1 Friday, 13 January 2023 2 (10.05 am) 3 MR BEER: Good morning, sir, can you see and hear me? 4 SIR WYN WILLIAMS: Yes, I can. 5 MR BEER: Thank you very much. Can I call Mr Gilding, 6 please. 7 CHRISTOPHER GILDING (affirmed) 8 Questioned by MR BEER 9 MR BEER: Thank you, Mr Gilding. As you know my name is 10 Jason Beer and I ask questions on behalf of the Inquiry. 11 Can you give us your full name, please? 12 A. Christopher James Gilding. 13 Q. Thank you very much for coming to give evidence to the 14 Inquiry today and for the witness statement that you 15 have previously provided we're very grateful. Can you 16 look at the witness statement, please. 17 A. Yes. 18 Q. It should be in the hard copy bundle in front of you? 19 A. Mm-hm. 20 Q. It should be 19 pages in length, excluding the exhibits 21 page and exhibits, and dated 7 September -- sorry, 22 7 December and on the last page there should be your 23 signature. Is that your signature? 24 A. It is, yes. 25 Q. Are the contents of that statement true to the best of 1 1 your knowledge and belief? 2 A. They are, yes. 3 Q. Thank you very much. A copy of that witness statement 4 will be uploaded to the Inquiry's website and therefore 5 I'm not going to ask you questions about every part of 6 it. Do you understand? 7 A. Okay. Thank you. 8 Q. Can we start, please, with your background and 9 experience. I think you joined the Post Office in 1977; 10 is that right? 11 A. Indeed, yes. 12 Q. And you left in 2016? 13 A. Yes, that's correct. 14 Q. Therefore, you were employed by the Post Office for, by 15 my calculation, 39 years; is that right? 16 A. 39, yes. 17 Q. Would you consider yourself to be a loyal company 18 employee in that time? 19 A. I was indeed, yes. I felt so. 20 Q. Between 1977 and the late 1980s, I think you describe it 21 as in your statement, you worked in Crown branches; is 22 that right? 23 A. That's correct, yes. 24 Q. First as a counter clerk and then as an assistant branch 25 manager? 2 1 A. That's right. 2 Q. So that's your first job, as it were? 3 A. Well, yes, yes, and progressed through the branch 4 management, so from assistant branch manager I became 5 a branch manager and I managed at pretty much every 6 branch office in Hampshire over the years. 7 Q. Then between the late 1980s and 1992 you were a regional 8 reserve trainer, it's described as. 9 A. Yes. So that was a role that was sort of an add-on to 10 myself being an assistant branch manager at the time. 11 So as a reserve instructor, if there were any courses 12 due to take place that they didn't have staff available 13 for, then I was asked to go and run those courses. 14 Q. Then I think in 1992 you became a Crown branch 15 manager -- 16 A. That's right, yes. 17 Q. -- and you stayed a Crown branch manager until 2009; is 18 that right? 19 A. That's right, yes. 20 Q. If you just look at paragraph 3 of your witness 21 statement, please, where you say that, 1992 to 2009, and 22 it says 27 years as a Crown branch manager. I think 23 that must mean 17 years? 24 A. 17 years, yes. 25 Q. In that time as a Crown branch manager, did you use 3 1 Horizon after it was introduced in about 2000? 2 A. Indeed, yes. 3 Q. Would you have used it on a daily basis? 4 A. Absolutely, yes, yes. 5 Q. So that's your sort of third role, if you like, after 6 being the regional reserve trainer. Then between 2009 7 and 2013 you were what's described as a field team 8 leader in network support and, is this right, that meant 9 that you managed a team of trainers and auditors? 10 A. That's correct, yes. 11 Q. Did you hold the title training and audit manager? 12 A. No. I was a field team leader. 13 Q. Just look at paragraph 9 of your witness statement on 14 the second page where it says under the heading "My 15 roles in relation to the Horizon IT System","Branch 16 manager", which we've dealt with and then "Training and 17 Audit Manager". 18 A. So the field team leader was the job title. Training 19 and audit manager was what the purpose of the role was. 20 Q. Understand. During that time, you would have used 21 Horizon in training events presumably -- 22 A. Yes, indeed. 23 Q. During branch audits? 24 A. Absolutely. 25 Q. And in visits to offices assisting postmasters to 4 1 investigate balance enquiries? 2 A. That's very true, yes. 3 Q. Then your next role between 2013 to 2015 you were 4 seconded for, I think, a two-year period within those 5 three years to the Horizon mediation investigation team. 6 A. That's correct, yes. 7 Q. I think also looking at paragraph 9 there you were 8 a team leader? 9 A. That's right, yes. So within that mediation team I was 10 line managing a team of -- I believe it was six people. 11 Q. Thank you. Then in 2015 you returned to the field team 12 leader role where you stayed for about a year or, and so 13 in 2016 you took voluntary redundancy? 14 A. That's correct, yes. 15 Q. I'm going to come back to some of those roles in 16 a moment but I just want to focus on something now that 17 we haven't heard much about so far. 18 A. Okay. 19 Q. It's your role in the Horizon mediation investigation 20 team? 21 A. Mm-hm. 22 Q. As we've said, that was for two years in 2013 to 2015. 23 By way of background, would this be right, that the Post 24 Office had established an investigation into some issues 25 about the operation of the Horizon scheme following 5 1 a campaign for the Justice for Subpostmasters Alliance, 2 the JFSA; do you remember that? 3 A. Yes, I do remember that and the mediation team that 4 I was asked to join was to look at the data for some of 5 the offices that were involved in the scheme. 6 Q. So do you remember, to put this in context, the setting 7 up of the scheme following some work done by, amongst 8 others, an MP called James Arbuthnot? 9 A. I remember the scheme being set up but I was not 10 involved in any part of that. 11 Q. Do you remember the involvement of Second Sight? 12 A. They were -- I'm trying to think what the title was -- 13 but yes, they were involved with the mediation 14 programme, yes. 15 Q. Can you remember what their -- we know an awful lot. 16 I want to ask you what you can remember from seven or 17 eight years ago. 18 A. Their role was to -- my understanding was their role was 19 to look at if there was any discrepancies within the 20 Horizon System from a software point of view and then to 21 make recommendations based on what they found. 22 Q. Looking at it generally, was this the position: the Post 23 Office had offered a scheme to subpostmasters so that 24 individual subpostmasters could have an opportunity to 25 raise their concerns about discrepancies or issues with 6 1 the Horizon scheme that Second Sight could investigate. 2 You were not seconded to Second Sight at all. You were 3 still working for the Post Office? 4 A. No, very much working for the Post Office. 5 Q. What did your work consist of when you were a team 6 leader on the mediation investigation team? 7 A. So we were allocated -- my team were allocated certain 8 cases, so -- I say cases/branches that had become part 9 of the mediation scheme. So they entered the mediation 10 scheme and then we were allocated individual cases and 11 we would work primarily as a pair and investigate the 12 Horizon data to try and ascertain how the losses had 13 occurred according to the data that was provided from 14 the Horizon System. 15 Q. I think you told me earlier how many people were in your 16 team. 17 A. I believe it was six. I'm trying to recall but I'm not 18 sure. But it was around six in my team. 19 Q. Was there more than one team? 20 A. Yes, there were two teams within -- from the line 21 manager that I worked for, there were two teams, yes. 22 Q. Who was the line manager that you worked for? 23 A. Kathryn Alexander. 24 Q. Were there any other teams other than those two 25 investigating Horizon Issues? 7 1 A. Yes, you are quite right. So we were the south team. 2 There was a north team as well, based in Scotland, and 3 I'm trying to -- I think it was Wendy Mahoney was the 4 team leader for the north. 5 Q. Thank you. I just want to look at the approach that you 6 took in the course of that two-year period investigating 7 discrepancies raised by subpostmasters and others. 8 A. Mm-hm. 9 Q. Can we look, please, at paragraph 106 and 107 of your 10 witness statement, please, which is on page 18. 11 A. Yes. 12 Q. In that paragraph, under the heading "Bugs, errors and 13 defects", you say: 14 "I always operated on the statement received from 15 Fujitsu that Horizon was 'the 2nd most secure system in 16 Europe'. I personally was never aware of any issue or 17 problems with Horizon. 18 "All of my dealings with Subpostmasters and staff 19 were based on Horizon being a robust accounting system." 20 When did you receive that statement from Fujitsu 21 that it was the second most secure system in Europe? 22 A. So that was a statement that was used when we had -- 23 when I was in the Crown network and we had our very 24 initial training into the introduction of Horizon. 25 I attended a two-day course that all branch managers 8 1 would have attended and that was a statement that was 2 used as part of the introduction to that program, that 3 the Horizon System was robust and -- yes, as I said, 4 they were very confident that this was a very secure 5 system. 6 Q. You used language there that you received the statement 7 from Fujitsu. 8 A. Sorry, the statement was as part of the training given 9 by whoever the trainers were at that time. So it would 10 have been a Post Office trainer not Fujitsu, but it was 11 a statement that they were obviously given to pass on as 12 part of the training to show how strong the system was. 13 Q. So the people that were training you said, "We have been 14 told by Fujitsu that the system is the second most 15 secure in Europe"? 16 A. Yes, yes. 17 Q. You have added that you were personally never aware of 18 any issue or problems with Horizon and it was, to your 19 knowledge, a robust accounting system. 20 A. Absolutely, yes. 21 Q. When you say that you operated on the basis of that 22 statement, do you mean that you believed what Fujitsu 23 said in that statement without investigating the merits 24 of it? 25 A. Yes, that's true, yes. 9 1 Q. So you mean by that statement you operated on the basis 2 that the statement must be true? 3 A. Yes. 4 Q. Does that mean that, because you operated on the basis 5 that the statement must be true, you were therefore 6 sceptical or disbelieving of any suggestion that there 7 may be errors, bugs or defects in Horizon? 8 A. I'm not sure "sceptical" is the right word but 9 I never -- I didn't see any evidence to say that there 10 had been any problems. 11 Q. If you were operating on the basis that the statement 12 must be true, why would look for any evidence that there 13 might be errors, bugs or defects? 14 A. Because that was the role I was asked to do and I was 15 looking at the data that was provided to try and 16 identify how the losses had occurred in the branch. But 17 all of that was under the assumption that the Horizon 18 data was solid and true. 19 Q. And that assumption was based on something that you had 20 been told in a training exercise, what, a decade 21 earlier? 22 A. Yes, yes. And also when we were part of the mediation 23 team, I personally, and other members of the team, did 24 enquire with our team leader as to whether we were 25 100 per cent confident with the data that we were 10 1 working on because there would have been no point in 2 interrogating the data if it was known to be false and 3 we were assured that the data was solid. 4 Q. Who gave you that assurance? 5 A. That was my team leader who was Kathryn Alexander. 6 Q. When you say we asked, do you mean -- 7 A. Myself and my team, when we were seconded onto the 8 mediation team. Obviously, we wanted to make sure that 9 we were working with good evidence and not information 10 that was going to be corrupted in any way because there 11 was no point in investigating data if it wasn't true -- 12 Q. Obviously not. 13 A. -- to the best of our knowledge. 14 Q. And you got, what, a verbal assurance, "No this data is 15 solid, robust and reliable"? 16 A. Yes, nothing written, just verbal. 17 Q. And, "There are no problems, no errors, bugs or defects 18 in Horizon that could be causing these discrepancies"? 19 A. That's correct, yes. 20 Q. Can we look, please, at POL00006581. 21 A. Sorry, which page are we on? 22 Q. It's going to come up on the screen for you. 23 A. All right, thank you. 24 Q. This is a document that you wouldn't, I think, have seen 25 at the time but it's been shown to you in preparation 11 1 for these hearings. 2 A. Yes. 3 Q. It's an advice of Brian Altman, King's Counsel. It's 4 dated 15 October 2013. I'm not going to go to the back 5 end of the document to establish it's date. Just take 6 that from me. 7 The document concerns a review by him of past 8 prosecutions undertaken by a firm of solicitors called 9 Cartwright King on behalf of the Post Office. 10 A. Mm-hm. 11 Q. Do you remember Mr Altman? 12 A. I met him briefly once. 13 Q. Can we look, please, at the third page of the advice. 14 Then at paragraph 4, Mr Altman says: 15 "Regarding the process by which I have been asked 16 to conduct my review and by reference to each in the 17 above process list in chronological order ..." 18 He sets out how he went about the process of 19 fulfilling his instructions. 20 Then if we go over the page, please, and look at 21 the top of the page, point 3 of his instructions, he 22 says: 23 "... on 19 September 2013, I attended Guildford 24 Classroom Training Office ... where I received a day's 25 training on the Horizon system. Chris Gilding (Network 12 1 Support Team Leader) trained me. Andy Holt (Business 2 Relationship Manager) was on hand to assist and answer 3 questions." 4 Is that the occasion that you're referring to when 5 you said you briefly met him? 6 A. Yes. 7 Q. Did you give him a day's training? 8 A. I did, yes. 9 Q. Do you remember that in the Guildford classroom training 10 office? 11 A. Yes, I remember being in the Guildford training office 12 and over -- with training for legal teams, over a period 13 of a few months, I was asked to do three different 14 training sessions. This was one of the ones that 15 I undertook and there were other sessions where I had 16 six representatives from the legal team. The point of 17 the one-day training was just to give them an oversight 18 of what the equipment looked like and how it was used 19 from a user interface point of view. 20 We also looked at the reports that could be drawn 21 from the system and how they were interpreted. 22 Q. Did you undertake balancing training? 23 A. We did a balancing exercise. So they were given 24 a handout with some transactions to put through, as you 25 would do in a live situation, and then they were shown 13 1 the balance procedure and talked through the balance 2 procedure and, at the end of the balance procedure, we 3 looked at how many discrepancies or any discrepancies 4 that they managed to identify as part of the exercise 5 that we'd done. 6 Q. Ie the person you were training, their own user error? 7 A. Yes. 8 Q. In the course of this training, you were presumably 9 still working on the basis that the statement you'd 10 received indirectly from Fujitsu, namely that there were 11 no problems whatsoever with Horizon, that it was 12 reliable and robust? 13 A. Indeed, yes. 14 Q. Do you remember was there any conversation about that in 15 the course of this training? 16 A. No, I don't remember any conversation on that subject. 17 Q. What did you understand the purpose of the training to 18 be? 19 A. The purpose of the training was, as I mentioned, was 20 just to give the legal team an oversight of -- 21 Q. Do you mean an overview? 22 A. Overview, sorry -- an overview of the equipment and how 23 it was used and how the staff using the equipment would 24 interact with the user interface. 25 Q. There was no discussion about bugs, errors and defects? 14 1 A. No. 2 Q. Thank you. That can come down. 3 Can we look back at your witness statement, 4 please, at paragraph 25, which is WITN05380100 at 5 page 4. Just wait for it to come up on the screen. 6 Can we see at paragraph 25, you say: 7 "I was never made aware of any bugs or defects 8 with Horizon and my view was that it was a robust system 9 as all of the accounting errors I came across as a Crown 10 manager were due to inputting errors by staff members." 11 Presumably now, in the light of what you know, you 12 accept that, with the benefit of hindsight, you were 13 proceeding on an erroneous assumption? 14 A. Yes, from what I now know but that was not my belief at 15 the time. 16 Q. You now know -- is this right -- that because of 17 litigation and the findings in the civil courts and in 18 the criminal courts, and indeed from some of the 19 evidence that the Inquiry has heard, that there were 20 a series of bugs, errors and defects within the Horizon 21 System from when it was rolled out until perhaps 2016? 22 A. I personally have not seen anything about what those 23 defects were. So, to this day, I'm still unaware of 24 what the bugs or defects were. 25 Q. You say in this paragraph that every error you came 15 1 across was down to the member of staff; it was always 2 their fault, never the system? 3 A. Yes. Any errors that I identified were to -- either 4 from staff inputting incorrectly onto the Horizon System 5 or, more often, it would be not actually the inputting 6 into the Horizon that was the issue, it was what they 7 physically did with the cash and stock. But obviously 8 what they recorded on Horizon was not necessarily the 9 same as what they were doing with the cash and stock, so 10 hence a discrepancy would appear. 11 Q. Did no-one in the 16 years or so that you were a Post 12 Office employee whilst Horizon was in operation ever say 13 to you "I think the computer's the problem, not me"? 14 A. Yes, I would have heard that statement. 15 Q. But it was always untrue? 16 A. I had no evidence to suggest otherwise. 17 Q. What enquiries did you make as to the reliability of the 18 data that the system was producing? 19 A. None, really. No, I was just -- 20 Q. So how can you say that, "I had no evidence that it 21 wasn't the computer, it was always the member of staff", 22 if you never made any enquiry? 23 A. I suppose what I'm saying is that data I would look at 24 from the Horizon System always seemed to be robust. 25 Q. How could you tell? 16 1 A. Just from experience of looking at that information. 2 Q. Experience at looking at a screen? 3 A. No, at reading the transaction and event logs that the 4 system produced. 5 Q. Now, you performed a variety of roles as we've seen, 6 training people, being a supervisor for training 7 people -- 8 A. Mm-hm. 9 Q. -- auditing branches, being a supervisor for those 10 auditing branches and then investigating alleged 11 discrepancies in the course of the mediation scheme, and 12 the only thing in all of that time you ever found was 13 that it was always the subpostmaster's fault or the 14 counter staff's fault; is that right? 15 A. I had -- didn't come across evidence to suggest anything 16 else other than that. 17 Q. You say in paragraph 26 of your witness statement: 18 "My view of the robustness of the system didn't 19 change over time as the losses attributed to Horizon 20 only appeared to occur in sub post offices, I am not 21 aware of any major losses in Crown offices, the Horizon 22 [system] installed in all branch types across the 23 network was identical." 24 What are you trying to say by that paragraph, 25 please? 17 1 A. I'm just saying that any losses that I was asked to look 2 at regarding Horizon errors, Horizon data, was always 3 with sub offices. I was never asked to investigate any 4 losses within Crown branches. 5 Q. I see. This attitude of mind that you had, that the 6 system was the second most secure in Europe, that it was 7 robust, that there were never any errors, bugs or 8 defects in it and that all and any issues were the fault 9 of subpostmasters or counter staff, did that remain for 10 the entirety of the 16 years that you worked whilst 11 Horizon was in operation? 12 A. Yes, it was, yes. 13 Q. So you carried that attitude of mind into your work as 14 a trainer and as a manager of trainers, as an auditor -- 15 A. Yes. 16 Q. -- and a manager of auditors and when investigating 17 allegations of Horizon-caused shortfalls? 