1 Tuesday, 10 January 2023 2 (10.00 am) 3 SIR WYN WILLIAMS: Good morning, Mr Beer. We're one short 4 here because Ms Eliasson-Norris is unwell today so she 5 will be following either remotely or catching up, as the 6 case may be, depending on how well she feels. 7 MR BEER: Good morning, sir, thank you. Can I call Bruce 8 McNiven, please. 9 JAMES BRUCE McNIVEN (sworn) 10 Questioned by MR BEER 11 MR BEER: Good morning, Mr McNiven. My name is Jason Beer 12 and I ask questions on behalf of the Inquiry. Can you 13 give us your full name, please? 14 A. My name is James Bruce McNiven. 15 Q. Thank you for providing a witness statement to the 16 Inquiry and for attending today. We're very grateful to 17 you for the assistance that you have given to this 18 investigation and will give to this investigation. Can 19 you look please at the hard copy witness statement that 20 should be in front of you, which, excluding the 21 exhibits, I think, is 12 pages in length. For the 22 transcript, the reference is WITN04120100. 23 Look at the last page, page 12. Is that your 24 signature? 25 A. It is. 1 1 Q. Are the contents of that witness statement true to the 2 best of your knowledge and belief? 3 A. They are. 4 Q. A copy of that witness statement will be uploaded to the 5 Inquiry's website, I'm therefore not going to ask you 6 about every part of it. Do you understand? 7 A. I do. 8 Q. Can I start with some questions about your background 9 and experience. I think you were first employed by the 10 Post Office in 1973; is that right? 11 A. That's correct. 12 Q. Did you have a background before then? 13 A. A background before then was largely in science-related 14 businesses and then I converted to general management. 15 Q. Did you have any qualifications in management or 16 similar? 17 A. I was a member of the Institute of what was then 18 Personnel Management, now Human Resources. 19 Q. In 1986 I think you became the district manager of for 20 Post Office Counters in Newcastle; is that right? 21 A. Correct. 22 Q. And in 1993 you became head of the retail network for 23 the north-east area; is that right? 24 A. That's correct. 25 Q. In 1996 you became the Deputy Director of the Programme 2 1 Delivery Authority, known as the PDA, and responsible, 2 therefore, for elements of the delivery of the Horizon 3 System; is that correct? 4 A. That is correct. 5 Q. Was that a promotion? 6 A. Yes, it was. 7 Q. Can you tell us the role and purpose of the PDA, please? 8 A. The PDA was set up to represent the parties to the 9 contract, DSS and the Post Office, and to interface with 10 ICL Pathway on the delivery of the solution which was 11 contained within that contract. 12 Q. How many people worked in the PDA? 13 A. In terms of direct employed people probably of the order 14 of 100. The majority, I would say, were from Benefits 15 Agency, some 40 or so staff from Post Office Counters 16 and also a number of contracted people and advisers from 17 outside concerns such as accountancy. 18 Q. Who was your line manager or senior within the PDA? 19 A. Yes, the PDA director was a chap called Peter Crahan who 20 had been appointed by DSS. 21 Q. And that's C-R-E-H-A-N? 22 A. C-R-A-H-A-N. 23 Q. He was, as you said, a DSS or Benefits Agency employee; 24 is that right? 25 A. That's correct, yes. 3 1 Q. So would you describe him as your line manager? 2 A. Yes, very much so. His title was Director of the 3 Programme Delivery Authority and I was Deputy Director 4 of the Programme Delivery Authority. 5 Q. Who was responsible out of the pair of you for reporting 6 back to the Post Office as to the work of the PDA? 7 A. We were jointly responsible through the PDA board, which 8 comprised directors from both Benefits Agency and Post 9 Office Counters. 10 Q. You tell us in your witness statement -- there's no need 11 to look at it up at the moment (it's paragraph 6) -- 12 that you reported back to the joint BA/PO programme 13 board. 14 A. Yes. 15 Q. How did the pair of you report back jointly to that 16 programme board? 17 A. Peter would take the lead in terms of the overall 18 progress of the solution with Pathway. I would report 19 back on areas within more of my responsibility, such as 20 progress on implementation plans, rollout plans and, 21 generally speaking, the work being done by the Post 22 Office constituent of the PDA. 23 Q. Did the BA/Post Office programme board have regular 24 meetings? 25 A. Yes, at least monthly. 4 1 Q. Would you report to that board in writing? 2 A. There would be a written report to the board and then we 3 would take questions on the day. 4 Q. Was there any other reporting mechanism to the board or 5 was that the principal way in which reporting was 6 effected? 7 A. That was the principal way in which reporting was 8 effected. I had, obviously, conversations and dotted 9 line responsibility back into Post Office Counters 10 Limited, with whom I would have conversations with 11 people like Paul Rich, et cetera, who might just ask 12 advice on certain aspects. 13 Q. That's what I want to ask you about in particular, what 14 that dotted line consisted of and to whom it went, 15 ie outside of the programme board. 16 A. Yes. 17 Q. Just sticking with the programme board for the moment, 18 what was the purpose of the programme board? 19 A. The programme board was there to confirm that progress 20 was being made relative to the contract with ICL 21 Pathway, to deal with any problems which were arising, 22 particularly around the release of software and the 23 programme behind that release, and to ensure that 24 Benefits Agency were aware of that progress, so that 25 they could modify or accelerate their plans accordingly. 5 1 Q. Was it a decision-making body? 2 A. It was a decision-making body in terms of requiring 3 myself or Peter or other members of the PDA to take 4 issues back to ICL Pathway and to resolve them as they 5 felt appropriate. 6 Q. Did it have any broader decision-making role than that, 7 ie -- 8 A. Is this the board still -- the board we're talking 9 about? 10 Q. Yes, the board. 11 A. I think that the board would exercise -- ultimately 12 exercise an authority about the extent to which they 13 were convinced by the progress; they held an authority 14 about whether or not the programme should continue (that 15 would be something done with the joint sponsors); and 16 they had a responsibility for ensuring that ICL Pathway 17 were held accountable for the progress of the programme. 18 Q. Who from the Post Office can you recall as being 19 a member of the programme board? 20 A. Paul Rich was a member of the programme board. He was 21 a principal member of the programme board. 22 Q. Anyone else you can recall now? 23 A. Not directly. He would report back to the managing 24 director of Post Office Counters Limited. 25 Q. That was the next question: to whom did the programme 6 1 board report? 2 A. The programme board then separately would report back to 3 the sponsor organisations (so Post Office Counters 4 Limited board on one hand, the DSS board on the other) 5 and they would then take, I guess, informed 6 decision-making from them back to the programme 7 development board to instruct us and to instruct Pathway 8 about the process which should then follow and the 9 extent to which progress was being made. 10 Q. So was it a reporting board, ie used to pool information 11 from the Programme Delivery Authority and then act as 12 a conduit back to the main boards of each 13 organisation -- 14 A. Yes, I think that's -- 15 Q. -- or did it enjoy its own decision-making powers? 16 A. I would say a combination of the two. I think the PDA 17 board were conscious that they were representing the two 18 contracted authorities and that the two contracted 19 authorities had the ultimate decision-making. So they 20 would be helping the contracted authorities to 21 understand the extent to which the contract was being 22 moved forward and delivered. 23 Q. Had you worked in the delivery of a project with a large 24 company like ICL Pathway or Fujitsu previously? 25 A. No. It was a new experience for me. 7 1 Q. Had you worked on the delivery of a large project that 2 involved a Private Finance Initiative contract before? 3 A. No, I had not. 4 Q. Had anyone on the PDA, to your knowledge? 5 A. Not to my knowledge. 6 Q. Had anyone within the programme board, to your 7 knowledge? 8 A. Not to my knowledge. 9 Q. I think you subsequently became general manager of the 10 Horizon implementation team; is that right? 11 A. Yes. When the PDA was wound up and responsibility was 12 moved back to the host businesses, I moved back with 13 that title and that responsibility. 14 Q. When was that, please? 15 A. I think the last PDA board meeting was towards the end 16 of 1998. I would say September 1998. 17 Q. Then you became general manager of the Horizon 18 implementation team? 19 A. That's correct. 20 Q. Was that a role within the Post Office alone? 21 A. Indeed, yes. 22 Q. Was that a promotion? 23 A. No, that was a sideways move. 24 Q. What was the role and purpose of the Horizon 25 implementation team? 8 1 A. The Horizon implementation team largely focused on the 2 actual physical rollout mechanism. So helping to enable 3 the office surveys that had to be proceeded with before 4 an office could be converted, with any physical 5 modifications that were required at those offices, with 6 the actual commissioning going live with individual 7 offices, and playing all that into the joint programme 8 that existed between the Post Office and Pathway. 9 Q. How many people were in the Horizon implementation team? 10 A. I would say between 40 and 50. 11 Q. Who was your line manager or to whom did you report? 12 A. Then I would report to Dave Miller. 13 Q. Were you, therefore, in charge of the Horizon 14 implementation team? 15 A. Yes. 16 Q. So you were responsible for the management of that 40 or 17 50 people? 18 A. I was, yes. 19 Q. I think your role in relation to the Horizon System 20 ended at some point in 1999; is that right? 21 A. That's correct, yes. 22 Q. Can you help us as to precisely when, not necessarily 23 a date but maybe a month? 24 A. Yes, I think it was probably December 1999 when 25 arrangements were in place to renew the rollout in 9 1 January of the following year. 2 Q. Why did you move on in December 1999? 3 A. I think roles changed. I think on the ground there were 4 people there who had responsibility for the field 5 implementation. Many things were in place to renew the 6 rollout. So, really, the job had transferred into its 7 component parts and the role that I specifically had did 8 not have the same strength of purpose. 9 Q. As in nobody took over from you? 10 A. Not immediately. A person who worked for me, I think, 11 his role was expanded to the Horizon field 12 implementation role. I think latterly someone else from 13 the business was brought in to perhaps take over some of 14 the former responsibilities I had and to provide a more 15 direct management input to the team. 16 Q. Did you report back to the Post Office Board in that 17 role? 18 A. No. 19 Q. Did you report back to the Post Office Counters Limited 20 board in that role? 21 A. Not directly. I reported back to Dave Miller, who was 22 member of the Post Office Counters board, through 23 a Horizon management team that he chaired, of which 24 I was a member. 25 Q. How regularly did that body meet? 10 1 A. Latterly, at least a month formally but the same people 2 would be drawn together probably almost on a weekly 3 basis because of the pace of events by that time. 4 Q. How did you understand that reports back to the Post 5 Office Counters Limited board were made? 6 A. We all made our constituent parts. So I would perhaps 7 write about or contribute to a report about the pace of 8 rollout, the readiness of the Post Office estate, the 9 situation regarding training, et cetera; so I would 10 report back on my individual responsibilities. Other 11 people would do the same and it would be combined into 12 a full report. 13 Q. Looking back now, having had the benefit of some years 14 of reflection, what would be your overriding view of the 15 work of the Programme Delivery Authority? 16 A. I think the work of the Programme Delivery Authority did 17 as well as it could within the constraints it was 18 working under. I think there was a will to work 19 together. The staff in the PDA, both POCL and BA worked 20 well together, but we were conscious that we were a bit 21 of a forced marriage. We had somewhat different 22 objectives. I think that was always realised. So we 23 were trying to make the best of what we had. 24 I think as the Programme Delivery Authority 25 developed and just before they split back into their 11 1 host organisations, it was becoming increasingly 2 difficult, I have to say, because the objectives of each 3 party were beginning to move further and further apart. 4 Q. You said that it worked well, given the constrains under 5 which it was working or the constraints it was working 6 under. What were those constraints? Were they only 7 different objectives or were there other constraints? 8 A. No, I think they were principally about different 9 objectives which were becoming clearer as time passed. 10 I mean, the other constraints within which it worked was 11 the whole relationship with ICL Pathway, which I think 12 has been rehearsed previously by other witnesses, and 13 that was a constant source of frustration. 14 Q. Why was it a source of frustration? 15 A. The inability -- well, the PFI contract was the primary 16 barrier. The role we had in the PDA was one of 17 assurance, so -- and largely documented assurance before 18 we could actually see anything developing. So a set of 19 requirements would be translated by ICL Pathway into 20 a solution. That solution would be recorded and 21 documented and the role we largely had, certainly from 22 a POCL perspective, was to try and understand what they 23 intended to do and to try and assure that their 24 intentions met the requirements. 25 As I say, often this was a nebulous process based 12 1 on a document before we could actually see things 2 operating. 3 So it was frustrating and trying to get behind 4 that to find out a bit more about the processes, the 5 thinking, how that was going to come together, was 6 extremely difficult. Now, I'm talking particularly from 7 a POCL interest here but, working with the Benefits 8 Agency, I was party to their frustrations as well as not 9 seeing how things were developing and the constant 10 requirement for re-plans. 11 I think my first six months to a year of working 12 at the PDA was almost entirely involved in re-planning 13 exercises as the timescale slipped, so new plans had to 14 then be devised. That had impact onto the 15 implementation and rollout plans of course, of which 16 I had a particular interest, but I think within that 17 first year this happened three times. So that was 18 a very frustrating aspect. 19 Q. Any other reflections overall on the way in which the 20 PDA works or how it functioned or the pressures under 21 which you were operating? 22 A. Along with Peter Crahan I met frequently with ICL 23 Pathway, normally at their premises, and we would go 24 through a long list of issues that were arising. They 25 were as helpful, I think, as they could be but it was 13 1 becoming clear that their development processes were 2 lagging behind and all we could do was take back as much 3 information as we could and try to understand how lags 4 in that process were going to impact on the plans which 5 we had developed. 6 It was difficult. I don't think through any 7 ill-will. I think Pathway's perspective on our 8 assurance was probably that we strayed too far into 9 interference and I think that constant tension was 10 always there. 11 Q. Given what you've mentioned as to the fundamentally 12 different objectives of the two client contracting 13 parties and constant frustrations with the way that ICL 14 was operating and working and delivering, why did, in 15 your view, the project proceed? Why was it not brought 16 to a stop? 17 A. Well, it was brought to a stop in terms of its initial 18 condition. I mean, the joint programme was brought to 19 a stop by BA when they essentially withdrew from the 20 programme. So there was a point, I guess, in 1998 where 21 Post Office Counters had to decide whether to continue 22 a relationship with ICL Pathway to get something over 23 the line, which was to the Post Office's benefit, or to 24 withdraw and there were many, many discussions around 25 this subject. 14 1 The decision, obviously, eventually was taken that 2 it was in Post Office's interest to continue because to 3 stop and try and restart the whole process would put 4 POCL so far behind the momentum of the DSS to move to 5 different payment methods that we would probably never 6 catch up. 7 They had withdrawn from the card payment process, 8 which is where we had come in. That was seen to be the 9 way ahead for both parties. Very quickly, I think it 10 became apparent that DSS did not favour that solution. 11 I think that position was amplified by a change of 12 Government. I think when the Blair Government came in 13 in May 1997 they had a vision of social inclusion which 14 was about people having bank accounts rather than 15 physical payment methods over a post office counter and 16 I think DSS regarded that as the way ahead. 17 So what we were trying to develop with Benefits 18 Agency was something which was to preserve the Post 19 Office position for as long as we possibly could until 20 we could adopt a technological solution which would 21 allow us to work alongside those decisions. 22 So, ultimately, the decision was taken that, 23 without technology and without technology soon and 24 without the technology which had at least in part been 25 developed, the whole future of the Post Office, as it 15 1 was constituted, was very much in doubt. 2 Q. You sat in your position, I think, would this be right, 3 in a space between directors and executives on the one 4 hand -- so the very senior management of POCL -- and 5 those responsible at a lower level on the ground for 6 actual delivery. 7 A. Yes. 8 Q. Did you feel any pressures from above to ensure that 9 this project proceeded? 10 A. At the point at which I have been talking, when BA 11 withdrew, the pressure was the pressure of continuity, 12 that we had something to deliver, that we had a business 13 at the end, and that was significant and I think people 14 signed up to that concept. As we go further downstream 15 towards the whole process of acceptance of the then ICL 16 Pathway solution for Post Office Counters, I think the 17 pressures changed. I think we still had that pressure 18 to deliver something for the future of the business. 19 Q. In what way did the pressures change? We're talking 20 here from April '99 onwards? 21 A. Yes. I think as part of -- if I can step back, when 22 I was working for the PDA, the impetus was from the PDA 23 to Pathway to get something done. When Post Office took 24 on the contract, very quickly, I think, the impetus 25 changed to being from ICL and Pathway to get this thing 16 1 over the line as soon as possible because, quite 2 clearly, it was clear to us, there were enormous 3 pressures on Pathway and the people in Pathway to get 4 this delivered because of the pressures on ICL and 5 Fujitsu, given the background and the degree of finance 6 they had put into the project. 7 Q. This switch, am I understanding it correctly, to say 8 that it was a move from pressure being placed on ICL to 9 a pressure coming from ICL for contractual and fiscal 10 reasons? 11 A. I think, in the broadest sense, that's probably true. 12 There was still pressure from ourselves in Post Office 13 Counters back to ICL Pathway in terms of this whole 14 aspect of assurance and making sure that what they were 15 delivering was fit for purpose. So we had these 16 competing pressures of ICL Pathway wanting to move this 17 contractually over a line at which they were paid and 18 most of us on the ground in Post Office Counters trying 19 to ensure that what was being delivered was of 20 a satisfactory quality to allow that to happen. 21 I mean, also I think at the time we were all -- we 22 all knew everything else that was happening, the 23 Treasury review, there was a political interest. So, 24 although these things were happening at a different 25 level, at the working level contact with ICL Pathway 17 1 these were quite apparent. 2 Q. In what way -- 3 A. In -- 4 Q. -- were they tangible? 5 A. In the way in which we were -- Post Office Counters was 6 under pressure perhaps to accept conditional changes to 7 whatever it was, training or software or whatever, to 8 get to that point of acceptance. 9 Q. Just explain what you mean there. I think I understand 10 it but for those that may not. So a pressure to accept 11 conditional changes to get to acceptance? 12 A. So the key process as the development with Pathway 13 proceeded, as a Post Office solution, began to focus on 14 contractual acceptance; that is, the conditions under 15 which Post Office Counters would say "Yes, we accept the 16 solution and, because of that, we will meet certain 17 contractual conditions about payment". So we were aware 18 of that. 19 The individuals concerned as well, on the Pathway 20 side, were obviously working under pressure to get this 21 done. Again, I think there was goodwill to try and get 22 it done as well as possible and I think that many of my 23 colleagues in Post Office Counters did enormously good 24 work to try and ensure that we had a satisfactory 25 solution and outcome. 18 1 Q. Can we now look at some of the material with that 2 background in mind. There are a large number of 3 documents that might be raised with you concerning your 4 earlier involvement in the project between '96 and '98. 5 I'm not going to go through all of those because they 6 principally relate to what we call Phase 2 matters, 7 which have already been addressed with other witnesses 8 and, in the interests of proportionality, it's more 9 important that we concentrate on the Phase 3 issues. 10 There are a few exceptions to that, which I just 11 want to look at now, please. Can we look at 12 POL00028591. It will come up on the screen. 13 Thank you very much. 14 This is a Post Office Counters Limited service 15 management report. 16 A. Yes. 17 Q. I think you'll be familiar with the style of the 18 document. 19 A. Yes. 20 Q. You will see that this one is dated 30 June 1998 and it 21 relates to the period of May 1998. You'll see the 22 author is Dennis Wong, who, in the bottom left, is 23 described as a Horizon performance analyst, and we can 24 see the distribution list that includes you, first 25 column, fourth down. 19 1 A. Sure. 2 Q. So this is before the Benefits Agency withdrew from the 3 project -- 4 A. Indeed. 5 Q. -- May '98? 6 A. Yes. 7 Q. Can we look at page 6 of the document, please. We're 8 dealing here with the Benefit Payment System, so the BA 9 part. Under the sub-heading "Lost Transactions (LT)" 10 the document reads: 11 "A baseline has been introduced this month to 12 regularly indicate current levels of [lost transactions] 13 in an easily readable form. This has been carried out 14 to reflect TP ..." 15 I think that's transaction processing; is that 16 right? 17 A. That's correct, yes. 18 Q. What was transaction processing? 19 A. Transaction processing was a unit within Post Office 20 Counters which derived information from the cash 21 accounts to produce the Post Office accounts. 22 Q. Thank you: 23 "... and Service Management concerns. These 24 concerns are that current levels, while presently 25 manageable, may not be acceptable to the business when 20 1 large volumes of encashments are returned by newly 2 automating post offices. [Lost transactions] indicate, 3 when extrapolated (for BES only) ..." 4 That's the Benefit Encashment Service; is that 5 right? 6 A. That's correct. 7 Q. "... volumes that may be startling in the live service. 8 It is worth noting however, that caution needs to be 9 exercised when viewing raw figures as there may be 10 variables and arguments that might effect 11 extrapolations." 12 That's a relatively significant warning, isn't it? 13 A. It's a significant warning from a low level volume of 14 encashments at an early stage of development. But it's 15 a signal that there is something not right. 16 Q. It was essentially being based on what was being seen in 17 the operation of the Horizon System in relation to the 18 Benefit Payment System? 19 A. That's correct. 20 Q. We're here about 18 months or so before national 21 rollout; is that right? 22 A. Yes. 23 Q. Can we look, please, next at POL00028589, and the same 24 style of document. This one is dated 28 July 1998, 25 I think produced by Mr Turnock, a Horizon performance 21 1 manager. Did he work under you? 2 A. Not directly, no. 3 Q. We can see that this relates to the period of June 1998; 4 so the period following the one that we just looked at. 5 A. Mm-hm. 6 Q. Again, you are on the distribution list. 7 A. Yes. 8 Q. Again, if we just look at page 6 of the document and 9 you'll see that under the same heading "Benefit Payment 10 System", the title of "lost transactions", as the text 11 says, has been changed to "incomplete transactions", as: 12 "This is considered to be a better description of 13 the problem. To date all transactions have been 14 recovered by manual fallback." 15 Then the second paragraph: 16 "It has been agreed both POCL and ICL Pathway that 17 the current levels of incomplete transactions is not 18 acceptable for a system where the primary function is to 19 record and manage transactions." 20 Just looking at that, that's obviously right -- 21 something that you would agree with -- 22 A. It did, yes. 23 Q. -- that lost or incomplete transactions is not at all 24 acceptable for a system whose raison d'etre is to record 25 and manage transactions? 22 1 A. That's correct. 2 Q. "From a POCL perspective it would seem reasonable to 3 expect that the Horizon System has integral safeguards 4 to protect and preserve transaction data." 5 No doubt you would agree with that sentence too? 6 It's not unreasonable for the Post Office to expect that 7 the Horizon System had safeguards within it, that were 8 integral to it, to protect and preserve transaction 9 data? 10 A. Absolutely fundamental, yes. 11 Q. "Integrity, consistency and durability are fundamental 12 requirements of any transaction processing IT system." 13 Again, I think you would agree with that as 14 a principal, that integrity, consistency and durability 15 are indeed fundamental requirements of a system such as 16 this? 17 A. Absolutely. 18 Q. "As it is, there seems to be a variety of situations 19 where the system reacts unpredictably and loses data." 20 Again, that must have been of significant concern? 21 A. Of course it was and these are issues arising in live 22 operation and some of these would be reflected back in 23 the testing arena and I've no doubt that they would be 24 being picked up there as well and conversations would be 25 taking place between people in model office testing and 23 1 ICL about digging underneath the issues that arise here, 2 so that solutions might be found. 3 Q. These two documents that we've looked at look at the 4 issue of the importance of integrity, consistency and 5 durability from the context of a transaction processing 6 system. 7 A. Mm-hm. 8 Q. Were you ever aware that one of the core requirements of 9 the system was for data that it produced to be available 10 to support investigations and prosecutions? 