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Witness Name: Graham Ward
Statement No.: WITN10590100
Dated: 4 January 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF GRAHAM WARD
I, Graham Ward, will say as follows
Introduction
1. This witness statement is made to assist the Post Office Horizon IT Inquiry (the
"Inquiry") with the matters set out in the Rule 9 Request dated 12.12.23 (the
"Request"). I have received advice and assistance from a lawyer in the
preparation of this statement.
Relevant Background
2. I am currently employed by the Metropolitan Police, as a member of their police
staff, working in an administrative role within the Economic Crime Team.
3. I ama former employee of Post Office Ltd ("POL") which I joined in 1984. I left
the business in May 2016.
4. During my employment with POL, I held the following positions, which I have set
out to the best of my memory:
a. 1984 — 1992, Post Office Counter Clerk at various branches within South
London. This role involved serving members of the public and balancing my
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counter till each week. I would also be involved each week in the
preparation and completion of the office branch account. I also tutored new
counter clerks on arrival at the Gatton Road branch in Tooting, which was
also a ‘satellite’ training office with a training team based above the branch.
I also covered various branch manager roles on occasions during periods
of annual leave.
In 1992 I was promoted to the role of Assistant Area Manager in the London
South West District, supporting Subpostmasters with the day-to-day
running of their branches in the SW2 to SW10 area. This included assisting
with balancing their accounts, processing ‘error notices’ received, and
assisting when required with various incidents including burglary or
robberies. Following a business re-organisation, this role was removed so
I then joined a Branch Conversion Project Team briefly, which involved the
conversion of Branch Post Offices to Modified Agency Branches.
In around 1993, I joined the South East Regional Audit Team as an auditor,
which involved auditing branch accounts and undertaking various
compliance tests. During this period I was seconded to a project team for
approximately 6 months, a role which involved installing lottery terminals in
branches within the South East of England.
In around 1997, I joined the Post Office Investigation Team, initially as an
Investigation Analyst working to and being line managed by an
Investigation Manager named Aileen Saubelle. I can recall receiving formal
training via the Royal Mail Training team, which was based in Croydon. This
training consisted of awareness of the Police and Criminal Evidence Act
("PACE"), search techniques and interviewing suspect offenders. I had to
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pass an assessment at the end of the two week course. Following a re-
evaluation of my job, the role of Investigation Analyst was retitled
Investigation Manager (I cannot recall the date), whereupon I began leading
investigations as a First Officer, investigating criminal offences committed
against the business. This involved conducting investigations, interviewing
suspected offenders and preparing cases for prosecution at either the
Magistrates or Crown Court. The role also involved providing advice on
physical security related issues at branches. My line manager at this time
was Ray Pratt.
My recollection is that, before moving into my next role (described in the
paragraph below), I covered the role of Investigation Team Leader for a
very brief period (possibly around six to eight weeks). It may be that I was
providing cover for a colleague, but I am unable to recall.
Sometime in 2001, I moved briefly to a Policy and Standards Manager role
but, following a team restructure, I moved into the role of Assistant
Casework Manager from 2002. When the incumbent Casework Manager,
Brian Sharkey, left the business in 2004, I took on the role of Casework
Manager until sometime in 2007. During this time I had line management
responsibility for four or five administrative support staff. The role of
Casework Manager was varied and included responsibility for raising cases
for formal investigation and the provision of performance statistics to senior
management. The role also involved regular communication and liaison
with law enforcement agencies and assorted stakeholders across POL. The
Casework Manager was also the single point of contact for requesting
Horizon data from Fujitsu via the Audit Record Query ("ARQ") process. I!
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believe my previous experience as a counter clerk, assistant area manager,
auditor and investigator meant I had a sound understanding of the
requirements to perform the Casework Manager role. My line managers
during this period were Tony Utting and then Dave Pardoe.
Due to the high volume of work within the Casework Team and then,
following another team restructure for which I cannot recall the date, I was
promoted to the role of Casework and Banking Fraud Team Leader, which
was essentially a similar role to that of the Casework Manager but which
bought into the team, two other managers, Jason Collins and Natasha
Barnard, to help me with the workload. I line managed both the new
managers and they split the line management of the support staff.
At some point in 2007, I cannot recall the exact date, I moved into the role
of an Accredited Financial Investigator ("FI"), which involved seeking
recovery of money stolen from the business through the application of the
Proceeds of Crime Act 2002 ("POCA"). To perform this role I was required
to achieve Accreditation via the Asset Recovery Agency under Parts 2 and
8 of POCA. I also achieved a BTEC diploma in Financial Investigations as
part of my training during this period. The role of an FI included making
applications at a Crown Court for Production, Restraint and Confiscation
Orders. My line manager was Ged Harbinson and, when he left, Paul
Southin took over as the Fl Team Leader and as my line manager. I believe
my previous experience as an auditor, investigator and Casework Manager
provided me with a good background and understanding for Financial
Investigation work.
At some point in 2012, I was moved into the Information Security Team for
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a period of approximately eight to 10 months, working to the Head of
Information Security and also supporting an external contractor on a project
involving PCI Data Accreditation. My line manager during this period was
Richard Barber.
je In January 2013, I left the Security Team, having successfully applied for
the role of Mail Conformance Manager within the National Network
Conformance Team, where I remained until I left the business in May 2016.
My line manager during this period was Gayle Peacock.
5. I do not recall any reason to question the capability or professionalism of any of
my line managers during the time I was employed by POL.
6. The Request asks me in particular to describe any roles I had in relation to
disciplinary matters, interviewing suspects, disclosure in criminal or civil
proceedings, litigation case strategy and liaising with other POL departments
regarding the progress of cases. My role in relation to disciplinary matters was
limited to those staff I line-managed directly, and I do not recall having to deal
with any such matters. In my role as Investigator, I interviewed suspect offenders
and was responsible for disclosure of material in these cases. I was not involved
in litigation case strategy but did liaise with POL civil litigation lawyers in terms of
requesting ARQ data, and also the Criminal Law team in respect of my own
cases as both an Investigator and Fl and also as the Casework Manager.
The Security team’s role in relation to criminal investigations and prosecutions
7. Paragraph 5 of the Request draws my attention to a series of documents
containing policies relating to investigations, and asks a number of questions
about the structure of the Security Team, the role of the Financial Investigation
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Unit, and my role in relation to the development of policies and procedures. The
Request also asks me to give an account of the legislation, policies and guidance
which governed the conduct of investigations
8. The structure of the Security Team changed frequently during my time in the
team and I cannot recall with any certainty when and how often these changes
occurred. Around the time I joined the team in 1997, there was a move away
from the corporate structure of the Post Office Investigation Department. This
meant each of the business units (Royal Mail, Parcelforce and the POL) had their
own independent investigation teams. However the Royal Mail Criminal Law
Team continued to advise on all POL cases. This remained the case until POL
separated from Royal Mail Group in approximately 2011, and at that point
prosecutions were dealt with by a Senior Lawyer, Jarnail Singh, and external
solicitors.
