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Witness Name: Lynn Pumford Hobbs
Statement Number: WITN09010100
Dated: 6 July 2023
Post Office Horizon IT Enquiry
FIRST WITNESS STATEMENT OF LYNN P HOBBS
I, Lynn Hobbs, will say as follows...
Introduction
1.
I am completing this statement at the request of the Horizon Inquiry following
receipt of a Rule 9 request dated 6 April 2023, relating to Phase 4 of the
Inquiry and my involvement in action taken against Subpostmasters by Post
Office Limited and my witness statement is in response to the questions asked
in the annex attached to that request.
I am a former Post Office employee having officially left the business in March
2011. I started work in the Post Office in January 1972 as a counter clerk and
during my career I covered numerous roles at various levels from clerical to
senior management. At the time I left and from October 1986 I worked within
Post Office Ltd (POL) previously Post Office Counters (POCL).
This witness statement is based on my personal recollection of events, policies
and processes and to this end I should add that my role in POL ceased in
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December 2010 and I have limited recollection of the specifics of my roles
within the business. I would also add that my memory has not only been
affected by the passage of time but also by health issues I experienced during
the last few years I was employed and I must therefore apologise if some of
my responses appear vague.
. [was given access to a very large number (93) policy, process and other
documents by the enquiry to assist me in compiling this statement. During my
discussion with a member of the inquiry solicitor team I queried why I had been
asked to review documents dated after December 2010, the date I ceased
working in POL. The inquiry accepted my point that to review documents dated
after I had left the business may distort my recollection of events, policies and
processes. I have therefore not reviewed any documents in my egress pack
with a date later than December 2010 or any undated documents unless, on
opening the document, it was immediately obvious that it was applicable to the
period prior to December 2010; this reduced the number of documents I
reviewed to 43, still, I believe, a substantial number. I have therefore limited
my reading to certain paragraphs where these were specified.
. After considering my personal known commitments in April and May, I
requested a further five weeks to complete this statement, however, I was
granted an additional two weeks.
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6. I would also wish to make the inquiry aware that I took a conscious decision
not to watch any broadcasts or read anything related to the Horizon Inquiry so
this statement is my first and I trust my only involvement in the inquiry.
7. I have not sought legal representation in the drafting of this statement.
Relevant Background
8. During the time I worked for the business there were a number of re-
organisations including the major reorganisation setting up Post Office
Counters (POCL) and Parcelforce as separate businesses within the Royal
Mail Group. POCL later became Post Office Ltd (POL) and there followed a
number of internal reorganisations during my employment. As it is over twelve
years since I left the business my recollection of job titles both my own and
others may not be accurate.
9. I started working for the Post Office after leaving school when I was sixteen. I
began my career working on the counter and held a number of clerical, junior
and middle manager roles until I was promoted to my first senior manager role
as Personnel and Services Manager, Leeds District, in 1989.
10. Following a business re-organisation in 1993/94 I became Head of HR for
North East Region, followed by Head of Network Support and finally Head of
Retail Network in 1999.
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11.Head of Retail Network North (NE Region) 1999-Sept 2001 — I was one of two
Heads of Retail Network in the North East Region and my area covered
Newcastle, Darlington and York. I managed a team of Retail Network
Managers (RNMs) who in turn were responsible for supporting around 1000
Directly Managed, Franchise and Sub Post Offices.
12.Head of Network Reinvention (Sept 2001- April 2005) — I was responsible for a
team which designed and delivered a radical programme to change the
structure of the Post Office branch network.
13.General Manager Service (April 2005 - Sept 2006) — this was a transitional
role. I was responsible for delivering a range of support services to all
branches and enabling the development of a revised organisation structure.
14.General Manager, Network Support (previously Head of Outlet Support) (Oct
2006- Dec 2010) — responsible for delivering performance standards,
regulatory compliance, agents’ contract management, staff training and
latterly, following the merger of the training and audit teams, assuring business
assets and compliance with ‘in branch’ transaction processes across the
franchise / sub office network and for the completion of financial audits at
Crown branches. During this time I also had responsibility for a several ‘one-
off business projects for example the conversion of Crown branches to WH
Smith franchise branches, the rollout of paypoint terminals to branches and
providing in-branch support for the roll-out of Horizon On-line. I had 7 senior
manager direct reports who were accountable for delivering the above Network
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Support responsibilities on a day to day basis which they did through a core
team of 200 staff which increased when projects were undertaken.