11 A. Yes, it's a good question. I mean, I think there is 12 documentation along the way that refers to the role of 13 audit in the process and how audit managers would 14 understand the system, how they could interact and 15 investigate the system. I mean, beyond that, I know 16 that they were part of the training aspect that they 17 received enhanced training about the use of the system 18 and I think there was an additional module about how 19 they could interrogate the system. 20 But, yes, of course it is important that they had 21 that access. 22 Q. Just thinking about the question more directly, were you 23 aware at this time that one of the core requirements of 24 the system was for it to produce data that had 25 sufficient integrity to support investigations and 24 1 prosecutions? 2 A. I don't think I was conscious of that in the way in 3 which you have expressed it. I was very conscious of 4 the requirement for the whole system to have data 5 integrity. I was not specifically focused on the 6 requirement for that to reflect into the audit process. 7 Q. Was that, in your time on the Programme Delivery 8 Authority and then as general manager of the Horizon 9 implementation team, ever discussed, ie the issue looked 10 at from that angle? 11 A. Not to my recollection. 12 Q. Did you know that the Post Office had the facility to 13 and, indeed, did prosecute its own subpostmasters and 14 other staff for criminal offences? 15 A. Yes, indeed. When I was a local manager, I was often 16 involved in the decision taken along that line towards 17 prosecution. Local management were a key component. 18 Q. In what way were local management a key component? 19 A. Well, if the audit team had been into an office and 20 found discrepancies, that would be reported back to the 21 local management. So, ultimately, dependent upon the 22 decision required, it could reach the head of retail 23 network, who was a senior man in charge of the field 24 force, or when I was district manager I was often 25 involved in decision-making of that sort. 25 1 So there was a check process that said, "Yes, 2 audit have found this, this is what we found" and, very 3 often as a manager, I would interview the subpostmaster 4 concerned, and very often they would have the support of 5 the Federation of SubPostmasters' representative and 6 I would go through the whole thing with them about how 7 this had arisen, what were the issues behind it, were 8 there any mitigating circumstances. 9 So, at that time, line management had a key role 10 to play in the prosecution decision. 11 Q. What role did line management play? You mentioned 12 interviewing and talking it through with the 13 subpostmaster. Did they have a role in decision-making 14 as to prosecution? 15 A. Yes. 16 Q. What role did they have in relation to decision-making? 17 A. Ultimately, they would endorse a decision to prosecute. 18 I mean, it would be taken by the audit people with the 19 legal stream within Post Office Counters but it was, 20 I think, inherently important, and written into the 21 arrangement, that the local manager had sight of and 22 endorsed the decision. 23 Q. Do you mean by that that they always endorsed? 24 A. Oh no, no, not at all. In fact, again, I recall, as 25 a district manager, there was an arrangement whereby if 26 1 the Federation representatives felt that the case was 2 wrong, the decision was wrong in district A, there was 3 an appeal process and some of us from district offices 4 outwith that decision-making could be called in to hear 5 appeal. 6 So we exercised a kind of independent perspective, 7 bringing knowledge from our own experience into that 8 decision-making process and I'm pretty sure from my 9 experience that there were occasions whereby the appeal 10 manager might say "I'm not sure this is right, I'm not 11 sure it's the right decision, I'm not sure about the 12 degree of the severity of the decision and maybe you 13 should go back and have a look at other aspects". 14 So there were checks and balances, I think, is 15 what I'm trying to say. 16 Q. With that knowledge that you had and that role that you 17 performed, wouldn't it have been obvious to you, 18 therefore, when you became Deputy Director of the PDA 19 and then general manager of the implementation team, 20 that the Horizon data would be used for the purpose of 21 investigation and potentially prosecution? 22 A. Inevitably it would be used. It was a source of the 23 accounting process. As I said before though, I was not 24 aware of any concerns from the audit community about 25 their engagement with this and, of course, I'm saying 27 1 all this on the understanding that the system was 2 sufficiently robust to be providing information which 3 was sufficiently supportive of these decisions. 4 Q. Why -- 5 A. That would be my belief. 6 Q. On what basis did you reach that understanding, as you 7 called it? 8 A. Of what -- my view of it? 9 Q. Yes. You said that -- you were saying it on the 10 understanding that the system was sufficiently robust to 11 produce reliable data. Where did you get that 12 understanding from? 13 A. I had no reason to doubt that it had. 14 Q. So it was a presumption of rectitude? 15 A. It was a presumption of rectitude, at the point at which 16 we reached when acceptance was given to the Horizon 17 System. 18 Q. Was that ever tested, the presumption? 19 A. The presumption of the information being sufficiently 20 robust to support prosecution? 21 Q. Yes. 22 A. Not as such. The presumption was that the information 23 was sufficiently robust for business purposes. 24 Q. In your role in the PDA and then the HIT, as I am going 25 to call it -- Horizon Implementation Team -- to your 28 1 knowledge, was anyone from audit investigation or 2 prosecution involved in discussions as to the 3 requirements of the system in order to produce data that 4 had sufficient reliability and integrity for criminal 5 justice purposes? 6 A. I'm afraid not to my knowledge -- not within the area in 7 which I was operating. 8 Q. If they had had involvement in the design of the system 9 the specification of the requirements and ensuring that 10 they were being delivered, I think in your roles in the 11 PDA and the HIT you would have known about it? 12 A. I'm sure that there was a requirement in the 13 requirements index of the contract that referred to this 14 availability in this report but, to be -- I really 15 cannot recall it. 16 Q. That requirement that you're referring to, is that 17 something that you now remember because you've seen the 18 process of the Inquiry unfold over the last three or 19 four months and seen people ask questions about it? 20 A. In any of the roles in which I was involved, I don't 21 think I was ever at any stage consciously aware of the 22 audit requirement or specifically focused on an audit 23 requirement and ensuring that that was delivered. 24 Q. So just looking, sorry, back at this document here and 25 that second paragraph, at the end of it, where it 29 1 records that there seem to be a variety of situations 2 where the system reacts unpredictably and loses data, 3 you said that that's the system in operation in live 4 time, not model office testing or other types of 5 testing. 6 To your knowledge, were these lost or incomplete 7 transactions on the BPS (Benefit Payment System) ever 8 seen as relevant to or a threat to the accounting 9 integrity of the system on the POCL side? 10 A. I'm sure they would be. Again, from my recollection and 11 knowledge, I can only presume that it would be. 12 I cannot comment beyond that. 13 Q. Can we look on please, moving the story forwards, to 14 POL00090839 and the second page, please. Just give me 15 a moment to catch up in my hard copy. 16 You will see this is a letter dated 17 23 August 1999 -- top right -- from Ernst & Young, the 18 well known auditors and accountants, to David Miller. 19 I think he was the MD of POCL at that time; is that 20 right? 21 A. No, I don't think -- no Stuart Sweetman would be the 22 managing director, I believe. 23 Q. Yes, quite right. 24 A. So Dave Miller would still be director of counter 25 automation. 30 1 Q. You will see the handwriting in the middle of the top of 2 the page, where Mr Miller, it seems, has added a note. 3 Do you see where it says "DWM", underneath that that is 4 Mr Miller's signature -- 5 A. Right. 6 Q. -- that's been redacted for data protection reasons and 7 his note is dated 24 August 1999, so the day after the 8 letter. You will see that it addresses the letter to 9 you. 10 A. Mm-hm. 11 Q. "1. Bruce McNiven 12 "2. Keith Baines ..." 13 There's a tick through your name. Would that be 14 done to record that you had been sent it or received it? 15 A. I should assume so, yes. 16 Q. Thank you. He says: 17 "... Mr Miller. 18 "Please ensure that these issues are fully 19 addressed during the remaining acceptance process. Keep 20 me in touch." 21 If we look at the letter itself, Ernst & Young 22 say: 23 "As auditors of The Post Office we have been asked 24 by [POCL] to provide you with our views in respect of 25 certain accounting integrity issues ... from tests 31 1 performed by POCL on Horizon data in the live trial." 2 We can skip the next paragraph. Paragraph 3: 3 "The live trial is limited to 323 outlets. We 4 make our comments on the assumption that this sample of 5 outlets will be representative of the full network of 6 outlets." 7 Then paragraph 4, if we scroll down, thank you: 8 "The following issue, as described to us by POCL 9 gives us concern as to the ability of POCL to produce 10 statutory accounts to a suitable degree of integrity. 11 We understand that POCL has attributed a severity ... of 12 "High" to this matter." 13 Paragraph 5: 14 "Incident 376. Data integrity -- In order to test 15 the integrity of weekly polling of Horizon cash account 16 transactions, POCL are reconstructing a weekly total by 17 outlet from daily Horizon pollings. At present this 18 control test is showing discrepancies in that certain 19 transactions do not record the full set of attributes 20 and this results in the whole transaction being lost 21 from the daily polling." 22 To your knowledge, was that the same or 23 a different issue, this time in relation to the Horizon 24 System being operated by POCL, not the Benefits Agency, 25 that we just looked at? 32 1 A. The one previously was the Initial Go Live offices of 2 which there were relatively few and they were only doing 3 business encashment for child benefit. 4 Q. I realise the difference in subject matter. 5 A. Sorry, I beg your pardon. 6 Q. My question was: was the issue the same, to your 7 knowledge? 8 A. To my knowledge, the issue was the same in terms of 9 outcomes, in that, if there was a discrepancy between 10 the two, that was a serious problem. 11 Q. But the reasons for it you don't know -- is this 12 right -- one way or the other the technical reasons for 13 the outcome are the same or different? 14 A. Honestly, I don't know. 15 Q. In the last paragraph -- sorry, in the penultimate 16 paragraph on the page, Ernst & Young say: 17 "We are informed that an incident has also 18 occurred where- transactional data committed at the 19 counter has been lost by Pathway system during the 20 creation of the outlet cash account and has not 21 therefore been passed to TIP in the weekly cash account 22 subfiles. 23 "Both types of incident result in a lack of 24 integrity on each of the two data streams used by POCL 25 to populate its central accounting systems. We 33 1 understand that the cash account data stream is the 2 primary feed for POCL's main ledgers and client 3 reconciliation [purposes]." 4 Then over the page, similar language used in the 5 second paragraph on the page to the language we have 6 been reading: 7 "It is a fundamental of any accounting system that 8 it provides a complete and accurate record of all 9 transactions. These discrepancies suggest that the ICL 10 Pathway system is currently not supporting this 11 fundamental." 12 Then skipping a paragraph: 13 "The nature of the gaps in both the cash account 14 and transaction data streams is such that POCL believe 15 that they would not be able readily to explain them, and 16 that significant balances might have to be written off 17 to the profit and loss account." 18 Then it goes tong deal with the impact of all of 19 that on the auditors' opinion on the statutory accounts. 20 The message being given by Ernst & Young here is 21 very similar to the message being delivered by the 22 analyst the year before. 23 A. Yes. 24 Q. Never mind from an auditing or accounting perspective, 25 did this letter cause you and the senior management of 34 1 POCL to stop, take stock and say "Hold on, this system 2 has fundamentally insufficient integrity and ought not 3 to be rolled out"? 4 A. Yes, simple answer to that is yes, and this issue and 5 some others became the final focus of the acceptance 6 process, and Keith Baines and the commercial team put in 7 a huge amount of work to try and ensure that the 8 contract, as it existed, as we moved forward, still 9 retained the right of Post Office Counters to ensure 10 that this question of derived cash accounts and office 11 cash accounts actually matched was proven at a point at 12 which acceptance was given and was given conditional to 13 this being one of the conditions that was given to 14 acceptance, and that continuing resolution would carry 15 on and be proven to Post Office Counters Limited before 16 further rollout took place. 17 So the contract, as I understand it, I'm trying to 18 remember, had various iterations as it went through and, 19 as these things arose, there were codicils or additions 20 put into the contract that said "We still will not 21 accept, we still will not go to rollout, until these 22 conditions are met". I do believe it was made clear in 23 contractual terms about the seriousness of these issues 24 and the impact that they would have on both acceptance 25 and rollout. Work went on this continuously, beyond my 35 1 being there, in fairness. Working trying to prove that 2 this would operate properly was still going on. 3 Q. Even that point of you leaving in December '99? 4 A. Yes, beyond that. I think it went into January. When 5 the decision to take the next phase of roll-out, which 6 commenced at the end of January/early February, I think 7 the proof that this was no longer an ongoing issue was 8 still being looked at. 9 Q. So, essentially, the answer is, yes, it was realised 10 that this was a fundamental problem, it was addressed 11 through amendments to the contract that introduced 12 acceptance criteria -- 13 A. That's correct. 14 Q. -- that related to it? 15 A. Absolutely. 16 Q. So, in short, we find the answer in the second and third 17 supplemental agreements. You have referred to them as 18 codicils? 19 A. Yes, yes. 20 Q. I am not going to take you through, we have been through 21 the second and third supplemental agreements extensively 22 but I just want to look at acceptance, faults and the 23 approach to acceptance and can we start, please, at 24 POL00028429. 25 You'll see that on 4 December Andrew Simpkins, 36 1 said to be of Horizon release management, wrote to 2 a number of key figures in POCL and, indeed, ICL 3 Pathway, I think, on that list. 4 A. Yes. 5 Q. What was Horizon release management? 6 A. As I recall, Horizon release management was looking at 7 it from a POCL perspective about the conditions being 8 put on acceptance and the way in which those conditions 9 were going to be met. 10 Q. Was Mr Simpkins in charge of it? 11 A. Yes, he was. 12 Q. So it was responsible for the management of the 13 acceptance criteria? 14 A. As I understand it, yes. 15 Q. You see this memo is copied to you just on the 16 right-hand side, underneath the two GRO redactions, and 17 underneath the title of "Horizon Testing and Programme 18 Plan -- Current Status", there's an abstract: 19 "This memo summarises progress made in the last 20 week, the agreed next steps, and issues for management 21 attention, and highlights the continuing uncertainty 22 between ourselves and Pathway with regard to the testing 23 plan." 24 You'll see under "Progress this Week", if you just 25 read that to yourself -- 37 1 A. Mmm. (Pause) 2 Q. -- that it highlights some problems including testing, 3 including in relation to, as we go through the memo, 4 EPOSS and the TIP interface? 5 A. Mm-hm. 6 Q. It includes problems concerning cash account imbalances 7 and problems with reference data and code problems. 8 A. Yes. 9 Q. Then if we go to the third page, please, under "Impact 10 on Plan", and if we look at the third line, Mr Simpkins 11 says: 12 "We do not have however an understanding of 13 Pathway's prognosis for fault clearances which would 14 help inform this assessment nor an alternative proposal 15 from them as to how this confidence could be achieved in 16 a faster timescale." 17 Then three lines on: 18 "Our position remains, however, that based on the 19 nature of the business processes involved, we need to 20 see clear evidence of, firstly, a stable accounting and 21 reconciliation position in the outlet followed, 22 secondly, by the transfer of accurate data across the 23 TIP/HAPS/BES and Reference Data interfaces." 24 So was this alerting you to known issues arising 25 with TIP and its interface and cash account imbalances 38 1 on the POCL side of the project? 2 A. Yes, I think this is the continuing dialogue about those 3 underlying problems. This is about the underlying 4 problems in relation to entering model office testing 5 and then, from there, into live trials, and I think you 6 are drawing out that it's a continuing theme. People 7 had seen throughout that this issue was never resolved 8 satisfactorily along the way, until we got to the actual 9 acceptance and, as you say, the conditions on the 10 contract. 11 Q. The document is emphasising that both live testing and 12 the acceptance process will be important? 13 A. Fundamental, yes. 14 Q. Can we move on, please, to POL00028571. We should see 15 that this is a memorandum, an update, from Dave Miller 16 to Stuart Sweetman on Horizon acceptance, dated 17 8 September 1999, copied to you in the top right. Can 18 you see that? 19 A. Yes, I can. 20 Q. Its subject is "Horizon Acceptance", and I'm going to 21 look at some of the headings in here, look at some 22 documents relating to them coming back to this each 23 time, if you understand. 24 A. Yes. 25 Q. So if we, firstly, look at paragraph 1.1, where it's 39 1 noted that you and Ruth Holleran -- can you help us as 2 to the role that Ruth Holleran undertook? 3 A. Ruth Holleran was in the POCL structure, she took a more 4 commercial perspective on this. So if some of these 5 failures affected the contract or the commercial 6 outcome, she would be involved in that transition. 7 Q. So: 8 "Bruce McNiven and Ruth Holleran have done 9 excellent work squeezing a better training deal out of 10 ICL Pathway. The incident remains at high because of 11 the need to support Training with a better Helpdesk 12 facility. However this will in all likelihood be 13 downgraded today medium incident with an agreed 14 rectification plan and therefore no obstruction to 15 acceptance." 16 Can you help us: in what way did ICL Pathway need 17 to be squeezed in order to provide a better training 18 deal? 19 A. I think, going right back to the earlier requirements, 20 they eventually said that counter staff had to be 21 trained to a degree that they could confidently, 22 accurately handle the new process, in terms of their 23 interaction with customers, and that managers of the 24 outlet could do that and be able to use the information 25 to produce a satisfactory balance in the office. 40 1 It was difficult along the way to get a clear 2 understanding and an acceptable outcome from ICL Pathway 3 that, from our perspective, met those requirements. 4 I think right back at the beginning the proposed 5 training schedule was something like half a day and then 6 workbooks and, essentially, distance learning. So 7 through iterations over months and indeed over a year or 8 a year and a half, we had moved this along to provide 9 a much better classroom training environment, much more 10 appropriate content, a beefing up of the balancing 11 training content and, ultimately, a defined role within 12 POCL to support offices as they went live and, 13 subsequently, on first and sometimes second balancing, 14 which we attributed to failures of the training product, 15 which ICL contested. 16 So, ultimately, there had to be an agreement, at 17 the end of the day, about how this would operate, how 18 subpostmasters would be supported through training and 19 how they would be supported post training in the live 20 environment. 21 We did succeed in reaching an agreement, which 22 actually involved the deployment of a large part of the 23 Post Office resource in the retail line into the support 24 mechanism. 25 Q. We're going to come to that a little later but can we 41 1 look first at the Acceptance Incident relating to 2 training, which is AI218, and look at POL00029130. Look 3 at page 4, please. You will see this is the AI relating 4 to training -- 5 A. Yes. 6 Q. -- 218 and under the description of the incident, it 7 records that: 8 "The Managers Training Course is not acceptable 9 due to deficiencies in the accounting modules. In the 10 live environment the training given did not equip the 11 users to perform the completion of office cash accounts. 12 This is a ..." 13 And I think that should read "basic": 14 "... [basic] POCL function that is central to 15 running and accounting for the POCL network." 16 So just dealing with the two issues that are being 17 raised there, firstly the managers' training course is 18 not acceptable due to deficiencies in the accounting 19 modules. Can you recall what the deficiencies in the 20 accounting modules were? 21 A. I can't specifically recall each individual component. 22 The testing of how well it was operating was in the 23 confidence and the accuracy with which a subpostmaster, 24 say, could complete his cash account in his office 25 within a reasonable time scale. So what we were 42 1 observing was the outcomes, and the outcomes being 2 unsatisfactory. 3 I think, in terms of content, I can't remember. 4 I could not go into detail. But there was insufficient 5 time initially given to allow subpostmasters to work 6 with the system to gain that confidence. So that time 7 was expanded and different scripts were written to 8 enforce -- to enhance, rather, their experience. 9 But, honestly, I just cannot remember in terms of 10 individual components of that training script. 11 Q. So you couldn't recall now what was done to address the 12 deficiencies in the accounting modules? 13 A. Not individually, apart from the length of time given to 14 it, devoted to it and an increase in the detail. But 15 I was not involved at that granular level. 16 Q. Then it says: 17 "In the live environment which training given did 18 not equip the users to perform the completion of office 19 cash accounts. This is a [basic] POCL function ..." 20 Can you recall whether any work was done to 21 establish, where errors were arising, whether they were 22 due, in fact, to poor training rather than a systematic 23 or structural bug, error or defect in the system? 24 A. It's a key question. From the perspective of training, 25 if we regard the deficiencies as a training issue in 43 1 that people had not sufficiently understood how to 2 interact with the system. If it subsequently transpired 3 that that was never going to work because of 4 deficiencies in the software, that may have appeared 5 later. 6 I think we have to remember that it didn't apply 7 to everybody. Although there were subpostmasters who 8 struggled, there were subpostmasters who succeeded and 9 I think because of that, we regarded it more of 10 a training issue than an underlying software issue. 11 I honestly -- we had concerns about the underlying 12 software but we -- in my experience, we did not relate 13 that software issue to -- 14 Q. Was that consciously addressed, ie we know on the one 15 hand that this system has got quite a significant number 16 of errors, bugs and defects that we know about through 17 a range of measures -- 18 A. Yes. 19 Q. -- some of them we are being told about by ICL Pathway, 20 some of them we saw in model office testing, some of 21 them we're seeing in live testing, some of them we're 22 seeing as the system is being rolled out: Issue 1. 23 Issue 2: there are problems being reported to us with 24 the adequacy of the training that subpostmasters are 25 receiving and, in particular, they're struggling to 44 1 perform basic accounting functions. Is there 2 a connection between the two? 3 A. I think it depends on the point in time at which you 4 look at this. In model office testing, where Post 5 Office staff were invited in to run the system as live 6 but in a model office environment, there were 7 deficiencies because things were not working properly. 8 That was early on. 9 Throughout all this and lying in parallel with all 10 this, was the Pathway process and assurance that, as 11 these issues arose, they were being fixed. So we have 12 what we see, visibility of issues and, alongside it, 13 a reassurance that these things were being fixed. So in 14 model office, I would say, yes, model office was 15 probably about software issues, that it wasn't working 16 properly. 17 When it came to live trial, there were two parts 18 to that. This is in May 1999. So there were the 19 Initial Go Live offices which were being upgraded, as it 20 were, from what they did to the full release software 21 and they had a training process there which was not 22 working very well. Again, alongside it, things were 23 being done by Pathway. 24 When we came to the next batch of live trial 25 offices, the new offices being brought into the process, 45 1 of which there were about 100, it was observed that the 2 training was -- the outcome of the training was better 3 but subpostmasters were saying of that batch that they 4 felt more confident about their ability to complete 5 a balance. 6 However, there was still sufficient concern that, 7 written back into the acceptance process an additional 8 group of offices -- I think about 25 or 26 -- were 9 brought into what was a final training product and put 10 through that training product as part of a live trial, 11 in addition to the baseline numbers and, as I recall, 12 the feedback from that was actually quite positive. So 13 we had gone from a position of concern, suspicion and 14 not working over months, to a position of rectification 15 seeming to indicate that the training product was 16 operating and one -- this is a leap -- but that the 17 basis of the system on which that training process was 18 working was also operating because balances were being 19 maintained and were being reached. 20 Q. Was there, to your knowledge, any communication to Post 21 Office auditors, investigators or prosecutors about 22 imbalances and discrepancies that may be being caused by 23 training inadequacies in this early period that should 24 be taken into account in investigatory and prosecutorial 25 decision making? 46 1 A. I'm honestly not aware of any conversations or 2 interactions of that kind. 3 Q. Would you agree that it was a logical thing to do? 4 A. It may have been done. I'm not aware whether or not it 5 was being done. I know that auditors were being trained 6 alongside. 