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” Natasha
Witness Name: gornard
Statement No: 1
Ref: WITN09390100
Dated: 16/10/23
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF NATASHA BERNARD
I, Natasha Bernard, will say as follows:
1. This witness statement is made following a request from the Post Office Horizon Inquiry
(“Inquiry”) dated 23 August 2023, for information pursuant to Rule 9 of the Inquiry Rules
2006 — Request number 1, regarding matters falling within Phase 4 of the Inquiry: action
taken by Post Office Ltd against Subpostmasters.
2. I left the Post Office over 12 years ago and a lot of the questions raised in the Rule 9
request relate to matters nearly 20 years ago. This passage of time has meant that I
have found it difficult to recall specific details and have had to rely heavily on the
documents provided to me as part of the Rule 9 request to answer the Inquiry’s
questions. However, I have done my best to assist the Inquiry to the best of my
recollection and will continue to assist the Inquiry in any way I can.
3. I can confirm that I have had legal assistance in responding to the Rule 9 request and
drafting this statement. In order to obtain insurance for this legal assistance, I was in
contact with the Post Office who provided me with the relevant contacts. I have not had
any contact with the Post Office other than to obtain legal insurance coverage.
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Relevant background
4.
I commenced employment with Post Office Ltd on 10 September 1985 as a Counter
Clerk. On 6 April 1998 I was an Assistant Branch Manager at Acton Crown Office and
stayed in this role until 5 June 2000 when I was promoted to an Investigation Manager
(“Security Advisor’) in South London. I subsequently left employment with Post Office
Ltd on 25 February 2011, before starting work as a Fraud Disputes and Control Analyst
at CCUK Finance Ltd from 9 August 2011 until 31 October 2016.
From November 2016 to August 2017 I was unemployed. From August 2017 to October
2017 I was self-employed, training individuals as an Accredited Counter-Fraud
Specialist (‘ACFS”). In November 2017 I commenced employment as an Executive
Officer Work Coach for The Department for Work and Pensions and remain in this role
to date.
In respect of my position as a Security Advisor, I came into the role after bumping into
Tony Utting, who I knew from school. I think that he was Head of Investigations at the
time and told me that vacancies were coming up in January 2000 for the Security and
Investigations Team. I applied and was successful, starting on 5 June 2000. I cannot
recall the exact dates but in my final years of working at the Post Office, I managed the
Banking Fraud Team.
I can recall the job title changing and, in the main, I was called an ‘Investigation
Manager and nota ‘Security Advisor’. I have therefore used the job title ‘Investigation
Manager going forward.
Prior to becoming an Investigation Manager I had experience working on counters and
managing branch offices. When I started my role as an Investigation Manager I went on
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a Security Foundation course. Further details on this are below at “Training, instructions
and guidance to investigators within the Security and Investigation Team”.
9. I was assigned a mentor, David Posnett, who I could seek guidance and support from
and who I shadowed at the beginning of my role. My line manager was Paul Fielding
and I also worked a lot with Tony Utting.
10.My role as an Investigation Manager was to carry out investigations into criminal
offences committed against the Post Office, dealing with both Sub Post Offices and
Branch Offices. The investigations I was involved with weren't just relating to audit
shortages, but also other issues, such as suspected fraud. Where an audit shortage
occurred, the Security and Investigation Team would get a call from the audit team, who
would have attended the Sub Post Office for an audit and found a shortage. This was
usually on a Thursday, as the Sub Postmaster would have declared their cash the night
before. The team manager would then assign the case to somebody in the Security and
Investigation Team to attend the Sub Post Office and investigate further. Who they
assigned it to would generally depend on who was nearby and available, meaning I
tended to do mostly South London based investigations.
1
.Following an investigation, from what I remember, we would write a report to the
Contracts and Services Manager. This report was only allowed to contain facts about
what had happened and not an opinion. We would also write a report to the Criminal
Law Team, which also summarised what had happened but in which you could express
an opinion on next steps, including a recommendation on charges. I thought that we
also wrote a third report but I cannot recall, and the documents do not assist me in
recalling, what the content or purpose of the third report was or who it was written for.