Contractual liability of subpostmasters for shortfalls
15.I have been asked about my understanding of the contractual position relating
to franchisees, and subpostmasters in terms of their responsibility for losses
identified in their branches. My understanding was that they were responsible
for making good losses in their branches although there were a number of
circumstances in which full or partial relief could be granted. This differed from
that of employees working in Crown (Directly Managed) branches in that
employees were responsible for declaring any losses or gains over a specific
amount (I think this may have been £5 but I cannot be certain) and there was a
process, which I believe formed part of the discipline code, for manging how
excessive numbers of misbalances were dealt with.
The audit process and the policies / practices in place
16.I've been asked to provide an account of my role as General Manager,
Network Support and also to provide information on policies and procedures in
place relating to audit practices. I was accountable for delivering performance
standards, regulatory compliance, contract management, staff training and
latterly, following the merging of the audit and training teams, I was
responsible for delivering audit processes which were in place to ensure
business assets and monitor compliance to specific processes, across a
network of over 11,000 sub post office and franchise outlets. I was also
responsible for providing audit resource to complete financial audits in the
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Crown network. I had a team of senior managers working to me and they and
their teams were responsible for the day to day delivery of each of these
accountabilities. In terms of policies and practices I am unable to provide any
detail on these and can only say my recollection is that the Network Support
team would have operated in line with policies, processes and practices in
force at the time. I was specifically asked to consider seven documents in
relation to this and other questions on organisational structure, however only
document [POL00083966] — Audit Charter was relevant as the remainder were
created after I left the business therefore my responses are mostly based on
my recollections.
Organisational Structure
17.I have been asked to summarise the changes to the organisational structure of
the audit team and to explain my understanding of the reasons behind them.
There were a number of reorganisations during the time I was employed and I
am unable to say how any of these impacted on the organisational structure of
the audit team. I can however say that around 2008 (I am not clear of the exact
date but it would likely be March / April to coincide with the year-end) the audit
team were merged with the training team to become the field support team
with team members given additional training to upskill them to enable them to
carry out audit and training tasks. Prior to this merger the audit team had, I
believe, worked in the Risk and Compliance team which I believe was part of
the Finance Directorate. Following the merger the team became part of the
Network Support team which was part of the Network Directorate. The reason
for the merger was in line with the business requirement to deliver the best
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outcome whilst also aiming to maintain and, where possible, reduce costs;
merging these two teams and multi-skilling team members enabled more
efficient use of resources.
18.In terms of the relationship between the audit team and other teams in POL my
recollection is that on occasions the audit team received requests to audit
specific branches from both the security and debt recovery teams when Post
Office funds were considered to be at risk. Findings would be reported back to
these teams and also the relevant contract manager if shortages in Post Office
funds were discovered.
19.I have been asked whether I considered it important that the audit team had
organisational independence. I was of the view that whilst the merging of the
audit and training teams created a bigger team capable of completing audits at
branches and being more responsive to training needs the team remained
independent in terms of its requirement to confirm business assets and
compliance with specific internal and external policies and processes.
20. I have also been asked whether I can recall any concerns being raised about
the independence of POL’s auditing activities and I cannot recall any concerns
being raised with me about the integrity or independence of the audit process.
I would add that the Risk and Compliance committee were fully aware of the
proposed change before the merger took effect and the Network and Finance
Directors were required to agree the structural change before it could proceed.
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The audit process
21.1 have been asked a number of questions about specifics of the audit process.
In my role as General Manager, I was not involved in the day to day activity of
the audit team and my responses are therefore based on my limited
recollection of discussions with Network Support Managers about the
processes followed by the team.
22.I have been asked about the sources of information an auditor would have
been expected to consider when completing an audit and also to discuss
whether information varied according to the type of audit being conducted.
