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Witness Name: Angela Van Den Bogerd
Statement No: WITN09900100
Dated: 20 March 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ANGELA VAN DEN BOGERD
I, Angela Van Den Bogerd, will say as follows:
1. I make this statement in response to a Request for Information pursuant to
Rule 9 of the Inquiry Rules 2006, regarding matters within Phases 5 and 6 of
the Post Office Horizon IT Inquiry, dated 29 January 2024.
2. As laid out below, I was closely involved with the Sub-Postmasters (“SPM”)
claims, including acting as a witness in the Common Issues Trial and Horizon
Issues Trial. I have followed the Inquiry and what has come out of it has
horrified me. Had I known that the Horizon IT system was flawed on
implementation, my approach would have been different throughout my time
with Post Office Limited (“POL”). I am in complete support of full
compensation for all SPM’s who were affected by Horizon IT issues and
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regret that it has not been paid out quicker and to an appropriate value which
meets their claims.
I have set out to answer the Inquiry’s questions to the best of my ability but I
have at times been limited in my ability to do so due to issues with disclosure.
Where I have knowledge that documents are in existence but have not been
disclosed, I have requested these both direct from POL and the Inquiry and
unfortunately some have been disclosed at the last minute or not at all. My
intention is to assist the Inquiry in a full and frank way which provides them
with meaningful answers, but I have felt impeded in my ability to do so and so
I feel it necessary to highlight these difficulties that I have experienced. In
addition to the Rule 9 documents disclosed by the Inquiry, I requested and
received over 300 additional documents, numbering over 4,500 pages.
. During my time with POL I have always acted to the best of my ability and
with the knowledge I had at the time, I was always reassured that Horizon
was robust and that underlined the basis of my actions. I regret that it took so
long for the true position on Horizon integrity and remote access to be
acknowledged and the impact that this has had.
. To those that were wrongly prosecuted, whilst I wasn’t personally involved in
those prosecutions, I am truly sorry for the devastating impact that has had on
them and their family and friends.
I have heard the term ‘corporate amnesia’ being referenced about some
evidence already given to the Inquiry. I want to say from the outset that my
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intention is to fully cooperate with the Inquiry and help Sir Wyn Williams in his
investigation. I will not try to hide anything and say that I cannot remember
something when I can. In putting together this witness statement I have
reviewed everything disclosed to me by the Inquiry and, as noted above, I
also requested and reviewed over 300 additional documents to help me
provide as full an answer as possible. If I am unable to recall a detail, I will do
my best to direct the Inquiry to where they can obtain that information. I hope
that my witness statement goes some way to assisting the SPM’s with
obtaining the truth.
7. Ican confirm that I have had the legal assistance of Ashfords LLP in drafting
this statement.
BACKGROUND
8. I left school in 1984 with 11 O Levels and 2 A Levels. Whilst studying for my A
Levels, I worked part-time as a retail assistant and as a lifeguard. I joined POL
in 1985 at the age of 19.
9. The Inquiry have been unable to locate a record of my employment from POL,
but from memory, the roles I held whilst employed by POL are as follows:
a. 1st April 1985: I joined the Post Office as a Post Office Counter
Assistant within the directly managed network of post offices in the
Swansea area.
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. 1987 — 1996: I was Branch Manager, responsible for the day-to-day
management and financial performance of directly managed post
offices in Swansea and surrounding areas.
. 1996 — 2001: I was a Retail Network Manager, responsible at an area
level for the operational performance of 24 post offices: 6 directly
managed branches employing approximately 130 staff, and 18 agency
branches in the Cardiff and surrounding areas. As part of this role I was
responsible for interviewing and appointing the SPMs, managing
performance and dealing with any contract breaches as appropriate.
. 2001 — 2005: I was Head of Area for the rural agency in Wales,
responsible for maintaining the provision of Post Office services and
the operational performance of the rural network of 950 branches in
Wales and the Welsh Marches, through a field based team of 18
managers.
. 2005 — 2006: I was General Manager for the Community Network of
branches, responsible for a team of 9 senior managers and a field
based team of 40 managers, and for overseeing the day-to-day
operational and financial management of 9,000 rural and 500 urban
branches.
September 2006 — March 2009: I was National Network Development
Manager. I was part of the team that designed, developed and
deployed the process (known as the Network Change Programme) to
deliver 3,000 changes to the Post Office network (2,500 closures and
the establishment of 500 new type services).
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g. April 2009 - November 2010: I was Network Change Operations
Manager, through a UK wide team of circa 50 managers, I was
responsible for maintaining the size and shape of the post office
network through post office branch relocations, refurbishments, re-
openings, new operating models and formats in line with POL’s
Network Strategy.
h. December 2010 — August 2012: I was Head of Network Services,
through a UK-wide geographically dispersed field team of 200 people,
delivering a yearly average of 120 network change projects (i.e. branch
relocations, refurbishments, closures and re-openings) across the Post
Office network; in excess of 5500 financial and compliance branch
audits and interventions; new entrant training for approximately 1000
agents/franchisees and employees and; 2000 recruitment and/or
contractual interviews. I was also responsible for maintaining the size
and reach of the Post Office network, including determining whether
branches in new locations should be opened.
i. September 2012 — August 2013: I was Head of Partnerships. I was
responsible for the relationship between Post Office and the
recognised representative bodies: the Communication Workers Union,
Unite the Union and the National Federation of Subpostmasters.
j. August 2013 —- March 2015: I was Programme Director for the Branch
Support Programme. I was responsible for reviewing the existing level
of support that the Post Office provided to branch operators, identifying
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gaps and making recommendations/introducing improvements to close
those gaps.
k. April 2015 - December 2016: I was Director of Support Services
where I was responsible for the Post Office helpline for
Subpostmasters (NBSC), the customer helpline, the Financial Service
Centre (FSC), the Human Resources Service Centre (HRSC), and also
managing the Contract Advisors and Contract Administration teams.
I. January 2017 — January 2018: I was the People and Change Director,
responsible for HRSC, Health and Safety and the Change Portfolio
(business transformational projects) across the organisation.
m. January 2018 — July 2018: I was People Services Director responsible
for HR services within the Finance and Operations business unit,
Health, Safety & Well-being and the HR Service Centre.
n. August 2018 — May 2020: I was Business Improvement Director and I
worked closely with Counsel and Legal Advisors, to assist in preparing
the Post Office case to defend a Group Litigation brought against it
(Bates v Post Office (No 3) [2019] EWHC 606 (QB)) whilst
simultaneously making improvements to the franchise support model.
10. In addition to my roles detailed above, from 2012 onwards, I was a member of
the Working Group, the Initial Complaint Review and Mediation Scheme and
the Postmaster Litigation Steering Group. I was also a witness for POL in the
Common Issues and Horizon Issues trials (further details below).
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11. Since leaving POL in May 2020, after a short period as Head of People with
the Football Association of Wales (December 2020 — March 2021), I have
operated as a freelance HR Consultant.
THE HORIZON IT SYSTEM
12. In respect of the Horizon IT System, the Inquiry have provided me with the
following documents, which I have reviewed and reflected on below:
a. POL00178199 (email from Clive Burton to me on 19 March 2004);
b. POL00041564 (Computer Weekly article dated 11 May 2009);
c. POL00026572 (Rod Ismay Report dated 2 August 2010);
d. POL00088956 and POL00088957 (emails from John Breeden to me
on 5 December 2010); and
e. POL00294728 (email from Tracy Marshall to me on 5 January 2011).
13. Document POL00178199 (email from Clive Burton to me on 19 March 2004)
refers to a Mrs Pugh, who was a SPM at Chirbury Post Office from 21 April
1999 to 3 September 2001, when her contract for services was suspended.
The email requests assistance with obtaining information to assist the Legal
Services Department with preparing statements for Mrs Pugh’s Court case,
relating to her final audit and the Post Office accounting system. I did not
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remember this email prior to the Inquiry providing it to me so I requested a
copy of my response to this email and the subsequent email chain
(POL00178200). From the email provided, I can see that I forwarded Clive
Burton’s email to Emlyn Hughes (Contract Manager within my team at the
time) to deal with the request for information. Emlyn forwarded the email to
contacts within the business (as that information was not within our team), to
provide the information to Clive Burton. I can see that this was treated as a
routine request for information. I am unable to add anything beyond what is
contained in the email chains (POL00178200, POL00178201, POL00178208,
POL00178211, POL00178219, POL00178223, POL00178221 and
POL00178225).
Document POL00041564 is a Computer Weekly article dated 11 May 2009
entitled ‘Bankruptcy, prosecution and disrupted livelihoods — Postmasters tell
their story’. I do not recall seeing this article at the time it was published, or at
any time subsequently, prior to it being provided to me by the Inquiry.
However, I am familiar with the SPM’s cases which it discusses.
Document POL00026572 is the Rod Ismay Report dated 2 August 2010. I
had no knowledge or involvement in the preparation of the report. I was not on
the initial distribution list and so I did not receive this report when it was first
produced on 2 August 2010. In terms of the content of the report, it reinforces
POL’s understanding and internal messaging at the time that Horizon was
robust and that:
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a. Only “authorised” branch users could create or accept transactions in
the system
b. “all transactions and events are tagged and traceable to the user”
c. “Sequential referencing of transactions, customer basket and
associated IDS. Prevent gaps, duplications or anonymous
transactions.”
d. “Audit file and read only control — transaction records securely sealed”
Whilst I cannot recall receiving the report, I assume that I would have been
reassured by its content at the time. However, knowing what I know now (as a
result of the Group Litigation Order trials and what has been presented to the
Inquiry), the report in my view was/is inaccurate on a number of points.
Importantly, it seems that full investigations were not carried out at the time as
Horizon was not considered as a possible or potential factor to the losses and
notably the report states that there is an “absence of ‘backdoors” whereas I
now understand the Fujitsu Super Users did have access to branch accounts.
Documents POL00088956 and POL00088957 are two emails from John
Breeden to me on 5 December 2010. I do not recall seeing these emails
before and requested further disclosure on any response that I made to
John’s email, as well as any subsequent emails in this chain to help me
understand what I did as a result of receiving these emails. However, POL
has been unable to locate any response from me.
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Document POL00088957 is an email forwarding me a copy of the Rod Ismay
Report. Neither the email nor Rod Ismay’s report stick out in my memory as
something important that I received prior to the Inquiry. In hindsight, I
appreciate the importance of this report in that it reinforced POL’s position that
Horizon was robust but I cannot recall it registering as something important at
the time.
Document POL0008956 is another email from John Breeden to me on 5
December 2010. Again, I cannot recall this email or the content of the pack
he attaches. Having reviewed the email, I have noted that Lynn Hobbs
(General Manager of Network Support) advised Mike Granville and Rod
Ismay that she had “found out that Fujitsu can actually put an entry into a
branch account remotely.” In her email to John Breeden, she says she had
discussed with Mike Granville and Andy McLean (POL’s senior IT team) were
looking into the “remote access to Horizon issues” but no update was given at
that point. I have asked for any subsequent emails in this chain to help me
understand what I did as a result of receiving these emails but POL have
been unable to locate a response from me. I would have expected to see
something further and my only explanation is that either IT did respond and
provided a plausible explanation or else IT did not respond and it dropped off
the radar because Lynn subsequently left the organisation and we were
getting messaging from the business that disputed it i.e. remote access was
not possible. Although I cannot recall, I assume that I satisfied myself that
senior people within IT were aware and looking into it and that no further
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action was needed from myself unless told otherwise. Again, with the benefit
of hindsight, I wholly appreciate the importance of this comment and I have
questioned myself, knowing what I know now, as to why it did not register. I
have, however, noted that Tracy Marshall’s email a month later (document
POL00294728) also references the ability for Fujitsu to have remote access
stating “Technically, Fujitsu could access an individual branch remotely and
move money around however this has never happened yet...so although
changes can be made remotely, they would be spotted and the person
making the change would be identified.” I assume that in the period, between
December 2010 and January 2011, the issue of ‘remote access’ was explored
by POL with this being the outcome. I have discussed the content of this email
in further detail below, in my response to questions about the Ferndown
meeting.
The below deals with the nature and extent of my knowledge of the Horizon IT
system when it was first introduced to the business.
As a Branch Manager in the late 90s, I worked with the forerunner to the
Horizon IT system for around 1 — 2 years. This system was then replaced by
the Horizon IT system which was the same system rolled out to the whole
network of post offices from 2000 onwards. I distinctively remember the
messaging from the Post Office, that the Horizon system was the largest and
most secure system in Europe at that time.
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In terms of what training I received on the Horizon IT System, I was working
as a Retail Network Manager/Area Manager when Horizon was rolled out to
sub-post offices. I believe that I received the same level of training as a
Branch Manager/SPM, which from memory was around 1.5/2 days. This was
at a local hotel where the trainers had set up Horizon equipment for the
purposes of training and we were taught how to operate it. I also attended the
training sessions that my SPMs and their staff attended (I believe that this
was 1 day for counter assistants and an additional half day/day for SPMs and
those assistants involved in the preparation and production of the branch cash
account) to support them through the process. I do not recall any particular
concern from SPMs about the training at the time other than it was going to be
a new way of working in branch for them. As Retail Network Managers, we
had planned to be in branch with SPMs for their first few cash accounts to
offer our support in embedding the training they had received and also to help
them with any misbalancing issues should there be any.
In terms of ARQ data, I believe that my first knowledge of ARQ data was
when Helen Rose used it to look into what had happened at the Ferndown
Post Office branch in preparation for the meeting with the SPM on 6 January
2011 (discussed further below).
I cannot recall now exactly what detail the ARQ data gave us, however my
understanding was that it provided insight into what had happened on the
Horizon system at the branch level. It therefore gave the information we
needed to piece together the picture of what had happened in a branch.
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The next reference that I remember to ARQ data was when Helen Rose was
looking into the issues experienced at Lepton as part of the Spot Review
process with Second Sight in early 2013 (Jan/Feb 2013).
Following this, I recall that when the Initial Complaint and Mediation Scheme
(‘the Scheme”) was established in August 2013, ARQ data was part of the
data/information pack that the Case Review Advisors used to investigate the
issues raised by the Scheme applications.
With the Scheme investigations concluded, the Support Services Resolution
Team was created (April 2015) to investigate any issues raised by post office
branches as part of ‘Business As Usual’. They used the investigation
approach developed for the Scheme and ARQ data continued to be part of
the data/information pack (event and transaction logs, Helpline logs, branch
trading reports, training records and others depending on the issue raised)
used by the team.
I don’t believe my knowledge of ARQ changed over time.
The first time I recall becoming formally aware of any bugs, errors or defects
in the Horizon IT system (“BEDS’” — although this wasn’t the term used at the
time), was when POL disclosed to Second Sight two anomalies — ‘Receipts
and Payments Mismatch Problem’ and the ‘Local Suspense Account Problem’
which were detailed in the Interim Report 8 July 2013 (POL00099063). From
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memory, Second Sight were putting together their report and the Legal team
said that they had been made aware of a couple of anomalies which they
needed to disclose. This was the first that I had heard of any bugs so it was a
surprise but I remember being reassured by the IT experts that bugs of this
sort were pretty routine and computer systems always have errors such as
these. Although, looking back at the timeline, this was the first revelation that
there were any bugs in the system at all, I do not recall that it set alarm bells
ringing as the IT experts were not concerned. The line was that these weren't
major, had been spotted and resolved and it was business as usual.
Prior to this, I was aware of general ‘rumblings’ of complaints and concerns
about the integrity of Horizon and I believe that when I took over the
responsibility for the Contract and Administration team, I became aware of
claims that the Horizon system itself was generating the discrepancies in
branches. These complaints were further formalised towards the end of 2011,
upon receipt of letters of claim from Shoosmiths when we started to engage
with Alan Bates/Justice For SPMs Alliance (“JFSA”) and later with Second
Sight in 2012. However, these complaints and concerns were all against the
backdrop of the very strong POL message that the Horizon system was
robust and the internally held view that all of these complaints were
unsubstantiated claims from disgruntled former SPMs. As mentioned in the
paragraph above, it was only when POL disclosed to Second Sight that there
were two anomalies within Horizon in 2013, that there was any suggestion the
system was not fool-proof but, even then, a rational explanation was provided
by IT experts. The strong message from POL continued to be that ‘remote
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access’ by either Fujitsu or POL employees to alter data in branch accounts
was not possible.
Pre-2011, I had no knowledge of the ability of Fujitsu employees to alter
transaction data or data in branch accounts without the knowledge or consent
of SPMs. In early 2011, I received an email from Tracy Marshall
(POL00294728) (discussed in further detail below) which made me aware that
Fujitsu employees could, in theory, have remote access but not without the
knowledge of SPMs.
Below, I have detailed the key messages from POL on remote
access/integrity of the Horizon system that shaped my understanding over the
years. These extracts all show a strong message that Horizon was robust and
altering data via remote access was not a plausible explanation for branch
discrepancies. I highlight these extracts to try to help the Inquiry to understand
what the internal messaging was within POL at the time in respect of remote
access. Where concerns were raised, there always appeared to be a rational
explanation that countered the initial allegation. I do not think that this was just
from a PR perspective, but a genuine belief which appeared to be supported
by IT experts. Despite clarification being sought over the years the message
that Horizon was robust, never changed.
a. 18 June 2012: Document POL00027722 is a meeting pack, put
together for a meeting with James Arbuthnot and other MPs scheduled
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for 18 June 2012. This contains speaking notes for Paula Vennells
which states “/ am confident about the integrity of Horizon; it was built
on robust principles of reliability and integrity. It has undergone many
external audits and no problems of this nature have ever been raised.”
. 8 July 2013: Document POL00099063. Second Sight’s Interim Report
quotes Ed Davey (Postal Affairs Minister) - “However, POL continues
to express full confidence in the integrity and robustness of the Horizon
system and also categorically states that there is no remote access to
the system or to any individual branch terminals which would allow the
accounting records to be manipulated in any way.” This was at a time
when two bugs had been disclosed but, in my mind, were reviewed and
dismissed as minor.
. 9 April 2014: Document POL00148075. Update on Deloitte’s work to
Project Sparrow subcommittee — “Although no system could be
absolutely “bullet proof’, no issues had yet been identified through the
cases being investigated or any other route that has called into
question the integrity of Horizon. Nor have any wide-spread systemic
faults been identified since Horizon online was implemented.”
. 25 July 2014: Second Sight’s Part One Report (POL00004439)— “Post
Office has advised that a limited number of security personnel at
Fujitsu had read-only access to this audit server. Post Office has
additionally confirmed that it is their understanding that it is not, and
never has been, possible for anyone to access Branch Data and
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amend live transactional or stock data without the knowledge of the
Subpostmaster or their staff.”
e. 13 October 2014: Approved POL messaging from POL Comms team
(POL00091394) — “Our current line if we are asked about remote
access potentially being used to change branch data/transaction is
simply: ‘This is not and never has been possible’. There is no remote
access for individual branch transactions. Fujitsu has support access to
the ‘back-end’ of the system used for software updates and
maintenance. This is of course strictly controlled with security
processes in place, but could not, in any event, be used for individual
branch transactions — there is no facility at all within the system for
this.”
f. January 2015. POL written submission to the Department of Business,
Innovation and Skills (“BIS”) (now known as the Department for
Business, Energy and Industrial Strategy) Select Committee — “There
is no functionality in Horizon for either a branch, Post Office or Fujitsu
(suppliers of the Horizon system) to edit, manipulate or remove
transaction data once it has been recorded in a branch's account. It is
possible for Fujitsu to view branch data in order to provide support and
conduct maintenance but this does not allow access to any
functionality that could be used to edit recorded transaction data.”
g. March 2015: POL’s draft response to Second Sight’s Thematic Issues
Report (POL00022382) — “There is no functionality in Horizon for the
7 https://committees.parliament.uk/work/1803/post-office-mediation/publications/
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Post Office or Fujitsu (suppliers of Horizon) to edit, manipulate or
remove transaction data once it has been recorded in a branch's
accounts. The Post Office can only post additional, correcting
transactions to a branch’s accounts but only in ways that are visible to
Postmasters e.g. transaction corrections (TC) and transaction
acknowledgements (TA). It is also possible for Fujitsu to view branch
data in order to provide support and conduct maintenance but this does
not allow access to any functionality that could be used to edit recorded
transaction data.”
. April 2015: POL’s Response to Second Sight’s Briefing Report Part
Two (UKGI00000018) — “To be clear, Horizon does not have
functionality that allows Post Office or Fujitsu to edit or delete the
transactions as recorded by branches”.
17 August 2015: Final statement for Panorama
(POL00231477)‘Remote Access. Neither Post Office nor Fujitsu can
edit the transactions as recorded by branches. Post Office can correct
errors in and/or update a branch’s accounts by inputting a new
transaction (not editing or removing any previous transactions).
However, this is shown transparently in the branch transaction records.
There is no evidence that any branch transaction data was
inappropriately accessed from a remote access point.”
22 August 2015: Statement from POL’s in-house lawyer
(POL00091401) — “Remote Access. Neither Post Office nor Fujitsu
can edit the transactions as recorded by branches. Post Office can
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correct errors in and/or update a branch’s account by inputting a new
transaction (not editing or removing any previous transactions).
However, this is shown transparently in the branch transaction records.
There is no evidence that any branch transaction data was
inappropriately accessed from a remote access point.”
