and in what circumstances evidence should be sought from third parties
who might hold relevant evidence and, in particular, Fujitsu, where shortfalls were
identified in branch;
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vii) an investigator's disclosure obligations;
viii) drafting investigation reports to enable a decision to be made about the future
conduct of a case.
63. In relation to paragraph 62 above, I have very little recollection as to what
specific instruction, guidance and training I received. I can recall that conducting
interviews, searches and taking witness statements was covered on my Security
Induction Training. I can recall that I attended a training course relating to conducting
interviews at some point when I was a Security Manager but I cannot recall the
details. As best as I can recall, following my induction training, knowledge and
experience was gained through shadowing and working with more experienced
colleagues, including support from the Team Leader.
64. The inquiry has asked me to consider the following documents:
i) The Casework Management document at [POL00104747] (version 1.0, March
2000) and [POL00104777] (version 4.0, October 2002);
ii) David Posnett’s email to me and others dated 23 May 2011 at [POL00118096]
and the documents contained within the attached compliance zip file at
[POL00118108}], [POL00118109], [POL00118101), [POL00118102],
[POL00118103], [POL00118104], [POL00118105], [POL00118106] and
[POL00118107].
65. I have no recollection of the 2 documents referred to in paragraph 64 i) above
and cannot say whether I was ever provided with copies of them. These documents
appear to have been written over 20 years ago and i would not now be able to recall
any of the content contained within, or what my understanding would have been in
relation to any content at that time.
66. Some of the documents referred to in paragraph 64 ii) above appear to relate to
compliance checks conducted, primarily on the presentation, layout and content of
case files. I am unsure at what point case file presentation became the subject of
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compliance checks, or if this continued after I left the Security Team. I do not recall
any specific documents, but I do recall that these compliance checks were
conducted and that some form of guidance (which I assume are these documents)
was sent out to Security Managers. I cannot recall who conducted the compliance
checks but I can recall there being a scoring matrix. I do not recall having any
involvement in either the development, management, or any amendment in relation
to these documents.
67. The inquiry has asked about my understanding of paragraph 2.15 (starting on
page 10) of the document entitled “Guide to the Preparation and Layout of
Investigation Red Label Case Files — Offender reports & Discipline reports”
[POL00118101] and how this related to the Offender Report Template
[POL00118102], as well as it’s relevance to POL’s disclosure obligations.
68. I have a vague recollection of these 2 documents, which appear to detail the
structure and layout of the Offender and Discipline reports. From recollection,
disclosure of materials would be dealt with by the Criminal Law Team. I have no
recollection of any reference made in relation to any “Horizon bugs, errors and
defects” during my time as a Security Manager.
69. I do not recall the document entitled “Identification Codes” (at [POL00118104)),
and do not know who drafted this document. My understanding of why Identity
codes were required, was that this information would be included on the Police
National Computer database, for any persons that were convicted of a criminal
offence in relation to a prosecution conducted by the Post Office. I can recall that the
relevant identity code was included in the preamble of the offender report. I also
believe this was indicated on a form named NPA01, by means of ticking the relevant
ID code box.
Analysing Horizon data, requesting ARQ data from Fujitsu and relationship with
Fujitsu
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70. As a Security Manager, I would have been able to submit requests for Horizon
data. I cannot recall whether this was submitted via the Casework Team, or another
admin function within the Security Team. The request would be submitted to a
contact point working for Fujitsu and a CD Rom containing data for the requested
period would be sent to the Security Manager.
71. From recollection, the data was in Microsoft Excel format and the data from the
CD Rom was either extracted or copied (I can’t recall the precise method) onto the
Security Manager’s laptop. I cannot specifically recall what analysis was conducted
but believe that I would have looked at things such high value transactions, including
any adjustments or reversals. I would also look at the amount of cash being
declared and the frequency of those declarations.
72. I have been asked by the Inquiry as to where a shortfall had been identified and
the relevant postmaster, their manager(s) or assistant(s) / Crown Office employee(s)
attributed the shortfall to problems with Horizon, was ARQ data requested from
Fujitsu as a matter of course?
73. I can recall that there was a limit to the amount of data that could be obtained as
per a standard request. I believe that there was a cost to POL for requests of data
that were over the agreed limit. I cannot recall Horizon data being supplied directly to
a postmaster, or others subject to a POL criminal investigation, but it would form part
of the disclosure from the Criminal Law Team to the Defence legal team. The
Security Manager would request a statement from Fujitsu, via the security admin
team, and that person (Fujitsu) would produce any Horizon data that had been
supplied in that case. My recollection is that the statement and Horizon data would
form part of the committal bundle, or further evidence disclosed.
74. The Inquiry has asked me to consider documents [FUJ00153133] and
[FUJ00125911] and asked whether I was aware of the issue of duplication of
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transactions records in ARQ returns:
My response is that I have no recollection of any such issues. I can see from the
documentation (email exchanges) that it would appear that an explanation for the
duplication was supplied by Fujitsu and that it did not affect the accuracy of Horizon.
75. The Inquiry has asked me to consider documents [FUJ00154911],
[FUJ00154925], [FUJ00156494], [FUJ00156530], [FUJ00156536], [FUJ00154903],
[FUJ00155009] and [FUJ00225238] and asked to describe the circumstances in
which I would have contact with Fujitsu when I worked within the Security team and
the relevant contacts at Fujitsu.
76. I can recall the names of Penny Thomas and Andy Dunks as being contact
points at Fujitsu. I seem to recall that Penny was the main contact point for the Post
Office Security and I believe that she dealt with Horizon data requests and produced
witness statements as and when required. I seem to recall that Andy performed a
similar function but from viewing the documentation it would appear that he also
dealt with Horizon Call Logs as part of any statement given. From recollection,
Security Managers would request Horizon data and statements from Fujitsu via a
Security Admin Team, although there appear to have been times when Security
Managers would either send or receive emails directly to / from Penny or Andy.
77. I have no recollection of the name Gareth Jenkins from my time as a Security
Manager, although I can see his name in some of the email documentation. I have
no recollection of him being an expert witness and have no recollection as to
whether I had an understanding at that time, as to what the rules are that govern an
independent expert witness.
Relationship with others
78. I have no specific recollection of Cartwright King Solicitors. I can recall that at
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some point in time that POL used external solicitors to assist with prosecutions, but I
cannot recall who this was, or the names of any of those solicitors.