From memory I am unable to say what specific information was considered by
an auditor when completing an audit. However, I have been given access to
the document catalogued as [POL00084801] which is Chapter 3 of the Audit
Process Manual and is entitled “Performing a Branch Audit”. This covers this
particular point in detail. I have already stated that the Network Support team
would have operated in line with policies, processes and practices in force at
the time and I therefore do not feel I can add anything to this document or that
spending a significant amount of time summarising that document in this
statement would add value.
23.My understanding is that if a discrepancy was discovered during an audit the
auditor would recheck their work and have a conversation with the
subpostmaster to try and identify other areas to check. My understanding was
that the auditor would aim to identify the cause of any shortfall before finalising
the audit in branch and would involve the subpostmaster in trying to identify
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the cause of any shortfall. I am unable to provide any further details on
additional enquiries or investigations the auditor would carry out.
24.1 have been asked if I was aware auditors had been given instructions on
taking payments from subpostmasters. I was not aware of any such
instructions. My understanding was that if the outcome of the audit was a
shortfall in funds the subpostmaster was asked if he/she was able to make
good the shortfall or asked for proposals for making good the shortfall. If the
shortage was over a specific amount or the subpostmaster had concerns
about making good the shortfall the auditor contacted the relevant Contract
Manager for advice.
25.1 have been asked about whether a subpostmaster could carry out their own
investigations if a shortfall was discovered. My understanding is that on the
day of the audit the auditor would discuss the shortfall with the subpostmaster
to try and identify possible causes and also that the subpostmaster would have
access to the Horizon system to carry out checks to try and identify the reason
for any shortfall. However, in a case where the contract advisor determined
the subpostmaster should be suspended pending further investigation, I do not
think the subpostmaster would be able to access Horizon data after the
suspension.
26.1 have been asked about what information was communicated to
subpostmasters while an audit was in progress. Subpostmasters were
expected to remain in the secure area whilst the audit was being conducted to
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ensure they were satisfied with the process being followed and to answer any
questions the auditor had. I am aware that in reality this did not always
happen as the majority of subpostmasters had other business activities
running alongside their post offices. However, my recollection is that when
any discrepancies were identified these were discussed with the
subpostmaster or their representative and they would have an opportunity to
check what the auditor had found to ensure they were satisfied with the
findings.
27.1 have been asked whether there was an opportunity for subpostmasters to
raise issues or concerns during an audit and my recollection is that anything
the subpostmaster raised as a concern would have been relayed to the
relevant contract manager.
28.1 have been asked whether it was possible to conduct a branch audit when the
Horizon system could not be accessed. I have read document [POL00084003]
which provides detailed instructions on completing a post incident audit in
circumstances where the Horizon equipment in branch is damaged and this
confirmed my recollection that a full audit could not be completed without
access to the Horizon system in branch.
29.My recollection of a Crown Office audit is that this did not necessarily involve a
check of every individual stock in the branch whereas a sub post office audit
did. I believe the reason for this was because Crown Office branch managers
checked individual clerks’ stock units on a rotational basis.
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30.1 have been asked about involvement Fujitsu had in the audit process and I am
unable to say whether Fujitsu had any involvement in the audit process. In
providing my response I have considered the document [FUJ00001894] Fujitsu
Services Audit Trail Function Specification (v8.0), however, as this is a
document I cannot recall ever seeing my answer is based only on my
recollection.
3
.I have been asked about information an auditor may have when conducting an
audit that was not available to the subpostmaster. I believe the only
information an auditor may have had would have been information related to
specific reasons for the audit if it had been requested by another team from
POL e.g. the Security team.
32.1 have been asked about my understanding of the Audit Global User Account
and been asked to consider document [POL00002841] in giving my response.
This document is dated September 2016 so I have not considered it and can
say that I have no recollection of the Audit Global User Account and therefore
cannot comment on the specific workings of the tool or information contained
within it.
Reporting and oversight
33.1 have been asked about the role of the Risk and Compliance Committee and
about my involvement with the committee. From recollection and by
referencing relevant documents I would say that the role of the Risk and
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Compliance Committee was to review business performance in relation to
financial, legal and operational compliance, and specific business projects, to
enable current and potential business risks to be identified and understood and
to direct future activity to enable business risks to be minimised. I became a
member of the committee in March 2008. I assume I would have remained a
member of this committee until the latter part of 2010 but am unable to confirm
that.