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12.1 can remember the role specification changing a lot but I think that there was, at one
point, a division between Security and Investigation roles. From memory, someone who
had a ‘Security’ role would deal with the physical security of a post office branch, for
example when there was a burglary. Someone who had an ‘investigation’ role would
deal with issues such as internal fraud and audit shortages. However, my memory on
this is limited and I cannot remember details about times or specific roles or
responsibilities. I do, however, recall that the roles were, at one point, combined.
13. Overall, I thought my colleagues were brilliant. I can recall Tony Utting red marking my
first report all over and really helping me to improve. Everyone was very professional
and respectful and even though we had a laugh with each other, we were very serious
when it came to the job and standards were very high.
14.As an Investigations Manager I had no involvement in disciplinary matters. After we
conducted an investigation, we would write a report to assist the Contracts and Services
Manager, an example being document [POL00044360]. This report had to be entirely
facts based, with no opinion given. Beyond writing the report, we had no involvement in
any decisions taken.
15.My role included carrying out interviews under caution of those accused of a criminal
offence. I had full training on how to carry out interviews under caution and they were
always carried out with another member of the team present. Before commencing the
interview, we would always inform the individual of their right to legal representation and
a friend.
16.In terms of disclosure in criminal or civil proceedings, once we had written our legal
report, we would submit it to the Criminal Law Team with the relevant documents. They
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would review it and give their advice. If their advice was to prosecute, they would list
additional documents and evidence that they required. For example, witness
statements. It would be our job to source and provide this. Should further information or
evidence be needed during the lifetime of a case, the Criminal Law Team would contact
us and we would assist in obtaining and providing it. I cannot recall having any official
role in relation to disclosure other than sourcing and providing documents as and when
requested. I also cannot recall whether I ever had any specific training on disclosure
whilst working at the Post Office.
17.1 had no involvement in litigation case strategy. When I submitted my legal report to the
Criminal Law Team, I might recommend what the Sub Postmaster could be charged
with, but it is my recollection that ultimately any charging decision was up to the Criminal
Law Team. I can recall occasionally sitting in on conferences with Counsel who would
ask questions about the evidence, but this was to provide information only, not to talk
about litigation strategy.
18.My role included liaising with other Post Office departments. I can remember that there
was a Casework Function Team. This department included the Casework Manager,
who would start the initial process, sending cases to our team leader who would then
hand them down to us to take forward. The name of the department changed a lot so it
may have been called something else during my time.
19.Once we had carried out the investigation, we would submit the case to the Criminal
Law Team who would look at the evidence and draft advice on prosecution. If
prosecution was going ahead, we would prepare the committal and issue the summons.
We might also liaise with the Criminal Law Team throughout the lifetime of a case if they
requested further information and/or evidence. I can also recall getting in touch
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occasionally with the Financial Investigation Unit although I cannot remember why. I
assume it was to assist them in obtaining financial information.
The Security and Investigation Team’s role in relation to criminal investigations and
prosecutions
20. The Inquiry have provided me with a number of policies to assist in answering their
questions on the above subject matter. A lot of these policies post-date the time that I
left the Post Office (February 2011) and therefore I have not reviewed any of the
documents after this date. To confirm, I have reviewed the following:
i. Casework Management Policy (version 1.0, March 2000) ([POL00104747]) and
(version 4.0, October 2002) ([POL00104777]);
ii. Rules and Standards Policy (version 2.0, October 2000) ([POL00104754));
iii. Investigation Procedures Policy (version 2.0, January 2001) ([POL00030687));
iv. Disclosure Of Unused Material, Criminal Procedures and Investigations Act 1996
Codes of Practice Policy (version 1.0, May 2001) ([POL00104762));
v. Royal Mail Group Ltd Criminal Investigation and Prosecution Policy (1 December
2007) ([POL00030578], which appears to be substantially the same as the policy
of the same date with a variation on the title at [POL00104812]);
vi. Royal Mail Group Security - Procedures & Standards - Standards of Behaviour
and Complaints Procedure (version 2, October 2007) ([POL00104806));
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vii. I Royal Mail Group Crime and Investigation (S2) (version 3.0,
September 2008) ([POL00031004));
viii. I Royal Mail Group Crime and Investigation Policy (version 1.1,October
2009) ([POL00031003));
ix. Post Office Ltd - Security Policy - Fraud Investigation and Prosecution
Policy (version 2, 4 April 2010) ([POL00030580));
x. Post Office Ltd Financial Investigation Policy (4 May 2010)
([POL00030579)):
xi. I Royal Mail Group Security - Procedures & Standards - The Proceeds
of Crime Act 2002 & Financial Investigations (version 1, September
2010) ([POL00026573));
xii. I Royal Mail Group Security - Procedures & Standards - Initiating
Investigations (September 2010) ([POL00104857));
xiii. I Royal Mail Group Ltd Criminal Investigation and Prosecution Policy
(version 1.1, November 2010) ([POL00031008));
xiv. Post Office Ltd Financial Investigation Policy (version 2, February
2011) ([POL00104853));
xv. Post Office Ltd Anti-Fraud Policy (February 2011) ([POL00104855));
xvi. Post Office Limited: Criminal Enforcement and Prosecution Policy
(undated) ([POL00030602)).