18 A. Yes, indeed. 19 Q. I'm just going to address very briefly your work as 20 an auditor and a team leader of auditors. That 21 statement can come down now, thank you. 22 I'm going to address this briefly, as it may be 23 that you will be returning to the Inquiry in one of its 24 later phases when we look at individual cases. 25 A. Okay. 18 1 Q. As an auditor, I think it's essentially for four 2 years -- is that right -- between 2009, when you stopped 3 being a Crown branch manager, and 2013, when you took up 4 the role of team leader in the mediation investigation 5 team that -- 6 A. It may have been a shorter period than that. When 7 I joined the training team in 2009, we were just 8 a training team and I believe it was about 2011, but I'm 9 not sure of the exact date, there was a restructuring of 10 the field support team and the training and audit teams 11 were amalgamated into a field support team -- 12 Q. Thank you -- 13 A. -- so before then they were two separate ... 14 Q. Okay, so it might be for the first two of the four years 15 you were just training -- 16 A. That's correct. 17 Q. -- and it was only for the second half that you were 18 training and auditing? 19 A. Yes. 20 Q. I understand. I was going to ask you about that later. 21 The merger of the audit and training functions, why was 22 that undertaken? On the face of it, they are not 23 natural bed fellows. 24 A. My understanding, it was to try and make a better use of 25 the resource as in people that we had available within 19 1 the field support team, so that because it was 2 a national team, by having multiskilled trainers and 3 auditors, it would reduce the amount of travel that the 4 audit team were having to make because we would have 5 more people across a wider geographical spread. 6 Q. I see. So your understanding was that it was for sort 7 of business pragmatic reasons, rather than because of 8 a natural affinity or similarity between the skillset 9 needed for both? 10 A. No, it was a restructure of the field support function 11 and it was, as I say, to improve the coverage over 12 geographical spread. But -- 13 Q. So -- sorry. 14 A. But what I will say is that, coming from the training 15 background, going into audits, we were very much 16 treating the audits as a support function rather than 17 a punitive visit. It was always there to support the 18 subpostmasters with any issues or questions that they 19 may have had. 20 Q. Okay. So "audit" is the wrong word to describe you 21 there? 22 A. So an audit -- 23 Q. You are supporters and helpers? 24 A. Yes. So, basically, we were asked -- we would be asked 25 to attend an office and -- 20 1 Q. Who would be asked by? 2 A. So there was a scheduling team based in Salford who 3 would allocate. The selection criteria for which 4 offices to visit, there was a team in our financial 5 department in Chesterfield who would identify from the 6 data that they were looking at from the offices if there 7 was an office where they thought maybe there would be 8 a reason for a visit to take place. 9 Q. What would be a reason for a visit to take place? 10 A. It might well be that there was a high volume of cash 11 declared as being in the office but when that office was 12 asked to return some of the cash to the cash centre that 13 they were not returning it. 14 Q. So something suspicious? 15 A. Yes, yes. But there was also a programme of random 16 audits that would just be -- so every office was due to 17 have a visit once every five years on a random basis. 18 Q. So the request didn't come from the subpostmaster? 19 A. No. 20 Q. So it wasn't "I need some help and assistance"? 21 A. Not from that audit point of view, no. 22 Q. So you were a team leader of the auditors? 23 A. Yes. 24 Q. How many people in the team did you lead? 25 A. It varied. At one stage, I believe I had 15 and then it 21 1 varied between nine and 15, depending on which area 2 I had responsibility for. 3 Q. Where were you based? 4 A. I was based in Southampton and -- 5 Q. What was your geographical area? 6 A. So my first geographical -- are we talking just the 7 audit function or the training function? 8 Q. Just the audit, please. 9 A. So just the audit function would have been Hampshire, 10 Berkshire, Dorset, Devon and Cornwall. 11 Q. Where were the staff that you led based? 12 A. Geographically spread over that area. 13 Q. Was there a central office to which they would come? 14 A. No. No, they were all field based. 15 Q. Who was your line manager? 16 A. At that time, I can't remember. 17 Q. Were they based in the Southampton office? 18 A. No. 19 Q. Did you -- 20 A. Again, it wasn't the Southampton office. It was my home 21 address. I was based at home, sorry, yes. 22 Q. The others out in the field, they were based at their 23 homes rather than Post Office offices? 24 A. Yes, that's correct. 25 Q. Did you carry out audits yourself? 22 1 A. I was part of the audit team, yes, and so I attended 2 some audits and, if it was an audit of a Crown Office 3 I would lead the audit and that was felt necessary 4 because you were dealing with managers of a certain Post 5 Office grade and so the Crown Offices audits were always 6 led by a field team leader, to make sure that there was 7 somebody of the same grade, because that had caused 8 issues in the past where a field adviser had led a Crown 9 audit, challenged a Crown manager about something and 10 because there was some -- 11 Q. They tried to pull rank? 12 A. Yes. 13 Q. So when you were carrying out these audits, you were 14 investigating discrepancies, shortfalls, imbalances and 15 sometimes suspending subpostmasters? 16 A. No, I never suspended a subpostmaster. That was not my 17 remit. Our job as auditors were to attend the office to 18 look at -- to get a report from the Horizon System of 19 the cash and stock that should have been on hand, to do 20 a physical check of the cash and stock that was there, 21 make a comparison of the two and, if there was any 22 discrepancies, we would then report that to a contracts 23 adviser. 24 So each of the sub post offices had a contracts 25 adviser. So our role was purely to identify what was 23 1 there in the branch and report to the contracts adviser 2 and they would then make a decision on how to proceed. 3 That could be either that the office was reopened and 4 the contracts adviser would speak direct to the 5 subpostmaster about how any shortfalls would be repaid 6 or it might be that they advised us to close the branch 7 whilst investigations were undertaken by the contracts 8 adviser. 9 Q. Would that happen on the occasion of your first 10 attendance? 11 A. Yes. 12 Q. So this would be done on the phone, would it? 13 A. Yes, absolutely, yes. 14 Q. Sometimes you would close the branch there and then? 15 A. We would -- yes. If the contracts adviser wanted the 16 branch closed, and it was always their decision, then we 17 would advise the postmaster what the decision was and we 18 would close the branch, secure the stock and cash, take 19 those keys away from the branch and make sure that they 20 were passed to the contracts adviser. 21 Q. So you wouldn't decide whether to suspend somebody? 22 A. No, that was not my role. 23 Q. Did you carry out the suspension, ie tell somebody whose 24 branch was closed and their keys taken away from them 25 that they were suspended or was that done by somebody 24 1 else? 2 A. No, that was done over the phone by the contracts 3 adviser. 4 Q. So you would hand a mobile to the subpostmaster and 5 somebody at the other end of the phone would say "You're 6 suspended"? 7 A. Would talk them through what their decision was and what 8 the process was, yes. 9 Q. And then you'd take the keys away and lock up? 10 A. That's correct. 11 Q. I just want to look, please, at a document just to work 12 out whether this is you or not -- 13 A. Okay. 14 Q. -- that's referred to. It's POL00029492. We should 15 have here a briefing pack prepared by the Post Office 16 for the Post Office for a meeting with James Arbuthnot 17 MP and Oliver Letwin on 17 May 2010. Can you see that 18 at the top? 19 A. Yes. 20 Q. Now, this is a document that I think you wouldn't have 21 seen at the time but, again, you have seen more recently 22 because we've shown it to you? 23 A. Indeed, yes. 24 Q. The index to the contents notes what the pack contains 25 and, at the bottom, there's a reference at point 8 to 25 1 the Yetminster case? 2 A. Mm-hm. 3 Q. Can you see that? Yetminster, I think, being a village 4 in Dorset. 5 A. That's correct. 6 Q. You told us already that your reach extended to Dorset; 7 is that right? 8 A. That's right. Is it Dorset or Somerset, I'm not quite 9 sure? 10 Q. The internet suggests Yetminster is in Dorset. 11 A. Okay. 12 Q. If we go over the page, please, and look at the agenda 13 for this meeting with the two MPs, we can see who was 14 going to be present: Messrs Arbuthnot and Letwin, and 15 then Alice Perkins, the then Chairman of the Post 16 Office; Paula Vennells, the then chief executive of the 17 Post Office; Susan Crichton, the legal and compliance 18 director of Post Office; and Lesley Sewell, chief 19 information officer of the Post Office; and then 20 Mr Ismay and Ms van den Bogerd, and you will see their 21 job titles there. 22 If we just expand out a little bit, please, thank 23 you, we will see the agenda and, again, under item 6b 24 we'll see the review of what's described as the "Tracey 25 Merrick Case". We'll see in due course that that's 26 1 a reference to Tracey Ann Merritt and that Susan was 2 going to lead on that; that's Susan Crichton the legal, 3 and compliance director at the Post Office. 4 So if you just -- to give you some context for 5 this document, if we go over the next page, please, you 6 can see that this is a list of key messages for the 7 people that are going to lead Alice, to start with, and 8 then Paula Vennells next. If you just scan. 9 A. Can I just say, Jason, at this stage, I was aware 10 that -- although I'm not listed on the attendees because 11 I didn't attend the actual meeting, I was aware that 12 this meeting took place because, as we discussed 13 earlier, where I was asked to show the workings of 14 Horizon System to the legal team, when this meeting was 15 called, I was asked to attend the Post Office 16 headquarters. They had what they called a model office 17 which was a dummy office set up there and I was asked to 18 be there and available in case the Members of Parliament 19 wanted to have a hands-on demonstration. 20 As it was, when the meeting was finished I wasn't 21 called, so I didn't participate in any way but I was 22 aware this meeting was taking place because I was there 23 on stand-by in case. 24 Q. Thank you. You weren't in the room? 25 A. Not at all, no. 27 1 Q. Then if we go over the page again, please, to page 4 on 2 the briefing note of what was going to be said, if you 3 just scan that. If you look that second bullet point in 4 the first box: 5 "Although we recognise that Horizon is not 6 perfect, no computer system is, it has been audited by 7 internal and external teams, it has also been tested in 8 the courts and no evidence of problems found ..." 9 Would that accord with your view at this time? 10 A. Indeed it would, yes. 11 Q. Did you contribute to this? 12 A. No. 13 Q. Did you brief up the people that wrote this document? 14 A. No. 15 Q. Then the next bullet point: 16 "An upgraded version of Horizon was deployed 17 2 years ago. Both versions of Horizon were built on the 18 same principles of reliability and integrity." 19 Would that match your own view? 20 A. Yes, it would, yes. 21 Q. "Although we recognise that Horizon is not perfect, no 22 computer system is, it has been audited by internal and 23 external teams, it has also been tested in the 24 courts ..." 25 That seems to be a repetition of the earlier -- 28 1 maybe it's to emphasise the point. 2 Then training is dealt with in the next paragraph 3 or the next bullet point. If you just scan that as to 4 what it is said that Ms Vennells, I think, was going to 5 lead on. Then if we go over the page, please. Under 6 topic 5 "Introduction to case review", the messages were 7 going to be: 8 "Occasionally we do get incidents of fraud. 9 "Process ... audit, internal review, interview, if 10 can't be resolved then dismissal for Crown staff, court 11 for subpostmasters (need to explain why)." 12 There seems to be a record there of a distinction 13 between treatment of Crown staff and subpostmasters. 14 Was that something that you had experience of? 15 A. Yes. Only in the fact that the Crown staff were 16 employed by Post Office Limited and -- 17 Q. SPMs were not? 18 A. No, indeed. 19 Q. But the difference in treatment. If the incident could 20 not be resolved then "dismissal for Crown staff, court 21 for subpostmasters"; do you know what that's a reference 22 to? 23 A. No, I don't, no. 24 Q. Then there was going to be a review of the Jo Hamilton 25 case. The Inquiry is very familiar with Josephine 29 1 Hamilton's case and it seems like the key facts or the 2 pitch was going to be that there were cash holdings; the 3 training was received; there was some audit findings; 4 Ms Hamilton was in personal financial difficulties; 5 she's provided an opportunity for an explanation; and 6 she did plead guilty to fraud. 7 Then the again misdescribed as Tracey Merrick case 8 at 6b. There's an outline of the timeline of events. 9 Then if we go forwards, please, to page 19 of this 10 document, there is on this and over the following pages 11 a detailed explanation of the Yetminster case, correctly 12 describing the person involved as Tracey Ann Merritt 13 and, again, the Inquiry is very familiar with Tracey Ann 14 Merritt. She was a witness in Phase 1 of our Inquiry 15 and gave evidence to us about what happened to her, 16 including how the prosecution of her left her suicidal. 17 Can we move through this, please. It says that: 18 "The defendant [as she's described] had been 19 employed as a postmistress for over four years. 20 Ms Merritt worked the Yetminster Post Office, but also 21 operated an outreach Post Office at Chetnole. 22 "An audit was conducted that Yetminster Post 23 Office on 29 September 2011 following concerns raised by 24 a former holiday relief worker at the Yetminster branch 25 in August 2011 over alleged cash shortages." 30 1 Then: 2 "Mr Constant and Mr Gilding arrived at the 3 Yetminster Post Office at 8.30 am ..." 4 That is, am I right, a reference to you? 5 A. It is, yes. 6 Q. You remember auditing the branch? 7 A. I do, yes. 8 Q. In this two-year period, I think it would be, as you now 9 described it, how many audits did you conduct? 10 A. I honestly can't remember. It would have been in the 11 high -- I would say around about 100 but it may have 12 been less, it may have been more. 13 Q. So one a week then? 14 A. Yes, sometimes there could be two or three in a week 15 but, yes, I would say 50 to 100, but I don't know the 16 exact number. 17 Q. Can you recall anything of the detail of this? As 18 I say, we may be coming back to you later but for now -- 19 A. Yes. I've read this document and, yes, I recollect what 20 was stated here was what happened on the day. 21 Q. If we go forwards to page 22 of the document, please, 22 under interview the caution was explained to Ms Merritt. 23 She was interviewed, it's said, in accordance with PACE 24 and she said the following: 25 "She denied having taken the money the night 31 1 before the audit as she had previously advised auditors, 2 and now produced a large document regarding ongoing 3 litigation by Shoosmiths Solicitors over the reliability 4 of the Horizon System." 5 Did you conduct the interview? 6 A. No. 7 Q. Until you read this document, did you know that, in her 8 interview under caution, Ms Merritt said that what she 9 had told you and your colleague was incorrect and was, 10 in fact, blaming the Horizon System? 11 A. No, I didn't know that. 12 Q. What involvement did the auditors have in the subsequent 13 investigation of a subpostmaster for the purposes of 14 prosecution? 15 A. After we'd attended and produced the audit report, we 16 had no further involvement. That was handled by the 17 contracts adviser and the security team. 18 Q. In the course of this audit, you would have been 19 applying the attitude of mind that you described 20 earlier; namely, the system's robust, nothing's wrong 21 with the data, it's down to the subpostmaster? 22 A. Yes, and as this audit report states, there was 23 a shortfall in the cash and there was a personal cheque 24 from the postmaster that was in the till and when 25 questioned as to why there was a personal cheque in, as 32 1 it says there, she gave us a statement that she'd taken 2 the cash for personal reasons. 3 Q. You now know that she says that's incorrect and that it 4 was the Horizon System and, in fact, I think you now 5 know that the prosecution against her was discontinued, 6 don't you? 7 A. I have heard that since but that was not what we were 8 told at the time. 9 Q. No. Did you ever think when conducting audits that 10 "What we might be" -- "What might be being said to us 11 was inaccurate and caused by upset and panic"? 12 A. So part of our remit was, once we conducted an audit, if 13 we were to find a discrepancy, like in this case, we 14 were to ask the postmaster for an explanation and that 15 would just be noted and a signature gained from the 16 postmaster to confirm that that was what was discussed. 17 We would not engage in any kind of investigation or 18 questioning because that would -- could possibly have 19 endangered any future questioning carried out by the 20 security team. So our role was purely to record what 21 was said at the time and record that and pass that on. 22 Q. Thank you. That document can come down now. 23 Can we go back to your witness statement, please, 24 and paragraph 25 which is on page 4 of the witness 25 statement. WITN05380100 at page 4, please. 33 1 You tell us in the witness statement at 2 paragraph 25 that you were never made aware of any bugs 3 or defects with Horizon, correct? 4 A. Correct, yes. 5 Q. Can we therefore look at a small number of documents, 6 please. Firstly, FUJ00052407. This is a PinICL 54313. 7 You're aware of what PinICLs are, aren't you? 8 A. Can you remind me? 9 Q. Well, I'm not going to give evidence but can you recall 10 what a PinICL was? 11 A. No. 12 Q. Do you remember a system where you could call in to 13 a centralised facility issues or problems with the 14 operation of the Horizon System? 15 A. Yes. So there was -- we had a Network Business Support 16 Centre which was a telephone helpline and one of the 17 options was if you had issues with Horizon you could 18 call them. 19 Q. This is a record at their end -- 20 A. Right, okay, thank you. 21 Q. -- of such a call. Can you see that in the top line, 22 underneath the title, it says "Opened" 23 19 September 2000, and the customer is recorded to be 24 you? 25 A. I can see that, yes. 34 1 Q. If we go two boxes to the right, we can see it's 2 recorded to be you. 3 If we go down to the big box, the activities box, 4 we can see that it deals with a call opened, as we saw, 5 on 19 September 2000 where the caller is having problems 6 balancing. Can you see that? 7 A. Yes, I can see that. 8 Q. That the postmaster is trying to balance and it is 9 saying "cannot balance while transfers are in 10 progression". Then if we go down to over the page, to 11 the entry at 7.52, there are lots of entries for 7.52 12 but the first one -- thank you -- Rakesh Patel says: 13 "I applied the outstanding transfers workaround 14 and have confirmation from the PM that this was 15 successful. 16 "The PM has agreed closure of this call." 17 Do you remember this problem, calling in that 18 a postmaster was trying to balance and couldn't balance 19 whilst transfers were in progression and a workaround 20 was applied? 21 A. No, I don't remember. I'm not sure why my name is on 22 there because the office code is that of a Crown Office 23 and I was a Crown manager at the time and the person 24 named as the caller on the third line was my assistant 25 manager at the time. So I'm -- from what I've read 35 1 there, it would appear that he was dealing with this and 2 I don't have any recollection of it at all. 3 Q. You say in your statement -- we needn't turn it up -- in 4 paragraph 108, when you were shown this document by the 5 Inquiry many months ago, that you recalled that the sum 6 wouldn't roll over if there were outstanding transfers. 