WITN08690100 Glyn Allan Burrows - Witness Statement

Evidence on official site

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Witness Name: Glyn Allan Burrows

Statement No.: WITN08690100

Dated: 11 October 2023

POST OFFICE HORIZON INQUIRY

FIRST WITNESS STATEMENT OF GLYN ALLAN BURROWS

I, Glyn Allan Burrows will say as follows:

Introduction

1. lama former employee of Post Office Ltd.

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

(the “Inquiry”) with the matters set out in the Rule 9 Request dated 23 August

2023 (the “Request’).

3. Ican confirm I was assisted by the Post Office 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

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4.

6.

I have been asked by the Inquiry to set out my relevant professional

background, explain a number of activities I have performed and the

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prosecution cases I have been involved in. I have tried my best to do this and

have detailed my responses below.

I joined the Post Office on 6" October 1980 as a Postal Officer serving the

public. I held this role for the next 12 years. I was promoted in January 1993

to a CM3 Audit Manager. After this date and as a result of various business

reorganisations I performed the following roles within different teams always

under the leadership of a Line Manager:

a. Audit Manager -— Performing onsite audits at Post Office branches,

managing a number of Auditors, and scheduling the weekly audit

programme.

. Management Information Manager — Providing support to different

teams on their performance against objectives.

. Compliance Manager-— Performing compliance audits and issuing

reports on the audit findings.

. Security and Investigation Manager — Performing investigations into

various cases relating to Post Office branches.

. Network transformation Manager — Supporting Post Office branches

that were converting their branch during the transformation

programme.

I left the business in November 2018.

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7. For the majority of my time within the Audit Team I reported to Martin Ferlinc,

Audit Manager.

8. I have been asked by the Inquiry how I became a Network Field Support
Advisor and Field Team Leader. I believe these roles were created after my
time in the team. My role in the team was Audit Manager. This role varied
over the years from completing onsite branch audits, to scheduling the weekly
audit programme. My colleagues and myself were managed using the
appraisal performance system. Many of the Auditors had good experience
and were very competent at running audits. In most cases my role in the
actual audit was very limited as this would be delivered by the Lead Auditor
with the support of their assistant Auditors. However, I would ensure I was

there to support them should any questions or issues arise.

9. As aLine Manager within Post Office Ltd I was responsible for the day-to-day
management of my direct reports which included allocating work, discipline
matters and managing sick absence. In my role as Audit Manager I was not
involved in interviewing those accused of criminal offences. I also did not
have any involvement in the disclosure for criminal or civil proceedings or
litigation case strategy. If the Investigation and Security Team required a
statement they would contact me and this activity would be completed as part

of their case.

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10.1 have no idea how many onsite audits I have been involved in. I would say
probably over 300. I have audited the following: Cash Centres, Stock Centres,
Crown Post Offices, Franchised Post Offices, Modified Post Offices, Post

Offices owned by Multiple Partners and Sub-Post Offices.

The audit process and the policies/practices in place
11.During my time in the Audit Team I have been involved in reviewing, updating
and creating audit policies linked to onsite audit activity. I can no longer recall

which polices I was involved in or when this activity happened.

Recruitment and training of auditors

12.The Inquiry have 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).

13.1 believe the Assurance Review (POL00032698) was developed by my

colleague during my time in the Audit Team but I do not recall this document.

The other documents seem to relate to a time when I was not working in the

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Audit Team. My responses to the Inquiry are based on my own understanding

from memory.

14.As far as I can recall if there was a position vacant within the Audit Team then
the Audit Manager would decide how it would be filled. My memory of this
process is that the position would be advertised internally and candidates
would be selected following an interview. I do not recall any specific
qualifications that were required to become an Auditor and individuals would

be selected based on their suitability through the interview process.

15.From memory, but I can’t be certain, when a new member joined the team
they would follow a plan of activity and coaching. This would involve meeting
different members of the Audit Team and going out to help on branch audits
as an extra person so their colleagues could give them some on the job

training.

16.From memory if new working practices or new products were developed then

this would be discussed atteam meetings or by smaller identified groups with

a view to cascading these activities to the team so everyone was aware.

17.When new members of staff joined the team I think there was an induction

process which would give them an overview of the team.

18.From my time within the Audit Team I believe it was an experienced team.

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The planning and scheduling of audits

19.The Inquiry have asked me to consider the document Audit Plan &

Scheduling, Chapter 1 of the Audit Process Manual (Version 8) (2010)
(POL00084650). I think this document was produced after I left the Audit
Team but I do recall some of the content. However, as I am not familiar with
this document, I have provided my response to the Inquiry in regard to the

planning and scheduling of audits from memory.

20.Branch audits were scheduled using information from the Audit Programme.