. 21 July 2016: Remote access wording presented by Bond Dickinson to
PLSG (POL00024802) — “Balancing transactions. Fujitsu (not Post
Office) has the capability to inject a new “transaction” into a branch’s
accounts. This is called a balancing transaction...A balancing
transaction can add a transaction to the branch’s accounts but it cannot
edit or delete other data in those accounts. Balancing transactions only
exist within Horizon Online (not the old version of Horizon) and so have
been in use since around 2010...Access to databases. There are a
small number of persons at Fujitsu (not Post Office) who have special
permissions to access and edit, within strict controls, the databases
and servers that sit behind Horizon. Use of these permissions is logged
and so there would be an audit trail of any activity undertaken using
these permissions...During the Scheme, it was alleged that Post Office
had the ability to ‘remotely access’ Horizon in order to conduct
transactions. This allegation is understood to mean that a Post Office
(or Fujitsu) employee could log on to a terminal in a branch from a
different location outside the branch and conduct (or edit or delete)
customer transactions. To be clear: this is not possible.”
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When presented with this information, I took the experts at their word. To
learn that this was incorrect shocked me deeply.
In the midst of this messaging, there were genuine cases where SPMs
complained about Horizon IT system causing issues but, when investigated, it
was proved that they (or their assistants) caused the error. I remember
distinctively a SPM writing to Paula Vennells that an error had occurred in his
branch. He was extremely diligent and experienced and was confident that he
had not caused the error and that therefore it must be the Horizon system.
Paula asked me to investigate and so my team went to the branch.
Unusually, the SPM had CCTV positioned so perfectly, you could see the
counter transactions. The team honed in on a Saturday morning transaction,
which was a £1k deposit into a bank account. In the CCTV footage you can
see the SPM serve the customer and process the £1k deposit on Horizon,
however rather than taking a £1k from the customer he mistakenly gave the
customer a £1k as if the customer was making a withdrawal. This resulted in a
£2k loss on balancing. It was instances such as this that leaned me more
towards the thinking that discrepancies were more likely to be caused by user
error rather than issues with Horizon, as even the best SPM could make
mistakes.
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OPERATION OF POL AND HORIZON
35. The below deals with my involvement and oversight in the following matters:
a. Provision of advice and assistance to SPMs in respect of disputed
shortfalls
b. Training on the Horizon IT system
c. POL’s audit of SPM’s branch accounts and/or seeking the recovery of
alleged shortfalls in branch accounts
d. POL’s procedures for resolving disputes with SPMs in respect of
discrepancies in branch accounts
e. POL’s prosecutorial function
f. POL’s handling of complaints made by or litigation involving SPMs in
which the integrity or adequacy of the Horizon IT System was raised
Provision of advice and assistance to SPMs in respect of disputed shortfalls
36. Prior to 2011 I had no involvement in the provision of advice and assistance to
SPMs in respect of disputed shortfalls.
37. In terms of how often SPMs would raise concerns about the Horizon IT
system, I am not aware of this information or that it was specifically tracked
within Royal Mail (pre 2012) or POL from 2012 onwards.
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The immediate reporting route for Post Office branches for problems with
Horizon was the Horizon Service Helpdesk (Fujitsu) and/or the Network
Business Support Centre (NBSC — “the Helpline”). From what I recall, if a
disputed shortfall was a result of a Transaction Correction, the SPM would
contact the FSC. If they were unable to assist, they would refer to the Dispute
Resolution Manager (Andrew Winn) for further investigation. If the disputed
shortfall was due to an in-branch misbalance, the SPM would ring the Helpline
for assistance in the first instance. If still disputed, they would again be
referred to the FSC and/or Dispute Resolution Manager for investigation. This
was both pre and post 2011.
When the Scheme was established in August 2013, I led POL’s investigation
into the issues raised in the 150 cases submitted to the scheme. Part of this
investigation process was to look into the level of advice and assistance that
had been provided to SPMs. On looking at the detail of the advice and
support provided to some SPMs in the Scheme I was disappointed to see a
lack of support from Area Managers/Retail Network Managers in some cases.
These were roles that I had done previously, and I had gone out of my way to
provide the best support I could to SPMs, on occasions working late into the
evenings to do so and I was disappointed to see that some SPMs did not
receive what I regard as an appropriate level of support.
The Helpline was the first port of call for SPMs who were having issues with
Horizon and from April 2015 — December 2016, as Director of Support
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41.
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Services, part of my responsibilities included oversight of the Helpline, which
included identifying its shortcoming and trying to fix them.
On 24 October 2016, I co-authored a paper with Marc Reardon that stated
“Horizon Help (the in-branch support tool) has since its introduction over a
decade ago fallen short of delivering the in-branch self-help functionality that
was promised as part of Horizon roll-out and that postmasters and their
assistants desperately need.” This paper has not been disclosed but is
referenced at paragraph 420 of Bates v Post Office Ltd [2019] EWHC 606
(QB). The paper shone a spotlight on the weaknesses of the system as I
wanted to land the point about its shortcomings to get a business case over
the line for its improvements. Whilst the Helpline was adequate in terms of its
content, it wasn’t the easiest or quickest to navigate. I remember that I wanted
to upgrade the system so that it operated like a google search, where SPMs
could search for an issue and get a response quickly. Another issue, was that
Helpline operators were relying on the SPM to describe the problem
accurately so that they could assist, whereas often the SPM didn’t know what
had caused the problem. I can recall wanting to put in place a system
whereby SPMs could share their screen with the Helpline operators to
improve the assistance that Helpline could offer. Unfortunately, this was never
implemented. I regret that I was not able to get either of these improvements
implemented.
In considering whether the advice and assistance available to SPMs was
adequate, my view is yes on the whole, however I think this depended very
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much on the person who was supporting the SPM. As mentioned above, the
Scheme revealed that there were occasions when the Area Managers or
Retail Network Managers did not provide what I regarded as adequate
support.
Training
43. Pre-2011, when the Horizon IT system was being rolled out to Post Office
branches, I had been a recipient of that training in my role as Retail Network
Manager. As detailed above, I also attended the training sessions that my
SPMs and their staff attended, to support them through the process and on
roll out, I along with my colleagues, supported SPMs in branch with their first
few cash accounts.
44. In my view, the initial Horizon IT training in advance of roll-out in 1999/2000
appeared to be adequate for the SPMs within my area. From memory, some
SPMs adapted better than others and in my role as Retail Network Manager I
was on hand to support where required but I don’t recall any particular issues
with the training. For new SPMs and staff appointed post the Horizon roll-out,
using the Horizon system was embedded into the new entrant training. Again,
I don’t recall any specific issues.
45. From December 2010 — August 2012, as Head of Network Services, I had
responsibility for the Audit and Training team. I believe at this time they were
called Field Support Advisors. My oversight of this team was to ensure that
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46.
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training was appropriate and delivered to a good standard and that the team
was appropriately resourced. The scheduling of training was done by the
Scheduling & Admin team. Feedback on the quality of the training delivered
was tracked through a customer satisfaction survey that those receiving the
training were asked to complete at the end of their training.
In this role I initiated a review of the new entrant training approach which was
led by the Network Support Projects and Standards Manager. Upon review,
the training for new entrant SPMs needed to be reconfigured as it pretty much
was a one size fits all and didn’t reflect the new Post Office models e.g.
Mains, Locals, outreaches and their specific training requirements (Mains did
the full range of products and services whereas Locals had a limited
range).This review resulted in a revised training approach that better
recognised the different types of post offices in the network and therefore
made the training more relevant.
In my role as Branch Support Programme Director from August 2013 — March
2015, we looked into issues around training. Problems identified and rectified
included: introducing an introductory call to new SPMs 2 weeks before they
took up post; replacing a telephone call 1 month after they had taken up post
with a branch visit from a trainer; refreshing training on balancing to help
SPMs identify and resolve balancing problems earlier.
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POL’s audit of SPM’s branch accounts and/or seeking the recovery of alleged
shortfalls in branch accounts
48.
49.
As noted above, from December 2010 — August 2012, as Head of Network
Services, I had responsibility for the Audit and Training team. This role
including having general oversight of the auditing team to make sure that they
did their jobs properly and were adequately resourced. Audits were scheduled
by the Scheduling & Admin team. There were different types of audits: risk
based audits were scheduled using a tool (Branch Performance Profile) that
used a number of criteria the details of which I can’t remember now, however
I believe holding more cash in branch than it should was one; Special Audits,
which were requested usually from P&BA (later known as FSC), the Fraud
Forum or the Security team in response to concerns they had; and Transfer
Audits, which were done when transferring a branch from the outgoing SPM
to the incoming SPM. Audits were also requested to establish actual loss
following a robbery or burglary at a branch. The Network Support Projects and
Standards Manager (direct report to me) produced a report each month on the
summary of the findings at audit which fed into a quarterly report I did for the
Audit & Risk Committee that I attended (POL00141432 is the Q1 2012/2013
report).
Another area of focus for me was spending time with the Field Support
Advisors and their Team Leaders to understand the mood within the team and
importantly what was affecting that mood - what was working well, what
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wasn’t, what were the improvement opportunities - so that we could constantly
improve as a team in supporting SPMs better.
50. Should an audit uncover a shortage, under the terms of the SPM contract,
failure to make good a shortfall could be escalated to the Contract Manager
as a potential breach of contract. Again, as Head of Network Services I was
responsible for the Contract Managers. Their role was to investigate whether
there was breach of contract and, depending on the seriousness of any
breach, they would consider whether action was necessary, taking into
account any mitigating circumstances usually discussed during an interview
with the SPM.
POL’s procedures for resolving disputes with SPMs in respect of discrepancies in
branch accounts
51.Prior to 2011, I did not have any involvement in, or oversight of, resolving
disputes with SPMs in respect of discrepancies with branch accounts.
52. From August 2013 — March 2015 I was Branch Support Programme Director.
The Branch Support Programme sought to make improvements for SPMs by
addressing key issues raised in the Second Sight Interim Report and some
issues raised in the Scheme, including helping improve procedures for
resolving disputes with SPMs in respect of discrepancies in branch accounts.
For example, there was criticism that the process for resolving disputes was
slow. I used the programme to refine processes so POL reacted more
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responsively to reports of unexplained losses by fast-tracking them to the
Branch Support Team for resolution. If further investigation was needed, the
case was referred to the Mediation Case Review team (later called the
Support Services Resolution team) who had the benefit of real time data tool
from Fujitsu, enabling analysis to be undertaken at the point it happened
rather than waiting for historical data to be gathered.
I also looked into suspensions and in 2014 I introduced ‘suspended
termination’, a new category of action in dealing with material breaches of
contract. The usual process was, if a discrepancy was found which was over
a certain amount (from memory I think £1,000), the SPM would be suspended
immediately pending investigation. The new approach recognised that the
previous policy of precautionary suspending the SPM whilst investigations
were done, potentially damaged the reputation of the SPM in their community
regardless of whether the SPM was reinstated or not. The essence of the new
approach was that suspending a SPM was the last resort. The majority of the
investigative work was to be done in advance of the audit (rather than after
the audit had taken place, as per the previous approach) and the Contracts
Manager was to work with the SPM to establish the facts and then take the
appropriate action, keeping the SPM in post and the branch operational
wherever possible. This reduced the number of SPM suspensions by around
50% in the year of its introduction.
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From April 2015 — December 2016, my role as Director of Support Services
included oversight of the FSC. Originally, it was part of the FSC role to help
resolve disputes with SPMs in respect of discrepancies at branch accounts.
This work was migrated to the Support Services Resolution Team from 2015
onwards, part of my broader team who used the investigation approach
developed for the Scheme.
POL’s prosecutorial function
55.
I had no involvement with, or oversight of, POL’s prosecutorial function.
POL’s handling of complaints made by or litigation involving SPMs in which the
integrity or adequacy of the Horizon IT System was raised
56.
57.
From memory, these were all handled by POL’s Legal team, although
requests for information were routinely made to the Contracts and
Administration team, for example for training and audit records. When I
became a member of the POL JFSA Steering Group, I believe that my role
was to help coordinate any requests for information from my Network
Services team, although I cannot recall the specifics.
In addition, as part of the Second Sight Spot Review process, I coordinated
information from within POL to assist Second Sight with their investigations. I
was also a member of the Working Group, the purpose of which was to
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oversee/ensure a fair and transparent process for applicants to the Scheme.
Further details on the Scheme and my involvement in it are below.
FERNDOWN INTERVIEW
58.
59.
60.
The below deals with my recollection of an interview undertaken in respect of
the Ferndown Branch, Dorset on 6 January 2011. In answering the Inquiry’s
questions about the Interview, I have reviewed the interview notes
(POL00294743).
I first became aware of the Ferndown branch when Lynn Hobbs (General
Manager Network Support) contacted me about providing a mobile Post
Office service near to the Ferndown branch if it were to close/remain closed.
The closure was as a result of an audit and subsequent suspension of the
SPM. I advised Lynn that I could provide a mobile post office to be set up near
the branch however I did not think that it would cope with the volume of
business that Ferndown transacts (this was a sizeable post office).
Although I do not recall the precise date that I was contacted, it would have
been prior to December 2010 and before I was appointed to the Head of
Network Services role. I can remember that this was a high-profile case, as it
had attracted a lot of media attention and had been raised with Dave Smith
(POL Managing Director at the time) and Paula Vennells, to whom Lynn
Hobbs reported direct.
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61.
62.
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My next involvement was when Kevin Gilliland, Network Director, asked me to
attend an interview with him due to my line manager (Sue Huggins — a direct
report to Kevin) being away on holiday. The interview was to be with the SPM
of the Ferndown branch, Mrs Rachpal Athwal and to take place on 6 January
2011. From POL’s perspective, I believe that the overarching purpose of the
meeting was to reset the relationship with the SPM and her husband,
following the suspension of the SPM due to a discrepancy at the branch. The
SPM and her husband didn’t believe that they were responsible for that
discrepancy and so the focus of the meeting was to find out what had
happened in the branch to generate the discrepancy.
Helen Rose, from the Security and Investigations team, was also asked to
attend the interview, to provide an insight into what had happened in the
branch using the relevant reports from the Horizon system. Helen’s role at the
interview was to walk through what the Horizon information was indicating had
happened in respect of user activity on the Horizon system. My role in the
meeting was to support Kevin (who led the meeting) in providing a more
operational level of knowledge and experience. This was the first time I had
ever attended an interview with a SPM and I think that I was asked because
Kevin’s operational experience was limited, whereas I had more extensive
and recent operational experience from working closely with branches.
The transcript from the interview is at POL00294743. During the interview I
stated that nobody in POL could remotely access the in-branch Horizon
system because it is all done from a user ID. I also said that nobody from
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Fujitsu could go in and amend the accounts without having been seen to have
done so. This information was based on an email received from Tracy
Marshall the day before the meeting (5 January 2011) (POL00294728). In this
email Tracy stated “POL cannot remotely access systems and make changes
to specific stock units etc.” She also stated that Fujitsu can remotely access
systems but “although changes can be made remotely, they would be spotted
and the person making the change would be identified.” I understand that
Tracy provided this information specifically for this meeting. I had not been
involved in this previously and would not have had first-hand knowledge or
experience of this level of detail on Horizon and from my comments in the
transcript, I seem to have taken this information from Tracy at face value. I
would not have had any reason to doubt its accuracy and whilst I cannot
remember my thought process at the time, I expect I was reassured by her
experience and the fact she has stated “the authority process required and
the audit process are robust enough to prevent this activity [changes made
remotely] from being undertaken fraudulently.” With hindsight and a better
understanding of what access Fujitsu had into individual branch accounts, I
know now that the information I provided in respect of Fujitsu was incomplete.
At the time, I did not know that to be the case.
SHOOSMITHS LITIGATION
64. The below deals with the nature and extent of my involvement in POL’s
response to the litigation threatened by Shoosmiths / Access Legal who were
acting for several former SPMs who had come together in the JFSA.
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65. In answering the Inquiry’s questions on this issue, I have reviewed the
following:
a. POL00046944 - This is a letter of claim in respect of Mr Wilson (former
SPM), dated 23 August 2011. I do not recall having seen this letter
before although I can see that it is referenced (but not attached) in
document POL00176467.
b. POL00294879 - The Inquiry have referred to this document as ‘Terms
of Reference for Steering Group’. As I understand it, this is an email
from Rod Ismay to the proposed members of a JFSA Steering Group
and whilst it sets out the purpose of the Group and the current situation
in respect of Shoosmiths (Access Legal), it does not detail any terms of
reference.
c. POL00176467 — This is an email from me to my Network Services lead
team, ensuring that they were aware of the advice from POL’s legal
team in respect of the JFSA cases.
66. From my recollection, POL’s response to the litigation threatened by
Shoosmiths / Access Legal was very much led by the Legal team. Having
reviewed POL00294879, my involvement was predominately due to the
Ferndown meeting (detailed above). However, as Head of Network Services,
the Contracts and Admin team, trainers and auditors were part of my
responsibility and so I would have been able to facilitate the provision of
information/documents from my team that the Legal team required. My role
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67.
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meant that I was in a position to get information to lawyers as quickly as
possible. I later became the ‘go to’ person for information (for the Spot Review
with Second Sight and then the Scheme) as I knew my way around the
business and if I didn’t know the answer myself, it was highly likely that I knew
the person who did.
In terms of POL’s strategy in responding to the Shoosmiths litigation, this was
prior to the 2012 separation and so would have been led by Royal Mail rather
than POL. I don’t recall seeing anything that set out any strategy however, as
detailed in the email from Rod Ismay to proposed members of the JFSA
Steering Group (POL00294879), the purpose of that group was “To define
and manage a coordinated response plan which defends existing challenges
and deters future challenges, in the most pragmatic and efficient manner”. I
can remember that this was the approach and tone of the discussions that
took place, with the lead being taken by Royal Mail’s Legal team.
In my email dated 21 October 2011 (POL00176467), I forward an email from
Emily Springford of the Legal team, which gave instructions around three
headings: document preservation; document creation; and information
required to respond to letters before action. My email asks everyone to read
Emily’s email and lists three bullet points, which appear to be my
interpretation of the key takeaway points from each of these headings:
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69.
70.
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a. “preserve all documents which might potentially be relevant to these
claims...”
b. “Mark communications in relation to these cases and as detailed below
as ‘legally privileged and confidential”
c. “Treat any request for information in relation to these cases as a
priority”
The Inquiry have specifically asked me why I wrote the second bullet point —
“Mark communications in relation to these cases and as detailed below as
‘4legally privileged and confidential”. I believe that this was my key takeaway
point from Emily’s instructions under the heading ‘Document Creation’ and so
I wanted to highlight it to the team, as I had highlighted my key takeaway
points from the other two headings.
My email to the team was to ensure that they were sighted on the potential
legal action in respect of these cases and that they were aware of, and
complied with, the instructions set out in Emily’s email. I was passing on the
instructions from the Legal team and my email was intended to summarise
Emily's email, with the overarching message that her email should be read in
full.
The Inquiry have asked to what extent, if at all, legal professional privilege
was used within POL to try to prevent the disclosure of documents that could
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prejudice its position in relation to the Horizon IT System. During my time with
POL, I do not believe that it was.
ENGAGEMENT WITH MPs IN EARLY 2012
72. Preparing responses to MPs or journalists was the responsibility of the
Communications Team. As I understand, when they received a question, they
would reach out to the relevant contacts within POL to obtain information for
any response and may ask for the content to be reviewed for accuracy before
they responded.
73. In terms of the extent to which I was involved in preparing POL’s response to
MPs who raised concerns about the integrity of Horizon in early 2012, my
involvement was to provide information, when requested, to those within POL
who were preparing a response. An example of this approach is in
POL00085836, where I actioned a request from Simon Baker with my team to
provide documentation of our SPM appointment and training process.
74. I have also been provided with, and reviewed, documents POL00113791 and
POL00027722:
a. Document POL00113791 is an email from Susan Crichton to Alice
Perkins and Paula Vennells on 6 June 2012 which attaches the Terms
of Reference for Second Sight. I was copied into this email but I was
not involved in setting or agreeing the Terms of Reference for Second
Sight.
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75.
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b. Document POL00027722 is a meeting pack for a meeting with Lord
Arbuthnot and other MPs on 18 June 2012.
The Inquiry have asked about my involvement in briefing Paula Vennells,
Alice Perkins and other senior managers or Board members on the integrity of
the Horizon IT System (including remote access). I did not do the briefings on
the integrity of the system (including remote access) and I did not have the
technical knowledge to be able to do this. Any such information came directly
from Fujitsu (Pete Newsome was the Fujitsu Account/Relationship Manager
assigned to POL) and was passed on/briefed to senior managers by either/ a
combination of: the POL IT team and / or the Project Sparrow team. I was
very much in ‘receiving mode’ in respect of any information/messages
regarding the integrity of the Horizon system i.e. I did not brief any senior
managers / Board members but was myself a recipient of the information.
Whilst I do remember going to the meeting with Lord Arbuthnot on 18 June
2012, I do not remember much about the meeting itself. I do, however,
remember the prior meeting with James Arbuthnot and Oliver Letwin, held at
the Post Offices in Old Street on 10 May 2012 and I believe that the meeting
on 18 June 2012 was a follow-on from this initial meeting. I believe that my
involvement in the preparation for both meetings was to pull together the
information on the two cases — Hamilton and Merritt — to be able to explain to
the MPs from the information we had, what had happened in these cases and
to provide any further information as per the action points in document
POL00137248.