7 A. Yes, that was part of the Horizon balance process. If 8 you were in an office like a Crown Office where there 9 were multiple stock units, if there were outstanding 10 transfers from one stock unit to another, ie stock A had 11 transferred an amount out but stock B had not accepted 12 it, then the office accounts rollover procedure would 13 not be able to take place because there was 14 an outstanding figure. 15 Q. Did you know that you would have to ring technical 16 support for them to apply a fix, a workaround, to allow 17 that to happen? 18 A. No, I didn't because, personally, I didn't come across 19 that situation. 20 Q. What did you know about that problem then? In what 21 context did you know about it because this appears to be 22 a record of a system error with Horizon that has a fix 23 applied to it, a workaround applied to it? 24 A. I've no recollection of ever being involved in this and, 25 until I saw this document, that's the first that I'd 36 1 seen of a workaround. 2 Q. So your name is being used in vain in this document? 3 A. I wouldn't say "in vain". It may have been put on there 4 because I was the manager of that particular branch -- 5 Q. Would that have been right -- sorry, to speak over 6 you -- at that time, at September 2000? 7 A. I believe so. I believe so. I'm not sure which office 8 I was at at the time but, looking at the office code and 9 the name of the other person who was my assistant 10 manager at the Southampton branch, so round about 2000 11 I would have been in Southampton branch. 12 Q. Can we look at a different PinICL, please. Again, 13 I think you'll be familiar with this because we've given 14 them to you in advance and it's clear from what you just 15 said that you have pored over them very carefully. 16 FUJ00076367. 17 Can you see that this is 25 October 2000? 18 A. Yes. 19 Q. The PinICL is opened and the customer is recorded as you 20 again, yes? 21 A. Yes. 22 Q. Are you going to give the same answer as before: this is 23 nothing to do with you? 24 A. No, I'm not going to give that answer. However, looking 25 at this, it's a report -- what -- the enquiry made is to 37 1 do with a supplementary report that was produced as part 2 of the accounting process and what was being queried on 3 this occasion is why a supplementary report had 4 additional figures on that were different to what was 5 being reported in the account itself and what was 6 eventually brought to our attention, so myself and -- 7 well, particularly me, was the fact that I was 8 incorrectly reading the report that was being produced. 9 Q. So shall we go through the PinICL, please. 10 A. Sure. 11 Q. Looking at the big box at activities, third line: 12 "... has reprinted a [customer's] revenue for week 13 29" -- 14 A. "Counters revenue". 15 Q. Sorry, I'm so sorry: 16 "... counters revenue for week 29 and it is 17 showing the week numbers for 29 and 28 mixed as the 18 grand total." 19 Can you decode what that's saying, please, if this 20 was your message to support? 21 A. The counters revenue was a supplementary report that was 22 printed as part of the balance procedure for the office 23 and the counters revenue was where items were recorded. 24 So, for instance, the Post Office at the time was 25 selling different forms of stationery and because there 38 1 wasn't a product code attached on Horizon to the 2 stationery, that's where the sales would appear as part 3 of the counters' revenue. So the counters' revenue 4 would be a breakdown of those sorts of things. 5 So the figure that would appear at the bottom of 6 that report would agree with the corresponding line on 7 the account and, on this occasion, the two were -- on 8 the report had been amalgamated or appeared to have been 9 amalgamated. 10 Q. Now, there is lots of -- this is a long PinICL, this 11 one, and if we just look at some entries, please, look 12 at the third page, please, after it's been allocated by 13 a John Simpkins to a Steve Squires on 26 October it -- 14 if you look on the 25th -- sorry, before the allocation, 15 about ten lines in: 16 "Will pass to SSC ..." 17 Can you recall what the SSC was? 18 A. No. 19 Q. "Could this be a new CI4 Bug?" 20 Were you aware of that bug? 21 A. No. 22 Q. Was these ever discussed with you on the telephone? 23 A. No. 24 Q. Then the allocation that I mentioned at the foot of the 25 page, please, allocated, two lines from the bottom, to 39 1 Steve Squires to investigate. Then over the page, 2 please, to page 4 three lines from the bottom the call 3 record has been transferred to the EPOSS development 4 team. Did you know what EPOSS was? 5 A. EPOSS is Electronic Point of Sale, as far as I'm aware. 6 Q. Were you ever told of any difficulties or problems with 7 the EPOSS part of Horizon? 8 A. No. 9 Q. So that would fall within that attitude of mind that you 10 had -- 11 A. Yes. 12 Q. -- that everything was tickety-boo? 13 A. Yes. 14 Q. Can we move on, please, to page 5. When the issue's 15 investigated, it seems that a Mr Kay had problems 16 tracking the issue, because of missing messages in the 17 message store. Did you know what the message store was? 18 A. No. 19 Q. He records: 20 "I have traced through this problem and by looking 21 at the message store I find that all the stock unit 22 markers are correct, the office reprint markers are 23 correct and the WP level seems to be sufficiently high 24 to include the fixes for some known problems in this 25 area." 40 1 Was any of this ever fed back to you -- 2 A. Absolutely not. 3 Q. -- that there were known problems? 4 A. No, until I was shown this document as part of the 5 bundle, I'd not seen any of this information before. 6 Q. What did you think when you saw it? 7 A. I didn't understand it, to be honest. 8 Q. "However, looking that audit logs I cannot find any 9 evidence of the Counters Revenue reprint being printed. 10 I tried to build the message store from the attached 11 file and failed due to missing correspondence server 12 messages." 13 Do you know what any of that means? 14 A. No. 15 Q. If you had been told at the time, it would have been 16 gobbledygook to you then? 17 A. It would have been, yes. 18 Q. Can we go to page 6, please, four lines in it seems that 19 Mr Squires called your branch. You weren't available. 20 Mr Kemp, your assistant, said he would do a reprint to 21 see if the problem still occurs, "However, as the office 22 is very busy this is unlikely to be before 14.00". 23 A. Right. 24 Q. Then over to page 7 -- I'm not going through every line 25 here, you will appreciate, it's just looking at the sort 41 1 of key points as the issue developed. On page 7, there 2 are a number of entries about evidence deletion. Can 3 you see that? 4 A. I can see that, yes. 5 Q. Now, in due course, we may have to enquire of Mr Squires 6 about who it was who made those entries and what they 7 mean, why evidence was being deleted from the message 8 store or whether any other evidence was deleted. 9 But if we look forwards, please, to 8 December at 10 the foot of the page, I don't know at the moment exactly 11 what this means where a deleted -- sorry, a previous 12 user appears to have been deleted but there's a record 13 that, I think, Mr Kaiser is making these entries, albeit 14 in February 2002 or 2 February. 15 In any event, the text is: 16 "I have looked at the new attachments, and they 17 are not what Steve Kay asked ..." 18 If we go over the page, please: 19 "... for on [20 November]. In order to recreate 20 the problems we need ..." 21 Then there's a list of things that are needed: 22 "a FULL message store (ie every single record from 23 every counter and correspondence server) 24 "the audit logs from the counters on which the 25 reports were produced AND the date on which they were 42 1 printed." 2 Then he records or someone records: 3 "From what I could see within the message store 4 that was supplied, the problem with Redeemed Stamps 5 report could just be a case of user misunderstanding. 6 This report (& Counters Revenue) are Office Weekly 7 reports that are not cut-off. So if the user prints 8 them, then carries out further transactions between that 9 time and the point of office rollover, any reprint 10 produced in future [Cash Accounting Periods] will be 11 different from the originals." 12 Then if we go forwards to 11 December, which is on 13 page 9, we can see at the foot of the page that the full 14 logs are added and on 15 December, which is on page 10, 15 it's recorded at 17.07.21: 16 "Problem diagnosed and a code/data fix has been 17 applied ..." 18 Were you informed of that? 19 A. No. 20 Q. That they had applied a data fix -- 21 A. No. 22 Q. -- at the other end? 23 A. No, and I have no idea what that is. 24 Q. Were you told anything to the effect that, "Look, 25 there's a problem with the Horizon System. We've 43 1 changed some code" or "We've applied a data fix in order 2 to mend it"? 3 A. No. 4 Q. So what were you told? 5 A. I honestly can't remember. I'm not aware of -- we 6 looked at a statement just now that said that the 7 report, if not cut off from the previous cash account, 8 could duplicate the figures and I believe that's what we 9 were told but I can't say for definite that's what we 10 were told, that this was the early days of Horizon 11 System and we had not followed the right process and 12 that we hadn't cut off this particular report at the end 13 of the cash account period, hence why the duplication of 14 the following months and the previous months on this one 15 report. 16 Q. So in your mind this was another case of Horizon being 17 robust, reliable and perfect but, in fact, the user 18 error, ie you in your office, getting it wrong? 19 A. Yes, but I was never made aware of anything else that's 20 on this. 21 Q. Thank you. 22 MR BEER: Sir, we're at 11.15. Might that be an appropriate 23 moment to take the morning break? 24 SIR WYN WILLIAMS: I was just unmuting myself. Yes, by all 25 means, Mr Beer. What time shall we start again? 44 1 MR BEER: Let's say half past please, sir. 2 SIR WYN WILLIAMS: Fine. Thank you. 3 (11.15 am) 4 (A short break) 5 (11.31 am) 6 MR BEER: Sir, good morning. Can you see and hear me? 7 SIR WYN WILLIAMS: Yes. Yes, I can. 8 MR BEER: Mr Gilding, can we look at a third PinICL, please 9 FUJ00077691. Can you see that this one is dated 10 3 October 2000 as having been opened -- 11 A. Mm-hm. 12 Q. -- and the customer is recorded as being you again? 13 A. Mm-hm. 14 Q. I think you have had the opportunity to look over this 15 PinICL as well. 16 A. Yes. 17 Q. You will see the entry under "Activities", third line 18 in: 19 "Critical event ... Error in Riposte API call 20 Access is denied ... No KEL for this particular NT 21 error." 22 Can you recall calling a helpline or similar in 23 relation to this? 24 A. No. 25 Q. Have you had the opportunity to read the PinICL? 45 1 A. I have, yes. 2 Q. Can you recall what was reported back to you? 3 A. I have no recollection of this at all. 4 Q. I'm not going to go through it all, not least in the 5 interests of time and it's quite a long record, but the 6 long and the short of it was a decision was taken in the 7 course of the investigation of the bug that not -- that 8 the root cause of the bug needn't be investigated and 9 that the bug needn't be fixed. But you can't remember 10 what was reported back to you? 11 A. I have no recollection of this event at all. The fact 12 that the case is opened at 3.43 in the morning, 13 I certainly wouldn't have been in the office at that 14 time. 15 Q. No. 16 A. So why my name is attached to that I have no idea. 17 Q. Can you recall any communication over this issue? 18 A. No, nothing at all. 19 Q. You've informed us -- that can be taken down, thank 20 you -- that you had what I described as an attitude of 21 mind, a state of belief, on the basis of what another 22 POL employee said to you in the course of your training 23 on Horizon, that they said Fujitsu had said. 24 A. Mm-hm. 25 Q. When you were carrying out training, did you pass that 46 1 on? 2 A. No. 3 Q. Why not? 4 A. Because it was something that had been said as part of 5 the training and the reason that I -- the reason it was 6 explained in the initial training to us that it was the 7 second best -- 8 Q. "Second most secure", I think was the phrase you used in 9 your witness statement. 10 A. -- was because as employees of Post Office we were 11 sceptical because it was new technology. Everything had 12 always been paper-based so we had a lot of people (a) 13 who were having to deal with technology for the first 14 time and there were concerns about, obviously, using 15 a computer system that a lot of people hadn't used and 16 so this statement, I believe, was made to reassure 17 people. Because the payment of pensions and allowances 18 were taking place at post offices at the time, I believe 19 that the statement was made to reassure us that the 20 system was secure as regards people's information for 21 pensions. 22 But when I did any additional training, I would 23 not have used that statement. 24 Q. Just help us: you said that you think it was given as 25 reassurance to you. Why didn't you pass on the 47 1 reassurance when you were training? 2 A. I may have done. I can't honestly say I didn't. I may 3 have done but it was not something that was part of any 4 script or training plan that was given. 5 Q. But what you didn't do in the course of training, was to 6 say that "In the nine years [by then] that I've been 7 using Horizon, I have been informed of a series of 8 errors, bugs and defects in it", because you hadn't? 9 A. No. Because I hadn't. 10 Q. Nobody was telling you about things that were known by 11 the Post Office and Fujitsu about problems in the 12 system? 13 A. Absolutely. 14 Q. Therefore, you weren't training people that there were 15 such bugs? 16 A. I was training people on the knowledge that I was given 17 and that was that it was a secure system. There was no 18 indication of any bugs or defects at any stage whilst 19 I worked for the Post Office. 20 Q. You have explained to us the basis on which you came to 21 that conclusion earlier as, in part, on what you were 22 told and, in part, because you never had cause to 23 investigate the data that the system itself was 24 producing? 25 A. Yes. 48 1 Q. You assumed it was accurate? 2 A. Yes. 3 Q. In terms, speaking generally to start with, turning to 4 training, would it be right to say that there were two 5 types of training that were given: one was training to 6 new employees, entrants to the Post Office estate for 7 the first time, so new joiners? 8 A. Yes. 9 Q. And then, secondly, training about Horizon to existing 10 employees? 11 A. So what sort of timescale are you thinking about? 12 Q. Right from the beginning. So when Horizon was being 13 rolled out, they were the two types of training that 14 were going on. 15 A. So when Horizon was rolled out I was part of the Crown 16 Office network. I was not in the training team. So 17 from my personal introduction to Horizon, I, as a Crown 18 manager, attended a two-day course but what training 19 took place for Horizon at sub office network, I don't 20 know, because I wasn't part of the team then. 21 Q. You weren't part it. So when it came to 2009 and you 22 started to deliver training, were you trained as 23 a trainer. I think your witness statement says no. 24 A. No, I wasn't. I was -- because I had previously been 25 a trainer when I was on the reserve instructor 49 1 trainings, so I had experience of delivering classroom 2 training, and because of my years of experience as 3 a branch manager and using the Horizon System there, it 4 was decided that that was a fit for the role, so no 5 additional training was required. 6 Q. Were you training new recruits? 7 A. Not directly. You mean new joiners to the Post Office? 8 Q. Yes. 9 A. Not on a regular basis. That was the role of my team. 10 I was -- 11 Q. You were supervising -- 12 A. I was supervising the team, basically. There were odd 13 days where I would stand in if one of my team was unwell 14 and we just couldn't arrange cover. So I might step in 15 to deliver that day or morning's training until a relief 16 could be arranged. But that would be the only times 17 I did any classroom training. 18 Q. But the function of the team that you managed was to 19 train new joiners? 20 A. Primarily new joiners, yes. 21 Q. Primarily -- 22 A. Yes, it was new joiners, yes. 23 Q. I think you tell us in your witness statement -- it's 24 paragraph 10 -- maybe if we just turn that up, please, 25 WITN05380100, at page 2, paragraph 10. You tell us in 50 1 that paragraph that when you were training back in the 2 mid-'80s, when you were delivering the induction 3 course -- that's for new joiners -- 4 A. Yes. 5 Q. -- this was pre-IT and it was six-week classroom course. 6 A. Indeed, yes. 7 Q. Then I think if we go to paragraph 58, please, which is 8 on page 9, it says: 9 "Following the introduction of Horizon and the 10 reduction of emphasis on numeracy skills required to 11 balance the branch, the training was reduced to 12 4 weeks." 13 Yes? 14 A. Yes. 15 Q. Then in paragraph 59, you tell us that: 16 "This was reduced further to 2 weeks as the 17 product range changed drastically ..." 18 Yes? 19 A. Yes. 20 Q. So the scheme was six weeks training before Horizon, 21 then four weeks, then two weeks? 22 A. Yes. 23 Q. Just going back to paragraph 58 there, you say that: 24 "Following the introduction of Horizon and the 25 reduction on emphasis of numeracy skills ..." 51 1 What do you mean by that "the reduction on 2 emphasis of numeracy skills"? 3 A. Because pre-Horizon, the staff who were working for the 4 Post Office had to have a high level of numeracy because 5 everything was done with pencil and rubber, basically, 6 and you had -- 7 Q. Ledgers? 8 A. Ledgers, yes, basically. However, when Horizon came in, 9 the reports were automatically generated, based on the 10 inputs to the system, so a lot of the calculations were 11 done by the system, rather than the person having to be 12 able to have mental arithmetic and add up columns. 13 Q. So did that account from the drop from six weeks to four 14 weeks? 15 A. The drop from six to four was primarily around the 16 change -- and the same with when we went from four to 17 two, it was all to do with the change of the product 18 range that was being trained. So as the number of 19 products being trained was reduced, so the amount of 20 time required in the classroom was reduced. The 21 training in the classroom was very much based around the 22 products and introducing new entrants to the products 23 and their understanding and then the actual use of 24 Horizon in the classroom would be through practice 25 sessions of how to sell those products and then how it 52 1 was for -- accounted for. 2 Q. Were there Horizon terminals in the classroom? 3 A. Yes, there were. 4 Q. Could you facilitate or demonstrate rolling over the 5 accounts in the classroom? 6 A. No. 7 Q. Why couldn't you roll over in the classroom? 8 A. Because the information from the software allocated to 9 the classroom, they were given a branch code which 10 identified them as we a training unit, so that was to 11 ensure that any transactions put through a classroom 12 terminal did not go into the live server. 13 Now, because it was a training unit, it 14 wouldn't -- the system wouldn't allow the branch to be 15 rolled over. So, at the start of each training course, 16 the trainer would go in before the course started and 17 reset all the terminals to a certain starting position 18 with amounts of cash and stock and then, when the 19 balance procedure was shown, we could go as far as 20 producing the reports and checking the stock against the 21 printouts but we couldn't then progress to roll over to 22 the next accounting or trading period. 23 Q. So the people being trained were being trained on 24 equipment that didn't enable them to be trained about 25 progressing from one accounting period to the next? 53 1 A. That's correct. 2 Q. Wasn't that -- 3 A. So that training -- sorry, that would have been covered 4 with the on-site training. So after attending the 5 classroom, the subpostmasters had a trainer with them 6 for the first two weeks of Go Live. So that was part of 7 the online, to show how that that finalised. 8 Q. Wasn't that a flaw in the training being offered? 