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Witness name: Linda McLaughlin
Statement No: WITN08480100
Dated: 28 December 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF LINDA MCLAUGHLIN
I, LINDA MCLAUGHLIN, 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 28 November
2023 (the "Request’).
2.1 can confirm I was assisted by the Post Office Limited ("POL") in confirming
insurance coverage for support in preparing my statement. I have also been
assisted by DAC Beachcroft LLP in the preparation and drafting of my
statement.
Background
3.1 am a former employee of POL. I joined POL on 2 February 1987 having
previously worked in a Sub-Post Office as a Sub-Office Assistant for
approximately 4 years. I was recruited following an entrance exam and a
face-to-face interview. My previous experience working in a Sub-Post Office
meant that when I joined POL I already had transaction experience. As part
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of my induction I attended a 1-week training course that was bespoke for Sub-
Office Assistants. This was shorter than the normal induction due to my
experience working in a Sub-Post Office.
4. Following my induction, I worked on the counter within the Crown Office
Network for approximately 3 years. During this time I worked mostly in
Belfast Post Office but also provided cover in Bangor Post Office and
Shaftesbury Square Post Office. This role was as a Postal Officer grade
performing counter duties.
5. In around 1990/91 I moved to the Belfast Audit Team where I worked as an
Auditor. I initially worked in the team on a temporary basis providing cover for
annual leave before I moved into a permanent role. This role was again a
Postal Officer grade.
6. I spent the majority of my career working as an Auditor and although the job
title changed through various reorganisations the role remained relatively the
same. I did receive several promotions during this time and also moved into
a training role when a reorganisation brought the Training and Audit Team
together. I cannot recall the exact dates when I changed roles, but I have
contacted the POL HR team who have assisted with some of the dates. I
have listed below the specific roles I had during this time and a brief
explanation of each role:
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. 1991 to 1996 (approx.) — Auditor/Network Auditor — Responsible for
conducting asset verification and compliance audits at Post Office
Branches as determined by the audit schedule.
. 1996 (approx.) — Retail Network Manager — This was a temporary
position covering maternity leave. I was the point of contact for a
section of Post Offices in Northern Ireland. After 9 months I returned to
my substantive Audit role which I held until 2002.
. April 2002 to July 2002 — Performance Advisor — I was promoted to a
CM3 grade and was responsible for approximately 80 Community
Offices in Northern Ireland.
. 2002 — mid-2010 — Senior Auditor (CM3 grade) — I was responsible for
assisting and leading asset verification and compliance audits at Post
Office branches as determined by the audit schedule.
. Mid-2010 — Dec-2010 — Field Support Team Leader (Grade 2A) -.
Responsible for Auditors in Northern Ireland. I also had responsibility
for Auditors in other geographical areas during this time including
Liverpool, Manchester, Glasgow and Edinburgh. I still actively
completed audits in addition to having line management responsibility.
Jan 2011 — Audit and Training Team Leader (Grade 2A) — Following a
reorganisation a new team was created based in Northern Ireland and
Scotland which amalgamated the previous Audit Team and Training
Team. I was responsible for the delivery of the audit and training
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programme to branches. This was mostly a line management role
which I recall was for a team of approx. 10 to 12 people. Duties
included Quality Assurance Reviews for Audit activity and onsite visits
at branches during a Subpostmaster's initial training. My job title
reverted back to Field Team Leader in October 2012.
g. October 2012 (approx.) — Area Manager (Grade 3B) — This was a
unique role in Northern Ireland. The role was essentially Field Team
Leader but also provided additional capacity during the Network
Transformation programme.
7. I left POL in October 2016.
8. The Inquiry has asked about my role in relation to disciplinary matters. As an
Auditor I did not get involved in any branch disciplinary matters. Disciplinary
issues or concerns that were highlighted at a Sub-Post Office audit would be
escalated to the Retail Network Manager or the Contract Manager (these titles
changes during the years) for action. For Crown Offices this would be the
Crown Area Manager. My only role would be in providing information to the
relevant persons following an audit, but I would not be involved in any
discussions or decisions regarding disciplinary action.
9. The Inquiry has asked me about any involvement I had in interviewing those
accused of a criminal offence and my role in litigation case strategy. I cannot
recall any involvement I had in either area. From memory I would expect
interviewing to be conducted by the Security and Investigation Team. I have
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no recollection of litigation case strategy and do not know what was required
by POL in this respect or who was responsible for it.