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I cannot recall the specifics as to my involvement with POL’s response to MPs
and journalists who raised concerns as to the integrity of the Horizon IT
System, however, typically my involvement related to issues that a SPM
constituent had raised with their MP. I did meet (usually accompanied with
Patrick Bourke) with some MPs at the request of their constituent to discuss
their issues/Scheme case as appropriate). I also attended the meetings with
MPs — 10 March 2012 and 18 June 2012. In respect of journalists, other than
the Panorama meeting 9 June 2015, my involvement was usually to provide
information to the Communication Team for them to respond to the journalists.
INSTRUCTION OF SECOND SIGHT
78.
79.
I had no involvement in POL’s decision making process in respect of the
appointment of Second Sight or the ambit of its investigation. I believe that
these decisions were joint between Alice Perkins (POL Chair), Paula Vennells
(CEO) and POL Board and that it was endorsed by the MPs (predominately
Lord Arbuthnot) and JFSA. I recall some internal discussions about getting an
external IT expert, such as Deloitte (or another appropriately qualified
organisation), to do a deep dive into the Horizon system, but this was
dismissed in favour of Second Sight.
In terms of the ambit of its investigation, I have reviewed POL00113791,
Second Sight’s Terms of Reference as is detailed in the email from Susan
Crichton to Alice Perkins dated 6 June 2012 and POL00022378 POL’s Initial
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80.
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Complaint Review and Mediation Scheme Report which states that “the Post
Office commissioned Second Sight Support Services Limited to carry out an
independent review of its Horizon computer system, which is supplied to the
Post Office by Fujitsu Services Limited, in response to allegations by a small
number of former Postmasters about the integrity of that system.”
The document also states “The basis of Second Sights initial engagement,
was reflected in a document for Postmasters entitled “Raising Concerns with
Horizon”...and included to: “Consider and advise on whether there were any
systemic issues and or concerns with the Horizon system including training
and support processes, giving evidence and reasons for the conclusions
reached.”
My working recollection of the ambit of Second Sight’s investigation was that
they were to investigate the issues regarding Horizon raised by SPMs via their
MP and/or JFSA. Following the feedback from Second Sight that they couldn't
look in isolation at the Horizon system but rather they also needed to consider
associated elements, their scope broadened to include looking at: training and
support provided to SPMs; operational processes including balancing; branch
trading and transaction corrections; interfaces with other systems e.g. lottery
machine, ATMs; power supply and telecoms equipment; and the effectiveness
of POL’s audit and investigative processes.
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82.As to who had responsibility for the extent of its access to relevant information
83.
and documents, the flow of information and documents was, in the main,
through the Project Sparrow. When the Scheme was established, the Working
Group (chaired by Sir Anthony Hooper) did, I believe, also have oversight of
the provision of relevant information and documents. In terms of my role, due
to my operational experience, I could effectively bridge the gap between Head
Office and SPMs so I would often be asked to provide information.
I have laid out below my review of the following documents which the Inquiry
have provided to me in respect of Second Sight:
a. POL00186110 (email from Simon Baker to me and others on 8 April
2013);
b. POL00296463 (email from me to Simon Baker on 9 May 2013);
c. POL00115919 (draft briefing note to Paula Vennells dated 2 July
2013);
d. POL00141432 (Post Office Branch Audit Trend Analysis dated 7
September 2012); and
e. POL00065349 (my draft letter to Karen Lumley MP).
84. Document POL00186110 is an email from Simon Baker (Head of Business
Change and Assurance) to myself and others dated 8 April 2013. The email
states that, to ensure that there is appropriate governance for the Horizon
investigation, Simon is setting up a monthly project and governance board.
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The broad terms of the Board and how it relates to the overall project
governance are attached (POL00186111). This states that there will be three
levels of governance: Sponsor Board; Project Board and Team Meeting.
Document POL00296463 is an email from me to Simon Baker on 9 May
2013. This emails relates to 4 ‘Spot Review’ responses that I was asked to
comment on. This is an example of where I might be involved to provide
information/comments due to my operational experience. My comments
reflect my approach of working openly and transparently with Second Sight
and in the spirit of what we agreed:
“Intentionally not answering questions raised by 2"4 Sight will in my
view give rise to suspicion i.e. that we have something to hide and is
not in the spirit of our interaction/engagement with Ron and lan. By
trying to dodge answers that may not present POL as positively as we
would like will in the long term come back to bite us. I would much
rather be upfront from the start. There is always a risk that our policies,
procedures and processes would come under the spotlight and in
some cases be deemed to not be as good as some would expect
whether this expectation is reasonable or otherwise — this was a risk I
believe we accepted from the start and whilst the integrity of the
Horizon system may be intact we should not ignore any lessons that
come out of these investigations.”
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86.
87.
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Document POL00115919 is a draft internal briefing note to Paula Vennells on
‘Second Sight review into Horizon — Implications of Interim Report’. This was
a briefing note prepared for Paula in advance of her meeting with James
Arbuthnot MP, to update her on the likely content of Second Sight’s Interim
Report and the potential risks associated with it.
Document POL00141432 is a Post Office Branch Audit Trend Analysis dated
7 September 2012 written by me. Annexed to this is a flow chart to investigate
Horizon claims from branches. At page 3 of this document I have stated
“discrepancies in branch are typically as a result of a cash error over the
counter...” Without seeing the information that sits behind the summary table,
I am unable to say exactly why I concluded this to be the case, however what
I have set out as examples reflected what I understood to be the most
common causes of discrepancies within branches through my experience at
that time.
Document POL00065349 is a draft letter from me to Karen Lumley MP
responding to a letter sent from Karen to Paula Vennells on 11 June. Although
undated, I assume that this was in 2015. The letter is in relation to Julian
Wilson’s case and it explains the Scheme and that mediation is a voluntary
process for both parties. Having reviewed the letter, I take from my response
that POL would not mediate this case due to a previous Court
ruling/conviction. The Inquiry have asked me how I satisfied myself that the
contents of this letter were accurate. I cannot recall from memory and as I
have only had sight of this letter and no related correspondence, I can only
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say that any correspondence that I drafted/sent in relation to the Scheme had
the input from the Project Sparrow team, POL’s legal team and the Comms
team. I am therefore confident that I would have satisfied myself of its content
through discussions and verification with them.
As to how senior managers within POL viewed Second Sight and the purpose
of its investigation, in my view there were two parts to Second Sight’s
investigation: the investigations as part of the Scheme and the investigations
pre this scheme i.e. Spot Reviews. From my observations, the senior
managers within POL (connected with Project Sparrow) who engaged with
Alan Bates/JFSA and subsequently appointed Second Sight, did so with a
genuine desire to get to the truth. That is, to find out if there was any
substance in the claims from JFSA and other SPMs through their MPs, that
the Horizon system was responsible for the losses in their branches that they
had been held responsible for by POL. I think the view of Second Sight
changed over time, when there became a frustration at the slow delivery of
any output. I have provided further detail on Second Sight below.
The Helen Rose Report
90.
The below sets out the nature and extent of my involvement in the creation of
the ‘Helen Rose Report’ dated 12 June 2013 (FUJ00086811) and POL’s
response to the same. The report looked into a transaction that took place at
Lepton SPSO 19130 on 4 October 2012 for £76.09. On the same day, the
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91,
92.
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payment was reversed and the branch was issued with a Transaction
Correction for £76.09. However, the SPM denied reversing the transaction.
Other than my correspondence with Helen Rose on the Lepton Spot Review
(POL00144296 and POL00134139), discussed further below, I had no
involvement in the creation of the Helen Rose report. I am not aware of who
Helen shared it with, or what POL’s response was to the report at the time.
Looking at the background correspondence that the Inquiry have provided me
with, document FUJ00229801 is an email chain in January 2013 with
correspondence initially between Gareth Jenkins (Fujitsu IT engineer) and
Helen Rose and then between Gareth Jenkins and myself. It concerns me
requesting Gareth Jenkins to carry out a formal investigation into the Fujitsu
transaction log for Lepton 191320.
Document POL00144296 is an email from Helen Rose to me on 7 February
2013. Here, Helen is raising concerns about the transaction log for Lepton
about information in ARQ not being visible in Credence. She is also raising
concerns that “the recovery session is showing as a normal existing reversal
rather than a system recovery reversal“. I have not been provided with, and
cannot recall, my response. After this length of time, I cannot recall who I
discussed the detail of this with. However, in trying to establish what had
happened in this situation, I do remember discussing the issue with Ron
Warmington (Managing Director of Second Sight) as part of the Spot Review
process. However, I cannot remember the exact detail of those discussions.
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94. Document POL00134139 is an email from Helen to me on 13 February 2013,
forwarding email correspondence between her and Gareth Jenkins flagging
concerns that Horizon system based corrections and adjustment transactions
are not clear on either Credence or ARQ logs, as shown with the Lepton logs.
I cannot recall my response and have requested a copy of my response to
Helen's email but POL could not locate this which indicates that I did not reply
to Helen via email. I may have had a conversation with her to discuss the
email but, given the passage of time, I cannot remember.
95. I did not share the report with, or brief others in senior management, Board
members, SPMs or MPs on the report. I cannot recall when I first became
aware of the report. I have asked POL for a copy of the covering email from
Helen Rose to recipients of the report but they are unable to locate this email.
I seem to remember that it was brought to my attention by the Legal team as
they were preparing for the Group Litigation Order.
96. The Inquiry have asked to what extent, if at all, did the matters concerning
ARQ raised in the Helen Rose emails and / or the Helen Rose Report made
me or anyone else at POL concerned that past convictions may be unsafe.
Whilst I cannot speak for anyone else, personally I did not make any
connection to the safety of past convictions from the emails from Helen Rose
or the Helen Rose Report. Whilst I realise that this sounds naive,
prosecutions were outside of my area of responsibility and indeed my
knowledge scope. I took no view on how they were put together, other than to
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be assured that they were done in line with the Crown Code for Prosecutors,
with oversight of both internal and external lawyers. Here, the focus was on
the case in front of me. I wasn’t aware of any practical procedures around
disclosure and whilst I do not know if Helen discussed her findings with
anyone else within POL, my assumption would have been that she would
discuss anything important with her line manager and ultimately the Head of
Security and Investigations.
THE INTERIM REPORT AND THE INITIAL COMPLAINT REVIEW AND
MEDIATION SCHEME
97.
98.
The below deals with the nature and extent of my involvement with: a. POL’s
preparation for and response to Second Sight’s reports; and b. the Scheme
and the Working Group established to monitor the Scheme (“the Working
Group”).
I can confirm that I have reviewed the following documents provided to me by
the Inquiry in respect of this subject matter:
a. POL00099063 (Second Sight Interim Report) dated 8 July 2013;
b. POL00298004 (document entitled “Update on the work programme
arising from the Horizon report” dated 26 July 2013) — although not
headed as such, this reads like a Board Update paper;
c. POL00190036 (email from Simon Baker to Alwen Lyons, copied to me,
on 2 July 2013) and POL00190037 (attachment) — the email is simply a
cover email with no narrative. The attachment lists two
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incidents/defects shared with Second Sight and detailed in their Interim
Report 8 July 2013;
POL00116057 (email from Lesley Sewell to me and others on 9 July
2013) — this is an email with Lesley setting out actions ahead of a call
on 9 July 2013;
POL00089711 (Branch Support Programme Terms of Reference v2);
POL00137327 (email from Susan Crichton to me on 25 July 2013) —
this is an email regarding Brian Altman QC’s terms of engagement
which was forwarded to me and Alwyn Lyons as we were not on the
original recipient list.
POL00193074 (email from Simon Baker to me and others on 31 July
2013) and POL00137343 (attachment). The email is a cover email for
sending the attachment which is the Weekly Steering Group meeting
minutes for 1 August 2013. This appears to be setting out the approach
for the initial cases from James Arbuthnot and JFSA which was pre the
Mediation Scheme;
POL00027664 (draft Terms of Reference for the Branch User Forum);
POL00105634 (note of meeting on the Mediation Scheme and Branch
Improvement Programme) — I was in attendance to provide an update
on the Scheme and any improvements made to business processes
etc.;
POL00043640 (notes of the Working Group meeting on 17 October
2013);
POL00026625 (notes of the Working Group meeting on 25 October
2013);
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POL00043622 (notes of the Working Group meeting on 7 November
2013);
POL00043635 (agenda of the Working Group meeting on 22
November 2013);
POL00043624 (notes of the Working Group meeting on 28 November
2013);
POL00027505 (draft settlement policy for the Scheme v1.3)
POL00043625 (notes of the Working Group meeting on 5 December
2013);
POL00026634 (notes of the Working Group meeting on 19 December
2013);
POL00026638 (notes of the Working Group meeting on 3 January
2014):
POL00026682 (notes of the Working Group meeting on 9 January
2014);
POL00026639 (notes of the Working Group meeting on 16 January
2014)
POL00026640 (notes of the Working Group meeting on 23 January
2014) — note that POL action to remind the business that files are not to
be destroyed — Chris Aujard;
POL00026641 (minutes of the Working Group on 30 January 2014);
POL00026635 (minutes of the Working Group on 6 February 2014);
POL00138101 (notes of the Mediation Scheme Programme Board
meeting on 17 January 2014);
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aa.
bb.
cc,
dd.
ee.
gg.
hh.
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POL00043626 (note of meeting of the Working Group on 13 February
2014);
POL00026637 (minutes of the Working Group meeting on 27 February
2014);
POL00026656 (notes of the Working Group meeting on 7 March 2014);
POL00026644 (notes of the Working Group meeting on 27 March
2014);
POL00026633 (notes of the Working Group meeting on 1 April 2014);
POL00148075 (minutes of the Project Sparrow subcommittee on 9
April 2014);
POL00026642 (notes of the Working Group meeting on 10 April 2014);
POL00138282 (notes of the Initial Complaint Review & Case Mediation
Scheme Programme Board on 11 April 2014);
POL00303871 (my email to Kathryn Alexander and another on 22 April
2014);
POL00061368 (email chain on 22 April 2014 regarding the disclosure
of officers’ reports); This appears to be an unfinished internal
discussion on approach to routinely provide Officer's Report with the
POIR. My view was that we should assess on a case by case basis but
proceed with caution in respect of the Officer's Report as per the legal
advice provided. I did request from POL the subsequent email chain so
that I could understand how the discussion concluded. The further
disclosure (POL00169322) did not provide a conclusion. I cannot from
memory recall how we proceeded;
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kk.
nn.
oo.
Pp.
qq.
rr.
ss.
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POL00043627 (minutes of the Working Group meeting on 6 May
2014);
POL00304439 (email from me to Kathryn Alexander on 9 May 2014)
and POL00117650 Email chain between Andy Winn and Alan Lusher
2008 (email from Andrew Winn to Alan Lusher on 23 October 2008);
Email from Andy Winn to Alan Lusher (23/10/2008) stating that the
only way POL can impact branch accounts is via the TC process.
Fujitsu has the ability to impact branch records via the message store
but have extremely rigorous procedures in place to prevent
adjustments being made without prior authorisation within POL and
Fujitsu’;
POL00026657 (minutes of the Working Group meeting on 15 May
2014);
POL00026659 (minutes of the Working Group meeting on 20 May
2014);
POL00026668 (minute of Working Group meeting on 5 June 2014);
POL00026664 (minutes of Working Group meeting on 12 June 2014);
POL00140431 and POL00026673 (minutes of the Working Group
meeting on 16 June 2014);
POL00026665 (minute of Working Group meeting on 26 June 2014);
POL00026672 (minutes of the Working Group meeting on 10 July
2014);
POL00026671 (minute of the Working Group meeting on 17 July 2014);
POL00026683 (minute of the Working Group meeting on 24 July 2014);
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tt.
uu.
vw.
XX.
yy.
aaa.
bbb.
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POL00004439 (Second Sight Briefing Report Part One dated 25 July
2014);
POL00026674 (minute of the Working Group meeting on 31 July 2104);
POL00029749 (email from me to Andrew Parsons on 2 August 2014).
This relates to concerns about M025 POIR which discloses a Horizon
incident that affected circa 3000 branches. POL was aware at the time
and communicated with affected branches via ‘memoview’ as was the
case with M025. The issue here was that POL did not disclose this
incident to Second Sight along with the 2 it did disclose to them for their
Interim Report. I don’t recall anything about this other than what is in
the documents disclosed to me;
POL00026676 (minute of Working Group meeting on 28 August 2014);
POL00026679 (minute of the Working Group meeting on 4 September
2014);
POL00026680 (minute of the Working Group on 11 September 2014);
POL00101361 (my email to Richard Weaver and another on 11
September 2014). Bryan Hewson, SPM was a member of the Branch
User Forum. He was bringing his concerns about the impact of silence
from POL on a very serious matter. I accepted his concerns and raised
with Mark, Comms Director;
POL00026685 (minutes of the Working Group meeting on 16
September 2014);
POL00209634 (my email to Chris Aujard and others on 22 September
2014 - my email highlights concerns about Second Sight Part Two
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Report) and POL00209636 (attachment - copy of the POL letter
(signed by me) sent to recipient of SS Part Two report);
ccc. POL00043628 (minutes of the Working Group meeting on 25
September 2014);
ddd. POL00026684 (note of the Working Group meeting on 2 October
2014);
eee. POL00091394 (Melanie Corfield’s email to me and others on 13
October 2014);
fff. POL00107151 (letter from Alan Bates to Sir Anthony Hooper dated 10
November 2014). Alan sets out his concern that the Scheme is not in
the spirit of what was agreed when it was set up and is not delivering
for applicants what they expected when they entered into it;
ggg. POL00043630 (minutes of the Working Group meeting on 14
November 2014). Alan Bates raised his concerns about the Working
Group in a letter to the Chair - these were discussed at the meeting;
hhh. POL00213728 (note of a team meeting on 11 December 2014). This
was the agenda of a meeting with my Branch Support Programme core
team. Meeting purpose: To consider the improvement opportunities
from the Scheme; Second Sight's Thematic Issues; and the individual
case investigations with a view to incorporating into the Branch Support
Programme which is tasked with improving the effectiveness and
efficiency of the support we provide to our branch operators in the
running of their post offices;
iii. POL00150195 (email from Mark Underwood to Mark Davies, copied to
me, on 14 December 2014) and POL00150196;
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il.
kkk.
mmm.
nnn.
ooo.
Ppp.
qaqa.
rrr.
sss.
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POL00101858 (my email to Rodric Williams on 14 December 2014);
POL00109809 (email from me to Alwen Lyons on 18 December 2014);
POL00022296 (note of meeting on 9 January 2015);
POL00043633 (minutes of the Working Group meeting on 14 January
2015);
POL00219926 (email from Belinda Crowe to Andrew Parsons, copied
to me, on 25 January 2015);
POL00022297 (email from Andrew Parsons to Chris Aujard, copied to
me, on 27 January 2015). Although I’ve not seen the attachments, this
email is about providing the information requested by Second Sight.
Andrew Parsons refers to him and me discussing this with Rod to see if
we could provide the information requested by Second Sight. The
conclusion was that it was a significant undertaking to do that due to
the number of products;
POL00043634 (minutes of the Working Group on 13 February 2015);
POL00022380 (my email to Mark Underwood and others on 7 March
2015) and POL00022381 (POL’s draft response to SS Thematic Issues
Report) and POL00022378 (POL'’s Initial Complaint Review &
Mediation Scheme Report). POL00022383 has not been disclosed to
me;
POL00117183 (my email to Mark Davies on 7 March 2015) Mediation
Scheme Press release comments and POL00117184 (attachment);
POL00151569 (draft speaking note for 10 March 2015). This was for
my telephone call to Alan to advise that all cases can proceed to
Mediation and of the cessation of the Working Group;
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ttt. I POL00029849 (Second Sight’'s Briefing Report — Part Two dated 9
April 2015);
uuu. UKGI00000018 (POL’s Reply to Second Sight’s Part 2 report);
vw. POL00228264 (letter from Mr Withers to Tom Wechsler dated 7 May
2015, enclosing my letter of 27 April 2015). I do not recall these letters
or the rationale behind the letters. Whilst it is my signature on the
letters, these would have been the result of a business decision. I did
not act independently on any matters related to the Scheme;
www. POL00168655 (my letter to Mr Withers on 21 May 2015).
xxx. POL00043631 (8 December 2014 Working Group meeting minutes)
99. As stated above, I was not involved in any decision making relating to the
ambit of Second Sight's investigation or the extent of its access to relevant
information or documents other than as stated at ‘hh’ above.
100.When Second Sight were engaged, it was against a very credible
background. As can be seen in their presentation slides at POL00113791,
they had good technical and stakeholder credentials. However, as time went
by, we found their output to be very slow and minimal. They were engaged in
around June/July 2012 to investigate 47 cases and by the time we received
the interim report a year later (POL00099063), only 4 of these cases had
been investigated and the investigations into these still weren't concluded.
Progress felt very slow and disorganised, and POL was getting frustrated as
we had MPs and JFSA criticising us for the length of time being taken for
cases to progress. In response to this frustration, the Scheme was created, in
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an attempt to try and focus on getting a quicker output for SPMs (please see
below for further details on the Scheme).