.I did not remember the Casework and Management Policies ([POL00104747]
and [POL00104777}) prior to being provided them by the Inquiry. However,
having reviewed them, I remember that I would use them to guide me with
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what needed to be contained in the legal report. I do not specifically
remember the Post Office Ltd policies listed above, although I appreciate that
I would have been aware of them at the time of my employment. I do not
recall any of the Royal Mail Group policies and it is less likely that I would
have been aware of them at the time of my employment.
22.1 did not have any role in the development and / or management of any of the
policies listed above.
23. The organisational structure of the Security and Investigation Team changed
so often during my employment in it that I find it difficult to remember how it
was at any particular time. I can recall that, at one point, it was divided into
lots of different sub-teams, two of which I think were called ‘Fraud Risk’ and
‘Commercial Risk’. When I left, things were starting to change again but I
cannot remember how.
24. The policies listed above governed the conduct of investigations conducted by
the Security and Investigation Team and as part of the Fraud Investigation
and Prosecution Policy ([POL00030580]), we had to ensure adherence and
compliance with the following:
a. Police and Criminal Evidence Act 1984
b. Data Protection Act 1998
c. The Data Protection (Processing of Sensitive Personal Data) Order
2000
d. Regulation of Investigatory Powers Act (RIPA) 2000
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e. Human Rights Act 1998
f. Criminal Procedures and Investigations Act 1996
25.1 was not involved in the development of any policies within the Post Office
post-separation and cannot recall that the separation had any impact in
relation to the way investigations were conducted.
26.1 do not remember what the process was for dealing with complaints about the
conduct of an investigation by the Security and Investigation team and cannot
recall any specific complaints happening.
27.\n terms of supervision over criminal investigations, once we had written our
report, it would go to our line manager who would review it and make sure we
had exhausted every line of enquiry. Sometimes you would submit a report
and they would give it back to you, suggesting other avenues of enquiry that
you needed to pursue. If I had any queries, I would go to my supervisor to ask
for help and they would always be very approachable and you felt like you
could challenge them if you disagreed.
28.1 do not think that the Post Office policy and practice regarding investigation
and prosecution of Crown Office employees differed at all from the policy and
practice and regarding investigation and prosecution of Sub Postmasters or
their managers or assistants. Personally, I would always treat them the same.
The only difference would have been that we had more control when going
into a Branch Office as this was Post Office property, whereas if you were
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going to a Sub Postmasters office, there was an extra layer of risk
assessment as often, if it was part of the Sub Postmaster’s house.
Audit and investigation
29.The Inquiry have asked me to consider the document ‘Condensed Guide for
Audit Attendance’ (version 2, October 2008) ([POL00104821]). However, this
document looks like it is for auditors and I do not remember ever having seen
it before.
30.An investigator would not attend an audit but would be called afterwards, if a
shortfall had been discovered in the audit. Upon attendance, you would speak
to the auditor who would let you know if the Sub Postmaster had made any
significant statement explaining the cause of the shortfall. You would then
start to gather facts and inform the Sub Postmaster that you needed to
interview them under caution.
3
.An investigation would always happen following an audit where a shortfall was
discovered if it was more than a nominal amount. I cannot remember what the
threshold amount was. I think that reports were reviewed by our line manager,
and can recall that this was certainly the case when we did not have much
experience. However, I think that once we became more experienced, our
reports would be sent direct to the Criminal Law Team but could be reviewed
by our line manager beforehand on request.