Involvement in the Criminal Case Studies
Prosecution of Josephine Hamilton
79. The Inquiry has asked me for a full and detailed account of the investigation and
prosecution of Josephine Hamilton and to set out my recollection of this case
including but not limited to addressing the questions below. In answering the
questions below, the Inquiry suggests that I may be assisted by the following:
i) The emails, dated March 2006, at [POL00067205];
ii) The audit report from 9 March 2006 [POL00044497];
iii) The letter from Graham Brander, dated 9 March 2006 [POL00047137];
iv) The letter from Graham Brander, dated 12 April 2006 [POL00118743];
v) The letter from Graham Brander to Ged Harbinson, dated 12 April 2006
[POL00118769];
vi) The record of Ms Hamilton's interview on 5 May 2006 at [POL00044477] and
[POL00045409];
vii) The offender report in respect of Ms Hamilton at [POL00044389);
viii) The investigation report (personnel) [POL00047955);
ix) The investigation report (legal) [POL00044389];
x) The suspect offender report [UKGI00001504];
xi) The financial investigation events log [POL00044470);
xii) The memo from Graham Brander (undated) [POL00064288];
xiii) The letter from Graham Brander, dated 13 June 2006 [POL00118739];
xiv) The memo from Juliet McFarlane to the Investigation Team, dated 26 June 2006
[POL00048035);
xv) The letter from Graham Brander, dated 30 June 2006 [POL00118745];
xvi) The letter from Graham Brander to Josephine Hamilton, dated 10 July 2006
[POL00048223};
xvii) The memo from Graham Brander, dated 11 August 2006 [POL00118610];
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xviii) The memo from Juliet McFarlane, dated 11 October 2006 [POL00048205];
xix) The letter from Graham Brander, dated 30 October 2006 [POL00118760] and
summons [POL00118761];
xx) The memo from Graham Brander, dated 14 November 2006 [POL00048252];
xxi) The memo from Juliet McFarlane, dated 16 November 2006 [POL00048269];
xxii) The letter from Graham Brander, dated 27 November 2006 [POL00118768];
xxiii) The information, dated 6 December 2006 [POL00118762];
xxiv) The witness statement of Graham Brander, dated 3 January 2007
[POL00044484);
xxv) The witness statement of Penny Thomas, dated 9 January 2007
[POL00044481);
xxvi) The memo from Graham Brander, dated 15 January 2007 [POL00118754];
xxvii) The memo from Juliet McFarlane, dated 30 January 2007 [POL00048473];
xxviii) The memo from Juliet McFarlane, dated 13 February 2007 [POL00118650];
xxix) The witness statement of Graham Brander, dated 21 February 2007
[POL00064257];
xxx) The memo from Graham Brander, dated 27 February 2007 [POL00118758);
xxxi) The memo from Miss Andrews, dated 1 March 2007 [POL00091018];
xxxii) The memo from Miss Andrews, dated 15 March 2007 [POL00048558);
xxxiii) The memo from Phil Taylor, dated 10 May 2007 [POL00118619];
xxxiv) The memo from Juliet McFarlane, dated 14 May 2007 [POL00119068];
xxxv) The memo from Juliet McFarlane, dated 30 May 2007 [POL00118641];
xxxvi) The memo from Juliet McFarlane, dated 31 May 2007 [POL00048761] and the
same document with comments attached [POL00118868];
xxxvii) The memo from Juliet McFarlane, dated 6 June 2007 [POL00048766);
xxxviii) The witness statement of Graham Brander, dated 25 June 2007
[POL00064258);
xxxix) The memo from Graham Brander, dated 16 July 2007 [POL00048905);
xl) The memo from Juliet McFarlane, dated 15 November 2007 [POL00049154);
xli) The memo from Juliet McFarlane, dated 19 November 2007 [POL00044388];
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xlii) The indictment [POL00048533];
xliii) The case opening [POL00126356];
xliv) The witness list [POL00118756];
xlv) The list of exhibits [POL00118757];
xlvi) The Schedule of Non-Sensitive Unused Material [POL00118755];
xlvii) The memo from Phil Taylor, dated 5 February 2008 [POL00118858]; and
x\viii) The case closure report [POL00057745].
80. I have very little recollection of the details relating to this case, which I can see
relates to an audit shortage in 2006.
81. I have no clear recollection of the circumstances in which I became involved in
Ms Hamilton’s case but they appear to have been covered in the document
[POL00067205], which is an email chain relating to the fact that Ms Hamilton was
asked to return circa £25,000 in excess cash but it didn’t appear that this had been
done.
82. As a Security Manager it would be my role to investigate the high value audit
shortage that was identified. This would involve analysing POL documentation from
the PO branch in question and any Horizon data requested, conducting interviews
under caution and usually searches. In this particular case, I can see that searches
weren't conducted, which was probably due to the fact that Ms Hamilton had been
signed off work.
83. I cannot recall whose decision it was to conduct an audit at South Warnborough
PO and it is not clear from the documentation that I have been sent, who was the
person that requested the audit.
84. I have no recollection of the audit itself but see from the documentation that I was
in attendance and witnessed it.
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85. I cannot recall whose decision it was to attend Ms Hamilton’s property on the day
of the audit but can see from the documentation, that Ms Elaine Ridge, Area
Intervention Manager had earlier obtained the PO keys from Ms Hamilton at her
abode. From the documentation, it appears that the purpose of the visit, was for Ms
Hamilton to be made aware of the amount of the deficit and in view of this, that Ms
Ridge needed to precautionary suspend her. The purpose of my attendance was to
advise Ms Hamilton that I would be conducting an investigation into the audit
shortfall and would like to interview her.
86. From the documentation, I can see that I explained the nature of the
interview, including her legal rights and the PO Friend rule. I can see that it is
} so I advised her
+
mentioned that Ms Hamilton had been I
to contact me when she felt able to be interviewed.
87. Other than advising Ms Hamilton of the above, I did not have any discussion with
her, as I stated that I was not going to ask her any questions about the deficit at that
time.
88. My understanding of the circumstances in which Ms Hamilton was suspended
was due to the high value audit shortage.
89. I cannot say whether it was Elaine Ridge’s decision to precautionary suspend Ms
Hamilton, or whether she was instructed to do so by someone else from the retail
line.
90. I have no recollection as to what enquiries were conducted before the decision to
suspend Ms Hamilton was made. Until the audit, it was not known whether there
would be a deficit identified, or what the amount was likely to be.
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91. I cannot recall what further enquiries were made in relation to the shortfall
identified at the audit. The enquiries that I conducted are covered in the offender
report and memos, items [POL00047955], [POL00118745] and [POL00118610].
92. I have been asked to consider [POL00047137] and the record of interview from 5
May 2006 at [POL00044477] (commencing at 12:13 and concluding at 12:58) and at
[POL00045409] (commencing at 13:09 and concluding at 13:32) in relation to some
questions, in which I respond as follows:
i) As the Security Manager that was allocated this case then it would effectively have
been my decision to interview Ms Hamilton as that would be the normal procedure in
such an instance.
ii) Although I cannot recall this, I can see from my offender report [POL00044389]
that I made disclosure to Ms Hamilton's solicitor prior to the interview. The disclosure
would likely have been details of the audit shortage and any accounting
documentation that was I intending to refer to during the interview.
iii) As the officer in the case, I would have taken the lead on the questions put to
Ms Hamilton.
93. I cannot recall the details of the investigation conducted after the interview,
although these appear to be covered in the documentation referred to in paragraph
79 above, in particular, items [POL00047955], [POL00118745] and [POL00118610].
I can see from the documentation that I obtained some Horizon printouts and
accounting documents from South Warnborough PO, some Horizon data from
Fujitsu, some information relating to cash declarations, details of calls made to the
Helpdesk, and details of training materials supplied to Ms Hamilton in respect of
Branch Trading. I can also see that I received from the PO Area Office in
Bournemouth, some details relating to what appeared to be a pre-existing £112,000
debt that Ms Hamilton had declared to POL, prior to appointment as postmaster. I
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can also see that I sought to obtain bank statements relating to Ms Hamilton. No
searches appear to have conducted in this case, which I can only presume was
due to Ms Hamilton being signed off work for some time.