.Paragraph 4 of POL00298004 states that there are two concerns around
Second Sight: the first that they do not have the capacity to deal with all of the
cases within an acceptable timetable and the second is in relation to their
approach of “seeking to reconcile the conflicting evidence and views of the
Post Office and sub-masters...” Given that this was a Board update, these
were clearly concerns held within POL, although I am unable to remember
who specifically held these views. In respect of the first point, as noted above,
I was concemed about the lack of progress by Second Sight in producing the
Spot Reviews. I cannot recall any detail in respect of the second point but I
believe that the concern was that Second Sight was not concluding their
investigation reviews as quickly as they should have been and this was
perhaps due to them spending too much time going back and forth between
the applicants and POL.
102.The Scheme was set up in August 2013 following this note. As such, Second
Sight’s focus changed from reviewing the cases put forward by MPs and
JFSA, to those who applied to the Scheme (although I believe that many of
the SPMs in the original cases for review subsequently became applicants to
the Scheme). Consequently, Second Sight’s initial Terms of Reference were, I
believe, superseded by the Scheme Terms of Reference as agreed by the
Working Group.
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103.POL’s strategy in preparing responses to applications and / or Second Sights
Report was as follows:
a. Preparing responses to Scheme Applications. On receipt of the
Case Questionnaire Report (CQC) from the applicant to the Scheme,
the CQC was assigned to a Mediation Case Review Advisor/Handler to
investigate the issues raised by the applicant. The Case Review
Advisor/Handler would then produce the Post Office Investigation
Report (“POIR”) with their findings. This was reviewed by the Mediation
Case Review Manager and then passed to me for further review, which
included ensuring the issues raised had been fully investigation, a full
explanation of the findings set out in the report (with supporting
evidence) and easy to understand language (rather than technical
jargon). The final review step was with POL’s Legal team. Once
internal review checks were complete, the POIR and supporting
evidence was passed to Second Sight for them to undertake their
independent review of the issues raised by the applicant and produce
the Case Review Report.
b. Preparing responses to Second Sight Reports. I believe that this
was a coordinated effort across POL with the Project Sparrow team
holding the pen on the drafting of the responses, with others (the Legal
team, the Communications team and myself for Scheme cases and
operational matters) feeding into, reviewing and providing comments
on the content of the responses.
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104.In terms of POL’s approach to disclosing documentation to Second Sight, for
the Scheme cases, the approach was that the POIR (along with supporting
documents), was disclosed as a pack to Second Sight. For those cases with a
criminal conviction, the legally privileged material that POL would not make
available to the defendant or Court would not be provided to Second Sight. I
understood this to be in keeping with the standard practice for prosecutors.
This approach was agreed by the Working Group. For any other
documentation, requests from Second Sight were referred to the Project
Sparrow team for consideration and coordination.
105.To enable the timely provision of information from Fujitsu, a project manager
was assigned from within Fujitsu to facilitate the requests from POL. This was
in the main, the provision of ARQ data and from memory, it worked well. If the
Case Review Advisors/Mediation team had any queries on that data or
required further information, I believe that the Fujitsu project manager
facilitated the responses to those requests. Pete Newsome was the
Relationship/Account Manager for the POL account and I believe that some
requests/queries were progressed by him.
106.1 was not involved in the review of past convictions obtained in reliance on
data generated by Horizon. This was done by the Legal team.
107.1 was aware that Second Sight had raised concerns in respect of POL’s
suspense account and that POL may have unexplained profits caused by
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SPMs settling illusory discrepancies. Al Cameron (Chief Financial Officer) was
identified as the appropriate POL person (along with Rod Ismay) to have
discussions with Second Sight. However, I was not involved in this
investigation.
108.Within the email chain at POL00061368 I say to Andrew Parsons that the
disclosure of officers’ reports “needs to be addressed on a case by case basis
as you suggest but with a presumption against disclosure”. Here I was
agreeing with his earlier advice and playing it back to him. The Inquiry have
asked in what circumstances I thought the presumption against disclosure
should be displaced — if the relevant information had not been provided in
other documents then my view was that in some cases the officer’s report
should be disclosed as per my thoughts in respect of M054 (POL00061368)
109. Document POL00022296 is a meeting note from 9 January 2015. The
purpose of this meeting was to discuss the responses that POL had provided
to the 97 questions posed by Second Sight on 9 December 2014, with a view
to enabling them to progress their Part Two Report.
110.1 recall that POL was providing a huge amount of information (perhaps tens of
thousands of documents) to Second Sight during their period of engagement.
I remember that there were some ongoing discussions and disagreements
about the provision of information in relation to: Suspense Accounts (the
request was deemed too wide); Bracknell emails (I think this was genuinely a
misunderstanding of dates although I was not involved in the provision of this
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information or discussions around it); and legally privileged documents (POL
had provided the same documentation it would to the defence in a
prosecution case). This was agreed to be the appropriate approach (ie. in line
with standard procedure) at the October 2014 WG meeting.
111.The Branch Support Programme was a response to the issues raised (i.e.
training and support could have been better) by Second Sight in their interim
report.
The Scheme and Working Group
112.As noted above, the Scheme was born out of the fact there were ongoing
concerns about Horizon potentially being the cause of losses, and Second
Sight’s lack of progress in producing outputs and conclusions from their Spot
Reviews.
113.Working Group was formally put in place slightly after the Scheme launched,
to have independent oversight over the Scheme. The Working Group
designed the format of the Scheme, such as setting out the application
process and the approach to be adopted by POL Case Review
Advisors/Investigators. The approach was to investigate each issue raised by
the applicant and produce a POIR detailing the findings of that investigation
with the supporting evidence. This report was then passed to Second Sight for
them to undertake their investigative review, produce their report and make
their recommendation to the Working Group on whether the case was suitable
for mediation. POL would then also provide their view on the suitability of the
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case for mediation and, if deemed suitable, the Project team liaised with the
applicant, POL and a mediator.
114. My role within the Scheme and the Working Group was to, on behalf of POL,
lead the team of Case Review Advisors/Investigators who would be carrying
out the investigation and drafting the POIR. I had a North and South team
(with 10 case review advisors/investigators in each), each led by a manager
with extensive Post Office operational experience. The managers sent each
draft case POIR for my review and my review involved ensuring that each of
the issues raised had been investigated, their findings explained (in an easy
to understand language) and that the findings were supported by evidence.
My involvement in the Scheme was prompted by my involvement in the
Ferndown interview, but I wanted to take on this role as I had a genuine
desire to understand if there was any substance in these complaints. I saw
this as an opportunity to investigate the cases properly and reconcile the
disconnect between POL and SPMs.
115.As a member of the Working Group I was involved in drawing up the Working
Group’s Terms of Reference and its scope. However, I cannot recall any
detail around this.
116.In terms of direct involvement with the mediations, they were allocated among
the senior team according to availability and experience. From memory, I
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dealt with 3 mediation cases, although my memory around these is limited
other than to recall that one settled, two did not.
117.As a member of the Working Group, my role in attending its meetings was to
provide an update on the progress of the Scheme cases and any issues and /
or recommendations in relation to individual cases. I also provided information
on / answers raised by the Working Group in relation to the POL operation,
policies and procedures. Where I did not know the answer first-hand, I took
the action to find out and report back. I also participated in the Working Group
discussions where my experience, knowledge and skill sets enabled me to.
118.The Working Group became more structured and focused on the progress of
the individual cases as time went on. In my view, all parties were committed to
a thorough investigation and making the process as simple as possible for the
applicants. However, there were periodic frustrations within the Group as to
the time they were taking, compounded by the ongoing expectations of MPs,
Applicants (and their advisors), JFSA and POL. Discussions at the meetings
could be challenging however in my view, the Working Group process did, in
the main, work relatively well.
119. From memory, any briefings on the Scheme were led by the General Counsel
and/or the Project Sparrow team. Whilst I do not recall any specific briefings
from memory, I would have provided Scheme cases information i.e. progress
of the cases through the Scheme and anything that senior management
needed to be aware of, such as the death of Martin Griffiths.
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120.In document POL00107151 Alan Bates criticises the Scheme stating “UFSA is
121.
now of the opinion that the Scheme has strayed so far from the original
purpose for which it was intended, that the few Applicants who have actually
reached a mediation meeting through CEDR have expressed disappointment
with the Scheme, that at least one Applicant has withdrawn.” From reviewing
this letter and subsequent discussions at the next Working Group meeting, his
view was that the role of Working Group was not in line with that of JFSA’s
and indeed, what had been agreed in the Working Terms of Reference. I
disagree with Alan’s view that POL had become more “entrenched and
defensive” as the Scheme progressed “and the original concept of actually
seeking the truth has long since been abandoned, replaced by denial and a
culture of blaming the Applicant time after time.” I genuinely wanted to get to
the truth and to find out what had caused the issues for the applicants of the
Scheme, and I invested a huge amount of time and effort in a full and
thorough investigation into the issues raised, as far as the evidence enabled
us to. The findings detailed in the POIR were the outputs of those
investigations. Our approach in the mediations was also a genuine desire for
both parties to have a better understanding of each other's position and
hopefully move closer to closure for the applicant.
In terms of the extent that I was involved in POL’s internal communication
regarding challenges to the Horizon IT system, I would usually have been
asked to comment on draft communications regarding content and tone. I do
not believe that I saw a policy document, however from memory the approach
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was to keep the communications factual, proportionate and focused on key
points/messages.
122.In the email at POL00303871 I state “please ignore the comment from SS that
POL’s investigations are inadequate — this was Ron having a pop in an
attempt to cover his lack of output.” Whilst I can’t recall the discussions that
took place, from the minutes of the Working Group meeting on 17 April 2014
at POL00026652, I can see that Second Sight were behind on their agreed
timeline for a number of cases. The POL team of case review
advisors/investigators led by Kathryn Alexander (South team) and Shirley
Hailstones (North team) had been working incredibly hard to conclude their
POIRs to the agreed timeline whilst ensuring a thorough investigation into the
issues raised by the applicant. I probably made this comment as I did not
want Ron’s comments to demoralise the team.
123.At the time, I did not have any concerns that either myself, or others
responding to applications to the Scheme, were not receiving accurate and/or
complete information regarding BEDs, remote access or the integrity of
Horizon as I believed that we had all of the relevant information from Fujitsu
that enabled us to undertake a thorough investigation of each case.
124. The Inquiry have asked why I think that POL’s investigation of allegations
made by SPMs in the Scheme did not identify new BEDs that caused
discrepancies in branch accounts, a lack of integrity in Horizon or the extent of
remote access. I cannot answer other than to say that the information that the
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investigators received did not evidence or point to any of these issues. In the
older cases that were reviewed, due to the passage of time, the information
that would have pointed to these issues was not available.
125. The Inquiry have asked for my views on the reasons or motives for SPMs
making applications to the Scheme and / or campaigning in respect of
Horizon. Whilst every SPM had their own reason and motive, my experience
was that many SPMs felt that they had unresolved issues that they wanted
closure on, whilst others had issues that they did not understand and were
looking for explanations. Some SPMs had suffered significant losses and felt
that they deserved compensation and saw the mediation as the route to
achieving this. For those that campaigned, they did so in my view as they felt
that they had not been listened to or received satisfactory redress from POL.
126.1 have reviewed document POL00109809. In general, I did not think SPMs
who campaigned and/or spoke to journalists did so to avoid settling debts to
POL for which they thought that they were liable, however, in this particular
instance, as I said in the email, I did believe this to be the case. Seeing this
SPM on the Panorama show was particularly disappointing as we had been
working with him over a period of time to get to the bottom of what was
causing the losses in his branch. In this case, there was evidence that the
losses were caused by SPM error.
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Project Sparrow
127.From memory, as the Terms of Reference have not been disclosed, the
purpose of Project Sparrow was to oversee the running of the Mediation
scheme by effectively creating structure and making sure that the Working
Group got what they needed. For example, providing secretariat support,
providing updates to POL Board, coordinating messaging on remote access
and setting up meetings in relation to suspense accounts. The project was
headed up by Belinda Crowe and worked closely with the Communications
team. I was not a member, but I occasionally sat in on meetings
128.1 do not recall being advised of the rationale as to why the Project Sparrow
committee became a formal subcommittee of the Board.
129.1 do not recall any specific policies or strategies being discussed/formulated in
response to complaints made about the Horizon IT System, other than the
Scheme approach as agreed with the Working Group and those implemented
by the Branch Support Programme.
130.With the Post Office investigations completed into all the Scheme
applications, POL took the decision to put forward the mediation of the
remaining cases (other than those subject to a previous Court ruling). This
decision removed the need for the Working Group to determine whether a
case was suitable for mediation. Consequently, the Working Group was no
longer required. The rationale is set out in my speaking note POL00151569.
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131.1 had no involvement in the decision to close the Working Group. However, I
did ring Alan Bates to advise him of that decision ahead of him receiving
written confirmation.
132.The Inquiry have asked to what extent, if at all, do I think that the Scheme
fulfilled POL’s intended purpose. As I recall, the Scheme was established as a
mechanism for applicants to set out their Horizon related (and other) issues
for POL to investigate and provide a POIR and offer mediation where suitable.
Where not suitable, the applicant was offered a direct discussion about the
investigation findings. Therefore, in my view, the Scheme did in the main, fulfil
its intended purpose. That said, I felt some disappointment that despite our
best efforts, a number of applicants were not satisfied with the mediation
process and/or the outcome of the mediation meeting with POL.
133. Project Zebra is not something I remember so I do not believe that I was
involved in, or aware, of it.
Branch Support Programme
134. The report from Second Sight and the Scheme raised key issues with the way
things were being run and the Branch Support Programme was created to
address these issues.
135. The programme was implemented through normal project management
principles, with the establishment of a governance structure, including a
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Programme Board and a project plan with key milestones and deliverables.
The project plan has not been disclosed. However, I can recall that one of the
core values was to stand in the SPM shoes. I felt that I had to work really hard
to get people to understand the day-to-day job of an SPM and how difficult it
could be for a SPM to get everything running properly. The art of a good SPM
was making that look easy. In addition to the issues identified through Second
Sight and the Scheme, I took the opportunity to see what other improvements
we could make as an organisation through the programme. These
improvements are set out in POL Board Report updated 20 February 2014 at
POL00027454.
.I led the Branch Support Programme as Programme Director from August
2013 — March 2015 with Gayle Peacock being accountable for running the
Programme on an operational level.
The Terms of Reference v.2 and v.3 disclosed (POL00002194 and
POL00148920), detail the purpose of the Branch Support Programme as
being ‘to understand the current business purposes, operational procedures
and ways of working which are in place to support branches, identify gaps and
produce recommendations to rectify the issues.” I should flag that I am not
sure whether this was the final Terms of Reference as the final version has
not been disclosed. However, either way, I recall that the Terms of Reference
was later reworded to reflect the extended scope of the programme as
detailed in the POL Board update February 2014 on the Branch Support
Programme (POL00002194): “The purpose of the Branch Support
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Programme is to improve the effectiveness and efficiency of the support we
provide to our sub postmasters and operators in the running of their Post
Offices from an operational and engagement perspective.” This is the purpose
statement that I recognise and that aligns with my understanding of the
Branch Support Programme at the time.
138. The programme had the backing of Paula Vennells to get changes made
quickly and because of that, I felt that it was really effective as things could be
acted upon fast without the usual bureaucracy for approval. For example, I
recall that there was an issue that if a customer paid for foreign currency on a
card, the usual process was that the SPM had to print an additional receipt
and record the last 4 digits of the customer’s card on that second receipt.
Should fraudulent activity be discovered on the card, the SPM would need to
produce that receipt or else be held liable for the funds. SPMs had been held
liable for this before and so my view was for something that important, the
system should automatically generate the second receipt with the necessary
information. I therefore took steps through the programme to get this change
put in place.
139.Another issue that came to the programme was with a MoneyGram scam.
Individuals rang branches, saying that they were engineers and asking a SPM
to do a test transaction. The individual on the phone would talk the SPM
through the transaction and effectively steal the money via the MoneyGram
transfer of money process. POL had clear instructions that MoneyGram
transactions could only be done when the customer is in front of them so that
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they can take ID and the money. Therefore if an SPM fell victim to the scam,
they would be held liable for not following the correct process. I seem to
remember that one branch fell for the scam over 9 times, becoming liable for
around £40k. To try to prevent this happening again, through the programme
we put in place, a message notification would pop up at the beginning of the
transaction saying ‘we will never ask you to do a test transaction over the
phone.’
Branch User Forum
140. Paula Vennells asked me to set up the Branch User Forum as a mechanism
for the voice of the SPM to be heard by senior managers at the heart of the
organisation. It was an opportunity to bring them inside the organisation in a
way that we had never done before.
141.This purpose and objectives of the forum are set out in the Post Office Branch
User Forum Terms of Reference document dated 18.10.2013
(POL00196510):
“Purpose
The purpose of the Branch User Forum is to provide a way for sub-
postmasters and others to raise issues and insights around business
processes, training and support directly feeding into the organisation’s
thinking at the highest level. The forum is a forward looking mechanism
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to ensure the business processes and approaches are fit for purpose
for users and are in keeping with Post Office behaviours and values.”
Objectives of the Forum
a. To assess issues raised from with the Post Office network; identify
appropriate solutions and recommend improvements to rectify the root
cause and prevent recurrence of the issue.
b. To assess issues raised from Post Office support/central functions;
identify appropriate solutions and recommend improvements to rectify
the root cause and prevent recurrence of the issue.
c. To input into the design of the end to end process for new products and
services before launch to the Post Office Network.
d. To assess improvement suggestions from the Post Office network and
support/central function i.e. ‘would this work?”
142.In terms of membership, I put out a memo to the network saying that we
wanted to give SPMs an opportunity to feed into the thinking of POL at the
highest level and asked them to apply with a paragraph to tell me why they
should be selected. I remember that I wanted full representation with SPMs
from branches of all shapes and sizes, from smaller traditional post offices to
large city post offices. I then brought in a number of senior people within POL
to represent different functions, for example Network, IT and Commercial.
The Subgroup members were also senior managers who took responsibility
for actioning and responding to any issues/questions raised during the Branch
User Forum meetings. Depending on the issue/topic they may have attended
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some of the Branch User Meetings to provide an overview of their respective
function/work area and/or update on any actions they had responsibility for.
143.The forum was very much positioned as a confidential, safe place to have a
conversation with ‘Chatham House Rules’ applying, which was really
important to the functioning of the forum. From memory, there were around 6
SPMs and 6 POL representatives, with me chairing. I remember that we also
had a federation representative and a union representative but both were on
the basis that they were wearing their SPM hat whilst in the forum. I didn’t
want to shy away from any conversation.
144.As Chair, it was my duty to give SPMs their voice and making sure that the
business understood what they were saying and equally, to make sure the
SPMs understood the implications of the actions they wanted. There were
some very challenging conversations but some really successful results and it
was something that I was very passionate about. At times the forum was
about educating and at other times it was about making changes. There was
a session on Second Sight and the Branch Support Programme so there were
some conversations around the Horizon system but the main focus of the
forum was looking forward and making improvements. I remember that we
took the forum to Chesterfield so that they could see how FSC worked and
Paula Vennells attended another meeting so questions could be put to her.
145.1 also wanted to use the forum as a test bed for new products so if POL was
proposing a change it would come to the forum first so SPMs could share
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their feedback. I felt that this was invaluable as we were taking out the niggles
in processes and preventing errors upfront.
146.1 requested copies of the agenda and minutes for the Branch User Forum
meetings that I chaired. POL has provided the dates of 22 meetings held
during the period that I was Chair, from November 2013 — January 2017
inclusive, and have provided agendas with minutes for approximately half of
those. From these, the range of discussion areas can be seen to cover
predominately (especially in the earlier meetings) feedback on issues with
some products (e.g. Drop & Go); communications to branches via Memoview
and Branch Focus; improvements to processes on Horizon (e.g. cheque rem
out, Bureau second receipt).
147.The last meeting I attended was January 2017. I handed the Chair role over at
this meeting to Mark Ellis the Network Operations Director. Unfortunately I
received anecdotal feedback from a couple of the SPMs that the forum lost its
momentum and impact as senior manager support and attendance dwindled
at the sessions. I’m not aware if the Branch User Forum is still in place today.
148. In terms of the nature and content of any briefings that I gave to those working
on the Branch Support Programme or the Branch User Forum in relation to
Second Sight’s Interim Report or the Helen Rose report, my recollection is as
follows:
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a. Branch Support Programme — a key focus of the programme was the
key issues raised by Second Sight in their Interim Report (July 2013)
and the themes of the Scheme. Whilst I can’t recall exactly whether the
Interim Report was shared in its entirety (although I would normally
have done this and so my working assumption is that I did), the key
issues would certainly have been briefed to the Branch Support
Programme Board and the core Branch Support Programme team for
the same subsequent improvements to support and processes to be
made. I do not believe that I shared the Helen Rose report with the
Branch Support Programme members.
b. Branch User Forum —I cannot remember whether I provided the
Second Sight Interim Report or the Helen Rose report to the Branch
User Forum. However, POL00294615 is a slide deck about the Branch
Support Programme (dated 17 July 2014), which was established to
review the lifecycle of the SPMs‘ experience with Post Office; to “fix”
the issues identified in the Second Sight report and the subsequent
mediation cases and to ensure that any lessons learnt are factored into
future ways of working.
THE DEATH OF MR MARTIN GRIFFITHS
149. The below deals with my recollection of the death of Mr Martin Griffiths.
150.In answering the Inquiry’s questions, I have reviewed the following
documents:
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a. POL00027757 — This was the email chain of October 2013, notifying
up the line the tragic news that Martin Griffiths had passed away.
b. POL00027757 - email to Andrew Parsons on 1 September 2014.