10. The Inquiry has asked me about my role in disclosure in criminal and civil
proceedings. I! am not sure what is meant by disclosure and I do not recall
having any involvement in disclosure during my time at POL. I do recall I was
asked to make statements following an audit which I understand were for the
purpose of criminal proceedings. I was also sometimes asked to provide
documents to other POL teams, for example the Investigation Team or
Contracts Manager may request a copy of an audit report.
1
a
. The Inquiry has asked me what role I had in liaising with other POL
departments in respect of the progress of cases. I would liaise with other
teams as part of my role within the Audit Team. In particular I would liaise
with the Security and Investigations Team who may have an interest in the
result of an audit and require a statement from me for their investigation. I
would also liaise with Contract Advisors and provide them with details of the
audit and the audit report as requested. I There may be other teams that
would ask for similar information, but I can no longer recall any specific
details.
The Audit Process and the Polices/Practices in place
12. As noted above, my role changes during my time in the Audit team and at
various times I held the job title of Auditor, Senior Auditor, Audit Manager and
Field Team Leader. During an audit my role would either involve assisting or
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leading an audit of a Post Office branch. In essence the process would
involve ascertaining what assets were held at the branch and comparing this
to the reported cash, stock and vouchers. The Auditors would also complete
a series of compliance checks to ensure that the Post Office procedures were
being adhered to.
13. Whilst there were a number of processes and policies in place, I can no
longer recall their details or when they changed. I do recall that when I first
joined the Audit Team there was a manual system in place which later
changed to a computerised system with the implementation of Horizon. The
processes followed by the Auditors were updated to reflect this new practice.
Recruitment and Training of Auditors
14. The Inquiry has asked me to consider the following documents:
a. “Assurance Review - Recruitment (Vetting & Training)” (version 1.0, 27
October 2009) (POL00032698);
b. “Network auditing approach, methods and assurance” (2013)
(POL00086765);
c. “Training & Audit Advisor” (undated) (POL00088453);
d. “Audit Advisor” (undated) (POL00088557).
15. In regard to the Assurance Review (POL00032698), I do not recall seeing this
document previously. I also do not recall the document “Network auditing
approach, methods and assurance” (POL00086765). They may have been
considered by Senior Management rather than my grade. I do not recall ever
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being involved in the external recruitment process and I believe this would
have been completed by the HR Team.
16. The other two documents, POL Training & Audit Advisor’ (undated)
(POL00088453) and “Audit Advisor” (undated) (POL00088557) are both job
adverts. I do not recall seeing these documents previously, but the contents
look to describe the key elements of each role.
17. From what I can recall Auditors tended to be recruited internally following an
internal job advert. From memory it was usually Postal Officers who worked
in Crown Offices that were recruited to the roles. There was no specific audit
qualification required but a working knowledge of POL transactions and
procedures would be listed as a requirement on the job advert.
18. When in the role an Auditor would receive training in various forms. New
Auditors would initially shadow other team members and would be allocated a
buddy to support their development. I remember when I was a line manager
I would develop a training plan for a new team member which would introduce
them to different aspects of the role and allow me to monitor their progress
and ability to complete each task.
19. Auditors would receive further training as significant changes were
introduced. For example, when car tax moved from a paper based to
computerised system specific training was received. This training could take
different forms depending on the requirements and included classroom
training, workbooks, videos and various policy and process documents. I do
not recall any refresher training that was provided to Auditors and the
fundamental process remained relatively the same. I recall that when Horizon
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was introduced the Auditors were provided with specific training. I do not
recall the exact details but from memory there were two courses rolled out
across the business. There was a 1-day course for individuals working on the
counter and a 2/3 day course for individuals with back-office responsibilities.
The Auditors would have attended the longer course.
20. The Inquiry has asked me if I considered then and now whether the Auditors
had the necessary training and experience during my time at POL. I do not
have any concerns and believe the Auditors had the necessary training and
experience for the requirements of the role.
The Planning and Scheduling of Audits
21.1 remember there were a number of different types of audits. This included
planned audits, for example, where a branch was closing or transferring to a
new Subpostmaster, and unplanned audits, for example, where there had
been a robbery or burglary, or the Investigation team required an audit of a
specific branch. These types of audits remained relatively consistent during
my time in the team.
22. However, I can recall that the way in which other audits were scheduled
changed during my time in the Audit Team. When I started in the team
branches were audited on a calendar-based system. This meant each branch
would be audited on a set frequency which would be determined by their size,
products and how busy they were. Under this system some branches may
be audited annually whereas others would be every two years.