9. From memory, the POL Security team when I joined it included an Investigation
Team; Physical Security Team (dealing with burglary, robbery, safes and alarms
etc.); Commercial Security Team; and IT Security Team. When I left the team in
2013, John Scott was the Head of Security, having been in post from
approximately 2007. I recall John Scott giving a presentation on Security Team
strategy and new structure for the team at an event, where he outlined the five
new strands, namely Security Operations, Physical Security, Information
Security, Commercial Security and Security Administration.
10. I cannot recall having input to these documents, aside from the document
referred to at paragraph 11 below, which I may have had some input to but
cannot recall with any certainty.
11. I have reviewed the document at [POL00084989] (the "Security & Investigation
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Financial Investigation Unit Criminal Debt Recovery Process"). The Request
says that I am referred to in this document as the Financial Investigation Unit
("FIU") manager. I have reviewed this document and on page 1, at Step 1, I note
that the document refers to Ged Harbinson as the FIU Manager. I am referred to
on page 2 at Step 3 as one of the Fis.
12. The role of the FIU was to pursue recovery via the application of POCA.
Decisions to carry out financial investigations were informed by the amount of
the loss in each case. [POL00084989] indicates that the FIU would become
involved where losses were greater than £20,000. I cannot recall exactly when,
but this amount may have increased from a figure lower. The reason for the
increase was the volume of work we could realistically manage.
13. In addition to the various internal policies and procedures, Investigators were
also required to adhere to PACE, the Criminal Procedures and Investigations
Act, the Data Protection Act and the Human Rights Act. Internal policies may
have changed, but I do not recall any significant changes other than the
introduction of Fraud Act legislation.
14. From memory, POL's policy with regards to the investigation and prosecution of
offenders was the same for all POL employees, as well as for Subpostmasters,
managers and staff. I recall a ‘Triggers & Timescales’ document that was held
on the Intranet site, which broadly outlined the types of cases the team would
investigate and the expected timescales for completion.
The process followed by Security team investigators when conducting a
criminal investigation following the identification of a shortfall at an audit
15. Paragraph 11 of the Request asks me what process investigators followed when
conducting investigations, once a decision had been made to conduct a criminal
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investigation. Having been contacted by the Audit Team or a Contract Manager
and asked to attend an audit shortage, my recollection is that Investigators would
obtain as much information as possible via the person making the phone call
and, if they had time, they would try to obtain a Subpostmaster's printout from
HR which recorded personnel details for the Subpostmaster and staff. The next
course of action would be a decision for the Investigator to make, in conjunction
with their team leader, but invariably every effort would be made to attend the
Post Office on the day to conduct further enquiries.
Decisions about prosecution and criminal enforcement proceedings
16. Paragraph 12 of the Request asks me who decided whether a Subpostmaster
(or their manager and/or their assistants) or a Crown Office employee should be
prosecuted and the considerations that informed that decision. Following
attendance at an audit shortage, and after any suspect offender interviews had
been undertaken, the Investigator would then complete a case file, taped
summary of interview and offender report (where PACE interviews had been
conducted) and this case file would then be submitted via the Casework Team
to the Criminal Law Team who would prepare an advice and detail any charges
based on the evidence. The Head of Investigations, or whoever was the
Prosecution Authority at that time, would also have sight of the case file and
would make the final decision on whether to prosecute or not.
17. Paragraph 13 of the Request asks me what test was applied by those who made
charging/prosecution decisions. I am not aware of the ‘tests’ applied by the
Criminal Law Team for charging and prosecution decisions although, from
memory, I believe a memo from the Criminal Law Team would be placed in the
respective case file outlining the rational for proceeding with a prosecution or not.
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18.
19.
20.
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Paragraph 14 of the Request asks me what legal advice was provided to those
who made charging/prosecution decisions. I am not aware if there was any
advice given to decision makers in respect of making charging and prosecuting
decisions.
Paragraph 15 of the Request asks me about the circumstances in which POL
would consider taking steps to restrain a suspect's assets by criminal
enforcement methods, and paragraph 16 asks me who made decisions to pursue
criminal enforcement proceedings and the factors they took into account. In
relation to the decision to restrain a suspect's assets under POCA, this would be
based on the information provided to the FIU on a Financial Evaluation Sheet
("FES"), which included the investigator's view on whether a suspect's assets
could be dissipated. This would form the basis for considering whether to apply
for a Restraint Order. The decision to apply for a Restraint Order was carefully
considered in each case and only applied for when it was considered necessary,
e.g. in cases where dissipation was considered a possibility or in cases where
we considered there was a possibility of a suspect entering into receivership. I
recall from my FI training the PLAN mnemonic ("Proportionate, Legal,
Accountable, Necessary") and we always considered this when making
decisions on case progress. The decision to restrain would be discussed with the
Senior Authorising Officer and a lawyer from the Criminal Law Team and all
decisions would be recorded on the FI event and policy decision logs.
The Criminal Law team, Senior Authorising Officer and the Fl would determine
whether to pursue confiscation proceedings, but this process would only follow
the conviction of a defendant. The submission of a Section 16 prosecution
statement detailing the defendant's benefit from crime would be sent to the
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21.
22.
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Criminal Law Team by the FI for review and approval and, if approved, the
Criminal Law Team would arrange for it to be sent to the Defendant's solicitors
and also the Crown Court. This statement outlined the details of the case and
benefit obtained and it would be for the court to decide on whether to grant the
Confiscation Order or not.
Paragraph 17 of the Request refers me to the document at [POL00121975], an
email I sent to Dave Posnett on 1.11.12, and asks me what I meant by the
statement I gave in the email. Having looked at the correspondence set out in
[POL00121975], I note that I had earlier on the 1.11.12, in an email I sent to Andy
Hayward (at 14:29), outlined the process that Fls always followed in seeking to
request compensation out of any awarded POCA Confiscation Order amount. I
do not recall whether this was a policy decision or not, but it was the process we
followed to avoid the court ruling that the defendant must pay the Confiscation
Order and, in addition, compensation to POL for the loss (which I recall a judge
having the power to do). In every case I can recall dealing with as an FI, the court
would agree to the POL's request for a Compensation Order made out of the
Confiscation Order (in other words the defendant would not have to pay anything
other than the loss).
Looking again at my email to Dave Posnett later that day, I believe I was
expressing my frustration that I must have been unable to explain this clearly to
Jarnail Singh during a telephone call I had had with him on that same day. I
cannot recall what I was thinking in 2012 with regards to a ‘watered down’
approach to prosecution and recovery, but I believe I was on the verge of leaving
the Security Team at that time and seem to recall that Investigations and
Financial Investigations had slowed down considerably (they may have ceased
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altogether, but I cannot be sure), which meant we would not be able to use the
POCA for recovery of losses.