Please note that the Inquiry have provided the same reference in
respect of the above document.
c. POL00306234 — This is an email from Lauren Griffiths to me on 2
September 2014, expressing her disgust at the treatment of POL to her
family following the death of her father and asking me to escalate the
matter. My response to Lauren and the internal emails leading up to
that is at POL00116698. I say how sorry I am that she feels that her
and her family have been let down by the POL and for what they have
been through, as well as outlining the steps that POL have taken to
support them. In a letter of 5 September 2014 I offer a discretionary
payment of £140,452 to Gina Griffiths, Martin’s wife, which is
equivalent to the sum offered to SPMs who chose to leave POL as part
of the Network Transformation (“NT”) programme, for which Martin was
not formally eligible for as he had been served 3 months’ notice of
contract termination by POL.
d. POL00306171 — This is an email from me to Andrew Parsons on 4
September 2014. POL00306172 is the attachment to the email. These
emails are about putting in writing the NT payment equivalent offer to
Gina in respect of Martin’s prior request to exit POL via NT programme.
This was following the meeting I had with Gina Griffiths and her brother
in Chester on 1st September 2014.
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e. POL00219796 — This is an email from Rodric Williams to me on 22
January 2015, sharing a copy of the Settlement Agreement with Gina
and asking us to confirm a few points around the intention of the
agreement.
151.1 also requested and received additional disclosure in respect of this case,
which is listed in the annex below.
152.In terms of my involvement in POL’s response to the tragic news that Mr
Griffiths had taken his own life, to the best of my recollection I believe that
Kevin Gilliand (Director of Network and Sales) rang Gina Griffiths, Martin’s
wife, to offer his condolences and I think that he suggested to her that I would
be in touch to offer whatever support I could. After making initial contact with
Gina (by telephone I believe) I became the contact within POL for Gina. As
stated in my response to her daughter, Lauren Griffiths (POL00116698), I
tried to assist operationally and financially by arranging for a temporary SPM
to run the Post Office branch, agreeing the rental amount to help with the
overheads of the business and making an exceptional payment to Gina in
October 2013.
153.1 met with Gina and Martin Griffith's mother in November 2013 at their request
at a local pub (a few weeks after his death) to discuss their preference for the
future of his Post Office branch. I then met with Lauren in London (November
2013) to answer whatever questions she had at the time. I later met with Gina
and her brother in September 2014 in the lounge area of a hotel and
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discussed exceptionally progressing the NT exit payment that Martin had
previously expressed an interest in but for which he wasn’t formally eligible. I
also recall having telephone conversations with Gina over this period as well.
The further disclosure shows a degree of regular contact between myself,
Gina and Lauren Griffiths.
154. My involvement in POL’s decision making in relation to offering Gina Griffiths
a discretionary payment was as follows: Martin Griffiths had previously
expressed an interest in leaving the Post Office with a NT payment. The
payment was a ‘loss of office’ payment made to SPMs where their existing
post office could be transferred to a new SPM. However, when Martin was
given 3 months’ notice to terminate his contract, he was no longer eligible for
the NT payment. I made a case to the business that, in light of the exceptional
and tragic situation, we should exceptionally include Hope Farm Road Post
Office in the NT Programme and facilitate the transfer of this Post Office to a
new SPM, therefore triggering the NT payment to Gina Griffiths. The business
agreed, however the payment was to be made within the NT Scheme rules in
terms of the approach to a settlement agreement as laid out in the letter at
POL00306172.
155. Document POL00027757 contains an email dated 11 October 2013 from
Paula Vennells to myself, with others copied in and states the following: “...we
need to look at the business: to help me brief this properly to the Board, can
you let me know what background we have on Martin and how/why this might
have happened. I had heard but have yet to see a formal report, that there
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were previous mental health issues and potential family issues...” The Inquiry
have asked what response I gave to this request and whether I conducted
investigatory work to aim to respond to this request. I can see in the email
chain that on the same day, Kevin Gilliland has advised Paula that I was to
pull together a brief. From the further disclosure 7th March 2024 I can see that
I did liaise with Glenn Chester to provide a brief to Paula on the relevant
information on Martin Griffiths’ case.
CORRESPONDENCE WITH DAVID HILL
156. The below sets out my involvement with responding to David Hill's
correspondence regarding the Horizon IT System and any investigation into
his concerns. In answering the Inquiry’s questions on this subject matter, I
have reviewed the following documents:
a. POL00116957 (email chain between 10 December 2014 and 2
January 2015). This contains the original email from David Hill, giving
details of an overpayment he received after depositing a cheque and
subsequent correspondence within POL about how to respond.
b. POL00101966 (email chain between Tom Wechsler and me on 2
January 2015). This contains a re-draft of my proposed response to
David Hill. Whilst I can’t remember the discussion I had with Tom, I can
see that the final paragraph has been amended from the first draft as in
POL00116957, with the outcome appearing that I wanted to investigate
the issue further, rather than send a response which assumes the error
is due to a manual inputting error.
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c. POL00116960 (my letter to David Hill on 2 January 2015). This is the
final letter that was sent to David Hill, based on the drafts in the email
correspondence. In the letter I apologise for the error and
inconvenience and request further information so that I can investigate
what had happened.
d. POL00102078 (email from David Hill to me on 28 January 2015). Mr
Hill declines my request for further information. I do not remember
these emails/letters and cannot recall if any further action was taken.
e. POL00319590 (email exchange between Melanie Corfield and Mark
Underwood). This is an email from David Hill with Mel’s suggested
response. I am not a recipient of the email.
157.1 do not remember dealing with this before the letters were provided to me by
the Inquiry and therefore cannot recall if any further action was taken in
respect of them. Looking at my request to Mr Hill for details about the
transaction, I obviously wanted to investigate this further to establish what had
happened. The working assumption appeared to be that the transaction had
been correctly processed in the branch and it was in the processing centre
where they entered the deposit value and payment value, that the error had
occurred. This is what I wanted to investigate, but wouldn't have been able to
without the details of the transaction requested from Mr Hill, which he declined
to provide.
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158.As noted above, I did not remember this correspondence prior to it being
provided to me by the Inquiry and cannot remember exactly what I thought at
the time. However, as this transaction was not done during the time of the
suspended SPM and was thought to be a processing centre error rather than
a branch error, I probably would not have considered this relevant to any
criminal convictions.
POL’s RESPONSE TO COMPLAINTS FOLLOWING THE MEDIATION SCHEME
159.In addressing the Inquiry’s questions on this topic, I can confirm that I have
reviewed the following documents:
a. POL00089010 (briefing on Panorama);
b. POL00140211 (minutes of a Panorama meeting on 9 June 2015);
c. POL00152161 (email from Mark Davies to Kevin Gilliland and others,
copied to me, on 14 June 2015);
d. POL00317725 (entry for a meeting on 24 June 2015);
e. POL00317780 (email from Melanie Corfield to me on 24 June 2015),
POL00317781 and POL00317782 (attachments);
f. POL00152439 (email from Mark Davies on 25 June 2015);
g. POL00318510 (email from Patrick Bourke to Jane MacLeod on 22 July
2015) and POL00318511 (attachment);
h. POL00168291 (email from Mark Davies to Paula Vennells and others,
copied to me, on 5 August 2015);
i. POL00231476 (email from Mark Davies to me on 17 August 2015) and
POL00231477 (attachment);
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j. POL00319556 (email from Mark Davies to me on 20 August 2015). Mark
is asking me to review his letter of complaint to the BBC and
POL00319557 (attachment). I don’t recall this letter, however if I did
review it there should be a response from me but this has not been
disclosed.
k. POL00029912 (email from Mark Underwood to me on 21 August 2015);
I. POL00139183 (email chain between Melanie Corfield and me on 21
August 2015); and
m. POL00091401 (email from Rodric Williams to me on 22 August 2015).
160.1 cannot recall the exact detail as to the extent to which I was involved in
POL’s response to concerns raised by SPMs, MPs and journalists about the
Horizon IT system. However, I have detailed below a general overview of my
involvement, to the best of my recollection.
16
.In respect of concerns raised by SPMs, from 2012 onwards, I would have
normally been the person to engage with SPMS, for example investigating
issues raised as part of the Scheme, dealing with ‘Business As Usual’ queries
(those raised outside the Scheme and after the Scheme had closed) and
dealing with general queries within POL that related to SPMs. Where
concerns related to remote access issues, POL had pre-approved wording for
what we were to say. For example, see POL00022659 and POL00022665
which confirms the approved wording as at July 2016.
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162. Following the closure of the Scheme, I embedded the investigation approach
that we had developed for the Scheme into business as usual via the Support
Services Resolution Team. This is the team that I would refer any issues from
SPMs to in relation to discrepancies in branch. Depending on the issues
raised and/or if the branch was high profile and there was MP or journalist
involvement, I may have engaged directly with the SPM or I may have left it to
the Support Service Resolution Manager to do so.
163.In respect of concerns raised by MPs, responses to MPs were usually
coordinated through the Communications team (including the Executive
Correspondence Team) and/or the Project Sparrow team whilst it existed. As
noted above, I met with MPs on 10 May 2012 and 18 June 2012, prior to the
closure of the Working Group. Whilst I recall that I did also meet with some
other MPs and their SPM constituent at their request to discuss particular
issues/concerns, I do not remember the dates or precise details. However,
typically the discussions were around Horizon or contract termination.
164.In respect of concerns raised by journalists, I can recall that I was part of the
meeting with journalists on 9 June 2015 in respect of the BBC Panorama.
Prior to seeing the transcript, I did not recall the content of this meeting
(POL00140211). I do not feel able to add anything beyond what is contained
in the transcript. I do not recall attending any other meetings with journalists
between March 2015 and April 2016. Nor do I recall being involved in any
other responses to journalists during this time, but without access to my
calendar, I am unable to be absolutely certain. As noted above, it was the
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responsibility of the Communications team to respond to journalists and if they
required any information from me, I would respond to their request.
165.1 never did any briefings to the POL Board and / or senior managers on the
integrity of the Horizon IT System. It was, however, usual for me to do
briefings/provide updates on the Branch Support Programme and the
improvements made as part of this programme. This programme ended in
March 2015 and later briefings that I delivered would have been on the
outputs of the Business Improvement Programme/Support Services
Transformation programme, again relating to improvements linked to the
issues raised in the Scheme.
166.Whilst I have seen that there was a meeting on 24 June 2014 (POL00317725)
at which the Communications Director, Mark Davies, was due to brief us on
media questions in respect of the Horizon system, due to the passage of time,
I cannot remember what was said during this meeting.
167.In document POL00029912, there is an email from me to Mark Underwood
(21 August 2015) asking for POL’s “response to what Richard Rolls said on
the programme...I'd like to have a robust response/explanation of the mention
of going in by the back door and altering the coding.” My request for this
information was part of my preparation for the mediation of case M005. The
mediation statement had mentioned the programme that featured Richard
Rolls and I needed to know (in lay terms as I didn’t have the technical
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knowledge) what he was actually saying and the associated implications so
that I was able to discuss it as part of the mediation. It was very typical for us
to request IT’s input on technical issues when dealing with a mediation as we
did not have the requisite knowledge.
168.1 did not consider making contact with Richard Rolls and I am not aware of
any others at POL making any consideration to interview or make contact with
Richard Rolls.
THE SWIFT REVIEW
169. The below deals with the nature and extent of my involvement with POL’s
instruction of Sir Jonathan Swift and its response to his review. The Swift
Review is provided at POL00006355 and is “a review on behalf of the
Chairman of POL concerning the steps taken in response to various
complaints made by SPMs” dated 8 February 2016. At the outset I should say
that I was not involved in POL’s instruction of Sir Jonathan Swift and I do not
recall seeing a response from POL to his review. I did, however, meet with Sir
Jonathan Swift to provide information for his review.
170.I have reviewed the following documents in relation to The Swift Review:
a. POL00153379 (action points from a meeting with Christopher Knight
on 27 October 2015) — I do not recall attending this meeting;
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b. POL00153578 (Kendra Dickinson’s email to me on 11 November
2015). This is an email request for information from NBSC via me and
Kendra for the Chairman’s review;
c. POL00153691 (Kendra Dickinson's email to Steve Allchorn, copied to
me, on 19 November 2015). This is an email from Kendra, providing
updated information to the original request from NBSC;
d. POL00153696 (Rodric William’s email to Jane MacLeod, copied to me,
on 20 November 2015). Although I was copied into this email chain,
these were legal points that I did not participate in; and
e. POL00323294 (Mark Underwood’s email to me and others on 16
December 2015). This is an email from Mark requesting information
following a meeting with Jonathan Swift and Christopher Knight in
relation to the Chairman’s review.
171.1 was aware of the compilation of the Chairman’s Review/Report (as it was
referred to within POL at the time) and I did act as a conduit for gathering
information for the NBSC. However, I don’t recall receiving a copy to read or a
briefing on the contents whilst at POL. I can recall that at some point I was
told (and this is paraphrasing), that everything is fine with the Chairman’s
Report and we can continue as we are.
172.In August 2023, I became aware that the report was in the public domain in
redacted format and at that point, I downloaded a copy to read. This was the
first time that I read it. On reading the report, I remember thinking that the
suggested approach of a top down approach to the Scheme investigations in
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addition to the bottom up approach that we had adopted was something that I
wished we had implemented as it would have been a more complete
approach and would have enabled more conclusive findings.
DALMELLINGTON BUG
173.I have been asked to consider document POL00153527 which is an email
from Melanie Corfield me and others on 10 November 2015. Whilst this
document does not reference the ‘Dalmellington Bug’ specifically, my
knowledge of the detail of this ‘bug’ is limited due to the passage of time and I
have therefore assumed that ‘the issue’ referenced in the email is the
Dalmellington bug. I believe that this was a bug that impacted Outreaches
only (an outreach is not a Post Office in its own right but is attached to a ‘core’
Post Office and treated as one Post Office branch for the purpose of branch
accounts). The issue occurred when the Core Post Office was remming
(transferring /remitting money) money out to the Outreach. I think that they
were able to press the button again and transfer of money doubled up. I don’t
recall what POL’s response was at the time.
GROUP LITIGATION
Early stages
174.1 can confirm that I have reviewed the following documents:
i. POL00025509 (draft terms of reference for Postmaster Litigation
Steering Committee);
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ii, POLO0025507 (Rodric Williams’ email of 6 June 2016). Cover
email from Rod for Postmaster Litigation Steering Committee
meeting), POL00025508 (7th June 2016 meeting agenda)
POL00025509 (Postmaster Litigation Steering Committee TOR),
POL00025510 (Court Claim), POL00025511 (Letter of claim),
POL00006536 (Womble Bond Dickinson disclosure
advice/instruction), POL00025513 (Agent debt recovery
principles), POL00025514 (Standard agenda template) and
POL00025515 (workplan & actions) (attachments);
POL00167538 (email from Rodric Williams to me and others on
8 July 2016 attaching agenda for PLSG meeting on 14th July
2016;
iv. POL00024988 (email from Andrew Parsons on 13 July 2016
(WBD one pager advice on each agenda decision point) and
POL00006360 (attachment);
v. POL00105719 (agenda for steering group meeting on 20 July
2016). Although this has been described as the agenda, on
review this document is Jenny O’Dell’s case write up not the
agenda;
vi. POL00024801 (email from Andrew Parsons to me and others on
21 July 2016) cover email for PLSG meeting and POL00024802
Remote Access note from WBD;
vii. POL00025167 (email from Rodric Williams to Andrew Parsons
on 21 July 2016). This is about remote access and what POL’s
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messaging has been over time. The email references an
attachment which has not been disclosed.
viii. POL00022659 (email from Amy Prime to me and others
on 27 July 2016) and POL00022665 (attachment); and
ix. POL00041259 (email from Andrew Parsons to me and others on
27 July 2016). Proposed letter of response to Freeths and
POL00041260 (attachment - letter of response).
175. The below deals with my role and responsibilities in relation to the group
litigation and the nature and extent of my involvement in POL’s work and
decision-making process in that case.
176.1 was not involved with and cannot recall any specifics around POL’s general
litigation strategy. From memory (and without seeing anything disclosed
around this), my understanding was that any strategy was ultimately a Board
decision following a recommendation from POL’s Group Executive/Legal.
177.I can recall that I sat in on a number of meetings at the early stage as Jane
MacLeod (General Counsel and Company Secretary) would keep me in the
loop with what was going on. After she left, I felt I wasn’t as included as I had
been previously.
178.The Postmaster Litigation Steering Group (‘PLSG’), of which I was a member,
was established with a ‘Business As Usual’ focus as set out in the Terms of
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Reference (POL00025509), which had been agreed by the Post Office Group
Executive as set out below:
“Terms of Reference. The objectives of the PLSG are to ensure that
Post Office's defence of the Claim:
e is proportionately managed;
e does not place unplanned constraints or resource burdens on Post
Office; and
e is consistent with business as usual (BAU) practices, processes and
procedures.
In order to deliver these objectives, the Post Office Group Executive
has agreed that PLSG will undertake the following responsibilities:
a. providing a forum for cross-business discussion of Claim-related
BAU issues so that all relevant matters are considered when
making a decision;
b. providing instructions to Post Office's legal team on
BAU/commercial matters;
c. maintaining and progressing an Action Plan for Claim-related
activity, and monitoring the resources required to deliver
against that plan;
d. signing of key Claim-related documents;
e. monitoring and approving Claim-related expenditure;
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f. reviewing, challenging and signing of any Communications
plans developed as a consequence of the Claim’;
g. reporting matters to the Group Executive as appropriate.”
179.In terms of general litigation, my team (those previously involved in the
Scheme investigations) were investigating the lead cases and making sure
that the Legal team had the right information. I was heavily involved in
conversations with Womble Bond Dickinson from an operational standpoint as
they would use me a sounding board to ask questions and explain to Counsel
how things worked ‘on the ground’. My role was very much as a provider of
facts, rather than any decision-making.
180. The advice from Counsel was that we had a better than 50% chance of
winning and therefore there was a general sense of comfort within POL that
we had a sound case and it was proper that we should be defending this.
181.1 do not recall being part of either the decision-making process for disclosure
of documents or the decision making process for lay and expert advice. This
was led by the Legal team.
182. It was not within my responsibilities to keep the Board or Government
informed of any of the above matters.
183.My understanding was that ultimately the POL Board — or the sub-Board if
they had delegated authority to do so — took all of the strategic decisions in
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relation to the group litigation. I recall that Womble Bond Dickinson would
often product an ‘Option Report’ with a recommendation when required, off
the back of conversations with POL lawyers. I cannot recall any time when
POL Board did not go with the recommendation.
184.I do not know and therefore cannot comment on how POL satisfied itself that
the substantive position it took in letters and Court documents were correct.
However, on a personal level both for the legal arguments and the technical
position, I took at face value the advice and technical explanations as
provided by the Legal team, Fujitsu and Deloitte. I had no reason to doubt
what experts in this field were telling me.
185.Whilst the draft/proposed letter of response was shared with the PLSG, my
involvement in drafting it was limited. This was very much a legally crafted
response.
186.My involvement in POL’s position on remote access was limited to being
briefed on the approved wording/messaging from those with the technical
expertise as referenced in the email chain (POL00025167) i.e. Rob Houghton,
POL’s ClO, Fujitsu and Deloitte.
Preparation of the Defence
187. The below deals with my involvement with / oversight of the drafting of POL’s
Generic Defence and Counterclaim. At the outset, I should say that this
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responsibility primarily lay with the Legal team and my involvement was
limited.
188.1 can confirm that I have reviewed the following:
a. POL00024650 (email from Mark Underwood dated 19 May 2017 giving
the agenda for PLSG Meeting 24th May 2017); and POL00024653
(decision paper on counterclaims and recommendation from Bond
Dickinson to bring counterclaim for outstanding losses).
b. POL00003340 (letter from Bond Dickinson to Freeths dated 18 July
2017 enclosing POL’s Generic Defence and Counterclaim).
189.Whilst I cannot recall exactly what happened at the time, the usual approach
taken was that each section of the Generic Defence and Counterclaim had
input from the respective business owner/subject matter expert and/or verified
by them as being accurate. For example, Branch Trading Statements and
making good and disputing shortfalls fell within the FSC area of responsibility
and so they would verify the section relating to these issues. It was the Legal
team that led on the overall drafting and coordination of the document.
190.1 have reviewed paragraphs 43(1) to (3) of the Defence (POL00003340). At
paragraph 4(3) it states “The blocked value is not (and is not treated as) a
debt due to Post Office.” Whilst I can’t remember exactly, the usual approach
was that FSC would verify that this was correct.
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191.Paragraph 48(3)(b) of the Defence states that it is denied that Fujitsu “edited
or deleted specific items of transaction data”. As above, I cannot recall having
a specific discussion about the Defence, however I believe the approach
would have been to seek input from the business expert/subject matter expert
and/or have them verify that the wording was accurate. In this instance, the
expert was Fujitsu with the oversight/assurance also sought from Rob
Houghton, POL’s CIO and Deloitte as referenced in POL00024801 and
POL00025167.
192.Paragraph 57(4) of the Defence states “To have abused those rights so as to
alter branch transaction data and conceal that this has happened would be an
extraordinarily difficult thing to do, involving complex steps...which would
require months of planning and an exceptional level of technical expertise.