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23. I can see from the document Audit Plan & Scheduling, Chapter 1 of the Audit
Process Manual” (Version 8.0) (2010) (POL00084650) that the method of
planning changed in May 2004 when the Financial Branch Performance
Profile was introduced. This was a risk-based system which meant branches
would be audited based on their risk rating, which took into consideration
specific factors, rather than a set schedule.
24. By the time I left in 2016 I can remember the risk-based audits involved two
parts:
a. A Financial Assurance Audit (FAA) — This was an audit of all cash,
selected stock items and vouchers which would be counted by the
Auditor. If this showed any discrepancies the audit could be upgraded
to a Tier 2 audit which would include all stock items.
b. A Compliance Audit — This would check the branches compliance with
the Post Office procedures and following up on any gaps from previous
audits.
25. How an audit was scheduled depended on the type of audit that was
required. Audits for transfers and closures of Post Offices were scheduled in
advance with the agreement of the incoming/outgoing Subpostmaster.
Special audits were usually instigated by the Security and Investigation Team
and would be arranged for a specific date. Risk audits were determined
based on the availability and resources in the Audit Team. Compliance
audits and follow up audits would usually be completed as a second audit of
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the day. All audits would be scheduled as soon as it was operationally
possible.
26. The frequency a branch would be audited would be dependent on the type of
audit and the performance of the branch, i.e., the number of error notices,
transaction corrections, cash and stock holdings etc.
27. The Inquiry has asked me to describe any enquires or investigations that
were conducted before a branch visit. I cannot recall the exact details, but I
do remember that before a special audit there would be a pre-audit meeting to
make arrangements for the audit and to understand the reason for the audit.
There would also be a discussion on the previous audit results for the branch
in question.
28. The Inquiry has also asked me to describe any variation between the
scheduling of audits in respect of Crown Office branches and other branches
and to explain the reason for any differences. I do not recall if there were any
different scheduling criteria based on the different branches.
The Auditing Process
29.When completing an audit, I would consider specific information which
included the branches previous audit findings. I would also be able to access
specific information on the branch, for example, how much cash they were
holding. I believe an auditor could also access information on any
transactions corrections that were due. I recall there was a branch database
which Auditors could access to view this information. It would be important to
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view and understand this information to aid with the planning and preparation
of an audit. I recall this would have been the case for any audit and would
not have differed based on the type of branch.
30. If a discrepancy was discovered at an audit the Auditor would have an initial
conversation with the Subpostmaster or their staff to determine if any items
had not been produced and therefore still needed to be counted. I recall that
I would also check if any transaction corrections were due to be issued but I
cannot now recall who provided this information. Where a discrepancy was
over £1000 I would also report this to the Contract Advisor.
31. The Inquiry has asked me whether I was aware of a practice in which
Auditors asked Subpostmasters to make good discrepancies on the day of the
audit. From what I now recall if I was completing a transfer audit and a
discrepancy was found the Subpostmaster would be asked to make good the
discrepancy so the new Subpostmaster could start with a clear balance. I do
not recall asking a Subpostmaster to make good a shortage on other audits.
If there was a small shortage I believe I would have had a conversation with
them to make good the discrepancy on completion of their own balance/cash
account/branch trading statement. If there was a significant shortage I would
report this to the Contracts Manger or Crown Area Manager as would be the
process.
32. The Inquiry has asked me whether I was aware of Auditors being given
instructions on taking payments from Subpostmasters. I do not recall this
process, but I do recall that Auditors carried without prejudice receipts. In
some audits a Subpostmaster would request to make good the shortage.
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They would usually provide me with a cheque. In return I would provide a
without prejudice receipt. I believe this would be used in the event of a
Subpostmaster receiving a precautionary suspension due to a shortage where
they wrote a cheque for the discrepancy. I cannot recall the exact wording,
but I believe it explained that the cheque was accepted without prejudice to
any further action taken by POL.
33. The Inquiry has asked me whether, on discovery of a_ shortfall, the
Subpostmaster was able to and/or permitted to provide their own information
or undertake their own investigation. From memory I recall that when the
audit result was provided to the Subpostmaster they were offered the
opportunity to check the audit figures. I would expect any further
investigation on their part would be discussed with the Investigation Team.