Training, instructions and guidance to investigators within the Security team
23. Paragraph 18 of the Request asks me about the training, instructions and
guidance given to investigators on interviewing suspects, taking witness
statements, conducting searches, obtaining evidence in the course of an
investigation, disclosure obligations and drafting investigation reports. When I
first joined the Investigation Team around 1997, all training was delivered by the
Royal Mail training team. The training covered undertaking an investigation,
compiling evidence, interviewing suspects, conducting searches and taking
witness statements. Further training was provided by the more experienced
members of team on an ongoing basis. I recall the Criminal Law Team would
also provide ad-hoc sessions on new legislation (e.g. the Fraud Act). My belief is
that I did attend a training session on disclosure, but I cannot recall this for
certain. My recollection of the training I attended was that it delivered by
experienced professional investigators and lawyers and was adequate.
24. When POL separated from Royal Mail Group, training was delivered internally to
new members of staff by existing members of the Security Team. I had no
involvement in the preparation or delivery of those training courses as far as I
can recall.
25. I do not recall ever receiving specific training on the gathering of evidence from
Fujitsu, but I think there was an ARQ process already in place when I joined the
casework team in 2002 and which I believe all Investigators were aware of.
26. I also recall that all Investigators had access to a Royal Mail Intranet site that
contained copies of the various policies and procedures in place at that time.
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27.
28.
29.
30.
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Circulars with updates to policies and any legislation changes were also
uploaded to this site. When POL separated from Royal Mail, a POL intranet site
was created which was used to store policies and procedures.
Paragraph 19 of the Request refers me to the documents at [POL00121639] and
[POL00121640] and asks me to explain my involvement in devising and
delivering training to the Security Team. I have reviewed the two documents. I
cannot recall specifically how these Financial Investigation and Compliance
presentations were put together, but I would assume from the first slide on each
presentation that it was a collaborative effort by Ged Harbinson and I. I can recall
that we did attend team meetings across the country to go through the content
with all Financial Investigators in the team at that time to raise awareness of
POCA and compliance processes.
Paragraph 20 of the Request draws my attention to a series of documents
relating to casework management and guidance about the preparation and
layout of case files, and paragraph 21 asks me a number of questions about
these documents.
I have reviewed the two Casework Management documents (version 1.0, March
2000 at [POL00104747] and version 4.0, October 2002 at [POL00104777)). I
cannot recall having seen either document but my recollection is that all policy
documents were available on the Royal Mail intranet site.
As regards what I understood by the second, third and fourth bullets on page 2
of the 2000 version, and the first, second and third bullets on page 2 of the 2002
version, I believe that I would have understood these bullet points to relate to
disclosure obligations, and that information about any Horizon bugs, errors or
defects would need to be disclosed. Albeit that, during my time in the Security
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31.
32.
33.
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Team, I was not aware of any bugs, errors or defects.
As regards the circumstances in which investigations became subject to
compliance checks, my recollection is that all investigations were subject to
compliance checks, carried out by either the Compliance or Casework Manager.
The purpose of such checks was to ensure accuracy and consistency in the
presentation and reporting of the case.
I have reviewed the two versions of the "Guide to the Preparation and Layout of
Investigation Red Label Case Files" ("Offender reports & Discipline reports" at
[POL00121569] and "Case File Reports and Case Closure Reports" at
[POL00121581]). My understanding of the rationale of paragraph 2.15 of
[POL00121569] was that it was put in place to ensure that any procedural failings
identified during the course of the investigation were highlighted within the report.
The issue of procedural failings is also addressed in the guide at
[POL00121581], at paragraphs 1.8, 2.4 and 2.5. My understanding of these
provisions was that such procedural failings were to be highlighted in the
confidential offender report. The discipline report, which was a separate report
sent to the Contract Manager and so available to the suspect, should exclude
procedural failings as this could negatively impact other ongoing cases.
I have reviewed the "Identification Codes" document at [POL00118104]. I played
no role in drafting or reviewing this document. I can recall a similar document
was used as a guide for identifying which identity code to use when completing
what I recall were called "NPA (Non-police Agency) forms" and which were sent
to the police for suspect offender cases that were then to be added to the Police
National Computer Unit. The terminology used in [POL00118104] is clearly
extremely offensive and outdated, and I do not recall seeing this version in
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circulation during my time in the Security Team.
Analysing Horizon Data and requesting ARQ data from Fujitsu
34. Paragraph 22 of the Request asks me to describe my understanding of the
agreement in place between POL and Fujitsu for the provision of litigation
support. I was aware of a contract between POL and Fujitsu to provide and
maintain the operating system known as the Horizon system. I was aware that
within the contract there was provision and reference to an ARQ process, which
allowed POL to request Horizon and banking data for any Post Office branch
covering a specified period.
35. Paragraph 23 of the Request asks me to explain the contractual requirements
on Fujitsu, as I understood them, governing POL's ability to obtain audit data, the
type of data and the quality and completeness of the data. In particular, the
Request asks me to explain the position as regards the number of ARQ requests
which could be made without charge to POL; changes between Legacy Horizon
and Horizon Online; my role in making requests and my recollection of how
requests were handled by Fujitsu; and the additional prosecution support that
Fujitsu provided to POL.
36. The Casework Manager acted as the single point of contact between POL and
Fujitsu and was responsible for requesting the ARQ data from the Fujitsu
Prosecution Support team. I cannot now recall the exact numbers of requests
that were available each month, but at the time I was working as the Casework
Manager I would have been aware of the contractual limits imposed each month.
I recall maintaining a spreadsheet to record all ARQ requests and the volume of
data being asked for, to ensure we did not exceed our contractual limits. Having
reviewed the various versions of the Fujitsu Security Management service
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37.
38.
39.
40.
41.
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documents that the Request draws my attention to, I note the reference to 720
ARQ requests per year, which is a figure that we would have worked to. I also
note the reference within these documents to Litigation support dealing with 150
record queries each rolling year (which I assume to be provision of witness
statements) and 60 days per year attendance at court.
Given that any requests above the contractual limits could be charged to POL, I
do recall, at some point in my time as the Casework Manager, discussing the
volume of requests issue with my then line manager Tony Utting. Whilst I cannot
be 100% certain given the time that has since passed, I seem to recall that the
ARQ limits were increased during my time in the Casework Team.
The Request asks me to describe any changes as between Legacy Horizon and
Horizon Online. I do not have any recollection of any changes as between Legacy
Horizon and Horizon Online, other than that I believed that Horizon Online was
an upgrade to the Legacy Horizon system.
The Request asks me to describe who from Fujitsu was responsible for the
provision of ARQ data. Fujitsu's Prosecution Support Team was responsible for
providing data. Towards the end of my time as Casework Manager, I dealt with
Penny Thomas and Andy Dunks. Prior to that, I recall that Bill Mitchell led the
team comprising Pete Sewell and Neneh Lowther.