34.1 have been asked to comment on my involvement in the analysis or review of
the actual audit process. My involvement was in the merging of the audit and
training teams. I cannot recall any specific involvement in any analysis or
review of the audit process.
35.1 have been asked to say whether I considered the audit process to be fit for
purpose and also to comment on whether I now feel the process was fit for
purpose. I am able to say that during the time I had overall responsibility for
the audit process I was satisfied that it was fit for purpose otherwise I would
have initiated a review of the process. I would add that it is easy to say with
hindsight that any process could be improved.
36.1 have been asked to explain my involvement in error notices, transaction
corrections and acknowledgements, branch discrepancies, “corrective action”
taken against subpostmasters and recovery of agents’ debt and to explain
policies and practices in place at the time. I have been asked to clarify my
response by roles I covered, dates and policies relevant at the time. I have
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been asked to address a number of documents as part of my response. I am
unsure of the level of detail I am expected to provide, however, having read
the documents I have been asked to refer to [POL88904], [NFSP00000043}],
[NFSP00000169], [POL00085794], [POL00030562], [POL00083951],
[POL00083952]' [POL00005888], [POL00105417], [POLO00003060],
[POL00084012]' [POL00084075], [FUJ00091215], [POL00001642],
[POL00088904], [POL00086845], and [POL00088867] I can see there is
significant information in these in relation to how the above items were dealt
with and where the responsibility lay for dealing with such items. I have
therefore provided a brief summary of my involvement as I cannot recall
specifics related to each of the above. I would also add that in carrying out my
role and responsibilities I would have referenced appropriate policies and
operated within the processes in force at the time, however, with the passage
of time, I am unable to refer to specific policies and practices.
37.Between 1989 and 1993 I was Personnel & Services Manager at Leeds
District and part of my role was to support Area Managers who were
responsible for managing subpostmasters and Crown branches in their area. I
would provide advice and guidance related to subpostmaster contractual
matters which may have included issues related to error notices and agents
debt.
38.Between 1999 and 2001 I was Head of Retail Network in the North East
Region. I managed of team Retail Network Managers (13 or 14 I think) who
were responsible for providing support to the branches in their area. As part of
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my role I had responsibility for the write off of agents’ debt up to a level of my
financial authority.
39. Between 2005 and 2006 I was General Manager Services and from 2006 until
late 2010 I was Head of Outlet Support / General Manager Network Support
and in these roles I had responsibility for the write off of agents’ debt up to a
level of my financial authority.
40.In terms of my involvement in error notices, transaction corrections and
acknowledgements, branch discrepancies, “corrective action” taken against
subpostmasters and recovery of agents debt I am unable to provide specific
details of my involvement but I would say I would probably have seen reports
containing information, data and statistics and would also have provided
advice and support if required by my direct reports on issues related to any of
the above in my role as line manager.
Error notices, transaction corrections, transaction acknowledgements
and branch discrepancies
41.1 have also been asked very specific points about error notices, transaction
corrections, transaction acknowledgements and branch discrepancies and in
each instance my response would have to be simply to search through
documents and retype the statement in the document as I cannot add anything
more to what is in the relevant documents I have been referred to.
42.1 have been asked what role the suspense account had in the accounting
process followed by subpostmasters. I believe the suspense account was
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used by subpostmasters to hold losses following a misbalance pending further
investigation and to ‘settle’ transaction corrections the subpostmaster wished
to query. I think that by using this facility the cash account could be completed
without the error showing as a loss or gain. This was a short term measure (I
think items should have remained in suspense for no longer than 8 weeks) to
enable further investigations.
43.1 have been asked whether the only option available to a subpostmaster who
received a transaction correction (“TC”) they didn’t understand or wished to
challenge was to telephone NBSC Helpline. I do not understand this question
as I have read the document “Debt Recovery Processes under Branch
Trading” [POL 00085794] which clearly states that if a subpostmaster receives
a TC they don’t understand or they wish to challenge they should contact the
telephone number given on the TC. Having looked at the example TC in the
document I can say that I believe the telephone number on that example TC.
was not the NBSC Helpline number but a telephone number in what I knew to
be the Product and Branch Accounting team in Chesterfield.
