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WITNESS NAME: KEITH GILCHRIST
STATEMENT NO: WITN10490100
DATED: 22 DECEMBER 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF KEITH GILCHRIST
I, Keith Gilchrist, will say as follows
Introduction
1. I ama former employee of the Post Office Limited and I worked within the
business for around 3 years between June 2010 and June 2013. During this
time I held the following positions: Security Manager and Team Leader.
2. This witness statement is made to assist the Post Office Horizon Inquiry (the
“Inquiry") with the matters set out in the Rule 9 Request dated 2 November
2023 (the "Request"). In order to produce this statement I have received
legal assistance from Ashfords LLP. When seeking their assistance, I was
assisted by the Post Office in the initial stage of confirming availability of
insurance coverage, in order to cover the associated legal costs.
3. What I include in this statement is to the best of my recollection.
Nevertheless, the Request relates to matters that occurred over 10 years
ago, so there have been times where I have found it difficult to recall precise
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details and I have had to defer to the accompanying documents enclosed to
me. I have indicated clearly where this is the case.
Background
4. Atsome point in the first quarter of 2010 I applied externally for a part time
role in the Post Office Limited. I recall the role being advertised as a part-time
Security Manager, to look after the security of Northern Ireland Post Office
cash in transit operations. I attended an interview conducted by Dave Pardoe
and Lesley Frankland and by the time my vetting was completed I was
offered a full time role as a Physical Security Manager for Northern Ireland. I
accepted the job and started in June 2010.
5. My role of Security Manger entailed physical security of the Post Office. I was
responsible for implementing security measures for the business in its cash in
transit operations, its property, for its people and its assets. I was based in
Belfast but after several months in post I was asked to cover the Northern
parts of the UK, again from a physical security perspective only.
6. To the best of my recollection, there were three occasions where I carried out
a role which did not relate to physical security. These are the three
occasions where I attended interviews under caution as a second officer
carried out as part of an investigation - I deal with this in more detail in
paragraph 14 below.
7. During my time as a Security Manager I also delivered training to sub
postmasters and other post office staff on security and risk management. I
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have a Masters in Security and Risk Management, which I obtained from
Leicester University in 2003.
8. When in my post as Security Manager I reported to my Team Leader, Lesley
Frankland , who was based in Manchester. I recall that Lesley reported up to
Dave Pardoe who was Senior Management within the Security Team and
Dave Pardoe reported up to John Scott, who was the Post Office Head of
Security.
9. Atsome point in early 2012 my Team Leader, Lesley Frankland, transferred
to a different Post Office position outside of the Security Team. This may
have been around April 2012 but I cannot recall for certain. At this time I was
asked by Andy Hayward to temporarily step into a Team Leader position,
where I would report to the following line managers: Andy Hayward, Rob King
and Dave Pardoe. I primarily reported to Andy Hayward but I was also
involved in a project where I reported to Rob King. This was project
Grapevine, which I comment briefly upon in paragraph 20 below. If both Andy
and Rob were off on leave I would report to Dave Pardoe. I believe this
temporary Team Leader position was intended to last for a few months,
during which there was an application process within the Security Team to fill
the role permanently. I was successful in obtaining the role on a permanent
basis, but I cannot remember if others applied or if I was just the most
appropriate person for the job at that time. I cannot recall the exact date that I
was appointed in to the role permanently, but I believe this was around the
summer months in 2012.
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10.1 note that on documentation I have received from the Inquiry my role is
referred to as a ‘Fraud Team Manager.’ I always referred to myself as a
Team Leader, but for the avoidance of doubt, I believe that ‘Team Leader’
and ‘Fraud Team Manger’ mean the same thing. Simon Hutchinson (who
was based in Northern Ireland) was recruited into the Security Manger
position that I had vacated, to deal with physical security.
4
.When in my Team Leader position, the following regional Security Mangers
reported to me: Kevin Ryan (Greater Manchester) Michael Stanway (North
England), Andrew Wise, (Midlands) Steve Bradshaw, (Liverpool, Cheshire
and North Wales), Suzanne Winters (Northern Ireland) and Robert Daley
(Scotland). At this time my recollection was that these Security Managers
were primarily engaged in Post Office investigations, with the exception of
Kevin Ryan who I think also did physical security.
12.From the outset I made clear to Andy Hayward that I would only agree to step
into a Team Leader role on the proviso that I would not have to provide any
in-depth investigation supervision to Security Managers unless I was properly
trained on the processes and procedures followed by the Post Office in
relation to investigations and the in-depth workings of a Post Office. I never
received extensive training on these processes and procedures so my role as
a Team Leader was to help manage the Security Managers mentioned in
paragraph 11 above, in terms of logistical and administrative matters
including carrying out team meetings to discuss workloads and progress. For
example, I would look at how many cases they had on to see if workloads
were manageable and I would check who would be best placed to attend
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interviews as a second officer based on everyone’s workloads and the
location of the interview. I would also conduct one to one meetings on
performance. I would also approve holiday leave and carry out other general
administration. By the time I left the Post Office in June 2013, I do not believe
I had provided supervision to any Security Mangers in my Team as to the
substance of the investigations they carried out. As far as I can recall the
arrangement was that Andrew Daley would provide this supervision, who was
a Team Leader in Case Management. I deal with this in more detail below
within the section of my statement headed ‘The Security Team’s role in
relation to criminal investigations’.
13.During my time in the roles of both Security Manager and Team Leader, I do
not believe I had any department or sub-postmaster disciplinary matters to
address. I also never had any involvement in litigation case strategy or
disclosure in criminal or civil proceedings.
14.1 was not involved in the conduct of criminal investigations in general, apart
from on three occasions where I sat in on interviews under caution with Sub
Postmasters as a second officer; one in Scotland and two in Northern Ireland.
I have no recollection of the Sub Postmasters interviewed on these
occasions, except to say they were in relation to Post Offices in Strabane,
Belfast and Glasgow. I believe that the reason I would have attended the
interviews in Northern Ireland was due to my location, and the interview in
Glasgow due to the unavailability of any other investigator to assist. My
involvement in these interviews was to assist with setting up the room and
taking the taped recording. I do not believe I asked the interviewee any
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questions and I played no further role in these investigations beyond sitting
as a second officer in the interviews.
15.1 do not recall ever liaising with other Post Office departments in respect of
the progress of any investigations in both my time as a Security Manager and
a Team Leader.
16. Throughout my time as a Security Manager and Team Leader I received no
extensive training on the operational practices and procedures of the Post
Office Security Team, in relation to both physical security and investigations. I
did receive a week’s worth of brief training on the Police and Criminal
Evidence Act (PACE) and other matters relating to investigations at some
point towards the end of 2012, but I cannot recall exactly when. I comment
further on this training under the heading ‘Training, instructions and guidance
to investigators within the Security team’ below.