The Request asks me to describe the role I had in obtaining ARQ data. As I
explained above (at paragraph 36), the Casework Manager acted as the single
point of contact between POL and Fujitsu and was responsible for requesting the
ARQ data. This was a role I had from 2004 to 2007.
The Request asks me to describe POL's requirements as to how data was
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42.
43.
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presented and how Fujitsu presented ARQ data. I do not recall being involved in
how the ARQ data was presented; I recall Horizon event and transaction data
was provided in Excel spreadsheets but I believe this process was already in
place when I became the Casework Manager. I cannot now recall the content of
the data provided; I can recall there being several columns, but I cannot recall
the details contained within each column. Details of Horizon System helpdesk
("HSH") calls could also be requested for a specified period.
The Request asks me to describe any additional prosecution support that Fujitsu
was contractually obliged to provide (including witness evidence of fact and
expert witness evidence). I cannot recall there being any specific ‘additional’
support from Fujitsu. My understanding was that if ARQ data was required, it
would be supplied in accordance with the contract and, if a supporting witness
statement was needed, this would also be supplied in accordance with the
contract and would be dealt with on a case by case basis. I do not recall
differentiating requests between evidence of fact and expert witness evidence.
Paragraph 24 of the Request asks me to describe the process used by POL for
making ARQ requests. From memory, the process followed to request ARQ data
started with an email from an Investigator to the Casework Team, asking for
Horizon data covering a specified period for a particular branch (giving the name
and Branch Code). If there were specific requirements (e.g. that banking details
or a specific explanation on a transaction were needed) this would be included
in the email from the Investigator. This information would be copied onto the ARQ
request form, which would be emailed to the Fujitsu support team. The Casework
Manager did both these tasks. Requests for ARQ data were, to my recollection,
usually processed within the agreed timescales and the ARQ data would be sent
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44,
45.
46.
47.
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to the Casework Team via a CD-ROM disc posted by Royal Mail Special
Delivery. On receiving this, the Casework Team would forward it on to the
Investigator who had requested the data.
In my recollection, Horizon ARQ data requests would be prioritised for Security
Team cases due to the contractual limits in place each month, but if requests
came from other areas of the business (e.g. Subpostmaster via a Contract
Manager or the Product and Branch Accounting team in Chesterfield), these
would be considered if we had spare requests available.
Paragraph 25 of the Request asks me whether ARQ data was requested as a
matter of course in cases where shortfalls had been identified and a
Subpostmaster/their staff had attributed the shortfall to Horizon, and paragraph
26 asks me if this data was provided to Subpostmasters as a matter of course. I
believe my assumption in these cases would have been that the Investigator
would have requested Horizon data to look for any transactions or events that
could have explained the shortage. They would also, I suspect, have requested
HSH calls to try to gain a picture of any Horizon issues being reported to the
helpdesk by the branch and by whom.
I did not deal with any cases as an Investigator where the Subpostmaster blamed
the Horizon system for losses, so I cannot say whether or not ARQ data was
disclosed as a matter of course. From recollection, I believe that Horizon
transaction and event log data was also available to all Subpostmasters from
within their branch for up to one month.
Paragraph 27 of the Request asks me who within POL had the authority to
request ARQ data from Fujitsu, and paragraph 28 asks if authorization from POL
was needed to make such a request. As I explain elsewhere, this lay with the
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48.
49.
50.
51.
52.
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Casework Manager, who acted as POL's single point of contact with Fujitsu. In
my experience, the Casework manager did not need to obtain any authorisation
elsewhere within POL to make a request.
Paragraph 29 of the Request asks what procedures applied when obtaining ARQ
data and whether there any written guidelines or protocols. I describe the process
for obtaining ARQ data elsewhere (at paragraph 43). I don’t recall there being
any written guidelines or protocols.
Paragraph 30 of the Request asks what considerations informed the decision to
request ARQ data. I have referred elsewhere (at paragraph 36) to the contractual
provisions which provided for how many requests could be made in a months.
That was the main consideration, to my recollection. The numbers of requests
made was monitored very closely (we maintained a spreadsheet, as I mention at
paragraph 36) showing a running total of the requests made. I don’t recall
refusing many requests when I was Casework Manager because of the
contractual limits.
Paragraph 31 of the Request asks be about the form in which ARQ requests
were made. There was a particular form that was completed when making
requests, as I explain at paragraph 43.
Paragraph 32 of the Request asks me to describe my understanding of whether
PACE certificates were provided by Fujitsu to support a criminal prosecution and,
if so, what process was followed. I was not aware whether PACE certificates
were provided by Fujitsu to support a prosecution.
Paragraph 33 of the Request asks me to describe the process by which Fujitsu
was asked to provide a witness statement relating to audit data and my
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understanding of how this processed differed for witnesses of fact and expert
witnesses. Paragraph 34 further asks me to describe any involvement I had in
this process.
53. Witness statements were requested by each Investigator on a case by case
basis, following advice received from the Criminal Law Team, for cases
proceeding to a prosecution. Once an Investigator had emailed the Casework
Team with a request for a witness statement, an email would be sent to Fujitsu
asking for a witness statement in respect of the relevant ARQ(s) previously
supplied. I recall Penny Thomas or Andy Dunks usually provided these
statements exhibiting the data provided. I recall witness statements had two
paragraphs at the end that referred to the ‘system operating correctly’ (or words
to that effect). From memory, this was a form of words that was supplied by the
Criminal Law Team. In cases where a more detailed explanation of the Horizon
system was required, I recall that Fujitsu identified Gareth Jenkins as someone
who had a more detailed knowledge of the system from an operating perspective.
54. Paragraph 35 of the Request asks me what analysis was done of Horizon data
by Security Team/FIU investigators when a shortfall was attributed to problems
with Horizon. As an FI, I do not recall ever analysing Horizon Data as part of the
Fl process.
Relationship with others
55. Paragraph 36 of the Request refers to the email I sent on 1.11.12 at
[POL00121975] and asks me to describe any involvement I had with Cartwright
King solicitors. I do not recall any specific interaction with Cartwright King
solicitors, but I can recall attending an introductory meeting in their Derby office
when they started working with POL, following the separation from Royal Mail in
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around 2012. I may also have had some interaction in my role as an FI but I
cannot recall the details.
Relationship with experts
56. Paragraph 37 of the Request asks me to describe any involvement I had with
prosecution expert witnesses. As Casework Manager, I had little involvement
with prosecution witnesses, aside from liaising with Fujitsu’s Prosecution Support
team.
