WITN09080100 Deborah Alison Edwards

Evidence on official site

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Witness Name: Deborah Alison Edwards
Statement No.: WITN09080100

Dated: 24 October 2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF DEBORAH ALISON EDWARDS

I, Deborah Alison Edwards, will say as follows...

Introduction

1. This witness statement is made to assist the Post Office Horizon IT Inquiry
(the "Inquiry") with the matters set out in the Rule 9 Request dated 23 August

2023 (the "Request").

2. The facts within this statement have either come from my own recollections
and knowledge or rely on the documentation that has been provided by the
Inquiry. As these events happened over 16 years ago I am unable to recall
specific events but have provided as much detail as possible in order to assist

the Inquiry.

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3.

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I can 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.

Relevant Background

4.

lam a former employee of Post Office Limited ("POL"). I joined POL in June

1989 and left the company on 30 September 2016.

During my employment at POL, I worked in several different roles. My first
role was as a Counter Clerk where I worked until 1995 when I became a
Branch Auditor. As a Branch Auditor I would visit POL branches to audit
branch cash and stock, ensuring subpostmasters and their staff members
were compliant with POL process. I left this role in July 2007 to become a
Field Change Advisor where I would assist branches who were planning to

refurbish or relocate.

In June 2009 I became Assistant Branch Manager at Crewe Crown Branch
Office. As Assistant Branch Manager my role was to manage POL employed
staff members, plan weekly duties including seating plans and break times,
coach the team in sales and complete random and unannounced stock unit

checks.

In February 2012 I moved to become Property Project Manager ("PPM"), a

role I held until I left POL in September 2016. As a PPM I visited branches at

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the request of Field Change Advisors, working with the subpostmaster to plan
and calculate the cost of changes to physical counters. During my time in the
Property Project Team, I took a temporary promotion to Senior Property

Project Manager between May 2015 to October 2015.

. The Inquiry has asked me specifically about my position as a Field Support
Advisor ("FSA"). I did not hold the job title of FSA as this role came in much
later than when I was in the team and I had already moved roles. My job title
was Branch Auditor. After six years working as a Counter Clerk I applied for
the role of Branch Auditor and was successful at interview. The role involved
me attending Post Office branches to verify assets and check procedures
were being adhered to. When I started in the role I had good experience of
working in a Post Office branch from my time as a Counter Clerk. In my role
as a Counter Clerk I would help the subpostmaster count the cash and stock
on hand in branch to help them complete the branch accounts each week.
Also as Crown Office Counter Clerk I would help with counting cash and stock
and doing the weekly account for the stock unit I worked on. Completing

these tasks gave me good experience for the work I did as a Branch Auditor.

. After being successfully appointed as Branch Auditor I initially spent time
accompanying the other Branch Auditors on audits and was shown the
processes and procedures to follow. I mainly learnt the role from on-the-job
training, shadowing and mentoring. I was given competencies to complete to
demonstrate my ability to do the role. I cannot recall the exact details now but

remember this focused on specific elements of the role such as calculating the

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value of pension payments or building the branch balance. Over time I would
have less coaching and would need to demonstrate to my line manager that I
had met specific competencies as they observed me on audits. When I was a
Branch Auditor, I worked for several line managers although I can now only
remember the names of two; Glyn Burrows and Kevin Orgill. During my time
in the role, I felt I was always treated with respect and professionalism. I felt
competent in the role and had no concerns with the competency of my

colleagues.

10. During my time as Branch Auditor, I did not have any responsibility for
disciplinary matters or interviewing those accused of criminal offences. I had
no involvement in disclosure for criminal or civil proceedings or litigation case
strategy. My role was limited to the audit of the branch and concluded when
the audit report had been completed. I had no further involvement in
progressing cases or liaising with other Post Office departments. The only
time I can recall any further involvement was when a case had gone to court
and I was asked to produce a witness statement, however such requests were

unusual.

1

.I estimate I attended approximately 3 audits per week during my time as a
Branch Auditor. I cannot remember the names of the different branches but

would attend a broad range offering different services.