94. I have no recollection of the sources of evidence that I considered during the
course of the investigation, other than that covered in paragraph 93 above.
95. I would have submitted my offender report, further reports, any memos and
emails to the Criminal Law Team and they would respond with their own memos and
emails, in respect of things such as further enquiries and matters relating to the
prosecution. The Criminal Law Team would advise on the sufficiency of the
evidence.
96. I have been asked to consider [POL00044389], in relation to the Horizon
printouts and accounting documentation that was obtained from South Warborough
PO and my response to the questions asked are as follows:
i) I can see from the offender report [POL00044389] that in respect of analysing the
Horizon printouts, it states that I was unable to find any evidence of theft or that the
cash figures had been deliberately inflated. From my recollection of PO
investigations in general, then certain Horizon printouts obtained from the PO branch
could occasionally give an indication of criminality but other than the cash
declarations, most were simply summaries of transaction conducted. In some
situations, someone hiding a deficit in the accounts may declare the correct cash on
hand figure, which would then show any discrepancy in the accounts, shortly
followed by an inflated one, in order to effectively make the account balance.
Although I cannot recall specific cases, there were also occasions whereby if
someone was stealing money, that they may simply inflate the cash figure to achieve
a balance, or a near balance, having already known roughly how much it was likely
to be short. It may also be that the cash declaration was being inflated at the end of
each day.
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ii) I cannot recall the printouts that I viewed, but from my report I can see that a
Horizon Event Log Balancing was obtained for the period 26 January 2006 — 09
March 2006. This generally showed one cash declaration being done each day and
didn’t show any occasions whereby what appeared to be a genuine cash figure
would be declared followed by an inflated figure.
iii) A number of envelopes containing weekly accounting documentation were also
obtained. Up until around January 2005 it appeared that each day’s cash holding
was manually entered on a sheet of paper. However, for some reason this appeared
to cease after that time, as I did not find any of those sheets post January 2005. In
my experience, some Postmasters or their staff, would enter the various cash
denominations in a book or on paper, usually to keep a running total of the bulk
notes and coins in the safe. At the end of the day, the working notes and coin (in the
counter drawer) would be added to the bulk figures and the total of each
denomination entered onto Horizon.
iv) A number of Cash Account Finals and Branch Trading Statements were obtained.
(Horizon used to operate whereby the postmaster would produce a weekly balance
(cash Account) but this changed at some point to producing a monthly Branch
Trading Statement, although it was recommended that postmasters still balanced
weekly). I completed a schedule detailing the cash on hand figures from week
ending (w/e) 01/12/04 to the period ending 09/03/06. From this schedule it could be
seen that between w/e 01/12/04) and w/e 30/03/05, the declared cash on hand
remained fairly constant, generally fluctuating between £15,000 and £18,000.
Between w/e 06/04/05 and w/e 29/06/05 it fluctuates between £18,000 and £20,000.
From w/e 13/07/05 to period ending 08/02/06 it gradually rises from around £22,000
to £35,000.
97. Security Managers conducted the investigation and submitted case files to the
Criminal Law Team who would advise on the sufficiency of the evidence as to
whether criminal charges should be brought.
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98. Any decision to prosecute would be made by the relevant Senior Security
Manager. To the best of my recollection, Security Managers played no part in the
decision to prosecute.
99. I cannot recall the circumstances relating to requesting call log details, in respect
of South Wamborough PO, from the Network Business Support Centre (NBSC) and
the Horizon Support Helpdesk (HSH), although the offender report suggests that it
was in relation to references made in Ms Hamilton’s prepared statement. I cannot
recall what further steps were taken following the response from lan Speck, although
I can see that Andy Dunks (Fujitsu) produced details of HSH call logs in his
statement. I can see from document [POL00118610] that I reported Mr Speck’s
response to our Criminal Law Team and associated a copy of his email response in
Appendix C of the case file.
100.
i) From the documentation e.g. my further report, dated 11/08/06 [POL00118610], I
can see that in Mrs Hamilton's prepared statement, she says that she received two
weeks of half day training sessions. Also, in this report I can see that I was advised
that when Ms Hamilton became postmaster, that she would have been asked if she
required any training, and the records in the Area Office show that no training was
required in this instance. Ms Hamilton was already working in South Warnborough
PO for the previous postmaster. A copy of that record was placed in Appendix B of
then case file.
ii) From the document [POL00118610] I can see that South Warnborough Post
Office migrated to Branch Trading on 05 October 2005. It states that no visit would
have been made to the Post Office but they were sent an Interactive Training CD
ROM, a copy of the Transition Guide, a copy of the Quick Reference Guide, a
Branch Trading Calendar and one each of the Branch Trading Balancing and
Reporting manuals. It further states that each Postmaster would also have been
invited to attend the numerous Face 2 Face events explaining the migration to
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Branch Trading. It states that a number of offices requested replacement items or
videos in exchange for the CD ROM. It states that there is no record of South
Warnborough PO requesting a video.
101. I have been asked to consider [POL00048766] in relation to whether I found
any evidence from Ms Hamilton’s lifestyle “to illustrate where the money went”, as
instructed by counsel?
I have no recollection of this memo. I'm unsure what investigations into lifestyle that I
would have been able to be conduct, as I can see from my offender report
[POL00044389] that no searches were conducted, no doubt due to Ms
Hamilton bein:
seized from a search would have been the most likely way of finding any evidence
relating to lifestyle. I can also see that Ms Hamilton signed authority for disclosure
into her bank accounts, which I posted to the relevant banks, but it appears that bank
statements were never received. It appears that my postal requests may not have
been received by the relevant banks and I can see that I wrote to Ms Hamilton to ask
her if she would sign further disclosure copies for me to submit, but it doesn’t appear
that Ms Hamilton responded to this further request. I reported this to the Criminal
Law Team within my memo [POL00118610].
102. I have no recollection of any discussions that I may have had with counsel or
POL’s legal representatives regarding this case. Regarding disclosure, the Security
Manager would submit the case file, including the Offender Report to the Criminal
Law Team, and any additional reports and memos. If a case was committed to the
crown court, then the Security Manager would prepare a committal bundle (copies of
evidence, statements and Unused Material) and submit this to the Criminal Law
Team, who would then deal with any disclosure to the Defence.
103. I have no knowledge or recollection of disclosure requests and as per
paragraph 102 above, my understanding is that such requests would be dealt with by
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the Criminal Law Team.
104. I have been asked to consider [POL00044481] and [POL00118757] in relation
to disclosure from third parties e.g Fujitsu, whether ARQ logs were sought and if so,
the period they covered.
105. I can see from the documentation provided to me that Penny Thomas provided
a witness statement and produced as an exhibit, a period of Horizon data. I can see
from my offender report that I submitted a request and subsequently received
Horizon data covering the period 09 February 2006 - 08 March 2006, so can only
assume that this is the Horizon data that Penny has produced within her statement.
A copy of that statement would have been included within the committal bundle or
produced as further evidence. I cannot recall whether the CD containing Horizon
data was copied to the defence, but it would have been referenced in the committal
bundle or further evidence and the defence would have been able to request a copy,
if it hadn’t previously been provided.