The Security Team’s role in relation to criminal investigations
17.1 confirm that I have considered the following documents:
i. Casework Management Policy (version 1.0, March 2000)
[POL00104747] and (version 4.0, October 2002) [POL00104777];
ii. Rules and Standards Policy (version 2.0, October 2000)
[POL00104754);
iii. “Investigation Procedures Policy (version 2.0, January 2001)
[POL00030687];
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vi.
vii.
viii.
xi.
xii.
xiii.
Disclosure Of Unused Material, Criminal Procedures and Investigations
Act 1996 Codes of Practice Policy (version 1.0, May 2001)
[POL00104762);
“Security Managers’ Guide to the Prosecution Support Office” (May
2001) [POL00121455);
“Royal Mail Group Security — Procedures & Standards — Arrest
Procedures” (Version 2.0, May 2001) [POL00104760];
Appendix 3 of Investigation Policy “Notes of Interview — Northern
Ireland” (Version 5.0, November 2002) [POL00039952];
“Royal Mail Group Security — Procedures & Standards — Searching”
(September 2006) [POL00094163]
Police and Criminal Evidence (Northern Ireland) Order 1989 (1 March
2007) [POL00121591];
"Royal Mail Group Ltd Criminal Investigation and Prosecution Policy" (1
December 2007) [POL00030578], which appears to be substantially
the same as the policy of the same date with a variation on the title at
[POL00104812]
"Royal Mail Group Security - Procedures & Standards - Standards of
Behaviour and Complaints Procedure" (version 2, October 2007)
[POL00104806);
“Royal Mail Group - An Inspection of the Royal Mail Group Crime
Investigations Function” (July 2008) [POL00121607];
"Royal Mail Group Crime and Investigation Policy" (version 1.1,
October 2009)
[POL00031003);
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xiv.
XV.
xvi.
xvii.
xviii.
xix.
XX.
xxi.
xxii.
xxiii.
"Post Office Ltd - Security Policy - Fraud Investigation and Prosecution
Policy" (version 2, 4 April 2010) [POL00030580];
"Post Office Ltd Financial Investigation Policy" (4 May 2010)
[POL00030579];
"Royal Mail Group Security - Procedures & Standards - The Proceeds
of Crime Act 2002 & Financial Investigations" (version 1, September
2010) [POL00026573];
"Royal Mail Group Security - Procedures & Standards - Initiating
Investigations" (September 2010) [POL00104857];
"Royal Mail Group Ltd Criminal Investigation and Prosecution Policy"
(version 1.1, November 2010) [POL00031008});
Post Office Ltd Financial Investigation Policy (version 2, February
2011) [POL00104853);
Post Office Ltd Anti-Fraud Policy (February 2011) [POL00104855];
"Royal Mail Group Policy Crime and Investigation S2" (version 3.0,
April 2011) [POL00030786); -
“Royal Mail Internal Information Criminal Investigation Team- Casefile
Construction England, Wales and Northern Ireland” (Version 1.0, June
2011) [POL00104877].
“Royal Mail Internal Information Criminal Investigation Team -
Appendix 1 to 8.2 Suspect Offender Reports, Preamble Guide,
England, Wales and Northern Ireland” (Version 1.0, June 2011)
[POL00104879);
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XXiVv.
XXV.
XXvi.
xxvii.
xxviii.
XXix.
XXX.
XXxi.
XXxxii.
Xxxiii.
XXxiV.
XXXV.
“Royal Mail Internal Information Criminal Investigation Team — 8.2
Guide to the preparation of suspect offender reports, England, Wales
and Northern Ireland” (Version 1.0, June 2011) [POL00104881];
“Royal Mail Internal Information - Casework Management and PSO
Products and Services” (Version 1.0, June 2011) [POL00104888];
“Post Office Prosecution Policy” (version 1.0, 1 April 2012)
[POL00031034];
“Post Office Ltd PNC Security Operating Procedures” (August 2012)
[POL00105229):
"Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement (with flowchart)", (October 2012) [POL00104929];
"Undated Appendix 1 - POL Criminal Investigations and Enforcement
Procedure (flowchart)", (October 2012) [POL00105226];
The undated document entitled “POL — Enforcement & Prosecution
Policy” [POL00104968];
"Post Office Limited: Criminal Enforcement and Prosecution Policy"
(undated) [POL00030602];
"Conduct of Criminal Investigations Policy" (version 0.2, 29 August
2013) [POL00031005]:
“Post Office Prosecution Policy England and Wales” (1 November
2013) [POL00030686]
"Conduct of Criminal Investigations Policy" (version 3, 10 February
2014) [POL00027863]);
"Conduct of Criminal Investigations Policy" (September 2018)
[POL00030902].
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18.1 would like to make the Inquiry aware that a lot of the documents listed in
paragraph 17 above were created before I started the working at the Post
Office in June 2010, and I cannot recall ever seeing them. There are also
documents in this list that are dated after I left in June 2013. Again, I do not
recall ever seeing these. For those documents that were created within the
time I worked at the Post Office, it is likely I would have received them if they
were circulated to the Security Team, but I am unable now to recall when or if
I was aware of them at the time.
19.In terms of the organisational structure of the Post Office Security Team, I
recall that there were various sub-departments within it, all reporting
ultimately to John Scott, Head of Security. I believe that Dave Pardoe was
senior management responsible for the criminal investigations and physical
security side of the Post Office Security Team. I believe that John Bigley was
senior management responsible for policy and strategy within the Security
Team, with strategic and policy support also being provided by Dave Posnett
and Graham Ward to John Scott, Dave Pardoe and John Bigley.
20.1 also recall that there were North and South UK regional Mangers, Andy
Hayward and Rob King, who would report to Dave Pardoe. I cannot recall
everything that Andy and Rob were responsible for, but I was aware that they
looked after physical security and they worked on the introduction of
Grapevine, which was a system based on a national intelligence model by
which the Post Office could be briefed on crime in their area. I believe that
Andy Hayward also had day to day supervision of the 3 regional security
teams (the make-up of which I set out in paragraph 23 below) and was more
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hands on with looking after the investigations side of the Post Office Security
Team.
21.1 also recall that there were specific members who were responsible for
training within the Security Team. This was Paul Southin and Paul Whitaker
and I think they reported to John Bigley.
22. There was also a Case Management sub-department within the Security
Team, which consisted of Jane Banbury, Jane Owen and Andrew Daley as
their Team Leader. The role of Case Management was to assign case
management arrangements and assist with managing and responding to
communications between the Security Team and the Post Office Legal
department. They did this on behalf of the Security Team, removing
significant administration obligations from Security Managers and the Team
Leaders. As far as I can recall, the Case Management sub-department
always existed when I worked within the Security Team. I do not know if there
was a point before I joined where that department did not exist.