The audit process and the polices/practices in place

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12.During my time in the Audit Team my role as Branch Auditor would involve me
verifying POL assets, by counting cash and stock (for example postal stamps,
saving stamps, postal orders etc) and completing post audit reports to ensure
assets were tracked and branches were complying with the business
requirements and standards. It is over 16 years since I was a Branch Auditor,
and I can no longer recall the policies and practices that were in place in
relation to the audit or when these policies and practices changed during the

time period.

Recruitment and training of Auditors

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

i. “Assurance Review - Recruitment (Vetting & Training)” (version 1.0, 27
October 2009) (POL00032698);
ii. “Network auditing approach, methods and assurance” (2013)
(POL00086765);
iii. “Training & Audit Advisor” (undated) (POL00088453);

iv. “Audit Advisor” (undated) (POL00088557).

14.In regard to the first two documents, the Assurance review (POL00032698)
and Network auditing approach, methods and assurance (POL00086765),
both these documents were produced after I was in post as a Branch Auditor.
In regard to the other last two documents, Training & Audit Advisor

(POL0008453) and Audit advisor (POL00088557) I do not recall previously

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seeing these documents but note that the role of Training & Audit Advisor was
a role that came in after I had left the Audit team. I do recognised elements of

the Audit Advisor description which formed part of my role.

15.I never recruited anyone during my time as Branch Auditor and my only
experience of the recruitment process was when I was recruited into the team.
I can no longer recall the recruitment criteria or how the selection process was
completed. I applied for the role as an internal candidate, was interviewed
and was successfully appointed. I remember there were internal people, like
me, recruited into the team from other areas of POL but do not remember if

they tended to come from specific teams.

16.1 am unsure if there was a minimum level of qualification and/or experience
before you could conduct a branch audit. I did not have any specific
qualifications for the role but had good experience of Post Office branches.

As set out above, Audit training was completed on the job and a Line Manger
would have to sign off a Branch Auditor as compliant. I was nota line
manager in the Audit team and did not conduct this process but was signed off
compliant when I was inducted into the team. I cannot recall the criteria that
would have been used to assess whether a Branch Auditor was compliant but
remember it was based on achieving specific competencies as I have noted

above.

17. It is over 16 years since I was a Branch Auditor, and I can no longer recall the

finer detail of any induction, training or refresher procedures. As far as I recall

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following my appointment I attended audits and shadowed colleagues for a
number of months to learn the audit process. The length of time spent
shadowing was dependent on how long it took an individual to learn the tasks
for the role. This could be dependent on the types of audits they were
shadowing as not every branch would include the full set of procedures and it
may take longer to ensure an individual was fully compliant. Once a person
was considered compliant they would be observed by an Audit Manager and,
where appropriate, signed off as compliant. Following this induction period
Branch Auditors were also provided with mentoring from more experienced
colleagues to support their continued development. As a Branch Auditor you
had a yearly appraisal. The appraisal would review the work you had
completed in the previous year, review line manager observations and

consider whether you had met the expected standards.

18.From my experience working within the sub-Post Office and Crown network, I
believe I had the right skillset for the role of Branch Auditor. As a Counter
Clerk I had completed stock unit balances and cash accounts in branch for
some time and was fully conversant with how branch accounts were prepared.
I think this gave me a good understanding of how a branch operated and

manged its cash and stock on a day-to-day basis.

19.From what I can now recall I did not have any concerns about the training that

was provided or the ongoing support in the Audit team.

The planning and scheduling of audits

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20. The Inquiry has asked me to consider the document "Audit Plan & Scheduling,
Chapter 1 of the Audit Process Manual (Version 8.0) (2010)" (POL00084650).
I was not in post as an Auditor when this version was in place. I do not
remember any version of this document. Looking at the document it appears
that this would have been used by the Audit Manager and I do not believe it

would have been readily available to the Branch Auditors.

2

.I have very limited knowledge of the scheduling process as this was not part of
my role. I was only aware of the weekly schedule that was provided to me by
the Audit Manager. The weekly schedule would provide me with details of the
branches I would be auditing the following week, although it may provide for
slightly longer in exceptional circumstances, such as when the Audit Manager
was going on holiday. I am unaware of how the weekly schedule was

produced.