2

As I remember the Audit Programme generated the team's work. All Post
Office branches were input into a computer programme with scores allocated
against set criteria, for example, they were allocated a cash management
score, then once all the data had been input every branch was allocated an
overall score and the Audit Team were tasked with completing an agreed
number of audits based on this programme. As I can remember this would
have been agreed between my Line Manger, Martin Ferlinc, and his Line

Manager, Keith Woolard, Head of Compliance.

. Special audits would also be scheduled into the weekly plan. These were

requests from various people within Post Office Ltd who had a concern about
a Branch and required an audit to take place. I would also have to schedule
in audits where a Post Office branch was going to change hands to a new
subpostmaster. This involved the Audit Team completing an independent
check on the final balance of the outgoing subpostmaster before the new

subpostmaster took over. As part of this process our support team would

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inform the Audit Team of the transfer date and I would schedule this activity on
the date requested. Similarly if a Post Office branch was closing then the
Audit Team would attend to check the final balance and verify the Post Office
cash and stock agreed to what was declared on the final balance. Again
these Audits would be scheduledin on the date they were requested. When I
scheduled the weekly Audit plan, I would issue it on a Friday to commence in

10 days' time.

22.The onsite audit would be planned by the Audit Leader. They would obtain
information from the previous audit report, if there was one, and obtain
information from the Audit Planning File (1 am not sure if this is the correct
name but it was an Excel spreadsheet detailing various activities that the
Lead Auditor used to help plan the onsite activity prior to attending the audit

on the day).

23. Over the years I think scheduling changed from branches being selected from
the Audit Programme rather than a frequency visit (a fixed schedule when a
branch would be audied e.g. every 12 months or two years) but I could be

mistaken.

24. There was no difference in scheduling audits at Crown Office and Sub-Post

Offices as far as I’m aware other than making sure you had enough Auditors

available due to the size of the branch and the team's other commitments.

The Auditing Process

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25.The Inquiry has asked me to consider the following documents:

a. Audit Charter (version 4.0, undated) (POL00083966);

b. Performing a Branch Audit, Chapter 3 of the Audit Process Manual
(version 5.1, May 2010) (POL00084801);

c. Core & Outreach Audit Process, Chapter 3a of the Audit Process
Manual (version 1.0, 27 May 2011) (POL00085534);

d. Follow Up Audit Process, Chapter 3b of the Audit Process Manual
(version 3.0, May 2015) (POL00087627);

e. Performing a Cash Centre Audit, Chapter 7 of the Audit Process
Manual (version 5.0, Aug 2016) (POL00088252);

f. Quality Assurance, Chapter 11 of the Audit Process Manual (version
5.0, Apr 2015) (POL00087672);

g. Post Incident Auditing without Horizon, Chapter 14 of the Audit Process
Manual (version 1.0, Nov 2006) (POL00084003).

h. Condensed Guide for Audit Attendance (version 2, Oct 2008)
(POL00084813);

i. Requirement of Network Field Support Advisors at audit, following
discovery of discrepancy (version 1.0, Oct 2011) (POL00085652);

j. Network auditing approach, methods and assurance (2013)
(POL00086765);

k. Training Guide: Compliance Audit Tool (Sep 2015) (POL00087688);

I. Training-Aide for Branch Asset Checking (version 1.7, Nov 2014)
(POL000877 16);

m. Terms of Reference Audis (version 1, April 2015) (POL00087614).

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26.1 have reviewed the documents but can only now recall the Audit Charter
(version 4.0, undated) (POL00083966) (or a similar version of this document)
from my time in the Audit Team. This details parts of the process including
onsite auditing, post-auditing and scheduling processes which I seem to
recall. I believe the other documents relate to a period after I had left the
Audit Team and my response to the Inquiry is based on memory rather than

these documents.

27.As far as I can remember from my time within the Audit Team, as part of the
audit planning process the Lead Auditor would review the findings of the
previous audit and obtain the relevant information from the Audit Planning

File.

28. If a discrepancy was discovered at an Audit then the following steps were
undertaken:
a. The Lead Auditor would liaise with the person in charge at the branch.
b. The figures would be double checked and then depending on the
amount involved the Line Manager for the branch could be contacted.
c. Then whatever they stated was to happen the Lead Auditor followed

this and put it in the Audit Report.

29.The practice of asking for a shortage to be made good by the subpostmaster
on the day of the audit was standard business practice. It was also the case
that where an audit surplus was identified it could be withdrawn by the

subpostmaster.

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30. The practice of taking payment for shortages was the standard audit process.

3

a

32.

33.

If an audit shortage was discovered and was made good at the time within
guideline limits then this would be reported in the audit report. Larger amounts
would require the Lead Auditor to notify the subpostmaster's Line Manager

and they would then follow their instructions.