106. I have no recollection of the circumstances in which I requested a witness
statement from Andy Dunks but it would appear from the documentation that this
was at the request of the Criminal Law Team, in order to produce some HSH call
logs.
107. I have been asked to consider [POL00048913] and to describe the
circumstances in which I went to view the ‘defence documentation’, the purpose and
what documents I viewed:
I have no recollection of viewing any Defence documentation, but item
[POL00048913] refers to a visit I made to chambers and the documentation that I
viewed, which appeared to be a lot of standard PO accounting documentation e,g.
Cash Account Finals and Horizon printouts. I can see from the memo that there were
7 boxes, containing 91 ring binders of accounting documentation and included items
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prior to when Ms Hamilton had become postmaster. I can see that I advised the
Criminal Law Team that some Cash Account Finals, prior to the dates that I had
previously scheduled, showed from October 2003 to November 2004 that the
declared Overnight Cash Holdings totals were generally only around £8,000 —
£14,000.
108. I have no recollection of any circumstances in which I was asked for my view
on the acceptability of a guilty plea. I can see from [POL00049083] that I agreed with
counsel's view but stipulated that any decision on accepting the basis of the plea,
would be down to Dave Pardoe, who was a Senior Security Manager at the time.
109. I have no recollection of the memo from Ms McFarlane [POL00044388]
whereby it states that “a plea on the basis that the loss was due to the computer not
working properly will not be accepted” and cannot say what my view would have
been at the time.
110. I have no recollection of memo [POL00048471] and am not sure that I would
have had a view on the best way to proceed should Ms Hamilton not repay the
outstanding loss, as I would have thought that this would be a legal matter, and for
the Criminal Law Team to deal with.
111. I have no recollection of any further involvement that I had in this case once
court proceedings had concluded, other than that I believe that I would of
submitted the case file for closure.
112. I have no recollection as to whether I had any particular view, in respect of the
proceedings against Ms Hamilton.
113. I have been asked what my reflections are now on the way the investigation
and prosecution of Josephine Hamilton was conducted by the Post Office and the
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outcome of the case and that I may wish to consider the Judgment of the Court of
Appeal in Josephine Hamilton & Others v Post Office Limited [2021] EWCA Crim 577
at [POL00113278] (and in particular at paragraphs 142 to 148).
114. My response to the above, is that throughout my time as a Security Manager,
and also, up until I left POL in 2017, it was always my understanding that the Horizon
system was robust, as this was the message that was always instilled in everyone by
POL, and I was not aware of any reference to ‘bugs, errors or defects’ relating to the
integrity of Horizon. Although I cannot recall any specific examples, I
understand from the documentation that I have received from the Inquiry that Fujitsu
would in certain cases, supply an expert witness statement relating to the integrity of
Horizon.
Prosecution of Julian Wilson
115. The Inquiry has asked me for a full and detailed account of the investigation
and prosecution of Julian Wilson and to consider the following documents:
i) The Record of Tape Recorded Interview dated 15 September 2008
[POL00050140] (part 1) and [POL00050128] (part 2);
ii) Jarnail Singh’s memo to the Fraud Team dated 6 January 2009 [POL00044806];
iii) The Schedule of charges [POL00047083);
iv) The Summary of Facts [POL00044767];
v) The Financial Investigation Events Log [POL00044749);
vi) The event capture form [POL00118275].
116. In respect of the Julian Wilson case, I am asked to consider [POL00118275], as
in it, I am referred to as the Investigation Team Manager:
117. For a period of approx. 3 to 4 months in 2008, I was temporarily promoted to
Security South Team Leader. I cannot specifically recall what I would have done as
Team Leader, other than that I would allocate cases to the team, conduct one to
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ones and chair any team meetings during that time. I can see that I retained my
existing Security Manager caseload i.e. investigation cases, whilst also acting as
Team Leader.
118. I have no recollection of the case involving Julian Wilson and am unable to say
whose decision it was to conduct an audit at Astwood Bank PO branch.
119. I do not believe that I would have had any involvement in the audit, or have
been in attendance.
120. Conducting an interview would have been standard procedure for a high value
audit discrepancy case. The Security Manager allocated the case would arrange
such an interview, and this would no doubt have been the case in respect of Mr
Wilson.
121. I have no recollection, but there may have been materials disclosed by the
officer in the case (Security Manager) to the legal representative of the person being
interviewed.
122. I can see from the tape summaries that I was referred to as the second officer
at the interview. My role would have been to support the officer in the case during
the interview. I would also be able to ask questions of the person being interviewed.
123. I have been asked to provide details of my involvement (if any) in the
investigation conducted after Mr Wilson was interviewed, as well as my view
regarding how the prosecution was conducted, the outcome and whether I think
anything should have been done differently.
124. My response to this is that I do not believe that I would have had any further
involvement in this case, other than participating in the interviews. As such, I am
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unable to comment on my views surrounding the prosecution and outcome of this
case, or anything that possibly should have been done differently.
125. I have been asked for my reflections now on the way the investigation and
prosecution of Julian Wilson and related criminal enforcement proceedings were
conducted by the Post Office and the outcome of the case and advised that I may
wish to consider the Judgment of the Court of Appeal in Josephine Hamilton &
Others v Post Office Limited [2021] EWCA Crim 577 at [POL00113278] (and in
particular at paragraphs 175 to 178), in addition to the documents referred to above.
126. As mentioned in paragraphs above, other than participating in the interviews, I
do not believe that I would have had any further involvement in this case. Also, as
mentioned in paragraph 114 above, I was not aware of any reference to ‘bugs, errors
or defects’ relating to the integrity of Horizon at that time. POL had always instilled in
us that it was robust and that there were no issues regarding its integrity.
Prosecution of Ms Lynette Hutchings
127. The Inquiry has asked me for a full and detailed account of the investigation
and prosecution of Lynette Hutchings and to set out my recollection of this case,
and that it may be that I assisted by the following:
iv) The handwritten note at [POL00046065];
v) The Audit Report dated 31 March 2011 at [POL00056292];
vi) The Record of Tape Recorded Interview dated 20 April 2011 at [POL00056417]
(part 1), [POL00044505] (part 2), [POL00046625] (part 3);
vii) The prepared statement of Ms Hutchings [POL00056420);
viii) The suspension letter, dated 30 March 2011 [POL00067173]);
ix) Ms Hutchings’ antecedents [POL00046704);
x) The Investigation Report (legal) dated 5 May 2011 [POL00046706);
xi) The Investigation Report (personnel), dated 6 May 2011 [POL00044508);
xiii) The HSD Call Log [POL00066754);
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xiv) The memo from Jarnail Singh dated 17 June 2011 [POL00046626);
xv) The ARQ Requests, dated 21 June 2011 [POL00056585] and [POL00056694];
xvi) The memo from Maureen Moors to Graham Brander, dated 21 June 2010
(appears to be a typo and should be 2011) [POL00046627];
xvii) The memo from Maureen Moors to the Criminal Law Team (undated)
[POL00046088];
xviii) The witness statement of Andrew Dunks, dated 12 July 2011 [POL00046615);
xix) The witness statement of Graham Brander, dated 11 August 2011
[POL00056742);
xx) The witness statement of Adam Shaw, dated 20 September 2011
[POL00046637];
xxi) The witness statement of Nigel Allen, dated 22 September 2011
[UKG100014819];
xxii) The witness statement of Louise Sheridan, dated 24 November 2011
[POL00057230);
xxiii) The witness statement of Graham Brander, dated 25 November 2011
[POL00063481_ 008);
xxiv) The memo from Graham Brander to Jarnail Singh, dated 9 December 2011
[POL00046628];
xxv) The Advice and Proposed Charge drafted by Martin Smith of Cartwright King
[POL00057362];
xxvi) The indictment [POL00046097];
xxvii) The status report, dated 21 March 2012 [POL00057528];
xxviii) The Schedule of Non-Sensitive Unused Material, dated 14 May 2012
[POL00057752);
xxix) The letter from Cartwright King, dated 22 May 2012 [POL00057796];
xxx) The brief to prosecution counsel, dated 2 July 2012 [POL00058081];
xxxi) The handwritten note outlining the false accounting charge [POL00046095);
xxxii) The attendance note, dated 30 July 2012 [POL00058132);
xxxiii) The basis of plea [POL00046096]; and
Page 35 of 51
WITN08300100
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xxxiv) The attendance note, dated 24 August 2012 [POL00058236].
