WITN09230100 Keith Noverre - Witness Statement

Evidence on official site

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Witness Name: Keith Noverre
Statement No.: WITN09230100
Dated: 20" October 2023

POST OFFICE HORIZON IT INQUIRY

FIRST WITNESS STATEMENT OF KEITH NOVERRE

1, Keith Noverre, will say as follows:-

Introduction

1. Iama former employee of Post Office Ltd and held the position of Auditor

between September 2003 and October 2016.

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 17 August
2023 (the “Request”). The focus of this statement is my position as a Branch

Auditor at the Post Office and the prosecution of Mrs Seema Misra.

Background

3. My Post Office career was as follows:
i) September 1986 — May 1992 Counter Clerk.

ii) May 1992 — October 1997 — Cash Centre (Watford and Hemel

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Hempstead) — numerous roles.

iii) October 1997 — September 2003 — Cash management team (St
Albans and London).

iv) September 2003 — August 2008 — Auditor.

v) August 2008 — October 2016 — Auditor / Trainer (Field support team).

The above dates are approximate dates as I cannot remember exactly when I
changed roles. I remained an Auditor until I left the Post Office in October

2016.

4. As to qualifications I had no qualifications relevant to the audit role. I was
given full on the job training to ensure I carried out my role to a high level and
in a professional manner. The role was to visit a branch and verify financial
assets due to the Post Office was being accounted for accurately and
compliance matters were adhered to in branch as per guidelines. My line
manager was Mr. Warren Hattrell. All my colleagues were professional and
competent in carrying out our role. I just reported our findings to the Contract
Manager and if applicable Investigations Team. I do not know how many
audits I attended. The process was to ensure branch was in compliance with

their financial declarations and to ensure procedures were followed.

The audit process and the policies/practices in place

5. I have been asked to provide an account of my role and the policies and

practices in place in relation to the audit process. I have no recollection of the

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policies and practices.

Recruitment and training of auditors

6. I have been asked to describe the process by which auditors were recruited.

I have no recollection of the recruitment and training of auditors.

7. I have been asked to consider the 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].

8. I have no recollection of the any of the above.

9. I recalled that auditors were recruited internally, and I am not aware of the
process. As I was not involved in this process I am not aware of what
qualifications were required. Training was mainly based in branch but I
believe induction training was given. I personally had sufficient training to

carry out my role.

10. In August 2008, the audit and training teams merged together to form Field

Support Team.

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The planning and scheduling of audits

11. I have no recollection of the planning and scheduling of audits as this was

administrated by the administration team.

12. Ihave been asked to consider document “Audit Plan & Scheduling, Chapter

1 of the Audit Process Manual” (Version 8.0) (2010) [POL00084650}.

13. The scheduling of audits was completed by the administration team. It was
my understanding that they prepared a weekly audit schedule giving priority

to special audit requests.

The auditing process

14. I have been asked to consider documents:

i) “Audit Charter” (version 4.0, undated) [POL00083966];

ii) “Performing a Branch Audit”, Chapter 3 of the Audit Process
Manual (version 5.1, May 2010) [POL00084801];

iii) “Core & Outreach Audit Process”, Chapter 3a of the Audit
Process Manual (version 1.0, 27 May 2011) [POL00085534];

iv) “Follow Up Audit Process”, Chapter 3b of the Audit Process
Manual (version 3.0, May 2015) [POL00087627];

v) “Performing a Cash Centre Audit”, Chapter 7 of the Audit Process
Manual (version 5.0, Aug 2016) [POL00088252];

vi) “Quality Assurance”, Chapter 11 of the Audit Process Manual

(version 5.0, Apr 2015) [POL00087672];

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15.

vii)

viii)

x)

xi)

xii)

xiii)

“Post Incident Auditing without Horizon”, Chapter 14 of the Audit
Process Manual (version 1.0, Nov 2006) [POL00084003].
“Condensed Guide for Audit Attendance” (version 2, Oct 2008)
[POL00084813];

“Requirement of Network Field Support Advisors at audit,
following discovery of discrepancy” (version 1.0, Oct 2011)
[POL00085652];

“Network auditing approach, methods and assurance” (2013)
[POL00086765];

“Training Guide: Compliance Audit Tool” (Sep 2015)
[POL00087688];

“Training-Aide for Branch Asset Checking” (version 1.7, Nov
2014) [POL000877 16];

“Terms of Reference Audits” (version 1, April 2015)

[POL00087614].

