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Witness Name: Michael F MATTHEWS
Statement No: WITN09380100
Dated: 9 October 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF MICHAEL FRANCIS MATTHEWS
I, MICHAEL FRANCIS MATTHEWS, will say as follows;
1. This witness statement is made to assist the Post Office Horizon IT Inquiry
with the matters set out in the Rule 9 Request dated 23 August 2023.
2. I have been assisted by Priyesh Patel of DAC Beachcroft LLP in the
preparation and drafting of my statement.
BACKGROUND
3. I ama former employee of Royal Mail Group and Post Office Ltd (‘POL’) and
have held several positions across Royal Mail Group Security (RMGS') but
the most notable two are as follows:
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a. Firstly between 2005 and 2007 I was a Financial Investigator in
training, then an Accredited Financial Investigator (AF) for POL; and
b. Secondly between 2007 and 2018 I was the Procedures and Standards
Manager in Royal Mail Letters Security (RMLS), which became RMGS,
after separation from POL. RMLS who as the biggest team in RUGS
undertook functions for the whole of RMGS Including the preparation of
Procedures and Standards.
Relevant background
4. Between 1980 and 1990 I served in the Army, the first 5 years in the Army
Catering Corps and the second 5 years in the Royal Military Police. In the
military police I carried out general military police duties which included minor
criminal investigations.
5. Between 1990 and 1997 I was an Assistant Investigation Officer (AIO), then
Investigation Officer (10) in the Post Office Investigation Department (POID)
and then the Post Office Security and Investigation Services (POSIS). During
this time I was mainly employed on Royal Mail Investigations but I also
occasionally undertook investigations into losses and suspected theft and
fraud at Post Offices.
6. Between 1997 and 2001 I was employed as a trainer in the POSIS Training
Wing. The POSIS Training Wing offered training to all Investigators and
Security Managers across the different Business units in Royal Mail, such as
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Royal Mail Letters, Post Office Ltd and Parcelforce Worldwide. My role was to
develop and deliver training courses to all Criminal Investigators employed by
RMGS which included POL Criminal Investigators. During this time I received
a NVQ level 3 in Training and Development from Croydon College and a NVQ
4 in assessing Investigations which I believe was from the POSIS Training
Wing as it was an accredited NVQ Assessor Centre.
. In about 1999 we started to prepare for a large recruitment of about 80
recruits into the Investigation role across the RMGS. In the past the initial
training was a five-week residential course for Royal Mail Investigators which
was extended to six weeks for POL. Under the new system Investigators were
allocated 15 open learning modules which they were to complete under the
supervision of their mentor/line manager.
. These open learning modules covered all the theory of an investigation up to
the end of the suspect interview. Delegates then attended a two-week
residential course where they underwent practical exercises such as witness
interviews, suspect approach, searching and suspect interviews. None of this
training covered Horizon as that was the responsibility of POL to train their
Criminal Investigators “on the job”. This would have been by a mixture of
observing criminal investigators conducting tasks and then actually
undertaking tasks under the supervision of an Investigator.
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9. From 2001 to 2005 I moved to POL. For a short period of time I assisted in
Casework Management and then became a Commercial Security Manager.
Casework Management involved checking casefiles to see what action should
be taken. For example, should they be forwarded to the Criminal Law Team
(‘CLT’) for advice on prosecution, returned to the investigator for further
inquiry or filed as it was not possible to solve the case or identify who may
have been responsible.
10. During this time I was the second officer to Ged Harbinson at an interview of
4
Ms Tracy Felstead at Peckham Police Station. This will be discussed later in
this statement. Ged Harbison was an Investigation Manager at the time
responsible for the criminal investigation into Ms Felstead. I knew him
because I trained him in 2000.
.After some time I took up the role of Commercial Security Manager. This
involved liaising with POL product managers, reconciliation teams at
Chesterfield, outside commercial companies and Law Enforcement Agencies
in an attempt to secure products (such as foreign currency, postal orders and
stamps) from fraudulent activity and theft mainly from non-POL suspects. My
main product responsibilities were Foreign Currency, Banking Products and
Postal Orders. My only involvement in Horizon during this period was to write
communications to Branch staff which appeared on Horizon. For example a
message that appeared on Horizon, before a counter clerk accepted an
American $100.00 bill for exchange, to check the security features to make
sure that the bill was not counterfeit.
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12.Between 2005 and 2007 I was a Financial Investigator in training to be an
Accredited Financial Investigator. I become accredited under the Proceeds of
Crime Act 2002 by the relevant authority at the time, (Assets recovery
Agency). I was initially accredited to allow me to apply for Production orders
under the Proceeds of Crime Act 2002 and subsequently accredited to apply
for Confiscation under the Proceeds of Crime Act 2002. Being Accredited
earns a Business & Technology Educational Council Level 4 Qualification in
Financial Investigations.
13. Between 2007 and 2018 I become the Procedures and Standards Manager
for RMLS and later RMGS. My main responsibilities were to produce and
maintain Procedures and Standards (‘P&S’) for all Investigators across all the
different Business units. My role was explained to me by Ray Pratt as one
where the Senior Leadership Team would produce RMGS Policy which would
be high level and I would articulate what process were needed to be followed
to deliver the policy. Ray Pratt was my line manager and the Policy
Standards and Investigation Support Manager in Royal Mail Letters Security
(RMLS). The P&S were published on the Group Security Database to which
all RMGS Investigators (including POL) had access to. I do not know how the
Senior Leadership Team produced RMGS Policy. I was never present at any
meetings with the Senior Leadership Team where Policy was discussed.
14.1 do not know who in the Senior Leadership team produced Policy.
15.With the exception of explaining the process of how to obtain detailed
transaction data from Fujitsu, I cannot recall any of the P&S detailing how
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Horizon enquires were to be conducted. This was because this was the
responsibility of the POL Investigation Team which was a different business
unit to the one I worked in.
16. After some time, POL separated from RMGS completely. POL were able to
copy whatever P&S they wanted prior to separation and I had the task of
removing all irrelevant references to POL from the RMGS P&S.
Notwithstanding this at some time I produced the initial version of P&S 2.2
Joint Investigation Protocols RMGS and POL Security (Version 2 July 2015)
[POL00114559]. Procedures and Standards (P&S) should not be confused
with policies. I do not know who in POL decided which P&S they were going
to copy as I was in a different Business Unit (RMLS) at the time and no longer
had any responsibility for POL. I unable to comment on or whether the P&S
were copied directly, or whether any amendments were made, or by whom as
I was not a part of the copying process within POL.
17.When I had delivered the Set of P&S on the RMGS database, I also got
involved in training again. One of the Courses I delivered was a course on
preparing Trial papers including disclosure and this was based on a Royal
Mail casefile. I believe this was after separation and so POL Investigators did
not attend as at this time RMGS was a completely different business and my
course may have been delivered after Royal Mail Privatisation.
18.Between 2018 and 2019 I was the RMGS Helpdesk Manager following which
I took voluntary redundancy.
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19.1 have been asked how I became an Internal Crime Operations Manager. To
clarify, whilst I was with POL I was a Financial Investigator rather than a
Criminal Investigator. I was a commercial Security Manager on Joining POL in
2001 until 2005. In 2005 there was a reorganisation and I was appointed to a
newly created role of Financial Investigator with the view of becoming an
Accredited Financial Investigator (AF1). I never carried out any criminal
Investigations in POL (save second officer for Ms Felstead) or attended
Branches or audit for an investigation. I have never been responsible for a
criminal Investigation in POL whilst Horizon was in place.
20.With regard to training and relevant experience and expertise I undertook and
obtained Accreditation from the Assets Recovery Agency and became an AFI
but I would say I was very inexperienced. I was accredited under Part 2
Confiscation and Part 8 Investigation of the Proceeds of Crime Act 2002
(POCA 2002’).