23.From my recollection, when I was a Team Leader the investigations side of
the Security Team were split into the following three regional areas:
i. South UK, where the Team Leader was originally Jason Collins and
latterly Darrell Kennedy and he had 6 to 8 security managers reporting
to him;
ii. Mid UK, where the Team Leader was Helen Dickinson and she had 6
to 8 security managers reporting to her; and
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iii. I North UK (including Scotland and Northern Ireland) where the Team
leader was myself and I had the 7 security managers previously
outlined in this witness statement reporting to me.
24.1 would like to flag to the Inquiry that when I was a Team Leader in the
Security Team, Andrew Daley (Team Leader in Case Management) reviewed
the content of the North Region criminal investigation files on my behalf due
to my lack of experience and knowledge of Post Office procedures and
processes relating to criminal investigations and Horizon. He also assisted
with providing supervision in investigations for the North UK Team. I believe
Andy Hayward also provided supervision to the Security Managers in my
team on occasion. As mentioned earlier in this statement, my experience as
a Security Manager prior to me becoming a Team Leader only related to
physical security and when I became a Team Leader I only really dealt with
logistical and administration matters for my team.
25. The only other sub-department I recall is the Financial Investigation Unit who
I believe were involved in recovering financial losses faced by the Post
Office. I do not believe I had any involvement or interaction with that team so
lam unable to comment on their specific roles.
26. I confirm that I have reviewed the following: [POL00122075],
[POL00122078], [POL00122170], [POL00122037], [POL00118289],
[POL00118377], [POL00118290] and [POL00122103]. I can see that
[POL00118290], [POL00118377] and [POL00118289] is email
correspondence from 18.12.2012 relating to the renaming of Post Office
investigating and reporting documents. I believe I am simply copied in to this
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correspondence due to my role as Team Leader. It appears to be ‘catch all’
correspondence and I do not believe that I had any involvement in renaming
or carrying out any review of the documents. I can see from the emails that it
was Suzanne and Robert who were requested to review the Northern Ireland
and Scotland forms referred to within this correspondence.
27.1 can see that the email from me to Andy Hayward dated 06.02.2013 in the
chain at [POL00122103] relates to the identification of a legal firm in Northern
Ireland to assist and represent the Post Office in criminal investigations and
prosecutions in Northern Ireland. McCarten Turkington and Breen was the
firm who entered into discussions with Post Office but I do not think this was
formalised prior to my departure from the Post Office in June 2013. I believe
the rationale for this was that historically the Police Service of Northern
Ireland (PSNI) assisted the Post Office by accepting their investigation files at
their Central Processing Office where I believe they conducted a check of the
papers and then electronically submitted them to the Director of Public
Prosecutions. I believe the Security Managers working on cases in Northern
Ireland would have sent their investigation file to the PSNI directly, perhaps
with the assistance or on advice from Case Management. Due to reducing
numbers of police officers and budget strains the PSNI were reviewing all
services provided and this was one under threat of termination. If the police
were not going to assist in this way, the Post Office would need other
external assistance with checking the papers and sending files to the Director
of Public Prosecutions. I do not know how these discussions progressed
following my departure.
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28.1 have no recollection of the emails at [PO 00122078] dated 05.02.2013 and
at [POL00122170] dated 11.03.2013, nor of the meeting mentioned within by
Andy Hayward. I could have attended this meeting but I do not remember if I
did. It looks like it related to having a final review meeting to make sure all
amendments to the Post Office policy had been addressed. I cannot recall if I
had any direct involvement in the formulation or amendment of this policy,
apart from the submission of opinions and ideas to Andy Wise via email, as
mentioned directly below.
29.1 can see that the email dated 03.01.2013 at [POL00122037] is an email from
me to Andrew Wise, who with Rob King was reviewing the Post Office
investigation polices for the Security Team. I note that I am seeking
clarification as to why we were required to report discipline matters to a
contract manager prior to court proceedings. I do not believe that this is me
playing a part in managing and or developing the procedure around this. To
the best of my recollection I was providing my opinion on the required course
of action and it is clear from this email that I believed it was nonsensical and
unnecessary. I believe the rationale I had for sending this email was that I
thought that allowing discipline matters to be progressed beyond a
suspension prior to the outcome of a criminal matter would be unfair on the
person subject to an investigation. I also thought it could potentially interfere
with the criminal investigation and any potential proceedings, as the discipline
reports were available to the Sub postmaster prior to the completion of the
investigation. I would like to emphasise that this email was not an attempt by
me to prohibit appropriate disclosure at interview stage, on completion of an
investigation or subsequently at court. I just did not think it was appropriate to
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be sharing the details of a criminal investigation with anyone outside of the
Security Team, beyond advising interested Post Office departments that a
criminal matter was being investigated and that any subsequent proceedings
were pending or yet to be decided. I believe that any further discipline
procedures beyond a suspension should only have been implemented
following the ultimate outcome of a prosecution and whatever those further
discipline procedures were should have been picked up by the Contract
Manager then.
30.1 believe that the following legislation, policies and / or guidance governed the
conduct of investigations conducted by the Security Team during the period I
worked within it:
i. Police and Criminal Evidence Act 1989;
ii. Theft Act 1968;
iii. I Police and Criminal Evidence (Northern Ireland) Order 1989
[POL00121591]:
iv. Post Office Prosecution Policy 2012 [POL0031034]; and
v. Post Office Ltd PNC Security Operating Procedures [POL00105229].
31.1 believe elements of the legislation and policies outlined above may have
been covered in the week’s training course I received in late 2012 on PACE
and investigations in general, which I deal with later in this statement. I know
that there is likely to be other legislation, policies and guidance that governed
the conduct of investigations conducted by the Security Team, but I am not
aware of what these are. As stated above, I did not really get involved in the
substance of criminal investigations.
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32. The only difference I was aware of between the policies and legislation
governing investigations conducted by the Post Office Security Team in
England and Wales and Northern Ireland was the submission of investigation
files in Northern Ireland to the Police Service in that jurisdiction. The Northern
Ireland Police Service would then put the matter onto their electronic case file
system and would then forward the file to the Director of Public Prosecutions
to obtain a decision on whether to pursue a prosecution. There was a similar
process in Scotland via the Procurator Fiscal. As far as I can recall, it was the
Post Office Security leaders, John Scott and Dave Pardoe who made the
decision to prosecute for England and Wales in consultation with the Post
Office Legal department. They may also have had some role for Scotland
and N. Ireland but I am unaware of that process if they did.
33.1 cannot recall there being any impact of the separation of the Post Office
from Royal Mail in relation to the way investigations were conducted within
the Post Office. I had only been employed for 6 months by the time the split
occurred and I was not involved in investigations at all.