32.1 believe that it was up to the Contracts and Service Manager to decide
whether a Sub Postmaster would remain as a Sub Postmaster or whether a
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temporary Sub Postmaster would take over. As noted above, we would issue
a report to help them make a decision but were not involved in the actual
decision making process and our report had to be facts only.
33. If, when carrying out an investigation, there was suspected fraud involved, I
would raise this to the Criminal Law Team in my legal report as a potential
offence.
The process followed by Security and Investigation Team investigators when
conducting a criminal investigation following the identification of a shortfall at
an audit
34.As described above, once a decision had been made to conduct a criminal
investigation, we would attend the Sub Postmasters Post Office to gather
facts and interview them under caution. The investigation would have followed
the inquiry methods as detailed in 3.1 of document [POL00030687]
‘Investigation Procedures’.
Decisions about prosecutions and criminal enforcement proceedings
35. Following an initial investigation, it was the Criminal Law Team who would
decide whether a Sub Postmaster, their manager(s) or a Crown Office
employee should be prosecuted. Although we could write recommendations in
our legal report, it was up to the Criminal Law Team to decide what charges to
bring. I cannot speak for the rest of the Security and Investigation Team but,
unless it was glaringly wrong, I would not challenge a decision on the charges
to be brought by the Criminal Law Team. I knew that there was a test applied
by those making prosecution and charging decisions, but I do not remember
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what this was. I do not think that the Contract and Services Manager had any
input into the prosecution decision-making process. I think that they were only
involved with the discipline aspect of the case and the Criminal Law Team
were involved in the legal aspect.
36.1 was not involved in any restraint of a suspect's assets, as this was dealt with
by the Financial Investigation Unit. We would tell them about the case and
they would look at it to see if criminal proceedings should be pursued. As I
was not involved in this, I do not feel able to comment on what factors they
considered when making decisions around this.
Training, instructions and quidance to investigators within the Security and
Investigation Team
37.When I began my role within the Security and Investigation Team, I completed
the Security Foundation Course, which provided training on a wide range of
skills, including carrying out interviews, taking witness statements, conducting
searches, obtaining evidence and drafting investigation reports. I remember
that there were about 17 modules in total. The course had two exams, both of
which you needed to pass to carry on the role. This training included being
made aware of Post Office policies around the duty on an investigator to
investigate a case fully and what this meant in practice. I also shadowed
David Posnett for the couple of few months to receive additional instructions
and guidance on investigations, before taking on my first case around August
2000.
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38.1 can also recall having training on how the Horizon system worked and that it
essentially worked as a giant calculator.
39.As referenced above, 3.1 of the Casework and Management Policies
([POL00104747] and [POL00104777)) laid out what needed to be included in
the legal report. You would have to assume that the legal team knew nothing
about the Post Office so would explain everything from the background of the
case, to the resultant shortage. You would then make recommendations and
say whether you had identified any weaknesses in the case.
Analysing Horizon data and requesting ARQ data from Fujitsu
40.In answering the Inquiry’s questions on this subject matter, I can confirm that I
have reviewed the following documents:
i. IThe document entitled “Conducting Audit Data Extractions at CSR”
dated 4 May 2000 at [POL00029169];
ii. IThe document entitled “Conducting Audit Data Extractions at Live”
dated 27 November 2001 at [FUJ00152176];
iii. I The document entitled “Management of the Litigation Support Service”
dated 27 October 2009 ([FUJ00152212]). Please note that I have not
reviewed the other versions of this document as they post-date my
employment.
iv. The document entitled “Audit Data Extraction Process” dated 13
September 2010 ([FUJ00152216]). Please note that I have not
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reviewed the other versions of this document as they post-date my
employment.
v. The documents entitled “Security Management Service: Service
Description” (SVM/SDM/SD/0017) dated 24 August 2006
([FUJ00002033]), 31 December 2008 ([FUJ00080107]) and 15
October 2010 ([FUJ00002264]). Please note that I have not reviewed
the other versions of this document as they post-date my employment.
41.To confirm, whenever I dealt with an investigation for a shortfall, I would
usually request ARQ data from Fujitsu as part of my investigation. I did this as
a matter of course, not because of any suspected issue with Horizon and in
fact, I do not recall that I ever dealt with a case where the Sub Postmaster
raised issues with Horizon at the time.
42.1 remember that there was a process to request ARQs but I cannot remember
what it was. I remember speaking to Penny Thomas at Fujitsu but I do not
know whether she was responsible for the provision of data or authorising an
ARQ request.