34. During the course of an audit the Auditors would provide information to the
Subpostmaster. On arrival the Lead Auditor would discuss the type of audit
and would discuss how best to set up for the audit within the branch. They
would advise the Subpostmaster that all cash, stock and vouchers would
need to be produced and that the office could not open until permission was
provided. The Lead Auditor would also advise the Subpostmaster on the
completion of each stage of the audit, informing them when the financial
aspect was complete and then when the compliance checks had been
completed, reporting the results at each stage.
35. A closing meeting was held with the Subpostmaster where the audit findings
would be discussed. The Subpostmaster was given the opportunity to
discuss any concems and raise any issues. Where an issue was raised by
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the Subpostmaster it would be highlighted in the audit report, a hard copy of
which was posted to the branch a few days after the audit. The Contract
Advisor would receive a copy by email. A feedback form would be left for
completion at the end of the audit.
36. The Inquiry has asked me if it was possible to conduct a branch audit in
circumstances in which it was not possible to access the Horizon IT system. I
do not recall if this was possible, but I note from the document "Post Incident
Auditing without Horizon (POL00084003) that there is a process for auditing
branches without access to Horizon. I can remember one audit I was involved
in where a fire following an overnight burglary had damaged the Horizon
equipment. In this audit we attempted to construct a balance within Belfast
Cash Centre but could only count what was left and in the end we couldn't
really construct a full balance.
37. I have also been asked by the Inquiry to describe any variations between the
audit process in Crown Office branches in comparison to other branches and
the reasons for those differences. I recall that in a Crown Office branch a
minimum of 50% of stock was checked along with all dormant (non-assigned)
stock and any stock held by the Branch Manager. Also, in Crown Office
branches where there was a loss in excess of £1,000, this would be escalated
to the Crown Area Manager. A loss of £10,000 would also be escalated to the
Security Manager. For audits outside the Crown Network, depending on the
Audit Type, they would be subject to a Financial Assurance Audit, a Tier 2 or
a Compliance Audit as mentioned above. An audit shortage of £1000 or more
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would be escalated to the Contracts Advisor while the Auditors were still
onsite.
38. The Inquiry has asked me to consider two documents, the “Audit Trail
Functional Specification” (version 8.0, 18 October 2004) (FUJ00001894) and
Global User Account (September 2016) (POL00002841). I cannot recall
seeing these documents previously, but I do recall I had a Global User
Account issued to me. I cannot remember ever using it, but this may be
because I was usually the Assistant Auditor rather than the Lead Auditor who
would have taken on this responsibility. I As far as I can recall the Audit
Global User Account would allow an Auditor access to log onto the Horizon
system where they could be identified as a user. This would be used when
there was nobody in branch with "Manager Access" to Horizon and would
allow the reports to be sourced and printed. I do not recall the audit measures
that were in place but note that POL00002841 explains the process for who
would be given an account and the actions that were required. I cannot recall
this process from my time in the Audit Team.
39. The Inquiry has asked me what involvement Fujitsu had in the audit process.
I cannot recall any interactions with Fujitsu in the Audit process, and I am not
aware of any involvement they had in completing an Audit.
40. The Inquiry has also asked me whether Auditors had access to any
information which was not available to Subpostmasters. _I cannot recall
anything from memory although I do remember that at one point Auditors
were able to ring and check if any error notices or transaction corrections
were imminent which I do not believe was available to Subpostmasters.
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Audit and Investigation
41. The Rule 9 Request has asked me to consider the document "Condensed
Guide for Audit Attendance (version 2, October 2008) (POL00104821). I
understand from the Inquiry that the reference is incorrect and this should
refer to document POL00084813.
42. The Inquiry has asked me to consider the circumstances when an
Investigator would attend the audit of a branch and the role they had at an
audit. From memory I can recall that special audits were requested by the
Security team. An Investigator may attend but not always and it may be
sufficient for the Auditor to make them aware of the result or provide them
with a copy of the audit report.
43. There were occasions where an Investigator did attend the audit as part of
the investigation they were conducting. They would usually introduce
themselves to the Subpostmaster and explain why they had requested an
audit. The Investigator did not get involved in the audit and would usually
remain in the back office with the Subpostmaster. At the end of the Audit the
Lead Auditor would provide the results to the Investigator before the Auditors
left.
44. During my employment with POL, I worked with the Security Team in relation
to requests for special audits they had requested. They may have been onsite
during those special audits and they would also be my point of contact should
witness statements be required as part of their investigation. I would also
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have liaised with Security Team on an ad hoc basis with questions regarding
Security procedures and equipment.