21.My main role was to Identify a suspect's "benefit from crime" and then try to
identify “realisable assets” In order to prepare for potential Confiscation
Hearings under POCA 2002. Confiscation can only happen after a suspect
has been convicted of a crime from which they have benefitted. Normally
proceedings would not be commenced unless the benefit was more than
£5,000.00. This was a general rule with confiscation in the courts rather than
POL.
22.My Line Manager was Tony Utting I recall he was Head of Internal Crime at
POL.
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23.With regard to my colleagues I thought that my colleagues and managers
were both competent and professional.
24.1 was never an Internal Crime Operations Manager or Investigations Manager.
They were responsible for the investigation into the suspected criminal
offence. I was responsible for the conduct of the confiscation investigation.
Confiscation Proceedings at Court should only happen after conviction where
the defendant has benefited from criminal conduct.
25.1 had no role in disciplinary matters as the line manager of the person to be
disciplined was responsible for conducting discipline in accordance with
procedures in place at the time.
26.1 only interviewed one individual in relation to a Horizon shortage and that was
Tracy Felstead where I acted as second officer. I believed it was my role to
establish the truth of the matter, whether this pointed to innocence or guilt, in
accordance with the law in the case . With regard to interviewing a Suspect
that would have been in accordance with the Police and Criminal Evidence
Act 1984 and their Codes of Practice . Apart from that interview I did not
interview any suspects following the introduction of Horizon. As my role during
the Horizon period held no responsibility to interview suspects.
27.Disclosure in Criminal Proceedings was to be conducted in accordance with
the Criminal Procedures and Investigation Act 1996 Codes of Practice. Each
Investigator would have been issued with a copy of the Codes of Practice and
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they were subsequently available on the relevant RMGS databases to which
all Investigators had access. The fundamental principles are that anything that
would harm the prosecution or aid the defence must be disclosed to the
defence and all reasonable lines of inquiry should be pursued. I cannot recall
being involved in civil proceedings. Whilst conducting Financial/Confiscation
Investigations we kept a Policy Log which recorded policy decisions and
Event log which recorded all events in the case and a Document Schedule
listing all the documents in the case. I am sure these were revealed to CLT. If
we did come across anything that needed disclosure before any trial I would
have informed CLT.
28.1 believe that whilst conducting confiscation investigations I pursued all
reasonable lines of inquiry.
29.1 had no knowledge of Civil Litigation strategy, that would have been the
responsibility of the Civil Litigation Team in Legal Services.
30. With regard to Liaising with other Post Office departments I only ever liaised
with the Criminal Law Team on the progress of cases.
The Security team’s role in relation to criminal investigations and prosecutions
31.To the best of my recollection soon after I joined the POL security team in
2001 the team was organised into 3 Teams or “strands”. The largest team
dealt with Criminal Investigations. A second team dealt with procedural and
physical security on an operational day to day basis. The third team dealt with
Commercial Security and Technical Security. I think that team looked at new
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technology (such as alarms systems, smart water and cash carrying
systems).
32.In 2005 there was a reorganisation and that was when I was appointed to
Financial Investigator working in the Internal Crime Team. I think the teams
stayed much the same with a reduction in Senior Managers I cannot recall if
the number of Investigators was reduced.
33.In respect of "Royal Mail Group Security - Procedures & Standards - The
Proceeds of Crime Act 2002 & Financial Investigations" (version 1, September
2010) [POL00026573] - I authored this P&S and I would have sought Input
from Ged Harbinson. The P&S would then have been agreed my Line
Manager Ray Pratt (deceased) and CLT before publishing. I think this was the
first version of this document. I am sure I would have sought input from Ged
Harbinson as he was an AFI at the time. I would have used the training
material and the knowledge that I had received whilst in training and from
being an AFI. Prior to being published it would have been submitted to Ray
Pratt and CLT for assurance.
34. Ray Pratt was the Policy Standards and Investigation Support Manager in
Royal Mail Letters Security (RMLS). As RMLS were the biggest team of
investigators within RMGS they tended to take responsibility for central roles
such as Procedures and Standards (P&S) and the provision of equipment.
Ray Pratt was responsible for standards and compliance in RMLS and he
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wanted a comprehensive set of P&S for his investigators to follow. I was told
that the P&S were to be useable by POL but my priority was RMLS.
35.In respect of "Royal Mail Group Security - Procedures & Standards - Initiating
Investigations" (September 2010) [POL00104857]. I would have authored this
document using historic documents and existing custom and practice. When I
first joined there was an Investigators Staff Manual in hard copy. Over
reorganisations this manual was not updated and a Group Security Database
was created. Changes in the law such as Regulation of Investigatory Powers
Act 2000 and changers to lines of responsibility required such P&S to be
reviewed and updated. Again, it would have been assured by the Ray Pratt
and CLT before publishing.
36. In respect of:
a. "Conduct of Criminal Investigations Policy" (version 0.2, 29 August
2013) [POL00031005];
b. "Conduct of Criminal Investigations Policy" (version 3, 10 February
2014) [POL00027863]; and
c. "Conduct of Criminal Investigations Policy" (September 2018)
[POL00030902].
37.1 did not draft these documents and I believe they were produced after POL
separated from, RMGS, but I can recognise some “lifts” from RMGS P&S. For
example, General Rules for the Use of Notebooks.
38.In respect of, “Post Office Ltd PNC Security Operating Procedures” (August
2012) [POL00105229], I did not have any part in the management or
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development of this document and it was in all probability written around the
time of separation. RMGS did have a PNC Manager who produced P&S and I
suspect this is the source of the information in this document.
39.1 did not have any part in the management or development of "POL —
Enforcement & Prosecution Policy" ([POL00104968]).
40.1 have been asked about the Security Team’s role in relation to criminal
investigations and prosecutions and I confirm I had no part in development or
management of the following documents:
a. Casework Management Policy (version 1.0, March 2000)
[POL00104747] and (version 4.0, October 2002) [POL00104777];
b. Rules and Standards Policy (version 2.0, October 2000)
[POL00104754];
c. Investigation Procedures Policy (version 2.0, January 2001)
[POL00030687];
d. Disclosure Of Unused Material, Criminal Procedures and Investigations
Act 1996 Codes of Practice Policy (version 1.0, May 2001)
[POL00104762];
e. Royal Mail Group Ltd Criminal Investigation and Prosecution Policy (1
December 2007) [POL00030578] and [POL00104812];
f. Royal Mail Group Security - Procedures & Standards - Standards of
Behaviour and Complaints Procedure (version 2, October 2007)
[POL00104806];
g. Royal Mail Group Crime and Investigation Policy (version 1.1 October
2009) [POL00031003];
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h. Post Office Ltd - Security Policy - Fraud Investigation and Prosecution
Policy (version 2, 4 April 2010) [POL00030580};
i. Post Office Ltd Financial Investigation Policy (4 May 2010)
[POL00039965];
j. Royal Mail Group Ltd Criminal Investigation and Prosecution Policy
(version 1.1, November 2010) [POL00104912];
k. Post Office Ltd Financial Investigation Policy (version 2, February
2011) [POL00026582];
I. Post Office Ltd Anti-Fraud Policy (February 2011) [POL00104855];
m. Royal Mail Group Policy Crime and Investigation S2 (version 3.0, April
2011) [POL00030786];
n. Post Office Ltd PNC Security Operating Procedures (August 2012)
[POL00105229);
0. Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement (with flowchart) (October 2012) [POL00104929];
p. Undated Appendix 1 - POL Criminal Investigations and Enforcement
Procedure (flowchart) (October 2012) [POL00105226];
q. The undated document entitled “POL — Enforcement & Prosecution
Policy” [POL00104968}; and
r. Post Office Limited: Criminal Enforcement and Prosecution Policy
(undated) [POL00030602].