9 A. It was but there was -- because of the restrictions on 10 the terminals, there was nothing that we could do to 11 actually demonstrate that. We had handouts that 12 explained how the process worked but we couldn't 13 physically walk them through it. 14 Q. Did anyone ever raise this, "Can't we create a training 15 environment which doesn't connect to the live estate and 16 we can roll over from one week to the next", because 17 it's something that the subpostmasters are going to be 18 doing every week, on a weekly basis, for the rest of 19 their working lives? 20 A. Yes, and the question was asked and I don't know who by 21 but, generally, by our team and us as team leaders, and 22 we were just told, no, the technology wasn't available. 23 Q. So a "computer says no" answer? 24 A. Basically, yes, sort of thing, yes. 25 Q. Did you view that at the time as a significant flaw, 54 1 that there was a disconnect between how people were 2 being trained in the classroom, as opposed to the 3 situation that they would experience live time in their 4 offices? 5 A. Not as a direct flaw because the -- what we would show 6 them in the classroom would take them right up until the 7 closing of that account. The only thing they wouldn't 8 see was how those figures were taken forward so the 9 final figures on that account would appear as the 10 starting figures on the next account. That's the only 11 thing they wouldn't see. 12 Q. If we just go back to paragraphs 18 and 19 of your 13 witness statement, please, which is on page 3. We're 14 dealing with a different type of training here, which 15 was when Horizon was first introduced into the Crown 16 network. You say: 17 "... all staff attended a one-day face-to-face 18 training event, which had a very hands-on syllabus. All 19 staff were trained on how to access the Horizon System, 20 how to enter transactions via the customer facing 21 screens and how to balance an individual stock unit at 22 the end of the balance period. This included 'rolling' 23 the [stock unit] into the next [balance period]." 24 How was it that that was able to be trained ten 25 years earlier and ten years later it wasn't? 55 1 A. So what I'm saying there is we were shown how to use the 2 equipment. The rolling over to the next bit was not 3 done on the terminals. Again, that was done via 4 a handout explanation. 5 Q. So the similar limitation -- 6 A. Absolutely. 7 Q. -- applied? 8 A. Yes. 9 Q. When you were managing the team, was feedback ever given 10 by your team members as a result of the training that 11 they delivered, that tutees were finding difficulty with 12 balancing? 13 A. So each training event there was feedback collated. 14 However, that was sent to -- that was collated and sent 15 to an external company who would provide the summary of 16 that feedback to the senior managers. 17 Q. Who was the external company? 18 A. I can't remember. I can't remember. 19 Q. Okay. 20 A. For some reason, I have a thing that they were based in 21 Totton in Southampton but I couldn't tell you their 22 name. 23 Q. So they were responsible for receiving feedback -- 24 A. We had feedback forms that we would give to the 25 delegates. They would be placed in a prepaid envelope, 56 1 sent to this company. They would then create the data 2 from the feedback and send that to our network 3 business -- to the national training team up in Salford. 4 Q. Did you ever get to see that? 5 A. The only part of that I ever got to see was if there 6 were specific comments made about individual members of 7 my team. 8 Q. What, and they were extracted? 9 A. Yes. 10 Q. What was that? 11 A. That was felt to be part of a training tool for the 12 individuals, any learning points that came out from 13 feedback from delegates about the individuals. 14 Q. What about the substance of what they were saying rather 15 than the identity of the trainers? 16 A. So that was being fed into the national training 17 managers who were making decisions about how the 18 training was run and what training would be delivered 19 and how it would be developed. So as -- in my role, as 20 managing the team, for the majority of the time I had no 21 involvement in that side of things. 22 There was after a later -- another reorganisation, 23 where part of that responsibility came down to us as 24 field team leaders, where we were asked to input into 25 different training reviews but, again, we were only 57 1 asked for our comments. We didn't actually action those 2 reviews. 3 Q. Can we look at that, please. 4 A. Yes, indeed. 5 Q. I think you are referring to POL00005850. We can see at 6 the bottom left training for quarter 3 review of 7 December 2011. Is this a record of the exercise that 8 you had just mentioned? 9 A. Yes, it is, yes. 10 Q. You'll see the way that the document works. The 11 individual who is providing the feedback referred to as 12 a stakeholder. 13 A. So these individuals, are they field team leaders across 14 the country? 15 Q. Yes, and they presumably have pulled this from -- 16 A. From their teams. 17 Q. -- from their teams. 18 A. Yes. 19 Q. So the individual who is providing the feedback who is 20 described as the stakeholder sets out a requested change 21 and then the response to that is given in the far 22 right-hand column. 23 A. Yes. 24 Q. If we go forward to page 5, please, I think we can see 25 yours. 58 1 A. Mm-hm. 2 Q. Just to understand what you're saying in this document, 3 a number of the columns say "lose" and some say 4 "change". When you say "lose" and then there's 5 a number, what's the number referring to? 6 A. So, for instance, "Lose 46 Cash Management", is that 7 what you're saying me, what 46 ... 8 Q. Yes. 9 A. 46 was the session number within the training event. So 10 each of the different -- 11 Q. Modules? 12 A. -- yes -- were all given session numbers. 13 Q. And you're suggesting nationally that module 46 should 14 be removed because, and then you give the reason? 15 A. Yes. 16 Q. I just want to ask you about an entry halfway down the 17 page, starting stock balancing. It reads: 18 "Stock balancing is only 2 slides and that is 19 talking about cash management, which has already been 20 covered in an hour's session. It needs to have more 21 reference to all aspects of balancing -- for example, TP 22 and ..." 23 By that you mean "transaction processing"? 24 A. Trading periods. 25 Q. And balancing periods? 59 1 A. Yes. 2 Q. "... net discrepancies' settling centrally, transaction 3 corrections and rems." 4 A. Remittances. 5 Q. We know what remming in and out is, it's all right. 6 Can you tell us on what basis were you making that 7 suggestion? 8 A. So that was -- so the actual stock balancing session was 9 very much a practical session and these two slides 10 were -- at the start of the session were an introduction 11 to what the delegates were about to do and how they 12 should complete the balance in the training environment. 13 But, as I've said with the outcome, there was very 14 little explanation around terminology and the accounting 15 procedures for losses and gains and it was important 16 that once they left the classroom that the delegates 17 were aware of how they correctly accounted for losses 18 and gains and what the correct procedures were. 19 Q. Why is it important to be able to account for a gain or 20 a loss? 21 A. Because if you don't account for it correctly, it would 22 impact on your accounts for the following -- so you 23 would have false starting figures for your next 24 accounting period. 25 Q. What might happen to you? 60 1 A. You might get an audit. 2 Q. You might get? 3 A. You might get an audit. 4 Q. Annoyed? 5 A. An audit. 6 Q. An audit? 7 A. You might get a visit from the audit team. 8 Q. What might happen then? 9 A. That would depend on the outcome of that particular 10 audit. 11 Q. You might get sacked? 12 A. Not necessarily. 13 Q. You might get prosecuted? 14 A. Not necessarily. 15 Q. It's been known to happen, hasn't it? 16 A. It has been known to happen but that's not the primary 17 role of the audit. 18 Q. You said that the primary role of the audit was actually 19 to help people. 20 A. Yes, to identify discrepancies and how they may have 21 occurred. 22 Q. Is that how your team saw it, the auditors that went in, 23 that "We're there to help people, not to act as 24 investigators, to pass on information to investigations 25 division" -- 61 1 A. No, our role was purely to go in and identify the 2 situation in the branch, to assist in any way we could 3 and then pass that relevant information on to the 4 contracts advisers and the security team. 5 Q. You are recording this in December 2011; so 10 or 6 11 years after the introduction of Horizon, you're 7 making the point that the training on balancing is 8 inadequate or needs to be changed? 9 A. Yes, needs to be -- but there were training reviews on 10 a regular basis, as far as I'm aware. 11 Q. We've heard some evidence that feedback that was 12 provided before rollout suggested that training on 13 balancing was inadequate? 14 A. Mm-hm. 15 Q. We've heard evidence that the feedback provided during 16 rollout, a decade earlier, was that the training on 17 balancing was inadequate, and here you are 11 years 18 later saying there are problems with the training on 19 balancing, aren't you? 20 A. Yes, with the -- yes, with the training in the 21 classroom. 22 Q. The entry in the row below: 23 "Add more information regarding how a branch works 24 ['differently', I think that must mean] between office & 25 stock unit, TPs and BPs, how Horizon accounts for 62 1 transactions." 2 Do you know how it was that -- which is 3 essentially the same point as above, isn't it? 4 A. Yes, this is more around explaining what all the 5 different terminologies are. There wasn't, in my view, 6 enough emphasis on what the different terminology was 7 used, so people could get -- yes, they might get 8 confused as to the difference between a trading period 9 and a balance period. So it was to make a lot clearer 10 what the differences were. 11 Q. These problems with the training on balancing, were they 12 raised -- were you raising this on the basis of what had 13 been said directly to you by recruits or by what your 14 team members had fed back to you? 15 A. So this was feedback from the team members. 16 Q. Was it fairly consistent across the board? 17 A. Yes. 18 Q. So not an isolated issue? 19 A. No, no. Isolated issues wouldn't have -- would have 20 been dealt with on an individual basis. Items that were 21 put forward as part of the training review were a wider 22 view. 23 Q. Can we look, please, at POL00005869, please. This seems 24 to be part of the same process. You'll see the date in 25 the bottom left. 63 1 A. Right. 2 Q. If we turn to page 17 of the document, please, we can 3 see a record of feedback from your team. Can you see 4 that? 5 A. Yes. 6 Q. Are the entries in the right-hand column from tutees, 7 from recruits? 8 A. No, these are from trainers who are running the courses. 9 Q. So this is pooling the actual words of trainers in 10 a document, so rather than you speaking for them they 11 are speaking to head office? 12 A. Yes, so they are giving me their feedback or thoughts on 13 these sessions and I'm collating that and passing that 14 to the review. 15 Q. Somebody says in the second entry for your team, in the 16 second paragraph: 17 "My initial thought is what has changed. I have 18 already expressed the opinion that we might have missed 19 the boat as far as making changes to the course and 20 still hope this isn't seen as being negative and 21 unconstructive. It seems to me all we have done is to 22 take the old sessions, update them a little but no 23 longer call them module 1, 2 or 3. I was very aware 24 that this course is still a one size fits all type of 25 course which is aimed more towards which the Crown 64 1 offices branches. All of this might of course be 2 changed with the network changes, even so, SPMR or Main 3 [Post Office] Branches are not the same as counter 4 assistants in a Crown Office, my feeling is there should 5 be a course written completely from scratch that is 6 aimed specifically at someone who will have to run 7 a branch by themselves after a couple of weeks or so. 8 As a for instance, we could cover rems more fully." 9 What's the essence of the complaint there? 10 A. The essence of the complaint is that it is -- the 11 training package was a one size fits all, that the style 12 of training was aimed primarily around the products and 13 that -- yes, the one size fits all didn't necessarily 14 fit. 15 Q. You said in the course of that answer, the course had 16 been aimed too much at the products or focused too much 17 on the products. Can we just look at what you say in 18 your witness statement, please? 19 A. Right. 20 Q. WITN05380100, at page 17, in paragraph 102, at the top 21 of the page. Is this what you were just referring to 22 there: 23 "... I felt the emphasis of the course, and the 24 business as a whole had become too sales orientated and 25 not enough focus was on cash discrepancies within 65 1 branches." 2 A. Right, so what I'm referring to there as, stated in 3 previous paragraph 101, this is around 2012 when Post 4 Office as a business changed the way that they were 5 operating and that they were going very much for 6 a sales-driven culture, rather -- so the changes to the 7 training then were very much around "Here's the product, 8 here's how we sell it" and then "How do you now add on 9 additional sales to that product?" 10 It wasn't something that sat comfortably with me. 11 That's not what I do. I'm not a salesman and, whilst 12 that was the direction the business was going, 13 personally it is just my view -- it's not the business' 14 view -- but my view was that there was too much time 15 spent on trying to increase sales rather than paying 16 attention to the accounting and accuracy within the 17 branch. 18 Q. You say in this paragraph that there was not enough 19 focus on cash discrepancies within branch. Why did 20 there need to be focus or more focus on cash 21 discrepancies? 22 A. So that when discrepancies occurred in the branch, the 23 subpostmaster would have a greater knowledge of how to 24 investigate and also have a full understanding of what 25 support options were available for them as well. 66 1 Q. You say at the end of that paragraph: 2 "I stress this [is] my view and not that of senior 3 management team who were striving to keep branches 4 afloat by generating new income streams." 5 A. Yes. 6 Q. Does that reflect what you were told back at the time? 7 A. Yes, yes. 8 Q. Is it right that on the course that your colleague 9 referred to in the document that we just looked at, 10 balancing and cash account issues were handled on day 2 11 of the course? 12 A. I can't remember the agenda of the course but if that's 13 what they say, then ... 14 Q. If you can't remember -- 15 A. No, I can't remember the exact agenda of the course. 16 Q. Can you recall at any time, until you went over to the 17 Horizon mediation investigation team, that anyone within 18 Post Office suggested to you that any of the problems 19 that subpostmasters and other branch staff might face 20 were due to any issue with Horizon at all? 21 A. No. 22 MR BEER: Thank you very much. They are the only questions 23 I ask at the moment. I think there are some other 24 questions. 25 Yes, Mr Jacobs. 67 1 Questioned by MR JACOBS 2 MR JACOBS: Mr Gilding, good afternoon. I ask questions on 3 behalf of 156 subpostmasters, assistants and managers 4 who are represented in this Inquiry by Howe+Co. I want 5 to ask you about some points in your statement that you 6 make about Horizon training and subpostmaster user 7 errors. I am going to take you to three paragraphs in 8 your statement. The first paragraph is paragraph 43 and 9 the reference for that, I see is already on the screen, 10 is at page 7 of 19. 11 Sir, can you hear me a bit better now? 12 SIR WYN WILLIAMS: I can hear you clearly or more clearly 13 than that last. 14 MR JACOBS: Thank you, sir, I think the microphone was too 15 far away. At paragraph 43, you say: 16 "Informal and formal feedback was given at each 17 event to the trainer." 18 Are you able to say whether you received any 19 feedback or whether feedback was given after the event, 20 after training had completed, or concluded? 21 A. So the feedback I'm referring to there is from the 22 paragraph above, which states that part of my role was 23 to attend training events whether that be classroom or 24 on-site and, as a result of what I observed and as part 25 of a training and development for the individuals, 68 1 I would give informal and formal feedback to that 2 trainer based on my observations. 3 Q. You would give feedback, right. 4 A. But that was purely on observations conducted. 5 Q. What about feedback given by the subpostmaster to the 6 trainer or the training team? 7 A. As part of the on-site visits that I would conduct with 8 the trainers, I would have a discussion with the 9 subpostmaster and ask them for feedback about their 10 training and about the trainer -- more -- I was more 11 focused on the actual trainer themselves but, obviously, 12 if they gave me information about the training as well, 13 then that was recorded as well. 14 Q. So, essentially, you were training the trainer? 15 A. Yes. 16 Q. Were you aware of any feedback or complaints about the 17 training that came from subpostmasters after the 18 training had taken place? 19 A. No. 20 Q. Why wasn't that fed back to you? Are you able to say? 21 A. No, I'm not able to say. 22 Q. Did you listen to the evidence of the subpostmasters who 23 gave evidence in Phase 2 of this the Inquiry -- Phase 1, 24 I ought to say -- from February to May 2022? 25 A. No, I've not seen any of that. 69 1 Q. Many -- then you won't have seen, and I have to put this 2 to you, many of our clients -- and 50 of them gave 3 evidence and the rest were read into the record, and 4 their statements have been exhibited -- many of our 5 clients say they received no training whatsoever in 6 balancing in relation to discrepancies, many others 7 requested further training but those requests were 8 refused. 9 Were you aware of those issues at the time when 10 you were involved? 11 A. No. 12 Q. We've looked at 102 of our clients' witness statements 13 and 95 of these -- that's 93 per cent of our clients -- 14 all say that the training they received was inadequate. 15 Why weren't you aware that there were these very serious 16 issues coming from subpostmasters in respect of Horizon 17 training? 18 A. Because it was not part of my role. My role was to 19 train the trainers, not to develop the training course 20 itself. That was down to the senior managers to develop 21 the training courses based on the feedback from 22 postmasters. 23 Q. What about feedback from those trainers who you trained? 24 19 of our clients have said in their evidence that 25 shortfalls occurred actually during the training process 70 1 itself, for which those who were conducting the training 2 were unable to provide explanations. Did you ever hear 3 from those who you trained about those issues arising? 4 A. No, and that's the first time I have heard that 5 statement. 6 Q. Right. It's one example, perhaps I ought to put to you 7 Heather Earley, who was a subpostmistress from 2011 to 8 2017, said that she never completed a balance during 9 training, she wasn't trained in respect of how to deal 10 with shortfalls and the Post Office trainer who trained 11 her could not make the Horizon System balance. That's 12 one example of the 19. 13 Are you not aware of this? 14 A. I'm not aware of that and I don't know who that is or -- 15 and may well have been in a different part of the 16 country that didn't come under my team's remit. 17 Q. It was in Antrim, I'm sure she wasn't trained by you but 18 it's an example of someone who was being trained at the 19 time when you were involved in training the trainers. 20 A. Okay. 21 Q. You say in your statement then, going back to 22 paragraph 43, that you cannot recall any trainer failing 23 in the delivery of the training, they were dedicated, 24 hard working, regularly went over and above their remit, 25 made themselves available for phone calls after training 71 1 had concluded and forged strong commitments with 2 subpostmasters. 