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If I discovered a discrepancy I would make the postmaster or manger aware
of our findings and check as to whether there was any other cash or stock not
been accounted for before informing the Contracts Manager. If the
discrepancy was small we would ask the postmaster to ensure the
discrepancy is made good by the completion of their next balance period. I
always gave the postmaster an opportunity to check all our figures to ensure
they agreed with our result and findings. I would explain the purpose of our
visit prior to commencement and keep them updated as the audit progressed.

I always explained if they had any questions or concerns during the audit they
16.

17.

18.

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could let me know. If access to the Horizon system was unavailable, as far
as I can remember, we would not be able to complete an audit as we would

have no details of what the branch should have on hand.

I have also been asked to consider documents:
i) “Audit Trail Functional Specification” (version 8.0, 18
October 2004) [FUJ00001894];

ii) I Global User Account (September 2016) [POL00002841].

I have no recollection of the above.

I was not aware of what Fijitsu had in the audit process and not aware of any
information I could access that a postmaster could not have on Horizon. I

cannot recall what an Audit Global User account was.

Prosecution of Mrs Seema Misra

19.

I have been asked to consider documents:

i) my audit report (dated 16 January 2008) in respect of the audit
conducted on 14 January 2008 of the West Byfleet (Branch Code
126023) branch at [POL00049500],

ii) the personnel/investigation report at [POL00066052],

iii) the investigation/legal report at [POL00044589],

iv) a list of witness statements from the trial of R -v- Misra (including my

statement from pages 3 to 6) at [POL00058438].

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Audit of the West Byfleet branch

20. I was requested to attend an audit at West Byfleet on 14 January 2008. I
believe this was a routine audit as far as I can remember. I had never had
any communication with Mrs Misra prior to this audit. I recalled that the
purpose of the audit was to verify financial assets due to the Post Office and
confirm compliance procedures and regulatory requirements were adhered
to. I was assisted by two colleagues Sue Le May, Field Support Advisor and
Chris Stevens, Field Support Team Leader. When Mrs. Misra arrived at the
branch at approx. 10.45 am she immediately asked to speak to me and made
me aware the branch would be short by between £50k and £60k. During our
discussion Mrs. Misra explained a member of staff had taken £89k and she
did not report this as she was worried the branch would be closed. I am
unaware if anyone from the Post Office had informed Mrs Misra that if she
was out by a certain amount her branch would be closed. I reported the
shortage to Paul Dawkins, Investigation Team Manager and Tony Hills,
Network Compliance Audit manager. I cannot recall whose decision it was to
suspend Mrs. Misra. I also cannot recall if I asked Mrs Misra to prepare a
hand written note to explain the discrepancy. During the audit I obtained from
Horizon print outs that included an Office snapshot, Balance snapshots from
each stock unit, Suspense Account Report, previous Branch Trading
Statement, Remittances In and Out figures for this Trading Period. On
completion of the audit I reported the findings of the audit, in my report to

Elaine Ridge, Contracts Advisor, Paul Dawkins, Investigations Team

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Manager, Gerry Conran, Business Development Manager, Tony Hills,
Network Compliance Audit Manager and the Outlet Intervention Team. I have
also attended two other court cases in relation to losses. I cannot recall the
names of either Sub Postmaster or the names of the Branches. Witness
statement was completed at request of Investigations Team. I cannot recall
any discussions I had with POL’s legal representatives or who helped prepare
my draft witness statement, but I was made aware I would be called to give

evidence.