. The Lead Auditor would discuss the findings of the audit with the

subpostmaster, or person in charge, at the end of the Audit. They would also
discuss findings at various stages of the audit, for example, when the cash on
hand had been counted, the first part of the audit process, the outcome would
be discussed with the subpostmaster. If the figures produced by the Audit
Team differed from the declared overnight cash holdings then it would be
brought to the attention of the branch and the branch could complete their

own checks and agree the figures.

From memory if a subpostmaster/subpostmistress or staff member in charge
had made comments about the audit result this would be documented by the
Lead Auditor who would ask the person to sign a statement. They would
inform either the Line Manager or the Security and Investigation Team
member of this statement. It would also be included in an extra audit report

which would be produced bythe Lead Auditor.

My knowledge now of the Horizon system is very limited and I don’t know if it

would be possible to complete an audit without Horizon. I presume it would

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require the team contacting other support teams to provide the required
information which could be a few days to get the data. I can see from the
document, Post Incident Auditing without Horizon, Chapter 14 of the Audit
Process Manual (version 1.0, Nov 2006) (POL00084003), provided to me by
the Inquiry, that you cannot produce an audit figure without Horizon, but I do

not recall this document and was not specifically aware of this at the time.

34.The approach taken to auditing a Crown Office was based around risk as far
as I can recall. This approach is focused on the assessment of risk to the
cash, stock and other valued items. The approach for compliance was the
same as far as I can recall. Crown Office branches are managed by a Post
Office Ltd employed person who has responsibility for completing various
management checks therefore the Audit Team's approach was to complete a
percentage check of live counter stock units and non-counter stock units.
There were compliance tests for Crown Offices and other branches. The tests
performed at each branch would be decided by the Audit Leader based on

previous audit findings and current guidelines.

35.The Inquiry has asked me to consider the following documents:
a. Audit Trail Functional Specification (version 8.0, 18 October 2004)
(FUJ00001894);

b. Global User Account (September 2016) (POL00002841).

36.1 cannot recall seeing the Audit Trail Functional Specification (FUJ00001894)

document and I don’t recall the detail from memory. In regard to the Global

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User Account (POL00002841) I think there was a process for onsite branch
Auditors to follow if they needed access to the Horizon IT system and I think

you had to phone the Helpline to get a password

37.The Inquiry has asked me to describe any involvement Fujitsu had in the audit
process. As far as I can remember Fujitsu had no involvement in the audit

process during my time in the team.

38.1 have also been asked by the Inquiry whether Auditors had access to
information which a subpostmaster did not have access to when they were
conducting a branch audit. Auditors had information available to them from
within the Audit Planning File as far as I can remember. This was an internal
model used by the Audit Team only. They also had the previous audit report.

This information would not be available to subpostmasters.

39.If my memory is correct and I am thinking about the same thing, the Audit
Global User Account was available at every branch. This could only be
accessed by Audit Team members as far as I’m aware. I think the Auditor who
needed to use this had to phone up the Helpline and was given a one-use

password but I could be mistaken with my memory of this.

40.1 can’t remember anything about any audit measures that were in place in

respect of Audit Global User Accounts.

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Involvement in the Security Team and training, instructions and guidance to

Investigators within the Security Team

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41.1 was in the Security Team for around two years. This was a much shorter
period then some of my other roles and I can no longer recall many details
from my time in the team. I remember I completed the necessary training
and was guided by the standard process documents when investigating
cases. I felt I was more suited and preferred working on supporting branches
which is why I left the Security Team to pursue other opportunities. In my role
within the Security Team my Line Manager was Alison Drake, her Line
Manager was Dave Pardoe and his Line Manager was John Scott, if my

memory is correct.

42.When I joined the Security Team I had to complete an Internal training course.
Once the training course finished I joined a team and started by shadowing
cases and the casework of my colleagues until I was given my own cases to
lead. Depending on the case I would follow the process, complete the activity
required, write a report on my findings which would be submitted along with
my recommendations. If I remember correctly, this would then be reviewed by

the Legal Team who would decide on the next steps.

43.The Inquiry has asked me about what instructions, guidance and/or training

was given to investigators within the Security Team about the following topics

and how this was provided:

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a. interviewing a SPM/ SPM's assistant / Crown Office employee who
was suspected of a criminal offence;

b. taking witness statements in the course of an investigation;

c. conducting searches in the course of an investigation;

d. the duty on an investigator to investigate a case fully;

e. obtaining evidence in the course of an investigation;

f. 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;

g. aninvestigator’s disclosure obligations;

h. drafting investigation reports to enable a decision to be made about the

future conduct of a case.

44.1 cannot recall the content of the training course or whether it covered all of
these elements. From memory before I could join the Security Team I had to
pass a test. Once I had passed this test my fellow new colleagues and I
attended a two or three week training course based around the role. I think a
further test was completed at the end of this course as well. As mentioned
above, after training, I shadowed colleagues on the job. All my casework was
reviewed and from memory I had to pass a compliance score to ensure it met

the standards.