22.1 am also unaware of the circumstances in which branch audits were
scheduled, how promptly they were scheduled or how frequently a branch
would be audited. It was not part of my role to make any enquires or complete
an investigation before a branch visit and I am not aware of any steps that
were taken before an audit took place. My role was to verify Post Office
assets on site and did not extend to any actions taken before or after the

onsite audit except for preparing the audit report.

The Auditing Process

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23. 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),

1) Training-Aide for Branch Asset Checking (version 1.7, Nov 2014)
(POL00087716); and

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

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I have reviewed the documents and note that POL00085534, POL00087627,
POL00088252, POL00087672, POL00087614 and POL00087688 were not
published or available when I was in the role of Branch Auditor. I cannot recall

the other documents from my time in the role.

24.When commencing an audit a selection of reports would be collected from the
Horizon system. This was usually done by the Lead Auditor although they
would sometimes delegate this task to one of the Auditors. These reports
would be used to verify cash and stock items and to build the account of the
office which included checking receipts and payments. Cash on hand would
have been verified to the report held at the branch. This report would have
been completed by the subpostmaster or their staff at the close of business
from the day before. As far as I am aware the Auditors and subpostmasters
had access to the same information when an audit was conducted. From my
recollection there were no differences in the source information according to
the type of audit being conducted. I cannot recall any differences between

Crown Office branches and other branches when conducting an audit.

25.The Branch Auditor leading the audit would keep the subpostmaster up to
date with their progress throughout the audit. This would normally involve
letting them know when each unit of stock or cash had been counted and what
the outcome of that unit had been. During the audit the subpostmaster may be
asked to clarify if all cash or stock had been counted. Once the cash, stock
and receipts and payments had been verified, any discrepancies would be re-

verified and any discrepancies, shortfalls or surpluses were discussed with the

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subpostmaster. Time was allowed for the subpostmaster, if they wanted to, to
check the discrepancies and confirm them. Once discrepancies had been
checked, the result of the audit would be shared with the subpostmaster. After
the conclusion of the asset verification, a set of procedural question would be
asked. At the end of the procedural question section any points raised that
were not in line with current procedures were discussed with the
subpostmaster and guidance was given to enable the subpostmaster to
correctly follow the procedures. Branch Auditors were always available to
listen to subpostmasters’ questions or queries. If any queries or questions fell
out of the Audit domain, the Branch Auditor would ask the subpostmaster to

raise the query with the Helpline.

26.I was aware of the process of asking subpostmasters to make good any
shortfalls at the time of audit. I believe this was the subpostmasters'
contractual obligation. It was also the case that when a surplus was identified
the subpostmaster was informed and they could withdraw the surplus. I would
have been made aware of this process through my training and this practice
was in place throughout the period that I was a Branch Auditor. Where there
was a shortfall the Branch Auditor could accept cash and/or a cheque from the
subpostmaster to cover the shortfalls. I have been asked by the Inquiry for my
views on this practice and whether I questioned it at the time. I did not have
any views on this particular practice and accepted it as it was part of the

process. I did not question it at the time.

27.\f a discrepancy or shortfall was discovered the Lead Auditor would discuss

the details with the subpostmaster who would be given the opportunity to

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check that the discrepancies were correct. During the audit the
subpostmaster would be given the time he needed to check the discrepancy
amounts but! am unsure whether they had the opportunity to provide any
further information or undertake their own investigation into the discrepancies
as this would be dealt with by the Security/Investigation team and the Contract

Team after the audit was complete.

28. I have been asked by the Inquiry if it was possible to conduct a branch audit
in circumstances in which it was not possible to access the Horizon IT System.
Assets could be physically counted and then recorded on Branch Auditors’

computers to be verified once the Horizon system was re-instated.

29.The Inquiry has asked me to consider the documents Audit Trail Functional
Specification (version 8.0, 18 October 2004) (FUJ00001894) and Global User
Account (September 2016) (POL00002841). I cannot recall seeing or using
FUJ00001894 and I was not in post as Branch Auditor when POL00002841

was in place.

30. The Inquiry has also asked me whether Fujitsu were involved in the audit
process. As far as I can remember Fujitsu were not part of any audits I was
involved in and I am not aware of any involvement they had in the audit

process.

31.The Inquiry has also asked me to comment on the Audit Global User Account.