Prosecution of Alan McLaughlin
45. The Inquiry has asked me to provide a full account of my involvement in and
recollection of the prosecution of Alan McLaughlin. The Inquiry has also asked
a number of specific questions in relation to Mr McLaughlin's prosecution. I
have endeavoured to answer these questions to the best of my knowledge
and have considered the documents provided to me by the Inquiry. However,
as the events are over 20 years ago, and I have not worked for POL for over 7
years, I do not recall these events clearly. I have provided as much
information as possible in order to assist the Inquiry.
46. As noted above, the Inquiry has provide seventeen documents relating to the
audit, prosecution and appeal of Mr McLaughlin. I have reviewed these
documents and considered them in my response. I note that the document
named "The audit report p.176 to p.188 — Appendix L (AMCL0000031) does
not appear to relate to the events of Mr McLaughlin's prosecution. This audit
report is provided to Mrs L Archer, not Mr McLaughlin. It is also dated 3
September 2004. The Interview Transcripts (AMCL0000014) are dated 26
July 2001; therefore, it appears that the Audit report which I have received
(Audit Report p176 to p188 AMCL0000031) relates to a later audit. To clarify
I was not the Lead Auditor on the audit dated 26 July 2001. This audit was
led by Ina Crawford, and I was there to assist. Although I have not seen the
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Audit Report from 26 July 2001, I expect this would have been written by the
Lead Auditor, Ms Crawford.
47. I can no longer recall but expect I would have been requested to assist at the
audit by the Audit Scheduling Team. Based on the size of the branch it
would have required two auditors present.
48. On 26 July 2001 I attended an audit at Brookfield Post Office with my Line
Manager, Ina Crawford. Ms Crawford was leading a special audit which had
been requested by Suzanne Winter. Ms Winter accompanied us into the
branch, with her colleague Leslie Thorpe, where she explained the purpose of
our visit. (List of Witness Statements p262 to 293 (AMCL0000031)). I do not
recall having any involvement prior to attending the audit.
49.1 assisted with the audit under the direction of Ms Crawford. There was a
standard process which we would follow. Ms Crawford would have taken the
lead, but we would both of worked on counting the cash, stock and vouchers
as required. I also note that the pension dockets were counted as part of the
audit. There would have been a process of counting the cash, stock and
vouchers and recording this on a sheet which would then have been collated
by Ms Crawford on her laptop to provide the overall balance.
50. On completion of the Audit Ms Crawford provided Ms Winter with the results.
The audit examined cash, stock and vouchers and highlighted an error within
the paid pension dockets with an overstatement of £381.60 (Group 13 -
£92.15, Group 7 - £206.60 and Group 11 - £82.85) (List of Witness
Statements p262 to 293 AMCL0000031).
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51. On completion of the audit and once the findings had been reported Ms
Crawford and I left the branch. Ms Winter and Ms Thorpe remained at the
branch to interview Mr McLaughlin. I did not have any involvement in the
investigation outside of the audit but was later asked to provide a statement to
the Investigation Team in regard to the findings of the audit.
52. The Inquiry has asked me if I was aware of any allegations made by Mr
McLaughlin in relation to the reliability of the Horizon IT system. I do not
recall being made aware of any allegations. As the Assistant Auditor my
involvement was limited, and I would expect any allegations would have been
shared with the Lead Auditor or the Investigators.
53.As noted above, I was asked by the Investigation team to provide a
statement. I am aware the case progressed to Court and note that document
AMCLO0000034 lists the charges against Mr McLaughlin on 26 April 2004. I
attended court as a witness but whilst wating in the witness room was told I
would not be needed as Mr McLaughlin had pleaded guilty. I left the court
and was not aware of any further details regarding Mr McLaughlin's
prosecution or his sentencing.
54. The Inquiry has asked me what my reflections are on the way the
investigation and prosecution of this case was conducted by the Post Office.
The Inquiry has provided me with the Judgment of the Court of Appeal at
AMCLO0000037. My knowledge of Mr McLaughlin's prosecution is limited to
my knowledge of the audit and therefore I cannot give a view on the way the
investigation and prosecution was conducted. My understanding was the
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audit identified discrepancies which were reported by my Line Manager, Ms
Crawford to the Investigation Team. I understood that this formed the basis
of the case against Mr McLaughlin but have a limited knowledge of the
subsequent investigation and prosecution which I have set out above.