LEGISLATION
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41.All legislation that covered criminal investigations governed the conduct of
Investigations in POL. The main ones were Police and Criminal Investigation
Act 1984, Proceeds of Crime Act 2002 Criminal Procedure and Investigation
Act 1996, Regulation of Investigatory Powers Act 2000. RMGS also allowed a
“friend” at interviews and Post Office Young people were treated differently
until they had reached 18 years old.
POLICES
42.1 was not in POL post-separation I was in RMGS and had no part in the
development of their investigation policies. Notwithstanding they were able to
copy RMGS P&S prior to separation. I did develop RMGS P&S as detailed in
my answer to question 26 below but I had no part at all in POL Policy.
43.With regard to Post Office policy and practice regarding investigation and
prosecution of Crown Office employees differing from the policy and practice
regarding investigation and prosecution of SPMs, I was not aware of any
difference between policy and practice regarding investigation and
prosecution of SPMs and their managers and assistants.
COMPLAINTS
44. If the complaint happened in a custody suite at a police station it would be
reported to the custody sergeant and as soon as practicable a Senior
Investigation Manager (SIM) within RMGS. If it was not in a custody suite it
would be reported to a SIM as soon as practicable. A SIM who was out of the
direct reporting line would Investigate the complaint. POL while part of RMGS
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would have followed the same procedure. After separation I have no
knowledge of what their complaints procedure was.
45.If a complaint was made by member of staff or SPM they could approach their
Union or the Federation of Subpostmasters. Suspects were informed of their
right to have a friend present at a voluntary interview who could be a union or
federation representative. When in custody the custody sergeant was
responsible for ensuring the rights of the suspect.
SUPERVISION
46. Every investigator had a line manager. Line managers were supposed to have
regular one to ones with their direct reports where cases and caseloads were
discussed. The frequency of 121s changed during my time at Royal Mail as
sometimes it was monthly and other times as required. Records were kept
and action points would be agreed for discussion at the next 121. These
action points may well have included what action was to be taken in specific
cases.
Audit and investigation
47.1 have not seen the document entitled “Condensed Guide for Audit
Attendance” (version 2, October 2008) [POL00104821] prior to this witness
statement request and have not had a part in its production. I have never
attended a Horizon shortage Investigation audit. As such I have considered
the document and all I can say is that an investigator would attend if
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criminality was suspected and the loss met trigger points. The investigator's
role would be to investigate suspected criminality.
48.Where a shortfall was identified following an audit of a Post Office branch, the
SIM or investigation team leaders decided whether the matter was suitable for
a criminal Investigation based on a Trigger Point Document. I do not think it
changed unless a new trigger point document was produced. I cannot expand
on this as I cannot recall what was in the trigger document. I do not think that
the local contract manager had any input into the decision whether or not as
case was to be to criminally investigated, that was based on trigger points. The
local contract/appropriate line manager did however at one point make the
decision on whether to prosecute or not.
49.1 cannot recall what the triggers were for raising a fraud case following the
identification of a shortfall / discrepancy in a branch nor can I recall if they
changed.
The process followed by Security team investigators
50.1 did not conduct any Criminal Investigations following the introduction of
Horizon (Save being a second officer with Ms Tracy Felstead in I believe
2001). I think they would have acted in accordance with regard to legislation
and Post Office P&S.
51.Whilst working in POID in the 1990s, I investigated a few cash losses and
Pension and Allowance Fraud cases at Post Offices. I think the system was
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called ECCO but the evidence was paper based. My main responsibilities
however during this time-was Royal Mail Letter investigation cases.
Decisions about prosecution and criminal enforcement proceedings
52. Following an initial investigation, a file would be submitted to the CLT. They
would assess the evidence and decide if there was sufficient evidence to
prosecute and whether it was in the public interest. I believe they followed the
Code for Crown Prosecutors.
53. Initially a Manager in Suspect Offenders line management made the decision
on prosecution, subsequently it was a senior Human Resources Manager.
Finally, I think the decision went to the Head of Internal Crime team.
54. The Head of Internal Crime could challenge a decision of the Prosecution
Decision Maker if they did not agree with the decision. The Prosecution
Decision Maker was the Manager with POL who after considering the written
advice of the CLT would decide if a prosecution should be undertaken. I
cannot recall any instances when the Head of internal Crime changed a
prosecution decision. My recollection is that when I initially joined POL in 2001
the teams were set up geographically with Regional Managers responsible for
both Investigation and Security. Soon after I joined this changed to three
strands with one being Internal Crime. The Head of Internal Crime at this time
was Phil Gerrish. He then subsequently moved to RMLS and Tony Utting
became the Head of Internal Crime. I left POL in 2007. I cannot remember
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who became the Head of Internal Crime POL after I left but it may have been
Dave Pardoe or John Bigley.
55.1 was not a party to the process of making the prosecution and charging
decisions and so cannot say what test would have been applied, but I
understand it was in accordance with the Code for Crown Prosecutors.
56. In terms of advice, legal or otherwise, I am only able to say that CLT would
give written advice on cases where summons was to be obtained or verbal
advice on charges if a person was to be charged at a police station. They
were also available to give advice over the telephone if an Investigator
required advice.
57.With respect to internal and external advice, when I worked for POL the initial
advice was always from the internal CLT. As the Case progressed agents
would prosecute on behalf of POL and if the case went to Crown Court, then
counsel would be used. Our agents were lawyers, usually based outside of
London and the Southeast who prosecuted cases at Magistrates court on
behalf of Royal Mail to keep the costs down. Agents were always different in
different areas. I cannot remember any specific names.
58.1 was not aware of a particular approach being applied to cases where a
shortfall was identified on audit.
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59.To apply for a Restraint Order the decision would have to have been taken
that a Confiscation Investigation was appropriate. For a Restraint Order to be
granted we would have to demonstrate to the Crown Court Judge that the
application was necessary and proportionate. Normally the necessary criteria
was Satisfied by there being information/suspicion that the assets would be
dissipated, reducing the amount available for a Confiscation Order. An AFI
may well conclude that a restraint order was appropriate but I understand that
before they can apply for one it has to be authorised by a Senior Authorising
Officer under POCA.
60. With respect to criminal enforcement proceedings, the Prosecution Decision
Maker made the decision on prosecution.
61.1 discussed potential financial investigations with my Line Manager Tony
Utting, Head of Internal Crime. I would look at most cases where there was a
significant loss to see if there were assets available to satisfy a potential
Confiscation Proceedings.
Training, instructions and guidance to investigators within the Security team
62. Initial training consisted of theory sessions followed by a practical training role
play. All Investigators were made aware of the fact they were required to have
regard for the relevant PACE 1984 COP and given copies. Following the initial
training courses, new Investigators were to be supervised by a mentor/line
manager for an extended period while they learned on the job.
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63. There was an Investigator’s Staff Manual which became electronic Policies,
Procedures and Standards. Any changes to Investigation practice were
communicated by Investigation Circulars which were initially manually
circulated but then were emailed to all relevant Investigators.
64.1 would add that whilst I was involved in training and P&S I would liaise with or
search for publications from the College of Policing and/or the Home Office.
Such a publication would the Home Office publication “Achieving Best
Evidence” manual in order to inform the training and P&S.
65.At some later refresher training was given where the PEACE module was
taught.
66. With regard to witness statements, initial training consisted of theory sessions
followed by practical training role play following which they would have been
guided by mentors/line managers. Additionally there were P&S dealing with
obtaining witness statements.
67.On the issue of conducting searches, following the murder of Andrew Gardner
on a house search in 1997 the whole issue of search was risk assessed and
reviewed. Most Investigators then attended a search course delivered by
Metropolitan Police
68.1 then produced the search training for the new investigators joining in 2000.
This training was based PACE 1984 Codes of Practice the Police Training
and my experience of search during my career. The emphasis being the
preservation of evidence and health and safety.