Post Office has never consented to the use of privilege user rights to alter
branch data and, to the best of its information and belief, these rights have
never been used for this purpose.” Whilst I am unable to answer from memory
the basis on which POL pleaded this, my understanding is that the same
approach would have been adopted in that POL would have requested
input/assurance from Fujitsu in the first instance and then possibly requested
an assessment from Rob Houghton and/or Deloitte of the statement from
Fujitsu.
193.1 do not recall from memory why POL decided to bring counterclaims against
the SPMs in the group litigation, however having read POL00024653, it was
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recommended by Womble Bond Dickinson that “Post Office should bring a
Generic Counterclaim for the outstanding shortfalls only.”
Ongoing management of the litigation
194.1 can confirm that I have reviewed the following documents:
a. POL00028070 (Bramble draft report dated 3 October 2017). It has not
been disclosed whether I received a copy of this report and on
reviewing this version, I don’t recall ever having read it before.
b. POL00139480 (email from Mark Underwood to me and others on 1
November 2017) and POL00139486 (general update on Deloitte)
c. POL00006764 (minutes of the Postmaster Litigation Subcommittee of
the POL board on 26 March 2018).
195. Although I was not involved in the oversight of the conduct of the litigation, my
understanding is that there were three layers of oversight: the POL Board, the
Post Office Litigation Subcommittee and the Post Office Group executive. As
described in POL00006764, the Post Office Litigation Subcommittee was
established to receive advice relating to Postmaster Litigation. However, as I
was not involved in any oversight, I am unable to add anything beyond what is
contained in the documents.
196. I do not recall receiving a copy of the Bramble report and I do not remember
hearing the Deloitte work referred to as ‘Bramble’. However, I do remember
being aware that Deloitte had been engaged to do some work as set out in
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POL00139486. I believe that my knowledge was limited to the noting paper
and any associated discussions at the PLSG meetings of which I cannot recall
any specific detail.
197.As part of the litigation preparation, I was asked to do a Risk Assessment of
the Common Issues, that looked at the likelihood of losing a Common Issue
and the impact on Post Office if a Common Issue was decided in favour of the
claimants. This risk assessment was done in advance of the Common Issue
Trial in November 2018. I also believe I did a risk assessment for the Horizon
Issues Trial. Following the Horizon Issue Trial I also led on the contingency
planning (Deloitte supported with this) to mitigate the impact of an adverse
judgment on the Post Office operation - this was referred to as our ‘Response
Plan’. I prepared briefings for each of these activities.
Disclosure
198.1 can confirm that I have reviewed the following documents:
a. POL00003340 (paragraph 50(4) of the Generic Defence and
Counterclaim which gives an explanation of Known Error Log (KEL);
b. POL00003414 (Freeths’ letter to Andrew Parsons dated 13 September
2017. This letter concerns POL’s failure to release the Known Error
Log to Freeths);
c. Paragraphs 33 to 41 of POL00000444 (Andrew Parsons’ fourth witness
statement). This witness statements details an offer for Freeths IT
expert witness to visit Fujitsu to review the Known Error Log;
d. POL00003386 (Freeths’ letter of 2 October 2018). This refers to
disclosure of PEAK system.
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e. POL00006431 (Noting paper: Update on Litigation Strategy for meeting
on 16 October 2017). This refers to Litigation Strategy Paper 11th Sept
2017 which has not been disclosed.
f. POL00003363 (Womble Bond Dickinson’s letter of 28 November
2018). This letter pushes back on Freeths claims of late disclosure of
PEAKs.
199.From memory, my knowledge of the Known Error Log (‘KEL’) and the
PinICL/PEAK database was limited to the extent of that which was shared at
the PLSG meetings. I had never heard of them until we got into the Group
Litigation Order (‘GLO’) process. Fujitsu only disclosed ARQ data for the
Scheme and so this terminology had never come up before and was not part
of what I did on a daily basis. I was cross-examined extensively on them and
whilst it might seem remarkable that I had not seen them before, I genuinely
had not. I do not feel that I am able to add anything substantive beyond what
is contained in the trial transcripts.
200. Although I was in attendance in the PLSG meetings when
KELs/PinICLs/PEAK were discussed, my involvement was limited and I had
no involvement with disclosure. From my perspective, disclosure was a
requirement of the GLO and managed by the Legal team as they had the
experience of, and expertise in, disclosure. The discussions that I can recall
on disclosure were pretty much ‘lawyer to lawyer’.
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201.1 do not know the basis on which POL pleaded paragraph 50(4) of the
Defence. I do not recall any discussions on this, although I presume that
Fujitsu provided this information to POL.
Preparation for the Common issues trial
202.My recollection is that decisions on redacting documents were taken by the
Legal team.
203.For the preparation of witness evidence, Womble Bond Dickinson worked with
witnesses to help them draft their witness statements.
204.1 do not recall specifically how the Post Office’s case on the effect of the
“settle centrally” button was prepared, but as set out above, the general
approach adopted when answering specific issues was to seek input from the
business area owner/subject matter expert and/or request that they verify the
wording for accuracy. In this case, for ‘settle centrally’ button, this was FSC
and so I assume that they were heavily involved.
205.1 was not involved in the decision-making for the approach to the cross-
examination of claimants. If I recall correctly, this was a Legal team decision
with, I expect, the approval of POL Board.
206.1! can confirm that I have reviewed the following documents:
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. The judgment of Fraser J in Bates & Others v. Post Office Limited
[2017] EWHC 2844 (QB);
. POL00253924 (proof of evidence as at 9 March 2018);
. POL00006674 (proof of evidence dated 25 January 2018);
. POL00024270 (Postmaster Litigation Advisory Board Subcommittee
document). This sets out the purpose, membership and ways of
working of the subcommittee as at 29' Jan 2018;
. POL00006764 (minutes of the meeting on the Postmaster Litigation
Subcommittee of the POL board on 26 March 2018);
POL00006763 (minutes of the Postmaster Litigation Subcommittee
meeting on 10 July 2018);
. POL00167503 (draft witness statement - 23 July 2018 v.1);
. POL00111032 (draft witness statement at 23 2018 July v.2);
. POL00111043 (draft witness statement at 23 2018 July v.3);
POL00041956 (draft witness statement at 23 July 2018 v.4) and
POL00041955 (covering email);
POL00111071 (draft witness statement at 23 July 2018 v.5);
. POL00111070 (draft witness statement at 23 July 2018 (v.5));
POL00041992 (draft witness statement at 23 July 2018 v.6);
m. POL00003777 (witness statement signed on 24 August 2018);
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. POL00042007(email from Andrew Parsons to me and others on 5
September 2018). The email is to witnesses for the Common Issues
Trial about what to expect in the run up to attending court and advising
of witness familiarisation training;
. POL00006757 (minutes of the Postmaster Litigation Subcommittee
meeting on 24 September 2018);
. POL00111236 (draft of second witness statement dated 28 September
2018);
. POL00154333 (email from Mark Underwood on 28 September 2018);
The judgment of Fraser J in Bates & Others v. Post Office Limited
[2018] EWHC 2698 (QB);
. POL00042065 (Jane MacLeod’s email to me and others on 16 October
2018);
POL00111241 (draft of second witness statement with comments at 24
October 2018);
. POL00258255 (email from Mark Underwood to me and others on 18
October 2018). This is an email from Mark to witnesses about logistics
for the Common Issues trial and their prep; and POL00258256
(attachment - background note from Mark for the witnesses);
. POL00154361 (email from Mandy Robertson to me on 1 November
2018). Cover email POL00154364 which gives a steer from Womble
Bond Dickinson on where to focus efforts as a witness on preparing to
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give evidence and POL00154362 (attachment - feedback on how I
performed at the witness familiarisation training);
w. POL00154364 (email from Dave Panaech to me on 2 November
2018);
x. POL00136336 (email from me to Andrew Parsons on 13 November
2018 raising a query on whether losses under £150 will be investigated
by POL if disputed by SPM);
y. POL00042132 (email from me to Andrew Parsons on 14 November
2018). This is further correspondence around losses under £150.
207.1 have been asked to explain the background and purpose to creating a formal
subcommittee of the POL Board to deal with the group litigation. I do not recall
ever being briefed on the reasoning. I was not a member of this
subcommittee.
208. The Terms of Reference for the subcommittee have not been disclosed but
POL00006764 states ‘it was noted that at the meeting of the Post Office
Limited Board on 29 January 2018, the Board established a committee to
receive advice relating to the Postmaster litigation. The Company Secretary
tabled draft terms of reference for the Committee which were noted and
approved for recommendation to the Board at the next Board meeting on 27
March 2018. It was explained that day-to-day decisions on the litigation were
taken by the executive but that the Board was consulted in advance of any
significant decisions being taken.” Similarly, POL00024270 states “A
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subcommittee of the Post Office Limited Board is established to receive legal
advice on the Post Office’s Defence in the Group Litigation as it proceeds to
final resolution.” As I was not involved, I do not feel that I am able to expand
on anything beyond what is contained in the documents.
209.1 do not recall having any discussions with POL senior managers or directors,
or representatives of UKGI or government, on litigation strategy following
Fraser J’s comments on POL’s approach in his decision on the application to
strike out aspects of the claimant's witness evidence.
210.As a witness, I understood that my role was to assist the Court/judge by
211.
providing factual evidence to the best of my knowledge, by way of the witness
statement and also through oral evidence. I undertook ‘familiarisation training’
where it was drummed into us that witnesses could not be coached and that
we were there to assist the judge and to go in and tell the truth in the most
simple and straightforward way as possible. My understanding of the role did
not change throughout the course of the GLO.
I was, however, highly criticised by Justice Fraser at the Common Issues trial
who stated ‘there are two particular matters in which I find that she [me] did
not give me frank evidence, and sought to obfuscate matters, and mislead
me...” This was not my intention and I deeply regret inadvertently giving him
cause to form that view.
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212.As to the process of taking and drafting my witness statement, I remember
that I had a meeting with a couple of the Womble Bond Dickinson lawyers and
I talked through my roles and experience in POL over the 33 years that I had
been with POL. I believe that they asked me questions about a number of
points and the meeting lasted several hours. From this discussion, they
drafted an initial document that went through several iterations before I signed
the final version.
213.As I recall, Melanie Corfield (Communication Team) and Kathryn Alexander
(Support Services Resolution at the time, previously Mediation Case Review
Manager) kindly helped me by locating the documents that I wanted to read to
refresh my memory and to ensure that I had the correct dates and appropriate
wording. Melanie Corfield provided the source links for the documents in the
footnotes.
214.1 have reviewed each paragraph of my Common Issues final statement signed
24 August 2018 and can confirm that, for the most part, this was derived from
my own knowledge at the time (although I no longer have this level of
knowledge), some of which will have been drawn from documents that I had
read over the years. I have referenced some sources in the footnotes within
my statement:
a. My own knowledge: 5-18 inclusive; 20-27 inc; 29-94 inc; 96-105 inc;
112 - 145 inc.
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b. Documents I read: for the ones I’ve referenced in the footnotes,
Melanie Corfield provided the source links for these for me
c. Information from others: 28; 95; 106 -111 inc.
215.1 do not feel that the lawyers at any point influenced what I said or told me
what to say in my witness statement. However, they did guide me on the
areas/topics to cover.
216.1 do not recall now why paragraphs 139 and 140 of my draft statement
(POL00253924) were removed and from the documents disclosed to me,
there is nothing that gives me any insight into the reason for this. I vaguely
remember broad discussions about putting more emphasis on certain things
or keeping things more brief but there was no conscious decision from me to
put POL in a good light and I cannot recall details beyond a general memory
of these sorts of discussions. It was a very long process, which I was doing
alongside my day job.
217.As noted above, I was guided by the Legal team as to what areas/topics to
include in my witness statement. Beyond this, I cannot recall why I did not
describe the detail of the settle centrally button and its consequences in my
witness statement.
218.1 do not recall considering what was helpful or unhelpful content to POL when
I was drafting my statement. POL is a complex organisation and in drafting my
witness statement for the Common Issues Trial I was trying to set out POL’s
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background, the environment it operated in and how it operated on a day to
day basis, in a factual (as to what I believed to be correct at the time) and as
straightforward way as I could. The Legal team guided me on the areas/topics
to cover and I followed their guidance.
219.1 was criticised by Justice Fraser in his judgement (Alan Bates and Others v
Post Office Limited [2019] EQHC 606 (QB)) for having left out certain details,
and for having stated at the time that my reasoning for leaving out certain
detail was because I thought that the statement was already too lengthy. To
be clear, I was not told that the length of my witness statement had to be a
certain length but I do recall general discussions about trimming it back and
what to keep in and take out. I distinctly recall that when cross-examined, I
said that I thought Horizon was “clunky” and I was criticised for not having
said this in my statement. I remember being surprised as I thought that I had
but when I went back and reviewed my statement, I realised that I had
forgotten that this reference was removed in one of the draft amendments.
Please see paragraph 115 of draft statement POL00253924 where I have
said ‘the biggest weakness in Horizon is that it is a bit “clunky” to use.” For the
avoidance of doubt, it is my view that the Horizon system was clunky. I wholly
accept that I signed that statement and only I am responsible for anything that
was or was not in that statement. I was guided by legal advice and it was an
error to have removed references such as this.
220. The witness familiarisation sessions were designed to give witnesses an
insight into the Court process and what to expect on the day. As I remember,
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the overriding message from the session was that as a witness, you are there
to provide factual, honest information to the judge to assist him in his
understanding of how POL operated/operates and the matters to which we
were providing witness statements on. Whilst it did not change my approach
to my evidence (as our evidence was not discussed in the sessions), it helped
me to be better prepared for my Court appearance.
221.As noted above, the areas that I covered in my witness statement were
guided by the Legal team. I did not feel pressured by this approach, I found it
helpful as I was not experienced in the Court legal process and without their
guidance I would not have known what areas to have covered in my
statement.
222. The first I heard of the recusal application was when Fraser J returned from
recess during the live trial and announced that he had received a recusal
application from the Post Office. I remember having to ask my lawyer what
recusal meant and finding the whole situation embarrassing.
Horizon issues
223.In preparing for the Horizon issues trial, I can confirm the following:
a. I had no involvement in the assertion of privilege in redacting
documents. This was done by the Legal team.
b. My involvement in the preparation of witness evidence was only in
relation to my own witness statement.
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c. I am not aware of how Post Office’s case on bugs, errors and defects
and remote access issue was prepared.
d. Although I can recall discussions between POL (legal team and
possibly the IT team) with Fujitsu and Gareth Jenkins, I was not
involved in these discussions and so I am unable to answer to what
extent they provided assistance in preparing the case.
224.1 can confirm that I have reviewed the following documents:
a. POL00006442 (decision paper on disclosing PEAKs). This is an
options paper from Womble Bond Dickinson to PLSG with a
recommendation to do word search for legally privileged
information;
b. POL00000679 (my witness statement dated 16 November
2018);
c. POL00042226 (email from Andrew Parsons to me on 20
January 2019);
d. POL00042278 (email from Andrew Parsons to me on 11
February 2019). This email is asking that my team help locate
relevant documents in relation to the bugs that Jason Coyne
identified;
e. POL00111660 (email chain between Katie Simmonds and me
on 14 February 2019). This email is regarding Angela Burke and
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is also a request from me to amend information in my witness
statement earlier than the week before the trial;
POL00024147 (email from Rodric Williams to Jane MacLeod on
19 February 2019). This email is about a risk assessment and
witness familiarisation training;
. POL00006753 (minutes of the meeting of the Group Litigation
Subcommittee of the POL Board on 21 February 2019);
. POL00000679 (amended second witness statement at 11
March 2019);
POL00000688 (corrections to Defendant's witness statements);
and POL00155095 (my email to Ben Foat on 8 July 2019).
Whilst I can’t remember the email or the circumstances leading
up to it, I was clearly concerned that the Steering Committee
was not functioning as originally intended and I wanted there to
be transparency with the members about this;
Document POL00042226 is an email from Andrew Parsons to
me on 20 January 2019, where Andy is flagging a risk with the
approach that Robert Worden is taking to present his
findings/evidence to the judge. I don’t recall discussing this
email with anyone at the time. While Andy was making us
(Rodric Williams and me) aware of the ‘off process’ approach
that Robert Worden was taking, he says in this email that there
is nothing POL or the Legal team can do (other than
acknowledge the risk) as this is his expert witness evidence.
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Whilst I was aware of Robert Worden’s work, I had not been
involved in it.
225.My role in relation to the training of witnesses for the Horizon issues trial was
to act as a conduit between Womble Bond Dickinson (who had arranged the
witness familiarisation training with Bond Solomon) and the POL employees
who had been identified as witnesses for the GLO trials. Being a witness ina
High Court trial was not a routine part of their role and potentially a daunting
experience. My role was to oversee the witness familiarisation training, to
ensure that the witnesses felt as comfortable and prepared as they could be.
Following the experience of the Common Issues and Horizon Trials, I drafted
the ‘Witness Support Framework’ (this document has not been disclosed)
setting out my recommended approach for POL to adopt as minimum support
for any future witnesses required to give evidence.
226.1 do not remember when I was asked to be a witness, however I understand
that I was asked because the timeline of the GLO meant that it spanned 20
years. I had been in the Post Office for 33 years by this point and I was the
most senior individual who had good operational experience as well as
knowledge of the investigations because of the Mediation Scheme.
Importantly, POL was approaching the GLO by looking at in-branch
transactions and operational evidence and that was where I had the most
knowledge. However, Patrick Green KC for ‘Alan Bates and Others’
approached the case from a ‘remote access’ and ‘bugs’ issue for which I did
not have the requisite knowledge. I think that there was a genuine blind spot
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in POL that Horizon was the issue, which meant that IT were not as involved
as I now, with the benefit of hindsight, believe they should have been. Instead
this was looked at from an operational point of view.
227.1 cannot recall the exact process by which my witness statement was drafted
in the Horizon issues trial, but as previously, I was guided by the Legal team
as to what areas to include in my statement. Much of the content of this
statement was responding to certain claims made by Lead Claimants in their
Common Issues witness statements; responding to certain claims by Mr
Coyne, the Claimant's IT expert, and responding to Mr Henderson’s analysis.
For the SPM evidence, the issues raised/claims made were investigated by
my team of investigators, with a report produced of their findings. Having
reviewed these reports, I then used that content in my witness statement.
Having reflected on the types of questions that were put to me during cross-
examination, I think that my witness statement tried to cover too many areas
as my role as a witness should have been limited to operational matters, with
the Chief Information Officer being brought in to speak to technical IT matters.
228.At 208 of Justice Fraser’s judgment (Alan Bates and Others v Post Office
Limited) [2019] EWHC 3408 (QB), he states the following:
“she [Angela] also explained that in relation to Mrs Burke “I have
looked at other evidence in relation to Mrs Burke and what was very
clear to me is that Mrs Burke had done absolutely nothing wrong in that
situation”. This is not at all how Mrs Burke had been cross-examined.
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Mrs VDB said that the corrects she had made to her statement had
been communicated to the PO solicitor’s before the Horizon Issues trial
had started. If this is true, I do not see how counsel for the PO would
have cross-examined her on the basis of her un-corrected statement.“
229.1 was deeply upset by this as I had been constantly ringing Jonny Gribben
(senior lawyer) prior to the Court case telling him that I needed to change my
statement because further evidence had come up that showed what had
happened behind the scenes and that Mrs Burke had done a transaction but it
had disappeared in branch. In parallel, Fujitsu had picked up on the issue but
POL had not been made aware. I knew this weeks before we got to Court and
I got in touch with my legal team to tell them this. I was really disappointed
that it had not been picked up and I have requested further disclosure from
the Inquiry for any correspondence with the legal team around this date. I
have expanded on this below in respect of the Inquiry’s questions around this
point.
230. The Inquiry have asked about why I sought to make changes to my statement
after it was signed and served and in particular, why the proposed
amendments of paragraph 110 of my second witness statement
(POL00000679) were not included in the list of amendments (POL00000688).
I first sought to make changes to my statement in mid-February as can be
seen by the correspondence between Womble Bond Dickinson lawyers and
myself in POL00111660. This is an email chain between Katie Simmons and
me on 13 and 14 February 2019. The email is in respect of Angela Burke and
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me requesting to amend information in my witness statement more than a
week before the trial.
-POL00111877 (my amended Second Witness Statement, disclosed by the
Inquiry 7 March 2024) shows tracked changes to paragraph 110 that were not
reflected in the list of amendments (POL00000688). I don’t know why that
was the case as the other changes (with the exception of a minor change to
add c .before £9000 at para 127) tracked in this version of my statement have
been included in the list of amendments.
232. The Inquiry have asked me to explain the background and purpose of my
email at POL00155095. I am unable to answer this question fully as I cannot
recall from memory and have asked for further disclosure in respect of this
question but not received any. At the time, I obviously felt strongly enough
about this issue to put it in an email to Ben. I seem to recall that other Group
members were mentioning to me that they felt the PLSG was not operating as
it had been previously in that it seemed that decisions were being taken by
Board/Board sub-group without any input from them and therefore they were
concerned about the potential impact of those decisions on their areas. I think
this is what prompted my email to Ben.
LEAVING POL
233.With the settlement being reached on the GLO in December 2019, my role
came to an end. As a result, I was made redundant.