128. I have no recollection of this case, but it appears that it was allocated to me,
and relates to an audit shortage at Rowlands Castle PO branch in 2011. My role
would have been to conduct an investigation into the audit shortage.
129. I am unable to say whose decision it was to conduct an audit at this branch, but
from the documentation, it appears that this was requested due to the postmaster
being asked to return £30,000 but they only sent back £14,000.
130. I do not believe that I would have had any involvement in the audit at Rowlands
Castle PO on 30 March 2011. I have no recollection, but do not believe that I was
present during the audit, so if this was the case, then I would not have had any
discussion with Ms Hutchings at that PO branch.
131. 1am unable to describe the circumstances relating to the suspension of Ms
Hutchings as this would have been dealt with by someone from the retail line. It
would appear from the auditor's report that Mr Nigel Allen, PO Contracts Advisor
dealt with the suspension.
132. I have no recollection of what enquiries may have been conducted before the
decision to suspend Ms Hutchings was made.
133. As mentioned above, I have no recollection of this case, but from my offender
report, I can see that I obtained details of overnight cash holdings (ONCH),
remittances and details of 4 call log entries from the Cash Management Team. I can
see that I obtained a copy of the audit report and some accounting documentation
pertaining to Rowlands Castle PO.
134. I have been asked to consider [POL00046607] and the Record of Tape
Page 36 of 51
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Recorded Interview dated 20 April 2011 at [POL00056417] (part 1), [POL00044505]
(part 2), [POL00046625] (part 3) and the statement at [POL00056420], and to
address the following;
ii) Who made the decision to interview Ms Hutchings?
iii) What pre-interview disclosure (if any) was provided to Ms Hutchings?
iii) What was your role during the interviews?
135. My response to the above, is that from the documentation, I can see that this
case was allocated to me for investigation and as part of this, it would be normal
practice to conduct interviews. As such, I can see that I have written to Ms
Hutchings, inviting her to an interview and explaining her rights. I can see from my
offender report [POL00046706] that disclosure was made to Ms Hutchings’ legal
representative prior to the interview. Although I cannot recall what items were
disclosed, it would most likely have been some accounting documentation relating to
Rowlands Castle PO as well as verbal disclosure relating to the audit shortage. As
the Security Manager that was allocated the case, it would have been my role to lead
on the interview.
136. I have no recollection as to what enquiries I made as part of this investigation
but from the offender report I can see that I obtained a copy of the audit report, a
schedule of overnight cash holdings (of which I produced a schedule), cash
remittances and a log of calls made to Rowlands Castle PO by the Cash
Management Team. I also received from Nigel Allen, Contracts Advisor, some
Branch Trading Statements and Horizon printouts, which I understand were sent to
him by the auditor. I can see that I was made aware of 2 pending errors in relation to
Cheques remitted out and can see from the report that I accessed Credence and it
appeared to me that these were genuine errors. I also obtained a schedule of call
logs made to the POL Helpdesk from Rowlands Castle PO. Following the interview,
Ms Hutchings was given some bank disclosure forms and was asked if she was
prepared to grant authority for me to request copies of her bank statements. It is
Page 37 of 51
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unclear whether these were ever signed and returned to me, as in my offender
report, I state that these are still outstanding. I have no recollection of the sources of
evidence that I would have considered, and what I have referred to above is based
on details within the offender report.
137. As far as I am aware, the only legal advice that would have been obtained,
would have been from the Criminal Law Team in relation to any charges, further
enquiries requested and in relation to the prosecution. I would not have been
involved in the decision to charge Ms Hutchings nor with the decision to authorise
the prosecution. The Criminal Law Team would advise on the sufficiency of the
evidence and if appropriate, formulate charges. The decision on whether to
prosecute or not, would be made by a senior security manager. I cannot recall any
discussions that I may have had with counsel or POL’s legal representatives in
respect of this case.
138. Regarding disclosure, the Security Manager would submit the case papers to
the Criminal Law Team, including the offender report and any additional reports and
memos. If a case was committed to the crown court, then the Security Manager
would prepare a committal bundle (copies of evidence, statements and Unused
Material) and submit this to the Criminal Law Team, who would then deal with any
disclosure to the Defence. I have no recollection of any disclosure requests made by
the Defence, or what POL’s response may have been.
139. On 21 March 2012, this case was transferred to Steve Bradshaw, Security
Manager as I was moving to a new role within the Network Transformation Team in
POL.
140. I cannot recall what I, or anyone else involved in the proceedings may have
considered in respect of disclosure from third parties e.g Fujitsu. I can see from the
documentation that Andrew Dunks (Fujitsu) provided a statement, in which he refers
Page 38 of 51
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to a number of calls to the HSH from Rowlands Castle PO. The request is to cover
the period from 01/10/2010 — 30/03/2011. It appears that this was at the request of
the Criminal Law Team. This request would have been submitted to Fujitsu by the
POL security admin team that dealt with all requests to Fujitsu for Horizon data, HSH
call logs and statements. I cannot recall what this admin team was called. I cannot
see from the documentation, but it is likely that I would have been the one to forward
the Criminal Law Team's request for a schedule of calls to HSH over this period, to
be produced in a statement from Fujitsu.
141.1 do not recall that I would have had any involvement in considering Ms
Hutchings’ basis of plea, and believe that Mr Bradshaw would be dealing with the
case at that stage. I do not recall having any further involvement in this case, after it
was transferred to Mr Bradshaw.
142. I have been asked for my reflections now on the way the investigation and
prosecution of Lynette Hutchings was conducted by the Post Office and the outcome
of the case and that I may wish to consider the judgment of the Court of Appeal in
Josephine Hamilton & Others v Post Office Limited [2021] EWCA Crim 577 at
[POL001 13278] (and in particular at paragraphs 75, 91, 198 to 209).
143. As mentioned in paragraphs 114 & 126 above, I was not aware of any
reference to ‘bugs, errors or defects’ relating to the integrity of Horizon at that time.
POL had always instilled in us that the Horizon system was robust.