45.1 have been asked by the Inquiry to consider the following documents:

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a. The Casework Management document at (POL00104747) (version 1.0,
March 2000) and (POL00104777) (version 4.0, October 2002);

b. David Posnett’s email to you and others dated 23 May 2011 at
(POL00118096) and the documents contained within the attached
compliance zip file at (POLO00118108), (POL00118109),
(POL00118101), (POLO0118102), (POLO0118103), (POL00118104),
(POL00118105), (POL00118106) and (POL00118107);

c. David Posnett’s email to you and others dated 27 April 2012 at
(POL00118110) and the attachments at (POL00118120),
(POL00118121), (POL00118122), (POL00118123), (POL00118124),

(POL00118125), (POL00118126) (POL00118127), (POLO0118128).

46.1 cannot recall if I saw the Casework Management documents (POL00104747
and POL00104777) therefore I cannot comment on what my understanding
was of these documents at the time. From memory I think compliance checks
were completed to ensure the completion of the casework files achieved a
standard set out by the leadership of the Security Team. I had no involvement
with producing any of these documents or processes as far as I can
remember. I think these processes had already been developed prior to me

joining the Security Team.

47.1 have reviewed the other documents attached to Dave Posnett's emails
(POL00118096 and POL00118110) but do not recall their contents or my
understanding of them at the time. I remember there were various documents

which were provided to the Security Team with guidance on managing cases

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and filing reports but can no longer recall the details of these guidance
documents. I had no involvement in the development of these documents

during my time in the Security Team.

Prosecution of Carl Page

48.The Inquiry have provided me with a copy of my witness statement in the
proceedings against Carl Page (POL00093714). However, I cannot recall the
exact details of this case against Mr Page and all I can remember is that an
audit was performed at Rugeley Post Office and the Security Team were

involved.

Initial Investigation by HM Customs and Excise

49.As far as I am aware I first became involved in Carl Page's case when the
Security Team requested an audit to be performed at the Rugeley Post Office

and I may have been the person who arranged this at the time.

50.As far as I’m aware, I was not involved in any activity prior to the audit. I am

not aware of any Post Office audits carried out by members of staff from HM

Customs & Excise.

51.1 don't have any memory of Staffordshire Major Crime Unit being involved with

the case. However, it states in my Witness Statement (POL00093714) that Mr

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Patel from the Investigation Team made me aware that the Police had

removed some cheques from the Bureau stock unit.

52.The Inquiry have asked me to consider the witness statement of Andy Dunks,
Fujitsu Services, IT Analyst (FUJ00122250) and the request I made for a one-
shot password after Carl Page reported a discrepancy. If I required a
password then this was because it was the process. I would have used my
access to the Horizon system to generate the reports required to undertake

the audit.

53.The outcome of the audit was detailed in my Witness Statement
(POL000937 14) as a shortage of £645,345.18. This was made up of the

following:

a. £638,675.65 — Cheques removed from the Bureau stock unit by the
Police the night before the audit as I was informed by Mr Patel from the
Investigation team. So these cheques were not included in the audit
figures because they were not on hand.

b. £3,583.14 — This was the difference between the cash and currency on
hand in the Bureau stock unit and the Horizon printout prior to the
Bureau stock unit being balanced. Once the Bureau stock unit had
been balanced as part of the audit, the result, which was a shortage
was reported as the figure above.

c. £3,086.39 — Shortages in the Counter stock units compared to the
Horizon printouts prior to each stock being balanced by the Audit team.

Once the Counter stock units had been balanced as part of the audit,

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the result, which was an overall shortage was reported as the figure

above.

54.1 can no longer recall any further details regarding the shortage other than

what I have noted above from my Witness Statement (POL000937 14).

55.1 do not recall how long after Mr Page had taken over at the branch that this
audit occurred. I think I may have attended another audit, or audits, at this
branch. I think I was also part of the team onsite when the branch converted
from a Crown Office to Sub-Post Office but I cannot confirm this. I don’t recall

being made aware of the financial position of Rugeley Post Office.

Audit of Rugeley Branch

56.The Inquiry has asked me to consider the Case File Events Log
(POL00093908) and my Witness Statement dated 11 April 2003
(POL00093714) and provide my recollections of a call I received from Colin
Price to arrange an audit of Rugeley Branch on 14 January 2003. I cannot
recall the conversation with Mr Price but note from my Witness Statement
(POL000937 14) that Mr Price requested a special audit at Rugeley Branch.
The purpose of a special audit is to audit a particular Post Office where other

business colleagues have particular concerns.

57.1 cannot remember the full circumstances of this audit. Sometimes the audit is

completed before the Security Team make themselves known at the branch

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and sometimes the Audit Team and Security Team go in together. I cannot

remember what happened on this occasion.