3 In light of the evidence, that hasn't been 4 contested, that our clients and other subpostmasters 5 gave in the first phase of this Inquiry, in relation to 6 the inadequacy of training, do you accept, with 7 hindsight, that trainers must have failed in the 8 delivery of training in respect of the Horizon System? 9 A. I can only answer, as it says in my statement there, 10 from the team that I was leading and I was satisfied 11 that the training they were given -- that they were 12 delivering was to the standard that was required and 13 I can only answer for my own team. I don't know the 14 rest of the country. 15 Q. Well, that was your experience, as you say. 16 A. That was my experience, yes. 17 Q. But this morning in answering questions from Mr Beer, 18 King's Counsel, in relation to robustness and bugs and 19 defects, you made a concession. You said at the time 20 I thought it was robust but that's not what I know now. 21 Are you able to say that in relation to training, to 22 make the same concession? 23 A. Yes, I could make that same concession but the comment 24 I made about being aware now, that awareness has only 25 come after I've left the business back in 2016. 72 1 Q. Thank you. If we could then turn to the next paragraph 2 I wanted to refer you to which is paragraph 79 of your 3 statement which is on page 12 of 19, and you say here: 4 "I believe [in the present tense] the training 5 programme was adequate, the vast majority of trainees 6 were competent in the use of Horizon, able to complete 7 all tasks required for their respective role within the 8 branch." 9 In light of what you've just said, that you can 10 make that concession, should "I believe" now read 11 "I believed", in the past tense? 12 A. Yes, yes. 13 Q. In relation to your evidence this morning a follow-on 14 question. You said that you were told by a Post Office 15 trainer that Horizon was the second most secure system 16 in Europe. Do you recall the name of the person who 17 told you this? 18 A. No. 19 Q. The problems that I have referred to, which the Inquiry 20 has heard about in Phase 1 of the evidence and the 21 hearings from February to May, they were problems that 22 you said you weren't aware of. Do you think there is 23 a reason why you didn't know about these? 24 A. Sorry, I'm not sure what -- 25 Q. These issues with training that had been arising from 73 1 the Horizon rollout? 2 A. Is the reason why I was not aware of them? 3 Q. Were there meetings of other trainers, issues that were 4 discussed in relation to "Have we heard any complaints, 5 what's the situation on the ground with these 6 subpostmasters"? 7 A. No. 8 Q. Were there discussions? 9 A. No. 10 Q. Do you think it would have been helpful to you if 11 someone within the Post Office had communicated these 12 issues to you? 13 A. Oh, absolutely, yes. 14 Q. Finally, if we can go to paragraph 91 of your statement 15 and that's at paragraph 14 of 19, for the benefit of the 16 screen, you say here: 17 "The only difficulties I encountered with Horizon, 18 were primarily due to user errors, ie incorrect 19 accounting processes followed and, quite often, 20 a reluctance from subpostmasters to seek assistance. 21 Unfortunately there were too many occasions whereby the 22 subpostmaster tried to 'fix' discrepancies but actually 23 by incorrect accounting made the situation worse. 24 However I am unable to offer any specific examples at 25 this time." 74 1 Now, we know, and you've acknowledged to Mr Beer 2 this morning, that your understanding of the robustness 3 of the system then is not what your understanding is now 4 because of what happened in the Group Litigation because 5 of the reasons that we're here for in this Inquiry. 6 A. Mm-hm. 7 Q. Are you able then to make the same concession in 8 relation to the errors in the Horizon System being down 9 to user error when, in fact, our clients say that that's 10 what the Post Office said but it was actually bugs, 11 errors and defects in the system? 12 A. Yes. So my statement there is based on my knowledge as 13 somebody who worked for the Post Office and obviously, 14 since I left the Post Office, other things have come to 15 light that I was not aware of at the time. So my 16 statement is based on my knowledge and experience from 17 working for the Post Office. 18 Q. But what you know now is different? 19 A. It's different, yes, indeed. 20 Q. Now, you also confirmed with Mr Beer that you had what 21 Mr Beer has described as an attitude of mind or a state 22 of believe in relation to that the system was robust and 23 errors were down to user error by subpostmasters. 24 Now, the High Court found that this was the 25 prevalent attitude in the Post Office, the system was 75 1 robust, it was the postmasters' errors that were causing 2 these problems. From what you can remember and 3 recollect at the time when you were with the Post 4 Office, when these issues with Horizon were arising, did 5 your colleagues share these views, this attitude of 6 mind, about the robustness of the system and the 7 culpability of subpostmasters? Was this widespread, 8 this view? 9 A. Yes, it was and when I worked for the mediation team, it 10 was -- we were looking at the data from the Horizon 11 equipment. That would have been a pointless exercise if 12 we'd have known that information was corrupt. 13 MR JACOBS: I don't have any further questions but I expect 14 I might have some questions I'm going to be asked to ask 15 you. (Pause) 16 SIR WYN WILLIAMS: Anyone else? 17 MR JACOBS: I apologise, I do have one further question that 18 arises on instructions, sir. 19 SIR WYN WILLIAMS: All right. Carry on, Mr Jacobs. 20 MR JACOBS: Paragraph 91. You say that you are unable to 21 offer any specific examples of incidences when 22 subpostmasters tried to fix discrepancies. Are there 23 any cases or examples that you can remember that are 24 relevant to your evidence of problems that 25 subpostmasters had or experienced that you were aware 76 1 of? 2 A. No, what I'm trying to explain there is there were 3 situations where subpostmasters had identified 4 a shortfall and, rather than seeking assistance from the 5 Network Business Support Centre or requesting a field 6 team adviser to go out and assist them, they were trying 7 to correct things on Horizon and, on several occasions, 8 I witnessed they got themselves totally confused as to 9 which way the accounts were, what was negatives, what 10 was positives and actually, rather than correcting the 11 discrepancy, they were adding to it. So that's what I'm 12 trying to explain now. 13 Q. Just one final point. This state of confusion that 14 people were in, might that have been as a result of the 15 training? 16 A. It might be a lack of knowledge, yes. 17 MR JACOBS: Thank you. I don't have any further questions. 18 Questioned by MS PAGE 19 MS PAGE: Just one question, please, from me or rather one 20 area of questioning. It's Flora Page on behalf of 21 a number of the subpostmasters. 22 What I want to ask you about is how you came to 23 give evidence before the Inquiry. Who approached you, 24 in the first instance, or did you volunteer yourself? 25 A. No. I was approached by the Inquiry, via email to 77 1 provide a witness statement. 2 Q. In your personal email? 3 A. In my personal email, yes. 4 Q. Do you know how that email was provided to the Inquiry? 5 A. No. 6 Q. Would it have been left with the Post Office when you 7 finished your period of term with them? 8 A. I don't know. I don't know. 9 Q. When you left in 2016, it was on terms which were 10 agreed, was it? It wasn't a dispute between you and the 11 Post Office? 12 A. No, it was a voluntary redundancy agreement. 13 MS PAGE: Thank you. 14 SIR WYN WILLIAMS: Anyone else? 15 Questioned by MS PATRICK 16 MS PATRICK: Yes, sir, we have one question on behalf of the 17 Hudgells CPs, thank you. 18 Mr Gilding, my name is Angela Patrick and together 19 with Tim Moloney KC we represent a number of 20 subpostmasters who were wrongly convicted and who are 21 now represented by Hudgell Solicitors. I have a number 22 of questions about two documents. 23 A. Right. 24 Q. It shouldn't take very long. So we're going to start 25 with a document which it goes by the reference 78 1 POL00033486, if that could be brought up I would be 2 grateful. I think you can see there it's a typed up 3 document and on the left-hand side it says "Do I need 4 a cash remittance?" Beyond that title, I'm just going 5 to ask you to look at the very bottom left-hand corner 6 there. Can, you see that version 4.3, August 2011, 7 Chris Gilding? 8 A. Mm-hm. 9 Q. Would this be a document that would have been drafted by 10 you? 11 A. So this document was not written by me but within the 12 field team I was -- it was one of the documents that 13 I was responsible for making any updates. So the reason 14 it's 4.3 is, in August 2011 I must have made some sort 15 of update but what that was I can't recall. 16 Q. You can't recall. Right. We don't need to go through 17 it but I'm sure you will take it as read, you can see 18 what's on the page in front of you. 19 A. Yes. 20 Q. It's a step-by-step guide on how to -- Mr Beer has 21 already said we're already familiar with the terms -- 22 how to rem in and rem out; is that fair? 23 A. Yes. 24 Q. Now, I want to look at another document, to look at 25 information that was available to Fujitsu at this time 79 1 when this document was being overseen/approved by you? 2 A. Mm-hm. 3 Q. Can we look at what is the technical appendix to one of 4 the Horizon judgments. I don't expect you to have seen 5 this before, I'm using it for shorthand. The reference 6 is RLIT0000006. 7 Is that in front of you now? 8 A. It is, yes. 9 Q. The front page -- I'm only bringing it up so everybody 10 can see -- the front page shows that the judgment was in 11 2019. So this is after your document was produced but 12 we're, as I say, only using it for reference to the 13 documents that are in the judgment, no reason you would 14 have necessarily seen this. 15 But I think you have said you are aware the 16 judgments themselves had identified a number of bugs, 17 errors and defects in Horizon. You're nodding 18 Mr Gilding, you have to say yes or no -- 19 A. Yes. 20 Q. -- for the transcribers, thank you. Yes. 21 Did you know that a number of those were related 22 to remming in and remming out? 23 A. No, I don't know any of the details of the judgments. 24 Q. If we -- 25 A. Can I just add that that document that you previously 80 1 showed me, the remming in and remming out, was 2 a document that was used for new entrant training so 3 only would have been used with people coming into the 4 Post Office from 2011. 5 Q. So who were new? 6 A. Yes. 7 Q. It wouldn't have been circulated to anybody else? 8 A. No, it was purely for the training team. 9 Q. So anybody else would have to refer back to their 10 earlier training if they had a problem? 11 A. And they would have operations manuals in the branches 12 that explained how the processes worked. 13 Q. We'll come back to the document itself. But if we can 14 look at a part of the judgment, and everybody will be 15 assured I'm not going to look at every bug, I'm just 16 going to look at one example -- if we can look at 17 page 46, please, and go to the bottom of the page and 18 I only really want to look that title here. You can see 19 there at 5 the judge is referring to a "Remming In bug". 20 Can you see that, Mr Gilding? 21 A. Yes. 22 Q. Just above paragraph 181. I don't need to go any 23 further than to read the start which says: 24 "This is a Horizon Online bug." 25 Then the judge starts to look at the evidence. 81 1 I want to look at a particular example -- a particular 2 paragraph, for some of the detail. So if we could go to 3 page -- I'm going to 187, which I think is on page 49 -- 4 I apologise to those dealing with the documents, 5 page 48, and it's at the bottom. You can see some Q&As, 6 the judge is considering some of the live evidence that 7 was given, and at paragraph 187, he goes on to say: 8 "This evidence does not support the submission 9 that remming errors are picked up by Horizon. It is 10 necessary, therefore, to look at the actual PEAKs ..." 11 Now, you have looked at a PinICL and you couldn't 12 remember it. A PEAK is like a PinICL. It's an internal 13 document. 14 A. Okay. 15 Q. "... to see what they show. The one associated with 16 what the Post Office called Issue 1, PC0203085, is dated 17 22 August 2010 and is headed 'pouch remmed in on two 18 counters at same time'. The first entry under impact 19 statement is ..." 20 It explains here: 21 "The same pouch can be remmed in to the system 22 more than once, resulting in a shortage at the branch 23 which POL have to rectify by issuing a Transaction 24 Correction." 25 If we can scroll down to the next page, please, 82 1 the judge has looked at other evidence, and he says: 2 "In my judgment [in the next paragraph] that entry 3 alone is evidence of a bug. It shows a pouch can be 4 remmed in more than once -- admittedly rarely -- and 5 that a TC [I think we can agree it's 'transaction 6 correction'] is necessary to correct this." 7 We don't need to go through all the detail but, if 8 we can scroll down a little more, but while we're at 9 that paragraph and that judge's conclusion, had you ever 10 been told that Fujitsu were aware that a bug error or 11 defect existed -- 12 A. No. 13 Q. -- which could show a pouch remmed in more than once? 14 A. No, never been told that. 15 Q. Thank you. 16 Actually, if we can stay at paragraph 188, you can 17 see that in front of you, there's an entry there from 18 a PEAK from Anne Chambers, which is recorded on 19 17 August, and she has some details about a pouch and 20 below the numbers it says: 21 "The [postmaster] cannot reverse the transaction 22 since rem reversal isn't allowed." 23 Can you see that, Mr Gilding? 24 A. Yes. 25 Q. Below: 83 1 "This is NOT another example of the duplicate rem 2 problem that we have seen in the past, where use of the 3 Prev key accepted the same pouch twice. In this case 4 the pouch was processed on both counters ..." 5 That seems to suggest that there were at least two 6 problems that Fujitsu were aware of, doesn't it? 7 A. It does, yes. 8 Q. That appeared similar. Can you help us first, what's 9 a "Prev key"? 10 A. That's the previous key. So it would take you back to 11 the previous screen. 12 Q. Thank you. So it's not that problem that relates to the 13 Prev key that the country problem relates to. But were 14 you told about any bugs, errors or defects which could 15 impact on remittances -- 16 A. No. 17 Q. -- or on any kind of remming in or remming out? 18 A. No. 19 Q. Can we scroll down to 192, which I think is on the 20 following page, page 50. I'm skimming over the 21 evidence. But in that paragraph, which I hope you can 22 see now: 23 "In my judgment, this PEAK is evidence of a bug 24 and a fix is required to remedy it. It also shows that 25 remming in errors are not always picked up by Horizon." 84 1 You said you weren't told about any bugs or 2 errors. 3 A. That's correct. 4 Q. I assume in that sense you weren't told that sometimes 5 there were remming errors that weren't picked up by 6 Horizon? 7 A. No, never heard that. 8 Q. As somebody who was involved in training and auditing, 9 would that have been useful information for you to have 10 had? 11 A. Of course. It would have been extremely useful. 12 Q. Can we turn back to the first document we looked at, 13 POL00033486, please. I know you've said this was only 14 new entrants but let's see what new entrants were being 15 told. If we can go to page 2 of this document, please, 16 and you can see on that page some bold text. Can you 17 see that, Mr Gilding? 18 A. Yes. 19 Q. I will read it for the transcript: 20 "If you have a discrepancy with any of your 21 remittances, please refer to Horizon Online help 22 facility or contact the NBSC." 23 That's highlighted in bold, isn't it? 24 A. Yes. 25 Q. Can you recall why? 85 1 A. That is -- that's there so that if somebody does have an 2 issue with their remittances and they don't know how to 3 correct it, then that was to emphasise that the support 4 that was there was either through the Horizon Online 5 help facility or that they should contact by telephone 6 the Network Business Support Centre which was their 7 first point of contact for any support. 8 Q. I mean, at that point when you're looking at this 9 document, by 2011 were you aware that anybody was 10 raising particular problems with remittances, were you 11 hard anything from the Post Office, from your line 12 management, from your trainers, or from subpostmasters? 13 A. No. 14 Q. Nothing? 15 A. No, nothing I can recall. 16 Q. But here it's in bold. 17 A. Yes. 18 Q. And it's relying on essentially the operator to identify 19 that a discrepancy they have is related to a remittance 20 and you're telling them to contact, in that case, the 21 Helpdesk? 22 A. Yes. 23 Q. So if they spot that there is a problem and it's related 24 to a remittance, contact either the Horizon Helpdesk -- 25 and I think we've heard that's HSH but you might not -- 86 1 is that an acronym -- 2 A. Yes. 3 Q. -- or the NBSC? 4 A. NBSC, yes. 5 Q. And would it then be up to the Helpdesk, whichever one, 6 to determine what the problem was and whether it might 7 be user error or a bug? 8 A. My understanding, although I was obviously not involved 9 in that, is that the information recorded by the NBSC 10 would then be passed on to the accounts department 11 within Chesterfield to look at that individual branch, 12 but that's not an area I was involved in. That's just 13 my thoughts. 14 Q. So just to be absolutely clear, before you looked at 15 this document -- you didn't draft it but you were 16 responsible for oversight of it -- 17 A. Yes. 18 Q. -- did anybody discuss with you that there might be bugs 19 in Horizon related to remming? 20 A. No. 21 Q. Did anybody discuss with you that there might be errors 22 in remming which were not spotted by Horizon? 23 A. No. 24 Q. As someone who has done remittances and who has used 25 Horizon yourself in a post office, would that have been 87 1 useful information for you to have had? 2 A. Yes. 3 MS PATRICK: Thank you. I don't have any more questions for 4 you, Mr Gilding. 5 MR BEER: Sir, there are no more questions but, just before 6 we end Mr Gilding's evidence session, can I just ask for 7 one document to be brought up on the screen. It's 8 POL00029492. It's the document prepared for the high 9 level meeting with Messrs Arbuthnot and Letwin that 10 I took Mr Gilding to earlier. You will see it says that 11 the meeting is scheduled for 17 May 2010. That is as 12 the document appears. 13 It's been helpfully drawn to our attention that 14 there are the other versions of this document which 15 suggest that the meeting was, in fact, on 17 May 2012. 16 THE WITNESS: I honestly don't know which this correct date. 17 MR BEER: I wasn't -- 18 THE WITNESS: Sorry. 19 MR BEER: I wasn't inviting an answer. I was more 20 addressing this to the Chair. 21 THE WITNESS: Okay, sorry. 22 MR BEER: No, that's all right. No need to apologise. 23 I just make that clear. We've got in the Inquiry 24 literally dozens of versions of this document from 25 various sources. We'll investigate that error on the 88 1 face of the document provided by, in this case, the Post 2 Office but -- 3 SIR WYN WILLIAMS: All right, Mr Beer. That's fine. I'm 4 sure we can satisfy ourselves what the correct date is 5 with appropriate investigations. 6 MR BEER: Yes, thank you very much, sir. Subject to that, 7 that's the end of Mr Gilding's evidence. 8 Questioned by SIR WYN WILLIAMS 9 SIR WYN WILLIAMS: Thank you, Mr Gilding. I'd just like to 10 get one thing straight in my mind, if I may. 11 A. Indeed. 12 SIR WYN WILLIAMS: I want you to think about the time period 13 2009, when you first began to become involved in 14 a formal sense with managing teams of trainers and 15 auditors -- 16 A. Mm-hm. 17 SIR WYN WILLIAMS: -- and the 2015 when your secondment to 18 the mediation investigation came to an end. So I'm 19 focusing on that approximately six-year period. You've 20 been asked a number of questions about your own mindset 21 and I take it that the mindset -- your own mindset in 22 relation to the robustness and reliability of Horizon, 23 and I take it from what you said that each of the teams 24 you managed, in whatever capacity, in that same period 25 shared your mindset. 89 1 A. Yes, that's correct. 