44. The document indicates that “Accept and Settle Centrally” was a facility
available if a subpostmaster was not able to identify the reason for the
discrepancy identified in the TC to enable further investigations to take place.
45.1 cannot say with any certainty that the “Accept and Settle Centrally” facility
was the only option available to a subpostmaster if they considered the error
was a result of a systems error but from recollection I would have to say I
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believe such a challenge would be treated as an error requiring further
investigation and that the subpostmaster would be advised to “Accept and
Settle Centrally”.
46. From recollection I would say that “Accept and Settle Centrally” was used to
indicate further investigation was required and did not signify acceptance of
debt liability as the investigation may have resulted in the TC being cancelled.
47.1 cannot recall a block on steps to recover centrally settled debt, this may have
been after I left POL so I am unable to say whether there was anything to
distinguish disputed from undisputed debt.
48.1 was not involved in the process for investigating challenged TCs and had no
reason to think that the process for challenging errors was anything other than
acceptable and designed to ensure TCs could be disputed and investigated.
At the time I considered the process to be acceptable. In response to the
question about whether I now consider the “settle centrally” process to be
satisfactory again I would say that it is easy to say with hindsight that any
process could be improved.
49.1 would accept that TCs were issued to branches on the assumption that the
error had been created in branch and that the onus was on the subpostmaster
to challenge TCs they considered were wrongly issued.
Recovery of current and former agents’ debt
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50.1 have been asked to explain the role of the P&BA team (later to be known as
FSC) and also to explain my role in the recovery of current and former agents’
debt. I have been asked to address a number of individual points as part of
this question.
5
.My understanding of the role of P&BA is that they were responsible for all
matters related to branch transaction accounting and reconciliation to enable
settlement with clients and for managing errors resulting from branch
transactions with branches and with clients. I appreciate this may be a
simplistic explanation of the role of that team. I cannot comment on whether
the role changed after 2010.
52. If a subpostmaster chose the ‘settle centrally’ option to manage a shortfall or a
transaction correction this allowed time for further investigation. If further
investigation did not resolve the shortfall the subpostmaster was required to
make good the shortfall. I believe there was a follow-up process for
outstanding amounts but I am unable to provide detail on that process. I’ve
specifically been asked about the “dunning” process but I have no recollection
of that process so am not able to comment.
53. If a subpostmaster would not or could not pay a debt I would expect this would
have been referred to the Contract Manager to discuss next steps with the
subpostmaster.
54.In some instances current subpostmasters were given the opportunity to repay
debt by deductions from remuneration. This was dependent on the amount of
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the debt and subject to levels of scrutiny related to the number of occasions
the subpostmaster had made use of this facility.
55. I’m unable to comment on the circumstances which would result in P&BA
raising concerns about a branch although I would have expected that they
would have certain triggers which would prompt such action.
56.In terms of recovery of debt from former subpostmasters my recollection is that
this was the responsibility of a team in P&BA who also engaged with other
business teams such as Security & Investigation and Legal Services. I am
unable to describe the end to end process from memory however, from
reading document [POL00084977] I can see that it involved attempts to
recover the money by telephone, letters and further escalation to Security &
Investigations and Legal Services always being mindful of the cost of recovery
versus the actual cost of the debt.
57.1 cannot say with certainty but would not have expected P&BA to have any role
in recovering debt from current or former crown office employees.
58.In terms of teams in POL involved in debt recovery and branch conformance in
addition to P&BA and Network Support teams I believe Business Development
Managers and Security and Investigation would also be involved. There may
have been other teams with some involvement but I am unable to name these
teams.