34.1 do not know what the process was to deal with any complaints raised
against the Post Office Security Team in relation to the conduct of an
investigation. As far as I can recall I never received or dealt with any
complaints to this regard.
35.In terms of the supervision provided to Security Managers, each Security
Manager had a Team Leader who they could go to in relation to any queries
on their cases or in relation to any other day to day issues. In turn, Team
Leaders had line managers who they could contact if they needed assistance
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or guidance with the supervision they were providing to Security Mangers.
There was also the Post Office Legal Team who could provide professional
assistance and guidance to Security Managers and Team Leaders in relation
to investigations upon request, but I am not sure what sort of requests these
would have been. I presume, for example, it could have related to what other
evidence was needed in a case. I believe that these were the supervision
arrangements in place for Security Managers in all regions, however, as
explained above it was slightly different for my team as whilst I was the Team
Leader for the North UK region, I did not provide supervision on the
substance of investigations to the Security Managers within that team. I only
dealt with logistical and administrative matters, but the arrangement was that
the Security Mangers within my team could go to Andrew Daley or Andy
Hayward for support and supervision on their files.
36.1 have no experience or recollection of any difference in policy and practice
regarding the investigation and prosecution of Crown Office employees in
comparison with the investigation and prosecution of SPMs and/or their
assistants.
Audit and investigation
37.1 confirm that I have considered the document “Condensed Guide for Audit
Attendance” (version 2, October 2008) [POL00104821]. I would like to flag to
the Inquiry that I was never an auditor in the Post Office, and I have no
recollection of ever attending an audit during my time as a Security Manager
and a Team Leader. From review of the documents provided to me I believe
that the circumstances in which a Security Manager would attend an audit
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would be where there was a suspected crime after a cash shortage or
potential fraud was discovered by the audit team. Reflecting on my time as a
Team Leader, I do not think it would have been logistically possible for the
Security Managers in my team to always attend an audit on the day, as they
covered a very wide area within the UK.
38. As already alluded to above, I was not heavily involved in the substance of
investigations in general, so I am unable to set out all the steps that would
have been taken by the Security Manager when attending an audit.
However, I would have assumed that where they did attend their role would
be to search for and seize appropriate evidence of any potential criminal
wrong doing. I believe that they would have had to treat anything seized as
an exhibit and would have labelled and secured it for future reference in an
interview, and to be included in their investigation files. I think this evidence
could have been receipts and stock books and information from the auditors,
but I am not sure of this for certain. I was not aware that this also would have
included printouts obtained on the day by the auditors from the Horizon
system - I learned this recently from following other evidence provided in the
Inquiry. I would assume that upon having a suspicion of a criminal offence
having been committed by the SPM, deputy or staff, the Security Manager in
attendance at the audit would also have the responsibility to caution those
who were suspected before they could proceed to ask any further questions.
I believe that Security Managers may have also requested to search home
addresses if considered appropriate and with the property owners
permission.
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39.As far as I am aware, following an audit and a shortfall being found, the
Auditors would report their findings to Case Management or directly to the
Team Leader or one of the Security Managers for that area and I believe a
case would then be commenced. Whether that commencement into an
investigation was approved by the Security Manager's Team Leader or
Regional or Senior Manager in consultation with Case Management I cannot
recall. Being a Team Leader, I may well have got phone calls from Auditors
to say they believed there was a short fall at a branch, but if I did I believe I
would have reported this to Case Management to allocate it out to a
respective Security Manager to investigate. I think I only ever allocated a
case out to Security Mangers directly on one occasion. This was the case
involving the Whitehaven branch.
40.As far as I can recall I was never involved in debt recovery and have no
knowledge of how and when instances would be referred to there.
41.From my recollection, the Contract Manager took a decision whether to
suspend the SPM when an investigation had been raised, but they had no
input into the decision as to whether to commence a criminal investigation.
42.1 believe that the trigger for commencing an investigation was an
‘unexplained loss’, but I do not recall a specific figure that would trigger this.
There was no change to this during my time with the Post Office as far as I
can recall.
43.1 have considered section 7 of [POL00085977]. Unfortunately I have no
knowledge of the differences between the audit process between Northern
Ireland and England and Wales.
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Decisions about prosecution and criminal enforcement proceedings
44. In England and Wales, I was under the impression that decisions on whether
to prosecute any SPM or Post Office employee were taken by senior
management in the Post Office (for example, John Scott and Dave Pardoe) in
full consultation with the Post Office Legal department. From recollection I
was never involved in the decision making process and I am unaware of the
criteria they used when deciding on whether to prosecute. In Northern Ireland
I believe that the decision to prosecute was ultimately taken by the Director of
Public Prosecutions. In Scotland, prosecutorial decisions were ultimately
taken by the Procurator Fiscal. Northern Ireland and Scottish case files may
well have been marked from a compliance standpoint and potentially
reviewed by Dave Pardoe first, but I do not know for certain. I have no
recollection of these processes changing during my time at the Post Office.
45.1 have considered paragraphs 4.3 and 4.4 of [POL00031034]. I have no
recollection of any disagreement arising in relation to investigations and
prosecutions between Post Office and prosecutorial authorities. During my
time with the Post Office I do not recall experiencing any variance from the
prosecution policies put in place by the Post Office in any part of the UK.
46.1 do not have any knowledge of the circumstances in which steps were taken
to restrain a suspect's assets by criminal enforcement methods such as
confiscation proceedings. I believe this was dealt with by the Financial
Investigation Unit, and I do not recall having any involvement in their work,
nor do I know who decided whether criminal enforcement proceedings should
be pursued and what factors were considered when deciding this.
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Training, instructions and quidance to investigators within the Security team
47.As mentioned earlier in this statement, my only experience of training during
my time with the Post Office was a one week course towards the end of 2012
which covered PACE and other matters relating to investigations. I believe it
was Paul Southin and Graham Ward who delivered this training to me
internally and it formed the first part of my induction when appointed
permanently into my Team Leader role. I was then meant to receive further
training on the workings of a Post Office and the relevant Post Office policies
and procedures relating to investigations, but this never occurred. I recall that
the week’s training course covered elements of PACE, taped interviewing,
the taking of witness statements, the caution, seizing and recording of
exhibits, giving evidence in court and possibly the definition of theft. I
remember that obtaining corroborating evidence where required was also
part of the training course, but I do not remember this covering obtaining
evidence from Fujitsu. I think it was more focussed upon obtaining evidence
from other witnesses such as other employees at the branch.
48.1 am unable to recall if the training included anything on investigating a case
‘fully’, but I imagine that emphasis would have been placed on the
responsibility to make sure that all lines of Inquiry were identified, followed
and further investigated where necessary.