2 SIR WYN WILLIAMS: To what extent, if at all, was there 3 discussions as between different teams? In other words, 4 were these teams kind of self-contained and just went 5 about their business in a vacuum or, from time to time, 6 would there be cross-fertilisation, if I can put it in 7 that way, between other teams doing the same job? 8 A. There was occasions where we would cross over with other 9 teams. So my team in the south would sometimes cross 10 over with the London team. So, yes, there was 11 a crossing-over between the teams on occasion. 12 SIR WYN WILLIAMS: Right. And in those sessions, were there 13 ever any occasions when the reliability or robustness of 14 Horizon came under discussion? 15 A. Not that I can recall. 16 SIR WYN WILLIAMS: So that I don't get a false impression 17 about this, was that because it simply didn't arise or 18 was it because, so far as you can judge, every other 19 team shared the same view of Horizon as did you and your 20 team? 21 A. I would say the latter, that everybody shared the same 22 view about the Horizon System. 23 SIR WYN WILLIAMS: So is this a fair point for me to take 24 from your evidence, that in this period when you were 25 dealing with teams who were looking into either audit or 90 1 training or the like, is it true that everyone you came 2 across who was engaged in this all had the same view of 3 Horizon? 4 A. As far as I'm aware, yes. 5 SIR WYN WILLIAMS: All right, thank you. Thanks very much, 6 Mr Gilding, for your willingness to answer a great many 7 questions this morning and for providing a witness 8 statement as well. I'm grateful to you. 9 A. Thank you. 10 MR BEER: Sir, can we say 1.40 to start the next witness, 11 please? 12 SIR WYN WILLIAMS: Yes, certainly. Fine. 13 MR BEER: Thank you very much. 14 (12.43 pm) 15 (Luncheon Adjournment) 16 (1.40 pm) 17 MR STEVENS: Good afternoon, sir, can you see and hear me? 18 SIR WYN WILLIAMS: Yes, I can. Thank you. 19 MR STEVENS: If I may call Kathryn Parker. 20 KATHRYN PARKER (sworn) 21 Questioned by MR STEVENS 22 MR STEVENS: Thank you. As you know, my name is Sam Stevens 23 and I ask questions on behalf of the Inquiry. Please 24 could I ask you to state your full name? 25 A. Kathryn Frances Parker. 91 1 Q. Thank you for giving evidence to the Inquiry today and 2 providing the written statement, which I would like to 3 turn to now, which should be in the bundle in front of 4 you. 5 A. Yes. 6 Q. Is that dated 10 December 2022 running to 11 pages? 7 A. It is, yes. 8 Q. Could I ask you to turn to page 9 of the statement. Is 9 that your signature? 10 A. It is, yes. 11 Q. Are the contents of that statement true to the best of 12 your knowledge and belief? 13 A. They are. 14 Q. That now stands as evidence in the Inquiry but I will be 15 asking you some further questions. I'd like to start 16 with your background. You say that you joined the Post 17 Office in 1984. 18 A. Yes. 19 Q. That was in its graduate training programme? 20 A. That's right, yes. 21 Q. What was your first substantive role with the Post 22 Office? 23 A. I was -- as a graduate, I was attached to Counter 24 Services 1.1, which was a team that was looking at the 25 Post Office network in terms of coverage, as far as 92 1 I remember, and then I had a variety of other roles. 2 Q. Could you just give a summary of roles you had up until 3 1998. 4 A. Up to 1998. Okay, apologies, I didn't bring my CV with 5 me, so I'm going to struggle a little as to the order in 6 which they came. I stayed in Counter Services for 7 a number of years after I finished the graduate 8 programme. I then went over to the -- I transferred 9 over to the Post Office to work for the company 10 secretary where I headed up a services group for the 11 company secretary. I then came back to Post Office 12 Limited in 1995. 13 Q. Would that be Post Office Counters Limited? 14 A. Post Office Counters Limited. Yes, it changed its name 15 several times during that period. So it started off as 16 the Post Office, then it was Counter Services, then it 17 was Post Office Counters Limited. 18 Q. So back to Post Office Counters Limited in '94, was 19 that? 20 A. '95. 21 Q. '95, my apologies. What was your role at that stage? 22 A. So I was head of resourcing for Post Office Limited. So 23 that was everything to do with recruitment of staff 24 workforce. 25 Q. Getting to 1998, were you in the same role then? 93 1 A. I was in the same role in 1998, yes. In 1999, I became 2 head of personnel policy development, which was leading 3 on all of the HR policies that applied to workforce but 4 also leading on the policies that related to training. 5 Q. As we'll come to and you've referred to in your -- or 6 you've been taken to in your witness statement, some 7 documents from January and April 1999 -- 8 A. Yes. 9 Q. -- were you in that training role in early 1999? 10 A. I believe so. What's important to say, though, is I was 11 in that training role so my day job was head of 12 personnel policy. The work to do with Horizon was not 13 part of the core job, it was something in addition to 14 that. So I wasn't part of the Horizon team per se, 15 I was doing my business-as-usual day job which was as 16 head of personnel policy development. 17 Q. In respect of training, what were your day-to-day 18 responsibilities? 19 A. It was around the policy, the policy for training 20 provision. So Post Office Counters Limited at the time 21 had a network of its own trainers and then, as Horizon 22 came along, there was a need to work with the Horizon 23 programme in terms of what did that mean for the way in 24 which we were training people and how did we encompass 25 Horizon training into what had been the previous 94 1 approach to training branch office and subpostmasters. 2 Q. We're referring there to Post Office Counters Limited 3 and focused -- when we talk about Horizon, focused on 4 what work goes on in the branches. Are you aware what 5 part of the group was responsible for the prosecutorial 6 function of the Post Office? 7 A. No. 8 Q. Were you -- as part of your remit, did you have any 9 involvement in training either investigators or 10 prosecutors? 11 A. No. 12 Q. I should add to that or auditors as well? 13 A. I don't recall any of those. I think somewhere in the 14 pack that you sent me there was a reference to auditors 15 receiving training in Horizon -- live training, you 16 know, during those training events. Other than that, 17 I don't recall, I'm afraid. 18 Q. I'd just like to bring up a document on screen. The 19 reference is NFSP00000550. This is a meeting of the 20 NFSP National Executive Council held between 19 and 21 21 October 1998. You didn't attend that but I'd like to 22 turn to page 18 and focus on the bottom. It should come 23 up on screen in front of you. It may be easier then 24 referring to the bundle. 25 A. Thank you. 95 1 Q. Thank you very much. So this is a minute, 6(a), 2 concerning human resources training for subpostmasters. 3 It says: 4 "Under this heading there were 2 specific subjects 5 related to subpostmasters' training: the Transactional 6 Knowledge Review trial which was currently underway in 7 the Midland Region, and the trial in the South East of 8 classroom style training." 9 We can skip the remainder of the paragraph, had 10 next paragraph says: 11 "Correspondence of the 3 September from Kathryn 12 Cook ..." 13 Now, I will pause there: that was your previous 14 name? 15 A. Yes. 16 Q. "Correspondence of the 3 September from Kathryn Cook 17 gave details of the current status of the trial within 18 the South East Region. She had indicated that a full 19 range of data on which the analysis of the trial would 20 be made available to the Federation." 21 Can you recall, this being October '98, what this 22 trial is referring to? 23 A. No. I can't recall it. I can try and give you a sense 24 of what I think it might have been referring to but 25 I don't know for sure. 96 1 Q. What do you think it was? 2 A. Well, there were a number of trials going on as the work 3 to develop the Horizon System was underway to sort of, 4 you know, try it out on live people, just so that you 5 can judge whether or not some of the assumptions made 6 by, you know, techy IT people actually were working in 7 the real world. 8 So I would surmise from that that we were sharing 9 with the NFSP some of the insights that we were getting 10 from those trials. 11 Q. If we could go to the next page please. Take down the 12 highlighted text and, on the next page, if you can focus 13 in on the first paragraph -- thank you. It went on to 14 say: 15 "Mr Burrows advised the Executive Council that 16 a quite separate form training was being introduced in 17 the North Thames & East Anglia Region which involved 18 classroom-style training but for a 4-week period." 19 Now, pausing there, the none of the -- it was 20 never -- a four-week period of training for Horizon was 21 never trialled; is that right? 22 A. I don't ever remember us trialling something for four 23 weeks. That would have been an incredible provision 24 even to consider, let alone to think about the logistics 25 of deploying that. 97 1 Q. So we -- knowing this four-week period scheme was being 2 trialled, does that assist you in remembering what this 3 trial may have been? 4 A. No, it doesn't. I have no recollection of us trying 5 a four-week trial. As I say, the logistical 6 implications of having a four-week trial for delivery of 7 Horizon training would seem quite a commitment. 8 Q. It goes on to say: 9 "The NC was concerned that training seemed to be 10 becoming fragmented and variations introduced on 11 a Regional basis. It was the intention to seek to 12 clarify the current situation and policy of Post Office 13 Counters towards training of subpostmasters in order 14 that the Federation could ensure that subpostmasters 15 received the proper training they required to meet their 16 responsibilities." 17 How was training organised prior to Horizon? Was 18 it on a national level or by regions? 19 A. I believe it was by regions but my memory of that is not 20 good. From recollection, I think there were training 21 teams regionally dispersed who were local to the area, 22 who would be providing training. Beyond that, I'm 23 sorry, I can't remember. 24 Q. We'll leave that there. If we can move to another 25 document it's POL00039737. I want to start talking 98 1 about what's been referred to as a Horizon training 2 competency and conformance group. Just wait for the 3 document to be loaded thank you. 4 This is a letter that appears to be in draft form. 5 It's addressed from you to Bruce McNiven dated 6 8 January 1999. There are changes in the -- handwritten 7 changes to the letter. Is that your writing? 8 A. I assume it's my writing, yes. 9 Q. It says that you had spoken to Bruce McNiven about this 10 competency. 11 A. Yes. 12 Q. How did Bruce McNiven sit in the sort of hierarchical 13 structure in comparison to you at this time? 14 A. Oh, very much senior to me. 15 Q. Did you work -- in what regard were you working with him 16 on this? 17 A. The way it worked in practice was that those who were 18 working full time on the Horizon programme would 19 sometimes come to people like me on specific items, 20 specific issues. They would ask for some input, they 21 would take it, and then do with what they felt they 22 needed to do with it. So it was more like being 23 commissioned, I suppose. 24 Q. If we could go down on the document, please, to the 25 bullet points -- thank you. In the bullet points, you 99 1 set out three things that you thought needed immediate 2 work. 3 A. Yes. 4 Q. The first one was: 5 "is the gap between the current performance and 6 the necessary levels of performance consistent (ie are 7 gaps in knowledge/performance/understanding etc, common 8 across the population -- or at least capable of being 9 clustered -- if they are then we stand a chance of 10 filling them, if not then without having individually 11 designed training interventions it's difficult to see 12 how we can do some nationally) ..." 13 So here are you looking at the gap between the 14 competence of subpostmasters pre-Horizon and the 15 competence required to operate Horizon? 16 A. I assume that's what I was talking about. It wasn't 17 just for subpostmasters, though, it was for anybody 18 working in a post office. 19 Q. Any end user? 20 A. Yes, I assume that's what I meant, yes. 21 Q. The second bullet point says: 22 "are these gaps 'trainable' (in any sense of the 23 word)." 24 A. Yes. 25 Q. What did you mean by that? 100 1 A. In -- how to put this. Some people who were required to 2 use the new system weren't happy about having to change 3 their working arrangements, so there is a sort of 4 a mindset, a sort of, you know, a personal reaction to 5 "What am I being asked to do". So what that was 6 referring to was, if somebody's reluctant to take on the 7 new knowledge, accept the new system, for example, then 8 you can't just sort of train that in to them. That's 9 a much more focused piece of change management work 10 rather than training. 11 So you know we can't win over hearts and minds 12 through training, although you know you can do a bit of 13 it, but actually the change management piece more 14 broadly is about doing that kind of thing. 15 Q. Then the third point is: 16 "what would meet this training need." 17 A. Yes. 18 Q. That's what I want to turn to now. You go on to say 19 basically that if the answer to the first two questions 20 is no, then the third bullet point doesn't apply. 21 You go on to say that: 22 "If the answer to the first two is 'yes' then we 23 can go on to specify the business impacts of trying to 24 fill these gaps (I suspect it won't cheap!) and, of 25 course of not filling them." 101 1 A. Yes. 2 Q. So at this stage, could you foresee that there was 3 a sort of training gap that the Post Office may not be 4 able to bridge or may not try to bridge? 5 A. I suppose my starting point with this particular one was 6 that -- and if I get the numbers wrong, forgive me, it's 7 a long time. I think there were over 200 transactions 8 that were being done across the counter network at this 9 point. If you were going for a training provision that 10 covered every single one of those transactions in detail 11 then, absolutely, you could come up with a gold-standard 12 training solution that would take everyone through that 13 for every single transaction. 14 The approach, though, was to say that, actually, 15 some of those transactions are done really rarely. You 16 know, people wouldn't come across them and therefore the 17 focus of the training was on the most frequently 18 required things for people to do because once you get 19 competent in doing the most frequent transactions and 20 you get confidence in using a system, that then means 21 that you have the confidence to move on to some of those 22 rarer, less frequent transactions. 23 So that was point I was making there, that, you 24 know, if the model had been "We are going to train 25 everyone on every transaction prior to going live with 102 1 Horizon", then the training solution would have to look 2 completely different. 3 Q. Did you anticipate at that stage that there may be 4 subpostmasters or end users who wouldn't be capable of 5 using Horizon, even after the training programme? 6 A. That was a concern and one of the reasons why the 7 training support was in different buckets, for want of 8 a better term. You know, so a standard training 9 provision for everyone that should get people to a level 10 of competency, plus access to post training support 11 where people were clearly struggling on particular 12 aspects, and the helpline. So the intention was by 13 mixing and matching the support for developing 14 competency you could pick up the majority of people. 15 But, yes, I remember conversations where we were 16 saying we are really concerned about particularly 17 subpostmasters or part-time counter assistants who might 18 only do limited shifts on counters picking up a very 19 different way of transacting business. 20 Q. When you say you had conversations around this, who were 21 those conversations with? 22 A. Oh, I would find it very difficult to list them but it 23 was definitely a concern in Post Office Counters at the 24 time. I would be very surprised if the people who were 25 copied into these documents weren't aware of that 103 1 concern. 2 Q. If that was a concern, what was the Post Office's plan 3 for those who weren't able to meet the competence levels 4 to operate Horizon? 5 A. During the period when I was working on this, the 6 issue -- we couldn't quantify that issue, so there was 7 a concern that was there but we didn't know and I think 8 I put this in my witness statement somewhere. Some of 9 the concerns that we identified we couldn't quantify. 10 They might not have been, in reality, things that we 11 should have been concerned about. 12 The issue is, as the data started to come through, 13 and much of that data came through after I'd moved on 14 sadly, you know that's where you start to see whether 15 there's evidence that people are struggling to use the 16 system appropriately. 17 Q. We'll come to that later on. We'll move on slightly in 18 the timeline. Please can I bring up POL00039748. This 19 is a memo that you wrote, January 1999, pulling people 20 together to work on the task that Bruce McNiven -- or 21 you discussed Bruce McNiven in the last document? 22 A. Mm-hm. 23 Q. Looking at the list of people who you have invited, 24 could you help with what areas of the business these 25 people came from? 104 1 A. As far as I can remember, absolutely. Sue Smith was one 2 of the trainers. So she was the person who provided the 3 expertise in terms of how do you do a transaction now. 4 So she was the subject matter expert in terms of this is 5 how Post Office Counters Limited does this transaction 6 and she was there because the knowledge of how things 7 were done previously obviously informs how you are going 8 to train to do them later. So she was the subject 9 matter expert. 10 I believe some of the other people in the list 11 were working for the Horizon project on a dedicated 12 basis. So I think Trevor and Clare possibly and maybe 13 Douglas. The other names, regrettably, I don't 14 remember. 15 Q. Thank you. That document can be taken down now and 16 could we please go to POL00039781. This is a letter 17 dated 19 February 1999 which you drafted following 18 an initial meeting of the group and it lists various 19 annexes, some of which we'll turn to in a moment. Right 20 at the bottom, the letter goes on to say: 21 "We agreed that we needed to get together again 22 around the middle of March to do the following", 23 essentially setting out the work the group needed to do. 24 Do you know why this work was only being carried 25 out at this stage and why it hadn't been done earlier? 105 1 A. No. 2 Q. I want to turn to annex D, which is described as "a copy 3 of our 'gap'/'vent your frustration' list". That's 4 POL00039785, here referred to as "Brainstorm of Gaps". 5 The second and the third entry on this list states: 6 "Horizon isn't delivering what they said we would. 7 "We don't have a cash account that balances." 8 Could you tell me what you are understanding of 9 those two things were at the time? 10 A. At the time this was a brainstorm of anything that could 11 go wrong, not necessarily things that had gone wrong. 12 So when I referred earlier to us not having the data to 13 know whether or not some of the issues that we feared 14 were going to happen had happened, this is why this was 15 a brainstorm of gaps. So "The Horizon isn't delivering 16 what we said we would", quite apart from being horribly, 17 grammatically incorrect, my sense of that is, you know, 18 at the time was it delivering all of the transactions we 19 were looking at? Was it covering everything that was 20 done? 21 I said in my witness statement, and I'll repeat it 22 again at this point, at no point in my involvement in 23 this did we think that the system wouldn't be working 24 correctly. That was an assumption that we made, that it 25 was going to be working perfectly. The issue for us is 106 1 that, you know, some of the clients, some of the 2 stakeholders might say, "We don't want our transactions 3 on there", for example. I think that's what that means. 4 Q. The Inquiry's heard evidence of various problems in the 5 system in '98 and '99. Is your evidence -- and just to 6 confirm that this document here, the group you were in 7 were not aware at this time of problems in balancing 8 arising from the EPOSS application? 