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69.1 do not recall specific training on the duty of an investigator to investigate a
case carefully. That would have been for the Casework Manager, Line
Managers or even CLT to instruct or train the investigator. An investigator
should have been aware of the CP&l 1996 COP which states Investigators
should pursue all reasonable lines of inquiry, whether these point towards or
away from the suspect.
70.With regard to obtaining evidence, initial training included theory on the types
of evidence and how it should be secured.
71.1 do not recall any specific training on the circumstances in which evidence
should be sought from third parties who might hold relevant evidence, outside
of obtaining any type of evidence from any witness.
72.When the CP&l Act 1996 came into force investigators received training from
CLT on disclosure obligations. All Investigators were issued with the CP&l
Codes of Practice. New investigators covered the subject on a Prosecution
Process Course.
73.On drafting investigation reports, although Investigators did write a report on a
mock case during training they would be guided by their mentors/line
managers. There would have been a written guide either in a P&S or the older
Investigators manual. Additionally, Investigators sourced previous reports
from experienced Investigators and used them as a guide.
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74.When I started in P&S in 2007 there had been a lot of change in RMGS over
the previous years and it was thought that the existing P&S were not fit for
purpose. So, I was instructed by my Line Manager Ray Pratt, Policy Standard
and Investigation Support Manager to produce a set of P&S for the Group
Security Database. It was explained to me that the Senior Lead Team would
be responsible for high level policy and these documents would be kept short.
I was to produce Procedures and Standards which went into more detail than
the Policy documents and detailed how investigators did things. I was also to
set up a review programme.
75. The way I produced P&S was to obtain all source information from the
following:
a. Internal documents which had been previously written on the subject
including training material;
b. I would use Codes of Practice such as PACE 1984 CP&l 1996
RIPA2000;
c. I would also contact Police Forces and ask for documents;
d. I would also use the internet this included searching for Home Office
documents, a good example is the publication Obtaining Best Evidence
in Criminal Proceedings. Also the College of Policing (Previously the
NPIA) produced a monthly Digest. This was a publication produced by
the College of Policing’s Legal Services. It provided updates
operational policing and criminal Justice. I would check each digest for
any relevance to RMGS;
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e. I would also consult specific team members had more knowledge, for
example on Health and Safety I would consult Allison Angus as she
has a NEBOSH certificate. Or David Brassington who was the lead of
the Digital Forensic Team. This was a team which copied computer
disks or downloaded evidence from mobile phones.
76. The drafted P&S were then forwarded to my relevant line manager and the
CLT for assurance and sign off.
77.The review programme was that core activities such as 7.4 Interviewing
Suspects [POL00104867] would be undertaken annually or whenever
information came forward requiring an immediate change. Others such as 7.7
Obtaining Fingerprints and Handwriting Samples [POL00104871] may have
been left to be reviewed every other year or whenever information came
forward requiring an immediate change.
78.I have been asked about the following Criminal Investigation Team
Guidance documents:
a. 2.2 Joint Investigation Protocols - RMGS and POL Ltd Security
(Version 2, July 2015) [POL00114559]:
b. 4.1 Criminal Investigations Duties Safe Systems of Work (Version 1.0,
April 2013) [POL00105233);
c. 4.2 Planned Operation Risk Assessments (PORA) (Version 1.0, March
2011) [POL00122561];
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. Appendix 1 to 4.2 Risk Related Intelligence Checks (Version 1, May
2011) [POL00104873];
. 5.1 Forensic Services (Version 1.0, January 2012) [POL00122588}];
Appendix 1 to 5.4 Rules and Continuity of Evidence (Version 6, May
2018) [POL00124133];
. Appendix 2 to 5.4 Managing the Witness and Structure and Contents of
a Witness Statement (Version 6.0, May 2018) [POL00124132];
. 6.1 Directed Surveillance (Version 3.0, April 2012) [POL00094132];
Appendix 1 to 6.1 A Practical Guide to Surveillance (Version 4.0, April
2018 [POL00124124];
Appendix 2 to 6.1 Securing Digital and VHS Tape CCTV Images for
Evidential Purposes (Version 1.0, February 2011) [POL00104866];
. 7.1 Suspect Approach and Arrest Procedures (Version 3.0, September
2012) [POL00030606];
7.2 Police Custody Procedures (Version 1.0, May 2012)
[POL00105230);
. 7.3 Criminal Offences Points to Prove (Version 1.0, August 2011)
[POL00104901];
. 7.4 Interviewing Suspects (Version 1.0, March 2011) [POL00104867];
. 7.5 Searching (Version 1.0, August 2013) [POL00030605];
. 7.7 Obtaining Fingerprint and Handwriting Specimens (Version 1.0,
March 2011) [POL00104871];
. 7.8 Recovering Computers, Mobile Phones & Digital Storage Devices
for Evidential Purposes (Version 1.0, 27 January 2011)
[POL00104896):
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r. Appendix 7 to 7.4 — Dealing with Defence Solicitors & Complaints by
Suspects (Version 1.0, March 2011) [POL00104893];
s. Appendix 8 to 7.4 Juveniles and Appropriate Adults (Version 1.0,
March 2011) [POL00104894];
t. Appendix 9 to 7.4 — Interpreters at Suspect Interviews (Version 1.0,
March 2011) [POL00104869];
u. Appendix 10 to 7.4 — Interviewing Suspects in Prison (Version 1.0,
March 2011) [POL00104870];
v. 7.9 Suspect Identification Evidence (Version 1, March 2011)
[POL00104865];
w. 7.1 Reporting Offences to the Police (NPA Procedures) (Version 1.0,
May 2012) [POL00094203};
x. 7.11 Suspension from Duty (Version 1.0, May 2012) [POL00038437];
y. Appendix 1 to P&S 9.1 Proceeds of Crime Act 2002 Investigation
Orders (January 2019) [POL00124167];
z. Appendix 2 to P&S 9.1 Proceeds of Crime Act 2002 Enforcement
Receivership Orders (January 2019) [POL00124168]; and
aa.9.4 Magistrates’ and Crown Court Procedures (Version 1, May 2011)
[POL00104872].
79.Most of the P&S bear the Royal Mail Cruciform (later versions contain the
Branding of “Royal Mail Group) at the top of the document. When I started to
write P&S, they were unbranded. Sometime later and I think it was prior to
separation of RM and POL I was told by Ray Pratt that the P&S were to be
reproduced in the Royal Mail Branding and references to POL were to be
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80.
8
82.
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removed. I understood this had been agreed with Senior Management. The
RM Versions were to start again with Version 1.
It is my understanding that the P&S 2.2 Joint Investigation Protocols - RMGS
and POL Ltd Security (Version 2, July 2015) [POL00114559] was written
because of the separation between RMG and POL as the Security teams no
longer had a working relationship. When I first joined POID all investigators
helped each other. Then as the Business Units separated, they each
conducted their own criminal investigations. As time when on the business
units grew apart as they had different responsibilities and ultimately this led to
there no longer being a working relationship.
.In respect of P&S Appendix 1 to P&S 9.1 Proceeds of Crime Act 2002
Investigation Orders (January 2019) [POL00124167] and Appendix 2 to P&S
9.1 Proceeds of Crime Act 2002 Enforcement Receivership Orders (January
2019) [POL00124168] appear to be P&S that I authored with Ged Harbinson
AFI and which has subsequently been copied and rebranded by POL.
Finally on P&S, with the exception of writing in the P&S 2.2 Joint Investigation
Protocols - RMGS and POL (the first version was written in July 2014)
Security Version 2 July 2015 [POL00114559] on how RMGS Investigators
obtain Horizon data from POL, I cannot recall ever writing anything about how
to obtain evidence from Horizon as I was not working in POL and POL was a
different business unit. They would have been responsible for their specific
individual business requirements.