49.1 believe that the Post Office did train and advise staff on their disclosure
responsibilities, but I cannot recall if I received this training during the week’s
training course. I believe that training on disclosure may have been provided
by circulation of explanatory training material or training conducted by the law
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firm Cartwright King. If it was delivered by Cartwright King, I do not think I
attended. I only ever recall going to their offices once and I think it was for a
Christmas networking event. I do vaguely remember discussions being held
on disclosure in internal meetings on the need for material to be fully
disclosed whether it is positive or negative in a case. I remember that items
could be put on sensitive schedules, but I cannot recall what evidence this
was specifically. I think it may have related to whistleblowing type evidence.
Unfortunately I cannot remember when this was or who conducted these
discussions. What I do recall is that I was never responsible for obtaining
disclosure in any investigation and I never completed or reviewed any
disclosure schedules in my role as a Security Manager or Team Leader.
50.1 can recall circulars and/or directions being disseminated within the Security
51.
Team on file preparation, structure and guides on what needed to be
included in a prosecution file, but I cannot recall when this was. I would not
have been required to consider any criminal investigation document prior to
my appointment as Team Leader. Any that I did receive when I was Team
leader I would have disseminated to the Security Managers within my team
and would have discussed them, if necessary, at team meetings. I would
have also raised issues on my line manager's behalf, had that been
necessary for clarification purposes.
I have considered [POL00121467], [POL00121485], [POL00129311],
[POL00158977] and [POL00158978]. Prior to receiving the request, I do not
recall ever seeing [POL00121467] and [POL00121485] previously. In terms
of [POL00129311], I can see I was invited to attend a Cartwright King training
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session, but I do not recall attending. By the 11 June 2013 I would have had
handed in my notice of resignation and I doubt I would have travelled for
training that would not have been of any future use or relevance to me.
52.With reference to the email at [POL00158977] and the attached document at
[POL00158978] I have no recollection of receiving both of these emails. It
seems to have been a ‘catch all’ communication email within the Security
Team, at which time I was merely involved in physical security and would
have most likely disregarded the content as it would not have been relevant
to my role.
53.1 have considered David Posnett’s email to me and others dated 23 May
2011 at [POL00118096] and the documents contained within the attached
compliance zip file at [POL00118108], [POL00118109], [POL00118101],
[POL00118102], [POL00118103], [POL00118104], [POL00118105],
[POL00118106] and [POL00118107]. I do not recall the email at
[POL00118096], nor do I recall the conference call on 26 May 2011 for the
North Security Team that the email refers to. I was at this time only dealing
with physical security and if this call was not relevant to my role it is likely I
would not have attended. As I was only doing physical security and this
related to the compliance of investigations, I believe it is likely I would have
disregarded the email altogether.
54.1 am aware of the form contained at [POL00118108] existing as I knew that
the Security Managers had their casefiles scored from a compliance
standpoint. The scoring may have been used in one to one performance
reviews but I cannot fully recall. I had seen some of these later in my career
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with the Post Office as Team Leader, but from my recollection I do not
believe I ever marked a Security Manager's file. I remember on one occasion
I challenged a mark received by, Steve Bradshaw on the compliance of one
of his files. He would have informed me about it as I was his Team Leader. I
cannot remember the specific details of that file, but I remember feeling that
the mark was unfair.
55.1 confirm I have considered [POL00118109], [POL00118101],
[POL00118102], [POL00118103], [POL00118104], [POL00118105]. I cannot
recall if I ever received these documents. I was aware of the systems
revolving around putting together a case file, but not in any detail.
56.1 do not recall ever seeing [POL00118106]. From my recollection I did not
ever maintain a notebook in my role as a physical Security Manager or as
Team Leader, although, I could have been provided with one. I believe that I
may have signed the Security Managers’ notebooks for the three interviews I
sat in on as a second officer (mentioned in paragraph 14 above).
57.1 have considered the Casework Management document from 2000 at
[POL00104747] and the 2002 Casework Management document at
[POL00104777], including the sections relevant to Northern Ireland. I do not
recall seeing these documents previously. I have reviewed the second, third
and fourth bullet points on page 2 of the 2000 version but as I do not think I
ever saw this document, I am unable to say what I would have understood
the guidance given within these bullet points to mean at the time.
58.1 have also reviewed the first, second and third bullet points on page 2 of the
2002 version. I cannot remember seeing this document but later when I
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became a Team Leader I must have considered the particular guidance
which was in force at the time and understood it to mean that discipline
matters were to be sent to a contract manager prior to court proceedings
being commenced. As dealt with in paragraph 29 above, I did not agree with
this process and I raised my concerns in the email dated 03.01.2013 at
[POL00122037] to Andrew Wise.
59.1 am unsure of the circumstances in which investigations became subject to
compliance checks, their purpose, the process for those checks being
conducted and who conducted them. I believe that it is likely that compliance
checks were required to ensure consistency over case files and to identify if
any extra training was needed in certain areas.
60. I do not know what the status of the suite of compliance documents attached
6
to the email from David Posnett dated 23 May 2011 was at the time they
were circulated; I had no involvement in developing or managing any of these
documents. It is likely that the purpose of those documents were to achieve
standardisation and identify areas of required training.
.I have considered paragraph 2.15 of the document entitled “Guide to the
Preparation and Layout of Investigation Red Label Case Files — Offender
reports & Discipline reports” at [POL00118101]. I do not recall seeing this
previously and I do not know how this related to the Offender Report template
at [POL00118102] as I never had to complete one of these reports. I also do
not understand its relevance to the Post Office’s disclosure obligations in
relation to information about Horizon bugs, errors and defects. I had very little
knowledge on the processes followed by the Post Office in relation to
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disclosure and I did not really know anything about the Horizon system
because as stated earlier in this statement, I never conducted criminal
investigations as Security Manger, nor did I supervise on the substance of
any when I was a Team Leader.
62.1 have considered the “Identification Codes” at [POL00118104] and I do not
know who wrote this. I do not remember ever seeing this document because
if I had I would have raised concerns about it to management as the
identification codes used within it are entirely inappropriate. I do not think I
would forget seeing something like this, which makes me think it even more
likely that I would have disregarded the email from Dave Posnett on 23 May
2011, to which this document was attached. I do not know if anyone else
raised concerns to management to say this document needed to be
amended.
63.1 have considered [POL00122145] and [POL00122150] and I can see that I
sent these emails following an incident at the Whitehaven branch. I believe
this was a Crown Office branch and I think I appointed Steve Bradshaw to be
the Lead Investigator. I think I asked Dave Posnett to supply me with the
relevant policy documents around Crown Branches as I had no idea about
crime policy at the time. It is clear that he sent me these documents and after
my review I was not happy with the circumstances. From memory I think the
suspect offender in this matter was able to be disciplined and they resigned
before the matter could be investigated. This just didn’t make sense to me
and I was not sure if it was a one off. I wanted to know why it had happened
and that is why I asked Andrew Wise to include it in his casework review.