57. Paragraph 38 of the Request asks me about my understanding of the
requirements and procedures governing instructing experts in legal proceedings,
and paragraph 39 asks me to explain my understanding of the role played by
Gareth Jenkins when he made a witness statement in legal proceedings. I do not
recall any instructions or procedures that related to expert witnesses. From my
recall of the interactions I had with Gareth Jenkins, which would have taken place
a long time ago, I believe I saw Gareth Jenkins as a Fujitsu member of staff who
had a greater depth of technical knowledge of the Horizon system than either
Penny Thomas or Andy Dunks (members of Fujitsu's Prosecution Support
Team), and who was better placed to answer any technical questions raised
during the course of an Investigation. I cannot recall if I saw him as an “expert”
witness or not.
Claim against Lee Castleton
58. Paragraph 40 of the Request draws my attention to a series of documents and I
am asked at paragraph 42 to give an account of my involvement in the case of
Mr Lee Castleton.
59. I would describe my involvement in this civil case came about because I was
asked to request Horizon ARQ data and a supporting witness statement from
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60.
61.
62.
63.
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Fujitsu.
I have reviewed document [POL00107851], which is a long email chain
forwarded to me by Brian Pinder, Fujitsu Security Manager, which began with an
email dated 18.10.05 from Stephen Dilley, a solicitor from Bond Pearce LLP, who
had asked if POL had documents that Mr Castleton had requested. I take it from
Brian Pinder's email to me of 25.10.05 that he was presumably aware that any
requests for Horizon data would need to be requested formally by the Casework
Team. My reply to Brian Pinder advises that this was not a criminal case, and I
read the remainder of my reply as an attempt to assist the Civil Litigation team.
I have also reviewed the document at [FUJ00152290] and specifically my email
to Brian Pinder dated 28.7.06. Having read this, I believe was acting as a liaison,
in my capacity as the Casework Manager responsible for being the single point
of contact between POL and Fujitsu.
Paragraph 43 asks me what my concerns were about the impact of Mr
Castleton's case and the difficulties and/or challenges it posed to POL, and
paragraph 44 asks me about my understanding of the significance of ARQ data
in this case. I have reviewed the documents that are referred to in paragraph 40
of the Request. The only ‘concern’ I can recall having related to the volume of
ARQ requests that would have to be made to respond to the request for
information, and the scale of the task of analysing it. I don’t personally recall
being concerned that Mr Castleton's claim posed a challenge to the integrity of
the Horizon system, as I don’t recall that it was considered a significant issue at
that time.
Paragraph 45 of the Request asks me if I considered how ARQ should be
presented by Fujitsu. I don't recall giving any particular consideration to this in
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64.
65.
66.
67.
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this case. As I explain elsewhere, there was a standard format for the
presentation of event and transaction logs.
Paragraph 46 of the Request asks me in particular about the email I sent on
25.10.05 at [POL00107851] and why I asked Keith Baines whether ARQ data
was required. I can see that this is in reference to the last paragraph of that email.
From my reading of the email as a whole, I believe I would have been asking
Keith Baines if an ARQ request was necessary in order to obtain information
about the calls made to HSH.
Paragraph 47 of the Request asks me if I was aware that some Subpostmasters
had blamed Horizon for shortfalls. I have reviewed the bundle of documents at
[FUJ00152573] and from the correspondence contained in it (for example the
email I sent to Brian Pinder on 28.11.05) I can see that I had referenced both the
Marine Drive Post Office (Mr Castleton's branch) and another branch at "Torquay
Road", and I refer in that email to these being "Civil matters where there is a
suggestion that the losses incurred at the offices are as a result of faults with the
Horizon software".
I have also reviewed the document at [POL00071165], the attendance note of
the meeting which took place on 6.6.06. Section 1 of the note refers to a number
of "Horizon Disputes"; besides Mr Castleton there is also a reference to the "Bajaj
and Bilkhu disputes". Given the time that has since passed, I do not recall
attending this meeting at Fujitsu's offices in Bracknell but can see that I am
among the list of attendees and that I have made some general observations
during the meeting.
Paragraph 48 refers to the document at [FUJ00152573] and asks if I am the
'Graham' referred to in Brian Pinder’s note dated 7.12.05 and, if so, what I
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understood by the information provided by Fujitsu which is set out in the note. I
have reviewed the note and I can see it has ‘Graham’ at the head of the page,
but I do not recall having seen the note. I cannot therefore say what I might have
thought of the information supplied by Fujitsu.
68. Paragraph 49 of the request asks me to describe any further involvement I had
in Mr Castleton's case. As I explained above, the documents I have been referred
to concern a civil case that POL was involved with against Mr Castleton. At that
time, the role of the Casework Team in relation to ARQ requests was limited to
criminal cases; I don’t recall any other case before Mr Castleton's when I became
involved in a request for ARQ data in a civil case. Having been alerted by Brian
Pinder and then by Stephen Dilley to the need to obtain information, my
recollection is that I was involved in requesting ARQ data and evidence from
Fujitsu. I do not remember having any other involvement aside from this.
Prosecution of Mr Hughie Thomas
69. Paragraph 50 of the Request draws my attention to a series of documents and I
am asked at paragraph 51 to give an account of my recollection of the case of
Mr Hughie Thomas.
70. Paragraph 52 of the Request asks me to describe the circumstances in which I
became involved in the case. I have little recollection of the case given the time
that has passed, but I have reviewed the documents referred to at paragraph 50
of the Request to inform my answers to these questions.
71. At the time of the events described in the documents, I was the Casework
Manager. As I explained above, the Casework Manager was the single point of
contact between POL and Fujitsu, including in relation to the ARQ process. My
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72.
73.
74.
75.
76.
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recollection is that it was in that capacity that I became involved in this case.
Paragraph 53 of the Requests asks me in particular about an email I sent dated
14.10.05 at [FUJ00155181], specifically who the intended recipient was, my
understanding of the issues in this case at the time I sent the email, and why I
considered a witness statement was going to be necessary. I have reviewed the
document and cannot recall who the intended recipient of this email was. The
email address I sent it to may have been a ‘Team’ inbox for the Fujitsu
Prosecution Support Team.
I believe my understanding of the issues in this case would have been informed
by the email that the investigator in this case, Diane Matthews, sent me on
14.10.05 (contained in the document at [FUJ00155181]). On reading this
correspondence again, it seems that the Subpostmaster was alleging there was
a fault with ‘Nil’ transactions on the card account online banking transactions.
I cannot now recall why I considered that a witness statement might be necessary
in this case. It is possible that it the amount of the loss identified at the branch
audit on 13.10.05 (£48,000) might have been a factor, but I am unable to say for
certain.
Paragraph 54 of the Request asks me to explain the circumstances in which I
made the ARQ request. From reviewing the documents, I believe I made the
ARQ request at the request of Diane Matthews, the Investigator in this case.
Paragraph 55 of the Request asks me about a further email I sent dated 10.3.06
at [FUJ00122197], specifically in relation to the statement in which I said it was
"very much in both ourselves and Fujitsu's interests to challenge the allegations
and provide evidence that the system is not to blame for the losses being
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77.