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Analysing Horizon data and requesting ARQ data from Fujitsu
83.1 have been asked to consider the following documents:
a. The document entitled “Conducting Audit Data Extractions at CSR”
dated 4 May 2000 at [POL00029169];
b. The document entitled “Conducting Audit Data Extractions at Live”
dated 27 November 2001 at [FUJ00152176];
c. The versions of the document entitled “Management of the Litigation
Support Service” dated 27 October 2009 ([FUJ00152212)]), 14
February 2012 ([FUJ00152220]) and 23 April 2012 ([FUJ00152225)),
as well as the version marked “withdrawn” at [FUJ00152235];
d. The versions of the document entitled “Audit Data Extraction Process”
dated 13 September 2010 ([FUJ00152216]), 1 March 2011
([FUJ00152218]), 14 February 2012, ([FUJ00152221]), 3 September
2014 ([FUJ00152226]) and 4 September 2014 ([FUJ00152228]);
e. v) The document entitled “Security Management Service: Service
Description” (SVM/SDM/SD/0017) dated 24 August 2006
([FUJ00002033]), 31 December 2008 ([FUJ00080107]), 15 October
2010 ([FUJ00002264]), 25 November 2013 ([FUJ00088868)]), 4
December 2013 ([FUJ00002555]), 4 April 2014 ([POL00002572]) and
19 February 2016 ([POL00002666}) (and in particular, paragraph 2.4).
84.1 was aware that Fujitsu maintained very detailed transaction data, but I was
not aware of any analysis that investigators carried out. I have never applied
for any data from Fujitsu and I cannot recall ever seeing any. I had no
requirement to see the data. My work was reliant on a conviction. I did not
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believe the Horizon data would show me the benefit from the crime I thought
the audit shortage showed me that and additionally it would not identify any
realisable assets.
85. With regard to audit data, an agreed amount of data was available in
accordance with the contract but when a certain amount had been obtained
there was a cost involved. I understand all key stroke data was available but I
do not recall who told me this. My understanding of key stroke data is that
every time a key on the keyboard/screen is touched an entry is made on
Horizon and the data was recorded. The significance of this for me was that
Horizon was able to show on balancing what cash on hand figures were
entered by the SPM before Horizon detailed what figure was required to
balance. When a Post Office Branch completes a weekly or later a monthly
balance the branch has to input into Horizon what cash and stock they have
on hand. Once these figures are entered, Horizon would then tell the branch if
they are short, over or whether they are in balance.
86. If a branch is short they can then resubmit the cash on hand and increase the
amount of cash on hand by the amount the system told them they were short
by. This would then mean that the branch showed a balance although in fact
they are short of cash.
87.1 do not know the limits or how the ARQ requests above contractual limits
were dealt with or charged.
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88.1 do not know of any changes between Legacy Horizon and Horizon Online
apart from to say the initial Horizon was not in real time “online”. It "polled"
data and updated regularly, whereas the Horizon online was that and in real
time.
89. My role in respect of obtaining audit data was limited to what I wrote in a P&S
2.2 Joint Investigation Protocols - RMGS and POL Ltd Security (Version 2,
July 2015) [POL00114559] and Version 1 was produced on July 2014.
Namely, if Royal Mail Investigators needed Horizon Transaction data it was
only available from Fujitsu and that would be at a cost. There was less
comprehensive Credence data available from POL at no cost. In order to
obtain the data an application had to be made to Paul Ackroyd who was the
Disclosure and Acquisition Manager RMGS. I do not know what Credence
data was but assumed it was data available directly to POL.
90.1 have no knowledge of issues such as ARQ request authorisations or
91.
provision of data by Fujitsu as this did not form part of my duties or
responsibilities nor did I have any contact with Fujitsu or anyone connected
with Fujitsu such as Gareth Jenkins.
In terms of prosecution support, I understood that Fujitsu were asked to
provide statements and transaction data. After providing a statement they
may be required to give evidence as any other witness would but I am not
aware of any prosecution support they were contractually obliged to provide. I
think it was normal for them to provide statement if the case went to court.
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92.1 do not know whether ARQ data was requested as matter of course in
circumstances where a shortfall had been identified. I conducted financial
Investigations and I do not believe the ARQ data would assist in the
Confiscation process. My view was that where ARQ data was obtained it
should rightly be disclosed to the SPM.
93. If I had ever needed an expert witness, I would have sought advice from the
CLT as that was their area of expertise.
Relationship with others
94.1 have never had any contact any one from with Cartwright King Solicitors. I
think these Solicitors were instructed after I had left POL in 2007.
95.1 understood that Mr Hughie Noel Thomas was a representative of the
National Federation of Sub-postmasters but aside from my contact with him I
have never had any contact with any one from with National Federation of
Sub-postmasters that I am aware of.
Prosecution of Ms Adedayo
96.1 am asked to consider:
a. an investigation report [POL00044360];
b. the record of the Ms Adedayo’s interview [POL00066742] (part 1) and
[POL00066745] (part 2);
c. the memo dated 15 September 2005 [POL00064797];
d. the memo dated 6 October 2005 [POL00044361];
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e. the memo dated 27 January 2006 [POL00052911];
f. the memo dated 6 March 2006 [POL00044362];
g. my letter to Ms Adedayo on 8 March 2006 [POL00052588];
h. the financial investigation policy log [POL00030561];
i. the section 16 statement [POL00044370];
j. the Financial Investigation Document Schedule [POL00047865]; and
k. the memo dated 5 October 2006 [POL00052907].
97.1 was asked by the CLT to prepare a Section 16 POCA 2002 Confiscation
Statement [POL00044370]. I also understand these were the first
Confiscation proceedings that Royal Mail had undertaken, but I cannot recall
anything which is not in the documents listed above or my attendance at
Maidstone Crown Court. I would add that the documents detail that Ms
Adedayo explained that she had borrowed the money to pay a family member
for some of the loss.
98.Prior to the Ms Adedayo case, apart from interviewing Tracy Felstead in 2001
I would only have been involved in financial investigations, I did not undertake
any criminal Investigations into losses involving Horizon. The financial
Investigation would not have involved looking at Horizon Data as this would
have been the responsibility of the criminal investigator.
99.1 had no involvement in the initial investigation, the decision to charge or the
decision to prosecute in the Adedayo case.
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100. I cannot recall any allegations made by Ms Adedayo relating to the
reliability of the Horizon IT system prior to the Confiscation proceedings.
101. I understand Natasha Bernard was the Criminal Investigator in the
case, but I cannot recall any assistance I gave her. My work was the
confiscation investigation and I would run my cases alone.
102. In terms of legal assistance I would have liaised with the CLT but
cannot remember any further details.
103. I cannot recall the sources of evidence but I would have looked at the
casefile and spoken with the investigator. The casefile would have contained
the evidence and statements in the case and any relevant intelligence. This
would have been prepared by Natasha Bernard.
104. With regard to confiscation proceedings in respect of Ms Adedayo I
produced a Section 16 POCA 2002 Confiscation Statement [POL00044370]
and gave evidence at Maidstone Crown Court - where my evidence related to
figures in the confiscation statement - apart from that I have no further
recollection.
105. I do not recall any discussions with anyone with regard to the Adedayo
case, but I would have spoken with the CLT.
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106. After confiscation I cannot recall any further involvement in the
Adedayo case.
107. At the time I believed that I acted wholly correctly in endeavouring to
recover public funds. POL at the time was being subsidised by the
government. Any loss was a direct loss to public funds so I believed it was
important to recover them from those criminally liable for the loss. I am not
sure if it was policy, but it would have been the mindset of the investigation
team and CLT.
108. If she is a victim of unexplained losses, then I am very sorry for the
profound effect this has had on her life. I would not have had any part of
Confiscation proceedings on innocent people had I known.