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Analysing Horizon data, requesting ARQ data from Fujitsu and relationship
with Fujitsu
64.1 confirm that I have considered [FUJ00225012] and I can see that I am
copied in to an email in this chain from Andrew Wise on 10 January 2012. I
believe I am copied in due to being the Team Leader, to keep me in the loop
about the progress of the file from a work load perspective and the difficulties
being experienced in obtaining ARQ data in this matter. However, this email
appears to be directed specifically to Jayne Bradbury and Andy Hayward. As
mentioned earlier in this statement, Andy Hayward would provide supervision
and support to Security Managers who fell within my region if it related to the
substance of an investigation. I have no direct recollection of this email and I
do not have any knowledge of what analysis was done by Security Managers
of Horizon data when a SPM / SPM’s manager(s) or assistant(s) / Crown
Office employee(s) attributed a shortfall to problems with Horizon. I was not
trained in this and from my recollection I had no direct involvement with
Fujitsu, or in obtaining any sort of data from them. The only thing I can
vaguely remember is that there may have been a cost to obtain data from
Fujitsu.
65.1 have no knowledge of whether ARQ data was requested from Fujitsu as a
matter of course when an SPM / SPM’s manager(s) or assistant(s) / Crown
Office employee(s) had attributed any shortfall discovered to problems with
Horizon. I also do not know if ARQ data was provided to SPMs if it was
obtained from Fujitsu following the identification of a shortfall.
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66.1 have considered [POL00121881] and I have no direct recollection of this
email. From reading it I believe that I would have cascaded this email to the
North Team of Security Managers at the next team meeting or by email to
make sure the instructions were followed, but I cannot recall. I remember
sitting with Suzanne Winters at some point and her boxing stuff up but I
cannot be sure if it was ARQ data or when this was.
67. During all of my time working in the Post Office as both a Security Manager
and a Team Leader, I do not recall ever having any contact with Gareth
Jenkins, Penny Thomas or any other member of Fujitsu management or staff.
68.1 did not know who Gareth Jenkins was before receiving the Request, and I
had no knowledge of his role in relation to criminal prosecutions. I knew at
the time that the Post Office had cases on where the integrity of Horizon was
being challenged at court and experts were required to rebut this challenge,
but I was unaware of Gareth Jenkins’ involvement.
Relationship with others
69. As far as I recall, I never had any dealings with any external solicitors in any
investigation matters, whether those investigations were based on Horizon
data showing apparent shortfalls or not. The only time I spoke with solicitors
was when I assisted with the identification of a law firm in Northern Ireland to
assist and represent the Post Office in criminal investigations and
prosecutions in that region. I have dealt with this in detail in paragraph 27
above.
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Prosecutions in Devolved Nations
70. As explained earlier in this statement, I did not get involved with the conduct
of investigations as a Security Manager, except on the three occasions where
I sat in on an interview as a second officer. I did not conduct the interview
and I do not believe I interjected to ask my own questions. After assisting in
these interviews I played no further role in the investigation.
7
. As far as I am aware the process in which investigations were conducted in
all Regions were the same, but there were minor variances between PACE
being applied in England and Wales and Northern Ireland. For example, I
believe there was a slight difference of wording in the cautions to be
provided. I believe this was covered in the week’s training I received, as
covered under the above heading - ‘Training, instructions and guidance to
investigators within the Security team’. I cannot recall what the other minor
differences were. The primary difference from my recollection related to who
took the prosecutorial decisions, which I have set out in paragraphs 32 and
44 above.
72.1 have considered [POL00158388], but I am unable to explain what
instructions were complied with in preparing a prosecution file to support
criminal proceedings in Northern Ireland as I had no direct involvement in
preparing any prosecution files as a Security Manager, nor of reviewing them
in my role as a Team Leader. As far as I am aware the Post Office in England
& Wales, Scotland and Northern Ireland all followed the same file preparation
process. I managed Security Managers for North England, Scotland and
Northern Ireland (albeit not on the content of casefiles) and I don’t remember
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having instructions from my line manger or anyone else that a different
approach should be taken in each nation.
73.1 worked with Suzanne Winters on two cases in Northern Ireland, supported
by other North Team Security Managers as required. These are the cases
involving branches in Belfast and Strabane where I only sat in as a second
officer in an interview, as mentioned in paragraph 14 above.
74.1 do not recall encountering any difficulties while providing support to
Suzanne Winters on the two cases in Northern Ireland. I did not work on any
other cases, but there might have been issues with logistics to get people to
attend branches on an audit or to carry out an interview due to the location of
the office and the workload of the team of Security Managers who cover the
particular region.
Involvement in criminal prosecution case studies being examined by the
Inquiry
75.I have considered [POL00044025], [POL00046250] and [POL00046635].
These are case closure reports forwarded to me by Steve Bradshaw, merely
to update me on his work load to assist me in my logistical role as Team
Leader. I do not know why I am referred to as a Security Programme
Manager in these documents. I always referred to myself as a Team Leader
and I assume ‘Security Programme Manager’ is just another variation to the
job role name.
Prosecution of Grant Allen
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76.1 confirm I have considered the following documents provided in connection
with this prosecution:
vi.
vii.
viii.
The Audit Report dated 2 February 2012 at [POL00089081];
The email dated 7 February 2012 at [POL00089237];
The Record of Taped Interview re. interview of 19 April 2012 at
[POL00089670] (part 1), [POL00089671] (part 2);
The Investigation report dated 1 May 2012 at [POL00089426];
The email from Andrew Bolc dated 4 July 2012 at [POL00089294] and
the attachments at [POL00089454], [POL00089057] and
[POL00089455):
The summons dated 19 July 2012 at [POL00089072);
The report dated 16 August 2012 at [POL00089259] (in which I am
mentioned);
The unsigned witness statement of Stephen Bradshaw dated 1 May
2012 at [POL00089560);
The unsigned statements of Richard Cross and Andrew Wise dated 17
September 2012 and 1 May 2012 respectively at [POL00089561]; and
The list of witnesses at [POL00089346] and the list of exhibits at
[POL00089351].