78.
79.
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reported". I have reviewed the email. I believe my intention was to make it clear
to Fujitsu that, in a case where the system was being blamed for the loss, it was
important to provide evidence that the system was working correctly and was not
responsible for the losses. My recollection is that, at this time, it was not common
for Horizon to be blamed for losses and I thought it was best to highlight this to
Fujitsu (as I have explained in relation to Mr Castleton's case, I would at this time
have been aware of his case and the case relating to "Torquay Road", but don’t
recall being kept up to speed with how those cases were progressing). With the
benefit of hindsight, the words I used appear to put across a view that it was in
POL's and Fujitsu's interests to disprove the allegations, and perhaps I should
have been asking Fujitsu to simply clarify whether the system was operating
correctly or not during the specified period.
I went on to say that "Whilst it may not be a statement that you, Penny or Neneh
can provide, I'm sure there must be someone who can". I cannot now recall why
I didn’t think Penny Thomas and Neneh Lowther could provide the statement for
this case, but as this was the first time I can recall having seen a reference to
‘Nil’ transactions, I may have assumed, possibly incorrectly, that this was
something that would have been outside of their knowledge.
I cannot recall how Gareth Jenkins came to provide a Witness statement but in
the document at [FUJ00122197] there is an email from Neneh Lowther dated
22.3.06, which references his draft witness statement. I can only assume that
Fujitsu had therefore made an internal decision for Gareth Jenkins to provide the
witness statement.
Paragraph 56 of the Request refers to a draft witness statement that Gareth
Jenkins made (at document [FUJ00122204]) and an annotation which said “I’m
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80.
81.
82.
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not sure that the yellow bit is true. Can this be deleted? All I’ve done is interpret
the data in spreadsheets that you have emailed to me.” The Request asks if I
discussed this concern with Gareth Jenkins. It was not part of my role as
Casework Manager to review witness statements provided by Fujitsu, but in this
case I appear to have done so, possibly because I was asked to, or because I
have tried to be helpful by doing so; this is set out in the email I sent to Neneh
Lowther on 22.3.06 (at document [FUJ00122203)). I cannot recall exactly why,
but I suspect that my concern at the words "system failure" would have been that
it would require a detailed explanation within the witness statement.
I do not recall discussing with Gareth Jenkins the concern expressed on the draft
witness statement. The last two paragraphs highlighted yellow, to which I
assume he is referring, were standard paragraphs that the Criminal Law Team
had asked be included on all witness statements producing Horizon data.
Paragraph 57 refers to the documents at [FUJ00122218], [FUJ00122217],
[FUJ00122211] (which has been superseded by reference [POL00047895)) and
[FUJ000122210] and I asks me to give an account of the amendments I
suggested and made in respect of Gareth Jenkins' witness statement; if I deleted
the references to "system failures"; and, if so, why I considered this appropriate.
I have reviewed the documents.
I have no recollection of what I thought about this statement since such a long
time has now passed. As I say, I believe I was responding to a request from
Fujitsu to review the statement and/or was just trying to help. I may also have
formed the impression (based on my reading the email exchanges and draft
statements disclosed to me) that Gareth Jenkins wasn’t clear about what he
should be putting in his statement. This was clearly an internal matter for Fujitsu
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83.
84.
85.
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to resolve, and I note that I suggested in my email to Neneh Lowther of 24.3.06
([FUJ00122217]) that someone from the Security Team should take the
statement directly from Gareth Jenkins.
It is my strong belief that I would not have insisted on removing or adding any
comments to Gareth Jenkins’ statement and I most certainly would not have
deleted anything. My belief is that my only motivation was to ensure that the
statement provided gave a full explanation of what ‘Nil’ transactions actually
meant, and that if the statement was going to assert that "system failures were
normal", then that would also need to be explained in detail and an account
provided about the impact any impact on POL's accounts. I cannot recall having
any involvement in finalising Gareth Jenkins' witness statement.
Paragraph 58 refers to the documents at [POL00049024], [POL00044917] and
[POL00049131] and paragraph 59 asks me to describe any involvement I had in
the financial investigation or confiscation proceedings. I have reviewed these
documents. I note that [POL0049131] is an internal memo that I sent to Dave
Pardoe dated 5.11.07 that summarises the outcome of the financial investigation.
I was not the FI in this case, as far as I can recall, but it was not uncommon to
undertake certain tasks on other cases, for example when someone was on
annual leave, and it may be that I was covering for someone else in their
absence.
Paragraph 60 of the Request refers me to the 2021 judgment of the Court of
Appeal in the case Josephine Hamilton & Others v Post Office Ltd at
[POL00113278] and in particular paragraphs 149-155 which relate to Mr
Thomas' case. To the best of my memory, I did not have any concerns as to how
the prosecution was dealt with at that time.
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86. I have considered very carefully the documents that the Request referred me to
in relation to Mr Thomas's case and I have given particular attention to the email
correspondence I had with Fujitsu regarding Gareth Jenkins’ witness statement.
I have tried to recall to the best of my ability why I became involved to the extent
of providing comments and feedback on the draft statement; as I explained, this
is not something that the Casework Manager would usually have got involved in.
I can only assume that I took it upon myself to respond to the request from Fujitsu
to provide feedback and/or to be helpful, as I had a good working relationship
with Fujitsu. In hindsight, I believe I should have left the content of Gareth
Jenkins' witness statement to him, and my getting involved to the extent that I
did was an error of judgement.
Prosecution of Ms Josephine Hamilton
87. Paragraph 62 of the Request draws my attention to a series of documents and I
am asked at paragraph 61 to give an account of my recollection of the case of
Ms Josephine Hamilton.
88. Paragraph 63 of the Request asks me to describe the circumstances in which I
became involved in the case and paragraph 64 asks me what my role was in this
case. I have reviewed the documents referred to in the Request. I believe my
involvement in this case was limited to obtaining ARQ data and a supporting
witness statement from Fujitsu. The ARQ request which I made on 24.4.06 is at
[POL00045401]; that request also features among the documents contained in
[FUJ00122346].
89. Paragraph 65 of the Request asks me to describe the circumstances in which I
made the ARQ request at [POL00045401] and paragraph 66 asks me to describe
the circumstances in which I requested the witness statement at [FUJ00122346].
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I note the memo that Graham Brander, Investigation Manager, sent to Juliet
McFarlane, Principal Lawyer, dated 11.8.06 (the document at [POL00118610])
describes some enquiries he had made in this case, and he refers to having
spoken to me and that I advised him that a statement could be obtained from
Fujitsu (as he puts it) “covering the fact that the discrepancies would not be due
to system failure".
90. Paragraph 67 of the Request asks me to describe any further involvement I had
in this case. I cannot recall having any further involvement in this case, besides
what I have already described above.