General
55.1 have been asked by the Inquiry to what extent (if any) I considered a
challenge to the integrity of Horizon in one case to be relevant to other
ongoing or future cases. If a Subpostmaster raised an issue I would include
this in the audit report which would be provided to the relevant parties. I
would expect any issues would then be picked up and investigated as
required.
56. The Inquiry has asked me if there are other matters I consider to be of
relevance to Phase 4 of the Inquiry that I would like to draw to the attention of
the Chair. Having left POL over 7 years ago I have had no further
involvement in POL and do not recall anything further that may be of
assistance to the Inquiry.
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Statement of Truth
I believe the content of this statement to be true.
Index to First Witness Statement of Linda McLaughlin
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No.
URN
Document Description
Control Number
1
POL00032698
POL00086765
Assurance Review - Recruitment
(Vetting & Training) (version 1.0, 27
October 2009)
Network auditing approach, methods
and assurance (2013)
POL-0029633
POL-0083823
POL00088453
Training & Audit Advisor (undated)
POL-0085511
POL00088557
Audit Advisor (undated)
POL-0085615
Oj BIo
POLO0084650
Audit Plan & Scheduling, Chapter 1 of
the Audit Process Manual (Version
8.0) (2010)
POL-0081708
POL00083966
Audit Charter (version 4.0, undated)
POL-0081024
POL00084801
Performing a Branch Audit, Chapter 3
of the Audit Process Manual (version
5.1, May 2010)
POL-0081859
POL00085534
Core & Outreach Audit Process,
Chapter 3a of the Audit Process
Manual (version 1.0, 27 May 2011)
POL-0082592
POL00087627
Follow Up Audit Process, Chapter 3b
of the Audit Process Manual (version
3.0, May 2015)
POL-0084695
10
POL00088252
Performing a Cash Centre Audit,
Chapter 7 of the Audit Process
Manual (version 5.0, Aug 2016)
POL-0085310
11
POL00087672
Quality Assurance, Chapter 11 of the
Audit Process Manual (version 5.0,
Apr 2015)
POL-0085310
12
POL00084003
Post Incident Auditing without
Horizon, Chapter 14 of the Audit
Process Manual (version 1.0, Nov
2006)
POL-0081061
13
POL00084813
Condensed Guide for Audit
Attendance (version 2, Oct 2008)
POL-0081871
14
POL00085652
Requirement of Network Field
Support Advisors at audit, following
discovery of discrepancy (version 1.0,
Oct 2011)
POL-0082710
15
POL00086765
Network auditing approach, methods
and assurance (2013)
POL-0083823
16
POL00087688
Training Guide: Compliance Audit
Tool (Sep 2015)
POL-0084746
17
POL00087716
Training-Aide for Branch Asset
Checking (version 1.7, Nov 2014)
POL-0084774
18
POL00087614
Terms of Reference Audits (version 1,
POL-0084672
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WITN08480100
April 2015)
19 I FUJ00001894 Audit Trail Functional Specification POINQO008065F
(version 8.0, 18 October 2004)
20 I POLO0002841 Global User Account (September VIS00003855
2016)
21 I AMCL0000031 I The audit report p176 to p188 AMCLO000031
22 I AMCL0000014 I The Interview Transcript AMCLO000014
23 I POLO0113386__I The incident log POL-0110794
24 I AMCLO000031 I The email from Graham Ward to AMCLO0000031
Suzanne Winter, dated 22 September
2004 p156
25 I AMCLO0000031 I The statement of complaint p257 to AMCLO000031
260
26 I AMCL0000034 I The indictment dated 26 April 2004 AMCL0000034
27 I AMCLO0000031 I The list of witness statements (which I AMCLO000031
appear to have been filed at the same
time as the statement of complaint)
p262 to 293 and p312 to 326
28 I AMCL0000031 _I The list of exhibits p.367 to 373 AMCLO0000031
29 I AMCLO0000031 I The letter from Richard Gardiner of AMCLO000031
McClure Watters, Chartered
Accountants, to John J Rice & Co
Solicitors enclosing his draft report
(dated 22 December 2004) p33 to 65
30__I AMCL0000033 _I The case result form AMCL0000033
31 I AMCLO000036 I The certificate of conviction dated 4 AMCLO0000036
November 2021
32 I AMCLO000037 I The Court of Appeal judgment in Rv I AMCLO000037
McLaughlin
33. I AMCLO000040 I Alan McLaughlin statement — AMCL0000040
Prepared for Northern Ireland Court of
Appeal Application