43.1 think that there was a limit on the number of ARQ requests which would be
provided by Fujitsu but I cannot recall amounts and this was not something
that I was involved in. I remember that sometimes we were told to hold back
requests until the following month because the data request limit had been
reached.
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44.1 do not remember whether there was a difference between Legacy Horizon
and Horizon Online when it came to requesting ARQ data. I do not know what
Legacy Horizon is.
45.1 have been asked about my recollection of obtaining audit data. It is my
assumption that what is meant by this, is data available to or obtained by an
auditor as part of an audit. I can recall, on occasions, requesting an auditor to
run reports from the Horizon system. However, the report was difficult and
lengthy to look through as it presented itself on a long piece of paper which
wound up like a ball of receipts. It was much easier to instead request the
data from Fujitsu as they could present it on an excel spreadsheet which was
easier to read.
46.1 cannot recall whether or not the data was provided to the Sub Postmaster
but I assume that it would have been during disclosure. If relevant, an extract
from a report might be provided to the Criminal Law Team within the
investigation documents.
47.Any data that was obtained by Fujitsu was presented in a spreadsheet for the
relevant period that you requested it for. This spreadsheet was given to you
on a disc. As noted above, I remember speaking to Penny Thomas but I
cannot recall the circumstances around these conversations. I cannot recall
anybody called Gareth Jenkins or what their role was.
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48.1 do not know what prosecution support Fujitsu was contractually obliged to
provide to Post Office. I had nothing to do with contractual arrangements with
Fujitsu and do not feel able to comment on any contractual requirements on
them, either in relation to Legacy Horizon or Horizon Online.
Relationship with others
49.1 cannot recall having any involvement with Cartwright King Solicitors.
50.1 did not have any involvement with the National Federation of Sub
Postmasters other than to ask a Sub Postmaster if they wanted somebody
from the National Federation of Sub Postmasters to be present when we
interviewed them under caution. I do not remember any direct interaction that
I had with them.
Prosecution of Ms Adedayo
51. The Inquiry have asked me for a full and detailed account of the investigation
and prosecution of Oyeteju Adedayo. At the outset, I would like to say that I
have no direct memory of the case. I have had to rely wholly on the
documents provided to me to be able to provide my answers and only been
able to expand where I can comment on general practices and procedures.
52.In consideration of Ms Adedayo’s case I can confirm that I have reviewed the
following documents:
a. the witness statement of Ms Adedayo [WITN09390100];
b. the audit report [POL00068926};
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. the investigation report [POL00044360);
. the legal report [POL00044366];
. the record of the Ms Adedayo’s interview [POL00066742] (part 1)
and [POL00066745] (part 2);
the memo dated 15 September 2005 [POL00064797];
. the memo dated 6 October 2005 [POL00044361];
. the memo dated 17 October 2005 [POL00052904];
the memo dated 7 March 2006 [POL00044362];
the memo dated 25 November 2005 [POL00052916];
. the notification of proceedings to the police [POL00044363] and
[POL00044364];
the schedule of charges [POL00044367];
. the memo dated 27 January 2006 [POL00052911];
. the notification of disposal to police [POL00044365];
. the Financial Investigation Events Log [POL00047897];
. the section 16 statement [POL00044370];
. the Financial Investigation Document Schedule [POL00047865];
the memo dated 5 October 2006 [POL00052907];
. the Memorandum for the information of the accused [POL00044358];
the Antecedents form for Oyeteju Adedayo [POL00052902];
. transcript to Ms Adedayo’s evidence to the Inquiry on 21 February
2022 (pages 60 to 104) INQ00001039
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53.1 have also read Ms Adedayo’s Impact Statement [WITN01780100].
54. Document [POL00044360] lays out a summary of how I came to be involved
in Ms Adedayo’s case. This confirms that, on Monday 5 September 2005,
Branch Auditor, Mr Deepak Valani, attended Rainham Road Sub Post Office
Branch to conduct a routine cash and stock verification audit. The audit
resulted in a shortage of £52,864.08. The Security and Investigation Team
were immediately informed and I went into the branch that same day to
commence an investigation.