7 Q. Just going back to the question: would you agree that it 8 would be a logical thing to have done? 9 A. It would. 10 Q. Can we move to page 7 of the same document, please, 11 which is a letter from you dated 10 August '99. Scroll 12 to the bottom, please. You're given the title here 13 "Director Horizon Programme"? 14 A. I think that's wrong. That's erroneous. I never 15 carried that title. 16 Q. No. Then going up to the top of the page, I think we 17 can see that it's to Mr Dicks at ICL Pathway. Was he 18 your opposite number? 19 A. Not really. I think he was brought in to try and 20 resolve this issue. 21 Q. The training issue? 22 A. The training issue -- 23 Q. I see. 24 A. -- because it was a high level incident. 25 Q. The title is "Review of Acceptance Incident 218" and you 47 1 said: 2 "An analysis of the evaluation against the 3 business impacts identified in the Acceptance Incident 4 is attached." 5 I'm not going to go through but there's 6 a five-page spreadsheet attached: 7 "Although many of the criteria have been met, it 8 is regarded as significant that the training and Go Live 9 process relies on the deployment of POCL HFSO resource." 10 Is that Horizon Field Support Officers? 11 A. That's correct. 12 Q. Just explain please what Horizon Field Support Officers 13 were. 14 A. Yes, there were two aspects. One was support to the 15 actual Go Live event at an office and the migration of 16 data and then, subsequent to that, they were also 17 deployed to support, as I said before, the first balance 18 and also potentially the second balance, to provide 19 support and confidence to the subpostmasters. 20 Q. "On the basis of this evaluation, we are not prepared to 21 reduce the severity rating from 'high'. 22 "POCL's view is that without this resource ..." 23 That's the HFSO resources: 24 "... there would have to be a complete revision of 25 the training approach in order to ensure helpdesks were 48 1 not rendered ineffective by the high level of calls 2 following the first and, to some extent, subsequent 3 balances." 4 Just to make clear what you are saying here, 5 you're saying that "Your training, ICL Pathway, is too 6 heavily reliant on the need for our Field Support 7 Officers to be deployed out on the ground to help 8 subpostmasters balance their accounts"; is that it? 9 A. That's correct, yes. 10 Q. So "Your training's inadequate because it needs us to 11 put people -- boots on the ground to actually help 12 subpostmasters do the most basic function, which is 13 balancing their accounts"? 14 A. That's the perspective we are taking there. I think ICL 15 Pathway would say we have fulfilled the obligation for 16 training. We don't know the competencies that exist out 17 there amongst 18,000 post offices. 18 Q. Wasn't that obvious to them, that there would be some 19 people who were 18 and keen and some people who were 87 20 and had never switched an electronic device on in their 21 lives? 22 A. Yes, I think it might have been obvious to everybody. 23 I don't think, in fairness, POCL would say they had 24 a clear understanding of the competencies of the estate 25 of subpostmasters and assistants. So I don't think, 49 1 coming in, POCL were able to say, "We know who will 2 adapt to this more quickly and we know who won't adapt 3 to this". We have an understanding of offices which 4 maybe cause problems, but we don't really understand the 5 whole estate. 6 Q. Just stopping at that point, was thought ever given to 7 taking a sample of SPMs beforehand to gauge the level of 8 competence? 9 A. I think you're going to talk to Kathryn Cook later this 10 week, who was custodian of training within POCL. 11 Kathryn Cook did some work in association with this 12 debate about what competencies we knew about out there. 13 Now, I know this is downstream, and maybe all that 14 work should have been done as a management of change 15 process and perhaps it would be done if we started 16 again, but I think we were trying to understand this as 17 we went along. But what we were convinced about was the 18 training product did not meet the requirements of every 19 individual and some individuals had to be supported post 20 Go Live. 21 Q. Again, if you're designing a training course, don't you 22 first establish what the level of existing competence is 23 and the training needs of the likely cohort to whom it 24 is to be delivered? 25 A. I think that's fair comment. 50 1 Q. Just very quickly before the break, if we just look at 2 the headline of the ICL response, that's at page 12 of 3 this document. I'm not going to read the whole 4 document. It's on the system that's available for 5 reading but, in essence, in replying to your letter of 6 the previous day, Mr Dicks, who is the author of this 7 letter, says: 8 "Pathway is convinced that it has done everything 9 that it can to improve the training and prepare users 10 for Horizon, and that the essence of the remaining 11 issues that you are seeking to address relate to POCL's 12 own management of change." 13 So he's saying "it's you, not us" essentially? 14 A. Yes, he is. He's saying that we -- the kind of things 15 that you have talked about about understanding levels of 16 competence, and also I think he's inferring that some of 17 the back-end processes, which we were changing to adapt 18 to Horizon being an office, were contributors to the 19 whole end-to-end training knowledge and that was the 20 position they took. 21 MR BEER: Thank you. Sir, might that be an appropriate 22 moment to take a 15-minute break? 23 SIR WYN WILLIAMS: Yes. Do you want to make it 25 to or 20 24 to, Mr Beer? 25 MR BEER: 25 to is fine. Thank you, sir. 51 1 (11.24 am) 2 (A short break) 3 (11.38 am) 4 MR BEER: Thank you, sir. Mr McNiven, can we go back to 5 POL00028571. You remember we were using this document 6 as our basis for exploring a range of issues and we 7 looked at training. Can we go on, please, to the second 8 page -- to the third page, actually. The second page is 9 blank. Thank you. 10 Under "Summary", and just see what Mr Miller says: 11 "Of our six key players (Keith Baines, Ruth 12 Holleran, John Meagher, Bruce McNiven, David Smith, Andy 13 Radka) the first 4 ..." 14 So I think that includes you? 15 A. Yes. 16 Q. "... would opt (somewhat reluctantly) for conditional 17 acceptance towards the end of September. Andy Radka and 18 David Smith would not accept and seek to use the full 19 period until 15 November to force improved performance 20 from ICL Pathway." 21 Can you help us: why did you consider it was 22 preferable to push on with acceptance in circumstances 23 where the criteria had not yet been met? 24 A. Conditional acceptance because we did recognise, I did 25 recognise there were issues. I can only reflect on what 52 1 was being said at the time, that resolution programmes 2 were in place, that the people who understood those felt 3 that the resolution would be effective. People like 4 John Meagher -- I knew John Meagher, I had many 5 conversations with John Meagher, and I had faith in his 6 judgement and he was on the technical side. And other 7 people who have been here before were saying that, yes, 8 there are still problems but these problems are reducing 9 and the resolution is effective and we expect that it 10 will be sufficient to go to acceptance with conditions, 11 and the conditions, I think we spoke about before, about 12 some demonstration of that effectiveness continuing 13 beyond the conditional agreement for rollout. 14 So I just tried to take it in the round. 15 I listened to what is being said, I look at the area 16 that I had most responsibility for, which was the 17 physical infrastructure and rollout and training and, 18 from that perspective, I was reasonably confident. 19 I was very confident about the physical implementation 20 side and I was accepting the judgement of colleagues 21 that it was capable of being fixed. And I suppose, 22 ultimately, I would say that, in all my dealings with 23 ICL, how frustrating they may have been, the battles 24 that may have been involved, this was a world-class IT 25 company and I fundamentally did not think that they 53 1 would allow over the line a system in which they had no 2 confidence. 3 Q. Was the system in front of you at the beginning of 4 September working as a world-class system? 5 A. No, fair comment. It was not and that's why the 6 acceptance process still had significant issues attached 7 to it and those issues would continue until they were 8 resolved. 9 Q. This is only four weeks after your letter of 10 August 10 to John Dicks -- 11 A. Yes. 12 Q. -- which, in the letter and in the annex to it, set out 13 a full range of issues known to both POCL and to 14 Pathway. What had changed in that four weeks to make 15 you, by this time, in September, reluctantly agreeable 16 for conditional acceptable to proceed? 17 A. The letter to John Dicks was specifically about 18 training. I was content that there were procedures in 19 place. There was a new document from ICL Pathway that 20 outlined changes to the whole training process, 21 including an awareness event which had not been there 22 before. We had essentially agreed that there would be 23 post implementation support and, ultimately, that was 24 paid for by ICL Pathway. 25 So from a training perspective, I was confident it 54 1 could be done. What more can I say? I accepted advice 2 from the people closer to the technical end that things 3 would be resolved. 4 Q. Can we look to the foot of this page, please, under the 5 heading "Where To Go From Here?" 6 At point 4, Mr Miller says: 7 "Bruce is preparing the bullet point brief for 8 John Roberts and I will incorporate Acceptance into it." 9 So I think John Roberts, at that time he would 10 have been chief executive of Post Office Counters -- 11 A. Yes. 12 Q. -- and a member of the board, obviously? 13 A. Yes. 14 Q. At this point in time, you were obviously a key member 15 of the Horizon Implementation Team. You have moved on 16 from the PDA? 17 A. Yes. 18 Q. You were the senior member of the Horizon management 19 team. 20 A. Of the Horizon field implementation team, yes. 21 Q. Thank you. You worked under Mr Miller? 22 A. Yes. 23 Q. You had a good working relationship with him presumably? 24 A. I did. 25 Q. He trusted you? 55 1 A. I hope. 2 Q. Presumably that's why he, when he deputed somebody to 3 draw up a bullet point memo for the chief executive 4 officer, he chose you to draft it; is that right? 5 A. I would think so. 6 Q. At this time, did you understand that this wasn't simply 7 a transition from a paper books ledger system to 8 a digital accounting system; there was a much broader 9 process of change that the implementation of Horizon 10 brought with it? 11 A. It was becoming apparent, yes. 12 Q. Was it your view and those around you that the Post 13 Office would, going forwards, not wish subpostmasters to 14 have the facility to challenge the data produced by 15 Horizon? 16 A. I really can't comment on that. I don't know -- I did 17 not know and I do not know, with hindsight, whether they 18 had that opportunity or not. 19 Q. Were you not party to any discussions or did you not 20 become aware of the absence of a facility allowing 21 subpostmasters to challenge the data produced? 22 A. To my recollection, I can't remember being aware of that 23 at that time. I have seen subsequent documentation that 24 refers to it. 25 Q. Did you understand that this was -- had a dual purpose: 56 1 it was intended to limit or remove the SPM right to 2 challenge but also to reduce the costs and resources 3 expended on the issue at Chesterfield? 4 A. I'm totally unaware of that issue. 5 Q. Was there any sense in the discussions that you were 6 a party to that automation had the benefit of exercising 7 greater control, central control, over the accounting 8 process by the Post Office, both by the IT and by reason 9 of the contractual terms of subpostmasters? 10 A. I think I would have been aware of a movement towards 11 conformance, that things would be done in a coherent and 12 repeatable way by subpostmasters across the whole Post 13 Office estate, which would be to benefit of the Post 14 Office, if that was done and done well. 15 Q. Were you aware that the obligation was placed upon 16 subpostmasters to cover any accounting shortfalls with 17 their own money? 18 A. As I recall, going back to my previous line management, 19 local management responsibilities, there had always been 20 a provision to that extent and there were mechanisms in 21 place to try and work out, say, how much of a deficit 22 might be accountable to the subpostmasters' actions. It 23 could be that a subpostmaster just gave someone a double 24 benefit and that then came back to evidence for us and 25 we would then say, "Well, you know, ultimately, that was 57 1 your doing and therefore you must make that good". 2 So there was always a provision of sorts about 3 subpostmasters rectifying financial shortfalls of which 4 they were a part. 5 Q. What about a change to irrespective of cause? 6 A. I'm not aware and I was not party to any conversations 7 of that type. 8 I find it now, being faced with that, hard to 9 understand that that would have been an outcome. 10 I would have thought there would always be a management 11 intervention in that decision. 12 Q. When the system was being rolled out, does it follow 13 that you weren't aware that the contractual terms for 14 SPMs required them to make good shortfalls, irrespective 15 of cause? 16 A. I'm absolutely not aware of that. My previous 17 experience was a requirement to make shortfalls but 18 there was a decision-making process within it. 19 Q. The briefing that you prepared for Mr Roberts, did that 20 just relate to training or did it extend to other 21 things? 22 A. I mean, I've read that and I've seen that I was 23 preparing a bullet point brief. I can't recall the 24 outcome of that. 25 Q. No, we haven't got it. Can we look at an email that was 58 1 sent at about the same time as this paper that we've 2 been looking at that also concerns a briefing of 3 Mr Roberts. That's POL00043705. Look at the second 4 page, please. Just wait a moment whilst I catch up. 5 Sorry, if we go back to the first page, I called 6 it an email. It's an electronic memo. 7 Can you see that? Then go to the page afterwards, 8 please. You'll see this is dated 10 September 1999 and 9 so a couple of days after the document we've just been 10 looking at and it's from Stuart Sweetman -- sorry, it's 11 to Stuart Sweetman from Mr Miller and we can see that 12 you're copied in on the top right. 13 A. Yes. 14 Q. It's an update about acceptance at 10.30 am on Friday, 15 10 September. In paragraph 1 there's a full update on 16 Horizon generally being sent, enabling Mr Stuart (sic) 17 to brief Mr Roberts on Monday, and then if we go to the 18 numbered paragraphs under 1: 19 "Very considerable progress has been made in the 20 joint workshops with ICL Pathway but as of today there 21 were still 2 high incidents (Data integrity across the 22 TIP interface and system stability around screen 23 freezes) which would, in the Post Office view, make it 24 difficult to accept on 24 September." 25 Then paragraph 4: 59 1 "... if we were to stick rigorously to our agreed 2 process I would not be allowing further rollout." 3 So were you a party to the creation of this 4 document or were just a recipient of it? 5 A. I think I was only a recipient. 6 Q. But overall the document is highlighting that the 7 outstanding incidents aren't related to training. They 8 include data -- or they are data integrity across the 9 TIP interface and system stability. 10 A. Yes. 11 Q. So this memorandum, I think you'll agree, makes it clear 12 that these two important issues were being raised with 13 the senior management team closest to the board clearly 14 and in writing? 15 A. Yes. 16 Q. They were being advised that the decision to go forward 17 with conditional acceptance in September 1999 was 18 a departure from the agreed processes for acceptance. 19 A. Strictly speaking, that would be correct. 20 Q. Why was that recommended? 21 A. I don't know if this goes on to talk about any more 22 activity on those exceptions but I think that those 23 exceptions still had rectification activities around 24 them. 25 Q. It says that in 2, "The two incidents have rectification 60 1 plans", but I don't think there's anything else about 2 those in the memorandum. 3 A. No, I'm only surmising here that it's taking a view from 4 the previous document about why some people, myself 5 included, felt that, perhaps, we should continue to move 6 forward. There were pressures. I think everyone felt 7 some pressure about continuing to move forward -- 8 Q. I'm so sorry, where was that pressure coming from? 9 A. Three sources, I think. One was the impetus behind 10 rollout. Now, that was something I was immediately 11 involved with. So by the stage the whole process, which 12 went back six or eight months of offices being visited, 13 offices being surveyed, offices being modified, offices 14 being made ready for implementation, there would be, by 15 this stage, some thousands of offices probably ready to 16 go to implementation and a build up of expectation, not 17 least amongst the subpostmasters, that this was going to 18 go ahead and they were going to be part of it. 19 From a personal perspective, I think it was 20 a pressure I've always believed that we should get this 21 done, otherwise, as I said at the outset, we would never 22 catch up again. I think I was aware of and probably 23 responded to external-to-my-own-team pressures about 24 commercial activities, political influences, the 25 Treasury review had given the go ahead and money was 61 1 committed. 2 Q. At a day-to-day level, how did that pressure manifest 3 itself? 4 A. I think it manifested itself in terms of our 5 relationship to Pathway. It would be fair to say that 6 we were under pressure from Pathway to move forward. 7 I mean, it talks about workshops. I remember being 8 involved in a number of meetings with ICL Pathway at 9 senior level where they were trying to downgrade 10 incidents to a level which the contract would allow to 11 go ahead. We, myself and colleagues, were in essence 12 trying to say "No, we're not going to do that, we won't 13 allow it until we have more proof". 14 That level of impasse that translated into 15 a series of workshops between the people most closely 16 involved, working level workshops. They tried to 17 disassemble all the reasons behind these problems not 18 being resolved but they were then being translated into 19 plans to resolve them rather than decisions about not 20 going forward at all. So the impetus was on resolution 21 as opposed to stopping and that's a pressure in itself, 22 I think. 23 Q. Can we turn, please, to move forward in the chronology 24 a little, to POL00090428. We can see, as the edge of 25 the spine tells us, that we're about to look at the 62 1 annex to the second supplemental agreement dated 2 24 September 1999 and we'll see that this document, 3 which is very long indeed -- 218 pages in total -- 4 includes very significant detail on the proposed 5 rectification plans. I want to look at AI218 and 6 training in particular. 7 Can we go to page 65 internally, please. As this 8 is part of the resolution plan for AI218 and, under the 9 third bullet point, it records that: 10 "The joint workshop on 13 August [that's 11 13 August 1999] accepted that not all users within the 12 large population will 'absorb' Horizon. This may 13 eventually call for closure of the outlet, replacement 14 of the subpostmaster or training of additional staff. 15 It has been agreed between POCL and ICL Pathway that 16 other steps taken within this resolution plan should 17 minimise the risk of this and that any residual fallout 18 will be handled by POCL. POCL have agreed to review and 19 strengthen the relevant process. This is reflected in 20 the timetable." 21 Then if we just go back to the previous page, 22 please, and look at the foot of it, the paragraph right 23 at the bottom: 24 "Further to the activities above, a workshop took 25 place on 13 August which identified seven specific areas 63 1 for potential improvement ... Commercial consequences of 2 the actions below are agreed in an exchange of letters 3 between [you] and Liam Foley of ICL Pathway ... 4 "These are as follows." 5 Then they are set out, including the one that we 6 looked at. 7 A. Yes. 8 Q. So what is recorded in that third bullet point seems to 9 be the product of an agreement reached between you and 10 Mr Foley in correspondence. Did POCL accept before 11 acceptance that there would be some subpostmasters who 12 would never absorb, in inverted commas, Horizon? 13 A. I think we accepted it was possible. I mean, a number 14 of subpostmasters resigned of their own volition, as 15 they became aware of the implications of taking on 16 an automated process in their office. So there was 17 a fallout from that as well. So it was not surprising 18 if there would be a fallout from the training process. 19 The training process was structured such that 20 there was a competency test -- it wasn't called 21 a competency test from the subpostmasters' or 22 assistants' point of view, it was a certificate of 23 competence -- but there were some who just would fail 24 the test at the end of training because they were 25 presented with some scenarios to which they had to give 64 1 answers and, even with some help, there were some that 2 failed. 3 We managed to then arrange for them to be 4 retrained along the lines of the same module and to be 5 retested. The agreement with ICL was that if people, 6 subpostmasters or assistants, failed a third time then 7 they would return to POCL as our responsibility rather 8 than a Pathway training issue and I suspect from that 9 there were discussions -- if it was a suboffice 10 assistant, there was the opportunity for the 11 subpostmaster to train them, to take them under their 12 wing and try to help them a bit more. 13 If it was a subpostmaster, there was help given in 14 terms of balancing. But there was fallout. There would 15 have been and there was some fallout along the way from 16 people who thought this is -- "I'm not going to do this, 17 this is just not for me", in which case an outlet may 18 have to be closed. 19 Q. So the fall out would be closure of the Post Office or 20 replacement of the subpostmaster within the Post Office 21 and did you understand that the means by which 22 subpostmasters, who could not or would not absorb 23 Horizon, would be through their contractual liability 24 for errors? 25 A. No, I did not associate the training and the withdrawal 65 1 with contractual liability for errors. 2 Q. How did you think that the non-absorbers would be, as 3 part of a residual rump, removed? 4 A. It was often by mutual agreement that the subpostmaster 5 and the local manager said "This is not working", or the 6 subpostmaster said, "I'm not going to continue with 7 this". So it was a kind of a voluntary resignation. 8 Q. What if it wasn't voluntary? What was the means by 9 which subpostmasters, who couldn't absorb Horizon, would 10 be removed? 11 A. I'm not aware of any force majeure closures of offices 12 because a subpostmaster had not passed through that 13 phase successfully. 14 Q. So how were they going to be removed then? How did POCL 15 intend to remove subpostmasters? 16 A. As I say, I think it was a mutual agreement, it was 17 a conversation. But I don't think we're talking about 18 a great number in the population here, by that stage, 19 because I think the local management would have -- the 20 local management would have a responsibility to the 21 customers of a post office as well as the integrity of 22 the Post Office finances that if -- and this is always 23 the case -- that if they felt the individual 24 subpostmaster was not performing to the requirements, 25 there would have to be a conversation about what 66 1 happened next. 2 Q. Was any link drawn between the ability of subpostmasters 3 to absorb Horizon with the adequacy or inadequacy of the 4 training with which they were being provided, which 5 I think was a day and a half, wasn't it? 6 A. Yes, I think that goes back to all the support that was 7 then put in place. I mean, I don't know the numbers and 8 I suspect it would be quite small if we got to that 9 point and I think along the way -- 10 Q. 20 per cent that failed the -- in inverted commas -- 11 "competency" test initially; is that right? 12 A. Initially, that may be right. You may well be correct. 13 But that's of all people, assistants and subpostmasters, 14 of course. 15 But I think I would expect that local managers the 16 whole system, would go as far as they possibly could to 17 help a subpostmaster. It was his business to help him 18 run his business properly, even if that meant line 19 resource, local managers going out there on successive 20 visits to try and help them. 21 Q. So the role of the local manager continued to be 22 absolutely central; is that right? 23 A. Yes, absolutely, and the field force that was sent out 24 were converted from the normal jobs of managing numbers 25 of outlets to specifically supporting the whole of that 67 1 balancing/reconciliation help process. So some 350/400 2 people were put in for that purpose. 3 Q. In your time, were you ever aware of the removal of the 4 local manager from the decision-making process in 5 relation to investigation, audit and prosecution? 6 A. Can you just say that again so I understand it? 7 Q. Yes. In your time, were you ever aware of the removal 8 of the local manager from the decision-making process in 9 relation to audit, investigation and prosecution? 10 A. No, I wasn't. 11 Q. Can we turn to the issue of balancing as a part of the 12 training process and acceptance. Can we look, please, 13 at NFSP00000120. It might have been easier if I said 14 NFSP00000120, thank you, and look at page 2, please. 15 This is a letter addressed to Colin Baker and, if 16 you just scroll down, please, and go over the page and 17 scroll down, from Paul Rich? 18 A. Right. 19 Q. You are a copy at the foot of the page. 20 A. Yes. 21 Q. You'll see, if we go back to the first page, please, 22 that the -- sorry, the first page of the letter, the 23 second letter of this clip of correspondence, thank 24 you -- that the letter's dated 4 September 1996. You'll 25 see in the third paragraph that you are referred to 68 1 "Bruce McNiven, from the Programme Delivery Authority". 2 Is that right, in September 1996 you were performing the 3 role of the Deputy Director of the PDA? 4 A. That's correct. 5 Q. Then you'll see in that third numbered paragraph it says 6 that you will be in touch with Mr Baker of the NFSP: 7 "... separately to notify you of a structural 8 framework we intend for subpostmasters to be involved in 9 both user acceptance testing, and in generating possible 10 solutions to operational problems that might arise. You 11 and Bruce will discuss the NFSP's part in that to help 12 smooth implementation." 13 So the part of the sentence that says "involved in 14 both user acceptance testing", just explain to the Chair 15 what "user acceptance testing" means? 16 A. I should imagine that would encompass two aspects of the 17 process: (1) model office testing where subpostmasters 18 and some directly managed counter staff would be brought 19 into the model office environment and run through the 20 scripts and the process using the equipment as it then 21 was to test how it was operating. And the other one 22 would be the live trial itself, which was, I suppose, 23 a key point within the process where subpostmasters 24 would be introduced to the system. 