General
144. I have been asked to what extent (if any) did I consider a challenge to the
integrity of Horizon in one case to be relevant to other ongoing or future cases:
My response is that I have no recollection of any specific challenges to the Integrity
of Horizon. My understanding from the documentation provided is that if a challenge
was made by the Defence then this would be referred to Fujitsu to give a view, and
Page 39 of 51
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to provide a statement and asked to rebut anything, if indeed they were able to. I
cannot recall any instances where any challenge to Horizon was upheld by the court.
Statement of Truth
I believe the content of this statement to be true.
Signed: -
Dated: 30/10/23.
Page 40 of 51
Index to First Witness Statement of Graham David Brander
WITN08300100
WITN08300100
No.
URN
Document Description
Control Number
1
POL00104747
Investigation Policy: Casework
Management (England & Wales)
v1.0
POL-0080387
POL00104777
Investigation Policy: Casework
Management (England & Wales)
v4.0
POL-0080417
POL00104754
Investigation Policy: Rules &
Standards v2.0
POL-0080394
POL00030687
Investigation Policy - Investigation
Procedures v2 January 2001
POL-0027169
POL00104762
Investigation Policy: Disclosure of
Unused Material, Criminal
Procedures and Investigations Act
1996 Codes of Practice v0.1
POL-0080402
POL00030578
$02 Royal Mail Group Criminal
Investigation and Prosecution
Policy December 2007
POL-0027060
POL00104812
Royal Mail Group Ltd Criminal
Investigation and Prosecution
Policy
POL-0080444
POL00104806
Royal Mail Group Security —
Procedures and Standards:
Standards of behaviour and
complaints procedure No.10-X v2
POL-0080438
POL00031003
Royal Mail Group Crime and
Investigation Policy v1.1 October
2009
POL-0027485
10
POL00030580
Post Office Ltd - Security Policy:
Fraud Investigation and
Prosecution Policy v2
POL-0027062
11
POL00030579
Post Office Ltd Financial
Investigation Policy, May 2010
POL-0027061
12
POL00026573
RMG Procedures & Standards -
Proceeds of Crime Act 2002 &
Financial Investigations doc 9.1 V1
POL-0023214
13
POL00104857
Royal Mail Group Security
Procedures & Standards: Initiating
Investigations doc 2.1
POL-0080489
14
POL00031008
RMG Ltd Criminal Investigation
and Prosecution Policy v1.1
November 2010
POL-0027490
15
POL00104853
Post Office's Financial
Investigation Policy
POL-0080485
16
POL00104855
Post Office Ltd. Anti-Fraud Policy
POL-0080487
Page 41 of 51
WITN08300100
WITN08300100
17
POL00030786
Royal Mail Group Policy - Crime
and Investigation (S2) v3 effective
from April 2011, owner Tony
Marsh, Group Security Director
POL-0027268
18
POL00105229
Post Office Ltd PNC Security
Operating Procedures
POL-0080854
19
POL00104929
Post Office Limited: Internal
Protocol for Criminal Investigation
and Enforcement (with flowchart)"
POL-0080561
20
POL00105226
Undated Appendix 1 - POL
Criminal Investigations and
Enforcement Procedure (flowchart)
POL-0080851
21
POL00104968
POL - Enforcement and
Prosecution Policy (with
comments)
POL-0080600
22
POL00030602
POL: Criminal Enforcement and
Prosecution Policy
POL-0027084
23
POL00031005
Conduct of Criminal Investigations
Policy - version 0.2
POL-0027487
24
POL00027863
Conduct of Criminal Investigations
Policy v0.3
POL-0024504
25
POL00030902
Final Draft of the Post Office
Conduct of Criminal Investigation
Policy
POL-0027384
26
POL00104821
Condensed Guide for Audit
Attendance v2
POL-0080453
27
POL00118096
Email from Andrew Wise to
Michael Stanway forwarding an
email re Casework Compliance
VIS00012685
28
POL00118108
Appendix 1 - Case Compliance
checklist. Undated (date taken
from parent email)
VIS00012697
29
POL00118109
Appendix 2 - File construction and
Appendixes A, B and C:
"Compliance Guide: Preparation
and Layout of Investigation Red
Label Case Files" Undated - date
taken from parent email
VIS00012698
30
POL00118101
Appendix 3 - Offender reports and
Discipline reports: Compliance
Guide to the Preparation and
Layout of Investigation Red Label
Case Files - undated (date taken
from parent email)
VIS00012690
31
POL00118102
Appendix 4 - Offender reports
layout: "POL template Offender
Report (Legal Investigation)" -
undated (date taken from parent
email)
VIS00012691
Page 42 of 51
WITN08300100
WITN08300100
32
POL00118103
Appendix 5 - Discipline reports
layout: "POL template Offender
Report (Personnel Investigation)" -
undated (date taken from parent
email)
VIS00012692
33
POL00118104
Appendix 6 - Identification codes
(undated - date taken from parent
email)
VIS00012693
34
POL00118105
Appendix 7 - Tape Interviews.
"POL Security Operations Team
guide: Summarising of Tape
Recorded Interviews." Undated -
date taken from parent email
VIS00012694
35
POL00118106
Appendix 8 - Notebooks: Guidance
on using notebooks in
investigations. Undated (date
taken from parent email)
VIS00012695
36
POL00118107
Appendix 9 - Case Progression
Toolkit. Undated (date taken from
parent email)
VIS00012696
37
FUJ00153133
Seema Misra Criminal Case Study:
Email chain from Penny Thomas to
John Longman re: Duplication of
Transaction Records in ARQ
Returns
POINQ0159328F
38
FUJ00125911
Email chain from Thomas Penny to
Mark Dinsdale re: Horizon/Post
Office Systems
POINQ0132125F
39
FUJ00154911
Email from Jane M Owen to Andy
Dunks Re: Fujitsu Statement
POLTD/0809/560-568
POINQ0161106F
40
FUJ00154925
Email from Mark Dinsdale to Penny
Thomas re: Fujitsu Information —
Bufferey
POINQ0161120F
41
FUJ00156494
Email from Bains Rajbinder to
Thomas Penny RE ARQ Retrieval
Data
POINQ0162688F
42
FUJ00156530
Email from Gareth Jenkins to
Thomas Penny RE RM v Bramwell
POINQ0162724F
43
FUJ00156536
Email from Penny Thomas to
Gareth Jenkins RE FW RM V
Bramwell
POINQ0162730F
44
FUJ00154903
Email from Jane M Owen to Andy
Dunks, Thomas Penny and Mark
Dinsdale re Fujitsu statement
POLTD/0809/560-568
POINQ0161098F
45
FUJ00155009
Email from Graham Brander to
Andy Dunks, CSPOA Security,
Penny Thomas and others re: RE:
POINQ0161204F
Page 43 of 51
WITN08300100
WITN08300100
Swiss cottage Fujitsu Statements -
urgent please
46
FUJ00225238
Email chain from Penny Thomas to
Jane Owen re: ARQ Retrieval Data
POINQ0231355F
47
POL00067205
Email from Adrian Skinner to
Elaine Ridge, cc Nigel Allen, Area
Intervention Office and others re:
South Warnborough 0929042 (Jo
Hamilton case study)
POL-0063684
48
POL00044497
Letter from Alan Stuart to Nigel
Allen re: Audit of Post Office South
Warnborough branch
POL-0040976
49
POL00047137
Letter from Graham Brander to Mrs
Hamilton, Re: investigations
POL-0043616
50
POL00118743
Josephine Hamilton Criminal Case
Study: Letter from Graham Brander
to Josephine Hamilton re: invite for
a formal interview
POL-0118662
51
POL00118769
Josephine Hamilton case study.