I do not recall the Audit Global User Account or any audit measures that were

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in place in respect of the Audit Global User Accounts so am unable to

comment any further.

Prosecution of Carl Page

32.1 have limited recollection of the prosecution of Mr Page as my role was limited
to completing the audit, as part of the audit team, and later completing a
witness statement. I do not recall much about these events and can only

recall completing the witness statement as it was provided to me by the

Inquiry.

Initial Investigation by Customs & Excise

33.1 was a member of the audit team who attended the Rugeley branch on 14
January 2003. I would have first been made aware of the audit by the weekly
audit plan which set out my schedule of work. I do not recall being made
aware of any of the issues at the branch prior to the audit and do not recall
when I first became involved in Mr Page's case, other than when I was asked

to complete a witness statement.

34.1 do not recall being made aware that HM Customs and Excise had raised
issues with this branch and I am not aware of them completing any audits. I
also do not recall being made aware of Staffordshire Major Crime Units

involvement prior to the audit that took place on 14 January 2003.

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35.In my experience as an Auditor it was normal practice for the Auditors to have
no prior knowledge of the issues before they attended an audit. This
protected the integrity of the audit by ensuring the audit was not prejudiced by
the ongoing investigation. The investigators may have an expected outcome
from the Audit but we would have no prior knowledge and would approach an
audit with no expectations of what we might find. We may be made aware
that an investigation or security manager would be attending the audit but we
would have no knowledge of their investigation. They would not be part of the

audit and we would only report the outcome to them.

Audit of Rugeley Branch

36.As noted above, the first I would have known about this audit was when I was
provided with the weekly audit plan, this would have been received the week
before. I was unaware of any circumstances surrounding the audit or why it
had been requested. My role was to ensure the audit was completed. I can
see from my Witness Statement in the proceedings against Carl Page
(POL00093897) that the audit appears to have been requested by the Post

Office Investigation Team.

37.1 am aware from the information shared by the Inquiry that there was a team of
four Auditors allocated to the audit of Rugeley Branch: myself, Kevin Orgill,
Glyn Burrows and one other. I cannot recall who the fourth Auditor was and
am only aware that Mr Orgill and Mr Burrows were the other Auditor's that day

by the information that has been shared by the Inquiry.

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38. Tasks on any audit are allocated by the Lead Auditor. From reading my
Witness Statement (POL00093897) I can see that I was allocated to check the
foreign currency stock unit that day. I cannot recall the events of that day but
under the normal process when each task was complete audit documentation
would be returned to the Lead Auditor providing the results of the checks and
highlighting any discrepancies. At this point discrepancies would be shared
with the subpostmaster who would be given time to verify them. The Lead
Auditor would then prepare the overall account for the branch to determine the
overall branch position. This would involve the Lead Auditor inputting into
their laptop the results from the Auditors' counting and checks to calculate the
overall position of the branch i.e. whether there was an overall shortfall or

surplus.

39.1 do not recall any discussions I had with either Mr Page, Manish Patel or any
of the investigators during the audit but usually when I have identified any
discrepancies I would discuss them with the Lead Auditor who would then
arrange for them to be shared with the subpostmaster and anyone else as

appropriate. This would also enable the Lead Auditor to write the audit report.

40.1 cannot recall the details of the outcome of the audit but using the information
within my Witness Statement (POL00093897) and the Expert Accountant's
Report of David Liddell (POL00062201) as a reference point, they indicate a

number of discrepancies were found. Unfortunately, after the time that has

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now passed I am unable to remember any further details in regard to these

discrepancies other than what is exhibited in these documents.

.I cannot recall the documents I considered in the audit but can see from my

Witness Statement (POL00093897) that I would have been responsible for
collecting any Horizon reports and reports from the Forde Moneychange. I
would have recorded the values of the currencies, stock items and Travellers
Cheques on hand. This was specific to the tasks I had been allocated by the
Lead Auditor. I was not responsible for completing any documents after the

audit. This role would normally be completed by the Lead Auditor.

42.I have been asked by the Inquiry whether ARQ logs were sought by POL from

Fujitsu in this case and, if not, why not? I am not familiar with the term ‘ARQ
Logs' and cannot confirm if they were sought by POL from Fujitsu in this audit

or any other audits which may be relevant to the Inquiry.