9 A. Absolutely, we weren't aware. We took it as a matter of 10 faith that it was working because, otherwise, you 11 can't -- you can't support people with a training 12 product if, actually, you know the system isn't doing 13 what it's meant to be doing. So no. 14 Q. At the bottom, it says "Issues not resolved", and the 15 first bullet point under that is: 16 "Final C/A NR21." 17 Do you recall what that means? 18 A. I have no idea at all what that means, sorry. 19 Q. If I said could it mean "final cash account New 20 Release 2", would that ring a bell? 21 A. No. 22 Q. Please could we bring that down and turn to annex B of 23 the same letter. It's POL00039783. This lists 24 information to be shared around the group. The second 25 square bullet point says: 107 1 "Horizon database key information (from John 2 Meagher)." 3 Do you recall who John Meagher was? 4 A. I don't recall what his job was. I know he was quite 5 senior. 6 Q. He gave evidence earlier, being he served as Horizon 7 product assurance manager and then Post Office 8 acceptance manager working on the Horizon project. 9 Would you accept that? 10 A. That's right entirely possible, yes. 11 Q. It goes on to say: 12 "Regular reports on the potential risks which 13 a training solution could avert, from: Horizon service 14 reports, BA/Pathway/POCL joint meetings, Before and 15 After procedures group ..." 16 Can you recall the type of information that the 17 group was seeking from John Meagher? 18 A. Beyond what's listed there, no, I can't. I'm sorry. 19 Q. Would it be fair to say that the group was seeking 20 information on the Horizon product itself or the system 21 itself and how it was performing? 22 A. Let me read it again. I'll answer that. I don't know, 23 is the honest answer after this length of time. I'm not 24 sure. 25 Q. We'll move on to another document now. POL00039724, 108 1 please. It's an email of 23 February 1999 from Clare 2 Dryhurst to you. I think you said earlier you 3 thought -- did you say you recalled Clare -- working 4 with Clare Dryhurst? 5 A. Yes, I do, yes. 6 Q. What was your working relationship with her? 7 A. I think she must have been working on the Horizon 8 project full time but I could be wrong. I don't 9 remember well enough, I do remember her name, though. 10 Q. This email states that she was sending some documents. 11 The second paragraph refers to a report of: 12 "... I'm sending the report Glenys Davies of PA 13 and I knocked together on costs, benefits and actions 14 for non conformance." 15 The third paragraph says: 16 "I'll send you the HEB report in paper form..." 17 I want to turn to those documents now in reverse 18 order. POL00039730, please. This is a memo from Andy 19 Radka in business service management, 7 January 1999, to 20 Clare Dryhurst. It says: 21 "Find attached a copy of the HEB Consultants 22 Summary findings from the 'Right First Time' 23 initiative." 24 Do you recall receiving this report? 25 A. No, I don't. I'm sorry. 109 1 Q. The report looked at two sub post offices and four Crown 2 Office branches focusing on back office activity, such 3 as the cash account. Could I ask that we turn to 4 page 5, please, and down to "Recommendations". It says: 5 "Over the course of the two studies it has become 6 clear that although many of the risk factors leading to 7 human error have been tackled successfully somewhere 8 within the Post Office network, the organisation as 9 a whole has not been benefited as fully as it might. 10 The considerable effort expended on improving counter 11 service needs to be matched in the 'back office' by 12 standardisation of the process and minimisation of 13 associated risk factors, all taking full account of 14 'good practice'. Competence of those performing each 15 aspect of 'back office' work must be assured." 16 It then gives some specific recommendations. 17 The last paragraph says: 18 "Different versions of the 'back office process' 19 will need to be developed to accommodate differing 20 circumstances (ECCO/non-ECCO, large/small, together with 21 various mixes of business) however, the core structure 22 could be common." 23 So is it fair to say this was not looking at back 24 office processes from a Horizon perspective? 25 A. No. My reading of this document, which I only saw an 110 1 hour or so ago, was that this was talking more 2 generally, about standardising ways of working which 3 were not standard across the network previously. 4 Q. Could we turn the page, please, to the implementation 5 heading. It says: 6 "Although any of the 'good practices' could be 7 implemented in isolation and locally with some benefit, 8 that would not address cultural shift needed within POCL 9 if significant impact is to be made on the major cost 10 burden of processing errors from over 19,000 post 11 offices at Chesterfield." 12 Pausing there, at the time within Post Office, was 13 there a perceived problem with the level of cost in 14 processing errors generated from manual cash accounts? 15 A. I can't comment on that specifically because I don't 16 know how much error rectification cost at Chesterfield, 17 but I do know that there were different ways of working 18 which people had developed over time and the 19 responsibility for subpostmasters to train their counter 20 assistants meant, again, that custom and practice 21 developed both amongst the branch offices but also 22 primarily amongst sub offices, as people found ways that 23 worked for them. 24 Q. Please could we -- let's stay on that page for the 25 moment: 111 1 "In the terms of reference described above, the 2 challenge was characterised as 'making the best like the 3 rest' and the study has made it clear that there are 4 define differences between those who make errors and 5 those who do not. More work needs to be done to define 6 those differences comprehensively and precisely and then 7 build them into a process but it plainly can be done." 8 Turn the page then, please: 9 "In an increasingly volatile business environment 10 POCL will need to disseminate many changes in working 11 practices to its huge network in the years to come and 12 now is as good a time as any to review the most 13 cost-effective means by which this might be achieved. 14 To ignore recent and rapid advances in information 15 technology and distanced learning techniques would be to 16 miss an opportunity." 17 At this point, did senior management see Horizon 18 as a tool to be able to standardise back office 19 processes? 20 A. I don't know for sure but I would have thought so. 21 Q. When you say you would have thought so, why would you 22 think that? 23 A. Well, if you've got a circumstance where you are 24 spending a lot of money rectifying errors at 25 Chesterfield, as the previous document was showing, the 112 1 opportunity to have technology that eliminated some of 2 those errors would, of course, deliver you a cost 3 saving. So that would make you may think the whole 4 operation more efficient. So I could see why. 5 The other benefit that I imagine was weighing 6 heavily on people's mind was the ability to extract data 7 from the system, to be able to get reports and 8 understand without manual processes how the organisation 9 was doing. So I don't know for sure. I'd never had 10 a conversation with a senior manager about whether or 11 not that was in their mind but those are the two obvious 12 things I would think, had it been me, that they would be 13 looking for are. 14 Q. Both of those things depend on Horizon providing 15 accurate data? 16 A. Absolutely, yes. 17 Q. Can we turn to the other attachment, which was 18 POL00089738. This is the "Conformance Strand 3 Business 19 Case", dated 11 December 1998 by Clare Dryhurst and 20 Glenys Davies, a document we referred to earlier in the 21 email of 23 February, and it looks at the cost of 22 conformance and non-conformance when Horizon was 23 introduced. 24 Could we turn to page 17, please. Under the 25 heading "Impact on Transaction Processing Business 113 1 Unit", it says: 2 "Once the cash account has become automated, the 3 potential for problems will expand exponentially as 300 4 new offices are automated weekly. In brief, there is 5 a possible of many mistakes in each cash account, which 6 will result in ..." 7 We don't need to go through the whole list but it 8 includes: 9 "error rates increasing significantly ... 10 "difficulty/impossibility of reconciling 11 accounts ... 12 "unable to explain discrepancies ..." 13 It goes on to say: 14 "If the approach for the Horizon National Rollout 15 does not incorporate conformance, and we use the Lottery 16 implementation as an example, we could expect a level of 17 60% of outlets' automated cash account to be incorrect 18 with the initial month after implementation. An 19 assumption has been made that 40% of this number will 20 become proficient the following month. However, there 21 is a potential that the number of outlets becoming 22 proficient will decline due to the speed of the rollout 23 and strain on support resources." 24 It then goes on to map out a trend in the chart 25 below: 114 1 "Using the above trend for additional staff 2 required to support the ... National Rollout, the 3 potential staff costs incurred", and then that's been 4 left blank. 5 Was this common knowledge within the business at 6 the time of the potential for discrepancies and 7 potential errors in the cash account, if training wasn't 8 properly implemented? 9 A. I don't recall it but I find it inconceivable that 10 people wouldn't be concerned about it. 11 Q. Can you recall what was done to address those concerns? 12 A. I think if you -- some of the design of the training did 13 include -- the face-to-face training did include some of 14 those back office processes, some of those balancing 15 processes and then the access to the helpline and the 16 additional one-to-one support required, I think, can all 17 be targeted at that. 18 Now, the timing of the introduction of those 19 additional aspects of support, I'm afraid, is lost to me 20 after this length of time but, taken together, I would 21 have expected that would pick up quite a bit of the 22 competency gap. 23 Q. Thank you. That can be taken down. I want to now look 24 at some of the collection of feedback on the training 25 programme. Could we turn to POL00039648, please. 115 1 It's a training evaluation paper dated 2 8 July 1999. You're not in the distribution list. Had 3 you seen this document or do you recall seeing it at the 4 time? 5 A. No, I don't. 6 Q. If we could go up slightly the abstract says: 7 "This document defines the processes applicable to 8 the Peritas activities undertaken to discharge the 9 contractual responsibilities for the measurement of the 10 effectiveness of the user training programme in a manner 11 consistent with the Kirkpatrick model." 12 Do you know what the Kirkpatrick model is? 13 A. I do. 14 Q. What is it? 15 A. It's the original and still the core methodology for 16 evaluating the effectiveness of learning interventions. 17 There are many different versions out there but, if you 18 are slightly cynical, they are all Kirkpatrick in 19 a different form or another. It's the gold-standard 20 one. 21 Q. Can we turn to page 10, please, of the document and 22 under section 5.4. It says: 23 "On completion of each training event each 24 delegate is required to provide an assessment of the 25 event in a manner consistent with level 1 of the 116 1 Kirkpatrick model. Such a process is consistent with 2 which the traditional end of course appraisal process 3 used in most commercial training events." 4 If we can go over the page, please, we see there 5 these five areas that are to be tested: 6 "Achievement of course objectives. 7 "Quality of course presentation", et cetera. 8 Then below that, there are four attributes with 9 four possible ratings: excellent, good, satisfactory 10 unsatisfactory. Below that it says: 11 "The rationale which results in the additional 12 positive rating in this case 'Excellent' arises from the 13 findings of the majority research studies in that 14 delegates have a basic aversion to marking the highest 15 positive category and therefore the need for balance is 16 achieved by inclusion of the extra category." 17 In your experience, is that standard practice? 18 A. It's not unusual. I mean, can I just give you 19 a personal view about level 1 Kirkpatrick? They are 20 referred to in the learning industry as "happy sheets", 21 you know, was the delegate happy with what was provided 22 to them? The reason -- you know, it's very easy to 23 collect the data but reason why you should always treat 24 happy sheets with caution is that, generally, at the end 25 of a training event when delegates have had the 117 1 opportunity to get to know the trainer and feel 2 comfortable, you may think that they tend to mark 3 relatively well. 4 The value of the Kirkpatrick model comes from 5 looking at evaluation at all levels, not just the easy 6 happy sheet piece, because that is data that you can -- 7 you can get a snapshot but it doesn't tell you anything 8 about the willingness, ability and capability of someone 9 to do it when they return to their office, which is why 10 there are up the levels of evaluation which are -- shall 11 we say, probably have equal, if not more, importance 12 than the level 1 evaluation that we're talking here. 13 Q. So is level 2 competency test immediately after at the 14 training site? 15 A. Level 2 is the competency test immediately afterwards 16 and the level 3 is the ability to do it once you are in 17 the real world. Level 4 would then look at whether or 18 not all of the aims and intentions of whatever change 19 programme you're talking have been delivered. 20 Level 4 is relatively rarely used but, actually, 21 is really important because that gives you the feel over 22 time whether or not actually whatever it is you're 23 training for has had the impact that you were looking 24 for. So with a big programme like this, although I know 25 this document does suggest that level 4 is very complex, 118 1 it surprised me when I read it just now that there 2 wasn't a level 4 of any description involved with this 3 piece of investment. 4 Q. Let's get a look at some of the feedback which we can do 5 before the break? Can I bring up POL00039733. This is 6 a fax from Alan Bourne to you dated 30 March 1999. On 7 page 3 we can see that it is a report from Kevin 8 Fletcher on New Release 2 training practice events. If 9 you could turn to page 5, it says: 10 "ICL Training Services were requested by 11 Pathway/POCL to provide trainers for a series of courses 12 for Counter Assistants and Counter Managers on the 13 Horizon System. The delegates on the courses were 14 volunteers from POCL." 15 Do you remember who commissioned this research? 16 A. I'm sorry, I don't. 17 Q. Kevin Fletcher gave evidence to the Inquiry on Tuesday 18 and he suggested that the volunteers would have been 19 selected by the Post Office. Would you agree with that? 20 A. I don't know. I don't know how they went about finding 21 volunteers, so I can't comment. 22 Q. I'm not going to go through all of the form but if we 23 could just turn to page 7, please, we see that this is 24 for the Bristol counter managers, two unsatisfactory 25 scores. In the comments below there's: 119 1 "More time required (several comments) ... 2 "Too much information compressed into course." 3 I'm not going through all of them, just selecting 4 some: 5 "Good trainer not enough time allowed." 6 Over the page, with the Bristol counter manager's 7 course one unsatisfactory. Selecting some of the 8 remarks: 9 "I will need extra training. 10 "More time on balancing -- error notices ... 11 "Second day should be expanded to full day -- 12 especially for delegates who have no experience of 13 automated systems ... 14 "More time needed, setting up users -- allocating 15 users. 16 "Course definitely requires two full days second 17 day is six hours with no lunch break. I feel the course 18 is unsatisfactory because it is very intensive and 19 coverage of important tasks ie balancing is rushed as 20 a result. Bearing in mind a subpostmaster could be 21 asked to do their first balance unsupervised." 22 If we could skip, please, to 17, at the bottom the 23 Tunbridge Wells Counter Assistants, no unsatisfactory 24 scores, and then over the page we have: 25 "Balancing (two [persons]) (like to add) ... 120 1 "Could always have more time ... 2 "Error adjustments ... 3 "Only satisfactory -- because for my role as 4 an auditor I need to cover the balancing aspect of the 5 system. 6 "Stock and office balancing (like to add) ..." 7 It's fair to say from those the theme that came 8 across was that people wanted from this more time on 9 balancing and more time generally; is that fair? 10 A. Yes. 11 Q. Also, you referred to these as "happy sheets". There is 12 a low number of unsatisfactory scores there. Do you 13 think it's fair to say that some of the comments made 14 did make substantive criticism of the course? 15 A. I don't know if the word "criticism" is right. 16 Improvement opportunities, certainly. Although, you 17 know, yes, maybe "criticism" is the right word. Maybe 18 "criticism" is the right word. But there's a disconnect 19 between the scores people give and the comments that 20 they have made and I think that points danger of relying 21 on happy sheets alone. 22 Q. As in, as the course is progressing, one should look the 23 comments? 24 A. You should always look that comments, yes. 25 MR STEVENS: Sir, that might be a good time to take a short 121 1 break if that is okay with you. I think you are on 2 mute, sir. 3 SIR WYN WILLIAMS: Sorry. Could you just give me some 4 indication of how much longer the evidence is likely to 5 take. 6 MR STEVENS: I anticipate another half-an-hour. 7 SIR WYN WILLIAMS: All right, fine. So what's the time now? 8 MR STEVENS: It's just past 2.25. 9 SIR WYN WILLIAMS: 2.35, yes? 10 MR STEVENS: That works, sir. Thank you. 11 SIR WYN WILLIAMS: Fine. 12 (2.28 pm) 13 (A short break) 14 (2.35 pm) 15 MR STEVENS: Please we bring up POL00039735. This is from 16 you to Bruce McNiven on 9 April 1999 and it's titled 17 "Horizon Training: Competency", and it encloses your 18 Horizon competency report which starts at page 3. 19 Actually, stay there. Thank you. 20 In your introduction, you say, five or six lines 21 down: 22 "The recent review of TK and its reallocation of 23 training time towards improving the performance of 24 'poor' offices has gone some way to enabling us 25 positively to affect competence after recruitment but 122 1 there is still some way to go (and this is something 2 that the Network Team will be looking and in 1999/2000." 3 The reference to poor offices, what did that mean? 4 A. I don't remember exactly. I can surmise that that was 5 talking about offices that had more errors than other 6 offices. 7 Q. Was there ever a process of performance management for 8 offices that generated high levels of errors prior to 9 Horizon? 10 A. Not that we looked at nationally but what were they 11 called? There was a post in the regions, retail network 12 manager, something like that, it was called and they 13 were responsible for managing networks of post offices 14 in particular geographical areas. I think they had the 15 responsibility for, you know, working with post offices 16 that were not achieving the kind of levels of competency 17 that others were as a sort of, you know, business as 18 usual kind of management piece. 19 Q. Can we take it from this, and the other documents we've 20 read, was the Post Office interested in this stage at, 21 on a national level, looking at performance management 22 of its various subpostmasters' branches? 23 A. I don't recall that it was at this point in time. 24 I think that was one of the benefits of -- or the 25 perceived benefits of moving to Horizon, which was that 123 1 you would get the data out that would enable you to spot 2 where performance was lower, without having to go 3 through a lot of, you know, analysis of separate 4 documents that were coming in to Chesterfield, probably. 