58.1 am aware from the information provided by the Inquiry that there was a team
of four conducting the audit, myself, Kevin Orgill (Witness Statement of Kevin
Orgill dated 31 March 2003 (POL00093733)), Alison Edwards (Witness
Statement of Deborah Alison Edwards dated 31 March 2003 (POL00093897))
and a fourth auditor. I cannot remember who the fourth Auditor was but in my
Witness Statement (POL000937 14) it says, "I confirm that the writing that
appears at the top of this printout is that of my colleagues Mr Kevin Watkins."
This would suggest he may have been the other Auditor that day. The role of
the Auditors was to complete the Audit of Accounts and inform all the
interested parties of the result. Who completed what roles would have been
decided by the Audit Leader depending on what was needed at the different

stages of the audit.

59.1 cannot recall any discussions I had with Mr Page during this audit. I also
cannot recall any of the discussions I had with Mr Patel or another member of
the Investigation Team. I can see from my Witness Statement
(POL000937 14) that Mr Patel had informed me that the Police had removed
some cheques from the Bureau stock the previous evening. The value of the

cheques removed were £638,675.65.

60. The Inquiry has asked me to consider page 3 of Mr Orgill's Witness Statement
(POL00093733) which notes that Mr Orgill passed documentation to me

during the audit. I do not remember this now but it would have been normal

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process for Mr Orgill to pass me, as Audit Leader, his audit working papers
and any support Horizon printouts so this information could be input into the

P32 Audit of Accounts for this audit.

61.1 have been asked by the Inquiry whether ARQ logs were sought by POL from
Fujitsu in this case and if not why not? I don’t recall what ARQ logs are but I
don’t think they related to my role at the time and I am afraid I cannot provide

any further information.

62. The Inquiry have also asked me to consider my audit report at page 47 of the
Expert Accountant's Report of David Liddell (POL00062201) and explain the
findings of this report and what other documentation, if any, I completed after
the audit. I can confirm that page 47 is not an audit report it is a printed
account of the P32 Audit of Accounts completed at Rugeley Post Office on 14
January 2003. This shows the account as £645,345.18 short. I cannot recall if
I produced any other documents relating to the Audit of Rugeley Post Office

on 14 January 2003.

63.My Witness Statement (POL00093714) confirms a copy of my written Audit
Report was sent to Mark Irvin, Retail Line Manager, and Manish Patel,
Investigation Team Manager. I cannot recall any conversations I had with Mr
Irvin or Mr Patel about the Audit Report or any comments they made about

the audit report.

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64.1 have been asked by the Inquiry whose decision it was to suspend Carl Page.
I do not recall who would have suspended Mr Page but my understanding of
the process is that the decision would have been made by his Line Manager
Mr Irvin. For clarity I would not expect this decision to be taken by an Auditor
or anyone in the Audit team as they would not have the authority to make this

decision.

65.1 cannot recall any other involvement I may have had in the investigation of
this case but it would be normal that the Audit team would have no further
involvement once the audit was complete and the Lead Auditor had shared

the audit report unless any specific concerns were raised.

R v Carl Page

66.1 cannot recall if I had any involvement in any other proceedings against
subpostmasters/subpostmistresses or other people who worked within Post

Offices involving the Horizon system before this case.

67.1 cannot recall who asked me to provide a witness statement against Mr Page
and Mr Whitehouse and I cannot recall when I completed my witness
statement. I cannot recall who I had contact with during the drafting of my

witness statement or the nature of any discussions I had with them.

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68.1 cannot recall having conversations with counsel and POL’s Legal Team
about my role as a witness. My role in this case was as Lead Auditor at

Rugeley Post Office on 14 January 2003.

69. The Inquiry has provided me with the Witness Statement of Carl Page
(WITN01510100) in which Mr Page recalls that I was questioned by his
defence team at his trial. I remember I was cross examined about my job title
a number of times until the Judge stepped in and explained his
understanding. He then directed Mr Page's Legal Team to move on from that
matter. That is all I can recall about giving evidence in court relating to this
case but I’m sure there would have been a number of questions from both

sides relating to the Audit at Rugeley Post Office on 14 January 2003.

The Prosecution of Tahir Mahmood

70. The Inquiry have provided me with a copy of the Audit Report completed by

Ms Edwards (POL00066040) which I have read. However, I do not recall this

case and I cannot recall Mr Mahmood.

The Audit at Ten Acre Street Branch

71.1 cannot recall the circumstances in which I first became aware of this case. If
I had any involvementin this case it would have been to contact Ms Edwards

and Mr Aubby to arrange the audit. I can see from the Audit Report dated 3

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May 2005 (POL00066040), provided to me by the Inquiry, that I was copied
into the report at the time but I do not recall anything about this audit and do

not remember this report.