43.1 have also been asked by the Inquiry whose decision it was to suspend Carl

Page. I have no recollection of any discussions in regard to the suspension of
Carl Page and as an Auditor would not expect to be made aware of this
decision. I would expect this decision would be made by the Investigation
team and would not require the input of the Auditors other than in providing

information from the Audit.

44.My role as Branch Auditor was to count cash and stock items on hand in

branches using information and documents held at the branch. I was not part

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of the Post Office Investigation Team and did not have any involvement in any

further investigations of Mr Page.

R v Carl Page

45. The Inquiry has asked if I have been involved in any other proceedings
against SPMs, their managers or assistants or Post Office employees
involving the Horizon IT system before this case. I do not recall any other
proceedings due to the time that has now elapsed but as noted above, on rare
occasions I would be asked to provide a witness statement by the
Investigations Team. This would involve me setting out the steps that were
taken at Audit. I cannot recall any other involvement, or whether they
specifically involve Horizon issue. I was never asked to attend Court as a
witness but was aware that by producing a witness statement I could have

been called.

46.1 was asked to complete a Witness Statement (POL00093897) in the case
against Mr Page and Mr Whitehouse. I cannot recall who asked me to
complete this document but this request would normally be made by the Post
Office Security and Investigations Team. I also cannot now recall who I had
contact with when completing this document. The discussions would be
reflected in the content of the Witness Statement but I cannot recall any
further discussions that I had with counsel or POL's legal representatives

about my witness statement.

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47.1 can see from the Letter from Ms Debbie Helszajn to Mr Tom Cleary dated 11
April 2005 (POL00067102) that I was listed as a witness required in this case.
I was aware that by completing a witness statement I may be called to give
evidence and I provided my availability. However, I cannot recall being told
the date of the court case or that I would not be called. I did not give evidence
at the trial. I do not recall any other involvement I had in this case and I do not

recall being made aware of the outcome of the proceedings.

48. The Inquiry has asked me to consider the Judgment of the Court of Appeal in
Josephine Hamilton & Others v Post Office Limited [2021 EWCA Crim 577] in
particular paragraphs 277 to 285 (POL00113278) and what my reflections are
now on the way the investigation and prosecution of Mr Page was conducted
by Post Office. I have no reflections on the investigation and prosecution
made by Post Office Limited. My understanding of the investigation is limited
to the audit and I appreciate there has been a much wider investigation and
prosecution. I do not feel I can comment any further on these issues as I was

not part of the investigation.

The Prosecution of Tahir Mahmood

49.As with the case of Mr Page, I have limited recollection of this case. My only
involvement was as part of the audit team and later completing a witness
statement. I can only confirm completing the Audit Report as it has been

provided to me by the Inquiry (POL00066040).

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The Audit at Ten Acre Street Branch

50.1 do not recall any events which led to the audit of Ten Acre Street Branch and

5

taking into account normal process I do not believe I would have been aware
of the case against Tahir Mahmood when I was asked to complete the audit.
I would not be aware of the circumstances that had led to the audit and I
would have received notification of the audit through the weekly audit plan.
Although I do not recall any details of why the audit was requested I can see
from reading the Audit Report (POL00066040) that it was requested by the

Internal Crime Team.

.I can also see from the Audit report (POL00066040) that I was the Lead

Branch Auditor that day, assisted by Guru Aubby. As was normal process I
would have allocated us both tasks. The cash on hand would have been one
of the first tasks to be completed, alongside the collection of reports from the
Horizon system. I expect I would have built the account for the audit on a
laptop, as Mr Aubby counted the stock items. All discrepancies would have
been checked and the subpostmaster, or their staff, asked if they wanted to
check the discrepancies. Once the physical verification had been completed
the result of the audit would have been shared with the subpostmaster. I can
see from the Audit Report (POL00066040), although I cannot recall this
directly, that two members of the Internal Crime Team were present, they
would not have played any part in the audit but would have been advised of

the outcome. From what I recall when member(s) of the Internal Crime Team

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(this is the former name of the Investigation and Security Team) attended an
audit they would wait for the outcome so they could speak to the

subpostmaster. I would not be part of those discussions.