55. Document [POL00068926] shows that the auditor, Mr Deepak Valani wrote to
me on 5 September 2005 to inform me that there was a shortfall and a
decision was taken to suspend Ms Adedayo. I do not know who made this
decision but it would probably have been the Contract and Services Manager.
56. The document shows that I was involved in the initial investigation and carried
out an interview under caution, along with Adrian Morris, but I cannot
remember anything beyond what is contained in the two transcripts of this
interview [POL00066742] (part 1) and [POL00066745] (part 2). I would have
written the legal report [POL00044366] following the interview and the
Criminal Legal Team would have made the decision as to whether to
prosecute and under what charges. I would have also written the report to the
Contracts and Services Manager [POL00044360]. Again, this was all normal
practice.
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57.1 have considered the transcript of Ms Adedayos’ evidence to the Inquiry on
21 February 2022 [INQ00001039], pages 60 to 104. Here, Ms Adedayo
described that on the day of the initial audit of her branch (5 September 2005)
there were “plain clothes police officers” in attendance (see page 76, lines 18
to 20). I am not a police officer and have never presented myself as such.
When we attended investigations, we would show identification and so I do
not think that she can be referring to me at this point.
58.1 cannot recall what information was provided to me in respect of the audit.
However, it was usual for auditors to provide us with information about the
shortage and any explanation that the Sub Postmaster had given. Having
reviewed my legal and disciplinary reports at [POL00044360] and
[POL00044366], I assume that the auditors would have told me of the
shortfall of £52,864.08 and that Ms Adedayo had informed the auditors, prior
to the commencement of the audit, that the accounts would be approximately
£50k short and wrote a note to that effect. However, this is only my
assumption and not based on my memory. I did not have any involvement in
the audit of this branch as that was not part of my job role.
59. During her evidence to the Inquiry [INQ00001039] at page 84, Ms Adedayo
states that after she was interviewed she had been told “You'd better get
yourself a lawyer because you're going to go down for a very long time and
we are going to make sure that you never work again”. I am not aware of this
or words to that effect having ever been communicated to Ms Adedayo or any
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Sub Postmaster who I interviewed. I would have been shocked if someone
said that as it is completely inappropriate. Had I ever heard anything said to
this effect, I would have told my line manager and would have reported it.
Although I cannot remember the interview of Ms Adedayo I am confident that I
would have remembered something as serious as this being said as it is so
shocking.
60. Besides Adrian Morris, who I can see from the transcripts interviewed Ms
Adedayo with me, I cannot recall anyone else at the Post Office who provided
assistance to the investigation apart from the auditors.
61.1 do not think that I obtained legal advice at any stage of the investigation prior
to sending my report to the Criminal Law Team. That document is at
[POL00044366).
62.1 cannot remember the sources of evidence that I considered during the
course of the investigation. However, I would normally have considered what
the audit showed, what any Horizon data showed and what she said on the
day. I cannot remember if we also interviewed Joan, who Ms Adedayo refers
to, or took a witness statement from her.
63. At no point was I aware of any allegations made by Ms Adedayo relating to
the reliability of the Horizon IT system. At the outset and throughout the
lifetime of the case, she consistently said that she had taken the money. She
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never attributed the shortfall to issues with the Horizon system. Had she done,
I would have made further investigations.
64.1 cannot remember whether Fujitsu were contacted to provide any additional
data in relation to this case. I would like to think that ARQ logs were sought,
but I also might have relied on the logs printed on the day. I cannot
remember.
65. In respect of my role in relation to the prosecution of Ms Adedayo, I was the
lead investigator which essentially involved conducting the initial investigation,
including an interview under caution and preparing the reports and putting
together the case file.
66.1 do not think that I was the Disclosure Officer in this case and I cannot ever
remember holding this official title. Although I did assist with sourcing and
providing information when requested, I had no direct involvement in actually
disclosing it.
67.Document [POL00052911] is a memo from Debbie Helszajn, which states
that Ms Adedayo appeared at Chatham Magistrates Court on 19 January
2006 and pleaded guilty to the three charges and accepted the further
offences set out in the Schedule of TIC’s. She advises that I should attend the
sentencing hearing. This was a normal course of action as all Investigation
Managers were asked to attend sentencing hearings and write something up
after the sentencing to conclude the case. I have no direct memory of the
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sentencing hearing and therefore cannot confirm whether or not I did actually
attend. However, it would not have been unusual for me to arrange for
someone else from the team to go in my place if I could not attend.