72.1 cannot recall scheduling the audit but if this audit was scheduled during my
time in this role then I would have scheduled the Auditors to attend. I would
have had to contact the Audit Team and probably seek volunteers as this audit
was performed on a Saturday. My selection of who would attend the audit
would have been based onwho was available as not all Auditors were

available every Saturday.

73.1 have been asked by the Inquiry what I thought about the size of the shortfall
that was discovered and whether! had any concerns. I cannot recall this
case so cannot comment on what my views would have been about the size
of the loss but I would not have had any concerns about the actual result
produced on the day by the Audit Team as I would expect each Auditor to be
responsible for reviewing the figures produced in the Audit and ensuring they
are correct. From memory the Lead Auditor, Alison Edwards, had good
experience in the role and I would only expect to get involved in the audit if
they had any particular concerns or if something was raised with me by other

colleagues in the business.

74.As I cannot recall this case I don’t know if any post-audit activity was

undertaken or if I was involved. I also cannot comment on if I had any further

involvement with this case post-audit. However, as noted above, I would not

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expect to have any further involvement in the audit once it is complete unless

any specific concerns were raised with me.

The Prosecution of Seema Misra

75.The Inquiry have provided me with a copy of the Investigation Report

(POL00044541) and the Summary of Facts (POL00044613). I have read both

document but I cannot recall this case or Ms Misra.

The Audit at West Byfleet Branch

76.The Inquiry has confirmed that on 10 October 2005, Elaine Ridge requested
that an audit be carried out at West Byfleet (POL00066397) and has asked
me to describe the circumstances in which a special request for an audit could
be made. Arequest for a special audit can be made at any time and for a
variety of reasons, mainly based around concerns relating to Post Office
funds at a particular branch. My role when scheduling audits was to action
these requests. The Lead Auditor would also be informed of the concerns

raised.

77.1 cannot recall this case so cannot comment as to when I first became aware
of the potential audit at West Byfleet branch or what my understanding was of
the alleged issues at the branch at this stage. Having read Elaine Ridges’
Special Request of an Audit of Accounts (POL00066397), Ms Ridge has

suggested there could be patential theft going on at the branch. Also, Ms

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Ridge stated that Ms Misra was a new subpostmistress and had some large

discrepancies.

78.1 cannot recall this case and cannot confirm what my role was in scheduling
the audit at West Byfleet. If this audit was scheduled during my time in this
role then I would have scheduled the Auditors to attend the audit. I would
have checked the Audit Team plan for the date when the audit was to take

place and make my selection of who would be asked to attend.

79.1 cannot recall this case but under normal circumstances I would not have
reviewed the audit findings. I would not have any concerns about the result of
the audit produced by the Audit Team as it would have been down to the
Auditors to check their own figures. From what I can see it appears that
Keith Noverre was the Lead Auditor that day. Keith was an experienced
Auditor and would have been very capable in his role. If Keith had any
concerns he would have raised them with me and I would have addressed
them accordingly. However, after this time I cannot recall if any concerns

were raised.

80. The Audit Leader may have informed me of the audit result and the
circumstances for the loss but I cannot remember if this happened or anything

that was said about this case.

81.As I cannot recall this case I am unsure if I had any further involvement in this

case or whether I was involved in any post-audit activity. However, I expect

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this was unlikely as the Audit team's involvement would generally end when

the audit was complete unless any specific concerns were raised.

The Prosecution of Josephine Hamilton

82.The Inquiry has provided me with the Investigation Report into Josephine

Hamilton (POL00044389) which I have read, however, I cannot recall this

case or Ms Hamilton.

The Audit at South Warnorough Branch

83.1 have been asked by the Inquiry to consider the email from Doug Brown to
Rebecca Portch, which Mr Brown forwarded to me on 7 March 2006,
(UKGI00014734) and answer the following questions:

a. Was this the first time that you became aware of the potential audit at
South Warnborough branch?

b. What was your understanding of the alleged issues at the branch at
this stage?

c. Doug Brown states that he would update you, did he provide this

update?

84.1 cannot recall this case so cannot answer these questions fully. The email to

Mr Brown from Ms Portch (UKGI00014734) states she had concerns that

funds would be missing at this branch. Having read the email there was no

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need for Mr Brown to update me as an audit had been planned to take place

on Thursday 9" March 2006.

85.1 have been asked by the Inquiry to consider the email from Rebecca Portsch
(UKGI00014734) and confirm what my reaction was to the suggestion that
there might be a shortfall in excess of £20,000 at South Warnborough branch.
I cannot recall this case but if our Cash Management Team had concerns then
it would be the right approach to see if we could support their concerns by
arranging an audit at this branch to verify the actual cash and stock on hand

at the branch.