52. Due to the time that has passed since I was a Branch Auditor I cannot recall
all of the documents that would have been considered during the audit. I recall

this would have included:

a) Acopy of the branch monthly accounts (known as a cash account and
in later years branch trading statement);

b) Audit reports from Horizon; and

c) Voucher/Receipt for customer payments/cheques on hand.

I cannot recall if this is a full list of documents.

53.1 cannot recall any direct conversations I had with the Internal Crime
Managers who were present at the audit but can see from my Audit Report
(POL00066040) that after asking Mr Mahmood a question, I refer the
response to Colin Price, from the Internal Crime Team, who then spoke to Mr
Tahir Mahmood. Having read the document, I would have indicated to the
security team what the result of the audit was, and where the discrepancies
are and any disclosures from the subpostmaster to explain the discrepancies.
I am afraid after this time I cannot recall the details of this discussion. At the
conclusion of the audit, I would have advised the result of the audit check,

giving details of any discrepancies.

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54. Again, I cannot recall any direct conversations I had with Mr Mahmood during
the audit. I note from reading my Audit Report (POL00066040) that I asked
Mr Mahmood ‘was there anymore Post Office cash in hand.’ This would be
normal and Auditors would ask subpostmasters to confirm that everything had

been counted.

55.Whilst I do not recall the outcome of the initial audit I can see from reading the
Audit Report (POL00066040) that the audit notes a total discrepancy of

£33,437.39. This amount is made up of:

a) Cash on hand difference of £33,575.72
b) Cheque on hand difference of £200.37
c) Stock difference of £66.83

d) Previous weeks balance result £4.79

56.1 have been asked by the Inquiry whether I considered the shortfall unusual in
my experience and whether I had any concerns about it. It is important to note
that the Audit team were required to approach audits without prejudice, and
we were not there to form an opinion on the reasons why there were
discrepancies. On occasion a subpostmaster may provide a reason for a
discrepancy which would be recorded however this would be for the
Investigations team to consider and not the Auditor. I would not ask any direct
questions of the subpostmaster to establish the reasons for the losses and my
role was to establish factually whether there was a surplus or deficit in the

branch. Therefore, in answering this question I did not consider the shortfall

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unusual at the time and would expect this to be a matter of concern for the

Investigations team.

57.Following the audit I would have completed an audit report. This is exhibited
at document POL00066040. I can see from this document that the report was

provided to:

a) Sue Mudderman — Contract and Services Manager
b) Colin Price — Investigation Manager

c) Martin Ferlinc — National Branch Audit Manager

d) Glyn Burrows — Data Analyst.

e) John Jenkinson — Operations Manager — Branch Audit Team.

58.1 do not recall any other involvement I had in this case, and I do not recall

being made aware of the outcome to the proceedings.

59.1 have read the Judgment in Josephine Hamilton & Others v Post Office
Limited (POL00113278) in particular paragraphs 319 to 323 and what my
reflections are now on the way the investigation and prosecution of Mr
Mahmood was conducted by Post Office. I have no reflections on the
investigation and prosecution made by Post Office Limited. My understanding
of the investigation is limited to the audit and I appreciate there has been a
much wider investigation and prosecution. I do not feel I can comment any

further on these issues as I was not part of the investigation.

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Prosecution of Hughie Thomas

60.As with Mr Page and Mr Mahmood's prosecutions I have little knowledge of
the prosecution of Mr Thomas and my role was limited to the Audit of
Gaerwen Branch and later completing a witness statement. I can only recall

completing the witness statement as it was provided to me by the Inquiry.

The Audit at Gaerwen Branch

61.Again, as with both Mr Page and Mr Mahmood, I would not have been aware
of the circumstances or issues that led to the audit and would have received

my normal notification of the audit through the weekly audit plan.

62.1 was again the Lead Branch Auditor in this audit, assisted by Mal Rennard. I
would have followed the same process as the other audits set out above,
allocating tasks between myself and Mr Rennard. From reading my Witness
Statement for the Proceedings against Hughie Thomas (POL00047942), it
notes that Mr Rennard counted the cash on hand and I counted the stock
items on hand. All discrepancies would have been checked and the

subpostmaster/staff asked if they wanted to check the discrepancies.