25 Q. So this is an early recognition -- 69 1 A. Yes. 2 Q. -- of the importance of end user, ie SPM, involvement in 3 the process? 4 A. Indeed, yes. 5 Q. What, if any, steps did you take in 1999 to involve 6 subpostmasters in the acceptance process? 7 A. There was no formal process for their involvement. 8 Their experiences in the live trial would inform a view 9 that we were taking about adequacy of various aspects 10 but there was no formal involvement in acceptance. 11 Q. Was there any involvement of SPMs or their 12 representatives in the negotiations over acceptance in 13 the autumn to winter period of 1999? 14 A. Not to my knowledge, no. I'm pretty sure the answer to 15 that is no. 16 Q. Given the early recognition of the importance of the 17 experience of end users, why is the answer no? 18 A. End users had been involved in those processes I talked 19 about. We also -- I remember vividly we had open 20 sessions with the people involved in live trial to get 21 their feedback in an open meeting. There were two in 22 Bristol with the south-west, which I attended. There 23 were two in the north-east, one of which I attended and 24 Dave Miller attended the second, and I think it's fair 25 to say we had a hard time -- I did -- because a number 70 1 of the subpostmasters at that stage, at that stage of 2 development of the live trial, were unhappy about their 3 experience and they told us and, you know, we accepted 4 it. I should say that there was -- 5 Q. What were they unhappy about, I'm sorry? 6 A. Mostly about the balancing and about the length of time. 7 It was the length of time more than anything else, that 8 it seemed it was taking into them -- balancing was 9 usually about a two-and-a-half-hour process, even in 10 manual times, and that was the expectation in automated 11 times. 12 I think, ultimately, that was achieved for many 13 people but during live trial -- I mean, with hindsight, 14 in live trial we exposed a lot of those people to 15 enormous amount of difficulty. To some extent, that 16 might have been expected because it was a live trial. 17 We wanted to know what was happening, we wanted to know 18 their experiences but some of them were unhappy about 19 that experience and they told us. 20 Q. So they were struggling, in the language we've looked 21 at, to "absorb"; would that be correct? 22 A. To absorb and I think it was mostly about the balancing. 23 Their big issue was about balancing, the difficulty of 24 achieving it and the length of time it was taking. 25 Q. Can we, in that connection, look, please, to 71 1 NFSP00000271. Moving on a little bit but still in your 2 role as PDA, this is a letter from you, if you just look 3 at the second page and scroll down. Thank you. 4 That's interesting. This is dated 5 22 September 1998 and you are referred to as the general 6 manager of Horizon implementation. Is that right, you 7 had transitioned to that role by then? 8 A. I had transitioned, yes. 9 Q. Going back to the first page then 22 September 1998 to 10 Mr Baker, again, of the NFSP, and if we look at the 11 third paragraph, please, you say to him: 12 "I know you would like a workshop to review in 13 detail the Horizon summarisation and balancing and how 14 this be approached in training. I hope to provide this 15 soon but we are still in the early stages of detail on 16 this part of training and it would be mid to late 17 October before I would be able to set up suitable 18 arrangements." 19 Is this in response to or does it appear to be in 20 response to the NFSP flagging the importance of there 21 being training on balancing as early as the autumn of 22 1998? 23 A. Yes, I think so. There may have been -- 1998. There 24 may have been some exposure in model office testing by 25 that stage and some subpostmasters may have been 72 1 involved. 2 Q. And balancing or the difficulties with balancing had 3 been pointed up as a problem then? 4 A. I would think so. 5 Q. Did the workshop there discussed take place? 6 A. I honestly don't know. I cannot recall it -- I cannot, 7 sorry, recall it taking place specifically for 8 Federation representatives. 9 Q. Can we look, please, at NFSP00000340 and look, please, 10 at the second page. This is essentially a report on 11 Horizon training as relayed by Pam Jervis on 12 30 April 1999, you can see from the heading at the top, 13 and she reported: 14 "The first day of training is OK, but the second 15 ... is bad because it is rushed. They are not finishing 16 on time, but are rushing to finish before 3.30 ... 17 because otherwise they have to buy lunch. Why did they 18 use the most expensive hotels?" 19 Skipping a paragraph: 20 "In every training session, nobody had done a main 21 balance, snapshot balances only. Nobody had been 22 trained to do a full balance. 23 "The trainers are people who have only received 24 the same training that they are giving out. It's too 25 narrow a ['field', I think that is] and no-one can 73 1 answer questions such as 'do we use the same form?' 2 "There were a lot computer problems which were 3 blamed on the fact that computers had to be ferried in 4 and out of vans a lot." 5 Do you recall receiving feedback like this? 6 A. Yes, I do. This is -- 30 April is the early part of 7 bringing offices up to spec for live trial and I suspect 8 that these were offices that were going from Initial Go 9 Live functionality up to the full release functionality. 10 It was a very early run of training, full training for 11 that purpose, and I recognise this. I recognise these 12 problems at that time. 13 Q. I skipped over it. This was a fax from Colin Baker, the 14 general secretary, to you, I think. 15 A. Yes. 16 Q. What did you do with this information? 17 A. Well, I mean, this is April. All of this was going into 18 the perspective that we had about training being a high 19 level incident, you know, a pass/fail incident. It was 20 not put right; it was part of acceptance. So it was 21 information that supported the perspective that we were 22 taking. 23 Q. In what way? 24 A. In the way that we had already expressed to ICL Pathway, 25 that we were not happy with the training product and it 74 1 had to be modified and improved. Those debates were 2 going on on a very regular basis with Pathway at that 3 time and from that time up to the revised training 4 package that they produced. 5 Q. Just look over the page, please, and look at the foot of 6 the page, please. Four paragraphs from the bottom: 7 "Everyone stressed that all subpostmasters must be 8 told to complete a manual balance if there are problems, 9 or even do a double check. They are told that the 10 balance goes down the line to Horizon, but once that 11 happens, if there is a query, then subpostmasters have 12 no proof of any work that's been done." 13 Do you understand what that's referring to? 14 A. I think you asked earlier about the opportunity for 15 subpostmasters to interrogate the balance once it had 16 been completed and whether or not they could influence 17 that, and I'm sure, I understand, that they did not have 18 that facility. So, at this stage, they were being 19 advised to perhaps do a manual backup. 20 Q. What does the manual backup involve? 21 A. A manual cash account, as they did before they actually 22 transitioned on to the automated system. 23 Q. How would they do a manual cash account? 24 A. They would still have a cash account process, a piece of 25 paper that was their cash account that they used to fill 75 1 in manually and, if it was as difficult as this, they 2 would be probably transposing the work they were doing 3 into that balance manually at the same time as putting 4 it into the system. 5 So they were replicating what they did before. 6 Q. Was that running of a dual or shadow -- 7 A. That's correct, yes. 8 Q. -- system limited to this stage of the process? 9 A. I mean, this is quoting someone as saying that that's 10 what they should do. 11 Q. Yes. 12 A. That was not official advice. That was people at the 13 training session being told you should do this because 14 it's difficult to recover things otherwise. I don't 15 think we ever advised subpostmasters to do a double 16 entry-type system. 17 Q. Did you hear about it being done nonetheless? 18 A. Only in terms of this. 19 Q. Not more widely? 20 A. No. 21 Q. So there wasn't a period, for example, during live 22 testing when people were asked to do to what you 23 referred as double-entry bookkeeping? 24 A. Absolutely not, no. 25 Q. So here, that "Everyone stressed that all subpostmasters 76 1 must be told to complete a manual balance", what do you 2 understand -- and I appreciate this is a document that 3 was sent to you, and not written by you -- what do you 4 understand the "everyone" to refer to? 5 A. Everyone ... I think they mean ... I think the people, 6 from the experience of that training episode, were 7 saying, "From our experience, subpostmasters should be 8 told to complete a manual balance". 9 Q. So we should read this as meaning that -- 10 A. Subpostmaster to subpostmaster, I think. 11 Q. Not trainer to subpostmaster? 12 A. No. No. 13 Q. And subpostmaster to subpostmaster are saying that it 14 should be trained that subpostmasters should be told to 15 complete this second or shadow account? 16 A. I don't think it came through formally. I think it's 17 subpostmasters saying to the Federation to say to 18 subpostmasters, "Look, there may be problems and we 19 suggest that you might wish to do a manual balance at 20 the same time as you are doing the Horizon balance, from 21 the experience we have at that point in time". 22 I don't believe it was ever formally adopted or 23 transmitted. 24 Q. Was it ever picked up by management as a sensible 25 precaution, given the consistent and repeated problems 77 1 with weekly balancing? 2 A. I don't believe so. 3 Q. To your knowledge -- 4 A. To my knowledge. 5 Q. -- was this picked up: whilst we are getting these 6 repeated complaints of an inability to balance, 7 subpostmasters (certainly in the live trials) should be 8 advised to run a mirror on paper of the accounting 9 system? 10 A. I was never aware of or party to advice from that nature 11 from a formal perspective. 12 MR BEER: Those are the only questions that I ask at the 13 moment. There may be some questions from others. 14 I think Mr Moloney was first on the list. 15 SIR WYN WILLIAMS: He's nodding. Over to you, Mr Moloney. 16 Questioned by MR MOLONEY 17 MR MOLONEY: Mr McNiven, I just want to ask you about one 18 topic which is the essential nature of data integrity to 19 the system and the extent to which that was part of the 20 audit process. You've mentioned that. You said that 21 you were aware that data integrity was essential to the 22 system, but you weren't specifically focused on the 23 requirement being part of the audit process. 24 Is that right? 25 A. I think I was saying I wasn't specifically aware of 78 1 audit auditors being engaged in the work that we were 2 doing in terms of data integrity. 3 Q. I see. Could I take you to POL00029130. It's 4 a document you've already been taken to. Could I go to 5 the letter at page 7 of the PDF. You have already been 6 taken to this letter. 7 This is a letter from you, Mr McNiven, dated 8 10 August 1999 to Mr Dicks at ICL Pathway. 9 A. Yes. 10 Q. We can see that you introduce the letter by speaking of 11 an analysis of the evaluation against the business 12 impacts identified in the Acceptance Incidents, and 13 that's Acceptance Incident 218 that's attached. In the 14 letter, you raise a number of issues around this 15 acceptance issue 218. 16 If we could go to the document which is on the 17 next page, page 8, this is essentially what you have 18 described in the letter. Now, before the letter was 19 sent and before the attached document was sent, they 20 deal with a number of issues. Would there have been 21 discussions between POCL and ICL Pathway about these 22 issues, essentially talking them through, and then this 23 is a distillation of what's gone on in terms of your 24 work on the process? 25 A. Yes. I mean, there were continuous conversations on all 79 1 these issues, training and all the rest, both through 2 myself to people like Liam Foley, et cetera, in ICL 3 Pathway but also through what shots being held people 4 closer to the issues, I would say, on both sides to try 5 and come up with a resolution, to try and produce 6 a solution that meant that the training content was 7 better than we started off with. 8 It was ongoing, it was continuous, it was 9 sometimes difficult and there were often arguments. 10 Q. This document is essentially a summary of where we are 11 and where we'd like to get to. 12 A. Yes. 13 Q. But there were many discussions behind it. 14 A. There were many, many discussions behind it. I think, 15 if I just may say, the outcome of that exchange of 16 letters between myself and Mr Dicks was probably such 17 that we, POCL, understood that the deployment of a large 18 part of our field infrastructure was going to be 19 deployed to support subpostmasters during the rollout 20 period. 21 Q. Right. 22 A. And that we would give them all that support. There's 23 a positioning behind this that says, "And we're not 24 going to pay for it". There's a commercial aspect to 25 this and that will come out later on. 80 1 Q. Sure. Were you involved in the drafting of this 2 document? And I'm not talking about the letter, 3 I mean -- 4 A. The evaluation? 5 Q. -- the attached document? 6 A. I don't think I actually wrote any part of that. It 7 would pass through me. 8 Q. You'd have to approve it? 9 A. I'd have to approve it. 10 Q. Was it approved above you in line management before it 11 was sent? 12 A. I don't think so. I think Dave Miller would be well 13 aware of the position that had been talked at the 14 Horizon management meetings and I think he would be -- 15 I would have given him an indication of what was going 16 to happen and what I was going to say. 17 Q. Yes, okay. So just to -- I only want to look at one 18 aspect of this document but if we just look at the 19 various columns, we can see "business impact" in the 20 first column, "summary of success criteria measure" in 21 the second, and "evaluation" in the third. Could we 22 please go down to I think it's the next page but it's 23 number 5. We've got 1, 2, 3, 4, 5 down this side. So 24 it's the next page again. That's it. 25 I'll read through it, if I can, to begin with and 81 1 then come back to ask you questions about it. At number 2 5, under "business impact": 3 "There is also an impact on TP who are having to 4 process a significant increase in errors on Class and 5 Pivot (up to 3 times as many weekly errors). This is 6 having a significant impact on resources in TP during 7 the live trial. These errors will also raise liability 8 issues between the POCL and subpostmasters, and POCL and 9 client organisations." 10 Then we see under summary of success criteria 11 measures, some definition, as it were, of the problems 12 that TP are having to deal with. We return, I think, 13 really here to the receipts and payments mismatches that 14 were apparent throughout the process. 15 A. Yes. 16 Q. So we see "reduction". This is the summary of success 17 criteria measure: 18 "Reduction in both the number of incidents where 19 receipts do not equal payments and incidents where 20 balance brought forward does not equal balance due to 21 Post Office on previous cash account." 22 And then: 23 "Reduction in the number of errors reported by 24 TP -- both class and pivot errors relative to the 25 sample." 82 1 Then evaluation: 2 "Overall, the incidents of receipts not equal to 3 payments have reduced and the residual causes are under 4 investigation or have been resolved. Criteria met. The 5 level of class errors between 26 May and 21 July has 6 reduced. Without full information, the indications are 7 that pivot errors have also reduced." 8 Now, it's back to the first column that I'd like 9 to take you, if I may, please, Mr McNiven, where it 10 reads at the end of that section: 11 "These errors will also raise liability issues 12 between the POCL and subpostmasters, and POCL and client 13 organisations", yes? 14 A. (The witness nodded) 15 Q. Is it fair to say that there was an awareness that 16 errors would produce liability issues? 17 A. Yes. 18 Q. Yes? 19 A. Yes. 20 Q. Was it obvious, really, that if there was a receipt and 21 payments mismatch, then if there was less money than was 22 expected, then it's potentially going to give rise to 23 liability issues? 24 A. Yes. There were always errors. There were always error 25 notices, as they were called, coming from transaction 83 1 processing, the Chesterfield accounting people, going 2 back to subpostmasters. Previously in the old 3 accounting system, because things came to light after 4 the event, and subpostmasters often had to correct 5 things and understand why it had happened. 6 What this is saying is there's more of them -- 7 there is more of them than there were previously and 8 that's an issue, which is absolutely correct. 9 Q. And there were issues of financial liability; that's 10 what you're referring to? 11 A. Ultimately, there was a conversation we had about 12 financial liability in subpostmasters for losses. It 13 was always a liability. 14 Q. Yes. 15 A. Obviously, if there were more issues there would be more 16 questions of liability. 17 Q. Well, precisely. So there could be a question of -- 18 debt recovery would be one thing but also, from the 19 experience you had of prosecution decisions that you've 20 told the Inquiry about today, you must have been aware 21 of the potential for prosecution. 22 A. I was always aware of the potential for prosecution in 23 the event of mis-balances. Everything that was being 24 done was to try and ensure that mis-balances were not 25 a function of the system and that's what the work was 84 1 intended to do. 2 Q. Now, this document went to ICL Pathway. 3 A. Yes. 4 Q. This document is a distillation of the discussions, the 5 many discussions, that you'd had with ICL Pathway around 6 the acceptance issues. So, so far as you were 7 concerned, ICL Pathway was aware of the liability issues 8 that might arise from the payments and receipts 9 mismatch. 10 A. I would expect that to be the case. 11 SIR WYN WILLIAMS: Mr Beer, are you aware of any other 12 would-be questioners? 13 MR BEER: Other people have put in requests -- 14 SIR WYN WILLIAMS: Mr Stein sent me a secret code by saying 15 no -- 16 MR BEER: Shaking of the head. 17 MR STEIN: I don't think Mr Beer can see that because of the 18 wall. 19 MR HENRY: Sir, I had questions but they've all been covered 20 by counsel to the Inquiry. Nothing further. 21 SIR WYN WILLIAMS: Thank you very much for coming to give 22 evidence to the Inquiry, Mr McNiven. 23 So I think this afternoon's witness is remote; is 24 that correct, Mr Blake? Have we got a likely time for 25 start? 85 1 MR BLAKE: 2.00 pm. 2 SIR WYN WILLIAMS: So we have an extended lunch break, all 3 right. 4 (12.37 pm) 5 (Luncheon Adjournment) 6 (2.00 pm) 7 MR BLAKE: Good afternoon, sir. 8 SIR WYN WILLIAMS: Good afternoon. 9 MR BLAKE: Can I call Mr Fletcher, please. 10 SIR WYN WILLIAMS: Yes. 11 KEVIN FLETCHER (sworn) 12 Examined by MR BLAKE 13 MR BLAKE: Thank you very much. Can you give your full 14 name, please? 15 A. Kevin Joseph Fletcher. 16 Q. Thank you for attending remotely today, Mr Fletcher. Do 17 you have in front of you a witness statement? 18 A. Yes, I do. 19 Q. Can I ask you to look at that witness statement. Is it 20 dated 16 November 2022? 21 A. Yes. 22 Q. Can I ask you to look at the final page. That's page 17 23 of 17. 24 A. Yes. 25 Q. Is that your signature? 86 1 A. Yes, it is. 2 Q. Can you confirm that the statement is true to the best 3 of your knowledge and belief? 4 A. I can. 5 Q. Thank you very much. That statement is now in evidence 6 and will be uploaded onto the Inquiry's website. 7 WITN06000100. The questions I'm going to ask you today 8 will be supplementary to the evidence that's in that 9 statement. 10 I'm going to begin by asking a little bit about 11 your background. You were employed by Her Majesty's 12 Forces for just over 20 years, between 1972 and 1994; is 13 that right? 14 A. That's correct, yes. 15 Q. Did your role in the Armed Forces include training to 16 some extent? 17 A. Yes, it was quite early on. Like you trained on courses 18 as you're going through and then, actually, then start 19 to train the courses. I had quite an interest in 20 training so at a fairly early age I got involved in 21 training other soldiers in different things, which 22 culminated in a tour with our junior leaders regiment. 23 I'd come out and did I two and a half years training 24 junior soldiers on all aspects of military and tactical 25 weapons courses, basically. 87 1 Q. Thank you. In 1994 after leaving the Armed Forces you 2 joined Peritas? 3 A. Yes. 4 Q. Was it Peritas or KnowledgePool at that stage? 5 A. It was Peritas at that stage and they advertised -- as 6 I was finishing in the Forces, they advertised for 7 people who trained on IT systems. I had done quite 8 a lot of IT systems for the juniors and other roles that 9 I had within the Forces. They didn't say what the job 10 was. They just said that it was a new system to be 11 launched and people could come along for an interview 12 and if successful then attend a course that would then, 13 if you were successful in that, be offered the job. 14 On arriving there, I found out it was the 15 implementation of the National Lottery system. I was 16 fortunate enough to get the job after the training and 17 very shortly after that they asked if I would then train 18 other trainers. 19 Q. So your first role was working on the National Lottery 20 for Peritas? 21 A. Yes, it was. 22 Q. Can you tell us the link between Peritas and 23 KnowledgePool and ICL? Were Peritas and KnowledgePool 24 the same thing but different names? 25 A. I mean, KnowledgePool was an autonomous company within 88 1 the group and it just changed the name, really, from 2 Peritas to KnowledgePool but, as far as I'm aware, the 3 position of the company stayed the same as that 4 autonomous company within the group, which meant they 5 could actually bid for other business outside ICL but 6 were also usually the first choice of training for ICL 7 projects, particularly IT rollout projects. 8 Q. It was a subsidiary or linked to ICL, was it? 9 A. It was linked to ICL, yes, but, as I say, it was what 10 they called an autonomous company within the group, as 11 far as I know. 12 Q. In September 1998 you were given your first full-time 13 contract. I think you began your initial role not on 14 contract -- is that correct -- or not as a full-time 15 employee at least? 16 A. The original role was as a contractor and it was some 17 time after that that we were in Liverpool and Stuart 18 Kearns, who was the director at the time, called me and 19 then offered me a full-time role within the company. 20 Q. Can you describe very briefly the positions that you 21 held between 1998 and 2002? 22 A. Very briefly, I was a contract trainer to begin with and 23 then I went into to be a trainer on the Lottery system. 24 It wasn't very long that I had been trainer that they 25 then promoted to a regional manager of training and then 89 1 I was -- after that, I'd finished, the company then 2 wound right down then to just a few people and, all of 3 a sudden, they won the Post Office project and, of 4 course, it started to gear up again. That's why I was 5 offered full-time work. 6 From then, I was a training manager and then went 7 to -- on a region, I trained the other trainers and to 8 end up, I ended up as director of what was then 9 KnowledgePool. 10 Q. Then in 2002, you left and you moved to Manchester City 11 Council, retiring in 2012; is that right? 12 A. Yes, that's true. 13 Q. Thank you. I'm going to ask you about the training that 14 was provided. We will come on in due course and look at 15 various documents that describe them in detail but, by 16 way of an introduction, can you briefly explain what the 17 user awareness event was and what user training was and 18 how they differed from each other? 19 A. Well, the user awareness events, as far as I recall, 20 were to actually give an idea to a larger number of 21 postmasters when their region -- what was likely to 22 happen in their regional and when they were likely to 23 come online and what coming online entailed. The user 24 training was actually a number of courses that were 25 given to both counter staff and also to subpostmasters 90 1 and managers to actually operate the system within their 2 own premises. 3 Q. Who was it that would provide that training? 4 A. It would be KnowledgePool who provided the training. 5 Can I just add, though, to that bit that, subsequent 6 until the training, there was also a number of other 7 elements of the training, such as an assistance within 8 that training. So it wasn't just the courses, it was 9 the documentation and the Helpdesk. There was a number 10 of other parts of the training or the support for the 11 training. 12 Q. So you had a lecture-based user awareness course, you 13 had a classroom-based training, and then you had various 14 documents also, such workbooks, to assist with the 15 training. Is that a fair summary? 16 A. That's correct. Included in that was also -- was 17 a training mode within the actual system itself, so in 18 other words they could switch from a live system into 19 a training mode. 20 Q. So there was a button on the Horizon system that you 21 could press that would assist you with training? 22 A. Yes. 23 Q. Thank you. I want to turn to your statement. I'm just 24 going to take you through a few passages within your 25 statement. Could I ask for it to be brought up on 91 1 screen. It's WITN06000100. 2 Can we look at paragraph 10, which is on page 6. 3 If we could scroll down that page to the second half of 4 the page. This is a section where you talk about 5 classroom training and you say the classroom training -- 6 it's at (f): 7 "I have no knowledge of why the training medium of 8 classroom based training was chosen for the user 9 training course as I was not involved in that decision 10 process. I do however consider this to be the most 11 appropriate training medium in this case because when it 12 was presented to POCL [that's Post Office Counters 13 Limited] they signed it off as fit for purpose." 14 I'm going to take you through a few similar 15 paragraphs in the statement. Can we look at 16 paragraph 16 on page 8, please. It's the final line in 17 paragraph 16. This relates to issues identified during 18 the pilot or post pilot events and you say: 19 "I do believe that any issues identified during or 20 post pilot events would have been rectified in the 21 programme which was final signed off by POCL as fit for 22 purpose." 23 You'll get an idea of why I'm asking this question 24 shortly because the phrase "fit for purpose" is 25 regularly used. Let's look at paragraph 17 on page 9. 