21. I have been. asked to consider my memo to Ms Elaine Ridge at

[POL00049500]. I recalled that this was the findings of the audit.

Criminal proceedings

22. I was not surprised by the outcome of the trial. Regarding the challenge of
the integrity of the Horizon I cannot comment as I do not know the workings

of the system and was never made aware of such issues.

23. I have been asked to consider the Judgment of the Court of Appeal in
Josephine Hamilton & Others v Post Office Limited [2021] EWCA Crim 577
at [POL00113278], in particular at paragraphs 198 to 209 on Mrs Misra’s

case.

24. My reflections on the Mrs Misra’s conviction are that these are the findings of

the court and I have no views on the outcome.

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General

25. I have been asked whether I had, or was aware of, any concerns regarding
the robustness of the Horizon IT system during my time working for POL.
During my career with the Post Office I was not aware of any issues with the

Horizon system.

STATEMENT OF TRUTH

I believe the content of this statement to be true.

Dated: 20/10/2023

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Index to First Witness Statement of Keith Noverre

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No. URN Document Control Number

Assurance Review - Recruitment (Vetting

4. I POLO0032698 I & Training) (version 1.0, 27 October POL-0029633
2009)
Network auditing approach, methods and

2. I POLO0086765 assurance (2013) POL-0083823

3. I POLO0088453 I Training & Audit Advisor (undated) POL-0085511

4, I POL00088557 I Audit Advisor (undated) POL-0085615
Audit Plan & Scheduling, Chapter 1 of the

5. I POLO0084650 I audit Process Manual (Version 8.0) (2010) I POL-0081708

6. I POL00083966 I Audit Charter (version 4.0, undated) POL-0081024
Performing a Branch Audit, Chapter 3 of

7. I POL00084801 I the Audit Process Manual (version 5.1, May; POL-0081859
2010)
Core & Outreach Audit Process, Chapter

8. I POLO0085534 I 3a of the Audit Process Manual (version POL-0082592
1.0, 27 May 2011)
Follow Up Audit Process, Chapter 3b of the

9. I POL00087627 I Audit Process Manual (version 3.0, May POL-0084685
2015)
Performing a Cash Centre Audit, Chapter 7

10. I POL00088252 I of the Audit Process Manual (version 5.0, POL-0085310
Aug 2016)
Quality Assurance, Chapter 11 of the Audit

11.) POL00087672 Process Manual (version 5.0, Apr 2015) POL-0084730
Post Incident Auditing without Horizon,

12. I POL00084003 I Chapter 14 of the Audit Process Manual POL-0081061
(version 1.0, Nov 2006)
Condensed Guide for Audit Attendance

13. I POL00084813 (version 2, Oct 2008) POL-0081871
Requirement of Network Field Support

14. I POL00085652 I Advisors at audit, following discovery of POL-0082710
discrepancy (version 1.0, Oct 2011)

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Training Guide: Compliance Audit Tool

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15. I POLO0087688 (Sep 2015) POL-0084746

16.I POLO0087716 Training-Aide for Branch Asset Checking POL-0084774
(version 1.7, Nov 2014)

17.I POLO0087614 dors) of Reference Audits (version 1, April POL-0084672
Audit Trail Functional Specification (version

18. I FUJ00001894 8.0, 18 October 2004) POINQO008065F

19. I POL00002841 I Global User Account (September 2016) VIS00003855
Audit Report (dated 16 January 2008) in
respect of the audit conducted on 14

20. I POL00049500 I ary 2008 of the West Byfleet (Branch I POL-0045979
Code 126023)

21. I POLO0066052 I Personnel/investigation Report POL-0062531

22. I POL00044589 I Investigation/legal report POL-0041068
list of witness statements from the trial of R

23. I POL00058438 I -v- Misra (including Keith Noverre’s POL-0054917
statement from pages 3 to 6)
Judgment of the Court of Appeal in

24. I POLO0113278 I Josephine Hamilton & Others v Post Office I POL-0110657

Limited [2021] EWCA Crim 577

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