63.1 cannot recall the details of the discussions I would have had with Mr Thomas
but note that some details are contained in my Witness Statement
(POL00047942). This document notes that Mr Thomas said, "it's been going

on for a year or so, I think something is wrong with the computers." After this

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time I cannot recall this comment or any further details that Mr Thomas
provided at the time. I cannot recall, prior to my involvement in these
proceedings, any other individuals attributing shortfalls to Horizon. As an
Auditor I would refer any comments that were made to the Contracts Manger
so they could be investigated further. It was not uncommon for
subpostmasters to provide explanations, but it was not my role to assess
whether they were legitimate concerns. If a subpostmaster provided a reason
for the shortfall the process would be to write the wording down and ask the
subpostmaster to sign it to say it was a true reflection of the discussion. I
would ensure this information was passed on through the audit report to the
Contract Manager who I would expect to assess whether there was any

further action required.

64.Whilst I do not recall the outcome of the initial audit I can see from reading my
Witness Statement (POL00047942) that the audit notes a total discrepancy of

£48,454.87. This amount is made up of:

f) Cash on hand difference of £48,157.79

g) Stock difference of £297.08.

65. The Inquiry has again asked me whether I considered this shortfall to be
unusual in my experience and whether I had any concerns about it. As was
the case with the audit of Ten Acre Street Branch I would not have reached
any conclusions on the discrepancies and would have left this for

consideration by the investigations team.

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66. The Inquiry has asked me to provide further details of my conversation with
Emlyn Hughes, Contract Manager, regarding discrepancies at the bank. I can
see from page 2 of the Offender Report for Hughie Thomas (POL00044861)
that the reference is to online banking. I called Mr Hughes but do not recall
the details of this conversation other than the purpose would have been to

inform him of the outcome of the audit.

67. The Offender Report (POL00044861) also notes that following the call Mr
Hughes and Steve Bradshaw from the Investigation Team arrived at Branch.
It also notes that Mal Rennard contacted the Horizon System Helpdesk.
Whilst I can see some of the details are provided in the Offender Report

(POL00044861) I cannot recall any further details regarding these events.
68. Following the completion of the audit I would have completed an audit report.

I cannot remember who the report would have been shared with, but normal

practice would be to report shortfalls to the Contracts Manager who in turn

may ask that it is also shared with the Security Team.

69. Following the completion of the report I cannot recall any further involvement

in this case.

Criminal Proceedings

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70.1 cannot recall the name of the person who requesting me to complete a
witness statement (POL00047942) in the case against Mr Thomas. This
request would normally be made by the Post Office Security and Investigation
Team but I can no longer remember and am unsure who would have

requested this statement.

7

-I also can no longer recall who I had contact with, or the discussions I had,
other than that which is apparent from my Witness Statement (POL0047942).
I do not recall being made aware that Mr Thomas had pleaded guilty to False

Accounting on 29 September 2006,

72.1 have read the Judgment in Josephine Hamilton & Others v Post Office
Limited (POL00113278) in particular paragraphs 149 to 155 and what my
reflections are now on the way the investigation and prosecution of Mr
Thomas was conducted by Post Office. have no reflections on the
investigation and prosecution made by Post Office Limited. My understanding
of the investigation is limited to the audit and I appreciate there has been a
much wider investigation and prosecution. I do not feel I can comment any

further on these issues as I was not part of the investigation.

General

73.1 have been asked by the Inquiry to what extent I considered a challenge to
the integrity of Horizon in one case to be relevant to ongoing or future cases.

As I have set out above, I was not primarily concerned with the reasons for the

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discrepancies in my role as this was the responsibility of others. I was focused
on completing the audit; therefore, it is unlikely I would have paid specific
attention to an individual challenge to the integrity of horizon and would have

expected this to be picked up through the subsequent investigation.