92 1 This is about the feedback form. You refer to the 2 feedback form and you say, it's about halfway down that 3 page: 4 "At the time I did consider it appropriate to have 5 different columns on the feedback form as no questions 6 were raised about the form by POCL and it was approved 7 for use as was." 8 Can we look at paragraph 29, page 11. This is 9 about the user awareness event, and you say there: 10 "The training did not differ at all from the 11 design training programme. Once the training programme 12 was signed off by POCL as fit for purpose it was 13 delivered as is." 14 Can we look at page 50, in paragraph 42. This is 15 in reference to the course appraisal forms and you say, 16 halfway through that paragraph: 17 "At the time I did consider the course appraisal 18 form to be appropriate and this was based on the POCL 19 approval of the form and sign off by POCL as fit for 20 purpose." 21 I'm nearing the end of the statement. Let's look 22 at paragraph 50, page 17. It's the top of that page. 23 It says: 24 "The full programme was delivered approved and 25 signed off by POCL and within the allotted timescale." 93 1 Then finally I'm going to read the top of 2 paragraph 52 on that same page, if we could scroll down, 3 thank you. It says: 4 "In my view this is training programme fully 5 enabled trainees to balance. If this had not been the 6 case then POCL would not have approved and signed off 7 the programme as fit for purpose." 8 It's fair to say that you rely quite heavily in 9 your witness statement on the fact that the Post Office 10 signed off various aspects of the training programme. 11 Do you agree with that? 12 A. Yes, I do. They were very insistent -- it could be 13 after several reworks, so we may have submitted 14 a solution or a process, which balanced the manual 15 system against the electronic system and then that would 16 go forward in various stages to POCL and they would then 17 require reworks, and then those reworks would go back, 18 and sometimes two or three times, before they actually 19 were deemed fit for purpose. 20 Q. So the Post Office was heave involved in developing the 21 training programme; is that right? 22 A. Absolutely. 23 Q. You say "fit for purpose". I mean, they didn't sign 24 a piece of paper that said "This is fit for purpose", is 25 that your way of describing their agreeing to proceed? 94 1 A. Yes. I mean, once -- if there were no more -- if there 2 were no more changes to it and they agreed that it was 3 fit for purpose, in other words it fulfilled the task 4 that it was meant to do for that specific part of the 5 processes, whether it be EPOSS or balancing, et cetera. 6 Q. Was your measure of success whether or not the Post 7 Office refused or agreed to proceed with something, 8 rather than some sort of internal quality control? 9 A. We had our own internal quality control and sometimes 10 there was -- it was a case of we actually went to 11 different post offices, some of us that were involved in 12 the creation of the documentation, and actually watched 13 people doing in a live environment the actual processes. 14 From those processes, of course, we linked that 15 with what the Post Office was giving us about certain 16 things that it had to do on the system, certain actions 17 on the system. We then wrote up that as an action and 18 then, as I say, it went to the Post Office for sign off 19 and, as I say, it could come back two or three times 20 before it actually -- or several times -- before it was 21 actually approved. 22 But once it was approved then that was the process 23 we needed to follow. 24 Q. Generally speaking, who was that contact within the Post 25 Office who would sign things off? 95 1 A. The one I remember mostly was a lady called Sue Smith, 2 and she was to do with the training for POCL. I think 3 she was part of the procurement team but I'm not 4 100 per cent on that. 5 Q. Did you have any involvement with any senior management 6 within the Post Office? 7 A. Again, they came to one or two of the demonstrations 8 that we actually gave. We actually had one session, 9 I do remember, in Stockport where some of the union 10 representatives came to look at the system and several 11 managers -- I can't remember all the managers -- but it 12 was widely demonstrated, sections of it were 13 demonstrated to very senior members within POCL. 14 Q. You've said unions. Is that the National Federation of 15 SubPostmasters? Is it the Communication Workers Union? 16 A. I'm pretty sure it was National Federation of 17 SubPostmasters. 18 Q. Thank you. I want to look at the objective of the 19 training programme. Can we look at FUJ00001276, please. 20 This is a very early document. This is dated 1997. 21 There is a later version that we have -- I'm not going 22 to bring it up but, just for the purpose of the 23 transcript that's FUJ00001322 -- from July 1999 but it 24 is the same, insofar as the section that I want to take 25 you to, which is on page 5 of this document. 96 1 This sets out the "Objective of the Training 2 Programme". Perhaps we could highlight that 2.2 and 3 blow that up slightly, if possible. Thank you. 4 I'll read that to you. It says: 5 "ICL Pathway have contracted Peritas Limited to 6 provide the training programme in support of the BA/POCL 7 Counter Automation project. The training programme is 8 required by ICL Pathway to meet the following 9 objectives ..." 10 The first: 11 "Compatibility -- the programme must be managed 12 and delivered in a manner consistent with the 13 implementation programme undertaken by ICL Pathway 14 Limited and their other subcontractors. 15 "Timeliness -- No individual is to be trained more 16 than five working days prior to the automation of their 17 normal counter position." 18 Then: 19 "... the required scope, which is -- 'To ensure 20 that all staff who work within a post office are 21 competent in the use of the automated platform, are 22 aware of the impact on operational procedures caused by 23 the introduction of the platform and that specialist 24 staff are provided with the appropriate additional 25 information to perform their job role within 97 1 an automated post office'." 2 Then it gives appropriate competence levels. It 3 says: 4 "The delivered programme is required to ensure 5 that 95 per cent of personnel have a minimum competence 6 that they are capable of processing 90 per cent of all 7 transactions undertaken by their base office correctly." 8 Were those objectives that you were aware of? 9 A. Maybe not in exactly the same words but, certainly, that 10 was an aim of the courseware and the training programme. 11 Q. We will look in more detail at the training but do you 12 think that those objectives were achieved? 13 A. I believe they were achieved, although the amount of 14 people that were trained, it's very difficult to put 15 an actual percentage of it. As I said in my own witness 16 statement, there was a wide range of both age groups and 17 IT competency in the Post Office itself and people who 18 worked in the Post Office. I don't know if it was ever 19 measured to the fact that it was those 90 per cent of 20 all transactions and 90 -- 95 per cent of personnel of 21 a minimum competence. They certainly undertook the 22 course as is and, yes, but putting a percentage on it, 23 I couldn't do that. 24 Q. Can we look at FUJ00001280, please. This is a document 25 that you wrote. It is the training and user awareness 98 1 style guide. I'll just wait a moment for that to be 2 brought on to screen. I'm not going to take you to 3 detail of this because I don't think it takes us 4 anywhere but, in terms of the document itself, if we 5 scroll down, we can see that you're the author of this 6 document. This was -- it's a style guide that sets out, 7 essentially, how training materials should appear. Is 8 that a fair summary? 9 A. Yes, from what I remember of it. As I say, it's 10 23 years ago, so remembering exactly what's in it is 11 difficult. But yes for the main part it was but what 12 would appear and how it should appear. The style guide, 13 again, was -- it had to meet both KnowledgePool and POCL 14 standards; in other words, fit in what we normally would 15 produce. 16 Q. Can we just quickly scroll through that document just so 17 we can get a flavour of what it contains. If we look at 18 page 18 or 19, for example, it gives examples of 19 workbooks and what they might look like, that kind of 20 thing. Was this the kind of thing that you produced? 21 A. Yes, it was. 22 Q. What other documents of this kind do you recall 23 producing? 24 A. Well, actually, this was a style guide for most of the 25 things. You know, there was the actual workbook, there 99 1 were the quick reference guides, et cetera, that were 2 produced to support the training. 3 Q. Did you produce the workbooks themselves? 4 A. Most of them, yes. 5 Q. So we'll come to look at them but some of them have, 6 I think, your name as an example, I think, as an example 7 username in workbook 9. We can look at that in due 8 course, if we need to. But the substance of those 9 workbooks then that were produced for the training, that 10 was something that you produced? 11 A. Yes. 12 Q. I want to talk about the early training sessions, 13 starting with what was called the first 14, and was 14 February/March 1999. I'll bring the document up but can 15 you tell thus background to the first 14? 16 A. These were a number of, if you like, trial courses where 17 it was to give the trainers and delegates, without 18 overlooking -- in other words, there wouldn't a great 19 lot of the senior management at each of -- or there 20 wasn't supposed to be a great deal of senior management 21 that first 14 courses, one, really to give the trainers 22 a chance in not a live environment but an environment 23 with the real postmasters and, another, to give the 24 postmasters a real chance on the system without being 25 overlooked by some of the very senior management and to 100 1 try to get as honest feedback as we could on the actual 2 course itself and how they felt about it and how the 3 trainers managed over the period of the course. 4 Q. Can we bring up on screen POL00039733 and perhaps if we 5 could scroll over to the next page. So this is 6 a report, I think, that you wrote. If we look at the 7 page after that it has you down as the author. Do you 8 remember writing this report? 9 A. No, not outstanding to other reports that I wrote but 10 I have a recollection of it but I wouldn't be able to 11 tell you exactly what was in it, no. 12 Q. Was it the first significant report that you wrote in 13 respect of the effectiveness or otherwise, of the 14 training for the Horizon system? 15 A. Yes, I would say so, particularly with the Post Office 16 staff. 17 Q. It's dated 28 March 1999. 18 A. Yes. 19 Q. Can we look at page 5, please, and I'll read to you 20 section 1 which gives the introduction. It says: 21 "ICL training services were requested by 22 Pathway/POCL to provide trainers for a series of courses 23 for Counter Assistants and Counter Managers on the 24 Horizon System." 25 So pausing there, there are separate training 101 1 courses for counter assistants and for counter managers; 2 is that correct? 3 A. That is correct. 4 Q. "The delegates on the courses were volunteers from 5 POCL." 6 They were volunteers. Were they subpostmasters, 7 assistants or something else? 8 A. They were both, I believe. There was postmasters and 9 assistants. 10 Q. Do you know how they were selected? 11 A. No. That would have been Post Office who would have 12 gave us the names. We would have had nothing to do with 13 the actual selection of the delegates attending. 14 Q. "The aims of these practice courses from an ICL Training 15 Service perspective were as follows: 16 "1. To give experience to new trainers who had 17 completed the ICL Training Services induction course in 18 November/December 1998 and a recent Horizon update 19 weekend in delivering the Counter Assistant and Counter 20 Managers events." 21 Who were those trainers? The new trainers, who 22 were they? Were they people who were employed by 23 Peritas, were they self-employed, were they contractors? 24 Do you know their backgrounds? 25 A. They were mostly contractors but they'd worked on other 102 1 projects for Peritas and for KnowledgePool -- not all of 2 them but some of them. 3 Q. Do you have an idea of how many trainers there were at 4 all? 5 A. It was certainly -- at its peak there were certainly in 6 the region of 250. 7 Q. Thank you. 8 "2. To receive feed back from delegates on the 9 course content. 10 "3. To evaluate the Performance Standard 11 Assessment ... results. 12 "4. To evaluate the equipment reliability when 13 used in a training environment. 14 "Pathway/POCL had agreed to use the courses as 15 an opportunity for new trainers to train in a real 16 environment." 17 Now, real environment, what do you understand by 18 that? 19 A. Well, a real environment, for us it wasn't a live 20 environment; there's a definite distinction between the 21 two. The systems were stand alone and, therefore, you 22 couldn't actually link into any short of network. 23 A real environment for us would have been going to 24 a room, whether it be in a hotel or whatever was chosen 25 for the actually training, and there were several 103 1 different types of room that we did manage to get, and 2 setting up the equipment, getting it all ready to go, 3 laying everything out, and making sure that as, you 4 know, as near as we could to actually make it as though 5 they'd been out on the road, we'd set up a classroom, 6 everything else, and the postmasters and counter 7 assistants came to attend the course. 8 Q. Thank you. So it wasn't in a post office and it wasn't 9 dealing with real customers? 10 A. No. 11 Q. But it was trying to replicate that environment in 12 a classroom? 13 A. Correct. 14 Q. In terms of how the training went forward from, say, 15 '99/2000 and onwards, was that still the format in terms 16 of it not being within a post office or on live 17 equipment? 18 A. Yes, that's all we could do. We had to have -- 19 everything we did in that, because of the amount of 20 trainers involved, the amount of training in locations 21 the width and breath of the country, we had to have 22 a generic approach to the training. So once we actually 23 got it, you know, as per the course specifications then 24 it was delivered as that each time. But, as far as 25 I know, it was never delivered on a live system. 104 1 Q. This training in February and March 1999, that was very 2 early on. It was almost 12 months before the national 3 rollout began properly. Were you aware at this time 4 that work was still ongoing in relation to the Horizon 5 platform? 6 A. Absolutely. I mean, I used to pay regular visits to 7 Feltham where they were developing new things and 8 actually improving some aspects of the system. So it 9 was -- we could test the courseware out but, obviously, 10 it was ongoing, as you say, a year before, before the 11 actual final system would have been signed up. 12 Q. So as a company that was linked to ICL, did you have 13 free access to ICL? I mean, you have said that you 14 visited. Could you go when you wanted to, speak to who 15 you want to? 16 A. Yes, I mean, usually if we had -- if there was sum issue 17 that I would go there and certainly one of the senior 18 training team would have gone down and actually looked 19 and tried to find out how it was developing and what 20 version we were up to because, of course, everything was 21 version controlled down at Feltham and just to see if it 22 was -- how far off it was so that, if we did have 23 a question from Post Office, why that wasn't actually 24 there yet or being used. In those early stages, we 25 could say "Well, this is that stage it was at at 105 1 development at Feltham". 2 Q. Can we look at page 6, please, in the bottom of page 6. 3 This looks at the feedback and it has totals there of 4 the feedback in the very final column at the bottom. 5 I've added those up. So it's 9 plus 66 plus 179 plus 6 137. That makes a total of 391. So does that sound 7 about right, that there were 391 attendees at this first 8 14 training session? 9 A. Yes, it would be about. 10 Q. I'm going to take you through some of the feedback. Can 11 we start on page 7, please. So if we look at page 7, it 12 starts with the Bristol counter managers training and if 13 we look at the remarks below. So some of the -- I'm 14 going to give you just some examples of the remarks, 15 I won't take you to every one and I should say that 16 there are some positive comments within this document 17 but I'm not necessarily going to focus on those. 18 I would like to talk to you about, for example, 19 number 1, "More time required (several comments). A bit 20 further down "Too much information compressed into 21 course". A little further down "Although trainer was 22 excellent not enough time to cover all topics plus 23 questions". "Good trainer not enough time allowed". 24 The next one is the Bristol counter assistants and 25 if we go over the page -- thank you -- it says there: 106 1 "A lot of information to take in on one day no 2 doubt practice is the best way to learn." 3 Scrolling down Bristol counter managers, and we 4 have quite few comments there. 5 "Not confident not computer literate. 6 "I will need extra training. 7 "More time on balancing -- error notices." 8 Looking down a little bit more it says: 9 "Second day should be expanded to full day -- 10 especially for delegates who have no experience of 11 automated systems." 12 I think we said earlier it was one and a half days 13 for managers, wasn't it? 14 A. Yes, it was. 15 Q. If we look at that final paragraph on that page, it 16 says: 17 "course definitely requires two full days second 18 day is six hours with no lunch break. I feel the course 19 is unsatisfactory because it is very intensive and 20 coverage of important tasks ie balancing is rushed as 21 a result. Bearing in mind a subpostmaster could be 22 asked to do their first balance unsupervised." 23 Scrolling over to the next page, 25 February 24 Bristol counter assistants, about halfway down on those 25 comments it says: 107 1 "Not yet totally confident -- 1 day is not 2 enough." 3 So the counter assistants course, was that one 4 day? 5 A. Yes. 6 Q. The final comment there it says: 7 "It would be useful for staff to try more 8 transactions -- products not covered." 9 Moving on to the Glasgow counter assistants, 10 5 March, if we could scroll down to the next page: 11 "More time needed on Reports." 12 Third comment says: 13 "Not confident on end of day procedures practice 14 will help." 15 A little further down it says: 16 "More time needed on training." 17 Two persons have said that. 18 "Not confident at all." 19 If we look at the bottom there it says: 20 "Not very confident. 21 "Do not have enough information to balance my 22 position at the end of my shift. 23 "Too much information was crammed into two short 24 a time, the course was too long time-wise." 25 Next is the Glasgow counter managers, if we could 108 1 scroll down on to the next page, some of the feedback 2 there is: 3 "Balance ran out of time more time required. 4 "More time daily summaries/balance." 5 We move on to the Newcastle counter managers and 6 if we look down the second comment there: 7 "More on transactions and how to balance. 8 "How to put things right (more time)." 9 A bit further down it says: 10 "More on balancing outputs/actual printouts." 11 A little bit further down it says: 12 "Balance/cash account procedure (more time)." 13 On to the next page, please, Birmingham counter 14 managers. Again, quite similar concerns being raised 15 there. They say: 16 "Concerned I feel if you're not careful in the 17 accounting aspects of Horizon you might find yourself in 18 trouble. You need to know what you're doing. 19 "More time needed on balancing procedure. Sped 20 through a lot of information and the course quite 21 intense. 22 "Balancing (more time). 23 "Pretty confident with day to day work & 24 procedures, still confused over the balance in relation 25 to comparing it with what I do at present." 109 1 A little further down it says: 2 "A little longer needed on balancing procedures." 3 Near the end there it says: 4 "Balancing section is a lot to take in within the 5 current format. 6 "Confident in day 1 content, less confident on the 7 management/balancing section." 8 The balancing section, I think, was on the second 9 day, wasn't it? 10 A. Yes. 11 Q. If we keep on scrolling, I think the next page is 12 actually just a photocopy of the first page so we can go 13 over the page again. We are at Newcastle. If we keep 14 on scrolling perhaps through to Birmingham counter 15 assistants and over the page "Remarks general": 16 "I need at least 2-3 times more of this training 17 before I can feel confident. 18 "I need to be training again for the course, as 19 I cannot remember everything that was taught. 20 "In general it felt a bit rushed. I did feel that 21 the course was a bit rushed. It may be better held over 22 two days." 23 Another comment near the bottom "Really needs two 24 days". That counter assistants, so that's only the 25 one-day course and they are saying there they need two 110 1 days. 2 St Albans counter managers, if we have a little 3 look below that table. Second entry there: 4 "Balancing needed more time." 5 About half way down: 6 "Having experience of ... ECCO and understanding 7 balance periods and CAP helped. Although I feel [half 8 a day] for balancing could be insufficient for offices 9 that do not have this experience." 10 There are more entries. I don't think need to 11 take you to them all. There are undoubtedly some 12 positive comments within this feedback but is it fair to 13 say that there are two themes that really stick out 14 there: one is of not enough time and the second is 15 insufficient information on balancing? Do you agree 16 with that? 17 A. I think whenever I've taught IT systems before, I mean, 18 you're subject to certain restrains. I mean, if you had 19 had it over a week you probably would have got as many 20 comments saying too much time we went over and over it 21 again and, again, it is a thread that runs through a lot 22 of the comments is the amount of time. 23 It's very difficult really because, for some 24 people, it wasn't enough time, for some people with the 25 additional support that they had in the form of the 111 1 workbooks the quick reference guides and Helpdesk, 2 et cetera, and the chance to actually go on to remedial 3 training then perhaps we should be looking at that, at 4 some of the feedback with relation to that, as opposed 5 to just looking at the feedback of those very early 6 courses, you know, without actually factoring in the 7 other assistance that was available to subpostmasters 8 and the staff. 9 Q. We'll look at the further assistance and we'll look at 10 some feedback later on but, insofar as this early 11 feedback is concerned, so March 1999, is it a fair 12 comment to say that, looking at those remarks, there are 13 quite a few that said there wasn't enough time and quite 14 a few that said that there was insufficient information 15 on balancing? 16 A. I agree. The other thing I would actually add into that 17 mix, though, which I think is very relevant, is the fact 18 that some of the postmasters and Post Office staff had 19 been actually balancing in a certain way for many years 20 and took a great pride in it, to be fair to them, and 21 I talked to a lot of postmasters at the time and it was 22 a real pride thing to balance the books as they did it 23 as they'd always done it. So any change to that 24 balancing process and anything that was taken away from 25 them, they were going to be incredibly confident in what 112 1 they did to something that was new and it didn't always 2 sit very well. I'm not making that as an excuse but it 3 is a point of fact. 4 Q. Can we look at page 20 of this document, and that has 5 the conclusion. The conclusion, I'm going to read it 6 out for the record, it says: 7 "The trainer appraisals have been very favourable 8 for a first attempt. There's still room for 9 improvement, particularly in the area of timings, 10 although the timings did improve where a trainer 11 delivered a subsequent event. It would appear from some 12 of the delegate appraisals that they expected balancing 13 on the counter assistants course. The appraisals 14 annotated unsatisfactory on overall level of 15 satisfaction was because of the amount of information to 16 be assimilated and the course content rather than any 17 problem with the trainer's delivery." 18 So the summary conclusion there is that the issue 19 was less with the way that the trainer was delivering 20 the course and more of an issue about the amount of 21 information that attendees needed to assimilate? 22 A. Can I also add from personal experience there that, if 23 you are delivering a training course particularly of 24 that length for the first time, it's a huge amount for 25 the trainer to remember and it's not the easiest thing 113 1 to do. So you usually find, on the first few courses 2 you do, you haven't got as much judgement of when to 3 actually slow down a little bit or make sure that's been 4 assimilated. That comes with maybe one or two courses 5 and then you actually feel more confident with the 6 material. So there's always a little bit of that as 7 well. 8 So while I accept that more time was a definite 9 thread running through it and the balancing also, there 10 are some other contributory factors as to why it might 11 not have been the slick as it could have been in the 12 first few events. 13 Q. Absolutely. But let's go back to page 12 of this 14 document which looks at a manager's course, the 15 Birmingham manager's course in March. 16 So this is a fair way through this first 14. 17 We're looking now at 8 and 9 March. Can we just look at 18 some of those comments again. The first is: 19 "Concerned I feel if you are not careful with 20 accounting aspects of Horizon you might find yourself in 21 trouble. You need to know what you're doing. 22 "More time needed on the balancing [process]. 23 Sped through a lot of information and the course is 24 quite intense. 25 "Balancing (more time). 114 1 "Pretty confident [on the] day to day work & 2 procedures, still confused over the balance in relation 3 to comparing it with what I do at present." 4 So, I mean, there are a fair few comments there 5 quite a few remarks that address concerns about 6 balancing, rather than simply the amount of time that 7 has been allocated in the course. 8 A. Yes, I accept that but, you see, there I mean, that sort 9 of -- where it says there -- yes: 10 "... still confused over the balance in relation 11 to comparing it with what I do at present." 12 I mean, that just justifies what I've said that 13 there, that some the postmasters for many, many years 14 had taken a pride in balancing as they did manually and 15 it was perfect and they took a great pride in it. To 16 suddenly take that away and give them an electronic 17 system to do it with, which was, in a lot of respects, 18 very different it was quite a culture shock to them on 19 the actual balancing side. 20 But I'm not decrying the fact that, yes, we would 21 have liked more time, I would have thought -- or they 22 would have liked more time and the balancing, yes, was 23 what it was on the system. But there were other support 24 mechanisms available to them. 25 Q. If we pause in time there then, so February/March 1999 115 1 do you think that the training course was sufficient, 2 insofar as it addressed balancing? 3 A. It addressed balancing within the time restraints that 4 we had to do the course and it certainly went through 5 the balancing process but, again, the trainers and, 6 well, everybody really, encouraged the attendees to 7 actually use the other things that were available to 8 them to actually confirm the knowledge that we'd picked 9 up on course, and certainly the Helpdesk. 