109. I was led to believe that the Horizon Computer System was the most
secure non-military computer in the country. This was because the
Government could not tolerate benefits not being paid as this could lead to
civil unrest. I cannot however remember the source of this statement.
110. During my time in POL I never doubted the Horizon data I thought the
problem was with the SPMs. I believe that the mindset of most of my
colleagues was that Horizon was infallible.
Prosecution of Mr Hughie Noel Thomas
111. I have been asked to consider:
a. The offender report for Hughie Thomas [POL00044861];
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. The record of Mr Thomas’ interview [POL00066736];
. The Restraint Order dated 7 November 2006 [POL00048231];
. The application to enter a restriction on the title for The Post Office
Holyhead Road Gaerwen [POL00048235];
. My witness statement of 7 November 2006 in support of the application
for a Restraint Order [POL00044873];
My statement of information relevant in accordance with Section 16(3)
of the proceeds of Crime Act 2002 on 16 January 2007
[POL00044872] and associated draft version 1 November 2006
[POL00044874];
. My letter to Norwich Union Financial Crime Team dated 6 November
2006 [POL00048233];
. My fax to Nationwide on 10 November 2006 [POL00044878];
My faxes to Sharron Mcintyre of Scottish Widows on 16 December
2006 [POL00044876] and on 15 February 2007 [POL00063888];
My fax to Conrad Szymanski of Humberstones on 21 February 2007
[POL00044879];
. Letter from Mr Wilson to Sion ap Mihangel enclosing my second
statement prepared on 22 February 2007 [POL00048516];
My fax to Karen Robson of Phoenix Life Assurance on 17 April 2007
[POL00063793];
. Transcript of proceedings on 19 April 2007 T20060330
[POL00048618];
. Memo from Ms McFarlane to Mr Mayall regarding Mr Thomas's
pension dated 20 April 2007 [POL00048621]; and
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0. my statements of information relevant in accordance with Section 16(6)
of the proceeds of Crime Act 2002 on 22 February 200
[POL00048515] and on 18 April 2007 [POL00044871].
112. I very little recollection of this case or the documents listed above, but
once I became aware of the case I would have discussed it with my Line
manager Tony Utting.
113. Apart from going to Carnarvon Crown Court for one of the hearings as I
was told to attend by CLT. I cannot add anything to the documents regarding
this case.
114. I would have been aware of any allegations made against Horizon by
Mr Thomas because I would have read the case documentation, nevertheless
I believed in the integrity of the Horizon. Accordingly, I would have thought the
money had been taken from the branch.
115. I would have spoken with the Criminal Investigator in the case Dianne
Matthews for case information, but I cannot recall any conversations.
Additionally, I cannot recall if I spoke with Michael Mayall about the payment
of Mr Thomas' pension.
116. In terms of legal advice I would have spoken with CLT and their agents
as they had conduct of the prosecution, but I cannot remember any
conversations or discussion with specific individuals.
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117. I cannot recall the decision to apply for a Restraint Order aside from my
witness statement of 7 November 2006 in support of the application for a
Restraint Order [POL00044873] upon which it would seem there was
information that assets were being dissipated.
118. I do not recall who asked me to provide a witness statement in support
of the application.
119. At the time I believed that I acted wholly correctly in endeavouring to
recover public funds. POL have accepted that this was an unexplained loss
and more importantly the Court of Appeal has quashed Mr Thomas’
conviction. I am very sorry for the profound effect this has had on his life. I
would not have had any part of confiscation proceedings of innocent people
had I known.
120. With regard to the Judgment of the Court of Appeal in Josephine
Hamilton & Others v Post Office Limited and my reflections on how the case
against Mr Thomas was conducted by the Post Office. I believe that too much
trust was placed into the integrity of Horizon and we put more faith in Horizon
than we did in Mr Thomas. I do not know if examining the Horizon data would
have identified the problem and prevented all this. Too many assumptions
about the infallibility of Horizon were made and I apologise for my part in Mr
Thomas profound experience. I hope he gets the compensation he deserves
and lives the rest of his life in peace.
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The mindset of people I dealt with was that Horizon was infallible and
as such the assumption was that it must be someone at the branch who was
responsible for the loss.
Prosecution of Ms Janet Skinner
122.
I have been asked to consider the following documents:
. An interim report dated 22 June 2006 [POL00044624];
. Instructions to counsel to settle the indictment [POL00048356];
. The summary of Ms Skinner’s interview [POL00047357];
. The indictment [POL00048345];
. My statements of information relevant in accordance with Section 16(6)
of the proceeds of Crime Act 2002 on 26 March 2007 [POL00048566]
and on 28 August 2007 [POL00048979];
The provision of financial information order made to under Section 18
of the Proceeds of Crime Act 2002 on 17 May 2007 [POL00064035);
. The memo from Juliet McFarlane dated 5 January 2007
[POL00048397];
. The memo from Juliet McFarlane, dated 6 September 2007
[POL00049016);
My letters to Ms Skinner on 25 January 2007 [POL00064027] and 26
March 2007 [POL00064028];
My letter to Thea of Kensington Mortgage Company on 8 December
2006 [POL00064012];
. My letter to Ms Flight of Friends Provident on 25 January 2007
[POL00044672]:
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I. My letter to Mr Turner from Max Gold Partnership Solicitors on 15
February 2007 [POL00064030];
m. My letter to Jen of Mark and Spencer Financial Services on 27 April
2007 [POL00064011];
n. My letter to Wendy Lyell on 28 June 2007 [POL00064029]; and
o. The letter to Royal Mail Legal Services on 7 June 2007
[POL00048772] and enclosed advocate note [POL00048773].
123. I have very little recollection of the Skinner case or the documents
detailed above. However, once I became aware of the case I would have
discussed it with my Line manager Tony Utting.
124. Apart from attending Hull Crown Court I have no recollection of the
Confiscation Investigation and cannot add anything to the documents relating
to this case.
125. I would have spoken with the Criminal Investigator in the case Dianne
Matthews for case information, but I cannot recall any conversations.
126. Additionally, I would have spoken with the CLT and their agents as
they had conduct of the prosecution, but I cannot remember any
conversations with CLT or any other specific individuals.
127. I cannot recall sources of evidence but it they have been intelligence
checks and personal financial documents.
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128. I cannot remember the adjournment application in this case but I
considered that her benefit from the crime was the money that she was short
on in addition to the increase in the value of money. This was because sub-
postmaster's were contractually liable as Sub-postmasters for any losses in
their branch, however they were caused. This was in accordance with the
contract sub-postmasters signed with POL on commencing as sub-
postmaster.
129. I would have been the AFI in the case so I would have had had
conduct of the case, but I have no specific recollections.
130. As with Mr Thomas, too much trust was placed into the integrity of
Horizon, and we put more faith in Horizon than we did in Ms Skinner. I do not
know if examining the Horizon data would have identified the problem and
prevented all this. Too many assumptions were made, and I apologise for my
part in Ms Skinners profound experience. I hope she gets the compensation
she deserves and lives the rest of her life in peace.
General
131. I left POL in 2007. Up until this time the assumption was that Horizon
data was to be trusted.
132. As soon as it was thought that the Data Integrity was not trustworthy
and I am not sure when that was, then a full Investigation should have been
mounted to identify the issues and this should have been disclosed to all
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persons convicted/adversely effected by unexplained Horizon losses. I would
imagine that the responsibility of the accuracy of the Horizon data was Fujitsu.
I do not know why the accuracy was not challenged.
133. I have no knowledge of investigations into bug errors and defects, so I
am unable to give a view of the sufficiency of POL's investigation or the
sufficiency of Fujitsu passing information to POL on bug and errors.
134. On reflection I am sorry to all those who have been adversely and
profoundly affected by these unexplained losses. POL should have done
more to ensure the rights of individual people as soon as they knew that
Horizon was affected by bugs errors and defects.