86.1 have been asked by the Inquiry to consider the email chain from Adrian
Skinner on 7 March 2006 (POL00067205), in which I was copied, and

address the following:

d. Why do you think you were copied into this email?
e. What was your impression of the issues at the branch having received

this email?

87. I cannot recall this case but Mr Skinner would have copied me into this email
(POL00067205) so that I could, if required to do so, pass on any information
to the Lead Auditor. I cannot comment on what I felt about this case because I

cannot recall it.

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88.As I cannot recall this case I do not know what role I played in scheduling the
audit. If this audit was scheduled during my time covering this role then I
would have scheduled the Auditor to attend the audit. I would have checked
the Audit Team's plan for when the date of the audit was to take place and

made my selection of who would be asked to attend.

89.As I cannot recall this case I do not know if I played any part in analysing the
results of the audit. I generally did not get involved with post-audit activity as
the Audit Team's role would normaly end on completion of the Audit. I cannot
recall this case so cannot comment on what my views were at the time or
about the size of the loss. I would not have had any concerns about the
actual result as I would expect each Auditor to be responsible for reviewing
the figures produced in the audit and ensuring they are correct. As with the
above audits, the Lead Auditor, Alan Stuart, was experienced and capable in
his role and would have raised any concerns about the result with me. I

cannot recall any concerns that were raised.

90.As I cannot recall this case I do not know if I became aware of the shortfall

identified in the audit. I would have only become aware of the audit result if

the Audit Leader informed me.

91.1 cannot recall this case but generally I did not get involved with post-audit

activity.

Prosecution of Susan Rudkin

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92.The Inquiry has provided me with the Investigation Report (POL00046485)
and the Summary of Facts (POL00044623). I have read both documents but

cannot recall this case or Ms Rudkin.

The Audit of Ibstock Branch

93.As I cannot recall this case I cannot remember the circumstances in which I
first became involved in Ms Rudkin's case. I would only have been involved in

scheduling the audit.

94.1 have been asked by the Inquiry to consider the email from Doug Brown
(POL00061712). As noted above, I cannot recall this case but if this audit
was scheduled during my time covering this role, which I think it was as my
name is mentioned in the email (POL00061712), then I would have scheduled
the Auditors to attend the audit. I would have checked the Audit Team Plan for
when the audit was due to take place and would have made my selection of

who would be asked to attend.

95.1 have been asked by the Inquiry what my involvement was, if any, in the
audit. I cannot recall this case but note from the Investigation Report
(POL00046485) that the named auditors were Paul Field and Kevin Watkins.
The only involvement! would have had, if any, would be to schedule the audit

and support the team as required.

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96.1 cannot recall this case and therefore do not know the process by which the
audit was carried out. Having read the Investigation Report for Ms Rudkin
(POL00046485), after the admission by Ms Rudkin at the start of the audit the
business practice at the time would have been to keep the Post Office closed
until the full audit result had been achieved and the Investigation Team and

the Line Manager of the branch had been cortacted.

97.1 do not know if I played any role in analysing the results of the audit as I
cannot recall this case. I generally did not get involved in post-audit activity as
the Audit Team's role would normaly end on completion of the Audit. I cannot
recall this case so cannot comment on what my views would have been about
the size of the loss but I would not have had any concerns about the actual
result produced by the Audit Team as I would expect each Auditor to be
responsible for reviewing the figures produced in the Audit and ensuring they
are correct. Again, Paul Field, Lead Auditor, was experienced in his role and
would have flagged any concerns with me but I do not recall any concerns

with this audit.

98.As I cannot recall this case I don’t know if I had any further involvement with

this case. However, as noted above, I would normally have no further

involvement once an audit was complete.

General

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99.1 would have been aware of the concerns raised relating to the Horizon IT
system during my time working for Post Office Ltd via any general
communications sent to all members of staff on what the findings of any
internal reviews of the Horizon IT system had discovered. As a Line Manager
I think I would also have received any standard communications to relay to
anyone who might ask my opinion or my direct reports opinion on the system.
I can no longer remember what was said in any communications but would

have relayed the messages to my team members as they were shared.

100. I have personally never considered a challenge to the Integrity of

Horizon and I cannot remember the guidance given at the time.

101. The Inquiry have asked me to what extent do I consider the
investigations into bugs, errors and defects in Horizon was sufficiently carried
out by Post Office and whether I consider sufficient information regarding
bugs, errors and defects in Horizon was passed to the Post Office by Fujitsu.
I cannot comment on this because I was not involved with this process and do

not recall any investigations that took place.

102. The Inquiry has also asked me to consider whether I had sufficient
information regarding bugs, errors and defects in Horizon and who provided
me with the information. As mentioned above the only information I would
have received about the Horizon system would be through business
communications. I cannot recall any concerns or any reason why this was not

sufficient.