68. The only involvement that I had in the financial investigation was to provide a
summary to the Financial Investigation Unit (“FIU”) to help them understand
the case. It would have been the FIU who made the decision to commence
confiscation proceedings in respect of Ms Adedayo, not me. I had no
involvement in the confiscation proceedings. Beyond what is contained in the
documents, I cannot recall any further involvement that I had in this case.
69.1 do not have any other reflections about this matter that I think are relevant,
other than to make clear that I never had any knowledge of any problems with
Horizon and no reason to suspect that there was anything wrong with the
Horizon system.
General
70.1 cannot remember ever having a case where the integrity of Horizon was
brought into question. I was shocked when all of the cases came out about it
as I cannot recall anyone ever saying to me that a shortfall was due to
Horizon when I conducted any of my investigations. I always kept an open
mind during an investigation and if a Sub Postmaster had said that there was
a problem, I would have been looking for it during my investigation. I never let
something go if I thought there was an issue which hadn't been resolved in
any aspect of my work.
200}-
WITNO09390100
WITNO09390100
71.Given that the issue of Horizon was never raised to me, I do not feel that I can
comment as to whether I consider sufficient information regarding bugs, errors
and defects in Horizon was passed to the Post Office by Fujitsu.
72.1 can only comment on my own cases and only feel able to repeat that the
issue of Horizon was never brought up. Had it arisen, I would have
investigated it further.
73. There are no other matters that I wish to bring to the attention of the Chair of
the Inquiry.
Statement of Truth
I believe the content of this statement to be true.
Date: Ub (0 ,20RZ
“23)=
Index to First Witness Statement of Natasha Bernard
No
URN
Document Description
Control Number
POL00104747
Investigation Policy:
Casework Management
(England & Wales) v1.0
POL-0080387
POL00104777
Investigation Policy:
Casework Management
(England & Wales) v4.0
POL-0080417
POL00104754
Investigation Policy:
Rules & Standards v2.0
POL-0080394
POL00030687
Investigation Policy -
Investigation
Procedures v2 January
2001
POL-0027169
POL00104762
"Investigation Policy:
Disclosure of Unused
Material, Criminal
Procedures and
Investigations Act 1996
Codes of Practice" v0.1
POL-0080402
POL00030578
S02 Royal Mail Group
Criminal Investigation
and Prosecution Policy
December 2007
POL-0027060
POL00104812
"Royal Mail Group Ltd
Criminal Investigation
and Prosecution Policy"
POL-0080444
POL00104806
Royal Mail Group
Security — Procedures
and Standards:
Standards of behaviour
and complaints
procedure No.10-X v2
POL-0080438
POL00031004
RMG Policy - Crime
and Investigation (S2) -
version 3.0
POL-0027486
10.
POL00031003
Royal Mail Group Crime
and Investigation Policy
v1.1 October 2009
POL-0027485
11.
POL00030580
Post Office Ltd -
Security Policy: Fraud
Investigation and
Prosecution Policy v2
POL-0027062
12.
POL00030579
Post Office Ltd
Financial Investigation
Policy, May 2010
POL-0027061
WITNO09390100
WITNO09390100
13.
POL00026573
RMG Proceedures &
Standards - Proceeds
of Crime Act 2002 &
Financial Investigations
doc 9.1 V1
POL-0023214
14,
POL00104857
Royal Mail Group
Security Procedures &
Standards: Initiating
Investigations doc 2.1
POL-0080489
15.
POL00031008
RMG Ltd Criminal
Investigation and
Prosecution Policy v1.1
November 2010
POL-0027490
16.
POL00104853
Post Office's Financial
Investigation Policy
POL-0080485
17.
POL00104855
Post Office Ltd. Anti-
Fraud Policy
POL-0080487
18.
POL00104968
POL - Enforcement and
Prosecution Policy (with
comments)
POL-0080600
19.
POL00030602
POL: Criminal
Enforcement and
Prosecution Policy
POL-0027084
20.
POL00104821
Condensed Guide for
Audit Attendance v2
POL-0080453
21.
POL00029169
ICL Pathway
Conducting Audit Data
Extractions at CSR
Process (v1)
POL-0025651
22.
FUJ00152176
Conducting Audit Data
Extractions at Live - ICL
Pathway Ltd - v2.0
POINQ0158370F
23.