OTHER MATTERS
135. I was the second officer during the interview of Tracy Felstead a
Peckham Police Station Ged Harbinson was the Criminal Investigator in the
case.
136. In the judgement of the Court of Appeal in Josephine Hamilton and
others V Post Office Limited 2021 EWCA Crim 577 at [POL00113278], at
paragraphs 185 and 186 the interview at Peckham police station is
commented on.
137. If I recollect correctly, I believe I asked the question “Can you
demonstrated how you did not steal the money? “. I am acutely aware that a
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suspect does not have to prove their innocence. Ms Felstead was also asked
questions about whether her family had driven her to steal. The reason for this
is that I seem to recollect that the information we had is that Ms Felstead had
been on an expensive family holiday and I was trying to establish where the
funds had come from. The questions were probably spur of the moment to
keep interview going. The interview was tape recorded and I do not think I
breached PACE 1984 Codes of Practice. It certainly was not raised at the
time, and I believe she was represented at interview by a solicitor.
138. If, however I was overzealous I apologise to Ms Felstead. At the time I
would have thought that it was my duty to robustly question suspects to get to
the truth of the matter.
139. Notwithstanding as with Mr Thomas and Ms Skinner too much trust
was placed into the integrity of Horizon, and we put more faith in Horizon than
we did in Ms Felstead. I do not know if examining the Horizon data would
have identified the problem and prevented all this. I apologise for my part in
Ms Flesteads profound experience. I hope she gets the compensation she
deserves and lives the rest of her life in peace.
140. I believe that the facts contained in this witness statement are true.
Signed:
Date: 9 October 2023
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Index to First Witness Statement of MICHAEL FRANCIS MATTHEWS
No. URN Document Description Control Number
1. POL00114559 I 2.2 Joint Investigation Protocols- RMGS_ I POL-0113665
and POL Ltd Security
2. POL00026573 I Royal Mail Group Security - Procedures & I POL-0023214
Standards - The Proceeds of Crime Act
2002 & Financial Investigations
3. I POL00104857 I Royal Mail Group Security - Procedures & I POL-0080489
Standards - Initiating Investigations
4. POL00031005 I Conduct of Criminal Investigations Policy I POL-0027487
v2
5. POL00027863 I Conduct of Criminal Investigations Policy" I POL-0024504
(version 3, 10 February 2014)
6. I POLO0030902 I Conduct of Criminal Investigations Policy" I POL-0027384
(September 2018)
7. POL00105229 I Post Office Ltd PNC Security Operating POL-0080854
Procedures” (August 2012)
8. POL00104968 I POL - Enforcement & Prosecution Policy I POL-0080600
9. POL00104747 I Casework Management Policy (version POL-0080387
1.0, March 2000)
10. IPOL00104777 I Casework Management Policy (version POL-0080417
4.0, October 2002)
11. I POL00104754 I Rules and Standards Policy (version 2.0, I POL-0080394
October 2000)
12. I POL00030687 I Investigation Procedures Policy (version POL-0027169
2.0, January 2001)
13. I POL00104762 I Disclosure Of Unused Material, Criminal POL-0080402
Procedures and Investigations Act 1996
Codes of Practice Policy (version 1.0,
May 2001)
14. I POL00030578 I Royal Mail Group Ltd Criminal POL-0027060
Investigation and Prosecution Policy (1
December 2007)
15. I POL00104812 I Royal Mail Group Ltd Criminal POL-0080444
Investigation and Prosecution Policy
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16.
POL00104806
Royal Mail Group Security - Procedures &
Standards - Standards of Behaviour and
Complaints Procedure (version 2, October
2007)
POL-0080438
17.
POL00031003
Royal Mail Group Crime and Investigation
Policy
POL-0027485
18.
POL00030580
Post Office Ltd - Security Policy - Fraud
Investigation and Prosecution Policy"
(version 2, 4 April 2010)
POL-0027062
19.
POL00039965
Post Office Ltd Financial Investigation
Policy (4 May 2010)
POL-0036447
20.
POL00104912
Royal Mail Group Ltd Criminal
Investigation and Prosecution Policy
(version 1.1, November 2010)
POL-0080544
21.
POL00026582
Post Office Ltd Financial Investigation
Policy (version 2, February 2011)
POL-0023223
22.
POL00104855
Post Office Ltd Anti-Fraud Policy
(February 2011)
POL-0080487
23.
POL00030786
Royal Mail Group Policy Crime and
Investigation S2" (version 3.0, April 2011)
POL-0027268
24.
POL00104929
Post Office Limited: Internal Protocol for
Criminal Investigation and Enforcement
(with flowchart) (October 2012)
POL-0080561
25.
POL00105226
Undated Appendix 1 - POL Criminal
Investigations and Enforcement
Procedure (flowchart) (October 2012)
POL-0080851
26.
POL00030602
Post Office Limited: Criminal Enforcement
and Prosecution Policy (undated)
POL-0027084
27.
POL00104821
Condensed Guide for Audit Attendance
(version 2, October 2008)
POL-0080453
28.
POL00104867
7.4 Interviewing Suspects
POL-0080499
29.
POL00104871
7.7 Obtaining Fingerprints and
Handwriting Samples
POL-0080503
30.
POL00105233
4.1 Criminal Investigations Duties Safe
Systems of Work (Version 1.0, April 2013)
POL-0080858
31.
POL00122561
4.2 Planned Operation Risk Assessments
(PORA) (Version 1.0, March 2011)
POL-0128791
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32.
POL00104873
Appendix 1 to 4.2 Risk Related
Intelligence Checks (Version 1, May 2011)
POL-0080505
33.
POL00122588
5.1 Forensic Services (Version 1.0,
January 2012)
POL-0128817
34.
POL00124133
Appendix 1 to 5.4 Rules and Continuity of
Evidence (Version 6, May 2018)
POL-0130267
35.
POL00124132
Appendix 2 to 5.4 Managing the Witness
and Structure and Contents of a Witness
Statement (Version 6.0, May 2018)
POL-0130266
36.
POL00094132
6.1 Directed Surveillance (Version 3.0,
April 2012)
POL-0094255
37.
POL00124124
Appendix 1 to 6.1 A Practical Guide to
Surveillance (Version 4.0, April 2018
POL-0130258
38.
POL00104866
Appendix 2 to 6.1 Securing Digital and
VHS Tape CCTV Images for Evidential
Purposes (Version 1.0, February 2011)
POL-0080498
39.
POL00030606
7.1 Suspect Approach and Arrest
Procedures (Version 3.0, September
2012)
POL-0027088
40.
POL00105230
7.2 Police Custody Procedures (Version
1.0, May 2012)
POL-0080855
41.
POL00104901
7.3 Criminal Offences Points to Prove
(Version 1.0, August 2011)
POL-0080533
42.
POL00030605
7.5 Searching (Version 1.0, August 2013)
POL-0027087
43.
POL00104896
7.8 Recovering Computers, Mobile
Phones & Digital Storage Devices for
Evidential Purposes (Version 1.0, 27
January 2011)
POL-0080528
44.
POL00104893
Appendix 7 to 7.4 — Dealing with Defence
Solicitors & Complaints by Suspects
(Version 1.0, March 2011)
POL-0080525
45.
POL00104894
Appendix 8 to 7.4 Juveniles and
Appropriate Adults (Version 1.0, March
2011)
POL-0080526
46.