Relief from accounting losses / Write off processes
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59.1 have been asked to explain the circumstances in which relief could be
granted from accounting losses and / or debt written off. The most obvious
circumstances were following robberies or burglaries when the full amount of
the debt was written off unless there was very strong evidence of contributory
negligence on behalf of the subpostmaster. New subpostmasters who had not
previously run a Post Office branch were able to have losses written off during
their first six weeks of trading. There were other instances where relief could
be granted and there were policies in place to facilitate this [POLO0088904],
[POL00086845] and [POL00088867].
60.1 have been asked how frequently a subpostmaster’s debt was written off by
POL. I am unable to answer this question as subpostmaster debt could be
written off by a number of people in roles across the business.
Civil claims and other debt recovery proceedings
61.1 have been asked about the circumstances which would result in civil claims
or other debt recovery proceedings being instigated against current or former
subpostmasters and against current or former Crown Office employees
including whose decision it was to bring such proceedings and what role if any
I had in the process. I have assumed this question refers to the involvement of
processes external to the business and I cannot recall being part of the
decision making process related to civil claims or other external debt recovery
proceedings being instigated against current or former agents or current or
former Crown Office employees.
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62.1 am unable to comment on either the mediation scheme or any review
undertaken by Second Sight as I understand these were undertaken some
time after I left the business.
Suspension and termination
63.1 have been asked to explain my involvement in policies and practices in place
in respect of suspensions, terminations and the appeals process. I was
involved to varying degrees with suspensions, terminations and the appeals
process from 1989 to when my role ended in December 2010. I was trained
as an Appeals Manager around 1993/94 (apologies I cannot remember the
exact date) and remained a member of the Appeals panel until December
2010. During that time I would have heard appeals from subpostmasters
whose contracts had been terminated and employees who had been
dismissed. Whilst I cannot provide specific details in respect of policies and
processes I would have followed the policies and processes in force at the
time. I would add that it is likely I was involved to some degree in reviews of
relevant policies and processes but I am unable to recall specific reviews or
level of involvement.
64.1 have been asked a number of questions relating to the suspension of
subpostmasters and the termination of subpostmasters contracts. I was asked
to consider a number of documents as part of the response, however the vast
majority of these documents were dated after December 2010 or were undated
and from information contained in the undated document it was clear they
were dated post December 2010. My responses are therefore based on my
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own recollection and the following documents: [POL00084993],
[POL00089004), [POL00084002}, [POL00005856}, and [NFSP00000511]
65.1 have been asked a number of questions about the Contract Manager role in
relation to discrepancies or shortfalls discovered at audit and about the
process followed by them. If a discrepancy or shortfall above a specified level
was discovered at audit the auditor would contact the Contract Manager to
advise them of the outcome of the audit and inform them of their findings
including any comments made by the subpostmaster in relation to the
discrepancy / shortfall. If the audit had been specifically requested by another
POL team they may also have information from that team about the reason for
the audit. The Contract Manager would fully question the auditor to ascertain
all known facts before making their decision in respect of next steps. They
could consult with a more experienced colleague or their line manager if they
felt they required further guidance. The Contracts Manager had the authority
and was responsible for making the decision related to next steps and he / she
would advise the auditor of that decision. If the decision was to suspend the
subpostmaster my recollection is that the Contract Manager would either
speak to the subpostmaster to advise them that they were being suspended,
the reasons for the suspension and discuss what would happen next in respect
of the branch and their contract or if for some reason that wasn’t possible then
the auditor would be asked to convey the same information. The Contract
Manager would then take steps to maintain service by appointing a temporary
subpostmaster to run the branch (the appointment of a temporary
subpostmaster would be on the basis that the current subpostmaster was
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prepared to let a temporary subpostmaster operate the branch from their
premises). The Contract Manager would then follow the conduct process to its
conclusion which would either result in the re-instatement of the
subpostmaster or the termination of his/her contract.
66.In terms of whether a subpostmaster had the opportunity to make
representations about the decision to suspend them then they could do so by
speaking to the Contract Manager and, if they felt it appropriate, they could
make representations to more senior managers in the Network Directorate.
67.My recollection is that a subpostmaster was not remunerated during their
period of suspension. If a temporary subpostmaster was appointed they could
negotiate a payment with the temporary subpostmaster for use of their
premises.