10 From my own personal experience of working in the 11 Post Office during the actual whole event, and that was 12 one in Slough that I worked in, if they needed to 13 resolve anything, the first thing that most postmasters 14 did, in a few offices that I went in, if something was 15 wrong, not with the Horizon System or anything, they 16 picked up the phone and phoned the Helpdesk, and they 17 didn't seem to -- they very rarely seemed to use the 18 documentation, supporting documentation. The Helpdesk 19 was their key. They rang the Helpdesk, the Helpdesk 20 solved the problem and they got on with the end of the 21 day. 22 Q. The Helpdesk assists once you are on the system but, 23 presumably, the training before you get on the system is 24 pretty important, isn't it? 25 A. Oh, absolutely, absolutely. But to get every single bit 116 1 of what was a fairly complex course into that time and 2 you'd be perfect on it as you finished the courses then 3 I think that was a tall order, to say the least, 4 considering some of the delegates which were attending 5 the courts. And, as I said, the age range was fantastic 6 really and the actual IT knowledge was excellent to none 7 at all. 8 So it wasn't just about the actual training 9 itself, it was that sometimes it was the people who 10 actually attended and no disrespect to them but they 11 tried their best but it's bound to be something new, if 12 you'd never done it before, always seems more complex. 13 Q. So let's say you were a manager and you have a day and 14 a half allocated for training. Your evidence is that 15 there was sufficient training, insofar as balancing was 16 concerned, for a day and a half's course but do you 17 think a day and a half was sufficient? 18 A. Again, it depended -- I come back to it's depending on 19 the delegates. For some, obviously, it wasn't because 20 that's expression they gave and for many it was. You 21 know, so it was striking that balance the two and 22 certainly the courseware and the delivery of the course 23 showed you how to balance. For most -- I can't put 24 a percentage on it, but for a large number of people 25 that was enough and for some people it wasn't enough. 117 1 But when you say you're a postmaster and you come 2 on a course on balancing, what's your background to 3 actually doing that, you know, you would have to look at 4 how -- you know how au fait were you with IT equipment 5 and using IT equipment to do the sort of functions that 6 were asked on the system. 7 Q. Did you take away from this exercise -- I mean, looking 8 at those kinds of comments that are on the screen now, 9 did you take away to any extent that more might be 10 needed to be done, insofar as training for balancing was 11 concerned? 12 A. Absolutely. It was trying to make it so that the 13 trainers were as clear as possible on how to -- you 14 know, from the actual courseware to actually -- to make 15 sure the balancing was right, particularly on the 16 subpostmasters course. And it was a case of you went 17 through it as slowly as you could with some of the 18 people, and I know many of the trainers who didn't have 19 to finish at that time stayed behind with some of the 20 delegates who were really, you know, who were 21 struggling, some of the older delegates who were 22 struggling to actually run through a bit of it again. 23 I know that happened quite often. 24 So yes, it would have been nicer to have more time 25 for some delegates but I think it was sufficient time 118 1 for whatever the percentage was of delegates. But you 2 always want more time on training courses. 3 Q. Following this exercise, which the intention of this 4 exercise was to get a snapshot in time in the early 5 stages to try and improve the programme going forward, 6 what concrete steps did you take to improve the training 7 with regards to balancing? 8 A. We went through the balancing and tried to make it as -- 9 I can't say simple because, obviously, there was 10 a system to be followed -- sorry, there was a procedure 11 to be followed on the system but the trainers were very 12 aware that this was a very important part of the course. 13 In fact, the whole course was important but they 14 tried to actually explain it as well as this could 15 explain it and, actually, look out for people who are 16 really struggling on the course, particularly with that 17 element, to actually make sure they got some remedial 18 training. 19 Q. So once you received the product of this study, how did 20 you communicate that to the trainers? 21 A. Well, depending if the trainers had actually been on the 22 courses and had finished the courses, although there 23 weren't that many at that time who had gone through, but 24 it was part of then their induction and when they were 25 doing the three-week induction, we actually made sure 119 1 that on the last week, where they were delivering 2 elements on the system, a lot of that was on the actual 3 balancing and we had -- you know, we were trying to make 4 them aware there that this had to be explained as well 5 as they could and also that they -- if they saw somebody 6 struggling then they would actually make note of that 7 and, you know, carry out remedial action where 8 necessary, in other words report it back or point the 9 actual delegate into an area where they could get 10 additional support on balancing. 11 Q. Can we go back to the first page of this, which is the 12 fax header. This is sent from Alan Bourne to Kathryn 13 Cook. Are you able to assist us with who they are? 14 A. I will be honest with you, I haven't got a clue. I've 15 not got a clue. 16 Q. Do you remember this report being escalated in any way 17 within ICL Pathway, even to the Post Office? 18 A. I can't remember it being escalated. I do remember 19 actually that the -- we were very aware of the timings 20 on the course. I mean, all trainers were made aware 21 that they had to -- you know, that there were some 22 things that were generic which were fairly 23 straightforward, such as the EPOS, the Electronic Point 24 of Sale element was fairly generic. But actually the 25 accounting bit, the balancing bit, would be difficult 120 1 for some delegates, as I say, and we tried to rectify it 2 from a training level. 3 As far as it being escalated to hierarchy in the 4 Post Office, certainly Stuart Kearns, who was the 5 director at the time, was very aware of it. 6 Q. I am going to take you to another document, 7 NFSP00000340. This is a document from one month later. 8 In fact, on the first page, it says 1996 but, actually, 9 if we turn over the page it's a 1999 document and it's 10 one that we looked at this morning. It's comments made 11 by subpostmasters to Pam Jervis from -- the cover letter 12 is sent from Colin Baker. 13 Let's have a look at those. These are comments 14 that were made to the NFSP: 15 "Training. 16 "The first day of training is OK but the second 17 day is bad because it is rushed. They are not finishing 18 on time, but are rushing to finish before 3.30 pm, 19 because otherwise they have to buy lunch. Why [do you] 20 use the most expensive hotels? 21 A couple down it says: 22 "In every training session, nobody had done a main 23 balance, snapshot balances only. Nobody had been 24 trained to do a full balance." 25 So this is one month after 30 April 1999. Were 121 1 you aware of those kinds of comments, even if not those 2 particular comments? 3 A. Certainly, the first one, I don't understand that at 4 all. I don't know of any trainers who did that and they 5 were checked regularly. Why they'd use the most 6 expensive hotels, that again was down to a location -- 7 you know, to a location thing and to make, obviously, 8 the delegates as comfortable as possible. So, no, 9 I don't see that top one at all. I've never seen this 10 document before, as far as I know, and a lot of it I -- 11 you know, certainly on the training there, I don't 12 recognise. 13 Q. But I mean the first comment that it's rushed, the third 14 comment that nobody had done a main balance and nobody 15 had been trained to do a full balance, those themes were 16 similar to the themes that were picked up in the 17 February/March report, aren't they? 18 A. Yes, it would appear so. As I say, I don't actually -- 19 I can't relate to that. I can't remember the whole 20 balance procedure. I mean, it's 23 years ago. As far 21 as I know -- I mean, as I say, the actual balancing 22 process was signed off by Post Office and from their 23 hierarchy. So I would imagine that it -- you know, it 24 was fit for purpose. We carried out the training as it 25 should have been done according to the training 122 1 documentation and what the Post Office required. 2 I don't recognise that number 3 at all. 3 Q. You don't recognise it in as much as you didn't receive 4 it and didn't see it at the time or you don't recognise 5 it in that you didn't receive any complaints about 6 training failing to assist sufficiently with balancing? 7 A. No. I mean, there is always issues on training. There 8 is issues with the courseware and obviously -- not so 9 much the courseware but actually what is taught on the 10 course, and you will always get feedback: it's not long 11 enough, it's too long, the room was too hot, it was too 12 cold, the tea wasn't on time. You know, you get lots 13 and lots of feedback. 14 I've already conceded that we would have liked 15 more time on the second day but that wasn't my decision 16 and it was a case or the two hierarchical elements of 17 the actual training rollout, which was Peritas and also 18 POCL, agreed that's what we had to do on that day and 19 the trainers and myself and other people involved at 20 that level tried to do the best we could in relation to 21 what we'd been told to do. 22 Q. I appreciate it's some years after now but were they 23 themes that you recall at the time, in the early days at 24 least of training, so February, March, April, themes 25 about there not being enough time, ie that first 123 1 paragraph, it being a bit rushed, and problems with the 2 balancing, that third paragraph? 3 A. I certainly remember the not enough time but it wasn't 4 by everybody. I mean, some people would say "Yes, it 5 was spot on" and some people would say "It wasn't enough 6 time". I do recognise that certainly and I've already 7 conceded that point. We would have liked, certainly as 8 a trainer and trainers are part of the training team, we 9 would have liked more time but we had to go with what we 10 were given and what was agreed at a higher level than 11 ours. So with the time we had, we tried to do the best 12 we could. 13 Q. Do you think issues such as timing were raised within 14 ICL? You said you did what you did with the time 15 available. Did you raise it at all with anybody? 16 A. Yeah, I mean, it's always a concern about the time but, 17 again, as I say, it was known within ICL and coming back 18 again, repeating myself, is the fact that one of the 19 fallbacks to that particular comment was that there was 20 other help and support available. So when it was 21 raised, even if they hadn't picked up 100 per cent on 22 the course itself, there was other supporting things 23 that could be done to help them with balancing, such as 24 the Helpdesk, the workbook, et cetera, et cetera. 25 So, although it was a concern, it was felt that it 124 1 would be addressed by additions to the actual training. 2 Q. You said it was raised within ICL. With anyone, in 3 particular? 4 A. Well, certainly Stuart Kearns, by boss, would have known 5 about it and he would be dealing at that level but, as 6 far as me being a part of those meetings or have any say 7 in that, apart from feeding it in to Stuart Kearns, 8 I wouldn't have been able to do anything else about it. 9 Q. Thank you. Can we look at POL00028357. This is 10 a document we looked at this morning. Can we look at 11 page 4, please. This may well not be something that you 12 at the time. This is relating to Acceptance Incident 13 218. Do you remember anything reference to Acceptance 14 Incidents and Acceptance Incident 218? 15 A. No. Sorry, I have no recollection of that. 16 Q. This was a contractual incident that was raised by the 17 Post Office and if we can just have a look at what is 18 says there, it says: 19 "The Managers Training Course is not acceptable 20 due to deficiencies in the accounting modules. In the 21 live environment the training given did not equip the 22 users to perform the completion of office cash accounts. 23 This is a [I think it means 'basic'] POCL function that 24 is central to running and accounting for the POCL 25 network." 125 1 That Acceptance Incident was observed, it says, on 2 19 May 1999. Was anything along those lines ever raised 3 with you at all? 4 A. No, I mean, if anything, the time which it was raised 5 more backwards that when we looked that appraisals that 6 we got from the postmasters and counter assistants 7 actually attending the course, there was quite obviously 8 a lot, as you already pointed out, a lot of comments 9 about the timings, you know, that they weren't enough 10 time. That was passed up. 11 But, as far as this particular document and input 12 into this document then, no, it was passed up through 13 Stuart Kearns and the hierarchy of Peritas, and 14 I believe then to ICL but I wouldn't know, and certainly 15 POCL attended nearly -- well, all the development of the 16 training course. 17 Q. If we think back to that time period, so we're talking 18 May -- summer of 1999 into the autumn, towards September 19 and during September 1999, do you remember any concrete 20 steps that were taken to improve the training course, 21 particularly in respect of balancing issues? 22 A. Not concrete steps, no. I mean, I don't believe the 23 course was changed. The course couldn't really be 24 changed because there was an actual process to 25 balancing. So you can't -- it's very difficult to 126 1 then -- you can't change that process because that's the 2 process needed to balance. So, as far as concrete 3 changes to the system or the way the process was 4 delivered, I don't remember and don't recall any what 5 you would call concrete changes. 6 There was issues about it and obviously these were 7 passed up to the hierarchy, in my particular case 8 anyway. But we have to follow that process and I don't 9 remember -- I don't remember the system changing, 10 I don't remember any of the training changing to address 11 those issues. In fact, it wasn't actually my line of 12 process, it was the timing of the process that may have 13 been an -- well, it was an issue, obviously. 14 Q. Can we look at FUJ00001356, please. This is the 15 "Counter Managers Course Specification". It is dated 16 October 1999. You are listed as being on the 17 distribution list. Is this something you remember at 18 all -- not word for word but do you remember it as 19 a document? 20 A. No, not particularly, not as a document, no. 21 Q. Could we -- 22 A. Am I on the distribution for it -- I can't -- 23 Q. Yes, if we look down -- sorry. Your name's listed in 24 those final few -- 25 A. If I was on the distribution I certainly would have seen 127 1 it. The actual document I don't particularly remember 2 but, yes, maybe so. 3 Q. Can we look over the page, please. So this is the 4 specification for the counter managers' course and it 5 seems as though, in October 1999, there were amendments 6 made following the evaluation exercise. So that's, 7 I think, that there was an exercise in July 1999 and 8 then it says: 9 "Document is based on the courses presented as dry 10 runs to Post Office Counters Limited and signed off by 11 Trevor Rollason in September 1999." 12 If we look at page 3, this is the contents of the 13 course. It still seems to be a two-day course or a one 14 and a half day course that's spread over two days. Is 15 that right, in terms of the time period? That didn't 16 change? 17 A. No. It is right, sorry. No, it didn't change. 18 Q. If we scroll over to page 5, on page 4 we're looking 19 that Day 1 training course, and we're now on page 5, 20 which is still the Day 1 and there is quite a lot of 21 content dealing with the EPOSS system: EPOSS intro, 22 EPOSS continued, EPOSS scales, and then scrolling down 23 it says EPOSS Rems and reversals. 24 Were you aware, during this period, so October 25 1999, of any issues with the EPOSS system, any technical 128 1 issues with the EPOSS system? 2 A. No, I can't actually say I was. I mean, I think it was 3 all okay. I mean, as I said to you, almost all the way 4 through the initial parts of the project, they were 5 working on different parts of the EPOSS system and it 6 was a fairly generic -- the EPOSS sales on the system, 7 if I remember, were very generic. I don't remember 8 a lot, if any, of the changes on what you've shown me 9 there on EPOSS. 10 Q. Through your conversations with people at ICL, you have 11 already said how you're able to visit their premises and 12 talk to people, talk to developers. Did you talk to 13 developers at all during your period of training? 14 A. Yes, I did. One of them, one that I wanted to learn, 15 was barcodes on benefit books, so I worked quite closely 16 with a guy who was actually developing that at Feltham, 17 and he showed me how all that worked and that way then 18 I could answer more in-depth questions if any of the 19 trainers we were training had issues about the 20 barcoding, et cetera, on the benefit books. 21 So it was thing like that, I went down so I could 22 get a more in-depth knowledge on some things that 23 I could then explain to the trainers, as they were 24 either doing the training or going through the training. 25 Q. In any of those conversations that you had, did anybody 129 1 point out any issues they were having with EPOSS 2 software or any other bugs, errors or defects at that 3 time? 4 A. Well, it's very difficult really because you actually 5 get the -- it depends which version and the version 6 control at Feltham was incredibly tight. There was 7 a lady who ran the version control and she was well 8 renowned for being very tight on which version. So, in 9 other words, as they added a particular function, it 10 could affect another function, so it was -- because 11 obviously they were interlinked. 12 So you could revert back to the previous version 13 and then develop -- and it kept going like that. So 14 sometimes a new thing that was added affected some other 15 parts of the system but they wouldn't actually release 16 that. I think they would actually go back to the 17 drawing board until it didn't affect the version and 18 then, as the next version was cleared, it would then 19 become, say, version 1, and then it would be version 2 20 and version 3. 21 So it was always stable in the last version if 22 that makes sense. 23 Q. As somebody who was designing the courses and the 24 materials, we have a day here almost a day dedicated to 25 there EPOSS system. Did anybody point out to you that 130 1 there will be problems being experienced in the EPOSS 2 system at that time? 3 A. Not really not on the training systems, no. I mean, it 4 seemed fine. I mean, most of the EPOSS was -- it was 5 fairly straightforward. Some people some of the 6 delegates said never seen touch screen technology before 7 and things like that, and that was something that, 8 again, we had to go through with some of the delegates 9 but, as far as the actual sales, et cetera, on EPOSS, 10 they seemed to work fine. 11 I don't remember there being a problem with those, 12 apart from the fact it depends what version you are 13 looking at. I mean, it was a case of, as a version 14 became released, then it was fine, it had been tested 15 and it was great. It was only the version on from that 16 which might have affected the previous version and that 17 wasn't released then until it was made right. 18 Q. You weren't working on a live system. 19 A. No. 20 Q. So did anybody say "Hang on a minute, although you are 21 working in this environment, when the postmasters get 22 out to the real world, their system might operate 23 slightly different"? 24 A. No. I mean, there's no reason why it should. I mean, 25 that's a bit like saying when you put Windows on 131 1 a computer if you try it stand alone it's fine but if 2 you try it on a network it won't work. It should have 3 worked. I have no reason to believe it didn't work. 4 I don't remember anybody telling me the EPOSS didn't 5 work and didn't work well. 6 Q. You have said at the beginning of your evidence today 7 about how much you relied on the Post Office signing off 8 the various training materials. What did you see as the 9 role of ICL in relation to identifying technical issues 10 with Horizon and informing you about those? 11 A. Well, as I say, it was a case of coming back to the 12 Stuart again, as a director of the company. He actually 13 went down several times and talked to high level 14 meetings about any issues that we had. But we were 15 informed if anything was affecting the training or may 16 affect the training through Stuart at the meetings and, 17 as I said, because I sometimes -- and others too -- 18 wanted more in-depth knowledge about a certain process 19 on the system, that would allow us to maybe train it 20 better. We would actually go down to Feltham and speak 21 to the guys who were developing it -- and women, 22 obviously. 23 Q. In all of your conversations with people in Feltham, did 24 nobody mention any concerns they had with the Horizon 25 System? 132 1 A. Thousands but, you know, that's part of development. 2 They were developing a system. So, you know, there was 3 always some concerns. You know you don't develop 4 a system like Horizon and not have some concerns. It's 5 just the way it is. But those concerns would all have 6 to be sorted before that the next version or the stable 7 version was released. So yes, of course there were lots 8 of concerns by various people about various parts of the 9 system until they were rectified and were included in 10 the next version for release. 11 Q. Can we look at FUJ00001357, please. This is a document 12 that -- the "Training and User Awareness Baseline 13 Document". Now, you're not listed on the distribution 14 list of this but is this a document that you recall or 15 you would have seen at the time? 16 A. Again, it's very difficult to recognise individual 17 documents, even ones I wrote myself after 23 years but 18 if it was to do -- if I could have got my hands on it 19 and it was to do with anything training, I would have 20 read it. 21 Q. Let's go through and I see where we get to. The date 22 for this is 29 November 1999, so it's eight months after 23 the first 14 training that we talked about earlier this 24 afternoon. So we're eight months down the line now and 25 this is what's called the baseline document. Can we 133 1 look at page 9, please. There's a diagram on page 9and 2 is wonder if we can just blow up the diagram, please. 3 This shows the training solution. 4 Are you able to tell us what this shows at all? 5 I mean, if we start with, for example "User Awareness" 6 is that that the user awareness course was the first 7 interaction somebody would have with training, that 8 lasting two and a half hours. 9 A. Yes. 10 Q. Then you have a specific course depending on who you 11 are: so you have a counter course, which is a day; 12 a manager course, if you are a manager, two and a half 13 days; and then you have specialist training, for 14 example, for auditors, for trainers and for HFSOs. Are 15 those Field Support Officers? 16 A. Yes. 17 Q. Their training would be longer. That would be two to 18 five days; is that right? Is that how you remember it? 19 A. Yes, it is. I don't remember the specifics of that 20 course. I almost certainly did one for the auditors 21 because I actually went down and attended at least one 22 of those courses with the auditors to actually make sure 23 it was you know we were training it right and they were 24 getting all the information they needed because, 25 obviously, to be able to audit, they needed to be, you 134 1 know, really hot on the system, basically. 2 Q. So here we are in November 1999, so eight months after 3 that first report that you wrote and the length of the 4 courses are still the same, aren't they: the counter 5 course one day; manager course one and a half days. So 6 nothing has changed as far as that's concerned; is that 7 right? 8 A. That's true. 9 Q. Can we look at page 16, please. Halfway down -- thank 10 you -- at 5, it describes the User Awareness course. 11 Just so that we can learn a little bit more about what 12 these different courses are, I will just read that 13 second paragraph. It says: 14 "The User Awareness event is aimed ALL users 15 working within, or providing support to, post offices. 16 The purpose of the event is to provide an understanding 17 of the impact the impending installation and automation 18 programme will have on them as individuals and their 19 outlet as a whole. The overall aim is to elevate 20 concern users may have of the Horizon System and 21 encourage participation during training and 22 installation." 23 Was the user awareness course, I think it was 24 a voluntary course; is that correct? 25 A. Yes, it was. They were obviously encouraged by Post 135 1 Office to attend. As far as I can recollect, it was 2 voluntary but they were usually -- the ones that 3 I actually saw were always very well attended because 4 obviously it was going to have a big impact on the 5 business they were in. 6 Q. Was that essentially an introduction, a brief 7 introduction, into the system? 8 A. Yes, it was a brief introduction about what the system 9 did. It was where they fitted in in the rollout process 10 and, basically, what it says in that paragraph and they 11 could ask some questions at the end, et cetera, and if 12 that's all fine, and if not we took them away and fed 13 them back to Post Office and to Peritas to actually get 14 in touch and answer the question. 15 But mostly it was fairly straightforward. The UAE 16 was a fairly straightforward event. 17 Q. Could we look at page 18, please, if we scroll down just 18 a little bit, it has there "Managers" and this describes 19 the managers' course, so that's one and a half day 20 contiguous training event delivered over two days to 21 include venue setup and clear down: 22 "This course will be targeted at staff who are 23 required to understand the full functionality of the 24 automated platform. 25 "It is understood that all management grades will 136 1 need this training. It is also understood that other 2 staff may perform these tasks, in some cases as backup, 3 and they will also need the Managers training event." 4 So the managers' training, the one and a half day 5 event, that was for, for example, subpostmasters and 6 also for assistants who would sometimes carry out those 7 subpostmaster tasks? 8 A. Yes. 9 Q. Then you had a separate one-day course that we see there 10 for the counter staff. It's recognised that some of 11 these staff who perform some management functions would 12 attend, as I said, the managers' course. 13 Scrolling down, you then have those other courses 14 that were a little longer. You have the "Back Office 15 Audit", the "POCL Train the Trainer". So "Train the 16 Trainer" is a five-day course for, I think it's fair to 17 say, training those who trained? 