POL00104869
Appendix 9 to 7.4 — Interpreters at
Suspect Interviews (Version 1.0, March
2011)
POL-0080501
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47. I POL00104870 I Appendix 10 to 7.4 — Interviewing POL-0080502
Suspects in Prison (Version 1.0, March
2011)
48. I POLO0104865 I 7.9 Suspect Identification Evidence POL-0080497
(Version 1, March 2011)
49. I POL00094203 I 7.1 Reporting Offences to the Police (NPA I POL-0094326
Procedures) (Version 1.0, May 2012)
50. I POLO0038437 I 7.11 Suspension from Duty (Version 1.0, POL00038437
May 2012)
51. I POL00124167 I Appendix 1 to P&S 9.1 Proceeds of Crime I POL-0130283
Act 2002 Investigation Orders (January
2019)
52. I POL00124168 I Appendix 2 to P&S 9.1 Proceeds of Crime I POL-0130284
Act 2002 Enforcement Receivership
Orders (January 2019)
53. I POL00104872 I 9.4 Magistrates’ and Crown Court POL-0080504
Procedures (Version 1, May 2011)
54. I POL00029169 I Conducting Audit Data Extractions at CSR I POL-0025651
dated 4 May 2000
55. IFUJ00152176 I Conducting Audit Data Extractions at Live I POINQ0158370F
dated 27 November 2001
56. I FUJ00152212 I Management of the Litigation Support POINQ0158406F
Service dated 27 October 2009
57. IFUJ00152220 I Management of the Litigation Support POINQ0158414F
Service dated 14 February 2012
58. I FUJ00152225 I Management of the Litigation Support POINQ0158419F
Service dated 23 April 2012
59. I FUJ00152235 I Management of the Litigation Support POINQ0158429F
Service marked withdrawn
60. I FUJ00152216 I Audit Data Extraction Process dated 13 POINQ0158410F
September 2010
61. I FUJ00152218 I Audit Data Extraction Process dated 1 POINQ0158412F
March 2011
62. I FUJ00152221 I Audit Data Extraction Process dated 14 POINQ0158415F
February 2012
63. I FUJ00152226 I Audit Data Extraction Process dated 3 POINQ0158420F
September 2014
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64. I FUJ00152228 I Audit Data Extraction Process dated 4 POINQ0158422F
September 2014
65. I FUJ00002033 I Security Management Service: Service POINQ0008204F
Description (SVM/SDM/SD/0017) dated
24 August 2006
66. I FUJ00080107 I Security Management Service: Service POINQ0086278F
Description (SVM/SDM/SD/0017) dated
31 December 2008
67. I FUJ00002264 I Security Management Service: Service POINQ0008435F
Description (SVM/SDM/SD/0017) dated
15 October 2010
68. I FUJO0088868 I Security Management Service: Service POINQ0095039F
Description (SVM/SDM/SD/0017) dated
25 November 2013
69. I FUJ00002555 I Security Management Service: Service POINQ0008726F
Description (SVM/SDM/SD/0017) dated 4
December 2013
70. I POL00002572 I Security Management Service: Service VIS00003586
Description (SVM/SDM/SD/0017) dated 4
April 2014
71. I POL00002666 I Security Management Service: Service VIS00003680
Description (SVM/SDM/SD/0017) dated
19 February 2016
72. IPOL00044360 I Investigation report POL-0040839
73. I POLO0066742 I Ms Adedayo’s interview record Part 1 POL-0063221
74. I POL00066745 I Ms Adedayo’s interview record Part 2 POL-0063224
75. IPOL00064797 I Memo dated 15 September 2005 POL-0061276
76. I POL00044361 I Memo dated 6 October 2005 POL-0040840
77. IPOL00052911 I Memo dated 27 January 2006 POL-0049390
78. I POL00044362 I Memo dated 6 March 2006 POL-0040841
79. IPOL00052588 I Letter to Ms Adedayo on 8 March 2006 POL-0049067
80. I POL00030561 I Financial investigation policy log POL-0027043
81. I POL00044370 I Section 16 statement POL-0040849
82. I POL00047865 I Financial Investigation Document POL-0044344
Schedule
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83. I POLO0052907 I Memo dated 5 October 2006 POL-0049386
84. I POL00044861 I Offender report for Hughie Thomas POL-0041340
85. I POLO0066736 I The record of Mr Thomas’ interview POL-0063215
86. I POL00048231 I The Restraint Order dated 7 November POL-0044710
2006
87. I POL00048235 I The application to enter a restriction on POL-0044714
the title for The Post Office Holyhead
Road Gaerwen
88. I POL00044873 I My witness statement of 7 November POL-0041352
2006
89. I POL00044872 I My statement of information relevant in POL-0041351
accordance with Section 16(3) of the
proceeds of Crime Act 2002 on 16
January 2007
90. I POL00044874 I My statement of information relevant in POL-0041353
accordance with Section 16(3) of the
proceeds of Crime Act 2002 on 16
January 2007 (draft version 1 November
2006)
91. I POL00048233 I My letter to Norwich Union Financial POL-0044712
Crime Team dated 6 November 2006
92. I POL00044878 I My fax to Nationwide on 10 November POL-0041357
2006
93. I POL00044876 I My fax to Sharron Mcintyre of Scottish POL-0041355
Widows on 16 December 2006
94. I POL00063888 I My fax to Sharron Mcintyre of Scottish POL-0060367
Widows on 15 February 2007
95. I POL00044879 I My fax to Conrad Szymanski of POL-0041358
Humberstones on 21 February 2007
96. I POL00048516 I Letter from Mr Wilson to Sion ap Mihangel I POL-0044995
enclosing my second statement prepared
on 22 February 2007
97. I POLO0063793 I My fax to Karen Robson of Phoenix Life POL-0060272
Assurance on 17 April 2007
98. I POL00048618 I Transcript of proceedings on 19 April POL-0045097
2007 T20060330
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99.
POL00048621
Memo from Ms McFarlane to Mr Mayall
regarding Mr Thomas's pension dated 20
April 403540122007
POL-0045100
100.
POL00048515
My statement of information relevant in
accordance with Section 16(6) of the
proceeds of Crime Act 2002 on 22
February 2007
POL-0044994
101.
POL00044871
My statement of information relevant in
accordance with Section 16(6) of the
proceeds of Crime Act 2002 on 18 April
2007
POL-0041350
102.
POL00044624
Interim report dated 22 June 2006
POL-0041103
103.
POL00048356
Instructions to counsel to settle the
indictment
POL-0044835
104.
POL00047357
The summary of Ms Skinner's interview
POL-0043836
105.
POL00048345
Indictment
POL-0044824
106.
POL00048566
My statement of information relevant in
accordance with Section 16(6) of the
proceeds of Crime Act 2002 on 26 March
2007
POL-0045045
107.
POL00048979
My statement of information relevant in
accordance with Section 16(6) of the
proceeds of Crime Act 2002 on 28 August
2007
POL-0045458
108.
POL00064035
The provision of financial information
order made to under Section 18 of the
Proceeds of Crime Act 2002 on 17 May
2007
POL-0060514
109.
POL00048397
Memo from Juliet McFarlane dated 5
January 2007
POL-0044876
110.
POL00049016
Memo from Juliet McFarlane, dated 6
September 2007
POL-0045495
111.
POL00064027
My letter to Ms Skinner on 25 January
2007
POL-0060506
112.
POL00064028
My letter to Ms Skinner on 26 March 2007
POL-0060507
113.
POL00064012
My letter to Thea of Kensington Mortgage
Company on 8 December 2006
POL-0060491
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WITNO09380100
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114.I POL00044672 I My letter to Ms Flight of Friends Provident I POL-0041151
on 25 January 2007
115.I POLO0064030 I My letter to Mr Turner from Max Gold POL-0060509
Partnership Solicitors on 15 February
2007
116.I POL00064011 I My letter to Jen of Mark and Spencer POL-0060490
Financial Services on 27 April 2007
117.I POLO0064029 I My letter to Wendy Lyell on 28 June 2007 I POL-0060508
118.I POL00048772 I Letter to Royal Mail Legal Services on 7 POL-0045251
June 2007
119.I POL00048773 I Advocate note POL-0045252
120.I POL00113278 I Josephine Hamilton and others V Post POL-0110657
Office Limited 2021 EWCA Crim 577
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