91. Paragraph 68 of the Request refers me to the 2021 judgment of the Court of
Appeal in the case Josephine Hamilton & Others v Post Office Ltd at
[POL00113278] and in particular paragraphs 142-148 which relate to Ms
Hamilton's case. I have reviewed the judgement. To the best of my memory, I
did not have any concerns as to how the prosecution was dealt with at that time.
92. AsIhad very little involvement in this case, I do not believe I am in a position to
comment on the way the investigation and prosecution was conducted.
Prosecution of Mrs Susan Rudkin
93. Paragraph 71 of the Request draws my attention to a series of documents and I
am asked at paragraph 69 to give an account of my recollection of the case of
Mrs Susan Rudkin.
94. Firstly, paragraph 70 of the Request draws my attention in particular to
correspondence between Mr Michael Rudkin and Paul Hemley, Retail Line
Manager in January 2005 (the documents at [POL00060416] and
[POL00061521]) and the incident report at [POL00065265]. The Request asks
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95.
96.
97.
98.
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me if I was aware of the so-called "phantom" banking transactions and the issues
documented in the incident report when I was involved in the prosecution of Mrs
Rudkin. I don't recall having seen this documents and have no recollection of the
"phantom" transactions described.
Paragraph 72 of the Request asks me to describe the circumstances in which I
became involved in the case and paragraph 73 asks me what my role was in this
case. Having read the documents I have been referred to, my belief is that I had
only limited involvement in this case.
Paragraph 74 of the Request asks me to describe my involvement in the financial
investigation and subsequent enforcement proceedings. The Financial
Investigation in this case was primarily conducted by Ged Harbinson. The first
mention in the documents I have reviewed of any involvement I had in this case
is in an email I sent to Jarnail Singh dated 4.8.09 (the document at
[POL00052228)). In this email I set out some information about the service of the
Section 16 prosecution statement and the benefit figure detailed.
Paragraph 75 of the Request refers me to the document at [POL00051248], a
memo from Debbie Helszajn, Principal Lawyer, to the Fraud Team dated 26.3.09,
and I am asked why it was necessary to pursue confiscation if Mr Rudkin was
paying the sum owed to POL (as Debbie Helszajn's memo advised). As I
explained above, I was not the FI in this case, so I cannot explain why it was
thought necessary to pursue confiscation against Mrs Rudkin.
Paragraph 76 of the Request refers me to two documents at [POL00053389] and
[POL00060428] and asks me to explain the circumstances in which Mrs Rudkin
repaid the loss owed to POL; if it is correct that deductions from Mr Rudkin’s
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salary were made to offset against the confiscation order against Mrs Rudkin;
and why I considered that deductions from Mr Rudkin's salary should continue.
As I explained above, I was not the FI in this case, so I cannot explain the
circumstances in which Mrs Rudkin repaid the loss owed to POL, or say if
deductions from Mr Rudkin's salary should continue. I have reviewed the email
exchanges at [POL00053389] where the issue of deductions from Mr Rudkin's
salary was discussed, but I cannot see that I was a party to these discussions,
and so I don't believe I had an opinion about the issue.
99. Paragraph 77 of the Request refers me to the document at [POL00055170], an
email I sent to Marilyn Benjamin dated 16.8.10, and I am asked to describe any
involvement I had in the discussion about the appropriateness of a certificate of
inadequacy and to describe the circumstances in which a certificate of
inadequacy would be considered appropriate. I do not recall the issue described
in this email, so I have to rely entirely on what my email says, and note that I
gave my opinion that a certificate of inadequacy was not the way forward. From
memory, a certificate of inadequacy would only be appropriate if the equity in
available assets had reduced in value. Confiscation Order repayments would be
dealt with by the Regional Asset Recovery teams, so my understanding was that
a decision would need to be made by them.
100. Paragraph 78 of the Request asks me to give my view of how the proceedings
were conducted and paragraph 79 asks me whether, in hindsight, anything
should have been done differently. Bearing in mind I was not the FI in this case,
I don’t feel able to offer a view on how the proceedings were conducted.
Prosecution of Mr Julian Wilson
101. Paragraph 81 of the Request draws my attention to a series of documents and I
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am asked at paragraph 80 to give an account of my recollection of the case of
Mr Julian Wilson.
102. I have reviewed the documents referred to at paragraph 81. I am unable to recall
any details of the case, and I rely entirely on the content of the document at
[POL000044749], the Fl Events Log which documents the progress of this case.
103. Paragraph 82 of the Request asks me to describe the circumstances in which I
became involved in the case. Based on what I recorded in the Fl Events Log, I
first became involved as Fl on receiving the offender report on the 22.9.08, which
detailed admissions made by Mr Wilson during a PACE interview of false
accounting over a five year period.
104. Paragraph 83 of the Request asks me to describe any investigation I conducted
or assisted and any sources of information I considered. I carried out intelligence
enquiries to identify and confirm any available assets and their value. These are
documented in the Fl Events Log.
105. Paragraph 84 of the Request asks me to describe the process by which I
obtained authorization from Ged Harbinson to apply for a restraint order. Ged
Harbinson was the Senior Authorising Officer ("SAO"), and he had undergone
training from the Assets Recovery Agency. As such, he was authorised to
approve applications for Restraint. I am reminded on reviewing the Fl Events Log
that following a discussion with my SAO, Ged Harbinson, and Jarnail Singh on
the 15.12.08, a decision was made to apply for a Restraint Order
106. Paragraph 85 of the Request refers me to the documents at [POL00050726] and
[POL00050878] and asks me to describe the circumstances in which an
application to vary the Restraint Order was made. I have reviewed
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[POL00050726] and [POL00050878] and while I have no direct recollection of
the restraint variation application being made, I note that I had agreed to vary the
original Restraint Order to allow Mr and Mrs Wilson use of their joint accounts,
which were under restraint. I note my entry on the FI Events Log which indicates
the Restraint Order had been varied on 16.2.09.
107. Paragraph 86 of the Request refers me to the document at [POL00051720], a
memo from Jarnail Singh to the Fraud Team dated 28.5.09, and asks if I recall
the advice from counsel referred to in the memo and what further enquiries were
made. I have reviewed the document and note this is a memo into which I am
copied, but which I believe would have been directed at the Investigator in this
case, Gary Thomas, and he would have made the further enquiries. I say this
because there are no entries on my Fl Events Log for 28.5.09, aside from an
account of the details of the charges in this case. I have no recollection of the
counsel's advice referred to in the memo.
108. Paragraph 87 of the Request refers me to the document at [POL00052047],
another memo from Jarnail Singh to the Fraud Team dated 15.7.09 enclosing a
letter dated 9.7.09 from Astwood Law Solicitors, and asks me to describe any
involvement I had in the decision to register a charge on Mr and Mrs Wilson's
remortgage of their property. I have reviewed the document but I have no
recollection of this, aside from what the relevant entries on the Fl Events Log
inform me, which do not record the outcome of any decision to register a charge
on Mr and Mrs Wilson's remortgage. I can only assume from the entry dated
24.7.09, which details an email from Graham Clark, that I consented to the
charge being applied by Lloyds TSB.