18 A. Yes. 19 Q. Can we look at page 31, please. Scrolling down this 20 again, this goes into a little bit more detail about the 21 managers' one and a half day course and it mentions 22 balancing there. It says -- it's the fourth bullet 23 down: 24 "This course would be targeted at staff who are 25 required to understand the full functionality of the 137 1 automated platform including balancing activities." 2 Then scrolling down you have a section on counter 3 assistants. Can we go to page 36, please. This talks 4 about the actual format of the courses. So all courses 5 will start at or before 10 am. There will be a maximum 6 of six staff on each event. Then the final bullet there 7 says: 8 "The training audience will be a maximum of 72,000 9 post office staff, subpostmasters and assistants as 10 defined in figure 8.1 overleaf." 11 If we scroll down, it has there the numbers. Do 12 you remember those kinds of figures, so managers events 13 you were expecting -- 14 A. Sorry. 15 Q. Sorry. 16 A. I believe it was the biggest IT training event ever 17 undertaken in the United Kingdom and I think we ran more 18 events on one day than any other training event in the 19 United Kingdom ever. It was a huge undertaking to 20 deliver so many events across the whole of UK, you know, 21 to counter managers and also counter assistants. 22 Q. Because you have there 7,004 managers and I think we saw 23 somewhere that you don't begin the training until, is 24 it, five days before Horizon is provided to them? 25 A. That was true. 138 1 Q. So there was a very short space of time to carry out 2 quite a considerable amount of training? 3 A. It was a huge undertaking. I mean, we were -- I realise 4 that there are some things that -- we had a very good 5 rapport for the most part with the trainers and 6 postmasters and the staff. The trainers have a very 7 good rapport, from what I remember, and what I'm sure 8 I've had to with the postmasters, and both understood it 9 was difficult to train that many people in that time. 10 So the course had to be very generic and it had to 11 run exactly the same on every event and that is quite 12 a difficult ask when you've got so many events running 13 concurrently. 14 Q. Can we look at page 41, please, at the bottom of that 15 page. 16 This is under the heading "Horizon Field Support 17 and Migration Visit" and it says at the bottom: 18 "It is ICL Pathway's experience that users require 19 further support after training to help remember topics 20 covered by their training event and build confidence 21 [over the page] in daily use. Therefore the Horizon 22 Field Support visit is part of this document for 23 recommendation purposes only." 24 Can you tell us a little bit about the role of the 25 field support officers? 139 1 A. I can't actually. It's not something I remember at all. 2 I mean, my -- as it was at this time, when we were 3 delivering so many events, it was a case of -- we did 4 all those events and, to the best of my -- to the best 5 of my memory -- "recollection", that's word I was 6 looking for -- recollection, I don't think we missed one 7 event in all those events. So a big part of it for me 8 was making sure the trainers were up to speed and the 9 Horizon field support was it was really not something 10 I had a great deal to do with. 11 Q. If we scroll down on that page there's also reference to 12 additional training. I think this is what you were 13 mentioning earlier, that the additional training 14 function becomes operable when any member of staff fails 15 the competency test. So there was possibility of 16 additional training? 17 A. Well, I lived in a small village in the Fylde actually, 18 and it was a very small village and I knew our local 19 postmaster and postmistress and the postmistress 20 actually passed the course and her husband had to go 21 back to remedial, which she delighted in telling 22 everybody who went into the Post Office. But it just 23 went to show that, you know, there was that additional 24 training there. He was quite a bit older than she was 25 and he undertook the remedial training and, after that 140 1 -- I mean, as far as I can recall again, for a good time 2 afterwards, they had no problem at all with the system. 3 Q. Can we look at page 46, paragraph 11. There's reference 4 there to "New Product and Update Training". It says: 5 "ICL Pathway are not currently contracted to 6 provide this service however ICL Pathway will be pleased 7 to deliver this service subject to change control." 8 Do you recall was the training for new products? 9 We was that something that was ultimately agreed? 10 A. Not on the rollout, no. Not as far as I can remember. 11 I don't remember any new products coming online at all 12 during that time. We went with the same version all the 13 way through the training. 14 Q. So we're here, November 1999 is this document. Did you 15 carry out any analysis after the March 1999 report to 16 see if the two complaints that we spoke about earlier, 17 the issues with the length of the course, which remained 18 at one and a half days, and issues with balancing, did 19 you carry out any analysis as to whether the situation 20 had improved insofar as those were concerned? 21 A. I think -- you know, coming back to what I said before 22 and I think if you go right up to the end of it, 23 obviously the trainer has got more au fait with it and 24 they probably weren't as much there because the trainers 25 then would slow down or they'd see people who were 141 1 struggling with it, they were a lot easier to spot when 2 you are more au fait with the course and they would have 3 to then go up and, as I said to you before, I know 4 trainers that actually stayed behind in their own time 5 and helped a few people who had one particular bit -- 6 they would say "Stay behind at the end and I'll give you 7 a bit more on it". So probably it did improve. 8 But on any course you went on there, because of 9 the vast spread of knowledge and age to be -- without 10 being ageist -- and age, quite a number of them had had 11 no IT experience at all, some of them were quite au fait 12 with IT. So it was -- there was no -- how can I put it? 13 There was no level playing field between who actually 14 attended the course. So it could be a massive 15 difference. I think there was somebody who well into 16 their 80s was still running the Post Office and not been 17 out of the village for years and never had anything to 18 do at all with IT. 19 So somebody like that coming on the course, it was 20 a massive -- it was a massive culture shock to them. 21 Q. So the message to the trainers was "Spend some more time 22 with those who are having some difficulties", but there 23 was no actual analysis or further report into the 24 broader picture? 25 A. No, they knew that there were some people who were 142 1 really going to struggle. You know, you do when you're 2 training, you can see people there. As I say, the 3 trainers that we used, and I can speak for all of them 4 I think, had a great rapport with the postmasters and 5 they wanted to deliver a good session, and if they saw 6 anybody struggling, and I know many that did they would 7 actually, if they could, stay and help that person a bit 8 more if they could. 9 But they would also, again, go through the 10 supporting documentation where they could get further 11 help, just so that when they did leave they felt a bit 12 more confident. 13 Q. As things progressed towards national rollout in January 14 2000, do you think that those problems, in particular 15 those two -- length and issues with balancing -- do you 16 think that those had been resolved? 17 A. No, no. Not with everybody. I would say certainly on 18 the course, no they wouldn't have been resolved. 19 I think the training stayed as was, because it had to be 20 that generic training. I think the Helpdesk got better, 21 from what I remember, and I think the people who were 22 supporting in POCL got better. So I would say the issue 23 on the course was that it was probably felt it was too 24 short but the support with the handbook and the quick 25 reference guides and, as I said, the Helpdesk, they got 143 1 better. 2 The Helpdesk was an interesting one, purely 3 because, as I said to you, the culture -- and I've been 4 to several post offices -- anything that went wrong or 5 something they didn't understand, they immediately 6 phoned the Helpdesk. They had manuals there from Post 7 Office to actually go through procedures but they very 8 rarely used them. It was a case of pick the phone up 9 somebody on the Helpdesk can talk them through it and 10 that was it. 11 Of course, with Horizon because there was a lot of 12 new material, there were many times where they phoned 13 the Helpdesk, you know, continuously, rather than 14 looking up a simple process in either the quick 15 reference guides or in the handbook, because it was 16 their nature, that's what they did. 17 Q. You said the course had to stay at one and a half days. 18 Why did it have to stay at one and a half days? 19 A. I don't know why it had to stay at one and a half days; 20 that wasn't my decision. If they'd have upped it to two 21 days or three days then we would have adapted 22 accordingly. I think it was because of the amount of 23 courses that needed to be carried out. I think it was 24 deemed by both the hierarchy in POCL and 25 KnowledgePool/Peritas that that was enough time to give 144 1 an understanding of the actual hardware and the 2 processes, and should people not be quite as au fait 3 with it and wanted more time, there was either 4 additional training or there was actually other support 5 available to them. 6 Q. Whose call would it have been? You said at ICL and 7 POCL, whose call would it have been that one and a half 8 days was sufficient? 9 A. I think we would have looked that courseware and thought 10 "We could do it in that time". I think the call would 11 have been mainly POCL and even though -- even if 12 somebody like Stuart Kearns had raised it as an issue, 13 there obviously would have been other implications, 14 possibly, I don't know. I wasn't privy to those 15 conversations. We were told that was the time we had, 16 we had to cover that courseware in that time. Several 17 times it was expressed it was difficult with some 18 delegates to get them confident in that time but, again, 19 I keep coming back to it but there was other support 20 available to them. 21 So we did what we were told basically within that 22 timescale. I did not have anything to do with the 23 actual timescale itself. 24 Q. I'm going to take you to one more document before we 25 take a short break. That document is POL00028441. Can 145 1 we look at page 3, please. 2 Now, this is a Post Office document. Is it 3 a document that you are familiar with at all? 4 A. No. 5 Q. It's dated January 2000 and it's called the "Christmas 6 Horizon Research Report". If we turn over the page to 7 page 4 it says: 8 "This document accompanies the report entitled 9 Christmas Horizon Research, January 2000 by Lorna Green. 10 The report discusses the results of a telephone 11 questionnaire carried in December 1999 with a sample of 12 335 national rollout post offices and asks questions 13 about various aspects of the Horizon programme. This 14 document contains the actual comments made by each 15 respondent." 16 So we're now looking at December 1999. Can we 17 look please at page 4 -- sorry, the next page, page 5. 18 There's a table of contents and one of the areas that 19 respondents were asked about is training, that's 20 number 3. Can we look at page 14, which is where we 21 will see those comments. I'm not the going to go 22 through every comment but let's have a look at that 23 first section. 24 So there were complaints about not enough 25 training: 146 1 "There wasn't enough training. On the course we 2 were booked to go together and didn't get the 3 appointment. We needed much more training and more 4 time. Balancing needs looking at. It was completely 5 inadequate. Day and a half was not enough, especially 6 training for balancing was concerned. I am used to 7 computers but some of the training was horrendous. Good 8 but not long enough. I only got one and a half days' 9 training. We needed more training. It was too rushed. 10 There wasn't enough training. Not enough training. 11 There wasn't enough training. It was good but not 12 enough. We need a bit more training. There was not 13 enough. Not enough. We didn't cover enough. We needed 14 to be taught more on the Horizon System, maybe spread 15 over a week we really needed more training", et cetera, 16 et cetera. 17 That's the first entry, so that's not enough 18 training. Over the page there's another section on not 19 enough training on balancing. It says there: 20 "Training for accounting was very bad. Balancing 21 took hours to sort out, and was kept up until midnight 22 sometimes. Tried to call Helpdesk but it was almost 23 always engaged. But needed more time on balancing. The 24 first day was all right but the quality of the training 25 was not good on the second day because we concentrated 147 1 on serving customers which was very easy but needed 2 training on balancing in back office. I think it was 3 useless, inadequate, particularly for balancing. They 4 didn't inform us very much on cash accounts. But not 5 enough time, especially on the balancing side. The 6 training was very inadequate on the accounting side. 7 Did not allow enough time, especially on the balancing 8 side of it. Just inadequate -- we were trained to do 9 the counter procedures but not on the office 10 administration side. Balancing training was poor, 11 I taught myself", et cetera. 12 Over the page there's another section on "Not 13 enough time allowed", and it says there: 14 "It was trying to cram too much in, in not enough 15 time. Inadequate. Day and a half was not long enough. 16 No time to practise anything. It could ideally have 17 been longer training session. We ended up being left 18 totally confused. There was not enough time." 19 So looking at December 1999, just before the 20 national rollout in January 2000, you see those same 21 themes as you saw in the original report, the not enough 22 time theme and the not enough help with balancing theme. 23 Were those concerns raised with you at the time, or 24 anybody in your team, by the Post Office? 25 A. Not by the Post Office. I mean, obviously we knew from 148 1 delegates on the appraisal feedback form. I would say, 2 looking at those comments there, we never had that many 3 comments of that nature on the feedback forms that we 4 got, you know, from each course. Instead of -- it's how 5 you phrase the question as well. I mean, one of the 6 things I noticed sometimes with Post Office -- and I'm 7 not saying there was enough time, I agree that there's 8 a thread going through that -- but it's a case of if you 9 ask somebody what they didn't like about something, they 10 tend to actually come up with a particular answer. And 11 I've noticed on feedback myself where they actually put 12 up "What did you like about something", on the board, 13 and then say what didn't you like, and the people see 14 things they did like and think they have to counter 15 balance it with things they didn't like. 16 I agree about the no time, or not enough time, 17 I should say, but it's a difficult one, really. We did 18 what we could within the time that we had and none of 19 them there have said, "even after, you know, I sought 20 further assistance". None of them have actually said, 21 as far as I've seen so far, none of them sought any 22 further assistance, none of them have talked about the 23 Helpdesk, none of them have talked about supporting 24 documentation. You know, so it's all about the 25 training. 149 1 Yes, the training would have benefited from more 2 time but, actually, nobody's even mentioned the other 3 support elements that there were to the course, so -- 4 having seen the course in just isolation and having seen 5 the course with the other things that were available to 6 them. 7 Q. What was it just a coincidence that those same two 8 themes seemed to crop up again in December '99, as we 9 saw in March 1999? 10 A. No, I don't think -- I think is no coincidence at all. 11 I think it's very true, in the fact that some people 12 would see or think or believe, or were actually right, 13 that there probably wasn't enough time on the balancing 14 stood in isolation, or actually saw it in the system. 15 But what I would say is you have to look at that with 16 regards to the other help that was available and you 17 have to look at balancing that with some of the people 18 that thought it was fine. I mean, all we've seen so far 19 is documents mainly that said there wasn't enough time, 20 and I accept that. I'm not disputing that and I think 21 of any training you will get -- particularly when it's 22 a little bit complex, which it was on the balancing, 23 that it is difficult. 24 The other thing, as I said earlier, the fact that 25 we were -- the actual system took them away from what 150 1 they've been doing, some of them for years and taking 2 a great pride in, to actually doing something completely 3 different and they wanted more time. 4 MR BLAKE: Thank you, sir. That might be an appropriate 5 time to take a mid-afternoon break. 6 SIR WYN WILLIAMS: How are we doing generally with this 7 witness, Mr Blake? 8 MR BLAKE: I am aiming to finish for 4.30, so if we take 9 a ten-minute break now that should be possible. 10 SIR WYN WILLIAMS: Fine. 11 (3.30 pm) 12 (A short break) 13 (3.41 pm) 14 MR BLAKE: Mr Fletcher, can you hear and see me? 15 A. Yes, I can hear you. 16 Q. Thank you. Can we look at FUJ00119801, please. This is 17 the counter managers' training pack. Is this a document 18 that's familiar to you at all? 19 A. Yes, I believe -- yes, that one is familiar. 20 Q. It says at the bottom it's version 1. Do you remember 21 at all would this have been consistent in 1999/2000? 22 Were there significant changes to this at all? 23 A. I can't remember specific changes. What would have 24 happened was there may have been increments to it but 25 the version numbers would have changed. It might have 151 1 been that changes were made. It would have to go 2 backwards and forwards for approval with POCL and if 3 they did approve any changes that were made then it 4 would have been version 2 or 2.0. So it would be 5 a whole -- if it was a whole number at the front, it 6 meant that was the actual document we were using at the 7 time. 8 Q. Thank you. Can we look at page 5, please. 5 is the 9 agenda for the first day and then if we turn over the 10 page it's day 2. Is this agenda familiar to you? Is 11 that the kind of time periods that you dedicated to 12 certain events throughout the training? Let's look at 13 balancing, for example. We have there 10.00 am to 14 11.00 am, 11.15 to 12.30, and then there's "followed by 15 a role play and performance standard assessment", but it 16 looks as though there were 2 hours 15 minutes on 17 balancing in the second day; is that right? 18 A. I can't -- it must be if it's on there. That's what the 19 trainers would have done, yes. 20 Q. So the aim -- we've said a day and a half, so the aim is 21 to finish at 1.30 on day 2? 22 A. Yes. 23 Q. Can we look at page 63, please. Thank you. So this is 24 training insofar as balancing is concerned, and can we 25 just scroll on to the next page and over the page again. 152 1 These are the topics that were covered in that section 2 on balancing. Thank you. Perhaps we could scroll again 3 and again. Thank you. 4 It seems as though that's quite a lot of 5 information to fit into that 2 hours 15 minutes; would 6 you agree with that? Quite a lot of different topics to 7 be discussed there? 8 A. Yes, I agree. 9 Q. I mean, reflecting on this and reflecting on what we 10 discussed before the break, do you think that a day and 11 a half's training was adequate? 12 A. For some people, yes. For -- some people, obviously, 13 would have benefited from more time. All I can say to 14 you is that, you know, as far as the actual timings 15 went, then that wasn't an issue for me. I couldn't 16 affect that at all. Obviously, what it came down to, 17 I don't know, whether it was the amount of people to be 18 trained, whether it was the cost involved, et cetera, 19 et cetera. But, you know, we were given a day and 20 a half, that was approved by POCL, and we had to get in 21 those topics within that timescale. 22 Q. I think it was your evidence before the break that you 23 have to look at things in the round and it's not just 24 the training itself, it's also things like the 25 workbooks; is that right? 153 1 A. Yes. I mean, there were other support available to 2 postmasters and to counter assistants. What I would say 3 to you, from personal experience, I did go round 4 a number of post offices to watch the manual processes, 5 was that they actually very rarely used written 6 documentation when they had an issue. It was nearly 7 always the Helpdesk and this is one thing I did pass 8 back up to both my boss, Stuart Kearns, and to POCL, was 9 that I thought, because the time was reasonably short, 10 that they may get a lot more enquiries to the Helpdesk. 11 Q. You said you fed that back to the Post Office. Can you 12 remember a particular name of anybody? 13 A. Well, it would have been -- Sue Smith would certainly 14 have been part of it because she was my main contact, 15 really, within the Post Office and she tended to get 16 together any people that would be involved in what we 17 were discussing. So I knew for a fact that the Helpdesk 18 would be under some pressure because, as I say, it was 19 a short amount of time, it was given out to the post 20 offices -- sorry, to the postmasters and counter 21 assistants that the Helpdesk would have been trained and 22 quite a lot of them, from what I remember, were quite 23 pleased about that because, of course, we had issues 24 with other things within the Post Office and, of course, 25 that was their first port of call, was to Helpdesk. 154 1 Q. Can we look at POL00090452, please, because I want to 2 ask you about the training workbooks. What were 3 workbooks? 4 A. Training workbooks were something they could actually 5 use. Remember, I said that the actual system had 6 a training mode as part of the system and they could 7 have used the workbooks to explain certain functions to 8 other members of staff or to new members of staff and 9 this could also be used as a reference to an operation 10 on the system. 11 Q. Am I right in saying that there were ten separate 12 workbooks? 13 A. Yes, I believe it was 10. 14 Q. Would it surprise you to hear that they are, in total, 15 over 480 pages in length? 16 A. No. 17 Q. When were subpostmasters and their assistants and others 18 expected to have read this? Was this before the 19 training event, after the training event? 20 A. It would be after the training event but what I would 21 say to you there is that it wasn't a reading document, 22 it was a reference document for particular functions on 23 the system. So it wasn't something you sat down at 24 night and read, it was something that, if you needed to 25 train somebody else or you wanted to refresh a process 155 1 in your mind, you could pick up one of the workbooks or 2 the workbooks and refresh yourself on that process. 3 Q. So you had the day and a half's training, let's say, if 4 you're a manager and then you have this 480-page 5 workbook to go through if you had a problem. Were the 6 significant documents like this to read before the 7 training? 8 A. Not as I recall. The other thing, although there's 9 a lot of pages, as you say, quite a lot of them are 10 diagrammatical because, obviously, there were a lot of 11 screenshots included in the workbooks, as I recall, 12 because, obviously, a picture tells a thousand words, 13 and it was a case of it was a way of showing what would 14 appear on the screen to assist the Post Office staff to 15 actually complete the process. 16 Q. Can we look at page 7, please, and near the bottom of 17 page 7. Thank you. 18 It's the penultimate paragraph on page 7. It 19 says: 20 "The workbooks do not cover every possible 21 transaction which you can perform on the Horizon System. 22 If you need further help or if a specific example is not 23 covered, you should consult the Horizon System User 24 Guide." 25 Can you tell us briefly what the Horizon System 156 1 User Guide was? 2 A. They were short guides, as I recall, to actually cover 3 some of the processes and I think some of the processes 4 were fairly generic, as I've said before and, certainly, 5 the EPOSS -- quite a lot of the EPOSS ones, if you sold 6 one thing on the system, it was the same process for 7 selling something else. It wasn't a completely 8 different process for everything that you did on EPOSS. 9 But the workbook -- sorry, the Horizon System User 10 Guide, they were also a supplement to this where you 11 could actually -- they were more like quick reference 12 guides. 13 Q. We have the user guide. I'm not going to take you to it 14 but, for the purpose of the transcript, it's 15 POL00090227. Would it surprise you to hear that the 16 Horizon System User Guide was 819 pages in length? 17 A. Yes, it would, actually. Perhaps I've mixed up there 18 with the quick reference guides. I think maybe I have. 19 I'm not aware of the User Guide but the quick reference 20 guides were a one-page quick reference -- as the name 21 would suggest, a quick reference guide to a specific 22 process. I'm not quite sure about the User Guide. 23 I can't recall exactly what that contained and what it 24 was for. 25 SIR WYN WILLIAMS: I can't help it, Mr Blake. In the old 157 1 days you could have waved the 819 pages around! 2 MR BLAKE: I'm not sure the Inquiry can pay for that much 3 printing! 4 We have here a 480-page workbook -- ten workbooks 5 that comprised 480 pages. They themselves refer to 6 819-page Horizon System User Guide. Did the length of 7 all these documents -- I accept that there were these 8 quick reference guides -- but do the length of this 9 workbook and the document that's referred to there give 10 any indication as to the complexity of the overall 11 system? 12 A. To a point, yes, but I also think that they were there, 13 as the name would suggest, as a reference to 14 a particular action. If it had been you had to read 15 through it all and then actually do things then, fine, 16 I agree with you, it would be far too hefty to do. But 17 if you were looking to complete an individual process, 18 then I would say they were fit for purpose. The other 19 thing, of course, is that POCL would have gone through 20 these and they wouldn't have got anywhere near the 21 offices unless POCL agreed them and signed them off. 22 Q. You gave evidence earlier the a postmaster who may be in 23 their 80s, whose first experience with a computer is 24 having Horizon put into their post office. Do you think 25 that workbooks that are 480 pages in length and refer to 158 1 a document that's 819 pages -- do you think that that is 2 helpful to those kinds of postmasters? 3 A. That's a difficult one. I can't really comment on that. 4 I mean, they were done for a specific purpose and, in my 5 own view, they matched that purpose. I agree with you 6 if somebody had to sit down and read them all, then no 7 they're not -- they would too hefty to actually to do 8 that. What I would say to you is that, from the post 9 offices that I went to on the manual process, there were 10 several large user guides and other guides within the 11 Post Office for the manual system. 