5 Q. So, at the time, Horizon, one of the -- it was 6 perceived -- 7 A. Yes, I believe so. I couldn't point you at a document 8 that said that. 9 Q. But your understanding from working there is that 10 Horizon was -- one of the advantages of Horizon is it 11 would give you the data -- 12 A. Yes. 13 Q. -- to pinpoint poor performing -- 14 A. Well, it would give you the data do pinpoint what was 15 happening in the network, you know. So whilst you could 16 look at poor performing, you could also look and high 17 performing and say, you know, why is this office 18 particularly high performing? It would let you look at 19 individual transactions and see whether or not there are 20 errors across the piece or whether there were errors 21 related to specific products or specific things that 22 anyone working in a post office needed to do. 23 So the data would allow you to cut and slice and 24 dice all of that to work out how effective performance 25 was. 124 1 Q. That recollection is that just a general or do you have 2 any specific recollection of discussing that with 3 a member of more senior management? 4 A. I have no recollection of discussing that but I do, even 5 after this passage of time find it pretty inconceivable 6 that that wouldn't have been a benefit of the Horizon 7 System. 8 Q. You say you go on to say about a definition of 9 competency and, if we could turn, please, to page 11, we 10 have annex A which is a competency statement, so what 11 group had set out as its definition of competency, and 12 on the left there is competency now and on the right 13 competency post Horizon. 14 Do you recall what was done with this competency 15 statement in the group or within Post Office Counters? 16 A. I'm sorry, I don't, no. 17 Q. If we can turn the page, please, at the top there is 18 "Balance Stock Unit" and, in the left-hand column, 19 "Now", that's now section, pre-Horizon, it says the 20 various things to do include "identify discrepancies". 21 In the column on the right, it says yes to all of those 22 points, so that will continue. But relation to 23 "identify discrepancies", it says: 24 "Yes, system does this, based on what user has 25 entered." 125 1 Then: 2 "Additional Horizon requirements: 3 "need to understand what a stock unit is and 4 understand the whole process using Horizon eg including 5 balancing periods." 6 Now, at this point -- so the point of the system 7 does this based on what the user has entered -- did the 8 competency group or the group that drafted this consider 9 what a postmaster may need to do or may need to know to 10 identify the cause of a discrepancy? 11 A. I don't remember that. I would have thought so but 12 I cannot say that I can remember that specific issue, 13 no. 14 Q. At this stage, would you -- do you think the group would 15 have considered whether a subpostmaster needed to be 16 able to determine whether a discrepancy was caused by 17 the Horizon IT System itself? 18 A. If they were looking at it in the way that we were 19 looking at it I think they would have assumed that the 20 system would have worked so they wouldn't need to 21 consider it was the system that was wrong. I would 22 imagine they were thinking what have I done, using the 23 system for it to come out wrong, but I can't speak for 24 everybody who was using the system. All I know is we 25 believed the system did what the system needed to do 126 1 100 per cent of the time. So therefore, if there was 2 a discrepancy, you would expect the subpostmaster or the 3 counter assistant, or whoever it was using the system, 4 to try and track back and work out "Have I put the wrong 5 figure in, have I done X, Y or Z", to work out what was 6 the cause. 7 Q. If we go down just slightly to when it all goes wrong on 8 the left, it's: 9 "Manual procedures (if ECCO) if equipment fails." 10 Then on the right: 11 "Yes, need to know what to do if equipment fails, 12 how to recover transactions (fallback and recovery 13 procedures); manually balance?; revert to manual 14 transactions?" 15 I take it from your evidence just now that's 16 referring to when the computer simply wouldn't work 17 rather than discrepancy? 18 A. Yes, that would be disaster recovery in the event that 19 you lost your electricity or you had a fire or, you 20 know, whatever it would be, yes. 21 Q. Can we turn, please, to page 7 of this document, 22 paragraph 8. This is where you made various suggestions 23 to the group makes various suggestions about what to do 24 with the findings, which we don't need to go through in 25 detail. The second sentence says -- it talks the 127 1 competency gap, and then it says: 2 "It could be thought that one of the things that 3 the data collected is telling us that although there was 4 a pre-course competency of only 79%, the fact that only 5 3 people would have failed the Horizon training (2.37%) 6 could be taken as an encouraging sign that a lack of 7 competency currently would not be an inhibitor to using 8 the Horizon system. There may however be other 9 explanations eg that the Horizon competency test is 'too 10 easy' or that isn't predictive of live operation 11 (eg that it's measuring the wrong things)." 12 Which of those three options did you think was the 13 real cause at the time? 14 A. I don't know. My take on each of those three right now, 15 if you look at the first one, the reference to a lack of 16 competency currently not being an inhibitor to using the 17 Horizon System, if technology is intuitive it can 18 eliminate errors because, you know, it gives you the 19 options and choices that sort of eliminate errors. So 20 my assumption is that that first one is saying that, you 21 know, the system itself could be helpful in the event 22 that people were not as rock solid as they could have 23 been in terms of the process or the detail. 24 The Horizon competency test being too easy, well, 25 this is where we launch back into the Kirkpatrick data 128 1 thing because this is where Kirkpatrick level 3 data 2 would give you some of the information that you would 3 need to know in order to say whether the competency test 4 was too easy. So that's where the level 3 data really 5 does help you and the level 4 data if you're doing that 6 would help you to know whether that was the case. 7 The predictive of live operation, I think, is the 8 least likely of the three to have been the key one. 9 Q. Do you have any recollection of anything being done to 10 test which of those three was correct? 11 A. I can't remember if there was, no, I'm sorry. 12 Q. Thank you that document can come down now. The 13 Inquiry's heard evidence about the process by which Post 14 Office and ICL Pathway settled disagreements over 15 whether or not this system matched the contractual 16 specification, and one of those disagreements was called 17 Acceptance Incident 218, which we've heard evidence that 18 it concerned the training course, in particular the 19 balancing aspect of it. 20 Were you consulted or in any way involved in the 21 acceptance process? 22 A. No. 23 Q. As a result of that, there was a second -- I say as 24 a result of the acceptance process, a second 25 supplemental agreement to the overall contractual 129 1 agreement was drawn up. Please could we bring that up 2 at POL00090428, and turn to page 64, please. 3 Sorry, it's 65. My apologies. 4 If we could highlight the "Post Installation 5 Competency Strategy", this states: 6 "The joint workshop on 13 August accepted that not 7 all users within the large population will 'absorb' 8 Horizon. This may eventually call for closure of the 9 outlet, replacement of the subpostmaster or training of 10 additional staff. It has been agreed between POCL and 11 ICL Pathway that other steps taken within this 12 resolution plan should minimise the risk of this and 13 that any residual fallout will be handled by POCL. POCL 14 have agreed to review and strengthen the relevant 15 process. This is reflected in the timetable." 16 This agreement, were you ever aware of it? 17 A. I don't remember seeing any or hardly any of the 18 commercial, in-confidence documents that were in the 19 second bundle that was sent to me, so I don't recall 20 ever having a discussion of having that shared with me 21 at the time. 22 Q. This concept, though, that there may be some 23 subpostmasters or end users who wouldn't absorb Horizon, 24 were you aware that that had been accepted? 25 A. I think there was -- I think I was aware of that, yes, 130 1 that there was a belief that there would be a very small 2 number of subpostmasters for whom this simply wasn't 3 going to work. There was particular concern about very 4 elderly subpostmasters who had very limited exposure to 5 technology and that, for some of them, they would choose 6 or they would not be in a position to use it 7 effectively. 8 Q. What extra steps did Post Office Counters take to try to 9 avoid the options of closure of the outlet or 10 replacement of the subpostmaster? 11 A. I can't answer you definitively because I can't line up 12 all the documents in the right timeline but my 13 assumption would be that this was where the provision of 14 additional support to subpostmasters, after the standard 15 training and the use of the helpline, came in. Whether 16 that is actually the case and whether there was 17 something else, I'm sorry, I can't recall, but that's my 18 assumption. 19 Q. So there's the Horizon training programme and then, once 20 that's complete, anything further is the helpline or the 21 additional training. Is that through the Horizon Field 22 Support Offices? 23 A. Well, either the Horizon Field Support Officers or the 24 POCL trainers because I'm pretty certain they got 25 involved post implementation as well. With an office 131 1 that's struggling, you know, it's inevitable that you 2 would try and provide that support first before saying 3 "This is grounds for terminating a contract". 4 Q. Please could we bring up the POL00089738. It's the 5 "Conformance Strand 3 Business Case" document again. So 6 it's POL00089738. Thank you. 7 We went to this document earlier. Can we turn to 8 page 14, please, down to "Supporting non competent 9 outlets". It says: 10 "The current training programme focuses on the 11 Horizon operational aspects, without ensuring that the 12 POCL processes and best practices are included. Also, 13 there is an assumption that all personnel have similar 14 base skills of working with the technology. This 15 approach to training will have a more dramatic effect 16 with the new release of Horizon as this version of the 17 software includes the reconciliation processes. These 18 processes require the POCL perspective to ensure that 19 the daily and weekly reconciliation are [complete] 20 (sic)." 21 It refers to competency testing and says, at the 22 bottom of that paragraph: 23 "Therefore there is a potential that additional 24 resource will be required to give remedial support to 25 these non competent outlets. This remedial support will 132 1 include: 2 "performing supplementary training to outlets, 3 part or all outlet personnel. 4 "assisting outlets/personnel meet the defined 5 competency criteria. 6 "This activity does not currently have an obvious 7 owner, ie implementation or operational." 8 Can you recall if or when an owner of that 9 additional remedial training was found? 10 A. I don't. I mean, this document pre-dates my involvement 11 with the training provision for Horizon. So I'm not 12 sure that I'd ever seen it before it was sent to me. 13 Yes, I can't shine any more light on that one, 14 unfortunately. 15 Q. It goes on to say at the bottom: 16 "By November 1999, the number of non-competent 17 outlets will have exceeded 1,200 that require additional 18 support above and beyond the operational support 19 provided by the Business Support Centre. At this point 20 in the rollout programme, the support services will be 21 at breaking point due to the speed of the roll out, 22 ie a further 1,200 outlets per month. At this point the 23 number of outlets becoming competent will increase with 24 the result that the need for additional support will 25 spiral upwards." 133 1 Can you recall any additional resources being 2 brought in to provide this remedial training or further 3 training that was required? 4 A. I don't recall any additional resources coming in. No, 5 I -- 6 Q. In your -- 7 A. It's not to say that they didn't; I just don't recall. 8 Q. You said in your evidence, as you say, these two things: 9 the one-on-one support, training support measures and 10 helpline support. That document can come down, thank 11 you. In Phase 1 of the Inquiry, many subpostmasters 12 gave evidence saying that they'd made requests for 13 a further training which weren't fulfilled. 14 When you say that you understood that there were 15 one-on-one measures in place, what's the basis for that 16 understanding? Was that checked by you, that the 17 resource was actually available when required by 18 subpostmasters? 19 A. I don't know is the honest answer. The organisation had 20 trainers embedded in regions who were there to provide 21 support to people. So I would have -- you know, my 22 rationale is that that resource, as well as the Horizon 23 trainers, would be there and available to provide that 24 support. But no, I don't know. 25 Q. I want to just cover a last topic. One thing we've 134 1 spoken about is using Horizon to drive conformance and 2 back-end conformance. When Horizon was initially rolled 3 out, subpostmasters were able to post discrepancies to 4 a local suspense account so that it could be held there 5 and then, when they rolled over to continue trading, the 6 cause of the discrepancy could be dealt with on another 7 day. Do you recall that? 8 A. No, I never had that level of knowledge about how the 9 transactions worked. That's why others on the team were 10 there. You know, so I wasn't counter trained, which was 11 the phrased used for, you now, people becoming competent 12 in terms of how transactions are done, how 13 reconciliations was done and how balancing was done. So 14 that wasn't something that I was competent in, which is 15 why there were others on the team who were able to do 16 that. 17 The differences between how Horizon did it and how 18 it was done before, that will be down to the Horizon 19 team to actually define how the process had changed. So 20 I can't help you with that one. 21 Q. We discussed how one of the hopes for Horizon, or you 22 said one of the thoughts it may be able to do, is 23 provide data to establish well performing offices and 24 poorly performing offices. When you remained at Post 25 Office following Horizon's rollout, did that come to 135 1 fruition? Did you see that data being used to target 2 poor performing offices? 3 A. Yes, I left Post Office Limited in 2001; so I had no 4 involvement beyond 2001. I would have expected that 5 data should be collected because, you know, if we 6 boringly go back to Kirkpatrick, that's your level 4 7 evaluation data that's tells you whether or not it was 8 working as had been intended. So that, for me, would 9 have been the data that would have proved or otherwise 10 how it was going. 11 Q. As part of -- because you were involved in the work on 12 conformance -- 13 A. Mm-hm. 14 Q. -- a decision that was later made in respect of Horizon 15 was to take away a subpostmaster's ability to put 16 discrepancies into this suspense account and effectively 17 the subpostmaster would have to, to continue trading, 18 accept the discrepancy that Horizon said was there. 19 Were you aware of that decision? 20 A. No. 21 Q. That wasn't linked -- that wasn't discussed as part of 22 the conformance project? 23 A. No, I don't remember that coming up at all. 24 Q. Could we please bring up your witness statement, which 25 is WITN6050100, page 8, paragraph 10, please. You are 136 1 reflecting on matters with hindsight and you say: 2 "Given the passage of time and the issue which the 3 Inquiry is now looking at, I wonder, however, if there 4 should have been a change to the pacing and phasing of 5 rollout. Although the approach to training, design and 6 competency felt proportionate at the time, it may be the 7 case that training duration should have been looked at 8 in the light of data coming back from the competency 9 testing process and other measures of effectiveness." 10 Can you just set out your recollection of what 11 data was coming back from the competency testing 12 processes. 13 A. Other than the documents that you've been able to share 14 in the bundles with me, I don't recall the specifics in 15 terms of the data that was coming back. Data must have 16 been coming back. You know, I'm not saying it didn't; 17 I just don't have access to what that was and after this 18 length of time, I'm sorry, I really can't recall which 19 data it was. 20 Q. During all this time, you've said it a couple of times 21 in your evidence, that you were working on the basis 22 that Horizon would work and it would produce reliable 23 data. If you were told that that wasn't the case and 24 that there were significant concerns as to Horizon's 25 ability to balance or produce accurate data, would you 137 1 have done anything different? 2 A. I think we would have looked at the design of the 3 training and the duration of the training and the 4 support that was provided because, if you can't rely on 5 the system to do what -- in ridiculously simple terms to 6 do the adding up for you, then you've got to find a way 7 of making that happen. So had it been known that the 8 system -- that there might have been issues with the 9 system, then you would absolutely have gone back to 10 first principles and said, "Well, what is the 11 expectation of competency for anyone using the system? 12 Do they need to be able to do this sort of 13 reconciliation of errors? Do they need to be able to 14 work out what's gone wrong and where and put that 15 right?" 16 But as I said, as I've said in the statement and 17 I've said a couple of times today, you know, the belief 18 was that the system was working as it was meant to work 19 and that therefore the training was there to help people 20 to use it, not to put right any errors that were not the 21 cause -- were not caused by the person using the system, 22 if that makes sense. 23 Q. Do you think you should have been told about the 24 problems that were evident within the Horizon System at 25 the time? 138 1 A. Yes, yes. 2 Q. Before I close, is there anything else you would like to 3 say either to the Chair or generally on this matter? 4 A. I'd like to apologise that my recollection isn't as good 5 as it could have been given the passage of time. I have 6 tried to be straightforward and truthful all the way 7 through. If I have forgotten something, my apologies, 8 but I've done my best. 9 MR STEVENS: Thank you, sir. I have no further questions 10 I'll just see around the room if there's ... no, no 11 questions from recognised legal representatives. 12 SIR WYN WILLIAMS: Well, thank you very much, Ms Parker, for 13 coming to give evidence. I don't think I'm saying 14 anything which is controversial by saying that people 15 trying to recollect events 21 or 22 years previously are 16 going to find it very difficult. So I completely 17 understand what you have to say about that. 18 A. Thank you. 19 SIR WYN WILLIAMS: So is that it for today, Mr Stevens? 20 MR STEVENS: Yes, sir, we're back on Tuesday at 10.00 for 21 Sandra McBride. Sir, I didn't know if you wanted to say 22 something about next week's timetable. 23 SIR WYN WILLIAMS: Only in the sense that I think everyone 24 should keep a keen eye on the Inquiry website because 25 I think there is a degree of uncertainty as to who might 139 1 be called next week, for reasons which I needn't explain 2 at the moment, but everybody who's following should, as 3 I say, look that website from time to time to see when 4 the Inquiry will be sitting and who will be giving 5 evidence before the Inquiry when it is sitting. 6 MR STEVENS: Thank you, sir. 7 SIR WYN WILLIAMS: Thank you, Mr Stevens. 8 MR STEVENS: Thank you, sir. 9 (3.04 pm) 10 (Adjourned until Tuesday, 17 January at 10.00 am) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 140 1 I N D E X 2 CHRISTOPHER GILDING (affirmed) ...................1 3 Questioned by MR BEER ............................1 4 Questioned by MR JACOBS .........................68 5 Questioned by MS PAGE ...........................77 6 Questioned by MS PATRICK ........................78 7 Questioned by SIR WYN WILLIAMS ..................89 8 KATHRYN PARKER (sworn) ..........................91 9 Questioned by MR STEVENS ........................91 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 141