Memo from Graham Brander to
Ged Harbinson regarding progress
of the case.
POL-0118688
52
POL00044477
Josephine Hamilton record of tape
recorded interview
POL-0040956
53
POL00045409
Record of Tape Recorded
Interview: Part 2 - Josephine
Hamilton interviewed by Graham
Brander
POL-0041888
54
POL00044389
Post Office Ltd Investigation report
for Josephine Hamilton -
POLTD/0506/0685 (Prepared by
Graham Brander, Investigation
Manager)
POL-0040868
55
POL00047955
Josephine Hamilton Offences
Report
POL-0044434
56
UKGI00001504
Josephine Hamilton case study -
Suspect Offender Reporting re:
Josephine Hamilton
UKG1I012318-001
57
POL00044470
Josephine Hamilton Case Study -
Financial investigation events log -
case number: POLTD/0506/0685
POL-0040949
58
POL00064288
Memo from Graham Brander RE
Notification of the commencement
of investigation into Jo Hamilton
POL-0060767
59
POL00118739
Josephine Hamilton case study.
Letter from Graham Brander to
Alliance & Leicester Commercial
Bank re: Requesting disclosure of
POL-0118658
Page 44 of 51
WITN08300100
WITN08300100
Josephine Hamilton's bank
statements
60
POL00048035
Josephine Hamilton case study:
Memo from Julie MacFarlane to
POL Investigation team and
Graham Brander
POL-0044514
61
POL00118745
Letter from Graham Brander to
Nationwide Building Society re.
disclosure of bank details re: J
Hamilton.
POL-0118664
62
POL00048223
Letter from Graham Brander to
Josephine Hamilton re Bank
Authority Disclosures.
POL-0044702
63
POL00118610
Memo from Graham Brander to
Juliet McFarlane Re Hamilton
POLTD/0506/0685
POL-0118529
64
POL00048205
Memo from Julie MacFarlane to
POL Investigation team - Advice on
Prospect of success of conviction J
Hamilton — Unsigned
POL-0044684
65
POL00118760
Josephine Hamilton case study.
Letter from Graham Brander to
North East Hampshire Magistrates
Court with attachments
POL-0118679
66
POL00118761
Josephine Hamilton criminal case
study: Summons for Josephine
Hamilton
POL-0118680
67
POL00048252
Memo from Graham Brander to
Julie MacFarlane re Confirmation
summons served on Josephine
Hamilton
POL-0044731
68
POL00048269
Jo Hamilton Case Study:
Memorandum from Juliet
McFarlane to Investigation Team
Post Office Limited cc Graham
Brander and Press Office. Re:
"Royal Mail Group plc v Josephine
Hamilton Aldershot Magistrates
Court - 6th December 2006 at
10am".
POL-0044748
69
POL00118768
Letter from Graham Brander (Post
Office) to Tanner & Taylor
Solicitors regarding a copy of the
interview tapes - Josephine
Hamilton case study
POL-0118687
70
POL00118762
Josephine Hamilton case study:
Information on Hearing,
Magistrates Courts
POL-0118681
71
POL00044484
Post Office Witness Statement -
Graham Brander
POL-0040963
Page 45 of 51
WITN08300100
WITN08300100
72
POL00044481
Post Office Witness Statement of
Penelope Anne Thomas
POL-0040960
73
POL00118754
Josephine Hamilton case study.
Memo from Graham Brander to
Juliet McFarlane regarding
committal papers
POL-0118673
74
POL00048473
Jo Hamilton Case Study: Memo
from J McFarlane to G Brander
and G Harbinson - Update on
Committal papers J Hamilton
POL-0044952
75
POL00118650
Memo from Juliet McFarlane to
Investigation Team Post Office
Limited CC Graham Brander re R v
Josephine Hamilton - Plea and
Case Management Hearing & non-
sensitive unused schedule.
POL-0118569
76
POL00064257
Josephine Hamilton case study:
Witness Statement Graham
Brander
POL-0060736
77
POL00118758
Josephine Hamilton case study.
Letter from Graham Brander to
Juliet McFarlane re: Josephine
Hamilton (POLTD/0506/0685) -
Additional Witness Statements
POL-0118677
78
POL00091018
Memo from Royal Mail Legal
Services to Post Office Security
ccing Christopher Knight re:
Regina v Alison Loraine Hall -
Leeds Crown Court - Plea and
Case Management Hearing - 30th
June 2011 at 9:30am. Case No:
POLTD/1011/0095
POL-0090662
79
POL00048558
Memo from J Andrews to POL
Investigation Team and G Brander,
RE: Update on Directions (R v.
Hamilton)
POL-0045037
80
POL00118619
Memo from Phil Taylor to
Investigation Team Post Office
Limited CC Graham Brander re: R
v Josephine Hamilton - Trial - 10th
September 2007
POL-0118538
81
POL00119068
Josephine Hamilton Case Study:
Memo from Juliet McFarlane to
POL Investigation Team cc
Graham Brander Re: Regina v
Josephine Hamilton Winchester
Crown Court Mention-25th May
2007 Trial-10th September 2007
Case No:POLTD/0506/0685
POL-0118987
Page 46 of 51
WITN08300100
WITN08300100
82
POL00118641
Memo from Juliet McFarlane to
Investigation Team Post Office
Limited c.c. Graham Brander and
Press Office re R v Josephine
Hamilton
POL-0118560
83
POL00048761
Memo from Ms Juliet McFarlane to
POL Investigation Team and
Graham Brander re: Regina v
Josephine Hamilton Winchester
Crown Court Trial - 10th
September (POLTD/0506/0685)
POL-004524 0
84
POL00118868
Memo of the Investigation Team
Post Office Limited, in the Regina
v Josephine Hamilton, in the
Winchester Crown Court. Court
Trial 10/09/2007. Responses made
to the points made CASE NO:
POLTD/0506/0685
POL-0118787
85
POL00048766
Memo by Juliet McFarlane to
Investigation Team Post Office
Limited and Graham Brander re
Regina v Josephine Hamilton.
POLTD/0506/0685.
POL-0045245
86
POL00064258
Josephine Hamilton case study:
Witness Statement of Graham
Brander
POL-0060737
87
POL00048905
Memo from G Brander to J
McFarlane — Jo Hamilton - list of
additional statements
POL-0045384
88
POL00049154
Josephine Hamilton Case Study:
Memo from Juliet McFarlane to
POL Investigation Team and
others re: Regina v Josephine
Hamilton (South Warnborough)
Winchester Crown Court Mention -
19th November 2007
(POLTD/0506/0685)
POL-0045633
89
POL00044388
Josephine Hamilton case study:
Memorandum from Miss J A
McFarlane to Investigation Team
Post Office Limited, cc Graham
Brander, Ged Harbinson and Dave
Pardoe RE: R v Josephine
Hamilton mentions hearing
19/11/2007 - update after hearing
POL-0040867
90
POL00048533
Criminal indictment for Josephine
Hamilton
POL-0045012
91
POL00126356
Josephine Hamilton Criminal Case
Study: Bundle of documents re:
Regina v Josephine Hamilton
POL-0132433
Page 47 of 51
WITN08300100
WITN08300100
including Case Opening statement
and Memo from Graham Brander
to Juliet McFarlane dated
11/08/2006 re Audit report of South
Warnborough PO branch.