68.Contract Managers made the decision to terminate a subpostmaster’s contract
after a full investigation and an interview where the subpostmaster could make
personal representation and could be accompanied by an NFSP
representative or a colleague at that meeting who could also make
representations / provide information on their behalf.
69. If the decision was made not to terminate a subpostmaster’s contract after a
period of suspension the subpostmaster would be re-instated.
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70.My recollection is that subpostmasters who had been suspended because of
cash shortages and whose contract was subsequently terminated were
summarily terminated without notice.
71.1 have been asked about whether subpostmasters had the right of appeal
against the decision to suspend them. The suspension was precautionary to
enable a full investigation to take place and to my knowledge a subpostmaster
did not have a right of appeal against the decision to suspend them.
72.I have been asked about whether subpostmasters had the right of appeal
against the decision to terminate their contract and about the process. All
subpostmasters whose contracts were terminated either with or without notice
had the opportunity to appeal that decision. The subpostmaster had a period
of time in which to lodge an appeal and then the appeal was allocated to a
member of the appeals panel who would have been a senior manager trained
to handle appeals.
73. The individual had all the previous investigation information used to make the
decision and any new information they requested. The role of the manager
allocated to hear the appeal was to investigate and rehear the case. It was
usual for a subpostmaster to attend an appeal meeting and for them to be
accompanied at that meeting by an NFSP representative or a colleague. At
that meeting the subpostmaster had every opportunity to put forward reasons
why their contract should not be terminated and the person accompanying
them could also make representations on their behalf. The appeals manager
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could request additional information if they felt that would be helpful in making
their decision on whether or not to uphold the appeal. The appeal manager
would ensure they had fully reviewed all of the evidence plus information
provided by the subpostmaster and their representative before making their
decision.
74.1 have been asked to explain about changes made as a result of the Network
Transformation Programme. I can confirm that the programme introduced the
concept of Core and Outreach and that a number of branches were closed as
part of the programme, however, I am unable to recall other changes made as
a result of the programme.
75. The appeal decision was final; however, a subpostmaster could always contact
the Network Director or the Chief Executive if they wished to do so. Whilst this
was not a formal part of the appeal process that avenue was always open to
any subpostmaster.
76.1 have been asked about my role in reviewing policies and guidance applicable
to suspensions, terminations and the appeals process. I cannot recall a
specific role I had in reviewing any of these processes; however I may have
been asked to comment on proposed changes to one or more of these
processes.
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Knowledge of bugs, errors and defects in the Horizon system
77.1 have been asked whether I was aware of a trend of increasing debt and
average audit loss and whilst I am unable to recall being aware of such a trend
I note from [POL00107129] that year on year from April 2007 to June 2010 the
percentage of agents suspended and audit shortages to audits completed was
declining .
78.I have been asked if I had, or was aware of, any concerns relating to the
robustness of the Horizon system during the time I worked for POL. I can
confirm that from my perspective, as an operational manager, I did not have
concerns about any aspect of the Horizon system in terms of its operation,
accuracy or integrity. I am aware that there were a small number of
challenges around the integrity and accuracy of the system, however, there
were assurances being given from within the business that the system was
robust. I note from document [POL00105565] that I was asked to provide
information to enable the business to consider a response to a Channel 4
programme. I assume with input from my team that I would have provided the
information requested but cannot recall the programme or whether the
business provided a response to the programme. I have also read Rod Ismay’s
report at [POL107129] and from information in this report I can see that at
Appendix 3 there is a report from Fujitsu that covers a number of points related
to Horizon data integrity and describes failure scenarios and measures in
place to ensure data integrity in each scenario. I had no reason to consider
that the assurances being given by the business were not accurate and I
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certainly did not have the technical expertise to question these assurances
given by the business or Fujitsu.
79.1 have been asked if I can recall auditors being instructed to disregard possible
problems with Horizon as a possible cause for shortfalls or audit
discrepancies. I cannot recall such an instruction being given.
Other Matters
80.1 have been asked if there are any other matters I consider the Chair of the
Inquiry should be aware of and can confirm that in relation to my own
recollections there are no further matters I think need to be considered.
Statement of Truth
I believe the content of this statement to be true.