77.1 have no direct memory of the specific facts or background to this case and
therefore am reliant on the documents above to aid my memory. What I do
recall is that I was appointed to a temporary Team Leader role for the North
Security Team in April 2012, and the Grant Allen case was being investigated
at this time by Stephen Bradshaw, who was a Security Manager within the
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North Team. I do not believe that I had any direct or indirect dealings with Mr
Allen. I also had no input in relation to the conduct of the investigation
whatsoever, with the exception of authorising the interview of Mr Allen merely
from a risk perspective for the Security Managers working on the case —
Stephen Bradshaw and Michael Stanway. This is why my name appears on
the Risk Assessment report at [POL00089259]. I believe that a risk
assessment would be carried out before all interviews to ensure the safety of
Security Managers, for example, if there was a potential risk of the
interviewee being aggressive. I can see that as the interview was to be
conducted in the Post Office premises, I identified no risks. At team meetings
chaired by me I would have asked for an update on all investigations for the
Security Managers within my Team and I assume the progress of Mr Allen’s
investigation would have been updated to me accordingly by Steve
Bradshaw. I would have been asking for updates of this sort in order to give
me an indication on the Security Managers’ workloads within the Team, to
assist me with dealing with logistical and administrative matters such as who
had best availability within the team to be the second officer in an interview in
another case that had arisen etc.
78.My first involvement in the case was my authorisation on the interview risk
assessment on the 16th April 2012. I do not believe that I had any previous
involvement in the investigation.
79. I have considered the Judgment of the Court of Appeal in Grant lan Allen &
Others v Post Office Limited [2022] EWCA Crim 1197 at [RLIT0000039]. I do
not feel in a position to comment upon how the investigation and prosecution
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of Grant Allen was conducted. The reason for this is because I do not have
any real experience of conducting investigations myself within the Post Office
and I do not have enough knowledge of the particular Post Office processes
and procedures implemented in relation to conducting investigations and
prosecutions. For those who were convicted and subsequently acquitted, I
have every sympathy.
General
80.1 was aware from team meetings that the integrity of the Horizon system was
81.
being challenged in some cases and that the Post Office was working with an
expert or experts to respond to those allegations. I did not know any further
detail beyond this. As I was not involved in conducting any Post Office
investigations or seeing a case through a prosecution I do not think that I
would have thought about a challenge to the integrity of Horizon in one case
being relevant to other ongoing or future cases at that time. I can remember
that the general Post Office position was that Horizon was an accurate
computer system. Looking at this with hindsight, in my opinion there should
have been no further prosecutions if there was any doubt that there could
have been an issue with Horizon until this was verified for certain.
Other than the matters already contained within this statement, there are no
other matters relevant to Phase 4 of the Inquiry that I would like to draw to
the attention of the Chair.
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Statement of Truth
I believe the content of this statement to be true.
22 December 2023 I 10:36:20 GMT
Dated:
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Index to First Witness Statement of Keith Gilchrist
WITN10490100
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No URN Document Description Control Number
1. POL00104747 Investigation Policy: Casework Management POL-0080387
(England & Wales) v1.0
2. POL00104777 Investigation Policy: Casework Management POL-0080417
(England & Wales) v4.0
3. POL00104754 Investigation Policy: Rules & Standards v2.0 POL-0080394
4. POL00030687 Investigation Policy - Investigation Procedures v2 POL-0027169
5. POL00104762 Investigation Policy: Disclosure of Unused POL-0080402
Material, Criminal Procedures and Investigations
Act 1996 Codes of Practice
6. POL00121455 Security Managers’ Guide to the Prosecution POL-0127718
Support Office
7. POL00104760 Investigation Policy: Arrest procedures v2.0 POL-0080400
8. POL00039952 Investigation Policy: Notes of Interview - Northern POL-0036434
Ireland
9. POL00094163 Royal Mail Group Security Procedures & Standards I POL-0094286
in relation to conducting searches
10. I POL00121591 Codes of Practice 2007 (Police and Criminal POL-0127853
Evidence) Northern Ireland Office - Order 1989
Article 60, 60A and 65.
11. I POL00030578 Royal Mail Group Ltd Criminal Investigation and POL-0027060
Prosecution Policy
12. I POL00104812 Royal Mail Group Ltd Criminal Investigation and POL-0080444
Prosecution Policy
13. I POL00104806 Royal Mail Group Security — Procedures and POL-0080438
Standards: Standards of behaviour and complaints
procedure No.10-X v2
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14. I POL00121607 Royal Mail Group-An Inspection of the Royal Mail I POL-0127869
Group Crime Investigations Function: July 2008.
Inspection Report
15, POL00031003 Royal Mail Group Crime and Investigation Policy POL-0027485
v1.1
16. I POL00030580 Post Office Ltd - Security Policy: Fraud POL-0027062
Investigation and Prosecution Policy v2
17. I POL00030579 Post Office Ltd Financial Investigation Policy POL-0027061
18. I POL00026573 RMG Procedures & Standards - Proceeds of Crime I POL-0023214
Act 2002 & Financial Investigations doc 9.1 V1
19. I POL00104857 Royal Mail Group Security Procedures & POL-0080489
Standards: Initiating Investigations doc 2.1
20. I POL00031008 RMG Ltd Criminal Investigation and Prosecution POL-0027490
Policy v1.1 November 2010
21. I POL00104853 Post Office's Financial Investigation Policy POL-0080485
22. I POL00104855 Post Office Ltd. Anti-Fraud Policy POL-0080487
23. I POL00030786 Royal Mail Group Policy - Crime and Investigation I POL-0027268
(S2) v3
24. I POL00104877 Royal Mail Internal Information Criminal POL-0080509
Investigation Team: Casefile Construction England,
Wales and Northern Ireland v1
25. I POL00104879 Appendix 1 to 8.2 Suspect Offender Reports, POL-0080511
Preamble Guide England, Wales and Northern
Ireland v1
26. I POL00104881 Royal Mail Internal Information Criminal POL-0080513
Investigation Team: Guide to the preparation of
suspect offender reports, England, Wales and
Northern Ireland v1
27. I POL00104888 Royal Mail Internal Information: 8.11 Casework POL-0080520
Management and PSO Products and Services v1
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28. I POL00031034 Post Office Prosecution Policy V1 POL-0027516
29. I POL00105229 Post Office Ltd PNC Security Operating Procedures I POL-0080854
30. I POL00104929 Post Office Limited: Internal Protocol for Criminal POL-0080561
Investigation and Enforcement
31. I POL00105226 Undated Appendix 1 - POL Criminal Investigations §IPOL-0080851
and Enforcement Procedure (flowchart)
32. I POL00104968 POL - Enforcement and Prosecution Policy POL-0080600
33. I POL00030602 POL: Criminal Enforcement and Prosecution Policy I POL-0027084
34. I POL00031005 Conduct of Criminal Investigation Policy for the POL-0027487
Post Office. (Version 0.2)
35. I POL00030686 Post Office Prosecution Policy England and Wales IPOL-0027168
(effective from 1/11/13, review 1/11/14)
36. I POL00027863 Conduct of Criminal Investigations Policy v0.3 POL-0024504
37. I POL00030902 Post Office Conduct of Criminal Investigation Policy I POL-0027384
38. I POL00122075 Email from Keith Gilchrist to Andy Hayward re New I POL-0128320
Criminal Prosecutions Policy Meeting Monday 4
February
39. I POL00122078 Email from Helen Dickinson to Andy Hayward re POL-0128323
New Criminal Prosecutions Policy meeting Monday
4 February
40. IPOL00122170 Email chain from Andy Hayward to John M Scott, POL-0128413
Helen Dickinson, cc'ing Rob King and others re:
New Draft Criminal Enforcement & Prosecution
Policy EPP.