FUJ00152212
Management of the
Litigation Support
Service - Fujitsu v1.0
POINQ0158406F
24.
FUJ00152216
Audit Data Extraction
Process - Fujitsu v0.2
Draft
POINQ0158410F
25.
FUJ00002033
Fujitsu Services
Security Management
Service: Service
Description. Version 1.0
POINQ0008204F
26.
FUJ00080107
Fujitsu's Guidance on
Security management
service: Service
Description (v.2)
POINQ0086278F
27.
FUJ00002264
Fujitsu and Post Office
Document re: Security
POINQ0008435F
WITNO09390100
WITNO09390100
Management Service:
Service Description v3
28.
POL00068926
Audit report of Rainham
Road Post Office
(FAD098941X) by
Deepak Valani
POL-0065405
29.
POL00044360
Theft/False Accounting
report - Oyeteju
Adedayo
POL-0040839
30.
POL00066742
Transcribed note on
Oyeteju Adedayo
Interview
POL-0063221
31.
POL00066745
Transcript of Oyeteju
Adedayo Interview -
Tape 2
POL-0063224
32.
POL00064797
Internal Memo from
Darryl Owen to Criminal
Law team
recommending
prosecution be pursued
(Oyeteju Adedayo)
POL-0061276
33.
POL00044361
Memo from Debbie
Helszajn to Ms Natasha
Bernard regarding
prospect of conviction
in Post Office Ltd v
Oyetehu Adedayo case
POL-0040840
34.
POL00052904
Internal memo from
Terry Crowther to
Natasha Bernard, RE:
Solicitors Advice on
Prosecution and
Schedule of Charges
(Oyeteju Adedayo)
POL-0049383
35.
POL00044362
Oyeteju Adedayo case
study - Memo from Phil
Taylor to the Post
Office Investigation
Team regarding Regina
v Oyeteju Adedayo
POL-0040841
36.
POL00052916
Letter from Natasha
Bernard to Debbie
Helszajn, RE: Oyeteju
Adedayo Summons
POL-0049395
37.
POL00044363
Notification of
proceedings to police -
Oyeteju Adedayo -
False accounting
POL-0040842
38.
POL00044364
Notification of
proceedings to Police -
POL-0040843
WITNO09390100
WITNO09390100
Oyeteju Adedayo -
False accounting
39.
POL00044367
Schedule of charges for
Oyeteju Adedayo in
Post Office Ltd v
Oyeteju Adedayo
POL-0040846
40.
POL00052911
Memo from Debbie
Helszajn (Royal Mail) to
Investigation Team Post
Office Ltd Re Post
Office Ltd v Oyeteju
Adedayo - Pleaded
guilty, on notice of
compensation
POL-0049390
41.
POL00044365
Form NPA 03 1/97 -
Notification of disposal
to police - Oyeteju
Adedayo
POL-0040844
42.
POL00047897
Oyeteju Adedayo Case
Study - Financial
Investigation Events
Log, Case Number: Fl
0506 0336
POL-0044376
43.
POL00044370
Statement of
information relevant in
accordance with section
16 (6) of the proceeds
of Crime Act 2002
Regina v Oyeteju
Adedayo
POL-0040849
44.
POL00047865
Financial Investigation
Document Schedule Fl
0506 0336
POL-0044344
45.
POL00052907
Memo from Phil Taylor
to Investigation Team
Post Office Ltd, RE: Rv
Oyeteju Adedayo,
Maidstone Crown Court
POL-0049386
46.
POL00044358
Memorandum for the
information of the
accused - Oyeteju
Adedayo
POL-0040837
47.
POL00052902
Antecedents form for
Oyeteju Adedayo
POL-0049381
48.
INQ00001039
Transcript (21/02/2022):
Post Office Horizon IT
Inquiry - John Dickson
[WITN0166], Pauline
Thomson [WITN0258],
Timothy Burgess
INQ00001039
WITNO09390100
WITNO09390100
[WITN0187], Siobhan
Sayer [WITN0183] and
Oyeteju Adedayo
[WITNO178]
49. I POL00044366 Report for theft/false POL-0040845
accounting - Oyeteju
Adedayo
50. I WITN01780100 I Impact Statement of Ms I WITN-01780100
Adedayo
WITNO09390100
WITNO09390100