Signed:I G RO
Dated: 6 July 2023 «
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Index to First Witness Statement of Lynn Hobbs
No.
URN
Document Description
Control Number
POLO0083966
Audit Charter (version 4.0, undated)
POL-0081024
POLO0084801
“Performing a Branch Audit”, Chapter 3
of the Audit Process Manual (version
5.1, 2010)
POL-0081859
POLO0084003
Post Incident Auditing without Horizon,
Chapter 14 of the Audit Process
Manual (version 1.0, 1 November 2006)
POL-0081061
FUJO0001894
Fujitsu Services Audit Trail Function
Specification (v8.0)
POINQOOO8065F
POLO0088904
Post Office Ltd Policy on Losses and
Gains within the POCL Agency Network
— Version 1 (20 November 1998)
POL-0085962
NFSP00000043
Negotiating Committee for Horizon
debt recovery (18 November 2004)
VIS00007491
NFSPO0000169
Letter circulated to the National
Executive Council enclosing
correspondence regarding debt
recovery process (17 December 2004)
VISO0007617
POLO0085794
Post Office - Debt Recovery Process
under Branch Trading — October 2005
POL-0082852
POLO0030562
Post Office Ltd — Losses Policy —
Overarching (Branches) (version 9,
effective date April 2006)
POL-0027044
10
POLO0083951
Appendix 3: Process for Awaiting TC
(Transaction Correction) - Multiples —
Version 1
POL-0081009
11
POLO0083952
Appendix 4: Process for awaiting TC
(Transaction Correction) - singletons —
Version 1
POL-0081010
12
POLO0005888
Dealing with discrepancies revealed at
audit — Version 1 (undated)
VISOO006956
13
POLO0105417
Summary of discussion on compliance,
conformance, losses and debt (3 March
2008)
POL-0104525
14
POLO0003060
Post Office Limited - Process
Documentation - Branch Correction
Process (TCs) — Version 2.0 (undated)
VIS00004074
15
POLO0084012
Transaction Correction / Debt Recovery
Process (undated)
POL-0081070
16
POLO0084075
Post Office Ltd Mandatory Losses &
Gains Policy in the Crown Office
Network (September 2008)
POL-0081133
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17
FUJO0091215
Feasibility Study carried out on
Interfacing Client Data into POL
Systems (Project PING) (25 March
2009)
POINQ0097386F
18
POLO0001642
Review of the Creation and
Management of Transaction
Corrections in POLFS to Correct
Accounting Errors in Horizon — Version
1.0 (10 February 2010)
VISO0002656
19
POLO0088867
Post Office Ltd: Liability for Losses
Policy for agency branches — Version
2.0 (January 2004)
POL-0085925
20
POLO0084977
Post Office, Former SPM End to End
Debt Review v.0.5
POL-0082035
21
POLO0088904
Post Office Ltd Policy on Losses and
Gains within the POCL Agency Network,
dated 20 November 1998
POL-0085962
22
POLOO086845
Post Office Ltd Security Policy:
Accounting Losses Policy for Agency
Branches
POL-0083903
23
POLO0088867
Post Office Ltd: Liability for Losses
Policy for agency branches v2.0 January
2004
POL-0085925
24
POLO0084993
Contract Advisor Process - Audit
Discrepancy flowchart
POL-0082051
25
POLO0089004
Managing Agents Contracts :
Guidelines for the line manager Version
3
POL-0080965
26
POLO0084002
Outlet Support — Audit Contact Points
(Version 2, September 2006)
POL-0081060
27
POLOO005856
Post Office Ltd - Appeals Handbook -
2001
VISO0006924
28
NFSP00000511
National Federation of Subpostmasters
Report of a Meeting of the National
Executive Council on 15-17 June 2009
VISO0008969
29
POLO0107129
Memo from Rod Ismay to Dave Smith
Mike Moores and Mike Young Re
Horizon - Response to challenges
regarding system integrity, 2 August
2010
POL-0105437
30
POLOO105565
Email from Lynn Hobbs to Adrian
Wales, John Breeden and others re
Channel 4 programme, 21 July 2010
POL-0104561
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