41. I POL00122037 Email from Keith Gilchrist to Andrew Wise re POL-0128285
Enforcement Policy and Protocol
42. I POL00118289 Email from Dave Posnett to Rob King, Andy POL-0119426
Hayward, Jarnail Singh cc Suzanne Winter Robert
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Daily, Keith Gilchrist and Graham Ward re Review
POL investigation forms
43.
POL00118377
Index to POL Investigation Forms
POL-0119514
44.
POL00118290
Index to GS Obsolete Investigation Forms -
undated
POL-0119427
45.
POL00122103
Email from Keith Gilchrist to Andy Hayward
regarding New Criminal Prosecutions Policy
meeting Monday 4 February
POL-0128348
46.
POL00104821
Condensed Guide for Audit Attendance v2
POL-0080453
47.
POL00085977
Audit Process Manual - Chapter 3 - Performing a
Branch Audit - v1.2.0
POL-0083035
48.
POL00121467
Email from Ruth Robinson To:
po_security_community Re: Corporate Security
Newsbrief Issue 22
POL-0127730
49.
POL00121485
Email chain from Ruth Robinson To:
Po_security_community Re: Corporate Security
Newsbrief Issue 28
POL-0127748
50.
POL00129311
Email from Dave Posnett to Helen Dickinson,
Andrew Daley, Keith Gilchrist and others.
Re:Cartwright Training Day in Birmingham
POL-0135205
51.
POL00158977
Email - Investigation Circular 4 - 2011: Police Bail
under the Police and Criminal Evidence Act 1984,
Mandatory Reading for all Royal Mail Group
Security (Investigations)
POL-0147056
52.
POL00158978
Royal Mail Security Investigation Circular 4-2011:
Police Bail under the Police and Criminal Evidence
Act 1984
POL-0147057
53.
POL00118096
Email from Andrew Wise to Michael Stanway
forwarding an email re Casework Compliance
VIS00012685
54.
POL00118108
Appendix 1 - Case Compliance checklist
VIS00012697
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55.
POL00118109
Appendix 2 - File construction and Appendixes A, B
and C: "Compliance Guide: Preparation and Layout
of Investigation Red Label Case Files"
VIS00012698
56
POL00118101
Appendix 3 - Offender reports and Discipline
reports: "Compliance Guide to the Preparation and
Layout of Investigation Red Label Case Files”
VIS00012690
57.
POL00118102
Appendix 4 - Offender reports layout: "POL
template Offender Report (Legal Investigation)"
VIS00012691
58.
POL00118103
Appendix 5 - Discipline reports layout: "POL
template Offender Report (Personnel
Investigation)"
VIS00012692
59.
POL00118104
Appendix 6 - Identification codes
VIS00012693
60.
POL00118105
Appendix 7 - Tape Interviews. "POL Security
Operations Team guide: Summarising of Tape
Recorded Interviews."
VIS00012694
61.
POL00118106
Appendix 8 - Notebooks: Guidance on using
notebooks in investigations.
VIS00012695
62.
POL00118107
Appendix 9 - Case Progression Toolkit.
VIS00012696
63.
POL00122145
Email from Keith Gilchrist to Andrew Wise
regarding Crown Office Policy on reporting
criminality to Post Office Security
POL-0128388
64.
POL00122150
Email chain from Keith Gilchrist to Rob King, re:
Crown Office Policy on reporting criminality to Post
Office and Whitehaven
POL-0128393
65.
FUJ00225012
Email from Penny Thomas to Post Office Security
re: ARQ 178-181 - Blackpool Road.
POINQ0231127F
66.
POL00121881
Email from Helen Dickinson to Sharon Jennings,
Christopher Knight, Glyn Burrows and others re:
FW: New process for dealing with Horizon data
requests - ARQs
POL-0128140
67.
POL00158388
Internal Loss Procedure, Appendix 2
POL-0146757
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68. I POL00044025 Email from Stephen Bradshaw to Paul Williams and I POL-0040504
John Breeden re case closure - POLTD/1112/0208
- Fazakerley Branch/ Angela Sefton
69 POL00046250 Email from Stephen Bradshaw to Paul X Williams I POL-0042729
and John Breeden re Case Closure Reporting -
Khayyam Ishaq
70. I POL00046635 Report: Case Closure reporting in re to Rowlands POL-0043114
castle dated 26/09/2012.
71. I POL00089081 Branch Audit Report of Winsford Post Office POL-0086056
(217401) - Identifying Mark: RC2
72 POL00089237 Email from Steve Bradshaw to Glenn Chester re POL-0086212
Stakeholder Notification
73. I POL00089670 POL Record of Taped Interview of Mr Grant lan POL-0086645
Allen
74. I POL00089671 POL Record of Taped Interview of Mr Grant lan POL-0086646
Allen
75. I POL00089426 Post Office Ltd: Legal Investigation - Offences POL-0086401
report
76. POL00089294 Email from Andrew Bolc to Post Office Security, POL-0086269
Jamail Singh, Steve Bradshaw and others re Grant
lan ALLEN - Winsford PO POL 1112/0228
77. I POL00089454 Letter from Andrew Bloc to Post Office Limited POL-0086429
Security Team re: POL v Grant lan Allen Case
POLTD/1112/0228
78. I POL00089057 Post Office Limited Regina v Grant lan Allen - POL-0086032
Charging Advice
79. I POL00089455 Proposed Charge - (Post Office Ltd v Grant lan POL-0086430
Allen)
80. I POL00089072 Magistrates Court (Code 1188) - Court POL-0086047
correspondence
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81. I POL00089259 Planned Operation Risk Assessment Report for POL-0086234
Winsford Post Office Branch - re Grant Allen
82. I POL00089560 Post Office Limited - Witness Statement of Stephen I POL-0086535
Bradshaw
83. I POL00089561 Post Office Limited - Witness Statement of Richard I POL-0086536
Cross and Andrew Wise
84. I POL00089346 Post Office Ltd - List of Witnesses in R v Grant lan I POL-0086321
Allen
85. I POL00089351 Post Office Ltd, List of Exhibits in R v Grant lan POL-0086326
Allen
86. I RLITO0000039 Richard Hawkes & Ors v Post Office Limited [2022] I RLIT0000039
EWCA Crim 1197
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