92
POL00118756
Josephine Hamilton case study.
Witness list for R v Josephine
Hamilton
POL-0118675
93
POL00118757
Josephine Hamilton case study -
List of exhibits
POL-0118676
94
POL00118755
Josephine Hamilton criminal case
study. Schedule of non-sensitive
unused material signed by Graham
Brander
POL-0118674
95
POL00118858
Criminal case study of Josephine
Hamilton: Royal Mail Memo from
Phil Taylor to Investigation Team
POL, cc Graham Brander and
Press Office re: R v Josephine
Hamilton- Contains charges and
sentences
POL-0118777
96
POL00057745
Jo Hamilton Case Study: Email
from Graham Brander to Nigel
Allen, Geb Harrison, Colin Price
and others re Case Closure
Reporting
POL-0054224
97
POL00048913
Email from Graham Brander to
Juliet McFarlane, Dave Posnett
and Investigation Team Post Office
re Josephine Hamilton.
POLTD/0506/0685.
POL-0045392
98
POL00049083
Email from Graham Brander to
Jennifer Andrews, Juliet
McFarlane, Dave Pardoe and
others re: Fw: Hamilton
POL-0045562
99
POL00048471
Jo Hamilton case study - Email
from Jennifer Andrews to Graham
Brander re Josephine Hamilton
POL-0044950
100
POL00113278
Approved Judgment between
Josephine Hamilton & Others and
Post Office Limited
POL-0110657
101
POL00050140
Transcript: Record of tape
interview in re to Julian Wilson
dated 15/09/2008
POL-0046619
102
POL00050128
Transcript: Record of tape
recorded interview in re to Julian
Wilson.
POL-0046607
103
POL00044806
Julian Wilson case study: Memo
from Jarnail Singh to the Fraud
POL-0041285
Page 48 of 51
WITN08300100
WITN08300100
Team Post Office Ltd re: POL v
Julian Wilson (Astwood Bank)
104
POL00047083
Julian Wilson Case Study: Post
Office Limited V Julian Wilson -
Schedule of Charges
POL-0043562
105
POL00044767
Summary of facts re: Royal Mail
Group Ltd v Julian Wilson
POL-0041246
106
POL00044749
Financial investigation events log -
Case number: 0809/126 Gary
Thomas - Astwood Bank/ Julian
Wilson
POL-0041228
107
POL00118275
Compliance Team - Event Capture
Form for Mr Julian Wilson
POL-0118417
108
POL00046065
Statement for Rowlands Castle -
Lynette Hutchings
POL-0042544
109
POL00056292
Audit Report of Rowlands Castle
Post Office 2011
POL-0052771
110
POL00056417
Lynette Hutchings Case Study :
Record of Taped Interview of
Lynette Hutchings dated
20/04/2011
POL-0052896
111
POL00044505
Record of Taped Interview with
Lynette Hutchings
POL-0040984
112
POL00046625
Transcript: Record of taped
interview re Lynette Hutchings
dated 20/04/2011
POL-0043104
113
POL00056420
Handwritten statement on behalf of
Lynette Jane Hutchings
POL-0052899
114
POL00067173
Lynette Hutchings case study:
Letter sent from Nigel Allen to Mrs
L K Hutchings re: SPMs
Suspension
POL-0063652
115
POL00046704
Antecedents in re to Lynette Jane
Hutchings
POL-0043183
116
POL00046706
Investigation report by Graham
Brander - Subpostmaster Lynette
Jane Hutchings.
POL-0043185
117
POL00044508
Post Office Ltd Investigation report
for Lynette Jane Hutchings
(prepared by Graham Brander)
POL-0040987
118
POL00066754
Incident Activity Report for
November 2007
POL-0063233
119
POL00046626
Memo from Jarnail Singh to
Maureen Moors and Graham
Brander in re to Post office LTD v
Lynette Jane Hutchings
POL-0043105
120
POL00056585
Audit Record Query, Rowlands
Castle Post Office
POL-0053064
Page 49 of 51
WITN08300100
WITN08300100
121
POLO0056694
Audit Record Query, Rowlands
Castle Post Office
POL-0053173
122
POL00046627
Internal Post Office memo from
Maureen Moors (Fraud Team) to
Graham Brander (Fraud Advisor)
re Lynette Hutchings (Rowlands
Castle Post Office) - Request for
further evidence from the Royal
Mail Group Criminal Law Team
POL-0043106
123
POL00046088
Memo from Maureen Moors to
RMG criminal law team re Fraud
and prosecution to be pursued
POL-0042567
124
POL00046615
Lynette Hutchings case study:
Witness Statement of Andrew Paul
Dunks
POL-0043094
125
POL00056742
Witness Statement for Gary
Thomas, Post Office Ltd
POL-0053221
126
POL00046637
Lynette Hutchings case study:
unsigned witness statement of
Adam Shaw
POL-0043116
127
UKGI00014819
Lynette Huthcings case study:
Royal Mail Group, draft witness
statement for Nigel Allen
UKG1I025612-001
128
POL00057230
Lynette Hutchings Case Study:
Louis Sheridan Witness Statement
POL-0053709
129
POL00063481_
008
Graham Bender Witness
Statement - Rowlands PO
prosecution, information on
Brander's investigation and
analysis of Horizon. Unsigned and
incomplete
POL-
0059960_008
130
POL00046628
Memo from Graham Brander to
Jarnail Singh in re to Ms
Hutchings.
POL-0043107
131
POL00057362
Lynette Hutchings Case Study:
POL v Lynette Jane Hutchings —
Advice
POL-0053841
132
POL00046097
Indictment - Regina v Lynette Jane
Hutchings - Hutchings charged
with fraud
POL-0042576
133
POL00057528
Interim/Current Status Report -
Lynette Hutchings 2012
POL-0054007
134
POL00057752
Unused material schedule -
Lynette Jane Hutchings
POL-0054231
135
POL00057796
Letter from Cartwright King to
Messrs. Coomber Rich re: Post
Office Ltd v Lynette Jane
Hutchings (Portsmouth Magistrates
Court on 06/06/2012)
POL-0054275
Page 50 of 51
WITN08300100
WITN08300100
136_I POL00058081 Post Office Ltd v Lynette Hutchings I POL-0054560
137 I POL00046095 Handwritten note on Regina v POL-0042574
Lynette Jane Hutchings
138 I POL00058132 Lynette Hutchings case study: POL-0054611
Court attendance note of William
Martin Counsel for Claimant
139 I POLO0046096 Handwritten notes on Regina v POL-0042575
Lynette Jane Hutchings: basis of
plea
140 I POL00058236 I Lynette Hutchings Case study: POL-0054715
Attendance note by William Martin
141 I POL00046607 I Letter from Graham Brander to Mrs
Hutchings re: invitation for
interview re audit deficiency
POL-0043086
Page 51 of 51