Page 110 of 132
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GENERAL
234.Based on my knowledge at the time, my view is that POL responded
appropriately by appointing Second Sight, setting up the Scheme and making
every effort to fully investigate the issues put forward by SPMs.
235.However, having seen what has come out of the Inquiry and having had the
opportunity to take a step back and evaluate things with the benefit of
hindsight, my biggest regret is that we did not get an external IT expert, such
as Deloitte (or another appropriately qualified organisation), to do a deep dive
into the Horizon system to assess whether what the claimants were claiming
was possible and if so, whether there was any evidence of their claims
happening. The idea that Fujitsu could be going into branch accounts, altering
figures and generating losses in those accounts seemed so fictitious that I do
not think anyone in POL properly contemplated it as a possibility. I think this is
why POL approached the cases from an operational and not a technical point
of view.
236.In my view, Fujitsu were being insufficiently transparent about the bugs in the
system meaning that even people of my seniority were not aware of the full
extent of them. Whilst making recommendations to POL during 2018/2019 I
suggested that POL established a portal for SPMs to access so that they
could see the characteristics of known bugs. Should a discrepancy arise, they
would be able to go to the portal to see whether the problem at their branch
was likely to have been caused by a bug. I wanted a more open way of
Page 111 of 132
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WITNO9900100
working to help SPMs identify and address the cause of any losses they may
have.
237.1 felt that the intentions of those I worked with were genuine and they wanted
to get under the skin of whether there was any substance to these claims,
including myself. However, on reflection I do think that at some point during
the GLO preparation/trials there became less emphasis on addressing SPM’s
issues, by making improvements to policies, procedures and ways of
workings, and the focus from a legal perspective, shifted to a more defensive
approach. I do not think that my approach changed throughout (and if it did
that wasn’t my intention) as I continued to use the process to identify issues
and make recommendations to the business on policy and process
improvements. I recall presenting a slide deck at a senior meeting (I can’t
remember the forum but General Executive members were in the room) on
my reflections on the GLO and subsequent recommendations quite soon after
the Common Issues trial (probably in December 2018).
238.In respect of POL’s approach to prosecutions, I do not feel able to comment
as I had no experience in this area and a limited knowledge of what was
involved. However, I was assured by the business that the strict process they
followed adhered with the Crown Code of Prosecutors. Similarly, I do not feel
able to comment on POL’s conduct of the GLO proceedings as I was not
involved in the decisions on how POL should engage in the process. I
believed at the time that the process being followed by the lawyers was the
norm and in keeping with how those processes typically worked.
Page 112 of 132
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239. Although the Inquiry has not asked me to review Human Impact Statements, I
felt it important to respond to two where I am referenced.
240.In respect of the Human Impact Statement of Jennifer O’Dell:
a. Page 26 line 16: ..."she became extremely intimidating, extremely
bullying towards me, demanding that I...! sign a piece of paper that I
had stolen the money and if I didn't they were going to take my
home away"
241.1 suggest that Mrs O'Dell is mistaken in her recollection. I have never, and
would never, behave in such a way. This was a mediation meeting and there
were five of us in the room - Mrs O'Dell and her representative from Howe &
Co, POL's legal representative, the independent mediator from CEDR and
myself. If I had behaved as Mrs O'Dell claims and said what she said I did (all
of which I strongly deny) the other parties in the room would have said
something and/or challenged such behaviour. They did not, as what Mrs
O'Dell alleges did not happen.
242.In respect of Chirag Sidhpura oral evidence 17 March 2022, page 43, line 13
"Angela Van Den Bogerd was appointed to conduct an independent
review of my case but because the trend was already set by Paul
Page 113 of 132
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WITNO9900100
Southin, she could not go back and change that, even if she wanted to,
as this was months before the GLO was to start"
243.1 did conduct an independent review of Mr Sidhpura's case and initiated a
fresh investigation into the issues that led to his suspension and contract
termination. However, on the findings of that investigation and the content of
his interview with me, the evidence was such that I was unable to reinstate Mr
Sidhpura. My decision was based on the facts of my review, the pending GLO
had no bearing on my decision. I have previously reinstated other SPMs
where that decision was justified.
244. There are no further matters that I consider are of relevance to the Inquiry that
I would like to draw to the attention of the Chair.
STATEMENT OF TRUTH
I believe the content of this statement to be true.
Dated:
Page 114 of 132
INDEX
WITNO9900100
WITNO9900100
No
URN
Document Description
Control Number
POL00178199
Email from Clive Burton to Angela Van-Den-
Bogerd RE: Mrs Keri Ann Pugh Former
Subpostmistress Chirbury Post office - FAD
Code - 296/641
POL-BSFF-0016262
POL00041564
Bankruptcy, prosecution and disrupted
livelihoods - Postmasters tell their story;
reported by Rebecca Thomson - Article
POL-0038046
POL00026572
Horizon — Response to Challenges Regarding
Systems Integrity
POL-0023213
POL00088956
Email thread between John Breeden, Angela
Van-Den-Bogerd and others, re: Follow up to
BIS meeting on JFSA
POL-0080917
POL00088957
Email from John Breeden to Angela Van-Den-
Bogerd cc: Sue Huggins, Tracy Marshall and
Lin Norbury RE: Horizon Integrity final report
POL-0080918
POL00294728
Email from Tracy Marshall to Kevin Gilliland,
Angela Van-Den-Bogerd cc'd Helen Rose re:
Horizon system issues
POL-BSFF-0132778
POL00178200
Email from Emlyn Hughes to Clive Burton, Denise
Sparkes RE: Mrs Keri Ann Pugh Former
Subpostmistress churbury Post Office - FAD Code -
296/641 — 22 March 2004 at 11:14
POL-BSFF-0016263
POL00178201
Email from Emlyn Hughes to Clive Burton RE:
Mrs Keri Ann Pugh Former Subpostmistress -
22 March 2004 at 11:50
POL-BSFF-0016264
POL00178208
Email from Emlyn Hughes to Clive Burton RE: Mrs
Keri Ann Pugh - Former Subpostmistress chirbury
Post Office - FAD COde 296/641 — 24 March 2004
at 15:21
POL-BSFF-0016271
10.
POL00178211
Email from Emlyn Hughes to Clive Burton RE: MRS
KERI ANN PUGH FORMER
SUBPOSTMISTRESS CHIRBURY POST
OFFICE - FAD CODE: 296/641 — 27 March
2004 at 11:27
POL-BSFF-0016274
41.
POL00178219
Email from Clive Burton to Jim Cruise re: MRS
KERI ANN PUGH FORMER
SUBPOSTMISTRESS CHIRBURY POST
POL-BSFF-0016282
Page 115 of 132
WITNO9900100
WITNO9900100
OFFICE - FAD CODE: 296/641 — 8 April 2004
at 12:59
42;
POL00178223
Email from Clive Burton to Jill Camplejohn and
Emlyn Hughes re Re: MRS KERI ANN PUGH
FORMER SUBPOSTMISTRESS CHIRBURY
POST OFFICE - FAD CODE: 296/641 — 8 April
2004 at 13:27
POL-BSFF-0016286
13.
POL00178221
Email from Clive Burton to Jill Camplejohn and
Emlyn Hughes re Re: MRS KERI ANN PUGH
FORMER SUBPOSTMISTRESS CHIRBURY
POST OFFICE - FAD CODE: 296/641 — 8 April
2004 at 13:08
POL-BSFF-0016284
14.
POL00178225
Email from Emlyn Hughes to Andrew Walsh, Clive
Burton, Denise Sparkes RE: Mrs Keri Ann Pugh
former subpostmistresss Chirbury Post Office - FAD
Code: 296/641 — 8 April 2004 at 13:34
POL-BSFF-0016288
15.
POL00099063
Signed Interim Report into alleged problems
with the Horizon system
POL-0098646
16.
POL00027722
Post Office Pack for meeting with James
Arbuthnot and other MPs Meeting scheduled
for 18th June 2012, 6pm, Portcullis House
POL-0024363
17.
POL00148075
POST OFFICE LTD, PROJECT SPARROW
SUB-COMMITTEE re: Minutes of a meeting of
the Project Sparrow Sub-Committee of the
Boardheld at 148 Old Street, London EC1V
9HQ on Wednesday 9 April 2014
POL-BSFF-0007198
18.
POL00004439
Initial Complaint Review and Mediation Scheme
- Briefing Report - Part One - Prepared by
Second Sight
VIS00005507
19.
POL00091394
Email from Melanie Corfield to Belinda Crowe,
Rodric Williams, Angela Van-Den-Bogerd; re:
M053 Revised Draft CRR
POL-0090416
20.
POL00022382
POL's draft response to Second Sight's
Thematic Issues Report
POL-0018861
21.
UKGI00000018
POL response to Second Sight briefing report -
Part Two as part of the Complaint Review and
Mediation Scheme
VIS00000979
POL00231477
Panorama Statement stating Allegations
against Miscarriage of Justice, POL's
investigation into branch losses, POL's
POL-BSFF-0069540
Page 116 of 132
WITNO9900100
WITNO9900100
Investigation into Horizon, Remote access,
Prosecutions led by POL etc.
23.
POL00091401
Email from Rodric Williams to Angela Van-Den-
Bogerd and Alexandra Ward with attachments,
re: O'Dell Mediation - Panorama
"whistleblower"
POL-0090423
24.
POL00024802
Womble Bond Dickinson Rider: Remote Access
(Letter of Claim)
POL-0021281
25.
POL00141432
Post Office Branch Audit Trend Analysis YTD
Q1 2012/13 - Prepared by Angel Van Den
Bogerd
POL-0142817
26.
POL00294743
Interview Notes - Ferndown branch - in
confidence
POL-BSFF-0132793
27.
POL00046944
Letter from Shoosmiths to The Post Office re:
Julian Wilson
POL-0043423
28.
POL00176467
Email from Angela Van-Den-Bogerd to John
Breeden, Lin Norbury, Sue Richardson and
others re: URGENT ACTION REQUIRED: JFSA
claims - disclosure and evidence gathering
POL-0171738
POL00294879
Memo from Rod Ismay to Angela Van Den
Bogerd and others on 12/10/11 re: JFSA and
Shoosmiths / Access Legal - Response to
Challenges - Proposed Steering Group and
Purpose.
POL-BSFF-0132929
30.
POL00085836
Email from Craig Tuthill to Angela-Van-Den-
Bogerd cc: Sue Richardson RE: IN STRICTEST
CONFIDENCE - Urgent Request Please
POL-0082894
34.
POL00113791
Email from Susan Crichton to Alice Perkins and
Paula Vennells re: TOR for the investigation
POL-0112899
32.
POL00137248
Meeting Agenda for Arbuthnot/Letwin attended
by Angela Van Den Bogerd, Chris Darvill,
Jarnail A Singh, Lesley J Sewell, Rod Ismay,
Simon Baker, Susan Crichton etc.
POL-BSFF-0000032
33.
POL00022378
Initial complaint review and mediation scheme
report
POL-0018857
POL00186110
Email from Simon Baker to Susan Crichton,
Alwen Lyons, Angela Van Den Bogerd and
others RE: Horizon investigation monthly
project board meetings
POL-BSFF-0024173
Page 117 of 132
WITNO9900100
WITNO9900100
35.
POL00296463
Email from Angela Van Den Bogerd to Simon
Baker re spot review responses
POL-BSFF-0134513
36.
POL00115919
Post Office Limited - Internal Briefing Note to
Paula Vennells: Second Sight review into
Horizon -Implications of Interim Report -
DRAFT
POL-0116921
37.
POL00065349
Letter from Angela Van Den Bogerd to Ms
Lumley re: Julian Wilson
POL-0061828
38.
POL00186111
Powerpoint presentation: Horizon Investigation
Governance.
POL-BSFF-0024174
39.
FUJ00086811
Horizon data, Lepton SPSO 191320, Draft
Report by Helen Rose
POINQ0092982F
POL00144296
Email from Helen Rose to Angela Van-Den-
Bogerd and cc'ing Elaine Spencer re: Lepton -
ARQ logs from Fujitsu for Lepton
POL-BSFF-0003440
41.
POL00134139
Email chain from Helen Rose to Angela Van-
Den-Bogerd, Elaine Spencer re: Lepton logs
POL-0138592
42.
FUJ00229801
Email chain from Penny Thomas to Gareth
Jenkins re: transaction log - Fujitsu transaction
log for Lepton 191320 for 4th October 2012 to
25th October 2012
POINQ0235955F
POL00298004
Update on the work programme arising from
the Horizon Report
POL-BSFF-0136054
POLO00190036
Email from Simon Baker to Alwen Lyons cc:
Lesley Sewell, Susan Crichton and others RE:
Summary of two incidents
POL-BSFF-0028099
POL00190037
Summary of 2 Anomalies. The 62 Branch
Anomaly and the 14 Branch Anomaly
POL-BSFF-0028100
POL00116057
Email from Lesley J Sewell to Susan Crichton,
Alwen Lyons, Angela Van-Den-Bogerd and
others re: FW: Actions
POL-0117059
47.
POL00089711
Branch Support Programme — Terms of
Reference v.2
POL-0086686
POL00137327
Email from Susan Crichton to Angela Van-Den-
Bogerd and Alwen Lyons cc Simon Baker re
Terms of reference for the appointment of Brian
Altman QC
POL-BSFF-0000093
POL00193074
Email from Simon Baker To: Susan Crichton,
Chris M Day, Andy Holt and others re
POL-BSFF-0031137
Page 118 of 132
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PRINTED: slide pack for tomorrow's weekly
Steering Group
POL00137343
Sub-Postmaster Improvements & Mediations -
Weekly Steering Group - 1 August 2013
POL-BSFF-0000101
51.
POL00027664
Post Office Branch User Forum (The Forum).
Terms of Reference - Draft
POL-0024305
52.
POL00105634
‘Meeting with MPs - Mediation Scheme and
Branch Improvement Programme’ Minutes,
undated.
POL-0104622
53.
POL00043640
Working Group for the Initial Complaint Review
and Mediation Scheme, Key points and actions
from teleconference on 17 October 2013
POL-0040143
POL00026625
Working Group for the Initial Complaint Review
and Mediation Scheme - Key Points and
Actions from Meeting 11am 25 October 2013
POL-0023266
55.
POL00043622
Working Group for the Initial Complaint Review
and Mediation Scheme - Key Points and
Actions from conference call - Working Group
applications to be accepted onto Scheme
POL-0040125
POL00043635
Working Group for the Initial Complaint Review
and Mediation Scheme, Agenda for meeting at
11:30am on 22 November 2013 @ Bond
Dickinson, London
POL-0040138
57.
POL00043624
Working Group for the Initial Complaint Review
and Mediation Scheme - Key points and actions
from the conference call at 1pm on 28
November 2013
POL-0040127
POL00027505
Initial Complaint Review and Mediation Scheme
- [Draft] Settlement Policy
POL-0024146
59.
POL00043625
Working Group for the Initial Complaint Review
and Mediation Scheme Key points and actions
from the conference call at 1pm on 5 December
2013
POL-0040128
POL00026634
Key points and actions of the "Working Group
for the Initial Complaint Review and Case
Mediation Scheme" from 19/12/2013
POL-0023275
61.
POL00026638
“Working Group for the Initial Complaint
Review and Case Mediation Scheme" Amended
Minutes of 03/01/2014
POL-0023279
Page 119 of 132
WITNO9900100
WITNO9900100
62.
POL00026682
Working Group for the Initial Complaint Review
and Case Mediation Scheme - Key points and
actions from the conference call at 1pm on 9th
January 2014
POL-0023323
POL00026639
“Working Group for the Initial Complaint
Review and Case Mediation Scheme Standing
Agenda" for 16/01/2014
POL-0023280
POL00026640
Meeting Minutes for Working Group for the
Initial Complaint Review and Case Mediation
Scheme
POL-0023281
65.
POL00026641
Initial Complaint Review and Mediation Scheme
- Working Group - Minutes - 30 January 2014
POL-0023282
POL00026635
Working Group for the Initial Complaint Review
and Case Mediation Scheme Standing Agenda
for Thursday Calls
POL-0023276
67.
POL00138101
Initial Complaints Review and Case Mediation
Scheme Programme Board
POL-BSFF-0000337
68.
POL00043626
"Working Group for the Initial Complaint Review
and Case Mediation Scheme’
POL-0040129
POL00026637
“Working Group for the Initial Complaint
Review and Case Mediation Scheme Standing
Agenda" for 27/02/2014
POL-0023278
70.
POL00026656
Face to face meeting of the working group -
Initial complaint review and mediation scheme-
7 March 2014
POL-0023297
71.
POL00026644
Working Group for the Initial Complaint Review
and Case Mediation Scheme - Minutes for
27/03/2014
POL-0023285
72.
POL00026633
Initial Complaint and Mediation Scheme
Working Group Minutes of 01/04/2014
POL-0023274
73.
POL00026642
Working Group for the Initial Complaint Review
and Case Mediation Scheme Standing Agenda
POL-0023283
74,
POL00138282
Initial Complaints Review & Case Mediation
Scheme Programme Board
POL-BSFF-0000508
75.
POL00303871
Email from Angela Van-Den-Bogerd to Kathryn
Alexander and Shirley Hailstones re: FW: WG
minutes - 17th April
POL-BSFF-0141921
76.
POL00061368
Email chain from Andrew Parsons to Jarnail
Singh; Angela Van-Den-Bogerd; Rodric
POL-0057847
Page 120 of 132
WITNO9900100
WITNO9900100
Williams and others, re: Officer's Report and
case M054 (Susan Rudkin)
77.
POL00169322
Email from Jarnail Singh to various RE:
Officer's report [BD-4A.F1D20472253] on 23
April 2014 at 12:16
POL-0167464
78.
POL00043627
Initial Complaint Review and Mediation Scheme
Working Group - Minute of meeting dated 6
May 2014
POL-0040130
19.
POL00304439
Email from Angela Van-Den-Bogerd to Kathryn
Alexander re: FW: URGENT - Request for
Information Please
POL-BSFF-0142489
80.
POL00117650
Email from Andrew Winn to Alan Lusher re:
Rivenhall - Graham Ward SPM suspension
POL-0115233
81.
POL00026657
Working Group for the Initial Complaint Review
and Case Mediation Scheme - Minutes of case
conference call 15 May 2014
POL-0023298
82.
POL00026659
Minute of Initial Complaint Review and
Mediation Scheme - Working Group 20 May
2014
POL-0023300
83.
POL00026668
Working Group for the Initial Complaint Review
and Case Mediation Scheme - Working Group
Minute - 5th June
POL-0023309
POL00026664
Working Group for the Initial Complaint Review
and Case Mediation Scheme Meeting Minutes -
12th June
POL-0023305
85.
POL00140431
Agenda and Briefing Notes - Working Group for
the Initial Complaint Review and Case
Mediation Scheme
POL-0141990
86.
POL00026673
Minute - Initial Complaint Review and Mediation
Scheme - Working Group 16 June 2014
POL-0023314
87.
POL00026665
Working Group for the Initial Complaint Review
and Case Mediation Scheme - Minute of
Working Group Call 26 June 2014
POL-0023306
POL00026672
Minute - Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 10th July 2014
POL-0023313
89.
POL00026671
Working Group for the Initial Complaint Review
and Case Mediation Scheme - Minutes of the
Working Group Call 17 July 2014
POL-0023312
Page 121 of 132
WITNO9900100
WITNO9900100
90.
POL00026683
Working Group for the Initial Complaint Review
and Case Mediation Scheme Meeting Minutes
of 24 July 2014
POL-0023324
91.
POL00026674
Minute - Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 31st July 2014
POL-0023315
92.
POL00029749
Email from Angela Van-Den-Bogerd (POL) to
Andrew Parsons, Belinda Crowe, Alexandra
Ward, Matthew Harris and Andrew Pheasant re:
M025 draft POIR [BD-4A.FID25887007]
POL-0026231
93.
POL00026676
Minute - Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 28 August 2014
POL-0023317
94.
POL00026679
Working Group for the Initial Complaint Review
and Case Mediation Scheme -Meeting Minutes
(04/09/14)
POL-0023320
95.
POL00026680
Minutes - Working Group for the Initial
Complaint Review and Mediation Scheme - 11
September 2014
POL-0023321
96.
POL00101361
Email from Angela-Van-Den-Bogerd, to Richard
Weaver, Mark Davies and others re: The news
POL-0100944
97.
POL00026685
Working Group for the Initial Complaint Review
and Case Mediation Scheme Meeting Minutes -
16.09.14
POL-0023326
98.
POL00209634
Email from David Oliver1 to Chris Aujard,
Anthony Hooper, CCing Rodric Williams and
others re: Post Office Response to Second
Sight Part Two Report
POL-BSFF-0047697
99.
POL00209636
Reply by POL to Second Sight's Briefing Report
- Part 2 22nd September 2014 - Initial
complaint review and Mediation Scheme
POL-BSFF-0047699
100.
POL00043628
Standing Agenda for Thursdays calls - Working
Group for the Initial Complaint Review and
Case Mediation Scheme (25/09/14)
POL-0040131
101.
POL00026684
Minute - Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 02 October 2014
POL-0023325
102.
POL00107151
Letter from JFSA (Alan Bates) to Sir Anthony
Hooper, RE: Raising concerns about the
POL-0105459
Page 122 of 132
WITNO9900100
WITNO9900100
position and direction of the Initial Case Review
& Mediation Scheme
103.