74.I have been asked by the Inquiry whether I consider investigations regarding
bugs, errors and defects in Horizon were sufficiently carried out by POL or
whether POL sufficiently passed information to Fujitsu. It was not my role to
investigate those matters at the time and I would not have been aware of any
information exchanges between POL and Fujitsu. I would expect that where
an audit flags up a discrepancy which could not be explained it would be
raised with the helpdesk and further investigations would be completed.
Alternatively, if reasons were shared with the Auditor this would be passed on
to the Contract Manager. I cannot recall what information was shared in
regard to bugs, errors and defects in Horizon, so cannot comment on whether
it was sufficient but do not consider that it was pertinent to my work area at the

time for the reasons set out above.

75.1 do not have any other matters to bring to the attention of the Chair of the

Inquiry or anything that I consider relevant to the Inquiry's Terms of Reference.

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Statement of Truth

I believe the content of this statement to be true.

om GRO-

Dated: 24 October 2023

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Index to First Witness Statement of Deborah Alison Edwards

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No. I URN Document Description Control Number

1 POL00032698 I Assurance Review - Recruitment (Vetting I POL-0029633
& Training) (27 October 2009)

2 POL00086765 I Network auditing approach, methods and I POL-0083823
assurance

3 POL00088453 I POL's advert for training and audit I POL-0085511
advisor role (undated)

4 POL00088557 I POL job poster for audit advisor role I POL-0085615
within loss prevention team (undated)

5 POL00084650 I Chapter 1 of Audit Process Manual — I POL-0081708
Audit Plan & Scheduling

6 POL00083966 I Audit Charter: Branch and Cash Centre I POL-0081024
Audit Activity - undated This policy
document sets out the standards and
code of ethics that apply to those staff
performing audits of branches and cash
centres within Post Office Ltd.

7 POL00084801 I Audit Process Manual: Chapter 3 - I POL00084801
Performing a Branch Audit (v5.1)

8 POL00085534 I Audit Process Manual: Chapter 3a - Core I POL-0082592
& Outreach Audit Process (v1.0)

9 POL00087627 I Audit Process Manual POL-0084685

10 I POL00088252 I Audit Process Manual Volume 4 - I POL-0085310
Chapter 7 Performing a cash centre audit

11 I POL00087672 I Audit Process Manual Volume 4: Chapter I POL-0084730
11 - Quality Assurance V5.0

12 I POLO00084003 I Audit Process Manual for compliance I POL-0081061
team process for auditing branches
without access to horizon

13 I POL00084813 I Condensed Guide For Audit Attendance I POL-0081871

14 I POLO0085652 I Requirement of Network Field Support I POL-0082710
Advisors at audit, following discovery of
discrepancy

15 I POL00086765 I Network auditing approach, methods and I POL-0083823
assurance

16 I POLO0087688 I Training Guide - Compliance audit tool v I POL-0084746
6.1

17 I POL00087716 I Training-Aide for Branch Asset Checking I POL-0084774
(v1.7)

18 I POL00087614 I Terms of Reference Audits POL-0084672

19 I FUJ00001894 I Fujitsu Services Audit Trail Function I POINQO008065F
Specification (v8.0)

20 I POL00002841 I Global User Accounts Guidance for I VISO0003855
Sandra McBride

21 I POL00093897 I Witness statement of Deborah Edwards. I POL-0094019

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22

POL00062201

Expert Accountant's Report of David
Liddell 2005, R-V-Carl Adrian Page

POL-0058680

23

POL00067102

Letter from Debbie Helszajn to Tom
Cleary of Frisby & Co Solicitors Re R v
Carl Adrian Page

POL-0063581

24

POL00113278

Approved Judgment between Josephine
Hamilton & Others and Post Office
Limited

POL-0110657

25

POL00066040

Letter from Alison Edwards to Sue
Mudderman re: Audit of Post Office Ten
Acre Street branch

POL-0062519

26

POL00047942

Witness statement of Deborah Alison
Edwards dated 2006 (RE: R v. Hughie
Thomas)

POL-0044421

27

POL00044861

Investigation Discipline Report by Diane
Matthews - Hughie Noel Thomas

POL-0041340

28

POL00066041

Post Office Ltd: Investigation, Personnel -
Offence Theft & False Accounting, Tahir
Mahmood

POL-0062520

29

POL00066748

Tahir Mahmood - 147000001.mp3 - Full
Transcript of Interview - part 1

POL-0063227

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