12 So whether you -- as I say, as a reference they 13 were fine but as a bedtime reading, no, they weren't. 14 Q. Can we look at page 367, please. This is Workbook 10, 15 which is entitled Balancing Using the Horizon System. 16 This is the section of the workbook that addresses 17 balancing. Could we scroll over the page onto page 369. 18 This Workbook 10 was 115 pages long. Does that sound 19 right to you? 20 A. If you say so. I mean, I can't recall exactly. 21 Q. If we look down, these are all the topics that are 22 covered in the balancing workbook. Can we scroll down 23 a little bit more? Over the page, over to the next 24 page. This is section 2 continued and it goes down 25 there to page 115. 159 1 Does number of topics that are covered in that 2 workbook indicate to you that cramming the issue of 3 balancing into that second day, the second half-day of 4 the training, was not sufficient? 5 A. What I would actually say back on that -- and I think 6 I've already conceded that we would have liked more 7 time -- is the fact that, although these may seem 8 foreign to somebody who isn't a post office person they 9 actually mean, you know, straight away they know what 10 shared stock unit declarations are, they know what 11 declared stock is. You know, so they are not all brand 12 new topics to them. It's just they are carrying out 13 what they normally did on the paper-based system onto 14 an electronic system. 15 So it may seem quite daunting if you just read 16 through it and said "Well, that's a lot to take in" but 17 actually it wasn't completely foreign to the POCL 18 workers, in my view. 19 Q. Can we turn back to page 287. This is training 20 Workbook 8. Training Workbook 8 dealt with Help and 21 Basic Maintenance of the Horizon System. Can we look at 22 page 296 which is within Workbook 8. It says at the top 23 there, section 1, "Horizon System Contingencies": 24 "If you have a failure of the complete system or 25 one of its components these are the procedures to 160 1 adopt." 2 Now, when it says "failure of the complete system 3 or one of its components", am I right in saying that's 4 something like a power failure or a screen failure; it's 5 not addressing errors in transactions, software errors 6 in transactions, for example? 7 A. Can you just repeat that. I didn't quite catch the -- 8 Q. Absolutely. So this section addresses what's called 9 "a failure of the complete system or one of its 10 components", and then it goes on to list nine topics: 11 (1) power failure; (2) monitor touch screen failure; (3) 12 magnetic swipe card reader -- these sound very much like 13 hardware issues and not software issues. 14 A. Yes. 15 Q. For each of those, apart from scales, the advice seems 16 to be to telephone the Helpdesk. So if we look at 17 "Power Failure": 18 "The most likely cause of a complete system 19 failure is a loss power for one reason or another. 20 Telephone the Horizon System Helpdesk as soon as 21 possible." 22 The next one "Monitor Touch Screen Failure", it 23 again says "Call the Horizon System Helpdesk". 24 Magnetic swipe card reader failure, again "Call 25 the system Helpdesk". Smartcard reader, "Call the 161 1 Horizon System Helpdesk". 2 If we scroll down keyboard failure, "Call the 3 Horizon System Helpdesk". 4 6, barcode reader failure, "Call the Horizon 5 System Helpdesk". 6 Scales failure isn't dealt with by the Helpdesk 7 but moving onto 8, counter, again "Call the Horizon 8 System Helpdesk"; and 9 multiple equipment failure, 9 "Call the Horizon System Helpdesk". 10 Am I right in saying that there isn't a section in 11 training Workbook 8 on software errors? 12 A. I honestly don't know. Looking at this now, I think 13 I can't recall any of this book, I really can't recall 14 it at all. I thought I did when you first put the thing 15 up. I don't remember ever seeing this failure part of 16 any book. I think this is a POCL document. 17 Q. So I thought you had said that the workbooks you had 18 contributed to. Had you not contributed to those? 19 A. I had contributed to a workbook but I certainly none of 20 these things here I wrote. I can't recall writing any 21 of those. I can't recall being involved in any of those 22 at all because surely there would have been an easier 23 way to write that than actually do every single one; do 24 you know what I mean? I certainly didn't -- I may have 25 known about the document. I don't think I did because 162 1 I've never -- I can't recall seeing this at all. 2 Q. It's called a training workbook. Is this not the 3 document that you recall being provided to those who 4 were trained by yourselves? 5 A. No, no, it isn't. 6 Q. Do you recall any document, in particular, being 7 provided to those who you trained? 8 A. Yes, there was a workbook. There was a system workbook 9 but, as far as I'm aware -- and, you know, some things 10 I just think can't remember but I'm pretty sure that 11 these elements were not in that book. 12 Q. I mean, this is -- if we look at the top right-hand 13 corner, it's dated July 1999 so that was a period that 14 you were involved in the training? 15 A. Absolutely. 16 Q. The reference is that a reference that you recognise at 17 all? 18 A. No, not at all. It's a Pathway reference and it's -- 19 I just honestly don't recall. I don't recall those 20 failures. If I'd have been involved in it, I certainly 21 wouldn't have put each one as separate. I would have 22 actually listed the potential failures and put "Call" -- 23 it's a bit monotonous to list every single one and put 24 "Ring the Helpdesk". It's just not something I feel 25 I would have done. I don't remember doing this in any 163 1 part at all. Whether I did or not, maybe I did I just 2 don't remember that and it doesn't sound like I would 3 have been involved in it, looking at it. 4 Q. In terms of the documentation that you were involved in 5 or you do recall from training, do you remember there 6 being any documents addressing software errors or what 7 to do in the case of a software error? 8 A. No. 9 Q. We've heard evidence of, for example, workarounds and 10 a Known Error Log that was held by ICL. Were those 11 things that you were aware of at all, that there were 12 certain procedures that you could use in order to get 13 around a problem, a work around? 14 A. No, not something I did. 15 Q. Do you recall things like workarounds being addressed in 16 any way in the training that was provided to 17 postmasters? 18 A. No, I don't recall at all. 19 Q. Can we stay on this document at page 297. You may -- in 20 light of the evidence you have given you may not be able 21 to assist with this at all but let's see where we get to 22 on this. Can we bring up on the same screen another 23 document, and it's FUJ00117722, page 15. These are two 24 different versions of training Workbook 8. The first 25 version is on the left-hand side and that's dated 164 1 24 July -- in fact, it says 24 July 2000 but it's called 2 Issue 1 and then, on the right-hand side you have 3 29 July 1999, which is referred to as Issue 2. It's not 4 clear which of those two is earlier. 5 But what I want to take you to is that note there, 6 the wording in bold. One of them says: 7 "Should Post Office counter staff have difficulty 8 in using the Horizon System or the training 9 documentation, they should contact the Horizon System 10 Helpdesk. For problems with the Horizon System User 11 Guide or the balancing with Horizon document, you should 12 contact the Network Business Support Centre." 13 A. That's just confirmed it for me. I had nothing to do 14 with that because I would have remembered that. This 15 document is not one that I was involved in. 16 Q. Thank you. We'll stay with the document because I do 17 want to ask you about the Helpdesk and the Network 18 Business Support Centre and your recollection of those. 19 The one on the right simply says: 20 "Should Post Office Counter staff have difficulty 21 in using the system or the documentation, they should 22 contact the Horizon System Helpdesk. The service hours 23 of the Horizon System Helpdesk are as follows ..." 24 What I wanted to ask you -- and you don't need to 25 refer to this document at all, just to your 165 1 recollection -- is: who were subpostmasters, assistants, 2 et cetera, told to contact if they were having 3 difficulty with the system in a way that affected 4 balancing but that wasn't, for example, caused by 5 hardware? So who would I call if I had a software issue 6 that was affecting balancing? 7 A. The Helpdesk. As I said to you before, the culture -- 8 forget the Horizon System. The culture in every post 9 office I visited is if there was an issue of any sort, 10 whether it be with a customer or whether it be with 11 benefits or anything else, was straight on to the 12 Helpdesk. They very -- in fact, I never saw one refer 13 to any of the current Post Office documentation that was 14 in the offices. They had a really good Helpdesk and 15 they were very reliant on it is my opinion and my view 16 of it when I actually went round the offices. 17 Q. What is your recollection of the Network Business 18 Support Centre? 19 A. I didn't know anything about that. I probably heard 20 about it but I didn't know -- I thought it was maybe 21 a subsidiary of the Helpdesk. I had nothing -- again, 22 nothing at all to do with the support centre. 23 Q. Do you recall postmasters ever being advised to contact 24 the Network Business Support Centre? Was the advice 25 that was given in training always contact the Horizon 166 1 System Helpdesk? 2 A. It would have been the Helpdesk. I honestly can't 3 recall, and I would be surprised because it would have 4 been something that would have stuck in my mind. 5 I can't recall them ever being told to contact the 6 Business Support Centre. 7 Q. Thank you very much. I will skip the next question 8 because it asks about the same document. 9 Do you recall discussing with those who you 10 trained what to do in the case of a software error and 11 a software error, in particular, that had affected 12 balancing? 13 A. The only thing I think that we actually mentioned was, 14 if there was an issue with balancing whether it was 15 something to do with the software, or they were just 16 having trouble with the actual process, was to first of 17 all look at the supporting materials and then actually, 18 if it couldn't be resolved that way, then obviously to 19 contact the Helpdesk. If they couldn't balance using 20 the system, they would normally balance manually and 21 that would have been, as far as I'm aware, acceptable to 22 the Post Office because of a system failure. 23 Q. Thank you very much. Those documents can be taken down. 24 I have a few further discrete topics to ask you about. 25 The first is field offices but I think you've said 167 1 that you don't really recall very much at all about 2 field offices -- 3 A. No. 4 Q. -- is that right? 5 I do want to show you FUJ00001520. This relates 6 to field offices but it's actually relevant also to 7 those who you trained in general. It's FUJ00001520. 8 This is a Horizon Field Support Officer Counter 9 Managers' Field Specification from the summer of 1999. 10 So July 1999 there seems to have been a proposal to 11 amend the course for counter manager, the support 12 officers. Can we look at page 4, please. Is this 13 a document you remember seeing or a topic that you 14 remember being discussed? 15 A. I would have seen it. Because of the author, I would 16 definitely have seen it. 17 Q. So this seems to be a request by the Post Office for an 18 amendment to the two-day counter managers' course but 19 I don't believe it's the counter managers' course 20 broadly. It seems to be for the Horizon Field Support 21 Officers. Do you remember this at all? 22 A. Not really but I can -- the general gist of it maybe, 23 but not in any detail. 24 Q. So some of the reasons given for amending that course 25 are given here: increased length of course; two days' 168 1 training not enough; no practice time; more training and 2 practice on balancing procedures. A little further 3 down: one-day balancing cash accounting. 4 And if we turn over the page for a proposed 5 timetable, it seems as though the proposal was to extend 6 the course that was given to the Horizon Field Support 7 Officers and we see there there's a day 3. So whereas 8 day 2 you have an overview of balancing at 2.15 -- can 9 we zoom out slightly. So you have the overview -- 10 perhaps zoom in a little bit more, if that's possible. 11 Thank you very much. 12 So day 2 you have overview of balancing, overview 13 of balancing processing reports, SU balance, but then 14 moving on to day 3, which is the next column, you have 15 quite a lot more: office balancing and cash account, 16 suspense account. 17 Is this something you remember at all, this 18 structure of training? 19 A. No, I don't remember this three-day proposal at all. 20 I probably would have seen it but I can't -- maybe I 21 didn't see it. It might be something that the author 22 was doing with Stuart or the Post Office. 23 I mean, I think I agree with what you've said 24 earlier on. Everybody would have liked more time. The 25 problem is that you have to work sometimes, even though 169 1 you raise it as an issue, and it was raised as issues, 2 that you have to work with what the client is proposing 3 and also your own company. 4 So it's very easy to say there should be more time 5 and et cetera, et cetera but there's a number of issues 6 about more time and it's certainly the time it would 7 take overall, the cost, there's a lot more than just, 8 "Oh, we'd like an extra day so we'll put an extra day 9 on." It wasn't at my level to make that decision. 10 Q. I mean, this particular proposal for the Field Support 11 Offices, it seems to address some of those concerns that 12 we saw earlier this afternoon and throughout this 13 afternoon about not enough time and more on balancing, 14 because it provides an extra day that addresses 15 balancing. Do you think that's the kind of thing that 16 should have been adopted for all of the managers? 17 A. To be honest with you, it would have -- yes, I mean 18 I can't say, you know, I wouldn't have liked that. It 19 would have made the course better. It wouldn't have 20 made it appear to be so rushed. But the problem with it 21 was, was that the fact that it wasn't our decision. We 22 could make all the suggestions and pass feedback back, 23 and feedback was regular available to both POCL and to 24 KnowledgePool at the time and ICL, and if the course had 25 to be extended they were the ones that would have to 170 1 decide for it to be extended. I had no sort of control 2 of that at all. They said this had to be covered in 3 a certain amount of time and, to the best of our 4 ability, that's what we did. 5 Q. If we look on the right-hand column, about half-way 6 down, it says "introduce dodgy balance comp". That 7 might be competition or composition? 8 A. I think what that would have been is that they would 9 have actually had a balance that was -- that had 10 mistakes in it and with common mistakes that we can 11 possibly make and the delegates then probably would have 12 had to look and say, "Well, that's a mistake, that's 13 a mistake" and look at it in that way. But, again, I'm 14 guessing that because I had no input into this document. 15 Q. Is that kind of thing, that kind of balancing common 16 mistakes training, is that the kind of thing that did or 17 didn't appear in the managers' training? 18 A. No, it didn't appear in the managers' training. It was 19 all the processes to complete balancing, you know, as 20 would normally be done in an actual office. The process 21 is to use on the system to balance the Post Office. The 22 problem with that is of course is that, you know, even 23 on the manual balancing there are discrepancies 24 sometimes or mistakes which doesn't produce a balance. 25 I mean, I talked to many postmasters that said they'd 171 1 spent hours and hours on balancing day trying to balance 2 the Post Office where a very simple mistake had been 3 made. 4 So problems occurred with manual balancing as well 5 as balancing on the system, it would appear, and were 6 there were quite regular issues with the daily 7 balance -- sorry, the Post Office balance and the manual 8 system. It wasn't all just on the automated system. 9 Not every Post Office balanced correctly, that I do know 10 for a fact, and quite a -- well, quite a number of them 11 didn't balance correctly or didn't balance correctly 12 until we'd done quite a number of hours after they 13 should have balanced trying to find the problem. 14 Q. I'm going to move on to training the trainers. I think 15 you've told us how many trainers you think there were. 16 Can you tell us their background at all. How were they 17 recruited -- 18 A. They came from a various background. There were a few 19 that were ex-military, there were some that were ex-Post 20 Office, there were some that had trained on other 21 systems like the National Lottery. And what we did, at 22 first there was an initial -- well, obviously a CV and 23 then an initial interview and, from that initial 24 interview, they were called forward. There was three 25 weeks of training for that particular trainer and it was 172 1 subsequent to that, if they passed those -- at the end 2 of each week, there would be an assessment and if they 3 passed the assessments after every week, so passed the 4 three assessments, then they would be employed as 5 a trainer on the system. 6 The actual first week was about general training, 7 use of training equipment such as overhead projectors 8 and other things that you would use as a trainer. The 9 second week was doing specific parts of training and 10 obviously dealing with sometimes problems, et cetera. 11 And the third week was all on the system. So they would 12 do elements on the system. 13 For obvious reasons they couldn't do every single 14 bit of the training as a test -- it would have taken too 15 long -- but by that stage you could tell who could 16 actually deliver it on the system and there was 17 assessment there. They had to pass all three 18 assessments before they were employed. 19 Q. Did they have any experience in working in a live post 20 office system? 21 A. Yes, quite a few did and I can't remember exactly but on 22 that many trainers, some of them were ex-POCL -- not 23 many. A lot of them had worked on IT systems before. 24 Quite a number were lottery. Like I said, there was 25 a few military. 173 1 It was a very arduous role as well. It sounds 2 easy to go to an hotel and set up and everything else 3 but, to be honest with you, they were travelling great 4 distances in between some of the events, and it was 5 quite a physical role as well because you were having to 6 break down the classroom quite often, you know, after 7 one evening -- sorry, one day and then travelling during 8 the evening, set up the next day for the next event. 9 Q. But in terms of their actual real-life experience in 10 using Horizon, being a new system, had any of them 11 actually used Horizon within a live post office? 12 A. No, no. 13 Q. Moving on, can we look at FUJ00078743, please. This is 14 a document from yourself. Is it a document that you 15 recall at all? 16 A. Not in detail again, but I'm sure ... 17 Q. It's 12 May 1999 and it relates to the live trial 18 operation plan. If we look over the page, it refers to 19 something called the Cash Account Expert Team. Do you 20 remember that? It seems as though there was an expert 21 team that was put in place on a Wednesday to assist with 22 issues relating to cash accounts. 23 A. No, I'm sorry, I don't recall that. 24 Q. If we look at the bottom of that page, it says: 25 "D Fletcher will attend the ICL Stevenage site to 174 1 oversee the activities on the ground and provide a focus 2 for management reporting and work with OSD to determine 3 staffing requirements for Thursday morning." 4 Is that anything you are able to assist us with at 5 all? 6 A. No, I'm sorry. The D Fletcher, I probably did meet him 7 but I don't know him. 8 Q. Can we look at FUJ00016958. Can I just say in relation 9 to that previous document, there's clearly a -- it's 10 been brought to our attention via a request from a Core 11 Participant, but it seems as though that document it's 12 "D Fletcher" rather than "Kevin Fletcher", so in fact 13 you may have had nothing to do with that topic 14 whatsoever. Is that right? It's a different Fletcher. 15 A. It is a different Fletcher but it actually says on the 16 comments, it gave the example of a simple report taking 17 three minutes to print: 18 "The performance is unacceptably slow and is 19 getting worse with successive" -- 20 Q. Sorry, sorry, I was talking about the previous document 21 that I just took you to? 22 A. Oh no, no. 23 Q. The Cash Account Expert Team. That document -- 24 A. It was a different Fletcher -- 25 Q. -- was written by a D Fletcher, so it must be a 175 1 different Fletcher. This particular document I've been 2 asked to ask you about, and it's an error log which we 3 know is a PinICL, and it has your name there having 4 discussed an issue. It relates, if we look on the top 5 right-hand corner, to a training counter and an error or 6 a difficulty -- I think it's a complaint that it's 7 unacceptably slow. Is this something you recall at all? 8 A. Yes, very well. It actually was switching over to the 9 training part of the system. It was -- I think that 10 contractually it was that there would be a training mode 11 on the system. What in reality at first there was an 12 issue with how long it took to change over from live 13 to -- or to change it from what would have been the live 14 system to the training system. So that was in live. It 15 wasn't on the actual stand-alone system. It was on the 16 actual system itself. 17 Q. Were there issues that you experienced with training 18 counters at all? 19 A. No, because of course all our systems were -- they were 20 training anyway. They were always in training. What 21 I'm saying to you is in the actual offices when the 22 system was installed, there was a training mode that 23 they could switch to. One of the issues that they had 24 was that to switch from live to training took too long 25 really. It was a long time and it became an issue. 176 1 Q. Was that issue resolved? 2 A. I believe so but I'm not sure. I think it's still 3 probably today takes a while to -- there's that much 4 information, particularly with benefits and that, that 5 the system is linked to that to actually run in a mode 6 that wouldn't affect any of that, it takes a long time 7 to change over. I know they improved it quite a lot but 8 how much in the end I couldn't honestly say. 9 It didn't really bother the training, apart from 10 the fact it was an assistance to the training that we 11 gave that we could operate in training mode in the live 12 environment, if that makes sense. But we had to come 13 out of the live system to go into the training system. 14 They do it on a lot of EPOSS systems as well where in 15 supermarkets they can actually quite often, or they can, 16 change over from a live till, if you like, to a training 17 till. This was very much the same which they could 18 change over from a live Horizon system to a training 19 Horizon System in the office. 20 MR BLAKE: Thank you very much, Mr Fletcher. Those are all 21 of my questions. 22 Mr Stein has identified another version of 23 a workbook. Unfortunately, we've implemented a new 24 process which means there's going to be a difficulty in 25 getting that document onto screen. So we can see where 177 1 we can get to. We can take a break. It depends on how 2 important that document is, Mr Stein. 3 MR STEIN: Well, sir, the position in relation to the 4 document I've identified is that the witness, 5 Mr Fletcher, referred to workbook 8 as being a possible 6 Post Office document. There is a version of it which 7 has an FUJ, so a Fujitsu reference, which appears to be 8 a Pathway version of workbook 8 and that would deal with 9 the point raised by Mr Fletcher. 10 Now, in a way, I have made the point by putting 11 forward the difference. I'm happy to leave it at that. 12 I would suggest, sir, that you and the panel peruse 13 workbook 8 in the version from Fujitsu which, for 14 completeness, is FUJ00117722 and it contains the same 15 points which relate to basically "go to the Helpdesk". 16 SIR WYN WILLIAMS: Is this ultimately the sort of factual 17 point that can be dealt with by a simple written request 18 to the representative of, say, POL and Fujitsu who would 19 provide the answer, or what do you think? 20 MR STEIN: Well, I think on the face of the document it 21 answers that particular question. 22 SIR WYN WILLIAMS: It actually answers it. 23 MR STEIN: Because it pretty clearly says at the very top of 24 the document where it's from: ICL Horizon. 25 MR BLAKE: We can in fact bring up precisely a document that 178 1 makes that point, sir. It's the second page of this 2 document. If we look over the page -- 3 SIR WYN WILLIAMS: So do you actually have a question for 4 the witness? 5 MR STEIN: With the explanation I provided, I don't think 6 so. 7 SIR WYN WILLIAMS: You've given the evidence. 8 MR STEIN: Exactly. 9 MR BLAKE: Perhaps I could ask Mr Fletcher: Mr Fletcher, if 10 you look on the document that is being brought onto 11 screen, this is training workbook 8 and it says there 12 "Copyright KnowledgePool Limited 1999/2000." Is this 13 really a document that you wouldn't have seen or don't 14 recall seeing? Perhaps we can look at the page before. 15 A. I'd have to look at the pages. It might be that it 16 wasn't written, you know, by me or I had input to. 17 I did a workbook but the workbook -- or my team did 18 a workbook that was the operation of the system. In 19 other words, it showed screenshots that were, you know, 20 if you press this, this came up. It was a very basic 21 one and I don't recognise it being training workbook 8 22 at all. 23 Q. Might it have been that you produced one of the ten or 24 one or more of the ten workbooks but not these 25 particular ones, Workbook 8 to Workbook 10? 179 1 A. I was never aware it was part of a series. The one 2 I did was really to support what was done in training. 3 In other words, it was a follow through book; in other 4 words, if you press this, this screen comes up, if you 5 want to do this, you press here, and it had all the 6 icons from the system which made for it easy to follow. 7 It was a real -- I don't know -- yes, simple book to 8 follow. It wasn't -- I don't remember it being part of 9 a set of any workbooks. 10 MR BLAKE: Thank you, Mr Fletcher. It's perhaps an issue 11 that we can explore with other witnesses in this phase. 12 I don't believe there are any other questions. 13 SIR WYN WILLIAMS: All right. Well, thank you very much, 14 Mr Fletcher, for giving your evidence to the Inquiry. 15 I'm very grateful to you. 16 A. Thank you. 17 SIR WYN WILLIAMS: It's just one witness tomorrow, is it, 18 Mr Blake, or have I got that wrong? 19 MR BLAKE: We have just one witness. 20 SIR WYN WILLIAMS: Yes, fine. 21 MR BLAKE: Mr Bansal. 22 SIR WYN WILLIAMS: That's it. I'm on track. Thank you very 23 much. So 10.00 tomorrow morning. 24 MR BLAKE: Thank you very much. 25 (4.24 pm) 180 1 (Adjourned until 10.00 am the following day) 2 I N D E X 3 JAMES BRUCE McNIVEN (sworn) ......................1 4 Questioned by MR BEER ............................1 5 Questioned by MR MOLONEY .......................78 6 KEVIN FLETCHER (sworn) ..........................86 7 Examined by MR BLAKE ............................86 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 181