POL00043630
Meeting Minutes - Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 14 November 2014
POL-0040133
104.
POL00213728
Agenda for Angela's Team meeting
POL-BSFF-0051791
105.
POL00150195
Email chain from Mark Underwood to Mark R
Davies, Angela Van-Den-Bogerd, cc'd Belinda
Crowe and others re 141212 - WHD speech
(Mediation scheme) mu.doc.
POL-BSFF-0009313
106.
POL00150196
Report on Sub-postmaster Mediation Scheme
by James Arbuthnot MP at Westminster Hall
Debate Date taken from Metadata
POL-BSFF-0009314
107.
POL00101858
Email Chain from Angela Van-Den-Bogerd to
Rodric Williams, Melanie Corfield and Jarnail
Singh, RE: comments from the One Show
POL-0101441
108.
POL00109809
Email from Angela-Van-Den-Bogerd to Alwen
Lyons RE: One Show
POL-0107797
109.
POL00022296
Notes on meeting held with Second Sight on
the 9th of Jan 2015
POL-0018775
110.
POL00043633
Meeting Minutes - Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 14 January 2015
POL-0040136
111.
POL00219926
Email chain from Belinda Crowe to Andrew
Parsons, Tom Wechsler, Angela Van-Den-
Bogerd and others RE: Disclosure of
prosecution files
POL-BSFF-0057989
112.
POL00022297
Email from Andrew Parsons concerning
suspense accounts
POL-0018776
113.
POL00043634
Agenda for the Working Group for the Initial
Complaint Review and Case Mediation Scheme
- 13 February 2015
POL-0040137
114,
POL00022380
Email from Angela Van Den Bogerd to Mark
Underwood, Jane MacLoed, Mark R Davies and
others regarding the end of term report and
thematic issues rebuttals
POL-0018859
115.
POL00022381
Report on the Post Office investigations and
findings
POL-0018860
116.
POL00022383
Not disclosed.
POL-0018862
Page 123 of 132
WITNO9900100
WITNO9900100
417.
POL00117183
Email from Angela Van-Den-Bogerd to Mark R
Davies, Belinda Crowe, Mark Underwood and
others re: RE: Core documents
POL-0118010
118.
POL00117184
Draft Press Statement re Post Office Mediation
Scheme Update
POL-0118011
119.
POL00151569
Draft Speaking Note for Angela Van Der
Bogerd to Speak to Alan Bates / Kay Linnell
POL-BSFF-0010681
120.
POL00029849
Initial Complaint Review Mediation Scheme:
Second Sight Briefing Report - Part Two
POL-0026331
121.
POL00228264
Letter from J Withers to Mr Wechsler re M069
POL-BSFF-0066327
122.
POL00168655
Letter from Angela Van Den Bogerd to James
Withers re Complaint Review and Mediation
Scheme (the Scheme)
POL-0163952
123.
POL00043631
MINUTE, Working Group for the Initial
Complaint Review and Case Mediation
Scheme, 8th DECEMBER 2014, MATRIX
CHAMBERS
POL-0040134
124,
POL00026652
Working Group for the Initial Complaint Review
and Case Mediation Scheme minute dated
17/04/2014
POL-0023293
125.
POL00027454
Post Office Board Report updated 20 February
2014
POL-0024095
126.
POL00002194
Post Office Business Support Programme Terms of
Reference — 7 August 2013
VIS00003208
127.
POL00148920
Post Office Business Support Programme Terms of
Reference — 04.02.2014
POL-BSFF-0008040
128.
POL00196510
Post Office Business Support Programme Terms of
Reference — 18.10.2013
POL-BSFF-0034573
129.
POL00294615
Post Office report for Branch Support
Programme - Branch User Forum Meeting 17th
July 2014 - Angela Van Den Bogerd
POL-BSFF-0161774
130.
POL00027757
Email from Kevin Gilliland to Paula Vennells,
Mark R Davies, Alwen Lyons and others RE: Mr
Griffiths
POL-0024398
131.
POL00306234
Email from Lauren Griffins to Angela Van-Den-
Bogerd CC ing regina.griffiths. RE: Hope Farm
Road Post Office
POL-BSFF-0144284
132.
POL00116698
Email from Angela Van-Den-Bogerd to various
RE: Confidential and Legally Prviliged - Hope
POL-0114601
Page 124 of 132
WITNO9900100
WITNO9900100
Farm Road Post Office at 16:13 on 5
September 2014
133.
POL00306171
Email from Angela Van-Den-Bogerd to
Parsons, Andrew, Belinda Crowe CC ing Rodric
Williams. RE: Griffiths letter [BD-
4A.F1D25887477]
POL-BSFF-0144221
134,
POL00306172
Letter from Angela Van Den Bogerd to Gina
(Post office Network Transformation)
POL-BSFF-0144222
135,
POL00219796
Email from Rodric Williams to Angela Van-Den-
Bogerd, Belinda Crowe. RE: M086
(Griffiths/Hope Farm Road) - draft Settlement
Agreement - URGENT
POL-BSFF-0057859
136.
POL00116957
Email to Tom Wechsler from Angela Van Den
Bogerd Re: Sub Post Masters - draft attached
for comment asap please
POL-0117805
137.
POL00101966
Email from Angela Van-Den-Bogerd to Tom
Wechsler re: Sub post masters - draft attached
for comment asap.
POL-0101549
138.
POLO00116960
Letter from Angela Van Den Bogerd to Mr
David Hill re: Radio 4 reports about Horizon
system
POL-0117808
139.
POL00102078
Email chain from David Hill to Angela Van Den
Bogerd; Re: Letter from Post Office
POL-0101661
140.
POL00319590
Email conversation between Melanie Corfield
and Mark Underwood’ Re: BBC Panorama and
the Post Office. CC-Karen Lumley, Julian
Wilson, Alan Bates, Andrew Bridgen, Cameron
d.
POL-BSFF-0157640
141.
POL00089010
Briefing for Angela Van Den Bogerd re:
Panorama
POL-0080971
142.
POLO00140211
Bond Dickinson Panorama Meeting - Tuesday 9
dune
POL-0141387
143.
POLO00152161
Email thread from Mark Davies to Kevin
Gilliland, Roger W Gale, Michael Larkin and
others RE: Panorama
POL-BSFF-0011273
144,
POL00317725
Email from Mark Davies RE: 9.30am:
Panorama conf call - Unsubstantiated
allegations about Horizon — important update
POL-BSFF-0155775
Page 125 of 132
WITNO9900100
WITNO9900100
145,
POL00317780
Email from Melanie Corfield to Angela Van-
Den-Bogerd re: Panorama related interview
tomorrow
POL-BSFF-0155830
146.
POL00317781
Email response by Mark on the issues
highlighted in the second sight report, review of
criminal cases, Issue log with Horizon etc.
POL-BSFF-0155831
147.
POL00317782
Draft Statement for Panorama- Prosecutions,
Remote access and Individual cases led by
POL
POL-BSFF-0155832
148.
POL00152439
Email from Communications Team to
Communications Team and bec'd Adam
France, Adnan Killedar and others re: in the
loop - a message from Mark Davies
POL-BSFF-0011551
149.
POL00318510
Email from Patrick Bourke to Jane MacLeod
RE: BBC Panorama programme - August 10
POL-BSFF-0156560
150.
POL00318511
Email Conversation between Matt and Mark
regarding the Post office programme to
broadcast the following interviewees like Jo
Hamilton, Seema Misra, Noel Thomas, James
Arbuthnot, Charles Mclachlan, lan Henderson,
Professor Mark Button, Former Fujitsu
employee etc.
POL-BSFF-0156561
151.
POLO00168291
Email from Mark R Davies (POL); to Paula
Vennells (POL); Alisdair Cameron (POL) &
others Re: BBC Panorama and mediation
scheme on Project Sparrow
POL-0163588
152.
POL00231476
Email from Mark R Davies to Angela Van-Den-
Bogerd re: Panorama statement August 2015
POL-BSFF-0069539
153.
POL00319556
Email from Mark R Davies to Angela Van Den
Bogerd. RE: Letter to BBC - Complaint on
Panorama
POL-BSFF-0157606
154,
POLO0319557
Letter by CMS Cameron McKenna LLP to BBC
Programme Legal advice and BBC Complaints
Board Re:Allegations made by POL,
Contributions from misleading experts,
Involvement of CCRC, BBC's formal complaints
procedure scheme.
POL-BSFF-0157607
155.
POL00029912
Email from Mark Underwood to Angela Van-
Den-Bogerd Lorraine Lynch and Alexandra
POL-0026394
Page 126 of 132
WITNO9900100
WITNO9900100
Ward cc Steve Allchorn and others Re:
Transcript of Panorama
156.
POLO0139183
Email from Angela Van-Den-Bogerd to Melanie
Corfield, Mark Underwood, Lorraine re
Transcript of Panorama
POL-BSFF-0001395
157.
POL00022659
Email from Amy Prime to Mark Underwood,
Angela Van-Den-Bogerd, Rob Houghton and
others re: Remote Access wording - subject to
litigation privilege [BD-4A.FID26859284]
POL-0019138
158.
POL00022665
Bond Dickinson Rider: Remote Access re:
Section 5(B) - Response to the factual
allegation that Horizon does not record
transaction accurately and /or that Post Office
has been manipulating Horizon data
POL-0019144
159.
POL00006355
Review on behalf of the Chairman of Post
Office Ltd concerning the steps taken in
response to various complaints made by sub-
postmasters
POL-0017623
160.
POL00153379
Action Points from the Meeting with Chris
Knight
POL-BSFF-0012491
161.
POL00153578
Email from Kendra Dickinson to Angela Van
Den Bogerd Re: Chairman's Report -
Requested Helpline Documentation
POL-BSFF-0012690
162.
POLO00153691
Email from Kendra Dickinson to Steve Allchorn,
Angela Van Den Bogerd, Mark Underwood1
and others Re: Chairmans report, requested
helpline documentation
POL-BSFF-0012803
163.
POL00153696
Email chain from Rodric Williams to Jane
MacLeod,Mark R Davies also cc'ed -Patrick
Bourke, Melanie Corfield, Mark Underwood and
others Re: Group Litigation
POL-BSFF-0012808
164,
POL00323294
Email from Mark Underwood to Angela Van-
Den-Bogerd, Kendra Dickinson, Kathryn
Alexander and others re: Actions from the
meetings with Jonathan Swift QC and
Christopher Knight
POL-BSFF-0161344
165.
POL00153527
Email from Melanie Corfield to Mark R Davies,
Jane MacLeod, Angela Van Den Bogerd and
others, Re: CWU and alleged Horizon error
POL-BSFF-0012639
Page 127 of 132
WITNO9900100
WITNO9900100
166.
POL00025509
Draft Postmaster Litigation Steering Group
Meeting Terms of Reference and Membership
POL-0021988
167.
POL00025507
Email from Rodric Williams to POL employees
re Postmaster Litigation Steering Group
Meeting on 7 June 2016
POL-0021986
168.
POL00025508
Agenda for Postmaster Litigation Steering
Group Meeting on 7 June 2016
POL-0021987
169.
POL00025510
Bates & Others v POL Claim Form, Claim no
HQ16X01238
POL-0021989
170.
POL00025511
Letter from Freeths to Rodric Williams (POL
Solicitor) re: Bates & Others v Post Office
Limited Group Action Letter pursuant to the
practice direction on pre-action conduct
POL-0021990
171.
POLO0006536
Disclosure of Documents in Litigation
POL-0017841
172.
POL00025513
Postmaster Litigation Steering Group Agent
Treatment of Debt Paper
POL-0021992
173.
POL00025514
Draft Postmaster Litigation Steering Group
Proposed Rolling Agenda for future meetings
POL-0021993
174,
POL00025515
Womble Bond Dickinson Postmaster Litigation
Steering Group Action Work Plan
POL-0021994
175.
POL00167538
Email from Rodric Williams to Thomas P
Moran, Angela Van-Den-Bogerd, Patrick
Bourke and others RE: Postmaster litigation
steering group
POL-0162835
176.
POL00024988
Email from Andrew Parsons to Rodric Williams,
Thomas P Moran, Andela Van-Den-Bogerd and
others RE: Postmaster Litigation Steering
Group - Confidential and Subject to Legal
Privilege
POL-0021467
177.
POL00006360
Bond Dickinson's recommendations on issues
in the Postmaster Group Action (undated)
POL-0017628
178.
POL00105719
Addendum to Shortfall Analysis: Brief Details -
Jennifer O'Dell (Great Staughton branch)
POL-0104831
179.
POL00024801
Email from Andrew Parsons to Thomas P
Moran , Rodric Williams, Angela Van-Den-
Bogerd and others re: Remote Access wording
- subject to litigation privilege [BD-
4A.F1D26859284] with attachment
POL-0021280
180.
POL00025167
Email from Rodric Williams to Andrew Parsons,
Mark R Davies, Angela Van Den Bogerd and
POL-0021646
Page 128 of 132
WITNO9900100
WITNO9900100
others RE: Remote access wording - subject to
litigation privilege [BD-4A.FID26859284]
181.
POL00041259
Email from Andrew Parsons to Jane MacLeod
and others, re Letter of Response (Final Form)
POL-0037741
182.
POL00041260
Draft Letter of Response to Freeths LLP from
Bond Dickinson LLP re Bates & Others v Post
Office Limited
POL-0037742
183.
POL00024650
Email from Mark Underwood, Jane MacLeod,
Angela Van-Den-Bogerd, and others re: PLSG
meeting on Wednesday 24 May 2017
@15:00pm in Tonbridge (1.11).
POL-0021129
184.
POL00003340
Letter from Andrew Parsons to James Hartley,
re: Bates & Others -v- Post Office Limited -
Generic Defence and Counterclaim
V1IS00004354
185.
POL00024653
Post Office Group Litigation Steering Group
Meeting decision document: Should Post Office
bring counterclaims against the Claimant?
POL-0021132
186.
POL00028070
Deloitte's ‘Bramble’ Draft Report
POL-0023073
187.
POL00139480
Email from Mark Underwood to Jane MacLeod,
Angela Van-Den-Bogerd, and others re: PLSG
meeting on Wednesday 24 May 2017 @12 in
Tonbridge (1.11)
POL-BSFF-0001611
188.
POL00139486
Noting paper by Womble Bond Dickinson
regarding Deloitte reports
POL-BSFF-0001617
189.
POLO0006764
Meeting Minutes of the Postmaster Litigation
Subcommittee of POL
POL-0018022
190.
POL00003414
Letter from James Hartley to Andrew Parsons
RE: Bates & Others v Post Office Limited -
Group Action, Claim Number: HQ16X01238 ,
Inspection of Known Error Logs
VIS00004428
191.
POL00000444
4th Witness Statement of Andrew Paul Parsons
(Womble Bond Dickinson), Solicitor to POL
V1IS00001458
192.
POL00003386
Letter from Freeths LLP to Womble Bond
Dickinson (UK) LLP,HE POST OFFICE GROUP
LITIGATION DEFENDANT'S DISCLOSURE -
THE PEAK SYSTEM
V1IS00004400
193.
POL00006431
Noting paper - Update on Litigation Strategy
POL-0017736
194.
POL00003363
Letter from Andrew Parsons to James Hartley
and Imogen Randall re: Post Office Group
Litigation - Horizon Issues Trial: Expert Reports
V1IS00004377
Page 129 of 132
WITNO9900100
WITNO9900100
195,
POL00253924
In the High Court of Justice Queen's Bench
Division of Royal Courts of Justice between
Alan Bates & others v/s POL regarding Identity
proof of Angela's Middle name
POL-BSFF-0091987
196.
POL00006674
Proof of Evidence of Angela Van Den Bogerd
(from interview dated 12 Jan 2018 signed 22
May 18)
POL-0017932
197.
POL00024270
Postmaster Litigation Advisory Board
Subcommittee
POL-0020749
198.
POL00006763
Meeting Minutes of the Postmaster Litigation
Subcommittee of POL
POL-0018021
199.
POL00167503
Angela Margaret Van Den Bogerd's draft
Witness Statement in Alan Bates and others v
POL (unsigned)
POL-0162800
200.
POLO00111032
Alan Bates and Others and Post Office Limited,
draft witness statement of Angela Margret Van
Den Bogerd
POL-0108638
201.
POLO00111043
Alan Bates and others and Post Office Limited,
draft witness statement of Angela Van Den
Bogerd
POL-0108649
202.
POL00041956
Witness Statement of Angela Margaret van den
Bogerd in PO Group Litigation
POL-0038438
203.
POL00041955
Email from Angela van den Bogerd to Andrew
Parsons and others re Witness Statement in
PO Group Litigation
POL-0038437
204.
POLO0111071
Alan Bates and Others v Post Office Limited -
Draft witness statement of Angela Van Den
Bogerd
POL-0108677
205.
POL00111070
Alan Bates and Others and Post Office Limited,
draft witness statement of Angela Margaret Van
Den Bogerd
POL-0108676
206.
POL00041992
Witness Statement of Angela Margaret Van
Den Bogerd
POL-0038474
207.
POL00003777
The Post Office Group Litigation - First Witness
Statement of Angela Margaret Van Den Bogerd
V1IS00004791
208.
POL00042007
Email from Andrew Parsons to Sarah Rimmer,
Helen Dickinson, David Longbottom and Others
re Post Office Group Litigation Trial - Privileged
POL-0038489
209.
POL00006757
Meeting Minutes of the Postmaster Litigation
Subcommittee of POL
POL-0018015
Page 130 of 132
WITNO9900100
WITNO9900100
210.
POLO00111236
Alan Bates & Others and Post Office Limited,
draft witness statement of Angela Margaret Van
Den Bogerd
POL-0108837
211.
POL00154333
Email from Mark Underwood’ to Jane
MacLeod, Julie Thompson, Mark Raymond and
others Re: Postmaster Group Litigation -
support from members of your team during
october and november
POL-BSFF-0013432
212.
POL00042065
Email from Jane MacLeod to Angela Van Den
Bogerd and others re PO Group Litigation
POL-0038547
213.
POLO0111241
Draft witness statement of Angela Margaret
Van Den Bogerd - re Alan Bates & Others v
Post Office Limited
POL-0108842
214.
POL00258255
Email conversation between Mark Underwood
and Sarah Rimmer, Michael Haworth, Michael
Shields, Mike Webb, Pal F Williams, Brian
Trotter, Helen Dickinson, LongBottom, John
Breeden, Andrew Carpenter, Nick Beal, Tim
Dance, Angela Van Den Bogerd, Elaine Ridge
RE: Postmaster Litigation Trial - Feedback from
Training & Logistical Information: Private &
Confidential - Subject to Legal Privilege.
Confidential
POL-BSFF-0096318
215.
POL00258256
Report on Common Issues Trial Briefing for
POL witnesses regarding background to the
litigation and Key issues at trial in November
POL-BSFF-0096319
216.
POL00154361
Email from Mandy Robertson to Angela Van
Den Bogerd, cc'ing Mark Underwood and Dave
Panaech re: Group Action, Bond Solomon
witness familiarisation feedback
POL-BSFF-0013460
217.
POL00154364
Email chain from Dave Panaech to Angela Van-
Den-Bogerd cc Beth Hooper re Group Action:
steps post witness familiarisation training
[WBDUK-AC.FID26896945]
POL-BSFF-0013463
218.
POL00154362
Assessment Criteria in the Witness Box with
handwritten answers - Angela Van Den Bogerd
POL-BSFF-0013461
219.
POL00136336
Email from Angela Van-Den Bogerd to Andrew
Parsons, Dave Panaech, CC'ing: Rodric
Williams and others - Re: Urgent Query Dispute
Process 2007-2009 [WBDUK-AC.FID26896945]
POL-0140789
Page 131 of 132
WITNO9900100
WITNO9900100
220.
POL00042132
Email chain from Angela Van-Den-Bogerd to
Dave Panaech, Andrew Parsons, Amy Prime
and others re: Urgent Query Dispute Process
2007-2009
POL-0038614
221.
POL00006442
Steering Group Paper - Peak Disclosure
POL-0017747
222.
POL00000679
Second witness statement of Angela Margaret
Van Den Bogerd
VIS00001693
223.
POL00042226
Email from Andrew Parsons to Rodric Williams,
Mark Underwood, Katie Simmonds and others
re: Supplemental expert report - privileged
[WBDUK-AC.F1ID27032497]
POL-0038708
224.
POL00042278
Email from Andrew Parsons to Angela Van-
Den-Bogerd, Jonathan Gribben, Katie
Simmonds and others re: 22 Bugs [WBDUK-
AC.F1ID27032497]
POL-0038760
225.
POLO0111660
Email from Angela Van-Den-Bogerd to Katie
Simmonds re. Angela Burke
POL-0109237
226.
POL00024147
Email chain between Rodric Williams, Jane
MacLeod, Andrew Parsons and others Re:
Litigation briefing
POL-0020626
227.
POL00006753
Meeting Minutes of the Group Litigation
Subcommittee of POL
POL-0018011
228.
POL00000688
Alan Bates & others and Post Office Limited
Corrections to Defendant's Witness Statements
VIS00001702
229.
POL00155095
Email from Angela Van-Den-Bogerd to Ben
Foat re: Legally Privileged - Postmaster
Litigation Steering Group Meeting
POL-BSFF-0014192
230.
POLO0111877
Amended Second Witness Statement of Angela
Van-Den-Bogerd
POL-0109448
Page 132 of 132