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Other Matters

103. I do not have any other reflections on these matters or any other

matters relevant to the Inquiry's Terms of Reference and there is nothing else

that I would like to bring to the attention of the Chair of the Inquiry.

Statement of truth

I believe the content of this statement to be true.

Dated: \ I \o/2o2

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Index to First Witness Statement of Glyn Allan Burrows

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No.

URN

Document Description

Control Number

4

POL00032698

Assurance Review - Recruitment
(Vetting & Training) (version 1.0, 27
October 2009)

POL-0029633

POL00086765

Network auditing approach, methods
and assurance” (2013)

POL-0083823

POL00088453

Training & Audit Advisor (undated)

POL-0085511

POL00088557

Audit Advisor (undated)

POL-0085615

POL00084650

Audit Plan & Scheduling, Chapter 1 of
the Audit Process Manual (Version 8)
(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-0084685

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-0084730

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 Audis (version 1,
April 2015)

POL-0084672

19

FUJ00001894

Audit Trail Functional Specification
(version 8.0, 18 October 2004)

POINQO008065F

Page 33 of 35
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20 I POL00002841 I Global User Account (September 2016) I VISO0003855
21 I POL00104747 I Casework Management Document POL-0080387
(version 1.0, March 2000)
22 IPOL00104777 I Casework Management Document POL-0080417
(version 4.0, October 2002)
23 I POL00118096 I David Posnett’s email dated 23 May VIS00012685
2011 re Casework Compliance
24 IPOL00118108 I Security Operations Team - Case VIS00012697
Compliance
25 IPOL00118109 I Guide to the Preparation and Layout of I VISO0012698
Investigation Red Label Cas Files. File
construction and appendicesA,B & C
26 IPOL00118101 I Guide to the Preparation and Layout of I VISO0012690
Investigation Red Label Case Files.
Offender reports & Discipline reports
27 IPOL00118102 I Offence Report Template VIS00012691
28 I POL00118103 I Offence Report Template VIS00012692
29 IPOL00118104 I Identification Codes VIS00012693
30 IPOL00118105 I Summarising of Tape Recorded VIS00012694
Interviews guidance
31 I POL00118106 I Notebook guidance VIS00012695
32_ I POL00118107 I Case Raise Facing sheet VIS00012696
33 I POL00118110 I David Posnett’s email to you and others I VISO0012699
dated 27 April 2012
34 IPOL00118120 I Summarising of Tape Recorded VIS00012709
Interviews guidance
35 I POL00118121 I Notebook guidance VIS00012710
36_I POL00118122 I Case Raise Facing sheet VIS00012711
37 I POL00118123 I Security Operations Team - Case VIS00012712
Compliance
38 IPOL00118124 I Guide to the Preparation and Layout of I VIS00012713
Investigation Red Label Case Files. File
construction and AppendicesA, B & C.
39 I POLO0118125 I Guide to the Preparation and Layout of I VISO0012714
Investigation Red Label Case Files.
Offender reports & Discipline reports
40 I POL00118126 I Offence Report Template VIS00012715
41_IPOL00118127 I Investigation Report Template VIS00012716
42 I POL00118128 I Identification Codes VIS00012717
43 I POL00093714 I Witness Statement in the Proceedings POL-0093836
against Carl Page
44 IFUJ00122250 I Witness Statement of Andy Dunks POINQ0128464F
45 I POLO00093908 I Case File Events Log: Rugeley MSPO POL-0094030

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46 I POLO00093733 I Witness Statement of Kevin Orgill dated I POL-0093855
31 March 2003

47 I POL00093897 I Witness Statement of Deborah Alison POL-0094019
Edwards dated 31 March 2003

48 I POLO00062201 I Expert Accountant's Report of David POL-0058680
Liddell R v Carl Adrian Page

49 I WITNO1510100 I First Written Statement of Mr Carl Adrian I WITN01510100
Page

50 I POLO0066040 I Audit Report — Ten Acre Street Branch POL-0062519
dated 3 May 2005

51 I POL00044541_I Investigation Report: Seema Misra POL-0041020

52 IPOL00044613 I Summary of Facts: Post Office Limited v I POL-0041092
Seema Misra

53 I POL00066397 I Special Request of an Audit of Accounts I POL-0062876

54 I POL00044389 I Investigation Report: Josephine POL-0040868
Hamilton

55 I UKGIO0014734 I Email Chain re South Warnborough UKGI025527-001
0929042

56 I POL00067205 I Email chain Re South Warnborough POL-0063684
0929042

57 I POL00046485 I Investigation Report: Susan Jane POL-0042964
Rudkin

58 I POL00044623 I Summary of Facts: Post Office Limited v I POL-0041102
Susan Jane Rudkin

59 I POL00061712 I Email from Doug Brown POL-0058191

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