109. I note from the last entries on the Fl Events log that the outstanding loss of
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£18,430.50 was repaid in full on 19.5.11 and a discharge of the Restraint Order
was obtained on the 15.9.11.
110. Paragraph 88 of the Request asks me to describe any further involvement I had
in this case. I cannot recall having any further involvement in this case, besides
what I have already described above.
111. Paragraph 89 of the Request refers me to the 2021 judgment of the Court of
Appeal in the case Josephine Hamilton & Others v Post Office Ltd at
[POL00113278] and in particular paragraphs 175-178 which relate to Mr Wilson's
case. I have reviewed the judgment. To the best of my memory, I did not have
any concerns as to how the prosecution was dealt with at that time. My focus
would have been on the financial investigation in my role as FI.
Knowledge of bugs, errors and defects in the Horizon system
112. Paragraph 90 of the Request asks me if I had or was aware of any concerns
regarding the robustness of the Horizon system during the time I worked for POL.
I will say that at no time was I ever aware that the Horizon system had bugs,
errors and defects that could have affected the balancing at a branch. As with
any computer system, I was aware of minor issues, such as Horizon monitors
freezing and terminals having to be re-booted. As I mentioned above in relation
to Mr Thomas' case, the exchanges with Gareth Jenkins in relation to his witness
statement refer to "systems failures" being normal, but I did not consider any of
these to be serious issues which could have affected the integrity of the data held
on the system or which could have affected branch balancing. I was also not
aware prior to the Court of Appeal judgment in the Josephine Hamilton & Others
case that Fujitsu had the ability to insert, edit or delete transaction data, as
detailed at paragraph 49 of the judgment.
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Other matters
113. I have no other issues which I wish to draw to the Chair's attention.
Statement of Truth
I believe the content of this statement to be true.
04 Jan 2024
Dated:
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Index to First Witness Statement of Graham Ward
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No.
URN
Document Description
Control Number
POL00084989
Security & Investigation Financial
Investigation Unit Criminal Debt
Recovery Process, undated
POL-0082047
POL00121975
Email correspondence, 1.11.12
POL-0128225
POL00121639
Presentation "Financial
Investigations Partnership for
Recovery", undated
POL-0127901
POL00121640
Presentation "Financial
Investigations Partnership for
Recovery", undated
POL-0127902
POL00104747
"Investigation Policy Casework
Management", version 1, undated
POL-0080387
POL00104777
"Investigation Policy Casework
Management", version 4, October
2002
POL-0080417
POL00121569
"Guide to the Preparation and
Layout of Investigation Red Label
Case Files - Offender reports &
Discipline reports", undated
POL-0127832
POL00121581
"Guide to the Preparation and
Layout of Investigation Red Label
Case Files - Case File Reports and
Case Closure Reports", undated
POL-0127844
POL00118104
"Identification Codes", undated
VIS00012693
10.
POL00121975
Email correspondence, 1.11.12
POL-0128225
11.
POL00107851
Email correspondence 18.10.05 to
25.10.05
POL-0106089
12.
FUJ00152290
Email correspondence 28.7.06 to
7.8.06
POINQ0158593F
13.
POL00107851
Email correspondence 18.10.05 to
25.10.05
POL-0106089
14.
FUJ00152573
Lee Castleton Civil Case Study -
Document bundle including letters,
investigation report, court
documents and others
POINQ0158768F
15.
POL00071165
Bond Pearce "Personal attendance’
note recording meeting on 6.6.06
POL-0067728
16.
FUJ00152573
Lee Castleton Civil Case Study -
Document bundle including letters,
investigation report, court
documents and others
POINQ0158768F
17.
FUJ00155181
Audit record query dated 24.10.05,
and attached emails
POINQ0161376F
18.
FUJ00122197
Email correspondence 10.3.06 to
23.3.06
POINQ0128411F
36 of 38
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19. FUJ00122204 I Draft Witness Statement of Gareth POINQ0128418F
Jenkins, undated
20. FUJ00122203 I Email correspondence 10.3.06 to POINQ0128417F
23.3.06
21. FUJ00122218 I Draft Witness Statement of Gareth POINQ0128432F
Jenkins, undated
22. FUJ00122217 I Email correspondence 10.3.06 to POINQ0128431F
28.3.06
23. POL00047895 I Draft Witness Statement of Gareth POL-0044374
Jenkins, undated
24. FUJ00122210 I Email correspondence 10.3.06 to POINQ0128424F
24.3.06
25. FUJ00122217 I Email correspondence 10.3.06 to POINQ0128431F
28.3.06
26. I POL00049024 I Memo Juliet McFarlane to Ged POL-0045503
Harbinson, 7.9.07
27. POL00044917 I Email correspondence 23.3.07 to POL-0041396
31.10.07
28. I POL00049131 I Memo Graham Ward to Dave POL-0045610
Pardoe, 5.11.07
29. POL00113278 I Judgment of the Court of Appeal in POL-0110657
Josephine Hamilton & Others v Post
Office Ltd [2021] EWCA Crim 577
30. I POL00045401 I ARQ request, 24.4.06 POL-0041880
31. FUJ00122346 I Various documents, including POINQ0128560F
Witness Statement of Penelope Ann
Thomas, 9.1.07; ARQ request,
24.4.06
32. I POL00118610 I Memo Graham Brander to Juliet POL-0118529
McFarlane, 11.8.06
33. I POLO0060416 I Letter from Michael Rudkin to Paul POL-0056895
Hemley , 14.1.05
34. POL00061521 I Letter from Paul Hemley to Michael POL-0058000
Rudkin, 18.1.05
35. POL00065265 I "Incident Report —- Cash Account POL-0061744
Week 10 (27/05/04 — 02/06/04)"
36. I POL00052228 I Email Graham Ward to Jarnail POL-0048707
Singh, 4.8.09
37. POL00051248 I Memo Debbie Helszajn to the Fraud POL-0047727
Team, 26.3.09
38. POL00053389 I Email correspondence 6.10.09 to POL-0049868
14.10.09
39. POL00060428 I Email correspondence 28.1.10 to POL-0056907
29.1.10
40. POL00055170 I Email Graham Ward to Marilyn POL-0051649
Benjamin, 16.8.10
41. POL00044749 I "Financial Investigation Events Log" POL-0041228
42. POL00050726 I Email correspondence 16.1.09 to POL-0047205
20.1.09
37 of 38
WITN10590100
WITN10590100
43. POL00050878 I Memo Jarnail Singh to the Fraud POL-0047357
Team, POL, 9.2.09
44. POL00051720 I Memo Jarnail Singh to the Fraud POL-0048199
Team, POL, 28.5.09
38 of 38